NERC

BREAKING: NERC Accepts Merced Irrigation District De-activation as TO

(Merced, CA, June 5, 2019) Merced Irrigation District Water & Power (MEID) learned that it has been successfully deregistered as Transmission Owner (TO) by the North American Electric Reliability Corporation (NERC) on April 23, 2019 through a decision of the NERC Led Review Panel. The determination was made based on an exhaustive analysis presented by MEID in conjunction with Cooper Compliance Corporation, who represented MEID to NERC in this matter. This result will enable both Turlock Irrigation District (TID) and MEID to narrow their focus to more efficiently continue to deliver safe, reliable and affordable electric service in Central California.

The NERC Led Review Panel has been established to evaluate the applicability to unique situations of registered entities that should not qualify as Bulk Electric System (BES), but otherwise qualifies by applying the approved NERC definition of BES.

Cooper Compliance and MEID started this process with an initial request for deregistration in August of 2018. After initial review, including more requests for information that were fulfilled by MEID and Cooper Compliance, the NERC-led Review Panel evaluated MEID’s materiality to the BES as a TO by considering evidence in light of the materiality test and the Risk-Based Registration (RBR) Implementation Guidance. After this review, the Panel concluded that MEID’s registration as a TO is not material to the reliability of the BES.

MEID owns a small section of transmission and bus bar rated at 230 kV and located at the tail end of the transmission system. A small amount of power flows through the transmission and bus bar at times, preventing MEID from qualifying for a BES definition exemption. The analysis of the MEID system prepared by Cooper Compliance and MEID included a determination that the amount of power that flowed through was no more than that of distributed generation under the Exclusion E2. That, along with consideration of other factors, helped the NERC Led Review Panel come to this final decision. Other decision factors included: the location of MEID on the Bulk Electric System; the agreement of the materiality to the BES by WECC (regional entity) and Turlock Irrigation District, to which MEID interconnects; MEID’s registration as a DP accompanied with a detailed analysis demonstrating no additional gaps exist.

NERC notes that the decision to accept MEID’s request to deactivate it’s TO registration does not set precedent regarding the registration of similar entities. Each request is reviewed on a case-by-case basis and determinations are made based on the specific facts and circumstances of each situation.

Rich Dragonajtys, Principle Engineering Manager of MEID, said of the decision: “I wanted to thank all the members of the Panel, Mary Jo and her staff at Cooper Compliance, Michael Dalebout, Brett Bodine, Scott Downey, you and your staff and my own management and coworkers who allowed Mary Jo and I to take a chance on this effort and helped me gather information and data for initial application write-up and subsequent RFI’s.”

Cooper Compliance is known for its commitment to its clients and provides invaluable assistance for NERC compliance. They provide excellent professional services and we love their Global Audit-Ready Products designed for SharePoint. The Global Audit-Ready suite fully documents our programs with built in controls that run our compliance program like a tax software while ensuring we get our best rate of return by providing reliable services to our customers.”

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NERC Update Summary September 2018

Global Audit-Ready Standards Updates

September 2018

This newsletter contains information of interest to compliance professionals in the electric utility industry. Cooper Compliance clients and non-clients alike will find useful, timely information, including the following:

  • Cooper Compliance News

  • Industry Events

  • Retired Standards

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • New NERC Guidance Documents

  • Recently Added RSAWs

Cooper Compliance News

NERC Requirements List Updated

Over the next few days, the Global Audit-Ready database of NERC and regional standards will be updated for Cooper Compliance clients to keep pace with changes released on the NERC website. Look for these changes if you have Global Audit-Ready applications:

  • Add standard of PER-006-1.

  • Added standard of PRC-027-1.

  • Added standard of BAL-002-3 and set retirement date of BAL -002-2, which it replaces.

  • Retired VAR-002-WECC-2.

  • Added RSAW for EOP-004-4.

  • Added RSAW for EOP-006-3.

Global Audit-Ready Application Enhancements

This month we have released enhancements to our workflow capabilities, our Editor tool which is used to set up new facilities or new Standards, and our Operator Instruction Log.

The Global Audit-Ready workflow capability just got better.
These changes affect workflows and  Global Audit-Ready Dashboard, Reporter, Editor, SME Responsibility Report, Document Loader.

  • When the due date is approaching for a compliance task that repeats over a predefined period, the workflow sends an email, creates an item in the SharePoint task list, and changes the status for the associated process. Once documentation is loaded that demonstrates completion of the task, the workflow will advance based on a predesignated cycle.  A new enhancement allows the user to specify if the start of the next workflow should advance based on a fixed (i.e. each quarter) or performance (i.e. 15 calendar months) cycle.  The enhancement also allows for the user to schedule a one-time occurrence task.

  • A task description field has been added to allow the user to provide specific instructions to the recipient of the task.

  • Multiple tasks can be assigned to one process.  Previously we only allowed for one task per process.  An example of where this feature might be used is MOD-032, where you may have multiple base case data submittals in one year, with some occurring at the same time.

  • The recipient of an outgoing email for a generated task can click on a link embedded within the email to upload a document to the system directly.

The Global Audit-Ready editor feature just got more efficient.
The Global Audit Ready Editor feature now allows the user to inherit attributes from an existing process.  This makes improves efficiencies when adding a new generator or facility.  With a click, the user can inherit a process from a similar generator and modify the properties such as assigning it to a different subject matter expert.  

The Operator Instruction Log just made logging more efficient and incorporates key indicators for SAIDI and SAIFI.  

  • An Open Logs report allows the operator to click on a link from the report to improve logging efficiency.

  • SAIDI (System Average Interruption Duration Index) and SAIFI (System Average Interruption Frequency Index) values are calculated when logging a distribution or transmission outage.

Industry Events

North American Generator Forum Annual Meeting
Cooper Compliance attended the North American Generator Forum (NAGF) annual meeting held at the NERC headquarters in Atlanta. NAGF was founded in 2009 and has grown to the point that there was standing room only. Presenters from highly knowledgeable industry experts, regions and NERC were extremely informative and valuable. NAGF offers an opportunity for generators to come together to influence and shape the development of regulations, and to share valuable technical information and techniques for meeting your compliance program.  If you are not yet a member of this forum and you are a generator we highly recommend you join NAGF. Request to join NAGF by filling out this information form.

WECC Reliability and Security Workshop
The WECC Reliability and Security Workshop (formerly "Compliance Workshop") is in San Diego from October 22 to 25.  Please come to the Cooper Compliance booth to view our latest products.  We will post our notes at
https://www.coopercompliance.com/download/
Sign up for the conference here.

 
NPCC Fall Compliance & Standards Workshop
The 2018 NPCC Fall Compliance & Standards Workshop is in Providence Rhode Island November 7 - 8. Cooper Compliance will be there!  Sign up here.
 

Retired Standards

For the WECC region, VAR-002-WECC-2 has been retired, as of September 5, 2018. NERC and WECC stated that VAR-002-WECC-2 is no longer necessary because reliability issues addressed in the regional Reliability Standard are adequately addressed by the continent-wide Voltage and Reactive (VAR) Reliability Standards and the retention of the regional Reliability Standard would not provide additional benefits for reliability.
 

New or Revised Standards

BAL-004-WECC-02 was replaced by BAL-004-WECC-3. Titled, “Automatic Time Error
Correction,” BAL-004-WECC-02 became inactive on September 30, and BAL-004-WECC-3 became effective on Oct 1.

PER-006-1, titled “Specific Training for Personnel,” has been approved for future enforcement. The purpose is to ensure that personnel are trained on specific topics essential to reliability to perform or support Real-time operations of the Bulk Electric System. This change replaces the current Standard PRC-001 R1 that requires that the generator operator is familiar with protection systems and their limitations. 
Effective Date: 10/1/2020
Applies to: GOP
 
PRC-027-1, titled “Coordination of Protection Systems for Performance During Faults,” has been approved for future enforcement. The purpose is to maintain the coordination of Protection Systems installed to detect and isolate Faults on Bulk Electric System (BES) Elements, such that those Protection Systems operate in the intended sequence during Faults.
Effective Date: 10/1/2020
Applies to: TO GO DP
 
BAL-002-3 will replace BAL -002-2. Titled “Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event,” this standard’s purpose is to ensure the Balancing Authority or Reserve Sharing Group balances resources and demand and returns the Balancing Authority's or Reserve Sharing Group's Area Control Error to defined values (subject to applicable limits) following a Reportable Balancing Contingency Event.
Effective Date: 10/1/2020
Applies to: BA and RSG
 

Standards Under Development

2016-02 Modifications to CIP Standards | CIP-002-6 and CIP-003-8

Balloting dates: 9/28/18 to 10/9/18
Comment Period:: 8/23/2018 to 10/9/2018
The SDT will modify the CIP family of standards (or develop an equally efficient and effective alternative) to address issues identified by the CIP V5 TAG, address FERC directives contained in Order 822; and address requests for interpretations as directed by the NERC Standards
 

2015-09 Establish and Communicate System Operating Limits

Balloting dates: 10/8/2018  to  10/17/2018
Comment Period: 8/24/2018  to 10/17/2018
Facilities Design, Connections, and Maintenance (FAC) standards fulfill an important reliability objective for determining and communicating System Operating Limits (SOLs) used in the reliable planning and operation of the Bulk Electric System (BES). This project will revise requirements for determining and communicating these SOLs. Revisions are necessary to improve the requirements by eliminating overlap with approved Transmission Planning (TPL) requirements, enhancing consistency with Transmission Operations (TOP) and Interconnection Reliability Operations (IRO) standards, and addressing issues with determining and communicating SOLs and Interconnection Reliability Operating Limits (IROLs).
 

2018-02 Modifications to CIP-008 Cyber Security Incident Reporting (SAR)

Comment Period: passed
Initial Ballot and Non-Binding Poll: 10/18/2018 to 10/22/2018
In Order No. 848 FERC has directed NERC to revise the Standard to require the reporting of Cyber Security Incidents that compromise, or attempt to compromise, a responsible entity’s Electric Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMs).
Cooper Compliance agrees that reporting should be made as directed by NERC.  However, it seems that this Standard should be merged with EOP-004, which requires redundant reporting.

 2018-01 Canadian-specific Revisions to TPL-007-2
Join Ballot Pool: 10/2/2018 to 10/31/2018
Comment Period: 10/2/2018 to 11/15/2018
Initial Ballot:   11/6/2018 to 11/15/2018
The purpose of this project is to enable the option for Canadian Registered Entities to leverage operating experience, observed GMD effects, and on-going research efforts for defining alternative Benchmark GMD Events and/or Supplemental GMD Events that appropriately reflect their specific geographical and geological characteristics. This project also addresses regulatory frameworks specific to Canadian jurisdictions.
 

NERC Guidance Documents

The NERC Planning Committee has released three new helpful guidance documents for those who need to verify and model inverter-based resources.
 
BPS-Connected Inverter-Based Resource Performance guideline provides recommendations for steady-state and dynamic performance characteristics for modeling inverter-based resources.

Methods for Establishing IROLs guideline provides recommendations for conducting analysis of instability, system instability, uncontrolled separation, and cascading for determining Interconnection Reliability Operating Limits (IROLs).

Power Plant Model Verification for Inverter-based Resources guideline provides clarity on validating MOD-025 for Inverter Based generators and the use of performance data as well as additional information needed for proper modeling.  It provides clarification on the difference of data provided under MOD-025, MOD-025, MOD-027 versus MOD-032 and MOD-033.  It provides recommendations on different methods for obtaining modeling data through testing and data validation.

New RSAWs

These RSAWs have been added to the NERC website and have also been added to the Global Audit-Ready software for Cooper Compliance clients.

EOP-004-4

EOP-006-3

Global Audit Ready Standards Update

Happy New Year from Cooper Compliance!

Cooper Compliance is pleased to provide news that compliance professionals need to know. In this newsletter, learn what standards are imminently changing, retiring, or becoming effective. Keep up to date with your entity’s responsibilities for NERC standards. We sift through the NERC website and bring it all together for you in a neat and succinct summary, freeing your time to build your business.   

This report provides:

  • A summary of the updates that were made during the fourth quarter of 2017.
  • A description of projects under development and our comments on each
  • A list of new RSAWs that have been added to the databases underlying Global Audit-Ready, our cutting edge compliance software package for energy industry compliance to government standards.

Those entities utilizing SharePoint 2013 or higher will soon be upgraded to our latest version of Global Audit-Ready that contains many new and exciting features.  For example, word RSAWs and RSAW packages are now auto-generated to prepare you for an audit with a click of a button.  The Global Audit-Ready Operator Instruction Log (OIL) for SP 2013 and higher has many great reporting features.  Contact Cooper Compliance if you are not already a user of OIL to see how it can help your organization raise its bar with a robust compliance program and internal controls.
 

Revised NERC Standards:

BAL-002-2 (R1, R2)
Title: Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
Applicability: Balancing Authority or Reserve Sharing Group
Effective Date: 1/1/2018
BAL-002-2 contains revisions to, and replaces, BAL-002-1. Major changes are as follows:
In R1 and R2 the VRF (Violation Risk Factor) has been moved from medium to high, replacing BAL-002-01.  To comply with R1 and R2, the responsible entity must supply evidence and documents proving compliance if there is a reportable balancing contingency event.

BAL-502-RF-03
Title: Planning Resource Adequacy Analysis, Assessment and Documentation
Applicability: Planning Coordinator in the Reliability First (RF) region
Effective Date: 1/1/2018
BAL-502-RF-03 contains revisions to, and replaces, BAL-502-RF-02. Major changes are as follows:
From M1, "Each Planning coordinator shall possess the documentation that a valid Resource Adequacy analysis was performed or verified in accordance with R1".  From M3, " Each Planning Coordinator shall possess the documentation identifying any gaps between the needed amounts of planning reserves and projected planning reserves in accordance with R3."  A third requirement was added, which states, “The Planning Coordinator shall identify any gaps between the needed amount of planning reserves defined in Requirement R1, Part 1.1 and the projected planning reserves documented in Requirement R2.”


PRC-006-SERC-02
Title: Automatic Underfrequency Load Shedding Requirements
Applicability: Planning Coordinators, Generator Owners, and UFLS entities, which might include Transmission Owners or Distribution Providers in the SERC region
Effective Date: 1/1/2018
PRC-006-SERC-02 contains revisions to, and replaces, PRC-006-SERC-01. Major changes are as follows:
In this update, the planning coordinator decides when the peak time is for each requirement as seen in R2, either summer or winter.


IRO-002-5
Title: Reliability Coordination – Monitoring and Analysis
Applicability: Reliability Coordinator
Effective Date: 10/1/2017
IRO-002-5 contains revisions to, and replaces, IRO-002-4. Major changes are as follows:

  • R1 Risk factor moved from High to Medium, and Time Horizon reduced to Operations Planning only.
  • Two new requirements were added. The first requires RCs to have data exchange capabilities and spells out the details of those capabilities. The second new requirement describes needed testing of the Control Center data exchange capabilities. R5 now directs that the status of Remedial Action Schemes, rather than the status of Special Protection Systems, be monitored.
  • The Compliance Enforcement Authority is expanded to include any entity designated by the applicable Governmental Authority.

.
COM-001-3
Title: Communications
Applicability: Transmission Operator, Balancing Authority, Reliability Coordinator, Distribution Provider, Generator Operator
Effective Date: 10/1/2017
COM-001-3 contains revisions to, and replaces, COM-001-2.1. Major changes are as follows:

  • The format of the requirement has been updated to include measures directly after the corresponding requirement.
  • Two new requirements, R12 and R13, specify additional interpersonal communication capabilities. R12 specifies that each RC, TO, GO, and BA shall have interpersonal communication that enables operation of the BES while specifying these communications must exist between control centers to control centers as wells as field personnel. R13 specifies that each DP shall have the same.  

The Compliance Enforcement Authority is expanded to include any entity designated by the applicable Governmental Authority.  In this update, the planning coordinator decides whether the peak demand is summer or winter for the purposes of each sub-requirement of R2.

VAR-501-WECC-3.1
Title: Power System Stabilizer(PSS)
Applicability: Generator Owner, Generator Operator in the WECC region
Effective Date: 9/26/2017
VAR-501-WECC-3.1 contains revisions to, and replaces, VAR-501-WECC-3. Major changes are as follows: 

This standard was written to ensure that the Western Interconnection is operated in a coordinated manner under any condition establishing performance criteria for WECC power system stabilizers. This update is due to an errata that corrects the effective date.  .  Requirement R3 has an effective date of July 1, 2017 for first time service after regulatory approval and R3 has an effective date of July 1, 2022 for units placed in service prior to final regulatory approval.  

VAR-002-4.1
Title: Power System Stabilizer(PSS)
Applicability: Generator Owner, Generator Operator
Effective Date: 9/26/2017
VAR-002-4.1 contains revisions to, and replaces, VAR-002-4. Major changes are as follows: 
The standard contained measures to ensure the generator provide voltage and reactive power control within generation facilities.   This update is due to an errata that adjusts foot note 4 to capitalize “Reactive Power” in order to reference the NERC definition for Reactive Power.
 

VAR-001-4.2
Title: Voltage and Reactive Control
Applicability: Transmission Operators, Generator Operators within the Western Interconnection(WECC)
Effective Date: 9/26/2017
VAR-001-4.2 contains revisions to, and replaces, VAR-001-4.1. Major changes are as follows:
The standard was replaced due to an errata that corrected NERC terms, corrected grammar, and other minor grammatical clarifications.  For example, The time horizon was modified from Operational Planning to Operations Planning and M1 clarifies that 30 days means 30 calendar days.
 

NERC Standards Under Development January 2017:

  • 2017-07  Standards Alignment with Registration. Open for comment until January 9. FERC approved the removal of two functional categories, Purchasing-Selling Entity (PSE) and Interchange Authority (IA), from the NERC Compliance Registry due to the commercial nature of these categories posing little or no risk to the reliability of the bulk power system.  FERC also approved the creation of a new registration category, Underfrequency Load Shedding (UFLS)-only Distribution Provider (DP), for PRC-005 and its progeny standards.(Reference) . 

Regarding 2017-07  Standards Alignment with Registration above, the Cooper Compliance feedback to NERC is that we agree with the proposed scope and objectives and with the merging of two SARs into a single SAR. Our comments to FERC are as follows:
Yes we agree the scope is appropriate, we also feel it could be expanded to cover the function of Generator Lead Lines Interconnection Facilities and TOP lite. While there is no registration type as Generator Lead Line Interconnection Facility, the concept has been introduced but is not well defined in the Standards.  In addition, while NERC has temporarily dismissed the concept of a TOP lite, it would be good to reintroduce this concept.  For example, a TOP that only owns a bus bar should not have to have a full blown backup control room and so forth. The Standards should match the risk to the Bulk Electric System. 


•    2017-05 NUC-001-3 Periodic Review. Open for comment through 1/29/2018.  The drafting team did not identify any changes that warrant a new project.  Cooper Compliance Agrees with this assessment.

Regarding 2017-07  Standards Alignment with Registration above, the Cooper Compliance feedback to NERC is that we agree with the proposed scope and objectives and with the merging of two SARs into a single SAR. Our comments to FERC are as follows:
Yes we agree the scope is appropriate, we also feel it could be expanded to cover the function of Generator Interconnection Facilities and TOP lite. While there is no registration type as Generator Interconnection Facility, the concept has been introduced but is not well defined in the Standards.  In addition, while NERC has temporarily dismissed the concept of a TOP lite, it would be good to reintroduce this concept.  For example, a TOP that only owns a bus bar should not have to have a full blown backup control room and so forth. The Standards should match the risk to the Bulk Electric System.

New and Updated RSAW Documents:

Standard Description Date Updated
PRC-006-3 Automatic Underfrequency Load,Shedding 11/29/2017
VAR-001-4.2 Voltage and Reactive Control 11/29/2017
VAR-002-4.1 Generator Operation for Maintaining Network Voltage 11/29/2017
BAL-002-2 Disturbance Control Performance - Contingency Reserve for Recovery from a Balancing Contingency Event 10/11/2017
IRO-018-1(i) Reliability Coordinator,Real-time Reliability Monitoring and Analysis Capabilities 10/11/2017
TOP-010-1 Real-time Reliability Monitoring,and Analysis Capabilities 10/11/2017
PRC-026-1 Relay Performance During Stable,Power Swings 9/25/2017