nerc standards cny engineering expo · nerc standards cny engineering expo herb schrayshuen vp and...

NERC Standards CNY Engineering Expo Herb Schrayshuen

VP and Director Reliability Assessment and Performance

Analysis

October 23, 2012

2 RELIABILITY | ACCOUNTABILITY

Learning Objectives

• Understanding NERC and the purpose of the Standards Process

• Review of the structure of the stakeholder process and NERC governance

• Understanding of the standards development process

• Briefing on a few of the upcoming issues

NERC Overview

What is NERC’s Role in the Industry?

• Mission: Ensure the reliability of the North American bulk power system by:

Holding entities accountable for compliance with mandatory reliability standards

Acting as a catalyst for positive change within the industry

Defining Reliability

• NERC defines a reliable bulk power system as one that is able to meet the electricity needs of end-use customers even when unexpected equipment failures reduce the amount of available electricity

• This means:

Adequacy – sufficient resources

Security – ability of system to withstand sudden and unexpected disturbances

Reliability History: Key Dates

November 9, 1965 - Northeast Blackout

1968: National Electric Reliability Council (NERC) established by the electric industry

2002: NERC operating policy and planning standards became mandatory and enforceable in Ontario, Canada

August 14, 2003 - Blackout

2005: U.S. Energy Policy Act of 2005 creates the Electric Reliability Organization (ERO)

2006: Federal Energy Regulatory Commission (FERC) certified NERC as the ERO; Memorandum of Understanding (MOUs) with some Canadian Provinces

2007: North American Electric Reliability Council became the North American Electric Reliability Corporation (NERC); FERC issued Order 693 approving 83 of 107 proposed reliability standards; became mandatory and enforceable

What Does it Mean to be the ERO?

• Only one ERO, overseen by U.S. and Canadian regulatory authorities (FERC and the provinces)

Responsible for developing/enforcing reliability standards

Independent of owners, operators, users

Adhere to rules governing standards development, compliance enforcement, budgeting

What Does NERC Do?

• Develops and enforces reliability standards

• Monitors the bulk power system

• Assesses adequacy

• Audits owners, operators, and users for preparedness

• Educates and trains industry personnel

NERC’s Board of Trustees

J. Schori F. Gorbet D. Goulding

J. Anderson P. Barber

R. Thilly K. Peterson

T. Berry V. Bailey J. Case G. Cauley

B. Scherr

NERC Membership

• Open to all entities interested in the bulk power system

• Twelve membership categories:

Investor-owned utility

State or municipal utility

Cooperative utility

Federal or provincial utility/power marketing administrator

Transmission dependent utility

NERC Membership

• More membership categories:

Merchant electricity generator

Electricity marketer

Large end-use electricity customer

Small end-use electricity customer

Independent system operator/regional transmission organization

Regional Entity

Government representative

Relationship of NERC Members to Board of Trustees

NERC Regions

• Florida Reliability Coordinating Council

Western Electricity Coordinating Council

Texas Reliability Entity

Southwest Power Pool RE

Florida Reliability Coordinating Council

SERC Reliability Corporation

ReliabilityFirst Organization

Northeast Power Coordinating Council

Midwest Reliability Organization

Eight NERC Regions

• Perform delegated functions:

Compliance

Regional standards

Organization registration

Reliability assessments

• Regional consistency key for transparency, predictability and uniform outcomes

NERC Standards

Stakeholder Accountability

• Standard development process depends on active participation of stakeholders

• Stakeholder technical expertise is essential to standard development process

• Order 672: Commission must give “due weight to technical expertise of ERO”

NERC’s Standards Process

• In 2010, a new process was developed with input from the Standards Committee, the Results-Based Standards Ad Hoc team, stakeholders, and regulators

• FERC approved the new Standard Processes Manual on September 3, 2010

• Goals:

Improve efficiency

Improve quality

Preserve American National Standards Institute (ANSI) accreditation

• Recently, there has been acknowledgement that even more can be done

Roles and Responsibilities

Standards Committee

Stakeholders Drafting Teams

Ballot Pools

Board of Trustees

TOW RTO

Gov’t

SEU Regulators

Standards Staff

Ballot Body

Standards Committee

• Prioritizes standards development activities

• Reviews actions to ensure the standards development process is followed

• Reviews and authorizes Standard Authorization Requests (SARs)

• Manages progress of SARs and standards development efforts

• Reviews and authorizes drafting new or revised standards and their supporting documents

• Makes appointments to drafting teams

Draft Standard

Collect Informal Feedback

Post for Comment

Post for Recirculation

Ballot

Board Adopts

Implement

Appoint DT

Authorize Posting SAR

Regulatory Agencies Approve

Submit Standard for

QR Revise

Consider/ Respond/Revise

Revise

Submit Standard for

QR Revise

Post for Comment/

Ballot

Consider/ Respond/Revise

Every valid SAR is accepted.

SARs need a technical basis and are posted based on

priority.

1. Add to list of projects 2. Assign a priority 3. Determine when to post

Technical Basis?

Wait for Study

No Yes

Roles and Responsibilities of Drafting Teams

• Develop an excellent, technically correct standard that helps provide an adequate level of bulk power system reliability and achieves stakeholder consensus

Stay within the scope of the SAR

Address regulatory directives and stakeholder issues

Ensure standard meets criteria for approval

• Develop initial set of Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs) and associated reasoning

• Produce a realistic implementation plan

• Develop supporting documents (optional)

Drafting Team Formation and Support

• If a team is formed to address the SAR, the same team develops the standard

• Includes a technical writer, if needed

• Technical experts provide content for requirements

• Technical writer drafts language for technical experts

• Technical experts have “power of veto”

Stakeholder Consensus Process

Informal Feedback

Post Standard for Comment

Consider/Respond to Comments

Post Standard for Comment/Ballot

Recirculation Ballot

New/Successive Ballot:

At this step, the standard is either “new” or significantly changed from the last version posted for comment/ ballot. The ballot record starts with no votes and no comments.

Recirculation Ballot:

At this step, there have been no significant changes to the standard from the last ballot. The ballot record starts with all votes and comments from the previous ballot.

New/Successive Ballot: At this step, the standard is either “new” or significantly changed from the last version posted for comment/ ballot. The ballot record starts with no votes and no comments.

Recirculation Ballot: At this step, there have been no significant changes to the standard from the last ballot. The ballot record starts with all votes and comments from the previous ballot.

Informal Feedback

Building Consensus with Comments

• Stakeholder feedback is essential

• The best comments offer suggested replacement language first and then support that suggested language with rationale

• If a stakeholder cannot suggest alternate language, he or she should still make sure to support his or her claim with sound technical rationale

Sample Comments

• In Attachments 1, 2, and 3 the six-month requirement for notice is too short in many cases. We suggest nine months to one year. Six months is not enough time for budgeting and construction scheduling

• The Generator Owner (GO) appears to be the logical choice. Generator Owner has the access to the equipment records, Generator Operator may not.

Sample Comments

• Disagree with R2 as written

• Disagree with assigning requirement to the GO

• Definition is a little loose

Drafting Team Responses to Comments

Navigating a Comment Report

If time is limited:

• Read the first section

• For each question, read the Summary Response

• Find responses to your comments

If time is not limited:

• Read the entire report

Navigating a Comment Report

Sections of Comment Report:

• Executive Overview (what was posted when; who commented; what was changed and why; unresolved minority issues; link to unformatted comments; reminder of appeals process)

• Index to questions

• List of commenters

• Questions and responses

Emphasis on Quality Before Posting Final Drafts

Quality review required before “final” draft posted.

Results of review sent to Standards Committee and drafting team.

Working Draft of

Standard

Final Draft

Informal Feedback

• Balloter accountability

Review changes made to the standard

Review unresolved minority issues

Last chance to see if you should change your vote

FERC’s Approval Process for Standards

Standard and Tech Details

NOPR Order FERC

Analysis FERC

Analysis

Where We Are Now

• Standard Process Input Group (SPIG)

Formed by Member Representatives Committee in February 2012 to recommend improvements to standards development process

• Additional Standard Processes Manual (SPM) changes in progress:

Changes to requirements for comment periods

Removal of measures from standards

Waiver to allow deviation from SPM in extreme cases

Changes to handling of ‘no’ votes

Clarification on handling of interpretations

Current Issues

• Definition of the Bulk Electric System

• Adequate Level of Reliability

• Frequency Response Initiative

• Transmission Planning Standards-Footnote b

• Revisiting the standards process to improve efficiency and throughput

• Cold Weather Readiness

Questions?

nerc standards cny engineering expo · nerc standards cny engineering expo herb schrayshuen vp and...

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