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Welcome!NERC 2015 Standards and Compliance Fall WorkshopThe Westin San Diego, CA

October 20-22, 2015

RELIABILITY | ACCOUNTABILITY2

• 8:45–9:15 a.m.: Compliance Guidance Patti Metro

• 9:15–9:45 a.m.: Risk-Based Registration Val Agnew

• 9:45–10:15 a.m.: Compliance/Standards Engagement Steven Noess Howard Gugel

• 10:15–10:30 a.m.: Break• 10:30–11:30 a.m.: NERC Standards Development Update Howard Gugel Ryan Stewart Elsa Prince Sean Cavote

Today’s Agenda


• 11:30–11:50 a.m.: Standards Information Barb Nutter

• 11:50–Noon: Project Management & Oversight Subcommittee (PMOS) Update Brenda Hampton Ryan Stewart

• Noon–1:00 p.m.: Lunch• 1:00–1:30 p.m.: North American Generator Forum (NAGF) Brenda Hampton

• 1:30–2:00 p.m.: North American Transmission Forum (NATF) Roman Carter

Today’s Agenda


• 2:00–2:30 p.m.: Quality Review Training Sean Cavote

• 2:30–3:00 p.m.: Break• 3:00–4:00 p.m.: NERC Standards Update Howard Gugel Ryan Stewart

• 4:00–4:30 p.m.: Interpretations Ryan Stewart

• 4:30–4:45 p.m.: Miscellaneous Q&A NERC Staff

• 4:45–5:00 p.m.: Closing Announcements NERC Staff

Today’s Agenda

Compliance Guidance PolicyPatti Metro, Manager, Transmission & Reliability StandardsNational Rural Electric Cooperative Association (NRECA)Standards and Compliance WorkshopOctober 21, 2015


• Purpose of the policy paper Develop approaches useful in providing guidance for implementing

standards

• May 2015: compliance guidance team (Team) formed Clarify the role, purpose, development, use, and maintenance of

compliance guidance Reduce controversial approaches to provide guidance Provide additional clarity on implementation of standards

Background


Compliance Guidance Team

• NERC executives and Board of Trustees (Board) members Ken Peterson Doug Jaeger Janice Case Mark Lauby

• Regional Entity Leadership Dan Skaar

• Leadership Sylvain Clermont Valerie Agnew Kristin Iwanechko

• Team Members Nabil Hitti Tony Montoya Tom Bowe Nelson Peeler Carol Chinn Jason Marshall Brian Murphy Patti Metro Steve Noess Sonia Mendonca


1. Guidance cannot change the scope of a Reliability Standard2. Contents of guidance are not the only way to comply with a

standard3. Clear compliance expectations during standards development

should minimize need for guidance after regulatory approval4. Forms of guidance should not conflict5. Guidance should be developed collaboratively and posted for

transparency

Principles


• Should be a finite and limited set of guidance tools• All forms of guidance related to the same standard should be

coordinated and collected in one location• To the extent guidance does not address all issues that arise,

consideration should be given to revising the standard• NERC and the Regional Entities (ERO Enterprise) will exercise

professional judgement and maintain processes to ensure its independence

• There are other methods for addressing risks not subject to a standard (i.e., feedback loops)

Additional Considerations


• Implementation Guidance Examples for implementing a standard

• CMEP Practice Guides Provides direction to ERO Enterprise compliance monitoring and

enforcement program (CMEP) staff on approaches to carry out compliance and enforcement activities

Proposed Types of Guidance


• Led and developed by industry experts• Does not prescribe the only approach• Endorsed for deference by ERO Enterprise

Implementation Guidance


• Endorsement ERO Enterprise CMEP staff will give the examples deference when

conducting compliance monitoring activities

• Deference Registered entities may rely upon the example with reasonable assurance

that guidance meets compliance requirements Compliance determinations depend on facts, circumstances, and system

configurations Following guidance alone is not a guarantee to meet compliance

Endorsement and Deference


• Initiation and Vetting Standard drafting team (during standards development) Through a pre-qualified organization (after final ballot)

• Submitted to a NERC email after being vetted• Example is posted to a central location on NERC’s website for

transparency

Implementation Guidance Development


• ERO Enterprise considers guidance for endorsement NERC facilitates resolution of any open questions Subject to technical soundness and compatibility with the standard

language ERO Enterprise leadership will ensure consensus among Regional Entities

• If endorsed, move to one-stop shop ERO Enterprise leadership ensures deference is given during CMEP

activities If not endorsed, removed from website

Obtaining Endorsement


• APPA• CEA• EEI• ELCON• EPSA• ISO/RTO Council• LPPC• NARUC• NRECA

Pre-Qualified Organizations

• NAGF• NATF• TAPS• WICF• NERC Planning Committee• NERC Operating Committee• NERC CIPC• Regional Entity Stakeholder

Committees


• Provides direction to ERO Enterprise CMEP staff on approaches to carry out compliance and enforcement activities

• Developed by the ERO Enterprise• May be initiated through policy discussions with industry• Posted for transparency

CMEP Practice Guides


One location on NERC website for:• Implementation Guidance• CMEP Practice Guides• Other supporting documents Other documents created during standards development (i.e., RSAWs,

white papers) Other types of guidance (i.e. Events Analysis Lessons Learned) Reports

One-Stop Shop for Guidance


• Compliance and Certification Committee (CCC) review, with Standards Committee (SC) support, of existing documents to submit for ERO Enterprise endorsement

• Review by the SC of Section 11 of the Standard Processes Manual to determine whether revisions should be considered

• CCC and SC jointly review, with ERO Enterprise CMEP staff, measures and RSAWs

• Develop CMEP Practice Guide on providing deference to endorsed Implementation Guidance

• Create a “one-stop shop” on the NERC website

Recommendations


• November 4, 2015: Present to MRC and request that MRC recommends the Board accept the policy and endorse the recommendations

• November 5, 2015: Request Board acceptance of the policy and endorsement of the recommendations

Next Steps

Risk-based Registration UpdateVal Agnew, Senior Director, Reliability Assurance, NERCStandards and Compliance WorkshopOctober 21, 2015


• Phase I – Industry Engagement Organized Advisory group to discuss policy issues Task Force created to address technical considerations

• Phase I – ROP changes Remove Purchasing-Selling Entities (PSEs) and Interchange Authorities (IAs) Modify criteria for Distribution Providers (DPs) Include NERC-led panel FERC Order March 19, 2015 Additional information to remove Load Serving Entities (LSEs) requested Response to FERC filed on July 17th

Risk-based Registration


• Phase II – Identify classes Generator Owner (GO), Generator Operator (GOP), and Transmission

Owner (TO), Transmission Operator (TOP) Collaboration with NAGF, ISO/RTO, ORCS, RCFG

• Phase II – Industry Engagement Continued use of advisory group and technical task force Engaged industry more broadly through workshops

• NERC examined: Submissions for registered entities Pre-identified Reliability Standards Detailed analysis of events and enforcement data

Risk-based Registration


• GO/GOPs and TO/TOPs that were not involved in an event • No violation or possible violation dating back to 2007• Analyze for potential group or groups• Identified potential candidate organizations for consideration by

the NERC-led panel

Phase II – Data Analysis


Phase II – GO/GOP Data Analysis

• 412 out of 8,525 generation units• 112 out of 922 registered GO/GOPs• No similar characteristics identified MW size as a bright-line was inconclusive Entity’s units may be critical during peak and emergency conditions 28 potential candidates identified for review by the NERC-led panel


Phase II – TO/TOPs Data Analysis

• 38 out of 497 registered TO/TOPs• Not sole indicator of risk• No similar characteristics identified• Identified potential candidates for review by the NERC-led panel


Recommendations

• Use the NERC-led review panel as defined in Phase I Review individual entity’s requests Monitor trends Identify similarly situated entities for potential groups or candidates

• Provide periodic updates to FERC, ERO, and industry with determinations and trends

BreakWebinar participants: We will return at 10:30 a.m. Pacific

NERC Standards Development Update

Howard Gugel, NERC Director of StandardsRyan Stewart, NERC Manager of Standards DevelopmentElsa Prince, NERC Manager of Standards DevelopmentSean Cavote, NERC Manager of Standards Development2015 Standards and Compliance Fall WorkshopOctober 21, 2015


• COM-001-3• IRO-018-1 and TOP-010-1• FAC-003-4• NERC Glossary Alignment of Terms• FAC-010-3, FAC-011-3, and FAC-014-2• Phase 3 of Protection System Misoperations: SPS/RAS• PRC-027

Presentation Topics


• BAL-004-2• BAL-005-1• BAL-006-3• TOP-009-1• EOP-004-2, EOP-005-2, EOP-006-2, EOP-008-1• Dispersed Generation Resources• TPL-001-4

Presentation Topics (cont.)

COM-001-3Project 2015-07: Internal Communications Capabilities


• In FERC Order No. 808, the Commission directed NERC to address the following: Address “internal communications capabilities that could involve the

issuance or receipt of Operating Instructions or other communications that could have an impact on reliability.” Order No. 808, at P 1.o Address internal telecommunications or other internal communication systems

“between geographically separate control centers within the same functional entity.” Order No. 808, at P 41.

o Address internal telecommunications or other internal communication systems “between a control center and field personnel.” Id.

o Address “[t]he adequacy of internal communications capability whenever internal communications could directly affect the reliable operation of the Bulk-Power System.” Id.

FERC Order No. 808 Directives


• COM-001-3 is a modified version of COM-001-2 Proposed Requirement R12 addresses Reliability Coordinator, Balancing

Authority and Transmission Operator responsibilities. Proposed Requirement R13 addresses Distribution Provider and Generator

Operator responsibilities. Two separate requirements were necessary to address different VRFs

based on the risks associated with different functional registrations. Capabilities are not limited but encompass any medium that allows two or

more individuals to interact, consult, or exchange information as stated in the NERC Glossary of Terms.

COM-001-3


• Each (R12: Reliability Coordinator, Transmission Operator, and Balancing Authority) (R13: Distribution Provider and Generator Operator) shall have internal Interpersonal Communication capabilities for the exchange of operating information. [Violation Risk Factor: High] [Time Horizon: Real-time Operations]

• Each (M12: Reliability Coordinator, Transmission Operator, and Balancing Authority) (M13: Distribution Provider and Generator Operator) shall have and provide upon request evidence that it has internal Interpersonal Communication capability, which could include, but is not limited to: physical assets, or dated evidence, such as, equipment specifications and installation documentation,

operating procedures, test records, operator logs, voice recordings, transcripts of voice recordings, or electronic communications.

Examples include, but are not limited to, between geographically separate control centers within the same functional entity, or between a control center and field personnel.

COM-001-3 Requirement and Measure


• Draft standard package posted Initial 45-day comment period and 10-day ballot September 25, 2015.

• Next standard drafting team (SDT) meeting is scheduled for the week of November 30, 2015.

• If the proposed standard passes and there are no substantive revisions to the initial ballot, the standard will be posted for a 10-day final ballot and presented at the February 2016 NERC Board of Trustees Meeting.

Next Steps

IRO-018-1 & TOP-010-1Project 2009-02: Real-time Reliability Monitoring and Analysis Capabilities


• Project will develop requirements to address issues related to Real-time monitoring and analysis of the Bulk Electric System Formal development paused in 2011 for prioritization

• SAR Drafting Team (SAR DT) appointed in April 2015 to revise previous project SAR taking into consideration: FERC Order No. 693 directives Real-time Tools Best Practices Task Force (RTBPTF) recommendations 2011 Southwest Outage Report recommendations Proposed TOP and IRO Standards (pending FERC approval) Technical conference for stakeholder input (June 2015)

• SAR posted for comments July 16 – August 17, 2015

Project 2009-02: Real-time Monitoring and Analysis Capabilities


• Most RTBPTF recommendations have been addressed Real-time Assessment definition Requirements to perform monitoring and Real-time Assessments Data specification requirements

• Project 2009-02 scope is focused on remaining objectives

Project 2009-02 SAR Conclusions

Project 2009-02 Reliability ObjectivesMonitoring Capabilities Analysis Capabilities

Quality Provide operator with indication of data quality and procedures to address issues

Provide operator with indication of analysis quality used in Real-time Assessments and procedures to address issues

Availability Provide operator with notification when alarming system is not operating

N/A


• Two proposed Reliability Standards have been drafted to meet the SAR objectives: IRO-018-1 applicable to Reliability Coordinators (RCs) TOP-010-1 applicable to Transmission Operators (TOPs) and Balancing

Authorities (BAs)

• Proposed requirements address: Quality of data necessary to perform Real-time monitoring and analysis Quality of analysis used in Real-time Assessments System Operator notification of alarm processor failure

• Posted for comment and initial ballot September 24 –November 9

Project 2009-02 Draft Standards

FAC-003-3Project 2010-07.1: Vegetation Management


• Minimal vegetation clearance distances (MVCD) need to be modified in FAC-003 based on Electric Power Research Institute (EPRI) testing The test result findings determined the Gallet equation required changing

from 1.3 to 1.0, which would increase the MVCD values compared to those specified in the existing standard.

• Advisory alert (Link) issued on May 14, 2015• Standards Committee (SC) approved the following at the August

19, 2015 meeting: Authorize Standards Authorization Request (SAR) for 30-day commento SAR posted for comment from August 24 – September 28, 2015 (Link)

Silicate standard drafting team (SDT) nominations

• SC appointed the FAC-003 SDT at the September 23, 2015 meeting

Project 2010-07.1 FAC-003

http://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/2015%20Alerts/NERC%20Alert%20A-2015-05-14-01%20FAC-003%20Vegetation%20Management%20Advisory.pdf

http://www.nerc.com/pa/Stand/Project%202010071%20Vegetation%20Management%20DL/2010-07.1_Veg_Man_SAR_082415.pdf


• FAC-003 SDT will meet to review and address SAR comments and revised table 2 of the standard early October 2015.

• Goal to submit FAC-003 revised standard at the October SC meeting for authorization to post late October/Early November.

Project 2010-07.1 FAC-003 (cont.)

NERC Glossary Alignment of TermsProject 2015-04


Purpose of Project

Phase 1 - Align the defined terms found in the NERC Glossary of Terms and the Rules of Procedure (ROP)

Phase 2 – Provide recommendations regarding other definition-related issues in the Glossary and ROP, including enhancements to the current definition development process, to prevent misalignment in the future


• Final ballot closed September 14, 2015

• Revised 26 Glossary definitions

• Revised 16 ROP definitions

• Changes to definitions of functional entities (i.e., Generator Owner, Generator Operator) to be incorporated into Functional Model by Functional Model Advisory Group (FMAG)

Phase 1 – Complete


• Drafting team meeting October 19-20, 2015• Focus of Phase 2 • Next steps…

Phase 2 – Currently underway


Contact information

Jerry Rust (Chair)[email protected] Office: 503-445-1074

Chris Scanlon (Vice-Chair)[email protected]: 630-576-6926

Lacey Ourso (NERC Standards Developer)[email protected]: 404-446-2581

mailto:[email protected]



FAC-010-3, FAC-011-3, FAC-014-2Project 2015-09: Establish and Communicate System Operating Limits


• Revise requirements for determining and communicating System Operating Limits (SOLs) used in the reliable planning and operation of the Bulk Electric System (BES).

• Address issues identified in Project 2015-03 Periodic Review of System Operating Limit Standards, including recommendations of periodic review team to: Retire FAC-010-3 Revise FAC-011-3 Revise FAC-014-2

Purpose of Project


• August 19, 2015: Project 2015-03 recommendations presented to Standards Committee

• September 2015: SAR posted for 30-day formal comment

• September 23, 2015: Standard Drafting Team appointed by the Standards Committee

• November 2015: Kickoff meeting at NERC Atlanta office

Project Timeline


Contact Information

Vic Howell (Chair)[email protected]: 970-776-5573

Hari Singh (Vice-Chair)[email protected]: 303-571-7095

Lacey Ourso (NERC Standards Developer)[email protected]: 404-446-2581




PRC-012Project 2010-05.3: Phase 3 of Protection Systems: Remedial Action Schemes (RAS)


• Purpose Consolidate the existing RAS-related standards into one standard Retire the term Special Protection System from the NERC Glossary o replacing it with Remedial Action Scheme

• Standard Developer Al McMeekin, [email protected]

Project 2010-05.3 Phase 3 of ProtectionSystems: RAS (PRC-012-2)


PRC-027Project 2007-06: System Protection Coordination


• Purpose Coordination aspects, Faults R3, R4 from PRC-001-1.1(ii)

• Standard Developer Al McMeekin, [email protected]

Project 2007-06 System Protection Coordination: PRC-027


BAL-004-2Project 2010-14.2.2: Phase 2 of Balancing Authority Reliability-based Controls


• Purpose Time error correction Drafting team recommends retirement of BAL-004-0

• Senior Standard Developer Darrel Richardson, [email protected]

Project 2010-14.2.2 Phase 2 of BARC:BAL-004


BAL-005 & BAL-006Project 2014.2.1: Phase 2 of Balancing Authority Reliability


• Purpose Establish requirements for acquiring data to calculate Area Control Error (ACE) Specifies a minimum periodicity, accuracy, and availability requirement for

acquisition of the data and for providing the information to the System Operatoro moved one requirement from BAL-005 to FAC-001o moved one requirement from BAL-006 to BAL-005

• Senior Standard Developer Darrel Richardson [email protected]

Project 2010-14.2.1 Phase 2 of BARC:BAL-005



• Purpose Define a process monitoring Balancing Authorities (BAs) meeting demand or Interchange obligations Standard Drafting Team (SDT) moved one requirement to BAL-005 to FAC-001


Project 2010-14.2.1 Phase 2.1 BARC: BAL-006



• Purpose Document and make Facility interconnection requirements available SDT moved one requirement to BAL-005 to FAC-001


Project 2010-14.2.1 Phase 2.1 BARC: FAC-001


TOP-009-1; Retirement of PRC-001Project 2007-06.2: Phase 2 of System Protection Coordination


• Purpose Knowledge of Composite Protection Systems and Remedial Action Schemes

and their effects Focus on knowledge critical to reliability R1, R2, R5, R6 from PRC-001-1.1(ii)o R1 – Addressed by TOP-009o R2, R5, R6 – TOP/IRO standards

• Standard Developer, Scott Barfield, [email protected]

Project 2007-06.2 Phase 2 of System Protection Coordination: TOP-009



• Aims to retire PRC-001-1.1(ii) Paradigm shift from “familiar with the purpose and limitations” in R1 R1 was basic and fundamental and did not address the knowledge areas

important to reliability concerning system protection.

• Scope is to ensure a knowledge of Operational functionality and effects of Composite Protection Systems and Remedial Action Schemes on BES (BA & TOP) and generating plant output (GOP)

• Focus is on Composite Protection Systems and Remedial Action Schemes Which the BA and TOP receives notification of current status or

degradation Which the GOP operates (generating Facility) and plant output

TOP-009-1


• Does not include the Reliability Coordinator (RC) The team is conducting outreach to determine if there is a gap If a gap, the team will suggest options to address knowledge by RC

• The team considered PER standards as an option The concept was previously vetted by the PER drafting team Reliability objective would not necessarily be addressed by training

• TOP-009-1 is about a high-level knowledge of Composite Protection Systems and Remedial Actions Schemes, and Their operational functionality and effects

• Implementation has been extended from 12 to 24 months• Both PRC-027-1 and TOP-009-1 must be approved by industry to

achieve the full retirement of PRC-001-1.1(ii)

TOP-009-1, Key Points


• Additional 45-day formal comment and ballot Comment period, early October Ballot, before Thanksgiving holiday

• Draft RSAW to be posted for feedback Two weeks after posting of the standard

• Next SDT in-person meeting early December• Anticipated Final ballot December 2015• Anticipated NERC Board of Trustees adoption, February 2016• NERC Standards Developer Project 2007-06.2, [email protected], 404-446-9689

TOP-009-1, Going Forward


PRC-005-6 Order 803 DirectiveProject 2007-17.4


• Initial ballot ended on September 16, 2015 with 96% approval• Drafting team has responded to comments and made

conforming (nonsubstantive) revisions to: PRC-005-6 standard Supplementary Reference and FAQ document Consideration of Directive document Implementation Plan

• Posting for final ballot the week of October 12• NERC Board consideration November 2015 Implementation Plan will request consolidation of versions 2(ii), 3, 3(i),

3(ii), 4, and 5 into version 6 Contact Senior Standards Developer [email protected]

Project 2007-17.4 PRC-005 Order 803 Directive


EOP-004-2, EOP-005-2, EOP-006-2, EOP-008-1Project 2015-08: Emergency Operations


Project 2015-08 Emergency Operations

• Project 2015-08 Emergency Operations The Emergency Operations Standards Drafting Team (EOP SDT) will

implement the recommendations from the Project 2015-02 Emergency Operations Periodic Review of the following standards:o EOP-004-2o EOP-005-2o EOP-006-2o EOP-008-1


Project 2015-08 Emergency Operations

• Periodic Review Objectives Determine whether the Reliability Standards should be:

o reaffirmedo revisedo withdrawn

• The EOP PRT developed the following recommendations and submitted a Standard Authorization Request (SAR): EOP-004-2 – (1) Revise the standard and attachment, and (2) retire

Requirement R3 EOP-005-2 – Revise the standard EOP-006-2 – (1) Revise the standard, and (2) retire Requirements Parts

R1.2, R1.3, and R1.4 EOP-008-1 – Revise the standard


• Reportable Events The EOP PRT recommended revisions to Attachment 1. The posted

recommendations and SAR posting resulted in comments and considerations from industry for attachment revisions, such as:

o Provide clarity to the obligations of the Responsible Entitieso Eliminating duplicative reporting by the GOP and BAo Address potential efficiencies to be gained between ERO and EAo Generation loss criteria specific to Quebec Interconnection.

EOP-004-2 Attachment 1

Dispersed Generation ResourcesProject 2014-01


• On May 29, 2015, FERC issued a letter order approving: PRC-001-1.1(ii) – System Protection Coordination PRC-004-2.1(i)a – Analysis and Mitigation of Transmission and Generation

Protection System Misoperations PRC-004-4 – Protection System Misoperation Identification and Correction PRC-005-2(i) – Protection System Maintenance PRC-005-3(i) – Protection System and Automatic Reclosing Maintenance PRC-019-2 – Coordination of Generating Unit or Plant Capabilities, Voltage

Regulating Controls, and Protection PRC-024-2 – Generator Frequency and Voltage Protective Relay Settings VAR-002-4 – Generator Operation for Maintaining Network Voltage

Schedules

Project 2014-01 DGR


• Updated version of the White Paper posted for comment through July 13, 2015. The Dispersed Generation Resources (DGR) standard drafting team is in

the process of considering the industry comments received during this comment period.

• Drafting team met October 12-14, 2015 to discuss further work• Contact Standards Developer [email protected]

Project 2014-01 DGR


TPL-001Project 2015-10: Protection System Single Points of Failure


• The System Protection and Control Subcommittee (SPCS) and the System Modeling and Analysis Subcommittee (SAMS) conducted a comprehensive assessment of the study of protection system single points of failure in response to FERC Order No. 754

• Assessment confirms the existence of a reliability risk associated with single points of failure in protection systems that warrants further action

• Request for authorization to post SAR planned for presentation to SC October 2015

• Contact Standards Developer [email protected]

Project 2015-10 TPL-001


Project ManagementOversight Subcommittee (PMOS)Brenda Hampton, PMOS Vice Chair2015 Standards and Compliance Fall WorkshopOctober 21, 2015


• Works with NERC staff to support industry subject matter experts (SMEs) in all aspects of standard development. Includes advising and supporting:o Standard Authorization Request (SAR) drafting teams o Standard Drafting Teams (SDTs) and o periodic review teams, as well as

Completing special projects to achieve standard goals specified in the Reliability Standards Development Plan.

PMOS Purpose


• PMOS Duties: Support all SAR drafting teams and SDTs by providing any specialized

resources as may be needed to resolve issues and increase productivity and quality to reach consensus and/or meet its milestones and deadlines.

Work with NERC staff to develop preliminary project timelines to set the expectation prior to the solicitation of an SDT so that prospective members of an SDT can understand and commit to meeting the project timeline, including milestones, at the time of their nomination and appointment.

Work closely with NERC staff and the SDTs to establish milestones and deadlines for all Standards Committee (SC) work activities relating to standard development, up to and including NERC Board of Trustees approval.

PMOS Duties


• Membership: PMOS membership and participation is open to SC members and

interested parties. The need to add or replace members will be evaluated at least annually

and nominations for new members may be solicited as necessary. The PMOS officers will select the new PMOS members.

The size of PMOS will be determined by the workload needs of the subcommittee.

Members will serve two‐year staggered terms with no term limits. The SC Chair and Vice Chair may participate in and support the PMOS as

non‐members. A NERC staff member will be assigned as the non‐voting PMOS

Coordinator.

PMOS Membership


Annual Calendar

Annual Calendar Link: http://www.nerc.com/comm/SC/Project%20Management%20and%20Oversight%20Subcommittee%20DL/2015_Projects_Annual_Calendar_PMOS_external.pdf

http://www.nerc.com/comm/SC/Project%20Management%20and%20Oversight%20Subcommittee%20DL/2015_Projects_Annual_Calendar_PMOS_external.pdf


PMOS Project Tracking Spreadsheet

Annual Project Tracking Spreadsheet: http://www.nerc.com/pa/Stand/Pages/default.aspx

http://www.nerc.com/pa/Stand/Pages/default.aspx

LunchWebinar participants: We will return at 1 p.m. Pacific

Brenda HamptonDirector, NERC & TRE Affairs

Energy Future [email protected]

2015 NERC Standards and Compliance Fall WorkshopSan Diego, CAOctober 20-22

Agenda NAGF Overview

NAGF Activities and Issues

Getting Involved

2

The NAGF mission is to promote the safe, reliable operation

of the generator segment of the bulk electric system through

generator owner and operator collaboration with others who

have a vested interest in the reliable operation of the bulk

electric system.

3

NAGF – Strategic Goals

Grow the NAGF to be the premier organization dedicated to generator reliability issues

Foster relationships with regulators and advocacy groups to provide avenues to educate and collaborate on the needs of NAGF members

Promote effective information exchange and learning opportunities for and between members

4

Completed incorporation as North American Generator Forum, Inc., a

tax-exempt 501(c) (6) corporation

Have a fully populated Board of Directors

Refined our Goals, Strategic Plan and Bylaws

Members include small (≤500 MW), medium (500-5000 MW) and large

(>5000 MW) generating entities.

New collaboration website: www.nagf.groupsite.com

Information on Board, Officers, Advisory Committee, Organization, and

Strategic Plan can be found at:

http://www.generatorforum.org/about_us

NAGF – Current Status

5

http://www.nagf.groupsite.com/

http://www.generatorforum.org/about_us

NAGF Overview


Getting Involved

Agenda

6

NAGF Activities

NAGF Annual Meeting (September 23-24)– Focused on information transfer and training– Synchro-phasor Initiative, Essential Reliability Services including

governor response improvements; Implementation of PRC-005, MOD, CIP; analysis of GADS data;

– Keynote: Michael Bardee, FERC Director of the Office of Electric Reliability. Lunch Speaker: Mark Lauby, SVP/CRO NERC

NAGF attends quarterly trade association meetings with NERC, provides policy input to the NERC Board of Directors, and reports on NAGF activities and concerns at the quarterly NERC Board meeting.

7

NAGF Activities NAGF is a member of the:

− Resources Subcommittee of the Operating Committee− Risk-Based Registration Advisory Group (RBRAG) − Reliability Assurance Initiative Advisory Group (RAIAG)

NAGF submitted input to NERC to assist in development of NERC Reports and Advisories on topics including:− Polar Vortex− EPA Clean Power Plan− Governor Frequency Response

NAGF Standards Review Team − Discussed generator concerns and provided feedback directly to

NERC Standard Drafting Team members (PRC-027, TOP-009, PRC-002, PRC-026...)

– Shared suggestions on development and implementation of standards including CIP V5/V6. 8

NAGF Activities

Provided representation at the 2015 Reliability Leadership Summit

Participated in the Eastern Interconnection Frequency Response Initiative.

Developed Lessons Learned and distributed to members Provided generator feedback to the NPCC RSC Presented at the MISO Governor Frequency Response

Webinar

9

Cold Weather Preparations / MitigationContinually Changing Landscape

• Capacity retirements• Availability of natural gas• Increasing penetration of Variable and Distributed Generation

Essential Reliability Services• Ramping, Reserve and Frequency Support• Voltage Support

EPA’s Environmental Regulations • Clean Power Plan under Section 111(d)

Continued Evolution of Cyber and Physical Security Standards• Implementation of CIP V5/6...?• Supply Chain

Potential for Expanded Regulation / New Standards

GO / GOP issues

10

Agenda NAGF Overview


Getting Involved

12

Joining the NAGF

Send an email requesting membership to:

Mike [email protected]

Katie [email protected]

Or request membership via:http://generatorforum.org/join

13



http://generatorforum.org/join

Volunteer to lead or participate in one of the NAGF teams:• Standards Review Team• Security Practices Working Group• Nuclear Peer Group

Respond to NAGF requests for input on technical issues important to generatorsAttend the NAGF Annual Meeting

• Offer to help plan the next meetingContact one of the NAGF Officers to inquire about other opportunities be involved and support the NAGF.

Member Involvement

14

http://www.generatorforum.org/yahoo_site_admin/assets/docs/2015_04_30_NAGF_Board_and_Officers.242183617.docx

Q & A

15

Thank you!www.GeneratorForum.org

http://www.generatorforum.org/

Open Distribution

North American Transmission Forum (NATF)

Roman CarterDirector- Reviews, Assistance, & Training

Open Distribution

NATF Evolution

• August 14, 2003 - Blackout in US and Canada puts 50 million people in the dark

• Congress developed legislation• August 8, 2005 - 2005 Energy Policy Act • Section 215 established an ERO to

– create mandatory reliability standards – enforce mandatory reliability standards

• NERC became the ERO on July 20, 2006

2

Open Distribution

NATF Evolution

• Left void for transmission owners/operators to “openly” share operating experiences

• 2006 - Transmission Owners and Operators Forum (TOOF) originated under NERC by registered entities– Formed under Section 712 of the ERO ROP– Subordinate to the NERC Board

• January 1, 2010 - TOOF becomes independent of NERC and the North American Transmission Forum (NATF) is formed

3

Open Distribution

NATF Mission, Vision, Approach

• Promote excellence in the reliable operation of the electric transmission systemMission

• Continuously improve the reliability of the electric transmission systemVision

• Aggressively pursue reliability and security excellenceby:• Fostering constructive peer challenge to improve• Efficiently sharing timely, detailed, and relevant

information, including lessons learned and superior practices

Approach

NATF strives to be both agile and impactful

Open Distribution

Guiding Principles

Community Complex, interconnected grid requires active collaboration with members to promote higher levels of reliability, security, and resiliency

Confidentiality Confidentiality promotes open, candid intra-membership dialogue

Candor Direct, objective performance feedback is delivered as a membership norm

Commitment Members’ senior leaders commit to the NATF’s mission of promoting excellence

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NATF Membership / Value Add / Principles• U.S. and Canadian members• 81 members & growing• ~85% miles 100 kV+• ~85% net peak demand

Value Propositions1. Improved reliability / resiliency2. Increased compliance margin3. Efficient use of industry

resources

COMMUNITY CONFIDENTIALITY CANDOR COMMITMENT

Member Types

IOUs State/MuniCo-op ISO/RTOFed/Prov

Open Distribution

Members Cover North American Grid

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NATF Programs

Peer Reviews • On-site reviews, recommendations, networking, gathering/sharing superior practices

Assistance • Focused, on-site assistance for select topicsTraining • Select educational offerings for members

Practices • Peer development and sharing of practices on specific topics

Reliability Initiatives

• Coordinated projects focused on important reliability topics

Information Sharing

• Operating experience, advisories and alerts, surveys, lessons learned, challenge board

Metrics • Outage database, reliability reports, peer benchmarking, program effectiveness

Knowledge Management

More than 4500 subject matter experts participate in NATF working groups, committees, and programs

Reviews, Assistance, and

Training

Practices and Initiatives

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Peer Review – Purpose

• It is about going from good to great!

Peer Review

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Peer Reviews

Design– Review teams of experts

spend 2.5-4.5 days at “Host” peer site

– Final team reports include:

• Strengths• Noteworthy practices,

are shared with all NATF members

• Recommendations for the host to implement

Scope– Review nine technical

areas including:• System Protection• System Operations• Vegetation Management• Human Performance• Internal Controls

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• Defines WHAT each program is intended to achieve

• Philosophy and concepts of what leads to reliability excellence

• Identify attributes that make a program excellent

Uses of POEs1. Keep Forum practices focused2. Provide a basis for peer reviews3. Member self assessment tool

Principles of Operating Excellence (POEs) and Practices

POE: “What”

Forum Practice• A documented method for

performing a process in a safe, effective manner.

• Reasonably expected from skilled and experienced industry organizations.

Practices: “HOW”

Forum Superior Practice• A leading industry practice for

achieving near optimal industry results in terms of quality, reliability, and maintainability.

Open Distribution

Assistance

Purpose– Targeted assistance for a

particular topic or issue

Design– Similar to Peer Reviews in

format but more focused– Tailored to a particular

member’s request or needs

Additional benefit– Lessons learned are

shared with NATF members

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Assistance– Purpose

• Helps a member to address a “gap” in a technical area and bridge that gap with recommended reliability solutions.

Assist Team Recommendations

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Challenge Board

Purpose– Began in late 2013– Challenge the conclusions

from causal analysis of an operating event or disturbance

– evaluate the methods used to analyze the event

Benefit– Members receive

thoroughly vetted OE reports and lessons learned

Design– Member review findings– Member SMEs provide

analysis feedback:

• Focused• Iron sharpening iron

– Meetings are web/phone based

Open Distribution

Practices

Approach‒ Monthly web meetings ‒ Annual workshops to share info‒ Develop NATF practices ‒ Develop principles of operating

excellence (POE)

Surveys and web discussions

InputMembers own experiences, diverse wisdom, and approaches

GoalCollectively move towards operational excellence

Includes-‒ Internal Controls/Risk Assessment‒ Equipment Performance and

Maintenance‒ Human Performance‒ Modeling‒ Operator Training‒ Physical and Cyber Security ‒ System Operations‒ System Protection‒ Vegetation Management

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Training

• Training topics are focused and specific• Surveyed Members on their training needs

– will focus on those areas most requested– where they do not have training already– where it is more appropriate for NATF to provide

• Reduces redundancy of member training• Maximizes member resources

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Metrics

Data– The NATF collects and

analyzes transmission equipment performance data

Theme– Improving equipment

performance directly contributes to improving reliability

Ongoing efforts– Expanding breadth and depth

of data collection and analysis

Tools– The program allows members

to confidentially view other’s data and provides tools to facilitate peer benchmarking

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Collaboration With NERC

• In addition to reliability and resiliency, NATF members strive to reduce redundancy and maximize industry SME resources

• NATF shares certain member documents with industry for specific initiatives

• Upon NATF BOD/CEO approval, we will share those products

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Collaboration With NERC

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Questions

NERC Reliability Standards Quality Review

Sean Cavote, NERC Manager of Standards Development2015 NERC Fall Standards and Compliance WorkshopOctober 21, 2015


• Quality Review Principles• Current Quality Review process• Enhanced Quality Review process• Industry participation expectations

Presentation Topics


• Fundamental principals Scope Clarity Enforceability

• Starts at project inception• Standards Developer Responsible for project QR planning and execution Planning discretion

• Quality Review (QR) procedure and guidance Meaningful direction Flexibility

Quality Review Principles


• NERC Standard Processes Manual (SPM) requirements Within scope of the associated Standard Authorization Request (SAR) Clear and enforceable Meets Benchmarks for Excellent Standards and governmental criteria for

approval

• NERC Quality Review (QR) guidance documentation QR guidance document QR checklists

• Standards Committee (SC) and NERC Board of Trustees (Board) expectations SC requires certification that a QR was performed in accordance with SPM

requirements and NERC guidance QR certification included with Board materials

Current Quality Review Process


•Roles and responsibilities Standard Drafting Team (SDT) Standards Developer Project Management and Oversight Subcommittee (PMOS)

representative QR participants



•Required participants Standards developer SDT leadership

•Optional participants NERC legal NERC compliance PMOS representative Subject matter expert (SME) assigned to the project Independent SME Independent legal or editing experts



•Required QR elements SPM requirements

• Suggested QR elements Content Quality Administrative



• Responds to feedback from SC and industry Errata, inconsistent standards language, editorial misses

• Enhanced QR procedure Elongated time line Integrated into project schedules Coordinated with PMOS Expanded mandatory participants Targeted checklists

• Applicable to all standards development Enhanced periodic reviews Drafting efforts Technical reports and white papers

Enhanced Quality Review Process


•Mandatory enhanced QR participants Administrative Legal Compliance, Enforcement, and Technical Industry Legal/Editorial



• Required QR elements SPM mandated requirementso Within scope of the associated Standard Authorization Request (SAR) o Clear and enforceableo Meets Benchmark for Excellent Standards and governmental criteria for approval

Content Quality Administrative Minimum two-week allocation Linear



•Test cases underway Continent-wide standards Regional standards

• Full implementation Q1 2016 Enhanced periodic reviews



• Enhanced industry participation Targeted independent subject matter experts (SMEs) Feedback loopso NERC inter departmento Regionso Tradeso Standards Committee

Ballot pools Industry QR database Standards Committee

• QR inputs within scope

Industry Participation Expectations


Sean CavoteNorth American Electric Reliability Corporation3353 Peachtree Road NE, Suite 600 – North TowerAtlanta, GA 30326404.446.9697 (O)[email protected]

Contact


BreakWebinar participants: We will return at 3 p.m. Pacific

NERC Standards UpdateHoward Gugel, NERC Director of StandardsRyan Stewart, NERC Manager of Standards DevelopmentElsa Prince, NERC Manager of Standards DevelopmentSean Cavote, NERC Manager of Standards Development2015 Standards & Compliance Fall WorkshopOctober 21, 2015


• 2016-2018 Reliability Standards Development Plan• 2016 Outlook• Enhanced Periodic Reviews• Outreach

Presentation Topics


• How did we get here? 2012 stakeholder inputs

• Progress towards steady state• Project Management and Oversight Subcommittee• Federal Energy Regulatory Commission (FERC) directives 247 directives outstanding during 2013-2015 11 directives outstanding in 2016

• Paragraph 81 and Independent Expert Review Panel 281 requirements recommended for retirement 273 addressed by 2016o 46% retiredo 43% revisedo 11% reaffirmed

2015 Trends and Expectations


• Steady State FERC directives and recommendations for retirement have been addressed Quality and content have been reviewed Standards have transitioned closer to being results-based

• Steady State will be reached early 2016 17 standards in 2015, two in 2016

• Principles to consider moving forward Stakeholder comfort with steady state Standards provide accountability Standards should mitigate risks to the Bulk Power System Standard and compliance expectations should be aligned

Steady State NERC Standards


• Analysis and coordination Ahead of project kick-off Feedback loops Committees, trades, forums Risk analysis

• Consider other projects, tools, and principles Connection to technical excellence Compliance guidance

• Project planning Project Management and Oversight Subcommittee Enhanced periodic reviews

Going Forward – 2016 and Beyond


• Sets forth plan for: Eight projects continuing from 2015 into 2016 Enhanced Periodic Reviewso Eight standards families planned for 2016

Emerging risks FERC directives Standard Authorization Requests

• Specifically considers: Integration of Variable Generation Task Force (IVGTF) recommendations Essential Reliability Services Task Force (ERSTF) recommendations Communicating with the Reliability Issues Steering Committee (RISC) on

other emerging risks Potential FERC directives

2016-2018 Reliability Standards Development Plan


• Flexibility in measured approach to development• Prioritization considerations Risk assessment Industry buy-in up front

• Feedback loops and factors for consideration of risk Emerging risks and changing technologies Event analysis and compliance violation statistics Lessons learned and FAQs Measures Reliability Standard Audit Worksheet development and compliance input Regional variances

2016-2018 Reliability Standards Development Plan (cont.)


• Status Industry comment period closed on August 17, 2015 NERC Standards Committee endorsed on September 23, 2015

• Next steps Present to the NERC Board of Trustees (Board) in November 2015 File with the applicable governmental authorities fourth quarter 2015

2016-2018 Reliability Standards Development Plan (cont.)


• Measured in-depth review to improve quality and content of standards

• Seek opportunities to make standards more concise Verify content is appropriate for inclusion in a standard Builds on Independent Experts’ work with industry input

• Enhanced periodic reviews to address: Emerging risks FERC directives Standards Authorization Requests

Enhanced Periodic Reviews


• Plan in development• Execution expected in Q1 2016 Topic was discussed at the May NERC Board meetings for policy inputs

• No mandated timeline Deliberate measured pace

Enhanced Periodic Reviews (cont.)


• Recognizes current trend at NERC Smaller drafting and review teams of 6-10 members Active observers Engaged industry throughout standard development process Active use of project listservs

• Essential part of standards development The ballot is an inefficient barometer of industry position Ad hoc groups have more influence early in the process Teams often more receptive to comments during early phases of

development Communication among industry, teams, NERC, and FERC

Outreach


• Continued open dialogue as we engage in a more measured development of standards Feedback loops Committees, trades, forums Compliance inputs and guidance Enhanced periodic reviews vs. standards development projects timing

• Feedback during outreach and development Suggested language Rationale

Outreach (cont.)

Interpretations

Ryan Stewart, Manager of Standards Development2015 Standards & Compliance Fall WorkshopOctober 21, 2015


• Standard Processes Manual (SPM) Section 7 outlines the process for developing an interpretation.

• A valid interpretation response provides additional clarity about one or more requirements, but does not expand on any requirement and does not explain how to comply with any requirement.

• Any entity that is directly and materially affected by the reliability of the North American Bulk Power Systems may request an interpretation.

• The NERC Standards and Legal staff shall make a recommendation to the Standards Committee whether to accept the Request for Interpretation (RFI).

Overview of Interpretations


• Four RFIs presented to the NERC Standards Committee (SC) on September 23, 2015 Interpretation of CIP-002-5.1 for EnergySec - Accepted Interpretation of CIP-007-5 for Foxguard Solutions- Accepted Interpretation of TOP-002-2.1b for FMPP- Accepted Interpretation of TPL-001-4 for GTC – Rejected

Recent Development


• Standards Committee Process Subcommittee (SCPS) of the SC is working on revising Section 7 of the SPM to streamline the process.

• From the FERC Order on the ERO’s Five-Year Performance: P63. We understand that the processing time for interpretations may be

affected by other considerations, including a possible preference for addressing ambiguities through the Reliability Standards development process. However, with NERC’s stated goal of bringing the Reliability Standards program to a “steady state” (i.e., with fewer Reliability Standards under development or modification), the ability to efficiently resolve possible ambiguities through the interpretation process may take on added importance. Accordingly, we encourage NERC to explore ways to reduce the time needed to process a request for interpretation.

Process Improvements


• RFI submitted by Energy Sector Security Consortium (EnergySec).

• Accepted by the SC on September 23, 2015.

• Request for clarity regarding Requirement R1, Attachment 1, Part 2.1, which provides,

“Commissioned generation, by each group of generating units at a single plant location, with an aggregate highest rated net Real Power capability of the preceding 12 calendar months equal to or exceeding 1500 MW in a single Interconnection. For each group of generating units, the only BES Cyber Systems that meet this criterion are those shared BES Cyber Systems that could, within 15 minutes, adversely impact the reliable operation of any combination of units that in aggregate equal or exceed 1500 MW in a single Interconnection.”

Interpretation of CIP-002-5.1


• The interpretation will address whether the language “shared BES Cyber Systems” refers to discrete Bulk Electric System (BES) Cyber Systems that are shared by multiple units, or whether instead it refers to groups of BES Cyber Systems that, collectively, could impact multiple units.

• This will provide clarity regarding whether the evaluation required under Requirement R1 should be performed individually for each discrete BES Cyber System at a single plant location, or instead, applied collectively for groups of BES Cyber Systems.

Interpretation of CIP-002-5.1 (cont.)


• RFI submitted by FoxGuard Solutions, Inc. • Accepted by the SC on September 23, 2015. • Request for clarity regarding Requirement R2, Part 2.1 which

provides, R2: Each Responsible Entity (RE) shall implement one or more documented process(es) that collectively include each of the applicable requirement parts in CIP-007-5 & CIP-007-6 Table R2 – Security Patch Management.

R2.1: A patch management process for tracking, evaluating, and installing cyber security patches for applicable Cyber Assets. The tracking portion shall include the identification of a source or sources that the Responsible Entity tracks for the release of cyber security patches for applicable Cyber Assets that are updateable and for which a patching source exists.

Interpretation of CIP-007-5


• The interpretation will address whether REs can identify and monitor a source that aggregates information about the release of cyber security patches from multiple “original” and “other” sources.

• The interpretation will provide clarity regarding what constitutes a “source.”

Interpretation of CIP-007-5 (cont.)


• RFI submitted by Florida Municipal Power Pool (FMPP).

• Accepted by the SC on September 23, 2015.

• Request for clarity regarding Requirements R2, R8, and R19.

Interpretation of TOP-002-2.1b


• Requirement R2 provides, R2. Each Balancing Authority (BA) and Transmission Operator (TOP) shall ensure its operating personnel participate in the system planning and design study processes, so that these studies contain the operating personnel perspective and system operating personnel are aware of the planning purpose.

• The interpretation will provide clarity regarding the meaning of the requirement that BAs and TOPs “ensure” their operating personnel participate in the planning and design study processes.

Interpretation of TOP-002-2.1b(cont.)


• Requirement R8 provides, R8. Each BA shall plan to meet voltage and/or reactive limits, including the deliverability/capability for any single contingency.

• The interpretation will provide clarity regarding whether “voltage and/or reactive limits” and “deliverability/capability” is intended to include the generator terminals.



• Requirement R19 provides, R19. Each BA and TOP shall maintain accurate computer models utilized for analyzing and planning system operations.

• Under the NERC Functional Model the BA does not analyze and plan transmission operations. The interpretation will provide clarity regarding what is required of the BA in “maintaining” accurate computer models for a load-interchange-generation balance.



• The accepted RFIs will be prioritized by the Project Management and Oversight Subcommittee of the SC.

• Interpretation Drafting Teams (IDTs) will be formed to answer the RFI.

• NERC will continue to process RFIs as they come in.

Next Steps

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