Agenda Standards Committee Meeting - NERC Highlights and Minutes/SC... · 2016. 9. 2. · Agenda - Standards Committee Meeting | September 14, 2016 2 12. Request for Interpretation

Agenda Standards Committee Meeting September 14, 2016 | 8:00 a.m. to 2:00 p.m. Pacific

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Introduction and Chair’s Remarks

NERC Antitrust Compliance Guidelines and Public Announcement*

Agenda Items

1. Review Agenda ― (Approve) (B. Murphy) (1 minute)

2. Consent Agenda ― (Approve) (B. Murphy) (1 minute)

a. July 20, 2016, Standards Committee Meeting Minutes* ― (Approve)

3. Upcoming Standards Projects or Issues*― (Update)

a. Three-Month Outlook* (S. Noess; B. Murphy) (10 minutes)

4. Projects Under Development ― (Review)

a. Project Tracking Spreadsheet (B. Hampton; S. Noess) (15 minutes)

b. Projected Posting Schedule (S. Noess) (5 minutes)

5. Project 2016-03 Cyber Security Supply Chain Management* CONFIDENTIAL ― (Appoint) (S.Cavote) (10 minutes)

6. Project 2015-10 Single Points of Failure* CONFIDENTIAL ― (Appoint) (S. Cavote) (10 minutes)

7. Project 2016-04 Modifications to PRC-025*― (Authorize) (S. Barfield-McGinnis) (10 minutes)

8. 2017-2019 Reliability Standards Development Plan and Grading* ― (Endorse) (S. Noess; B.Murphy) (10 minutes)

a. Presentation on Grading Process* ― (S. Noess; G. Zito) (10 minutes)

9. Standards Committee Charter Revision* ― (Approve) (SCEC; S. Noess) (10 minutes)

10. Standards Committee Annual Accomplishments* ― (Endorse) (SCEC) (10 minutes)

11. 2017 Standards Committee Meeting Dates and Locations* ― (Approve) (B. Murphy) (10minutes)

https://cc.readytalk.com/r/k8dwgl8w4b0p&eom

http://www.nerc.com/comm/SC/_layouts/xlviewer.aspx?id=/comm/SC/Project%20Management%20and%20Oversight%20Subcommittee%20DL/Project%20Tracking%20Spreadsheet.xlsx&Source=http%3A%2F%2Fwww%2Eqa%2Enerc%2Ecom%2Fcomm%2FSC%2FProject%2520Management%2520and%2520Oversi

http://www.nerc.com/pa/Stand/Documents/Projected_Posting_Schedule.pdf

Agenda - Standards Committee Meeting | September 14, 2016 2

12. Request for Interpretation of CIP-006 for Cleco Corporation* ― (Reject) (S. Noess) (10 minutes)

13. Request for Interpretation of BAL-001-2 for Orlando Utilities Commission* ― (Reject) (S. Noess)(10 minutes)

14. Revisions to the NERC Standard Processes Manual Section 6* ― (Endorse) (P. Heidrich) (10minutes)

15. Project 2015-04 Alignment of Terms* ― (Endorse) (SCEC; S. Noess) (10 minutes)

16. Subcommittee Reports and Updates

a. Project Management and Oversight Subcommittee ― (Update) (B. Hampton) (10 minutes)

b. Process Subcommittee* ― (Update) (P. Heidrich) (5 minutes)

c. Functional Model Advisory Group* ― (Update) (P. Heidrich) (5 minutes)

17. Legal Update

a. Upcoming Standards Filings* ― (Review) (L. Perotti) (5 minutes)

18. Informational Items ― (Enclosed)

a. CIP SDT Resignation*

b. 2015-2016 Standards Committee Term Elections* ― (Information) (J. Mallory) (5 Minutes)

c. Standards Committee Expectations*

d. 2016 Meeting Dates and Locations*

e. 2016 Standards Committee Roster*

f. Highlights of Parliamentary Procedure*

g. Standards Committee - Action Without a Meeting Results*

19. Adjourn

*Background materials included.

Antitrust Compliance Guidelines

I. General It is NERC’s policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition. This policy requires the avoidance of any conduct that violates, or that might appear to violate, the antitrust laws. Among other things, the antitrust laws forbid any agreement between or among competitors regarding prices, availability of service, product design, terms of sale, division of markets, allocation of customers or any other activity that unreasonably restrains competition.

It is the responsibility of every NERC participant and employee who may in any way affect NERC’s compliance with the antitrust laws to carry out this commitment.

Antitrust laws are complex and subject to court interpretation that can vary over time and from one court to another. The purpose of these guidelines is to alert NERC participants and employees to potential antitrust problems and to set forth policies to be followed with respect to activities that may involve antitrust considerations. In some instances, the NERC policy contained in these guidelines is stricter than the applicable antitrust laws. Any NERC participant or employee who is uncertain about the legal ramifications of a particular course of conduct or who has doubts or concerns about whether NERC’s antitrust compliance policy is implicated in any situation should consult NERC’s General Counsel immediately.

II. Prohibited ActivitiesParticipants in NERC activities (including those of its committees and subgroups) should refrain from the following when acting in their capacity as participants in NERC activities (e.g., at NERC meetings, conference calls and in informal discussions):

• Discussions involving pricing information, especially margin (profit) and internal costinformation and participants’ expectations as to their future prices or internal costs.

• Discussions of a participant’s marketing strategies.

• Discussions regarding how customers and geographical areas are to be divided amongcompetitors.

• Discussions concerning the exclusion of competitors from markets.

• Discussions concerning boycotting or group refusals to deal with competitors, vendors orsuppliers.

NERC Antitrust Compliance Guidelines 2

• Any other matters that do not clearly fall within these guidelines should be reviewed with NERC’s General Counsel before being discussed.

III. Activities That Are Permitted From time to time decisions or actions of NERC (including those of its committees and subgroups) may have a negative impact on particular entities and thus in that sense adversely impact competition. Decisions and actions by NERC (including its committees and subgroups) should only be undertaken for the purpose of promoting and maintaining the reliability and adequacy of the bulk power system. If you do not have a legitimate purpose consistent with this objective for discussing a matter, please refrain from discussing the matter during NERC meetings and in other NERC-related communications. You should also ensure that NERC procedures, including those set forth in NERC’s Certificate of Incorporation, Bylaws, and Rules of Procedure are followed in conducting NERC business. In addition, all discussions in NERC meetings and other NERC-related communications should be within the scope of the mandate for or assignment to the particular NERC committee or subgroup, as well as within the scope of the published agenda for the meeting. No decisions should be made nor any actions taken in NERC activities for the purpose of giving an industry participant or group of participants a competitive advantage over other participants. In particular, decisions with respect to setting, revising, or assessing compliance with NERC reliability standards should not be influenced by anti-competitive motivations. Subject to the foregoing restrictions, participants in NERC activities may discuss:

• Reliability matters relating to the bulk power system, including operation and planning matters such as establishing or revising reliability standards, special operating procedures, operating transfer capabilities, and plans for new facilities.

• Matters relating to the impact of reliability standards for the bulk power system on electricity markets, and the impact of electricity market operations on the reliability of the bulk power system.

• Proposed filings or other communications with state or federal regulatory authorities or other governmental entities.

Matters relating to the internal governance, management and operation of NERC, such as nominations for vacant committee positions, budgeting and assessments, and employment matters; and procedural matters such as planning and scheduling meetings.

Public Announcements

REMINDER FOR USE AT BEGINNING OF MEETINGS AND CONFERENCE CALLS THAT HAVE BEENPUBLICLY NOTICED AND ARE OPEN TO THE PUBLIC

For face-to-face meeting, with dial-in capability:Participants are reminded that this meeting is public. Notice of the meeting was posted on the NERCwebsite and widely distributed. The notice included the number for dial-in participation. Participantsshould keep in mind that the audience may include members of the press and representatives ofvarious governmental authorities, in addition to the expected participation by industry stakeholders.

Meeting Minutes Standards Committee Conference Call July 20, 2016 | 1:00 p.m. to 4:00 p.m. Eastern

Introduction and Chair’s Remarks Committee Chair Brian Murphy called to order a duly noticed meeting of the Standards Committee (SC or the Committee) on July 20, 2016 at 1:00 p.m. Eastern, with a quorum of SC members. The SC member attendance and proxy sheet is attached hereto as Attachment 1. H. Gugel reviewed the Segment 9 nominations and elections with an expectation that the election may open on July 25, 2016.

NERC Antitrust Compliance Guidelines and Public Announcement Committee Secretary Jordan Mallory called attention to the NERC Antitrust Compliance Guidelines and the public meeting notice. It was mentioned that any specific questions can be directed to NERC’s General Counsel, Charles Berardesco.

Agenda Items

Review Agenda The Committee approved the agenda with a waiver of the five-day rule in effect for Item Number 8’s consideration of the Standard Authorization Request (SAR) by unanimous consent.

Consent Agenda B. Li made the motion to approve the Consent Agenda by unanimous consent; B. Hampton seconded the motion.

June 15, 2016, Standards Committee Meeting Minutes The Committee approved the June 15, 2016 Standards Committee Meeting Minutes by unanimous consent.

SCEC/NERC Staff to work on 2017 SC Meeting Dates. The Committee approved the proposal of the SCEC to work with NERC staff on the 2017 SC meeting dates by unanimous consent.

Upcoming Standards Projects or Issues

Three-Month Outlook S. Noess reviewed the Three-Month Outlook and informed the Committee of FERC’s open meeting that will be held on July 21, 2016. B. Hampton requested an update regarding standards-related activity at FERC.

Projects Under Development Project Tracking Spreadsheet

Agenda Item 2a Standards Committee September 14, 2016

http://www.nerc.com/comm/SC/_layouts/xlviewer.aspx?id=/comm/SC/Project%20Management%20and%20Oversight%20Subcommittee%20DL/Project%20Tracking%20Spreadsheet.xlsx&Source=http%3A%2F%2Fwww%2Eqa%2Enerc%2Ecom%2Fcomm%2FSC%2FProject%2520Management%2520and%2520Oversi

Minutes - Standards Committee Meeting | July 20, 2016 2

B. Hampton reviewed the Project Tracking Spreadsheet and informed the Committee that Scott Barfield-McGinnis is working with the NERC standards developers to ensure that the projects are updated at least monthly.

Projected Posting Schedule S. Noess reviewed the Projected Posting Schedule. J. Bussman questioned the reasoning behind the Functional Model Advisory Group (FMAG) informal comment period. Peter Heidrich noted that the scope document indicated that the FMAG recommendations would be posted for informal comment period and explained that the FMAG would address stakeholder comments in summary form, if necessary.

Project 2016-02 Modifications to CIP Standards J. Bussman made the motion to accept the action item as written; A. Gallo seconded. The action item was as follows:

Authorize the initial posting of (1) proposed Reliability Standard CIP-003-7, (2) the proposed revised term and definition of Low Impact External Routable Communication (LERC) to be incorporated into the NERC Glossary of Terms Used in NERC Reliability Standards (“NERC Glossary”), (3) the proposed retirement of the NERC Glossary term Low Impact Electronic Access Point (LEAP), (4) the Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs), and (5) the associated Implementation Plan for a 45-day formal comment period with initial ballots and nonbinding polls during the last 10 days of the comment period. A new ballot pool will be established during the first 30 days of the 45-day formal comment period. The Standards Committee (SC) also accepts the Standards Authorization Request (SAR), as modified by the drafting team, with this action.

The Committee approved the motion with no objections or abstentions.

Request for Interpretation of CIP-002 (EnergySec) G. Zito made the motion to accept the action item as amended with the removal of the reference to conducting a nonbinding poll; S. Rueckert seconded. The action item as amended was as follows:

Authorize posting of the proposed interpretation of CIP-002-5.1 for EnergySec for a 45-day formal comment period with an initial ballot during the last 10 days of the comment period. A new ballot pool will be established during the first 30 days of the 45-day formal comment period.


Project 2015-08 Emergency Operations G. Zito made the motion to accept the action item as amended to remove the SAR acceptance language, given the SAR had already been accepted by the SC; J. Bussman seconded. The action item as amended was as follows:

Authorize posting Project 2015-08 proposed Reliability Standard EOP-004-4, the associated Implementation Plan, Violation Risk Factors (VRFs), and Violation Severity Levels (VSLs) for

http://www.nerc.com/pa/Stand/Documents/Projected_Posting_Schedule.pdf


45-day formal comment period with parallel initial ballots and nonbinding polls during the last 10 days of the comment period. A new ballot pool will be established during the first 30 days of the 45-day formal comment period.


Project 2015-10 Single Points of Failure Drafting Team Nomination Solicitation G. Zito made the motion to accept the action item as written; S. Miller seconded. The action item was as follows:

Authorize posting for nominations to form a Project 2015-10 Single Points of Failure standard drafting team (SDT). The Standards Committee (SC) also accepts the Standards Authorization Request (SAR) with this action.

G. Zito spoke in support of the motion, citing the FERC directives component of the project.


Grading of Standards B. Murphy stated that the Standing Review Team’s second public meeting for purposes of finalizing grading will be held on August 30, 2016. G. Zito noted that this work will be used to prioritize standards work next year and reminded the Committee that the comment period is open until August 1, 2016.

Subcommittee Reports and Updates Project Management and Oversight Subcommittee (PMOS) B. Hampton provided an update on the recent work of the PMOS and noted that its members would be working with the Standards Committee Process Subcommittee (SCPS) on its SAR Form revision project.

Process Subcommittee P. Heidrich reviewed the one-pager and provided a status update on the remaining projects on the SCPS Work Plan.

Communication Facilitation Project Recommendations G. Zito made the motion to accept the action item as written; Laura Lee seconded. The action item was as follows:

Endorse the Standards Committee Process Subcommittee’s (SCPS) no further action recommendation to establish additional mechanisms for communication among ballot pool members and communication among Standards Committee (SC) members in the same Registered Ballot Body Segments.

G. Zito noted that the Standards Balloting System has the functionality to comment. Several Committee members expressed the desire for listserv functionality. NERC staff noted again the time and technological resource constraints.


The Committee approved the motion with the following Committee members voting against the motion: S. Miller, B. Lawson, A. Gallo, F. McElvain, D. Kiguel, and R. Blohm; B. Hampton abstaining.

Review of Standard Authorization Request (SAR) Form and Development of Generic Questions Project Scope Document G. Zito made the motion to accept the action item as written; C. Yeung seconded. The action item was as follows:

Endorse the attached scope document for a project led by the Standards Committee Process Subcommittee (SCPS) to review the Standards Authorization Request (SAR) Form, and develop a set of common questions for inclusion in the comment form for SAR posting to better streamline the collection of stakeholder opinions on the need and scope of proposed standard development projects.

G. Zito explained that the SAR Form is not current and that it needs to be revised for future projects. B. Li thanked the Committee for their support and welcomed PMOS input.


Standards Committee – Rapid Revisions Procedure J. Bussman made the motion to accept the action item as written; B. Hampton seconded. The action item was as follows:

Endorse the Standards Committee Process Subcommittee’s (SCPS) recommendation to retire the Standards Committee –Rapid Revision Procedure.

J. Bussman explained that processes other than this procedure are currently being used to revise a standard; therefore, this document is not necessary.


Drafting Team Reference Manual Proposed Revisions P. Heidrich asked the Committee to review the contents of the Drafting Team Reference Manual and provide feedback by August 12, 2016.

Functional Model Advisory Group P. Heidrich reviewed the target milestones and reminded the committee of the next meeting on August 30, 2016.

Functional Model (FM) and Functional Model Technical Document (FMTD) After brief discussion was held regarding appropriate length of time for posting, G. Zito made the motion to accept the action item as amended to extend the comment period for a total of 45-days; J. Bussman seconded. The action item as amended was as follows:


Authorize the Functional Model Advisory Group (FMAG) to post proposed revisions to the NERC Functional Model (FM) and Functional Model Technical Document (FMTD) for a 45-day informal comment period.

P. Heidrich noted that extensive consensus building was conducted with members of the NERC technical committees for this document and further reviewed the project timeline.


Legal Update Upcoming Standards Filings L. Perotti reviewed the attached past and upcoming legal filings.

Informational Items No discussion was had on informational items.

Adjourn B. Murphy thanked the Committee members and adjourned at 2:46 p.m. Eastern.

Attachment I

Segment and Term Representative Organization Proxy Present (Member or

Proxy)

Chair 2016‐17

Brian Murphy Senior Attorney

NextEra Energy, Inc. Yes

Vice‐Chair 2016‐17

Michelle D’Antuono Manager, Energy

Occidental Energy Ventures, LLC

Yes

Segment 1‐2015‐16 Lou Oberski Managing Director, NERC Compliance Policy

Dominion Resources Services, Inc.

yes

Segment 1‐2016‐17 Laura Lee Manager of ERO Support and Event Analysis, System Operations

Duke Energy yes

Segment 2‐2015‐16 Charles Yeung Executive Director Interregional Affairs

Southwest Power Pool Yes

Segment 2‐2016‐17 Ben Li Consultant

Independent Electric System Operator

Yes

Segment 3‐2015‐16 John Bussman Manager, Reliability Compliance

Associated Electric Cooperative, Inc.

Yes

Segment 3‐2016‐17 Scott Miller Manager Regulatory Policy

MEAG Power Yes

Segment 4‐2015‐16 Barry Lawson Associate Director, Power Delivery and Reliability

National Rural Electric Cooperative Association

Yes

Segment 4‐2016‐17 Chris Gowder Regulatory Compliance Specialist

Florida Municipal Power Agency

Yes

Segment 5‐2015‐16 Colt Norrish Compliance Director

PacifiCorp Yes

Segment 5‐2016‐17 Randy Crissman Vice President – Technical Compliance

New York Power Authority

Standards Committee Attendance July 20, 2016

Segment and Term Representative Organization Proxy Present (Member or

Proxy)

Segment 6‐2015‐16 Brenda Hampton Director, NERC& TREAffairs

Energy Future Holdings – Luminant Energy Company LLC

Yes

Segment 6‐2016‐17 Andrew Gallo Director, Reliability Compliance

City of Austin dba Austin Energy

Yes

Segment 7‐2015‐16 Marion Lucas APGI Chief Compliance Officer, President & Director

Alcoa Power Marketing LLC Yes

Segment 7‐2016‐17 Frank McElvain Senior Manager, Consulting

Siemens Power Technologies International

Yes

Segment 8‐2015‐16 David Kiguel Independent Yes

Segment 8‐2016‐17 Robert Blohm, Managing Director

Keen Resources Ltd. Yes

Segment 9‐2015‐16 Mark Harris Electrical Engineer

Public Utilities Commission of Nevada

Segment 9‐2016‐17 Vacant N/A

Segment 10‐2015‐16 Steven Rueckert Director of Standards

Western Electricity Coordinating Council

Yes

Segment 10‐2016‐17 Guy Zito Assistant Vice President of Standards

Northeast Power Coordinating Council

Yes

Standards Committee Attendance – July 20, 2016

Three-Month Outlook

Brian Murphy, SC Chair, NextEra Energy Resources, LLCSteven Noess, Director of Standards Development, NERCStandards Committee September 1, 2016

Agenda Item 3aStandards CommitteeSeptember 14, 2016

RELIABILITY | ACCOUNTABILITY2

• September SAR for Modifications to PRC-025-1 (Project 2016-04)

• October None

• November None

Authorize Nomination Solicitations


• September Project 2015-10 Single Points of Failure Project 2016-03 Cyber Security Supply Chain Management

• October SAR for Modifications to PRC-025-1 (Project 2016-04)

• November None

Authorize Team Appointments


• September SAR for Modifications to PRC-025-1 (Project 2016-04)

• October Project 2016-03 Cyber Security Supply Chain Management

• November None

Authorize SAR Postings


• September None

• October Project 2015-09 System Operating Limits (FAC-010, FAC-011, FAC-014) Project 2016-02 Modifications to CIP Standards (TCA at Lows)

• November None

Authorize Initial Postings


• July Order No. 829 Directing Standard for Supply Chain Cyber Controls Order No. 822-A Denying Rehearing of Order No. 822 (approving 7 CIP

Reliability Standards) Notice of Inquiry (NOI) Regarding Cyber Systems in Control Centers

• August Letter Order Approving the Retirement of Regional Reliability Standard PRC-

002-NPCC-01

FERC Orders and NOPRs


Agenda Item 5 Standards Committee September 14, 2016

Project 2016-03 Cyber Security Supply Chain Management Standard Drafting Team

Actions Appoint a drafting team for Project 2016-03 Cyber Security Supply Chain Management (Supply Chain standard drafting team (SDT)) to draft the Standards Authorization Request and new or revised standard(s), as follows:

1. Appoint candidates 1 through 11 on the attached recommendation to form the SDT

2. Appoint candidate 10 and candidate 8 on the attached recommendation to serve aschair and vice-chair, respectively

Background On July 21, 2016, the Federal Energy Regulatory Commission (Commission) issued Order No. 829 directing NERC to develop a new or modified Reliability Standard that addresses supply chain risk management for industrial control system hardware, software, and computing and networking services associated with Bulk Electric System (BES) operations as follows:

"[The Commission directs] NERC to develop a forward-looking, objective-based Reliability Standard to require each affected entity to develop and implement a plan that includes security controls for supply chain management for industrial control system hardware, software, and services associated with bulk electric system operations. The new or modified Reliability Standard should address the following security objectives, [discussed in detail in the Order]: (1) software integrity and authenticity; (2) vendor remote access; (3) information system planning; and (4) vendor risk management and procurement controls."

In Order No. 829, the Commission established a filing deadline of September 27, 2017 for the new Reliability Standard.

NERC staff received over fifty nominations in response to the solicitation for members to form the Supply Chain SDT. The eleven nominees for the Supply Chain SDT in the attached recommendation were selected on the basis of their management experience or expertise in the objectives outlined in Order No. 829, in addition to leadership and communication skills and background in policy, regulatory, compliance, and legal matters. The recommended Supply Chain SDT is diverse in industry segments, functions, and regions and is well suited for developing requirements that are applicable across the North American Bulk Power System.

The recommended chair and vice-chair are respected industry leaders with exceptional consensus-building and facilitation skills in addition to their subject matter expertise.

NERC Staff will encourage all those not selected to actively participate with the Supply Chain SDT as observers and through the standards development process.

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order_SupplyChain_20160721_RM15-14.pdf



Project 2015-10 Single Points of Failure Standard Drafting Team

Actions Appoint a standard drafting team (SDT) for Project 2015-10 Single Points of Failure as follows:

1. Appoint candidates 1 through 10 on the attached recommendation to form the SDT; and

2. Appoint candidate 9 and candidate 2 on the attached recommendation to serve as chairand vice-chair, respectively.

Background On July 20, 2016, the Standards Committee (SC) accepted the revised Standard Authorization Request (SAR) for Project 2015-10.

As set forth in the SAR, the scope of Project 2015-10 is to:

• consider recommendations of the System Protection and Control Subcommittee (SPCS)and System Analysis and Modeling Subcommittee (SAMS) to modify Reliability StandardTPL-001-4 (Transmission System Planning Performance Requirements)1 to minimize thepotential risk of single points of failure;

• address two directives from FERC’s Order No. 7862; and

• replace references to MOD-010 and MOD-012 in the TPL-001-4 standard, which areretired as of July 2016, with MOD-032.

The recommended chair and vice-chair are respected industry leaders with exceptional consensus-building and facilitation skills in addition to their subject matter expertise.

NERC Staff will encourage all those not selected to actively participate with the Single Points of Failure SDT as observers and throughout the standards development process.

1 The recommended modifications address specifics of Protection System component failure, aspects of steady state and stability performance testing, and expansion of extreme event assessment requirements. See [Order No. 754: Assessment of Protection System Single Points of Failure Based on the Section 1600 Data Request]. This assessment was prepared in response to FERC’s Order No. 754. See Interpretation of Transmission Planning Reliability Standard, Order No. 754, 136 FERC ¶ 61,186 (2011) (http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20754%20-%20Approving%20Interp%20TPL-002-0%202011.9.15.pdf. 2 Transmission Planning Reliability Standards, Order No. 786, 145 FERC ¶ 61,051 (2013) (“Order No. 786”) (http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/E-2%20Transmission%20PLanning%20Rel.%20Strd.pdf). Specifically, FERC directed NERC to: (i) modify Reliability Standard TPL-001-4 to address the concern that the six-month threshold could exclude planned maintenance outages of significant facilities from future planning assessments (P 40); and (ii) consider similar spare equipment strategy for stability analysis upon the next review cycle of Reliability Standard TPL-001-4 (P 89).

http://www.nerc.com/comm/PC/System%20Protection%20and%20Control%20Subcommittee%20SPCS%2020/FERC%20Order%20754%20Final%20Report%20-%20SPCS-SAMS.pdf

http://www.nerc.com/comm/PC/System%20Protection%20and%20Control%20Subcommittee%20SPCS%2020/FERC%20Order%20754%20Final%20Report%20-%20SPCS-SAMS.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20754%20-%20Approving%20Interp%20TPL-002-0%202011.9.15.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20754%20-%20Approving%20Interp%20TPL-002-0%202011.9.15.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/E-2%20Transmission%20PLanning%20Rel.%20Strd.pdf

Agenda Item 7 Standards Committee

September 14, 2016

Project 2016-04 – Modifications to PRC-025-1

Action Authorize posting the Standards Authorization Request (SAR) for a 30-day formal comment period and authorize solicitation of nominations to form a 2016-04 Modifications to Reliability Standard PRC-025-1 SAR drafting team, which will be no less than 20 days.

Background Reliability Standard PRC-025-1 (Generator Relay Loadability), which was approved by the Federal Energy Regulatory Commission in Order No. 799 issued on July 17, 2014, became effective on October 1, 2014. Under the phased implementation plan, applicable entities have between five and seven years to become compliant with the standard depending on the scope of work required by the Generator Owner. In the course of implementing the standard, four specific issues have been identified.

Allen Schriver, Chief Operating Officer of the North American Generator Forum (NAGF), communicated that the forum has reviewed the proposed SAR to revise PRC-025-1 and endorses its authorization to post for formal industry comment. The NAGF notes that the core issues described in the SAR have an impact to the Standard, compliance, and reliability and need to be addressed. The NAGF believes the goals of the SAR will allow the revised Standard to provide for adequate protection for asynchronous generating resources while closing gaps and ensuring the technical basis for the development of the Standard is met.

Summary The SAR proposes that the PRC-025-1 standard be revised to provide: (1) an alternative loadability margin for dispersed generation resources; (2) revised to provide an inclusion or exclusion of the 50 overcurrent element, (3) clarification on whether the Elements in the “Application” column of Table 1 of PRC-025-1 that have two applications separated by an “or” conjunction should both be included or may one or the other be selected; and (4) alternative or additional Option(s) (e.g., calculation or method) for determining loadability settings for relays that are directional toward the transmission.

Item #1 above was identified by a Regional Entity while monitoring the standard during its five and seven year implementation period. It was discovered that loadability criteria specific DGR applications may result in an overly conservative protection setting due to physical limitations of some existing DGR. The absence of additional criteria in the standard to allow alternative loadability margins, particularly for DGR with non-adjustable protection settings, will result in instances of noncompliance.

Item #2 above was identified when NERC staff responded to questions about non-standard applications for generator protection using an Instantaneous overcurrent element. Based on discussions, it is clear that generator entities could apply a non-standard relay application that

Agenda Item 7 Standards Committee

September 14, 2016 could undermine the goal of the standard, which is to prevent generator units from tripping unnecessarily. Item #3 above was raised by an industry stakeholder that settings could be applied to a limited set of elements. For example, options in the standard could lead entities to apply settings on the DGR collector bus, but not the individual DGR units. This could lead to common mode tripping of DGR units, if not applied to the units as well, and undermine the goal of the standard to prevent unnecessary tripping. Item #4 above was identified by a northeastern Canadian stakeholder during implementation and concerns generating plants that are remote to the transmission system. For generating plants with interconnecting lines in excess of 20 miles, for example, the line impedance becomes a factor in the available generation reactive output, which is the basis for the relay margin settings criteria in the standard. Since the standard does not incorporate a provision for line impedance, the criteria can result in an overly conservative setting and limit the ability to provide adequate backup protection for the interconnecting line. The issue could affect generating plants across North America.

Standards Authorization Request Form

NERC welcomes suggestions to improve the reliability of the bulk power system through improved Reliability Standards. Please use this form to submit your request to propose a new or a revision to a NERC Reliability Standard.

Request to propose a new or a revision to a Reliability Standard

Title of Proposed Standard: PRC-025-1 – Generator Relay Loadability

Date Submitted: August 25, 2016

SAR Requester Information for #1

Name: Rich Quest

Organization: Midwest Reliability Organization

Telephone: (651) 855-1704 Email: [email protected]


Name: Jerry Thompson, E.I.T.

Organization: Kestrel Power Engineering



Name: Joe DePoorter

Organization: Madison Gas & Electric


When completed, please email this form to:

[email protected]


mailto:[email protected]




Standards Authorization Request Form (DRAFT PRC-025-1) 2

Request to propose a new or a revision to a Reliability Standard


Name: Éric Loiselle, ing.

Organization: Hydro-Québec TransÉnergie


SAR Type (Check as many as applicable)

New Standard

Revision to Existing Standard

Withdrawal of Existing Standard

Urgent Action

SAR Information

Industry Need (What is the industry problem this request is trying to solve?):

This SAR proposes revising PRC-025-1 for four specific problems.

1. Prevent instances of non-compliance for conditions where the Generator Owner may be prevented from achieving the margin specified by the standard for dispersed generation resources (DGR).

2. Prevent a lowering of reliability and potential non-compliance where the Generator Owner might apply a non-standard relay element application and undermine the goal of the standard.

3. Prevent a lowering of reliability where the Generator Owner might only apply part of the Table 1 application(s) thereby misapplying the loadability margins to relays for the stated application(s).

4. Prevent a lowering of dependability of protective relays directional toward the transmission system at generating facilities that are remote to the transmission network.

Purpose or Goal (How does this request propose to address the problem described above?):

Consider revising the PRC-025-1 standard through the standards development process to: (1) provide alternative loadability Options for Table 1 specific to DGR; (2) address the inclusion or exclusion of the 50 element (i.e., instantaneous), (3) review Table 1 for proper application where there is more than one application for the available Option(s), and (4) provide alternative or additional Options for Table 1 specific to relay applications that are directional toward the transmission system where the interconnecting transmission line impedance may be a factor in determining the maximum reactive output of the generators and associated relay settings.



SAR Information

Identify the Objectives of the proposed standard’s requirements (What specific reliability deliverables are required to achieve the goal?):

This SAR proposes the need for revising PRC-025-1 for four specific problems.

1. PRC-025-1, Table 1 requires setting the overcurrent relay of a Protection System applied to an asynchronous generating unit or an Element utilized in the aggregation of DGR to a margin greater than 130% of the calculated current derived from the maximum aggregate nameplate MVA output at rated power factor. This may result in instances of non-compliance due manufacturer requirements or physical limitations of DGR and may result in an overly conservative relay setting. Consider revising the standard to provide alternative options for setting the overcurrent element of a Protection System applied to an asynchronous generating unit and an Element utilized in the aggregation of DGR.

2. There is potential for Generator Owners to apply a pick up setting of the 50 element (i.e., instantaneous overcurrent) of a Protection System, which is not applicable to the standard, that is lower than the minimum pick up established by the standard for the 51 element (i.e., time delayed overcurrent). The 50 element is generally not used in the generator applications where the 51 element is found in the standard. Consider revising the standard to address the inclusion or exclusion of the 50 element for the various overcurrent applications within Table 1.

3. There is potential for Generator Owners not to apply loadability margins to all load-responsive protective relays in Table 1 of PRC-025-1 under the “Application” column that may affect loadability. For example, the Application column from Table 1 (Options 4, 5, and 6):

“Asynchronous generating unit(s) (including inverter-based installations), or Elements utilized in the aggregation of dispersed power producing resources.”

The above clause is separated by an “or” conjunction and may lead the Generator Owner to set one particular application and not the other. This may create a gap in achieving the goal of the standard when loadability margins are not applied to relays on certain Elements. Consider revising the standard to make it clear whether either or both of the listed Elements in the Application column of Options 1-6 must meet the criteria of the particular Option.

4. In the case of remote generating facilities that are electrically weak at its connection to the transmission network, the maximum reactive power required by the specific Table 1 Options is too high to be observed in any recoverable stressed condition. This is due to the system impedance (mainly line impedance) restricting the maximum reactive power output by the generator, no matter the generator characteristics. Lastly, applying the existing Table 1 Options for relay applications directional toward the transmission system results in an overly


SAR Information

conservative relay setting and could require reducing the backup protection coverage in order to comply with the stressed system condition anticipated by the standard.

Brief Description (Provide a paragraph that describes the scope of this standard action.)

The PRC-025-1 standard became effective on October 1, 2014 and has a phased implementation of five and seven years (i.e., 2019 or 2021) depending on the scope of work required by the Generator Owner. During the early stages of implementation, the above four problems were revealed by industry. The scope of work will be to consider providing (1) an alternative loadability margin for DGR, (2) revision that includes or excludes 50 element for overcurrent applications, (3) clarification of the application of the Elements in Table 1 of PRC-025-1 for each option that has two applicable Elements separated by an “or” conjunction, and (4) alternative or additional Option(s) (e.g., calculation or method) for determining loadability settings for relays that are directional toward the transmission.

Detailed Description (Provide a description of the proposed project with sufficient details for the standard drafting team to execute the SAR. Also provide a justification for the development or revision of the standard, including an assessment of the reliability and market interface impacts of implementing or not implementing the standard action.)

1. Consider revising the PRC-025-1 standard concerning #1 above through the standards development process to provide a means to determine alternative loadability Options for Table 1 of the standard specific to DRG equipment where there could be a manufacturer requirement or physical equipment limitation. Similar to the provisions already contained in the standard, consider methods that would eliminate the potential for non-compliance and/or a violation of manufacturer specifications. For example: (a) a provision could allow a margin consistent with the manufacturer’s requirements or based on the limitation of the equipment; (b) a provision to allow the DRG output to be studied through simulation (e.g., similar to Options 1c and 2c) and the relays to be set with an appropriate margin determined through the standard development process; (c) a provision to exempt equipment with fixed limitations installed prior to the effective date of PRC-025-1 or other justifiable date; and/or (d) any other equally effective and efficient method to accomplish the goal.

2. Consider revising the PRC-025-1 standard concerning #2 above to address the inclusion or exclusion of the 50 element (i.e., instantaneous overcurrent) of a Protection System with or without intentional time delay. Newer techniques in generator protection applications may result in a gap due to non-traditional applications of generator overcurrent relays.


SAR Information

3. Consider revising the PRC-025-1 standard concerning #3 above through the standards development process to bring awareness and clarification whether either or both of the Elements listed in the “Application” column of Table 1, Options 1-6 are to have loadability margins applied to the load-responsive protective relays.

4. Consider revising the PRC-025-1 standard concerning #4 above through the standards development process to provide a means to determine alternative loadability Option(s) for Table 1 of the standard specific to relays directional toward the transmission system. Similar to the provisions already contained in the standard, consider: (a) alternative Options for relay settings where the interconnecting transmission line impedance has a significant impact the maximum reactive output of the generating facility and the associated relay settings, (b) the technical validity of the existing options in the presence of significant transmission line impedance between generation and the network, and/or (c) any other equally effective and efficient method to address the problem of significant line impedance effecting how phase protective relays are set not limit generator loadability while maintaining reliable protection of the BES for all fault conditions.

Reliability Functions

The Standard will Apply to the Following Functions (Check each one that applies.)

Reliability Coordinator Responsible for the real-time operating reliability of its Reliability Coordinator Area in coordination with its neighboring Reliability Coordinator’s wide area view.

Balancing Authority Integrates resource plans ahead of time, and maintains load-interchange-resource balance within a Balancing Authority Area and supports Interconnection frequency in real time.

Interchange Authority Ensures communication of interchange transactions for reliability evaluation purposes and coordinates implementation of valid and balanced interchange schedules between Balancing Authority Areas.

Planning Coordinator Assesses the longer-term reliability of its Planning Coordinator Area.

Resource Planner Develops a one year plan for the resource adequacy of its specific loads within a Planning Coordinator area.



Transmission Planner Develops a one year plan for the reliability of the interconnected Bulk Electric System within its portion of the Planning Coordinator area.

Transmission Service Provider

Administers the transmission tariff and provides transmission services under applicable transmission service agreements (e.g., the pro forma tariff).

Transmission Owner Owns and maintains transmission facilities.

Transmission Operator

Ensures the real-time operating reliability of the transmission assets within a Transmission Operator Area.

Distribution Provider Delivers electrical energy to the end-use customer.

Generator Owner Owns and maintains generation facilities.

Generator Operator Operates generation unit(s) to provide real and reactive power.

Purchasing-Selling Entity

Purchases or sells energy, capacity, and necessary reliability-related services as required.

Market Operator Interface point for reliability functions with commercial functions.

Load-Serving Entity Secures energy and transmission service (and reliability-related services) to serve the end-use customer.

Reliability and Market Interface Principles

Applicable Reliability Principles (Check all that apply).

1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions as defined in the NERC Standards.

2. The frequency and voltage of interconnected bulk power systems shall be controlled within defined limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected bulk power systems

shall be made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected bulk power systems shall be developed, coordinated, maintained and implemented.

5. Facilities for communication, monitoring and control shall be provided, used and maintained for the reliability of interconnected bulk power systems.



6. Personnel responsible for planning and operating interconnected bulk power systems shall be trained, qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected bulk power systems shall be assessed, monitored and maintained on a wide area basis.

8. Bulk power systems shall be protected from malicious physical or cyber attacks.

Does the proposed Standard comply with all of the following Market Interface Principles?

Enter

(yes/no)

1. A reliability standard shall not give any market participant an unfair competitive advantage.

Yes

2. A reliability standard shall neither mandate nor prohibit any specific market structure.

Yes

3. A reliability standard shall not preclude market solutions to achieving compliance with that standard.

Yes

4. A reliability standard shall not require the public disclosure of commercially sensitive information. All market participants shall have equal opportunity to access commercially non-sensitive information that is required for compliance with reliability standards.

Yes

Related Standards

Standard No. Explanation

None.

Related SARs

SAR ID Explanation

None.


Related SARs

Regional Variances

Region Explanation

ERCOT None.

FRCC None.

MRO None.

NPCC None.

RFC None.

SERC None.

SPP None.

WECC None.

Version History

Version Date Owner Change Tracking 1 June 3, 2013 Revised

1 August 29, 2014 Standards Information Staff Updated template



2017-2019 Reliability Standards Development Plan

Action Endorse the Reliability Standards Development Plan 2017-2019 (RSDP).

Background The draft 2017-2019 RSDP focuses on conducting Enhanced Periodic Reviews (EPRs), as well as targeting emerging risks, addressing FERC directives, and responding to standards authorization requests. NERC and the Standards Committee will continue to work with NERC committees and task forces to bridge any potential reliability gaps and risks.

A draft RSDP was circulated for Standards Committee comment from May 16-26, 2016. The majority of comments received were incorporated in the 2017-2019 RSDP. Those comments not included are targeted for inclusion in the revised template for the 2018-2020 RSDP.

The industry comment period was conducted from June 20-July 19 2016. The RSDP will be presented to the NERC Board of Trustees in November 2016.

Standards Grading

Steven Noess, NERC Director of Standards DevelopmentGuy Zito, Assistant Vice President of Standards, NPCCSeptember 14, 2016



• Standards Grading: Beginning in 2016 Modeled after Independent Expert Review Panel templateo Contento Quality

All Standards eligible for Enhanced Periodic Review (EPR) also eligible for grading

EPR Standing Review Team: o Chairs of Operating Committee (OC), Planning Committee (PC), and

representatives from NERC and Regionso Meetings facilitated by Chair of the Standards Committee (SC)

Stakeholder input Grades are input into EPRs and attached to Reliability Standards

Development Plan (RSDP)

Standards Grading


• BAL-001• FAC-008-3• PRC family• INT INT-004 INT-006 INT-009 INT-010

• EOP EOP-010 EOP-011

• VAR: VAR-001 VAR-002

• PER PER-001 PER-003 PER-004

Standards Grading

Standards graded from the 2016-2018 RSDP


• Initial Grading Session June 22, 2016 in Atlanta Focused on resolving significant deltas:o For the decision-making tree portion of the grading, this involved any

disagreement over a requirement proposed to be deletedo For Content, this involved any grading of three versus any other gradeo For Quality, it only involved disagreements of at least three points

• Stakeholder Comment Initial grading posted for stakeholder comment Comments will instruct final Standing Review Team (SRT) grading

Standards Grading


• Second Grading Session – EPRSRT August 2016 in Atlanta Focused on resolving significant deltas not resolved in the initial grading

session using stakeholder input Final grades appended to RSDP Final grades will be starting point for EPRTs’ work, along with additional

information collected, as required under the EPR template

Standards Grading


• 2017 and Beyond Process to be repeated each year until standard has a Steady State grade If any EPR team determines, and stakeholders approve revisions to a

standard requirement that was graded in 2016, the SRT shall re-grade the standard requirement based on the revision o The re-graded requirement(s) will also be posted for stakeholder comment for at

least 10 business days prior to SRT finalizing

Standards Grading


NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 I

DRAFT Reliability Standards Development Plan

2017–2019

June 15, 2016

Agenda Item 8b

Standards Committee

September 14, 2016

NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 ii

Table of Contents

Background ................................................................................................................................................................ iv

Executive Summary .................................................................................................................................................... v

2016 Progress Report .................................................................................................................................................1

FERC Directives ......................................................................................................................................................1

Projects Completed in 2016 ..................................................................................................................................1

2017 Projects ..............................................................................................................................................................2

Projects Continuing from 2016 into 2017 .............................................................................................................2

High Priority ......................................................................................................................................................2

Medium Priority ................................................................................................................................................3

Medium to Low Priority ....................................................................................................................................3

Projects Commencing in 2017 ...............................................................................................................................4

Standards Cost Effectiveness Pilot ........................................................................................................................4

Enhanced Periodic Reviews ...................................................................................................................................4

Standards Grading Metric......................................................................................................................................5

Interpretations.......................................................................................................................................................6

Feedback Loops (Factors for Consideration of Risk) .............................................................................................6

Compliance Monitoring Enforcement Program Feedback ...............................................................................6

Construct of Standards .....................................................................................................................................6

Coordination with the North American Energy Standards Board (NAESB) ......................................................6

Emerging Risks and Changing Technologies .....................................................................................................7

Event Analysis and Compliance Violation Statistics .........................................................................................7

Lessons Learned and Frequently Asked Questions ..........................................................................................7

Measures ..........................................................................................................................................................7

Rationale and Guidelines ..................................................................................................................................7

Regional Variances ............................................................................................................................................7

Request for Interpretations ..............................................................................................................................7

RSAW Development and Compliance Input .....................................................................................................8

Standard Authorization Requests .....................................................................................................................8

Surveys and Polls ..............................................................................................................................................8

Attachment 1 - Enhanced Periodic Review Guidelines ..............................................................................................9

Standards Eligibility ................................................................................................................................................9

Criteria for What Makes a Standard Eligible: ...................................................................................................9

Criteria for What Makes a Standard Not Eligible: ......................................................................................... 10

Table of Contents

NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 iii

Prioritization ....................................................................................................................................................... 10

Attachment 2 – Final Standards Grading for Standards Graded in 2016 ................................................................ 11

NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 iv

Background

The 2016–2018 Reliability Standards Development Plan (RSDP) set forth a transitional plan to bring the body of NERC Reliability Standards to the initial stage of “steady state”1 by addressing remaining Federal Energy Regulatory Commission (FERC) directives and recommendations to retire standard requirements. It specifically included the Integration of Variable Generation Task Force and Essential Reliability Services Working Group (ERSWG) recommendations, and called for continued communication with the Reliability Issues Steering Committee (RISC) on emerging risks. The 2016-2018 RSDP recognized the need to address subsequent FERC directives and Standard Authorization Requests (SARs), and the need to enhance communication through industry feedback loops. The 2016-2018 RSDP also planned for initial Enhanced Periodic Reviews (EPR) of the PER and VAR standards, which successfully commenced in 2016. Pursuant to the NERC Rules of Procedure, section 310, NERC is required to develop and provide to applicable governmental authorities an annual RSDP for Reliability Standards development. NERC is also required to consider the comments and priorities of the applicable governmental authorities in developing and updating the annual RSDP. Each annual RSDP must include a progress report comparing results achieved to the prior year’s RSDP. NERC also includes the NERC Standards Committee review during RSDP development, and posts the RSDP for industry comment.

1 For the purposes of the RSDP, “steady state” means a stable set of clear, concise, high‐quality, and technically sound Reliability Standards that are results-based, including retirement of requirements that do little to promote reliability.

NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 v

Executive Summary

The 2017–2019 RSDP recognizes the diligent work of the last few years to bring the body of NERC Reliability Standards to the initial stage of steady state while transitioning to focusing on EPRs, FERC directives, emerging risks, SARs, and the standards grading initiative. The 2017-2019 RSDP contemplates that the work of the ERSWG may result in one or more SARs and subsequent standards projects. As with the 2016-2018 RSDP, EPRs will occur at a measured pace, compared to the level of activity and pace of standards development during the past three years,2 and they will be aligned with strategic considerations of reviewing standard families3 that are interrelated. The addition of the standards grading metric, which uses an enhanced version of the template developed by the Independent Experts Review Panel (IERP), will inform the EPRs as to the quality and content of the standards.4 The 2017-2019 RSDP also includes plans for completing the EPRs initiated in 2016, and for commencing additional EPRs in 2017. While most of the work in the next three years will focus on EPRs, there may be new or emerging risks identified that would generate new standards development projects. NERC and the Standards Committee will continue to seek input and recommendations from the RISC with regard to emerging or potential risks to reliability that may require revisions to existing standards or new standards development. The 2017-2019 RSDP provides insight into standards development activities anticipated at the time of publication so that stakeholders may make available appropriate resources to accomplish these standards development objectives.

2 The Standards Committee approved an EPR template on September 30, 2014 and presented it to the NERC Board of Trustees on November 12, 2014 as part of the Standard Committee’s update. The template includes background information and questions to guide a comprehensive review of the standard(s) by the EPR team, and serves as documentation of the EPR team’s considerations and recommendations. 3 In some cases, a narrower review of a standard will likely be appropriate. For example, there are not necessarily other interrelated standards with FAC-003. 4 The EPR standing review team will grade the standards. The team includes representatives from NERC, the Regions, and the NERC technical committees. Grading will occur prior to conducting the EPR. If there is a change in the standard due to EPR recommendations and subject to the standards development process, the EPR standing review team will re-grade the standard with the revised language.

NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 1

2016 Progress Report

FERC Directives As of June 30, 2016, there are 31 outstanding FERC directives.5 FERC issued some directives pertaining to groups outside of NERC Standards, such as the NERC technical committees and other NERC departments (e.g., topics related to reliability assessment, performance analysis, etc.), and are not included in this count.

Projects Completed in 2016 The 2016–2018 RSDP identified eight projects initiated in 2016 or continued from 2015. All of the projects listed therein have been completed in 2016 or are planned to be completed in 2016, except for Project 2015-08: Emergency Operations, Project 2015-10: Single Points of Failure TPL-001, and Project 2015-09: System Operating Limits, which are expected to be completed in 2017. The following projects have been or will be completed in 2016:

Projects from the 2016–2018 RSDP

1. Project 2009-02 Real-time Reliability Monitoring and Analysis Capabilities

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

3. Project 2010-07.1 Vegetation Management

4. Project 2010-14.2.1: Phase 2 of Balancing Authority Reliability-based Controls (BAL-005-1, BAL-006-2)

5. Project 2010-14.2.2: Phase 2 of Balancing Authority Reliability-based Controls (BAL-004-2)

6. Project 2015-07 Internal Communications Capabilities

5 These directives include FERC considerations for future standards development.


2017 Projects

Projects Continuing from 2016 into 2017 The approach to prioritizing Reliability Standards projects in this RSDP is consistent with previous RSDPs. Specific elements include: (1) RISC Category Rankings; (2) regulatory directives and deadlines; (3) Reliability Standard requirements recommended for retirement; (4) the IERP content and quality assessments; and (5) additional considerations (fill-in-the-blank status and five-year assessment commitments). The prioritization considers RISC category rankings, regulatory directives, and regulatory deadlines. Based on the application of these elements, this section prioritizes each Reliability Standard project as high, medium, low, or pending technical committee input.

High Priority

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

This project will address two directives and consider other improvements to TPL‐001‐4 — Transmission System Planning Performance Requirements. There are no remaining time-sensitive directives.

o From FERC Order No. 786

– Paragraph 40 directs NERC to modify Reliability Standard TPL‐001‐4 to address the concern that the six-month threshold could exclude planned maintenance outages of significant facilities from future planning assessments.

– Paragraph 89 directs NERC to consider a similar spare equipment strategy for stability analysis upon the next review cycle of Reliability Standard TPL‐001‐4.

RISC: overall risk priority is moderate for protection system and single points of failure (risk profile #3B).

IERP considerations: minor quality and content on possible P81 candidates.

Project 2016-01: Modifications to TOP and IRO Standards

Modifications to the TOP and IRO standards developed in this project address reliability concerns identified in FERC Order No. 817 as described below.

o From FERC Order No. 817:

– Paragraph 35 directs NERC to revise Reliability Standard TOP-001-3, Requirement R10 to require real-time monitoring of non-BES facilities. We believe this is best accomplished by adopting language similar to Reliability Standard IRO-002-4, Requirement R3, which requires Reliability Coordinators to monitor non-bulk electric system facilities to the extent necessary.

– Paragraph 47 directs NERC to modify Reliability Standards TOP-001-3, Requirements R19 and R20 to include the requirement that the data exchange capabilities of the Transmission Operators and Balancing Authorities require redundancy and diverse routing.

– Paragraph 47 directs NERC to clarify that “redundant infrastructure” for system monitoring in Reliability Standards IRO-002-4, Requirement R4 is equivalent to redundant and diversely routed data exchange capabilities.

– Paragraph 51 directs NERC to develop a modification to the TOP and IRO standards that addresses a data exchange capability testing framework for the data exchange capabilities used in the primary control centers to test the alternate or less frequently used data

2017 Projects


exchange capabilities of the Reliability Coordinator, Transmission Operator and Balancing Authority.

RISC: overall risk priority is moderate for the loss of situational awareness (Risk Profile #3C).


Project 2016-02: Modifications to CIP Standards

This project will modify the CIP family of standards to address issues identified by the CIP V5 Transition Advisory Group, FERC directives contained in Order 822 as explained below; and requests for interpretations.


– Paragraph 32 directs that NERC, pursuant to section 215(d)(5) of the FPA, develop modifications to the CIP Reliability Standards to provide mandatory protection for transient devices used at Low Impact BES Cyber Systems based on the risk posed to bulk electric system reliability. While NERC has flexibility in the manner in which it addresses the Commission’s concerns, the proposed modifications should be designed to effectively address the risks posed by transient devices to Low Impact BES Cyber Systems in a manner that is consistent with the risk-based approach reflected in the CIP version 5 Standards.

– Paragraph 53 directs that NERC, pursuant to section 215(d)(5) of the FPA, develop modifications to the CIP Reliability Standards to require responsible entities to implement controls to protect, at a minimum, communication links and sensitive bulk electric system data communicated between bulk electric system Control Centers in a manner that is appropriately tailored to address the risks posed to the bulk electric system by the assets being protected (i.e., high, medium, or low impact).

– Paragraph 64 directs NERC to conduct a study that assesses the effectiveness of the CIP version 5 remote access controls, the risks posed by remote access-related threats and vulnerabilities, and appropriate mitigating controls for any identified risks. NERC should consult with Commission staff to determine the general contents of the directed report. We direct NERC to submit a report on the above outlined study within one year of the implementation of the CIP version 5 Standards for High and Medium Impact BES Cyber Systems.

– Paragraph 73 directs NERC to develop a modification to provide the needed clarity, within one year of the effective date of this Final Rule. We agree with NERC and other commenters that a suitable means to address our concern is to modify the Low Impact External Routable Connectivity definition consistent with the commentary in the Guidelines and Technical Basis section of CIP-003-6.

RISC: overall risk priority is high for cyber security vulnerabilities (risk profile #4A).

IERP considerations: not addressed, as they require specialized expertise.

Medium Priority

Project 2015-08: Emergency Operations

No FERC directives (FERC guidance has been provided to this project)

RISC : medium-priority area (coordinated attack on multiple facilities), low-priority areas (extreme weather/acts of nature)

RISC: medium-priority area (coordinated attack on multiple facilities), low-priority areas (extreme weather/acts of nature)

2017 Projects


IERP considerations: minor quality and content on possible P81 candidates

Project 2015-09: System Operating Limits

No FERC directives

RISC: high-priority area (Situational Awareness)


2016-EPR-01: Enhanced Periodic Review of Personnel Performance, Training, and Qualifications Standards - PER-001, PER-003, PER-004

2016-EPR-02: Enhanced Periodic Review of Voltage and Reactive Standards - VAR-001, VAR-002

Medium to Low Priority The following requests for interpretation have commenced in 2016:

Project 2015-INT-01: Interpretation of CIP-002-5.1 for EnergySec

Project 2015-INT-03: Interpretation of TOP-002-2.1b for FMPP

Projects Commencing in 2017 The following projects should commence in 2017. Not all projects have SARs, which will be developed and presented to the Standards Committee at the appropriate time to initiate the project.

At least two EPRs that may recommend revisions to standards.

Emerging risks, if any, with input from the RISC on whether a standard is needed.

Potential modifications to existing standards that respond to FERC directives.

Standards Cost Effectiveness Pilot Federal, state, and provincial regulatory authorities, the NERC Board of Trustees, Regional Entities, and many industry stakeholders have expressed interest in identifying the costs incurred from implementing NERC Reliability Standards compared to risks addressed. The desire is to balance costs and risks during the standards development and revision process. Therefore, in 2016 NERC developed and implemented Phase 1 of its Standards Cost Effectiveness Pilot to inform the Project 2015-10: Single Points of Failure TPL-001 drafting team on potential implementation costs.6 Phase 2 of the pilot is expected to be completed in 2016 or 2017.

Enhanced Periodic Reviews Periodic reviews provide a wide view of the standards to determine whether a particular group of standards is effective. Attachment 1 to the RSDP contains the “Enhanced Periodic Review Guidelines” that further explain standards prioritization and selection criteria. The following EPRs commenced in 2016:

PER-001, PER-003, and PER-004

VAR-001 and VAR-002

6 Please see the Cost Effectiveness Pilot web page at http://www.nerc.com/pa/Stand/Pages/CostEffectivenessPilot.aspx for additional information on this initiative.

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

2017 Projects


The following EPRs are eligible to commence in 2017.7 At least two EPRs will commence in 2017 selected from the following set of eligible standards:

BAL and INT families of standards (BAL-001, INT-004, INT-006, INT-009, and INT-010)

EOP-010

FAC-003-4

FAC-008-3

NUC-001-3

PRC family of standards (PRC-004-5(i), PRC-005-6, PRC-006-2, PRC-010-2, PRC-018-1, PRC-019-2, PRC-023-4, PRC-024-2, PRC-025-1, and PRC-026-1)

Standards Grading Metric In 2016, NERC implemented a standards grading metric to grade all standards eligible for an EPR, which requires that the standard be in effect in the United States (compliance enforcement date) for at least one year. The EPR standing review team grades the standards using an enhanced version of the IERP grading template. Standards grades are harmonized in public meetings with the initial EPR standing review team grades posted for stakeholder comment. After consideration of comments, the EPR standing review team finalizes the grades and provides the results to the EPR teams, which are comprised of the standing review team and industry subject matter experts tasked with implementing the EPR to completion. Final grades are included as Attachment 2 for informational purposes. The grading will also assist in prioritizing future EPRs. For example, if the grading indicates a gap or a significant need to increase the quality or content of a standard or standard family, that set of standards may have a higher priority over standards and standard families that have high quality and content grades. If an EPR recommendation results in a revised standard, that standard will be re-graded, and the new grade will be attached to a future RSDP for informational purposes. In 2017, the grading metric will be applied to the standards that are eligible for an EPR to start in 2017, time and resources permitting. In 2017, the grading will occur in the first half of the year, which will assist in the prioritizing of EPRs in 2017 and 2018. The following non-CIP standards become eligible for standards grading in 2017:8

BAL-003-1.1

COM-001-2.1

COM-002-4

FAC-001-2

FAC-002-2

IRO-009-2

MOD-032-1

TPL-001-4 In 2018, the TOP and IRO families of standards would be eligible for grading and EPR.

7 For reference, the following standards will be eligible for EPRs in 2018 and 2019: EOP-011-1, BAL-003-1.1, COM-001-2.1, COM-002-4, FAC-001-2, FAC-002-2, IRO-009-2, MOD-032-1, MOD-031-2, and TPL-001-4. 8 For reference, in 2018 the TOP and IRO families of standards will be eligible for standards grading and EPR.

2017 Projects


Interpretations Pursuant to section 7 of the NERC Standard Processes Manual (SPM), the Standards Committee may accept requests for interpretation in 2016 and beyond. Those requests would commence based on NERC and the Standards Committee prioritization, which would also consider timing to ensure projects are developed at a measurable and sustainable pace, consistent with the criteria to prioritize standard projects that are included in this list.

Feedback Loops (Factors for Consideration of Risk) The following feedback loops, or factors for consideration, will assist in keeping the workload steady by prioritizing (a) the projects that do not have a one-year deadline, and (b) compliance input built earlier into the project’s timeline. Projects with a deadline are based on FERC directives that have a filing due date specific in a Final Rule.

Compliance Monitoring and Enforcement Program Feedback Compliance Monitoring and Enforcement Program (CMEP) feedback is an available mechanism for ERO Enterprise CMEP staff and registered entities subject to the CMEP activities to provide feedback on a standard, which could be beneficial to identify issues with standards. During CMEP activities, that feedback could be valuable for instructing standards development activity. The ERO CMEP Implementation Plan is the annual operating plan carried out by Compliance Enforcement Authorities while performing their responsibilities and duties as called for in the CMEP. It prioritizes risks to the Bulk Electric System (BES), registered entity functions, and Reliability Standards based on risk to determine appropriate oversight focus. The results of that plan also help shape prioritizing standards development projects, including EPRs. ERO Enforcement staff is collecting impact data to determine whether a particular violation caused or contributed to some observed impact on reliability. Data of this kind can further inform standards development by identifying the most consequential requirements, particularly in the context of EPRs. Implementation Guidance promotes a common understanding between industry and CMEP staff by providing examples for implementing a standard. For many standards, this is straightforward. For others, a variety of approaches may achieve the same objective. The fact that there is significant Implementation Guidance by itself may or may not mean there is reason for changing a standard. For example, the standard language may be clear but have many complicated ways of achieving compliance. Nonetheless, Implementation Guidance is another important feedback mechanism to alert drafting teams of possible ambiguities or complexities during standards development.

Construct of Standards The IERP recommendations on a new construct of standards will need to be consulted with industry to establish the benefit of realigning the standards. For example, the total transfer capability standards (proposed MOD-001-2) and some of the FAC standards have some overlap. If there is consensus in the industry, a discussion about the standards alignment and where requirements could best reside can take place as part of the EPR discussion.

Coordination with the North American Energy Standards Board (NAESB) NERC routinely coordinates with NAESB on NERC Reliability Standard development and how it may affect some of the NAESB business practices. NAESB monitors various NERC projects and the coordination between NERC and NAESB will continue.

2017 Projects


Emerging Risks and Changing Technologies The RISC, Integration of Variable Generation Task Force, and ERSWG are three important committees and task forces that focus on emerging risks and changing technologies. They need to be involved during the beginning of 2017 to assist in the EPR for prioritization and technical expertise.

Event Analysis and Compliance Violation Statistics Event analysis and compliance violation statistics should be reviewed as the EPRs get underway. Lessons learned and statistics from analyzing events will allow teams to review existing requirements to see if there is any correlation between the events and requirements. Violations statistics allow teams to investigate requirements that are highly violated to identify areas where language may have been misinterpreted and provide training to the industry on the intent of the requirements.

Lessons Learned and Frequently Asked Questions Lessons learned documents are designed to convey information from NERC’s various implementation activities. They are not intended to establish new requirements under NERC’s Reliability Standards, to modify the requirements in any existing Reliability Standards, nor to provide an interpretation under section 7 of the SPM. Additionally, there may be other legitimate ways to fulfill the obligations of the requirements that are not expressed in these supporting documents. Compliance will continue to be determined based on the language in the NERC Reliability Standards as amended from time to time. Implementation of a lesson learned is not a substitute for compliance with requirements in NERC’s Reliability Standards. Frequently asked questions (FAQs) provide transparency in providing answers to questions asked by entities. The information presented in FAQ documents is intended to provide guidance and is not intended to establish new requirements under NERC’s Reliability Standards or to modify the requirements in any existing Reliability Standards. A standard being the subject of numerous lessons learned or FAQs is an indication that the language in the standard may be ambiguous, subject to multiple interpretations, or does not appropriately capture the reliability risk.

Measures There have been more requests for guidance to industry on expectations for measuring performance on standard requirements. This is evidence that the measures within some standards may not be sufficiently informative. The EPRs should include consideration of requests for guidance from industry, and the efforts should have an emphasis on improving measures such that guidance documents or detailed reliability standard audit worksheets (RSAWs) are not necessary and the measures are sufficient guidance to the industry.

Rationale and Guidelines Industry feedback will be encouraged on how these sections relate to the work of the Member Representative Committee’s compliance guidance work.

Regional Variances If a regional standard is in effect, or is under consideration for a standards development project, it should be incorporated into continent-wide Reliability Standards as a regional variance in cases where there is a continent-wide standard that addresses the same subject.

Request for Interpretations Similar to lessons learned and FAQs, a standard receiving a valid interpretation request may indicate problems with the language of the standard or of a requirement.

2017 Projects


RSAW Development In the beginning of 2013, NERC endeavored to develop RSAWs concurrently with standards. The purpose was to post RSAWs within 15 days of a standard posting date to allow the industry to consider the compliance approach from auditors as they vote on the standard(s) being balloted.

Standard Authorization Requests SARs are an important mechanism for sponsors to transmit standards information to NERC. For example, SARs submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment may identify requirements that should be modified to mitigate an emerging reliability risk, or are little to no risk to the BES and should be considered for retirement.

Surveys and Polls Surveys and polls could be good outreach tools as the feedback loops are implemented in the beginning of 2017. Questions for the industry or thoughts on conducting the EPRs could be an efficient way to collect stakeholder opinions, since standards development is on a more measured and deliberate pace compared to previous years. Therefore, industry feedback is critical to ensure projects and EPRs are appropriately prioritized to focus on high-risk areas.


Attachment 1

Enhanced Periodic Review Guidelines9

Developing the plan to conduct EPRs considers several factors. The first task is determining how to group standards for review. For example, it may be reasonable to review standards by looking at the entire standards family, but it may also make sense to look at reliability actions that cut across standard families or by sections of standards that relate to each other.10 The next task is determining whether the subject group of standards is eligible for review. Other ongoing or planned standards development projects may affect standards eligibility. Standards are then grouped and prioritized.

Standards Eligibility The criteria below determine standard eligibility to conduct the EPRs for standards for 2017, 2018, and 2019.

Criteria for What Makes a Standard Eligible:

All requirements of a Reliability Standard must have been in effect, based on the implementation/compliance dates approved by the applicable governmental authority, for at least a year. In some instances, a standard may be eligible if it has been a year since the effective date of the order11 approving that standard if entities are “early adopting” the requirements as they implement their programs to prepare for the effective date. Examples of standards that met this criterion for the initial 2016 EPRs were:

NUC-001-3 and NUC-001-2.1: NUC-001-2.1 was effective 4/1/2013 and NUC-001-3 was effective 1/1/2016. The changes in NUC-001-3 were not significant (e.g., they related to capitalization of terms, deleting unneeded terms, etc.).

Compliance expectations are not clear or the standard is not being consistently monitored.

Feedback loops indicate risk (e.g., Event Analysis lessons learned).

9Per Section 13 of the SPM, all Reliability Standards shall be reviewed at least once every ten years from the effective date of the Reliability

Standard or the date of the latest NERC Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. If a Reliability Standard is approved by the American National Standards Institute as an American national standard, it shall be reviewed at least once every five years from the effective date of the Reliability Standard or the date of the latest NERC Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. The RSDP shall include projects that address this five- or ten-year review of Reliability Standards.

If a Reliability Standard is nearing its five- or ten-year review and has an issue that needs resolved, then the Reliability Standards Development Plan shall include a project for the complete review and associated revision of the Reliability Standard. This includes addressing all outstanding governmental directives, all approved interpretations, and all unresolved issues identified by stakeholders.

If a Reliability Standard is nearing its five- or ten-year review and there are no outstanding governmental directives, interpretations, or unresolved stakeholder issues associated with the Reliability Standard, then the RSDP shall include a project solely for the “five-year review” of that Reliability Standard.

While the main work in the next three years will be the continuation of research and conducting of the enhanced periodic reviews with consideration of the topics discussed below, there may be risks identified for which projects may need to be initiated. 10 The IERP developed one approach to grouping standards. 11 “Effective date” and “issue date” are different, so this must be considered.

Enhanced Periodic Review Guidelines


Outstanding Paragraph 81 requirements that may not have been addressed.

The implementation of the Standards Independent Experts Review Project - Final Report recommendations.12

Per the SPM, standards will go through a review at least once every 10 years for non-American National Standards Institute (ANSI) approved standards and every five years for ANSI-approved standards.

Criteria for What Makes a Standard Not Eligible:

A standard that is part of a current standards development project or is scheduled for standards development that will likely result in significant revisions of the standard currently in effect.

Standards development here includes standards:

o in a standards development project;

o adopted by the NERC Board of Trustees;

o pending regulatory filing;

o filed with regulatory agencies; or

o approved by regulatory agencies but not yet in effect.

Prioritization Specific elements considered in the prioritization of the EPRs include:

1. RISC category rankings

2. Feedback on risk through a risk-based input mechanism

3. Outstanding regulatory directives with deadlines

4. Outstanding regulatory directives

5. Outstanding requirements that are candidates for retirement

6. Standards Independent Experts Review Panel - Final Report content and quality assessments

12 The Standards IERP final report recommendations can be found here:

http://www.nerc.com/pa/Stand/Standards%20Development%20Plan%20Library/Standards_Independent_Experts_Review_Project_Report.pdf




Attachment 2

Final Grades for Standards Graded in 2016

The Enhanced Periodic Review (EPR) Standing Review Team (SRT) was tasked with using metrics from the 2013 Independent Experts Review Panel to assign numeric grades to instruct future EPR teams. While the SRT’s final standards grades are important data points for the EPRs to consider, they are intended as one of many inputs to facilitate discussion during the reviews. The EPRSRT completed the initial grading of eligible Reliability Standards, which NERC posted for a 30-day stakeholder comment period. The EPR SRT conducted a second public meeting in which it considered input from stakeholders and held additional discussion prior to reaching consensus to finalize the grades. Shown below are the average SRT grades for content (0-3) and quality (0-12) for each of the standard requirements eligible for EPR in 2016-2017. Detailed analysis and background information on the Standards Grading process can be found on the project page.

Standard and Requirement

Content Average

Quality Average

BAL-001-2 , R1 3.00 11.5

BAL-001-2 , R2 3.00 11

EOP-010-1, R1 3.00 12

EOP-010-1, R2 2.67 10

EOP-010-1, R3. 3.00 11.75

EOP-011-1, R1. 3.00 11.5

EOP-011-1, R2. 3.00 12

EOP-011-1, R3. 2.50 10.75

EOP-011-1, R4. 2.50 11

EOP-011-1, R5. 2.75 11.75

EOP-011-1, R6. 2.75 11.5

FAC-008-3, R1 3.00 10.75

FAC-008-3, R2. 3.00 11.33333

FAC-008-3, R3. 3.00 11.5

FAC-008-3, R6. 3.00 11

FAC-008-3, R7. 2.50 10.5

FAC-008-3, R8. 2.75 10.25

INT-004-3.1, R3. 3.00 11.25

INT-006-4, R1 3.00 11

INT-006-4, R2 3.00 11.25

INT-006-4, R3. 3.00 11.5

INT-006-4, R4 3.00 11.25

INT-006-4, R5 3.00 11.75

INT-009-2.1, R1 3.00 11.5

INT-009-2.1, R2 3.00 12


Content Average

Quality Average

INT-009-2.1, R3. 3.00 12

INT-010-2.1, R1 3.00 11

INT-010-2.1, R2 3.00 11.5

INT-010-2.1, R3. 3.00 11

NUC-001-3, R1 3.00 12

NUC-001-3, R2. 3.00 12

NUC-001-3, R3. 2.75 12

NUC-001-3, R4. 3.00 11.75

NUC-001-3, R5. 3.00 12

NUC-001-3, R6. 3.00 12

NUC-001-3, R7. 3.00 12

NUC-001-3, R8. 3.00 12

NUC-001-3, R9 3.00 11.75

PER-003-1, R1. 3.00 11.5

PER-003-1, R2. 3.00 11.5

PER-003-1, R3. 3.00 11.5

PER-004-2, R1. 2.75 11.25

PER-004-2, R2. 3.00 9.5

PRC-004-5(i), R1. 2.75 11.75

PRC-004-5(i), R2. 3.00 11.75

PRC-004-5(i), R3. 3.00 11.25

PRC-004-5(i), R4. 3.00 11.5

PRC-004-5(i), R5. 3.00 11.5

PRC-004-5(i), R6. 3.00 11.5

PRC-005-6, R1. 2.75 11.25

http://www.nerc.com/pa/Stand/Pages/Enhanced-Periodic-Review-Standards-Grading.aspx

Final Grades for Standards



Content Average

Quality Average

PRC-005-6, R2. 3.00 11.5

PRC-005-6, R3. 3.00 11.5

PRC-005-6, R4. 3.00 11.5

PRC-005-6, R5. 2.75 10.5

PRC-006-2, R1. 3.00 11.5

PRC-006- , R11. 3.00 12

PRC-006-2, R12. 3.00 11.75

PRC-006-2, R13. 3.00 12

PRC-006-2, R2. 2.00 11.5

PRC-006-2, R3. 3.00 11.5

PRC-006-2, R4. 3.00 11.75

PRC-006-2, R5. 3.00 11.75

PRC-006-2, R6. 3.00 11.75

PRC-006-2, R7. 3.00 12

PRC-006-2, R8. 3.00 11.75

PRC-006-2, R9. 3.00 11.5

PRC-010-2, R1. 2.50 11.5

PRC-010-2, R2. 3.00 11.5

PRC-010-2, R3. 2.50 11.25

PRC-010-2, R4. 2.50 12

PRC-010-2, R5. 2.50 12

PRC-010-2, R6. 3.00 11.5

PRC-010-2, R7. 3.00 12

PRC-010-2, R8. 3.00 12

PRC-019-2, R1. 3.00 11.75


Content Average

Quality Average

PRC-019-2, R2. 3.00 11.75

PRC-023-4, R1. 3.00 11.25

PRC-023-4, R2. 2.75 11.25

PRC-023-4, R3. 2.75 11.75

PRC-023-4, R4. 2.75 11.5

PRC-023-4, R5. 3.00 11.25

PRC-023-4, R6. 3.00 11.75

PRC-024-2, R1. 3.00 11.75

PRC-024-2, R2. 3.00 11.75

PRC-024-2, R3. 3.00 11.5

PRC-024-2, R4. 3.00 11.75

PRC-025-1, R1. 2.75 11.5

VAR-001-4.1, R1. 3.00 11.25

VAR-001-4.1, R2. 3.00 11.25

VAR-001-4.1, R3. 3.00 11.5

VAR-001-4.1, R4. 3.00 11

VAR-001-4.1, R5. 3.00 11.75

VAR-001-4.1, R6. 2.75 11.75

VAR-002-4, R1. 3.00 11.25

VAR-002-4, R2. 3.00 12

VAR-002-4, R3. 3.00 12

VAR-002-4, R4. 3.00 11.5

VAR-002-4, R5. 3.00 12

VAR-002-4, R6. 3.00 11.25

I

DRAFT Reliability Standards Development Plan

2017–2019

June 15September 14, 2016

Agenda Item 8c

Standards Committee

September 14, 2016

Agenda Item 8cStandards CommitteeSeptember 14, 2016

ii

Table of Contents

Background .......................................................................................................................................................... iviviii

Executive Summary ............................................................................................................................................... vviv

2016 Progress Report .................................................................................................................................................1

FERC Directives ...........................................................................................................................................................1

Projects Completed in 2016 .......................................................................................................................................1

2017 Projects ..............................................................................................................................................................2

Projects Continuing from 2016 into 2017 ..................................................................................................................2

High Priority ................................................................................................................................................................2

Medium Priority .........................................................................................................................................................3

Medium to Low Priority ..............................................................................................................................................3

Projects Commencing in 2017 ....................................................................................................................................4

Standards Cost Effectiveness Pilot .............................................................................................................................4

Enhanced Periodic Reviews ........................................................................................................................................4

Standards Grading Metric ..........................................................................................................................................5

Interpretations ...........................................................................................................................................................6

Feedback Loops (Factors for Consideration of Risk) ..................................................................................................6

Compliance Monitoring Enforcement Program Feedback .........................................................................................6

Construct of Standards ...............................................................................................................................................6

Coordination with the North American Energy Standards Board (NAESB) ................................................................7

Emerging Risks and Changing Technologies ...............................................................................................................7

Event Analysis and Compliance Violation Statistics ...................................................................................................7

Lessons Learned and Frequently Asked Questions ....................................................................................................7

Measures ....................................................................................................................................................................7

Rationale and Guidelines ............................................................................................................................................7

Regional Variances ................................................................................................................................................ 887

Request for Interpretations ................................................................................................................................... 887

RSAW Development and Compliance Input ...............................................................................................................8

Standard Authorization Requests ...............................................................................................................................8

Surveys and Polls ........................................................................................................................................................8

Attachment 1 - Enhanced Periodic Review Guidelines ..............................................................................................9

Standards Eligibility ....................................................................................................................................................9

Criteria for What Makes a Standard Eligible: .............................................................................................................9

Criteria for What Makes a Standard Not Eligible: ................................................................................................... 10

Prioritization ............................................................................................................................................................ 10

Table of Contents

NERC | DRAFT 2017–2019 Reliability Standards Development Plan | June 15, 2016 iii

Attachment 2 – Final Grades for Standards Graded in 2016 .................................................................................. 11

iv

Background

The 2016–2018 Reliability Standards Development Plan (RSDP) set forth a transitional plan to bring the body of NERC Reliability Standards to the initial stage of “steady state”1 by addressing remaining Federal Energy Regulatory Commission (FERC) directives and recommendations to retire standard requirements. It specifically included the Integration of Variable Generation Task Force and Essential Reliability Services Task ForceWorking Group (ERSWGTF) recommendations, and called for continued communication with the Reliability Issues Steering Committee (RISC) on emerging risks. The 2016-2018 RSDP recognized the need to address subsequent FERC directives and Sstandards Aauthorization Rrequests (SARs), and the need to enhance communication through industry feedback loops. The 2016-2018 RSDP also planned for initial Enhanced Periodic Reviews (EPR) of the PER and VAR standards, which successfully commenced in 2016. Pursuant to the NERC Rules of Procedure, section 310, NERC is required to develop and provide to applicable governmental authorities an annual RSDP for Reliability Standards development. NERC also isis also required to consider the comments and priorities of the applicable governmental authorities in developing and updating the annual RSDP. Each annual RSDP must include a progress report comparing results achieved to the prior year’s RSDP. NERC also includes the NERC Standards Committee review during RSDP development, and posts the RSDP for industry comment.

1 For the purposes of the RSDP, “steady state” means a stable set of clear, concise, high‐quality, and technically sound Reliability Standards that are results -based, including retirement of requirements that do little to promote reliability.

v

Executive Summary

The 2017–2019 RSDP recognizes the diligent work of the last few years to bring the body of NERC Reliability Standards to the initial stage of steady state while transitioning to focusing on EPRs, FERC directives, emerging risks, SARs, and the standards grading initiative. The 2017-2019 RSDP contemplates that the work of the ERSWGTF may result in one or more SARs and subsequent standards projects. As with the 2016-2018 RSDP, EPRs will occur at a measured pace, compared to the level of activity and pace of standards development during the past three years,2 and they will be aligned with strategic considerations of reviewing standard families3 that are interrelated. The addition of the standards grading metric, which uses an enhanced version of the template developed by the Independent Experts Review Panel (IERP), will inform the EPRs as to the quality and content of the standards.4 The 2017-2019 RSDP also includes plans for completing the EPRs initiated in 2016, and for commencing additional EPRs in 2017. While most of the work in the next three years will focus on EPRs, there may be new or emerging risks identified that would generate new standards development projects. NERC and the Standards Committee will continue to seek input and recommendations from the RISC with regard to emerging or potential risks to reliability that may require revisions to existing standards or new standards development. The 2017-2019 RSDP provides insight into standards development activities anticipated at the time of publication so that stakeholders may make available appropriate resources to accomplish these standards development objectives.

2 The Standards Committee approved an EPR template on September 30, 2014 and presented it to the NERC Board of Trustees on November 12, 2014 as part of the Standard Committee’s update. The template includes background information and questions to guide a comprehensive review of the standard(s) by the EPR team, and serves as documentation of the EPR team’s considerations and recommendations. 3 In some cases, a narrower review of a standard will likely be appropriate. For example, there are not necessarily other interrelated standards with FAC-003. 4 The EPR standing review team will grade the standards. The team includes representatives from NERC, the Regions, and the NERC technical committees. Grading will occur prior to conducting the EPR. If there is a change in the standard due to EPR recommendations and subject to the standards development process, the EPR standing review team will re-grade the standard with the revised language.

1

2016 Progress Report

FERC Directives As of June 30, 2016, there are 31 outstanding FERC directives.5 FERC issued some directives pertaining to groups outside of NERC Standards, such as the NERC technical committees and other NERC departments (e.g., topics related to reliability assessment, performance analysis, etc.), and are not included in this count.

Projects Completed in 2016 The 2016–2018 RSDP identified eight projects initiated in 2016 or continued from 2015. All of the projects listed therein have been completed in 2016 or are planned to be completed in 2016, except for Project 2015-08: Emergency Operations, Project 2015-10: Single Points of Failure TPL-001, and Project 2015-09: System Operating Limits, which are expected to be completed in 2017. The following projects have been or will be completed in 2016:

Projects from the 2016–2018 RSDP

1. Project 2009-02 Real-time Reliability Monitoring and Analysis Capabilities

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

3. Project 2010-07.1 Vegetation Management

4. Project 2010-14.2.1: Phase 2 of Balancing Authority Reliability-based Controls (BAL-005-1, BAL-006-2)

5. Project 2010-14.2.2: Phase 2 of Balancing Authority Reliability-based Controls (BAL-004-2)

6. Project 2015-07 Internal Communications Capabilities

5 These directives include FERC considerations for future standards development.


2017 Projects

Projects Continuing from 2016 into 2017 The approach to prioritizing Reliability Standards projects in this RSDP is consistent with previous RSDPs. Specific elements include: (1) RISC Category Rankings; (2) regulatory directives and deadlines; (3) Reliability Standard requirements recommended for retirement; (4) the IERP content and quality assessments; and (5) additional considerations (fill-in-the-blank status and five-year assessment commitments). The prioritization considers RISC category rankings, regulatory directives, and regulatory deadlines. Based on the application of these elements, this section prioritizes each Reliability Standard project as high, medium, low, or pending technical committee input.

High Priority

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

This project will address two directives and consider other improvements to TPL‐001‐4 — Transmission System Planning Performance Requirements. There are no remaining time-sensitive directives.

o From FERC Order No. 786

– Paragraph 40 directs NERC to modify Reliability Standard TPL‐001‐4 to address the concern that the six-month threshold could exclude planned maintenance outages of significant facilities from future planning assessments.

– Paragraph 89 directs NERC to consider a similar spare equipment strategy for stability analysis upon the next review cycle of Reliability Standard TPL‐001‐4.

RISC: overall risk priority is moderate for protection system and single points of failure (risk profile #3B).


Project 2016-01: Modifications to TOP and IRO Standards

Modifications to the TOP and IRO standards developed in this project address reliability concerns identified in FERC Order No. 817 as described below.


– Paragraph 35 directs NERC to revise Reliability Standard TOP-001-3, Requirement R10 to require real-time monitoring of non-BES facilities. We believe this is best accomplished by adopting language similar to Reliability Standard IRO-002-4, Requirement R3, which requires Rreliability Ccoordinators to monitor non-bulk electric system facilities to the extent necessary.

– Paragraph 47 directs NERC to modify Reliability Standards TOP-001-3, Requirements R19 and R20 to include the requirement that the data exchange capabilities of the Ttransmission Ooperators and balancing Balancing authorities Authorities require redundancy and diverse routing.

– Paragraph 47 directs NERC to clarify that “redundant infrastructure” for system monitoring in Reliability Standards IRO-002-4, Requirement R4 is equivalent to redundant and diversely routed data exchange capabilities.

– Paragraph 51 directs NERC to develop a modification to the TOP and IRO standards that addresses a data exchange capability testing framework for the data exchange capabilities

Final Grades for Standards Graded in 2016Enhanced Periodic Review Guidelines


used in the primary control centers to test the alternate or less frequently used data exchange capabilities of the Rreliability Ccoordinator, Ttransmission Ooperator and Bbalancing Aauthority.

RISC: overall risk priority is moderate for the loss of situational awareness (Risk Profile #3C).


Project 2016-02: Modifications to CIP Standards

This project will modify the CIP family of standards to address issues identified by the CIP V5 Transition Advisory Group, FERC directives contained in Order 822 as explained below; and requests for interpretations.


– Paragraph 32 directs that NERC, pursuant to section 215(d)(5) of the FPA, develop modifications to the CIP Reliability Standards to provide mandatory protection for transient devices used at Low Impact BES Cyber Systems based on the risk posed to bulk electric system reliability. While NERC has flexibility in the manner in which it addresses the Commission’s concerns, the proposed modifications should be designed to effectively address the risks posed by transient devices to Low Impact BES Cyber Systems in a manner that is consistent with the risk-based approach reflected in the CIP version 5 Standards.

– Paragraph 53 directs that NERC, pursuant to section 215(d)(5) of the FPA, develop modifications to the CIP Reliability Standards to require responsible entities to implement controls to protect, at a minimum, communication links and sensitive bulk electric system data communicated between bulk electric system Control Centers in a manner that is appropriately tailored to address the risks posed to the bulk electric system by the assets being protected (i.e., high, medium, or low impact).

– Paragraph 64 directs NERC to conduct a study that assesses the effectiveness of the CIP version 5 remote access controls, the risks posed by remote access-related threats and vulnerabilities, and appropriate mitigating controls for any identified risks. NERC should consult with Commission staff to determine the general contents of the directed report. We direct NERC to submit a report on the above outlined study within one year of the implementation of the CIP version 5 Standards for High and Medium Impact BES Cyber Systems.

– Paragraph 73 directs NERC to develop a modification to provide the needed clarity, within one year of the effective date of this Final Rule. We agree with NERC and other commenters that a suitable means to address our concern is to modify the Low Impact External Routable Connectivity definition consistent with the commentary in the Guidelines and Technical Basis section of CIP-003-6.

RISC: overall risk priority is high for cyber security vulnerabilities (risk profile #4A).

IERP considerations: not addressed, as they require specialized expertise.

Medium Priority

Project 2015-08: Emergency Operations

No FERC directives (FERC guidance has been provided to this project)

RISC : medium-priority area (coordinated attack on multiple facilities), low-priority areas (extreme weather/acts of nature)



RISC: medium-priority area (coordinated attack on multiple facilities), low-priority areas (extreme weather/acts of nature)


Project 2015-09: System Operating Limits

No FERC directives

RISC: high-priority area (Situational Awareness)


2016-EPR-01: Enhanced Periodic Review of Personnel Performance, Training, and Qualifications Standards - PER-001, PER-003, PER-004

2016-EPR-02: Enhanced Periodic Review of Voltage and Reactive Standards - VAR-001, VAR-002

Medium to Low Priority The following requests for interpretation have commenced in 2016:

Project 2015-INT-031: Interpretation of CIP-002-5.1 for EnergySec

Project 2015-INT-03: Interpretation of TOP-002-2.1b for FMPP

Projects Commencing in 2017 The following projects should commence in 2017. Not all projects have SARs, which will be developed and presented to the Standards Committee at the appropriate time to initiate the project.

At least two EPRs that may recommend revisions to standards.

Emerging risks, if any, with input from the RISC on whether a standard is needed.

Potential modifications to existing standards that respond to FERC directives.

Standards Cost Effectiveness Pilot Federal, state, and provincial regulatory authorities, the NERC Board of Trustees, Regional Entities, and many industry stakeholders have expressed interest in identifying the costs incurred from implementing NERC Reliability Standards compared to risks addressed. The desire is to balance costs and risks during the standards development and revision process. Therefore, in 2016 NERC developed and implemented Phase 1 of its Standards Cost Effectiveness Pilot to inform the Project 2015-10: Single Points of Failure TPL-001 drafting team on potential implementation costs during SAR development.6 Phase 2 of the pilot will occur during standards drafting and is expected to be completed in 2016 or 2017.

Enhanced Periodic Reviews Periodic reviews provide a wide view of the standards to determine whether a particular group of standards is effective. Attachment 1 to the RSDP contains the “Enhanced Periodic Review Guidelines” that further explain standards prioritization and selection criteria. The following EPRs commenced in 2016:

PER-001, PER-003, and PER-004

6 Please see the Cost Effectiveness Pilot web page at http://www.nerc.com/pa/Stand/Pages/CostEffectivenessPilot.aspx for additional information on this initiative.

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



VAR-001 and VAR-002 The following EPRs are eligible to commence in 2017.7 At least two EPRs will commence in 2017 selected from the following set of eligible standards:

BAL and INT families of standards (BAL-001, and INT-004, INT-006, INT-009, and INT-010)

EOP-010

FAC-003-4

FAC-008-3

NUC-001-3

PRC family of standards (PRC-004-5(i), PRC-005-6, PRC-006-2, PRC-010-2, PRC-018-1, PRC-019-2, PRC-023-4, PRC-024-2, PRC-025-1, and PRC-026-1)

Standards Grading Metric In 2016, NERC implemented a standards grading metric to grade all standards eligible for an EPR, which requires that the standard be in effect in the United States (compliance enforcement date) for at least one year. The EPR standing review team grades the standards using an enhanced version of the IERP grading template. Standards grades are harmonized in public meetings with the initial EPR standing review team grades posted for stakeholder comment. After consideration of comments, the EPR standing review team finalizes the grades and provides the results to the EPR teams, which are comprised of the standing review team and industry subject matter experts tasked with implementing the EPR to completion. Final grades are included in as Attachment 2 to this RSDP for informational purposes. [Note from NERC: final grades are not yet available but will be included in the final versions of this RSDP]. The grading will also assist in prioritizing future EPRs. For example, if the grading indicates a gap or a significant need to increase the quality or content of a standard or standard family, that set of standards may have a higher priority over standards and standard families that have high quality and content grades. If an EPR recommendation results in a revised standard standard is revised as a result of recommendations in the EPR, that standard will be re-graded, and the new grade will be attached to the a future RSDP for informational purposes. In 2017, the grading metric will be applied to the standards that are eligible for an EPR to start in 2017, time and resources permitting. In 2017, the grading will occur in the first half of the year, which will assist in the prioritizing of EPRs in 2017 and 2018. The following non-CIP standards become eligible for standards grading in 2017:8

BAL-003-1.1

COM-001-2.1

COM-002-4

FAC-001-2

FAC-002-2

IRO-009-2

MOD-032-1

7 For reference, the following standards will be eligible for EPRs in 2018 and 2019: EOP-011-1, BAL-003-1.1, COM-001-2.1, COM-002-4, FAC-001-2, FAC-002-2, IRO-009-2, MOD-032-1, MOD-031-2, and TPL-001-4. 8 For reference, in 2018 the TOP and IRO families of standards will be eligible for standards grading and EPR.



TPL-001-4 In 2018, the TOP and IRO families of standards would be eligible for grading and EPR.

Interpretations Pursuant to section 7 of the NERC Standard Processes Manual (SPM), the Standards Committee may accept requests for interpretation toward the end ofin 2016 and beyond. Those requests would commence based on NERC and the Standards Committee prioritization, which would also consider timing to ensure projects are developed at a measurable and sustainable pace, consistent with the criteria to prioritize standard projects that are included in this list.

Feedback Loops (Factors for Consideration of Risk) The following feedback loops, or factors for consideration, will assist in keeping the workload steady by prioritizing (a) the projects not havingthat do not have a one-year deadline, and (b) compliance input built earlier into the project’s timeline. Projects with a deadline are based on FERC directives that have a filing due date specific in a Final Rule.

Audit Compliance Monitoring and Enforcement Program Feedback Audit Compliance monitoring and enforcementMonitoring and Enforcement Program (CMEP) feedback is a possiblean available mechanism for auditors ERO Enterprise CMEP staff and registered entities being subject to the CMEP activitiesauditinged to provide feedback on a standard, which could be beneficial to identify issues with standards. During a monitoring process or CMEP activities, risk assessment, the auditthat feedback could be valuable for instructing standards development workactivity. The ERO Compliance Monitoring and Enforcement ProgramCMEP Implementation Plan is the annual operating plan carried out by Compliance Enforcement Authorities while performing their responsibilities and duties as called for in the Compliance Monitoring and Enforcement ProgramCMEP. It has historically specified the NERC Reliability Standards and Requirements to be actively monitored and audited during the implementation year. It also prioritizes risks to the Bulk Electric System (BES), registered entity functions, and Reliability Standards based on risk to determine the appropriate oversight methodfocus. The results of that plan also help shape prioritizing standards development projects, including EPRs. ERO Enforcement staff is collecting impact data to determine whether a particular violation caused or contributed to some observed impact on reliability. Data of this kind can further inform standards development by identifying the most consequential requirements, particularly in the context of EPRs. Implementation Guidance promotes a common understanding between industry and CMEP staff by providing examples for implementing a standard. For many standards, this is straightforward. For others, a variety of approaches may achieve the same objective. The fact that there is significant Implementation Guidance by itself may or may not mean there is reason for changing a standard. For example, the standard language may be clear but have many complicated possible ways of achieving compliance. Nonetheless, Implementation Guidance is another important feedback mechanism to alert drafting teams of possible ambiguities or complexities during standards development.

Construct of Standards The IERP recommendations on a new construct of standards will need to be consulted withvetted by industry to establish the benefit of realigning the standards. For example, the total transfer capability standards (proposed MOD-001-2) and some of the FAC standards have some overlap. If there is consensus in the industry, a discussion about the standards alignment and where requirements could best reside can take place as part of the EPR discussion.



Coordination with the North American Energy Standards Board (NAESB) NERC routinely coordinates with NAESB on NERC Reliability Standard development and how it may affect some of the NAESB business practices. NAESB monitors various NERC projects and the coordination between NERC and NAESB will continue.

Emerging Risks and Changing Technologies The RISC, Integration of Variable Generation Task Force (IVGTF), and Essential Reliability Services Task ForceERSWG (ERSTF) are three important committees and task forces that focus on emerging risks and changing technologies. They need to be involved during the beginning of 2017 to assist in the EPR for prioritization and technical expertise.

Event Analysis and Compliance Violation Statistics Event analysis and compliance violation statistics should be reviewed as the EPRs get underway. Lessons learned and statistics from analyzing events will allow teams to review existing requirements to see if there is any correlation between the events and requirements. Violations statistics allow teams to investigate requirements that are highly violated to identify areas where language may have been misinterpreted and provide training to the industry on the intent of the requirements.

Lessons Learned and Frequently Asked Questions Lessons learned documents are designed to convey information from NERC’s various implementation activities. They are not intended to establish new requirements under NERC’s Reliability Standards, to modify the requirements in any existing Reliability Standards, nor to provide an interpretation under Section section 7 of the SPM. Additionally, there may be other legitimate ways to fulfill the obligations of the requirements that are not expressed in these supporting documents. Compliance will continue to be determined based on the language in the NERC Reliability Standards as amended from time to time. Implementation of a lesson learned is not a substitute for compliance with requirements in NERC’s Reliability Standards. Frequently asked questions (FAQs) provide transparency in providing answers to questions asked by entities. The information presented in FAQ documents is intended to provide guidance and is not intended to establish new requirements under NERC’s Reliability Standards or to modify the requirements in any existing Reliability Standards. A standard being the subject of numerous lessons learned or FAQs is an indication that the language in the standard may be ambiguous, subject to multiple interpretations, or does not appropriately capture the reliability risk.

Measures There have been more requests for guidance to industry on what is expectedexpectations for measuring performance on standard requirements. This shows is evidence that the measures within some standards are may not be sufficiently informative enough. The EPRs should include consideration of requests for guidance from industry, and the efforts should have an emphasis on improving measures such that guidance documents or detailed reliability standard audit worksheets (RSAWs) are not necessary and the measures are sufficient guidance to the industry.

Rationale and Guidelines Industry feedback will be encouraged on how these sections relate to the work of the Member Representative Committee’s compliance guidance workinitiatives.



Regional Variances If a regional standard is in effect, or is under consideration for a standards development project, it should be incorporated into continent-wide Reliability Standards as a regional variance in cases where there is a continent-wide standard that addresses the same subject. Request for Interpretations Similar to lessons learned and FAQs, a standard receiving a valid interpretation request may indicate problems with the language of the standard or of a requirement.

RSAW Development and Compliance Input In the beginning of 2013, NERC endeavored to develop RSAWs concurrently with standards. The purpose was to post RSAWs within 15 days of a standard being posting dateed to allow the industry to consider the compliance approach from auditors as they vote on the standard(s) being balloted.

Standard Authorization Requests SARs are an important mechanism for sponsors to transmit standards information to NERC. For example, SARs submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment may identify requirements that should be modified to mitigate an emerging reliability risk.

Surveys and Polls Surveys and polls could be good outreach tools as the feedback loops are implemented in the beginning of 2017. Questions for the industry or thoughts on conducting the EPRs could be an efficient way to collect stakeholder opinions. , Since since standards development is on a more measured and deliberate pace compared to previous years. Therefore, industry feedback is critical to ensure projects and EPRs are appropriately prioritized to focus on high-risk areas.


Attachment 1

Enhanced Periodic Review Guidelines9

Developing the plan to conduct EPRs considers several factors. The first task is determining how to group standards for review. For example, it may be reasonable to review standards by looking at the entire standards family, but it may also make sense to look at reliability actions that cut across standard families or by sections of standards that relate to each other.10 The next task is determining whether the subject group of standards is eligible for review. Other ongoing or planned standards development projects may affect standards eligibility. Standards are then grouped and prioritized.

Standards Eligibility The criteria below determine standard eligibility to conduct the EPRs for standards for 2017, 2018, and 2019.

Criteria for What Makes a Standard Eligible:

All requirements of a Reliability Standard must have been in effect, based on the implementation/compliance dates approved by the applicable governmental authority, for at least a year. In some instances, a standard may be eligible if it has been a year since the effective date of the order11 approving that standard if entities are “early adopting” the requirements as they implement their programs to prepare for the effective date. Examples of standards that met this criterion for the initial 2016 EPRs were:

NUC-001-3 and NUC-001-2.1: NUC-001-2.1 was effective 4/1/2013 and NUC-001-3 was effective 1/1/2016. The changes in NUC-001-3 were not significant (e.g., they related to capitalization of terms, deleting unneeded terms, etc.).

Compliance expectations are not clear or the standard is not being consistently monitored.

Feedback loops indicate risk (e.g., Event Analysis lessons learned).

9Per Section 13 of the SPM, all Reliability Standards shall be reviewed at least once every ten years from the effective date of the Reliability

Standard or the date of the latest NERC Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. If a Reliability Standard is approved by the American National Standards Institute as an American national standard, it shall be reviewed at least once every five years from the effective date of the Reliability Standard or the date of the latest NERC Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. The RSDP shall include projects that address this five- or ten-year review of Reliability Standards.

If a Reliability Standard is nearing its five- or ten-year review and has an issue that needs resolved, then the Reliability Standards Development Plan shall include a project for the complete review and associated revision of the Reliability Standard. This includes addressing all outstanding governmental directives, all approved interpretations, and all unresolved issues identified by stakeholders.

If a Reliability Standard is nearing its five- or ten-year review and there are no outstanding governmental directives, interpretations, or unresolved stakeholder issues associated with the Reliability Standard, then the RSDP shall include a project solely for the “five-year review” of that Reliability Standard.

While the main work in the next three years will be the continuation of research and conducting of the enhanced periodic reviews with consideration of the topics discussed below, there may be risks identified for which projects may need to be initiated. 10 The IERP developed one approach to grouping standards. 11 “Effective date” and “issue date” are different, so this must be considered.



Outstanding Paragraph 81 requirements that may not have been addressed.

The implementation of the Standards Independent Experts Review Project - Final Report recommendations.12

Per the SPM, standards will go through a review at least once every 10 years for non- American National Standards Institute (ANSI) approved standards and every five years for ANSI-approved standards.

Criteria for What Makes a Standard Not Eligible:

A standard that is part of a current standards development project or is scheduled for standards development that will likely result in significant revisions of the standard currently in effect.

Standards development here includes standards:

o in a standards development project;

o adopted by the NERC Board of Trustees;

o pending regulatory filing;

o filed with regulatory agencies; or

o approved by regulatory agencies but not yet in effect.

Prioritization Specific elements considered in the prioritization of the EPRs include:

1. RISC category rankings

2. Feedback on risk through a risk-based input mechanism

3. Outstanding regulatory directives with deadlines

4. Outstanding regulatory directives

5. Outstanding requirements that are candidates for retirement

6. Standards Independent Experts Review Panel - Final Report content and quality assessments

12 The Standards IERP final report recommendations can be found here:






Attachment 2

Final Grades for Standards Graded in 2016

The Enhanced Periodic Review (EPR) Standing Review Team (SRT) was tasked with using metrics from the 2013 Independent Experts Review Panel to assign numeric grades to instruct future EPR teams. While the SRT’s final standards grades are important data points for the EPRs to consider, they are intended as one of many inputs to facilitate discussion during the reviews. The EPRSRT completed the initial grading of eligible Reliability Standards, which NERC posted for a 30-day stakeholder comment period. The EPR SRT conducted a second public meeting in which it considered input from stakeholders and held additional discussion prior to reaching consensus to finalize the grades. Shown below are the average SRT grades for content (0-3) and quality (0-12) for each of the standard requirements eligible for EPR in 2016-2017. Detailed analysis and background information on the Standards Grading process can be found on the project page.


Content Average

Quality Average

BAL-001-2 , R1 3.00 11.5

BAL-001-2 , R2 3.00 11

EOP-010-1, R1 3.00 12

EOP-010-1, R2 2.67 10

EOP-010-1, R3. 3.00 11.75

EOP-011-1, R1. 3.00 11.5

EOP-011-1, R2. 3.00 12

EOP-011-1, R3. 2.50 10.75

EOP-011-1, R4. 2.50 11

EOP-011-1, R5. 2.75 11.75

EOP-011-1, R6. 2.75 11.5

FAC-008-3, R1 3.00 10.75

FAC-008-3, R2. 3.00 11.33333

FAC-008-3, R3. 3.00 11.5

FAC-008-3, R6. 3.00 11

FAC-008-3, R7. 2.50 10.5

FAC-008-3, R8. 2.75 10.25

INT-004-3.1, R3. 3.00 11.25

INT-006-4, R1 3.00 11

INT-006-4, R2 3.00 11.25

INT-006-4, R3. 3.00 11.5

INT-006-4, R4 3.00 11.25

INT-006-4, R5 3.00 11.75

INT-009-2.1, R1 3.00 11.5

INT-009-2.1, R2 3.00 12


Content Average

Quality Average

INT-009-2.1, R3. 3.00 12

INT-010-2.1, R1 3.00 11

INT-010-2.1, R2 3.00 11.5

INT-010-2.1, R3. 3.00 11

NUC-001-3, R1 3.00 12

NUC-001-3, R2. 3.00 12

NUC-001-3, R3. 2.75 12

NUC-001-3, R4. 3.00 11.75

NUC-001-3, R5. 3.00 12

NUC-001-3, R6. 3.00 12

NUC-001-3, R7. 3.00 12

NUC-001-3, R8. 3.00 12

NUC-001-3, R9 3.00 11.75

PER-003-1, R1. 3.00 11.5

PER-003-1, R2. 3.00 11.5

PER-003-1, R3. 3.00 11.5

PER-004-2, R1. 2.75 11.25

PER-004-2, R2. 3.00 9.5

PRC-004-5(i), R1. 2.75 11.75

PRC-004-5(i), R2. 3.00 11.75

PRC-004-5(i), R3. 3.00 11.25

PRC-004-5(i), R4. 3.00 11.5

PRC-004-5(i), R5. 3.00 11.5

PRC-004-5(i), R6. 3.00 11.5

PRC-005-6, R1. 2.75 11.25

http://www.nerc.com/pa/Stand/Pages/Enhanced-Periodic-Review-Standards-Grading.aspx




Content Average

Quality Average

PRC-005-6, R2. 3.00 11.5

PRC-005-6, R3. 3.00 11.5

PRC-005-6, R4. 3.00 11.5

PRC-005-6, R5. 2.75 10.5

PRC-006-2, R1. 3.00 11.5

PRC-006- , R11. 3.00 12

PRC-006-2, R12. 3.00 11.75

PRC-006-2, R13. 3.00 12

PRC-006-2, R2. 2.00 11.5

PRC-006-2, R3. 3.00 11.5

PRC-006-2, R4. 3.00 11.75

PRC-006-2, R5. 3.00 11.75

PRC-006-2, R6. 3.00 11.75

PRC-006-2, R7. 3.00 12

PRC-006-2, R8. 3.00 11.75

PRC-006-2, R9. 3.00 11.5

PRC-010-2, R1. 2.50 11.5

PRC-010-2, R2. 3.00 11.5

PRC-010-2, R3. 2.50 11.25

PRC-010-2, R4. 2.50 12

PRC-010-2, R5. 2.50 12

PRC-010-2, R6. 3.00 11.5

PRC-010-2, R7. 3.00 12

PRC-010-2, R8. 3.00 12

PRC-019-2, R1. 3.00 11.75


Content Average

Quality Average

PRC-019-2, R2. 3.00 11.75

PRC-023-4, R1. 3.00 11.25

PRC-023-4, R2. 2.75 11.25

PRC-023-4, R3. 2.75 11.75

PRC-023-4, R4. 2.75 11.5

PRC-023-4, R5. 3.00 11.25

PRC-023-4, R6. 3.00 11.75

PRC-024-2, R1. 3.00 11.75

PRC-024-2, R2. 3.00 11.75

PRC-024-2, R3. 3.00 11.5

PRC-024-2, R4. 3.00 11.75

PRC-025-1, R1. 2.75 11.5

VAR-001-4.1, R1. 3.00 11.25

VAR-001-4.1, R2. 3.00 11.25

VAR-001-4.1, R3. 3.00 11.5

VAR-001-4.1, R4. 3.00 11

VAR-001-4.1, R5. 3.00 11.75

VAR-001-4.1, R6. 2.75 11.75

VAR-002-4, R1. 3.00 11.25

VAR-002-4, R2. 3.00 12

VAR-002-4, R3. 3.00 12

VAR-002-4, R4. 3.00 11.5

VAR-002-4, R5. 3.00 12

VAR-002-4, R6. 3.00 11.25

Consideration of Comments

Project Name: Draft 2017-2019 Reliability Standards Development Plan Comment Period Start Date: 6/20/2016 Comment Period End Date: 7/19/2016

There were 14 sets of responses, including comments from approximately 63 different people from approximately 50 companies, representing 8 of the 10 Industry Segments as shown in the table on the following pages.

If you feel that your comment has been overlooked, please let us know immediately. Our goal is to give every comment serious consideration in this process. If you feel there has been an error or omission, you can contact the Director of Standards Development, Steve Noess (via email) or at (404) 446-9691.

Agenda Item 8d Standards Committee September 14, 2016


Consideration of Comments | Draft 2017-2019 Reliability Standards Development Plan 2

Questions

1. Regarding the feedback loops for input into standards development, do you see other inputs that are missing from this draft RSDP?

2. Is there any information reported in the RSDP you believe is no longer useful or relevant?

3. Is there any information you believe NERC should report in the RSDP that is missing?

4. Please provide any additional comments you would care to offer. The Industry Segments are:

1 — Transmission Owners 2 — RTOs, ISOs 3 — Load-serving Entities 4 — Transmission-dependent Utilities 5 — Electric Generators 6 — Electricity Brokers, Aggregators, and Marketers 7 — Large Electricity End Users 8 — Small Electricity End Users 9 — Federal, State, Provincial Regulatory or other Government Entities 10 — Regional Reliability Organizations, Regional Entities


Organization Name Name Segment(s) Region Group Name Group Member

Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region

Southwest Power Pool, Inc. (RTO)

Charles Yeung 2 SPP RE IRC Standards Review Committee

Charles Yeung SPP 2 SPP RE

Ben Li IESO 2 NPCC

Greg Campoli NYISO 2 NPCC

Mark Holman PJM 2 RF

Matt Goldberg ISONE 2 NPCC

Lori Spence MISO 2 MRO

Christina Bigelow ERCOT 2 Texas RE

Ali Miremadi CAISO 2 WECC

MRO Emily Rousseau

1,2,3,4,5,6 MRO MRO-NERC Standards Review Forum (NSRF)

Joe Depoorter Madison Gas & Electric

3,4,5,6 MRO

Chuck Wicklund Otter Tail Power Company

1,3,5 MRO



Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region

Dave Rudolph Basin Electric Power Cooperative

1,3,5,6 MRO

Kayleigh Wilkerson

Lincoln Electric System

1,3,5,6 MRO

Jodi Jenson Western Area Power Administration

1,6 MRO

Larry Heckert Alliant Energy 4 MRO

Mahmood Safi Omaha Public Utility District

1,3,5,6 MRO

Shannon Weaver Midwest ISO Inc.

2 MRO

Mike Brytowski Great River Energy

1,3,5,6 MRO



Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region

Brad Perrett Minnesota Power

1,5 MRO

Scott Nickels Rochester Public Utilities

4 MRO

Terry Harbour MidAmerican Energy Company

1,3,5,6 MRO

Tom Breene Wisconsin Public Service Corporation

3,4,5,6 MRO

Tony Eddleman Nebraska Public Power District

1,3,5 MRO

Amy Casucelli Xcel Energy 1,3,5,6 MRO

Southern Company - Southern

Katherine Prewitt

1 Southern Company

Scott Moore Alabama Power Company

3 SERC



Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region

Company Services, Inc.

Bill Shultz Southern Company Generation

5 SERC

Jennifer Sykes Southern Company Generation and Energy Marketing

6 SERC

Dominion - Dominion Resources, Inc.

Randi Heise 3,5,6 Dominion - RCS

Larry Nash Dominion Virginia Power

1 SERC

Louis Slade Dominion Resources, Inc.

6 SERC

Connie Lowe Dominion Resources, Inc.

3 RF

Randi Heise Dominion Resources, Inc,

5 NPCC



Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region


Ruida Shu 1,2,3,4,5,6,7,10 NPCC RSC no National Grid

Paul Malozewski Hydro One. 1 NPCC

Guy Zito Northeast Power Coordinating Council

NA - Not Applicable

NPCC

Mark J. Kenny Eversource Energy

1 NPCC

Gregory A. Campoli

NY-ISO 2 NPCC

Randy MacDonald

New Brunswick Power

2 NPCC

Wayne Sipperly New York Power Authority

4 NPCC

David Ramkalawan

Ontario Power Generation

4 NPCC



Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region

Glen Smith Entergy Services

4 NPCC

Brian Robinson Utility Services 5 NPCC

Bruce Metruck New York Power Authority

6 NPCC

Alan Adamson New York State Reliability Council

7 NPCC

Edward Bedder Orange & Rockland Utilities

1 NPCC

David Burke UI 3 NPCC

Michele Tondalo UI 1 NPCC

Sylvain Clermont Hydro Quebec 1 NPCC



Name

Group Member

Organization

Group Member

Segment(s)

Group Member Region

Si Truc Phan Hydro Quebec 2 NPCC

Michael Forte Con-Edison 1 NPCC

Kelly Silver Con-Edison 3 NPCC

Peter Yost Con-Edison 4 NPCC

Sean Bodkin Dominion 4 NPCC

Silvia Parada Mitchell

NextEra Energy

4 NPCC

Brian O'Boyle Con-Edison 5 NPCC

Kathleen M. Goodman

ISO-NE 2 NPCC

Helen Lainis IESO 2 NPCC

Laura Mcleod NB Power 1 NPCC


1. Regarding the feedback loops for input into standards development, do you see other inputs that are missing from this draft RSDP?

Randi Heise - Dominion - Dominion Resources, Inc. - 3,5,6, Group Name Dominion - RCS

Answer No

Document Name

Comment

Dominion suggests adding the words “may be” to the following sentence: “This shows that the measures within some standards are may not be informative enough.”within the Feedback Loops section, Measures. We believe that often requests for guidance within the Measures are based upon a request to identifying elements required to meet compliance rather than ambiguous wording of a standard.

Response: NERC staff generally agrees with this comment and has made responsive changes in the RSDP.

Likes 0

Dislikes 0

Response

Si Truc Phan - Hydro-Quebec TransEnergie - 1 - NPCC

Answer No

Document Name

Comment

Likes 0

Dislikes 0

Response


Tara Lightner - Sunflower Electric Power Corporation - 1 - SPP RE

Answer No

Document Name

Comment

Likes 0

Dislikes 0

Response

Sergio Banuelos - Tri-State G and T Association, Inc. - 1,3,5 - MRO,WECC

Answer No

Document Name

Comment

Likes 0

Dislikes 0

Response

Diana McMahon - Salt River Project - 1,3,5,6 - WECC

Answer Yes

Document Name

Comment


Weighted consideration should be afforded to standards identified through Regional Risk Assessments and included in the ERO CMEP.


Likes 0

Dislikes 0

Response

Jeremy Voll - Basin Electric Power Cooperative - 1,3,5,6

Answer Yes

Document Name

Comment

Basin Electric Power Cooperative recommends that NERC also consider SARs in their feedback loop that are submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment (IRA) since this activity may identify those requirements that are little to no risk to the BES and should be considered for retirement.

ERO Enforcements staff has started to collect “impact” data. In other words, did a violation cause or contribute to some observed impact on reliability. The NSRF believes ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements. Data would also be useful in affirming whether or not a “paragraph 81” related requirement can be retired.

Response: NERC staff generally agrees with these comments and has made responsive changes in the RSDP.

Likes 0

Dislikes 0

Response


Emily Rousseau - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO-NERC Standards Review Forum (NSRF)

Answer Yes

Document Name

Comment

The NSRF recommends that NERC also consider SARs in their feedback loop that are submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment (IRA) since this activity may identify those requirements that are little to no risk to the BES and should be considered for retirement.


ERO Enforcements staff has started to collect “impact” data. In other words, did a violation cause or contribute to some observed impact on reliability. The NSRF believes ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements. Data would also be useful in affirming whether or not a “paragraph 81” related requirement can be retired.

Response: NERC staff generally agrees with this comment and has made responsive changes in the RSDP. Moreover, NERC staff will consider including the subject data in its enhanced periodic review process moving forward.

Likes 0

Dislikes 0

Response

sean erickson - Western Area Power Administration - 1,6

Answer Yes

Document Name

Comment


In the RSDP it is not evident where information from approved Implementation Guidance fits in with this process. It is mentioned under the Feedback Loops Section, but the text has not been updated from last year’s plan. Does it impact the priority of a project, IERP considerations, etc.? For example if there are quality and content issues for a standard, but the approved Implementation Guidance addresses the issues is the priority lowered? Do the projects consider the approved Implementation Guidance and/or the CMEP Practice guides when ranking or deciding to undertake projects? If the approved Implementation Guidance can’t address the main issues associated with standard is the priority raised. The EPR Guidelines don’t appear to consider information produced that is related to the NERC Approved Compliance Guidance Policy. The RSDP should be updated/revised to better reflect the guidance and language provided in the NERC Approved Compliance Guidance Policy.


Likes 0

Dislikes 0

Response

Katherine Prewitt - Southern Company, Southern Company Services, Inc. - 1, Group Name Southern Company

Answer Yes

Document Name

Comment

Since many compliance difficulties associated with a new Standard aren’t identified until the Standard is audited, consider implementing a voluntary pilot for new Standards whereby a participating entity is granted immunity for any violations identified by a targeted, multi-regional audit team. The results of this targeted audit would provide invaluable input to refining the requirements, measures, etc.

Response: Although this is outside the scope of the Standards Committee, NERC has considered such a proposal in the past but declined to take action after receiving feedback from industry indicating it would be costly and overly burdensome.

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Andrew Pusztai - American Transmission Company, LLC - 1

Answer Yes

Document Name

Comment

ATC recommends that NERC also consider SARs in their feedback loop that are submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment (IRA) since this activity may identify Standards which include requirements that provide little to no risk to the BES and should be considered for retirement.


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Terry BIlke - Midcontinent ISO, Inc. - 2

Answer Yes

Document Name

Comment

ERO Enforcements staff has started to collect “impact” data to identify when a violation caused or contributed to some observed impact on reliability. We believe ongoing collection of this information will allow the ERO and the Industry to identify the most consequential


requirements. Data would also be useful in affirming whether or not that a “paragraph 81” can be retired or treated as compliance exceptions.


There’s one feedback loop that should be reconsidered. NERC’s strategic plan notes it intends to use reviews of large system events to address reliability gaps via standards. The occurrence of a single event does not mean there is a reliability gap. W. Edwards Deming noted that that making changes to processes based on reaction to a single event often creates more waste, cost, and inefficiency than doing nothing at all. There is variation in the physical universe and the single data point could be a one-time convergence of multiple factors that would never likely occur again. While it is a worthwhile exercise to learn from events, changes to processes, particularly by implementing new standards, should be based on patterns of data.

Response: The proposed RSDP language does not require NERC to take any specific action on a single event. Rather, events analysis is one of many data points the Enhanced Periodic Review teams will consider.

While not directly part of the RSDP, we believe Standards are one tool in NERC’s kit that can be used to address risks. We believe NERC and the standing committees (including the Standards Committee) should work with the NERC RISC to outline the process to select the appropriate tool based on facts/data, immediacy, estimated risk, cost, and similar factors.

Response: NERC staff generally agrees with this comment and will consider it moving forward in mitigating risk to the BES.

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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,10 - NPCC, Group Name RSC no National Grid

Answer Yes

Document Name


Comment

NPCC Participating Members believe that the Standards Issues Database should be re-established to allow known issues to be “parked” and not lost. These issues can be effectively stored until such time as the standard is re-opened again during an EPR.

Response: NERC staff generally agrees with this comment. Although not specifically related to the RSDP, NERC is evaluating possible mechanisms to track issues for consideration in future standards development.

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Charles Yeung - Southwest Power Pool, Inc. - 2, Group Name IRC Standards Review Committee

Answer Yes

Document Name

Comment

ERO Enforcement staff has started to collect “impact” data, in other words, did a violation cause or contribute to some observed impact on reliability? We believe ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements. Data would also be useful in affirming whether or not that a “paragraph 81” can be retired.


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Rachel Coyne - Texas Reliability Entity, Inc. - 10

Answer

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Comment

Texas RE recommends changing “Audit Feedback” to “Compliance Monitoring and Enforcement Feedback”. Monitoring processes should include issues that arise in the Enforcement process. For instance, many issues with Standard requirements, as well as measures and other supporting materials arise through the processing of self-reports and self-logs. These experiences should be incorporated into a complete Standards feedback loop.


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2. Is there any information reported in the RSDP you believe is no longer useful or relevant?


Answer No

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Answer No

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Answer No

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Tara Lightner - Sunflower Electric Power Corporation - 1 - SPP RE

Answer No

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Answer No

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Answer No

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NPCC Participating Members believe that the RSDP should be a workplan of what is going to be done for standards development. The RSDP need not be a status report of what has been done, looking back. We suggest that the plan focus strictly on resources and projects that are going to be continued or started in the coming years covered by the plan. We don’t believe there is much value discussing and tracking issues such as outstanding FERC Directives. These other issues such as P-81 remaining issues, IERP recommendations and outstanding Directives should instead be status reports appearing in the weekly bulletin or as status items to the NERC Board of Trustees from the SC Chair.

Response: NERC staff generally agrees with this comment with some exceptions. For example, the NERC Rules of Procedures section 310 requires each RSDP to include a progress report comparing results achieved to the prior year’s RSDP. However, NERC staff believes the nature of that reporting can be refined, and is therefore working with the NERC Standards Committee on possibly refocusing the purpose of future RSDPs to provide stakeholders more relevant and actionable information.

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Answer Yes

Document Name

Comment

The Measures section under the Feedback Loops Section looks outdated and not in alignment with CMEP Practice guides or approved Implementation Guidance which are detailed in the NERC Approved Compliance Guidance Policy. Where or how do these requests for guidance on measuring fit in with the guidance policy which details a move to the use of approved Implementation Guidance and CMEP Practice guides? As I understand the policy these two items should provide the guidance the industry is requesting. The former coming from the industry would provide methods to implement with internal controls that measure and validate performance. The latter coming from the ERO/RRO provides information about the methods and what the auditors will be looking for to validate compliance. The CMEP practice guide represents the measures used by the ERO/RRO to check the effectiveness of internal controls and validate compliance. Because of this both items need to be considered and factored into the RSDP and right now they do not appear to be addressed in the draft. Putting an effort into get these items reviewed, approved and published could provide what is needed to avoid numerous revisions to the same standard.

The effort and cost associated with revising a standard can be enormous for all involved, so reducing the number of revisions to a standard thru use of approved Implementation Guidance and CMEP Practice guides benefits everyone and supports the ultimate goal of improved reliability to the BES. In addition when there is a change to a Reliability Standard new risks to the reliability of the BES can be introduced that will diminish over time. Frequent changes to the same Reliability Standard impacts the time needed to allow any new risks to diminish.

Response: NERC staff does not believe that the current RSDP is the appropriate forum to address these concerns. NERC staff recommends the commenter seek opportunities to discuss the issues with CMEP.

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3. Is there any information you believe NERC should report in the RSDP that is missing?


Answer No

Document Name

Comment

There are many activities outlined in the RSDP and NERC staff, drafting teams, and the Standards Committee should be commended in bringing us to a point where we have a sound body of standards. That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together. It also looks like these activities, combined with ongoing FERC directives and directives that occur when filing an “improved” standard will preclude achieving steady state.

Basin Electric Power Cooperative offers the following recommendations:

• The front of the RSDP should have long term (e.g. 10 year) objectives or principles in order to guide what we want the standards to be in the future. Examples might include:

o Maintain a set of clear, “workably effective” (not perfect) standards that provide an “adequate level of reliability.

o Develop new standards when

Directed by FERC.

Data affirms a reliability risk

When the industry affirms prior to starting the project that the investment is worth pursuing the project.

• Create a table or spreadsheet that tracks the next mandatory 10 year review date.


• Outline in the plan what specifically causes a standard to get escalated due to reliability risks. In general, Basin Electric Power Cooperative believes the activities in the RSDP should be used as input to decide whether or not to open a standard, not to move it earlier in the queue in order to always have something in the pipeline.

Response: NERC staff agrees with many of these comments as reflected in responsive changes in the current draft RSDP. Since NERC staff currently is working with the NERC Standards Committee on the focus of future RSDPs, many of these suggestions will be forwarded to that group for future consideration.

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Answer No

Document Name

Comment

There are many activities outlined in the RSDP and NERC staff, drafting teams, and the Standards Committee should be commended in bringing us to a point where we have a sound body of standards. That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together. It also looks like these activities, combined with ongoing FERC directives and directives that occur when filing an “improved” standard will preclude achieving steady state.

The NSRF offers the following recommendations:


• Maintain a set of clear, “workably effective” (not perfect) standards that provide an “adequate level of reliability. • Develop new standards when


• Directed by FERC. • Data affirms a reliability risk • When the industry affirms prior to starting the project that the investment is worth pursuing the project. • Create a table or spreadsheet that tracks the next mandatory 10 year review date. • Outline in the plan what specifically causes a standard to get escalated due to reliability risks. In general, the NSRF believes the

activities in the RSDP should be used as input to decide whether or not to open a standard, not to move it earlier in the queue in order to always have something in the pipeline.


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Tara Lightner - Sunflower Electric Power Corporation -1 - SPP RE

Answer No

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Answer No


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Answer Yes

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Comment

Dominion believes that the inclusion of the presentation or a link to the NERC Standards Grading Backgroup and Process presentation dated June7, 2016 would be beneficial in understanding the Grading flowchart and process.

Response: NERC staff generally agrees with this comment and has therefore provided a link to the Standards Grading project page that contains among other things the requested information.

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Answer Yes

Document Name


Comment

There are many activities outlined in the RSDP. NERC staff, drafting teams, and the Standards Committee should be commended bring us to a point where we have a sound body of standards. That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together. It also appears that these activities, combined with ongoing directives and directives that occur when filing a revised standard, will prevent the ERO from achieving steady state. With this regard, we offer the following recommendations:


o Maintain a set of clear, workable (not perfect) standards that provide an adequate level of reliability.

o Develop new standards when

Directed by FERC.

Data affirms a reliability risk.

When the industry affirms prior to starting the project that the investment is worth pursuing the project.

• Create and post a table that gives the next mandatory 10 year review date.

• Outline in the plan what specifically causes a standard to get escalated. In general, we believe the activities in the RSDP should be used as input to decide whether or not to open a standard, not to move it earlier in the queue in order to always have something in the pipeline.


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Answer Yes

Document Name

Comment

There are many activities outlined in the RSDP and NERC staff, drafting teams, and the Standards Committee should be commended for bringing us to a point where we have a sound body of standards. That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together. In other words, how do all the outcomes of these reliability based activities get introduced into a standards project? It also looks like these activities, combined with ongoing directives and directives that occur when filing an “improved” standard will preclude achieving steady state.

We offer the following recommendations:


o Maintain a set of clear, workable (not perfect) standards that provide an adequate level of reliability.

o Create a standards project when:

Directed by FERC.

Data affirms a reliability risk or gap

A cost effectiveness study affirms the project is worth pursuing

• Create a table that gives the next mandatory 10 year review date.


• Outline in the plan what specifically causes a standard to get escalated into an active standards project and introduced into the RSDP. In general, we believe the activities in the RSDP should be used as input to decide whether or not to open an approved standard for changes, not to move it earlier in the queue in order to always have something in the pipeline.


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Answer Yes

Document Name

Comment

There are no requests for interpretation (RFI) under the "Interpretations" section of the current draft. However, it is our understanding that there are at least a few RFIs that have been discussed by the NERC Standards Committee and are in the queue to be worked on. For example, we have heard in several NERC forums that the "Project 2016-02 Modifications to CIP Standards" drafting team has been tasked with reviewing an outstanding RFI regarding "shared BES Cyber Systems". Yet, we do not see this reflected anywhere in the RSDP. Tri-State would like to see more transparency regarding RFIs. If there are some requests pending, then they should be included in the RSDP since that could have an impact on standards development. Industry should be able to see what RFIs are in the queue, their status and estimated timeline for when those interpretations will be addressed.

Response: NERC generally agrees with this comment. Therefore, known and SC accepted RFIs are now included in the RSDP. NERC is evaluating the current RFI process and will consider this comment during the evaluation.


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4. Please provide any additional comments you would care to offer.


Answer

Document Name

Comment

The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat. FERC noted the need for a more adaptable approach at the recent Reliability Conference. One activity in the RSDP should be to take a step back and via technical conferences or other outreach try to develop an improved approach. NERC should develop a stable set of core CIP standards based on a review of the current set of CIP standards.

Response: Since NERC staff currently is working with the NERC Standards Committee on the focus of future RSDPs, NERC will forward this suggestion to that group for future consideration.

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Comment

NPCC supports the pace of standards development and the EPR process as well as feedback loops noted in the RSDP and encourages the use of the Standards Grading activity to help prioritize Standards requiring revision. NPCC also supports Cost Effectiveness analysis


activities and the NERC pilot to develop and refine any such analysis. We also suggest promoting the concept of cost effectiveness to the Reliability Issues Steering Committee (RISC). NPCC believes that cost considerations should enter into the emerging risk decision making process that the RISC is engaged in.

Response: NERC staff generally agrees with these comments.

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Answer

Document Name

Comment

The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat. FERC noted the need for a more adaptable approach at the recent Reliability Conference. One activity in the RSDP should be to take a step back and via technical conferences or other outreach develop an improved approach to address CIP risk. Things to be considered include:

• A stable set of core CIP standards.

• Unless there is a national emergency threat, have a measured burn-in period for CIP changes, where for a period after a new requirement is approved and implemented, it goes through a period (e.g. 2-3 years) where missteps (not programmatic failures) are handled as Compliance Exceptions.


• Move away from using standards for emerging and less defined issues. We believe that Readiness Reviews (aka Peer Reviews, Assistance Visits) would be a more nimble approach to evolving issues and move us from a least common denominator approach to one that pursues excellence.

Response: NERC staff generally agrees with many of these comments but notes that NERC and the industry need to respond to directives that often have mandatory deadlines. Standard drafting teams will continue to consider implementation dates. Additionally, since NERC staff currently is working with the NERC Standards Committee on the focus of future RSDPs, NERC will forward this suggestion to that group for future consideration.

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Answer

Document Name

Comment

Additionally, Dominion believes that Footnote 2, Page iv, “2 The Standards Committee approved an EPR template on September 30, 2014 and presented it to the NERC Board of Trustees on November 12, 2014 as part of the Standard Committee’s update. The template includes background information and questions to guide a comprehensive review of the standard(s) by the EPR team, and serves as documentation of the EPR team’s considerations and recommendations “ as it related to the statement in the Executive Summary, Page iv, first sentence in the second paragraph, “As with the 2016-2018 RSDP, EPRs will occur at a measured pace2 …” does not clarify the term measured pace but seems to be related to the template being used. Please consider updating the reference to clarify what is meant by a measured pace.

Also, Dominion suggests that throughout the document: since this is a NERC document, should the defined terms for the various functional entities (i.e. Reliability Coordinator, Balancing Authority, Transmission Operator, etc…) be used when describing the FERC


directives even though the FERC order does not use these defined terms? The FERC orders are not being directly quoted so this would appear to be appropriate. This would be consistent with other defined terms being used throughout the document.

Project 2015-08: Dominion believes adding a footnote to the FERC guidance reference would be helpful. Project commencing in 2017: Some additional information on potential emerging risks (i.e. GMD, CPP, etc…) would be helpful.

Dominion also notes that the RSDP has no mention or discussion of upcoming NERC assessments and coordination with standards/stakeholders on the impact these assessments could have on standards development and planning. Therefore, Dominion suggests that including some discussion on this interaction could be beneficial. This topic could also influence the criteria for EPRs.

Dominion recommends that in general, the entire document could use a refresh as it reads the same as it has for the last 4-5 years.

Response: NERC staff generally agrees with many of these comments as reflected in responsive changes in the current draft RSDP. Since NERC staff currently is working with the NERC Standards Committee on the focus of future RSDPs, some of these suggestions will be forwarded to that group for future consideration.

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Answer

Document Name

Comment

Editorial Changes recommended by ATC:

The RSDP Table of Contents should list the two new attachments:


The draft RSDP should have a placeholder for Attachment 2 as not to overlook adding the attachment at a later date when the 2016 final Standards Grading is completed.

1. Attachment 1 –Enhanced Periodic Review Guidelines

2. Attachment 2 – Final Standards Grading for Standards Graded in 2016

• The draft RSDP should have a placeholder (Blank pg.) at the end for Attachment 2 as not to overlook adding the attachment when the 2016 final Standards Grading is completed.

Response: NERC staff generally agrees with these comments as reflected in responsive changes in the current draft RSDP.

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Answer

Document Name

Comment

The process is missing a feedback loop from FERC once an Order is posted to the Federal Register. The SDP teams need to then clarify the implementation dates in the implementation plans for the Standard, instead of just leaving it in the circular references they do today.

Response: NERC staff generally agrees with this comment but notes that the current process accounts for FERC orders.

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Answer

Document Name

Comment

On page 5, first line, the reference to the « PRC family of standards » should be broken out so that specific standards are identified as eligible.

Response: NERC staff agrees with this comment as reflected in responsive changes in the current draft RSDP.

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Answer

Document Name

Comment

Editorial Changes Only:

1. The RSDP Table of Contents should list the two new attachments: • Attachment 1 –Enhanced Periodic Review Guidelines • Attachment 2 – Final Standards Grading for Standards Graded in 2016

2. The draft RSDP should have a placeholder for Attachment 2 as not to overlook adding at a later date.


The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat. FERC noted the need for a more adaptable approach at the recent Reliability Conference. One activity in the RSDP should be to take a step back and via technical conferences or other outreach try to develop an improved approach. Things to be considered include:


• Unless there is a national emergency threat, have a measured burn-in period for CIP changes, where for a period after a new requirement is approved and implement, it goes through a period (e.g. 2-3 years) where missteps (not programmatic failures) are handled as Compliance Exceptions.

• Move away from using standards for emerging and less defined issues. The NSRF believes that Readiness Reviews (aka Peer Reviews, Assistance Visits) would be a more nimble approach to evolving issues and move us from a least common denominator approach to one that pursues excellence.

Response: NERC staff generally agrees with many of these comments as reflected in responsive changes in the current draft RSDP.

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Answer

Document Name

Comment

Editorial Changes Only:

1. The RSDP Table of Contents should list the two new attachments:


i. Attachment 1 – Enhanced Periodic Review Guidelines

ii. Attachment 2 – Final Standards Grading for Standards Graded in 2016

2. The draft RSDP should have a placeholder for Attachment 2 as not to overlook adding at a later date.

The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat. FERC noted the need for a more adaptable approach at the recent Reliability Conference. One activity in the RSDP should be to take a step back and via technical conferences or other outreach try to develop an improved approach. Things to be considered include:


• Unless there is a national emergency threat, have a measured burn-in period for CIP changes, where for a period after a new requirement is approved and implement, it goes through a period (e.g. 2-3 years) where missteps (not programmatic failures) are handled as Compliance Exceptions.

• Move away from using standards for emerging and less defined issues. Basin Electric Power Cooperative believes that Readiness Reviews (aka Peer Reviews, Assistance Visits) would be a more nimble approach to evolving issues and move us from a least common denominator approach to one that pursues excellence.

Response: NERC staff generally agrees with many of these comments but notes that NERC and the industry need to respond to directives that often have mandatory deadlines. Standard drafting teams will continue to consider implementation dates. Additionally, since NERC staff currently is working with the NERC Standards Committee on the focus of future RSDPs, NERC will forward this suggestion to that group for future consideration.

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Standards Committee Charter

Action Approve the Standards Committee (SC) Charter with edits to Section 4 in the attached.

Background The SC 2016-2018 Strategic Work Plan stated:

Task No. 5 – Fourth Quarter Review of SC 2016-2018 Strategic Work Plan “The SC Executive Committee (SCEC) shall evaluate the need for additional reforms or enhancements to the SC Charter.”

In evaluating the need for additional reforms or enhancements to the SC Charter, the SCEC recommends adding a provision for Mexican representation on the SC in a similar manner as that provided for Canadian representation. There has been significant collaboration between NERC and Mexico following Mexico’s historic energy reforms to launch a competitive energy market and to become more interconnected. Given Mexican interest in participating on the SC, NERC supports updating the SC Charter in this manner for several reasons:

1. It is consistent with the requirement under Section 215 of the Federal Power Act thatNERC would seek recognition with both Canada and Mexico, and supports theestablishment of a common reliability framework as Mexico is implementing its reformsand seeking to become more interconnected.

2. As of earlier this year, certain NERC Reliability Standards are mandatory and enforceablein all of Mexico, and the Mexican regulator is required to update its regulations annuallyover the next five years. As the Mexican regulator proceeds through these updates, itenvisions adopting more standards each year, and participation on the SC would give itsome ownership of the standards and facilitate its internal processes.

3. It furthers ongoing collaboration and opportunity for all SC membership and interestedparties to learn from Mexico’s experiences as they undergo their current transition to amandatory Reliability Standards regime.

Specifically, in the attached, Section 4 of the SC Charter related to “Membership” was modified in the following two ways:

1. Modification to paragraph (4) related to Canadian membership for clarity; appointments occurring under that provision are intended to ensure up to two voting Canadian members.

2. Addition of a new paragraph (5) to provide for appointment of one Mexicanrepresentative when an annual election does not result in at least one voting SCrepresentative from Mexico.

NERC | Standards Committee Charter | December 9, 2014 September 14, 2016

Standards Committee Charter Approved by the Standards Committee

December 9, 2014, September 14, 2016



Table of Contents

Standards Committee Charter ....................................................................................................................................2

Section 1. Purpose ..................................................................................................................................................2

Section 2. Reporting ................................................................................................................................................2

Section 3. Overview and Functions .........................................................................................................................2

Section 4. Membership ...........................................................................................................................................3

Segment Representation ....................................................................................................................................3

Section 5. Officers ................................................................................................................................................ 43

1. Selection. ................................................................................................................................................... 43

2. Terms. ........................................................................................................................................................ 43

3. Voting. ....................................................................................................................................................... 43

4. Duties of the Chair. ................................................................................................................................... 43

5. Duties of the Vice Chair. ............................................................................................................................ 53

6. Duties of the Secretary.............................................................................................................................. 53

Section 6. Voting Members’ Expectations and Responsibilities ...................................................................... 53

1. Committee voting members: .................................................................................................................... 53

Section 7. Executive Committee and Subcommittees ..................................................................................... 63

1. Executive Committee. ............................................................................................................................... 63

2. Additional Subcommittees, Task Forces, and ad hoc Working Groups. ................................................... 63

Section 8. Meetings .......................................................................................................................................... 63

1. Open Meetings. ......................................................................................................................................... 63

2. General Requirements. ............................................................................................................................. 63

3. Notice. ....................................................................................................................................................... 63

4. Agenda. ..................................................................................................................................................... 63

5. Parliamentary Procedures. ........................................................................................................................ 73

6. Quorum. .................................................................................................................................................... 73

7. Voting. ....................................................................................................................................................... 73

8. Actions without a Meeting. ....................................................................................................................... 73

9. Proxies. ...................................................................................................................................................... 73

10. Field Tests. ................................................................................................................................................. 73



Section 1. Purpose The Standards Committee (the Committee) of the North American Electric Reliability Corporation (NERC), working together with NERC Standards Staff, manages and executes the Reliability Standards development process for the timely development and maintenance of a comprehensive set of results-based Reliability Standards that collectively provide for the Reliable Operation of the North American Bulk-Power System.

Section 2. Reporting The Committee reports and is accountable to the NERC Board of Trustees. The Committee has the responsibility to keep the industry segments informed regarding Reliability Standards. The NERC Board of Trustees shall approve this Charter and any amendments to this Charter pursuant to Section 1300 of the NERC Rules of Procedure.

Section 3. Overview and Functions The Committee, working together with NERC Standards Staff, manages the development and maintenance of a comprehensive set of results-based Reliability Standards that collectively provide for the Reliable Operation of the North American Bulk-Power System. Specifically, working together with NERC Standards Staff, the Committee has the following duties:

1. Develops a long-term (multi-year) strategic vision describing the goals and direction for Reliability Standards development consistent with NERC’s strategic and business plans.

2. Coordinates with the Reliability Issues Steering Committee to develop a Reliability Standards Development Plan (RSDP) prioritizing and aggressively pursuing work resulting in a body of high-quality, results-based Reliability Standards.

3. Assists with the drafts and development of the RSDP, including preparing the initial posting for stakeholder comment.

4. Establishes and facilitates informal and formal collaborative, consensus building processes with stakeholder groups and NERC committees throughout Reliability Standards development.

5. Establishes quality assurance and quality control process for reviews of Reliability Standards for clarity, completeness, sufficient detail, rational result, auditability and enforceability, as well as compatibility with existing Reliability Standards.

6. Appoints, monitors and directs agile and focused standard drafting teams generally consisting of no more than ten members (e.g., subject matter experts, a facilitator, a technical writer and compliance, legal and regulatory experts). The drafting teams should be suitably equipped to address the desired reliability objectives.

7. Receives and responds to decisions of appeals panels in accordance with the Reliability Standards process.

8. Develops, maintains and implements a Standard Processes Manual ensuring the integrity of Reliability Standards development in a manner that is fair, balanced, open and inclusive.

9. Facilitates communication about regular NERC Standards department and Standards Committee work, such as Reliability Standards under development and Standards Committee guiding documents.


NERC | Standards Committee Charter | December 9, 2014 August 15, 2016 3

Section 4. Membership Segment Representation The Committee membership consists of two members elected from each industry segment. Each industry segment may establish its own rules for electing and replacing its representatives consistent with the following requirements:

1. Membership Requirements.

a. No two persons employed by the same corporation or organization or by its affiliates may serve concurrently as Committee members.

b. Any Committee member with a membership conflict of this nature shall notify the Committee secretary, who shall inform the Committee chair.

c. Members impacted by a conflict, such as through a merger of organizations, may confer between themselves to determine which member should resign from the Committee and notify the Committee secretary and chair. If the conflict is not resolved in a timely manner by the impacted members, the Committee chair shall notify all members of the affected industry segments about the need to resolve the conflict. If the membership conflict is still unresolved, the Committee chair shall take the conflict to the NERC Board of Trustees for resolution.

d. Any Committee member aware of an unresolved membership issue shall notify the Committee chair.

2. Resignation from the Committee. Any member of the Committee who resigns from the Committee shall submit a written resignation to the Committee secretary and Committee chair.

a. The Committee secretary shall facilitate the election of a replacement member from the applicable industry segment. The new member shall serve the remainder of the vacant member’s term.

b. If any member of the Committee fails to attend or send a proxy for more than two consecutive regularly scheduled meetings and/or conference calls, or more than two e-mail ballots between regularly-scheduled meetings, the Committee chair shall send a written notice to that member. The member shall be advised to submit a resignation or request continuation of the membership with an explanation of any extenuating circumstances. If a written response is not received from the member within 30 days of the date of the written notice, the lack of response shall be deemed a resignation.

3. Committee Member Changing Employment.

a. Any Committee member who leaves one organization and is subsequently employed by another organization in the same industry segment may retain the membership position.

b. If a Committee member changes employment to an organization in a different industry segment, that Committee member shall resign from the Committee no later than the date of the employment change. The resignation letter shall be addressed to the Committee chair who will send a letter to the Committee secretary requesting an election to fill the vacant position.

4. Canadian Representation. If, at any time, the regular Committee election does not result in at least two voting members seated from Canada, up to two Canadian members garnering the highest percentage of votes within their segment will serve as additional Committee members, as needed to achieve a total of two Canadian members. The preference is to have the Canadian nominees fill any segment vacancies for which they are qualified.


5. Mexican Representation. If, at any time, the regular Committee election does not result in at least one voting member seated from Mexico, one Mexican member garnering the highest percentage of votes within his or her segment will serve as an additional Committee member. The preference is to have the Mexican nominee fill any segment vacancies for which he or she is qualified.

6. Membership Terms. Committee members shall serve a term of two years without limitation to the number of terms the members may serve, with members’ terms staggered so half of the member positions (one per segment) are elected each year by industry segment election. Membership terms start on January 1 of each year.

7. Vacancies Caused by Election of Officers. The vacancies in the industry segments and/or Canada representation created by selection of the chair and vice chair shall be filled at the next annual election of Committee representatives. When a representative is elected to serve as the chair or vice chair during the second year of a two year term, the representative elected to fill the vacancy shall serve a one year term.

8. NERC Director of Standards. Acts as a non-voting Committee member to represent NERC’s position on agenda items with the assistance of NERC Standards Staff.

Section 5. Officers 1. Selection.

Prior to the annual election of Committee representatives in odd numbered years, the Committee members shall select a chair and vice chair from among their membership by majority vote. The newly-elected chair and vice chair cannot represent the same industry segment. A nominating committee shall solicit nominations for chair and vice chair no less than 30 days prior to the election. The nominating committee shall consult with the chair of the NERC Board of Trustees’ Standards Oversight and Technology Committee on the nominations received.

No less than ten days before the election, the nominating committee shall provide to the Committee members the qualifications of the chair and vice chair nominees. At the time of the election, the Committee can accept nominations from the floor. Following the election, the successful candidates shall be presented to the NERC Board of Trustees for approval. The chair and vice chair, upon assuming such positions, shall cease to act as representatives of the industry segments that elected them and shall thereafter be responsible for acting in the best interests of the Committee as a whole.

2. Terms. The term of office for the Committee chair and vice chair is two years without limit on the number of terms an officer may serve. A member of NERC staff serves as the Committee’s non-voting secretary.

3. Voting. The Committee chair and vice chair are non-voting Committee members.

4. Duties of the Chair. In addition to the duties, rights and privileges discussed elsewhere in this document, the Committee chair:

a. Presides over and provides general supervision of Committee and Executive Committee activities and meetings.

b. Presides over all Committee meetings, including the nature and length of discussion, recognition of speakers, motions and voting.

c. In concert with NERC Staff, schedules Committee meetings.

d. Reviews all substitute or proxy representatives.



e. Acts as Committee spokesperson at forums within and outside of NERC.

f. Reports Committee activities to the NERC Board of Trustees and attends Board of Trustees meetings.

g. Reports all views and objections when reporting on items brought to the Committee.

h. Performs other duties as directed by the NERC Board of Trustees.

5. Duties of the Vice Chair. The Committee vice chair acts as the Committee chair if requested by the chair (for brief periods of time) or if the chair is absent or unable to perform his/her duties. If the chair resigns prior to the next scheduled election, the vice chair shall act as the chair until the Committee selects a new chair. The vice chair:

a. Assists the Committee chair.

b. Attends meetings of the NERC Board of Trustees in the chair’s absence.

c. Assists the chair in managing all Committee meetings, including the nature and length of discussion, recognition of speakers, motions and voting.

d. Assists the Committee chair in reviewing all substitute or proxy representatives.

6. Duties of the Secretary. A member of NERC staff shall serve under the direction of the Committee officers as a non-voting secretary and has the responsibility to:

a. Conduct the day-to-day operation and business of the Committee.

b. Prepare, distribute and post notices of Committee meetings, record meeting proceedings, and prepare, distribute and post meeting minutes.

c. Maintain a record of all Committee proceedings, including responses, voting records, and correspondence.

d. Maintain Committee membership records.

Section 6. Voting Members’ Expectations and Responsibilities 1. Committee voting members:

a. Contribute to the work and success of the Committee by, among other things, executing the Committee Strategic Work Plan.

b. Serve as subject matter expert representatives of their industry segments and represent their industry segments.

c. Should be knowledgeable about NERC Reliability Standards development activities.

d. Express their opinions on behalf of their segments at Committee meetings.

e. Respond promptly to all Committee requests for attendance, reviews, comments and voting.

f. Assist in educating the industry on the Reliability Standards development process.

g. When unable to attend a Committee meeting, notify the secretary and identify a proxy as described under Section 8. Meetings, sub section 9. Proxies, infra. The member is expected to instruct the proxy on his/her role and responsibilities.

h. Duty of Care: Use due care and are diligent with respect to the management and administration of the affairs of NERC and the Committee. This duty of care is generally thought to have two



components: (i) the time and attention devoted to NERC’s mission, and (ii) the skill and judgment reflected in the Committee’s decisions.

i. Duty of Loyalty: The duty of loyalty requires the members to faithfully promote the mission of NERC and the Committee, rather than their own or their entities’ interests. This duty includes compliance with NERC’s policies on conflicts of interest.

j. Duty to Adhere to High Ethical Standards: The duty to adhere to the applicable law and high ethical standards requires that Committee members devote themselves to assuring they operate to further NERC’s stated objectives in compliance with legal requirements and high ethical standards.

Section 7. Executive Committee and Subcommittees 1. Executive Committee.

The Committee shall have an Executive Committee consisting of five members, including the Committee officers and three segment members, elected by the Committee. The three segment members cannot represent the same industry segments the Committee officers previously represented, nor can any two of the segment members be from the same segment. The Executive Committee will be elected annually at the January Committee meeting. The Executive Committee shall meet when necessary between regularly-scheduled Committee meetings to conduct Committee business, including actions delegated by the full Committee. Additionally, the Executive Committee shall have the authority to:

a. Work with NERC Standards Staff to set agendas for Committee meetings.

b. Act on the Committee’s behalf to authorize postings of SARs, Reliability Standards, and other Standards-related documents.

c. Provide advice and guidance to subcommittee chairs, as needed.

2. Additional Subcommittees, Task Forces, and ad hoc Working Groups. The Committee may form subcommittees, task forces and ad hoc working groups, as it deems appropriate.

Section 8. Meetings 1. Open Meetings.

Committee meetings shall be open to all interested parties who pre-register by the cut-off date included in the meeting announcement. Meeting notices shall describe the meeting’s purpose and identify a readily available source for further information about the meeting. Only voting members may act on items before the Committee. Meeting notices and agendas shall be posted publicly on the NERC website on the same day they are distributed to Committee members. Final minutes of Committee meetings shall be posted publicly on the NERC website the day after Committee approval.

2. General Requirements. The Committee shall hold meetings as needed and may use conference calls or e-mail to conduct its business.

3. Notice. The Committee secretary shall announce regularly scheduled meetings with a written notice (letter, facsimile, or e-mail) to all Committee members not less than ten nor more than sixty calendar days prior to the meeting date.

4. Agenda. The secretary shall provide an agenda with a written notice (letter, facsimile, or e-mail) for Committee meetings no less than five business days before a proposed meeting.



a. The agenda shall include, as necessary, background material for agenda items requiring a decision or vote. The secretary shall post the agenda on the NERC website the same day it is distributed to Committee members.

b. Items not in the agenda that require a vote cannot be added at a meeting without the unanimous consent of the members present. If such a matter arises, it may also be deferred to the next meeting to allow Committee members to consult with their industry segments.

5. Parliamentary Procedures. In the absence of specific provisions in this Charter, the Committee shall conduct its meetings guided by the most recent edition of Robert’s Rules of Order, Newly Revised.

6. Quorum. A quorum requires two-thirds of the Committee voting members.

7. Voting. Voting may take place during regularly scheduled meetings or may take place through electronic means.

a. All Committee actions shall be approved upon receipt of the affirmative vote of a majority of the members present and voting at a meeting with a quorum present, with the exception of revisions to the Standard Processes Manual and the Committee Charter which can be approved only upon receipt of the affirmative vote of two-thirds of the members present and voting at a meeting with a quorum present.

b. Each individual member’s vote for each action taken shall be included in the minutes of each meeting, unless the vote is unanimous with no abstentions.

8. Actions without a Meeting. The Committee may act by mail or electronic (facsimile or e-mail) ballot without a regularly-scheduled meeting. A majority of the members participating in the voting is required to approve any action. A quorum for actions without a meeting is two-thirds of Committee members. The Committee chair or four members (each from a different industry segment) may initiate the request for an action without a meeting. The secretary shall post a notice on the NERC website and provide Committee members a written notice (letter, facsimile, or e-mail) of the subject matter for action not less than three business days prior to the date on which the vote is to be conducted. The secretary shall distribute a written notice to the Committee (letter, facsimile, or e-mail) of the results of such action within five business days following the vote and post the notice on the NERC website. The secretary shall keep a record of all responses (e-mails, facsimiles, etc.) from the Committee members with the Committee minutes.

9. Proxies. A Committee member may designate a proxy. Proxies may attend and vote at Committee meetings provided the absent Committee member notifies in writing (letter, facsimile, or e-mail) the Committee chair, vice chair or secretary along with the reason(s) for the proxy. The member shall name the proxy representative and his/her affiliation in the correspondence. No Committee member can serve as a proxy for another Committee member. The proxy must adhere to the Voting Members’ Expectations and Responsibilities as described in Section 6, above.

10. Field Tests. When authorizing any field test that modifies or supports NERC Reliability Standard requirement development, it is strongly recommended that the Committee, with input from the applicable drafting team, first receive acceptance from the relevant technical committee (e.g., Operating Committee, Planning Committee, or Critical Infrastructure Protection Committee) that the field test would not be expected to adversely impact BES reliability. Further, if BES reliability is or is expected to be adversely impacted during the course of any field test, the relevant technical committee may request the Standards Committee to suspend the field test until such time that the situation can be reviewed by the relevant



technical committee and, if necessary, the field test be modified by the relevant technical committee, as appropriate. When authorizing a drafting team to collect and analyze data or to conduct a field test of one or more requirements, the Committee may also request the assistance of the Compliance Monitoring and Enforcement Program.


Standards Committee Annual Accomplishments

Action Endorse the following:

1. The Standards Committee Executive Committee (SCEC) using the following metrics andself-evaluation process to assess the Standards Committee’s (SC) 2016accomplishments:

• Was a project schedule presented? (task 1) – yes/no• Did the Project Management Oversight Subcommittee and NERC Staff work together

to present for SC endorsement a prioritization and timing of 2016 Enhanced PeriodicReviews ? (task 2) – yes/no

• With the assistance of NERC staff, the leadership of the Operating Committee,Planning Committee, and the Critical Infrastructure Protection Committee, did theSC develop a Standard metric approach for the NERC Board of Trusteesendorsement? (task 3) – yes/no

• Did the NERC staff and the Standards Committee Process Subcommittee considerrevisions to the NERC Standard Processes Manual section 11 consistent with theCompliance Guidance Policy Paper? (task 4) – yes/no

• Did the SC conduct a review of its 2016-2018 Strategic Work Plan? (task 5) – yes/no• Did the SCEC evaluate the need for additional reforms or enhancements to the SC

Charter? (task 5) – yes/no; and

2. The SCEC presenting the results of answers to the above questions to the SC in itsDecember 2016 meeting for the SC’s endorsement.

Background The 2016-2018 Standards Committee Strategic Plan required that the SC “develop metrics and a self-evaluation process to assess its annual accomplishments.” The Action Item requires the SCEC to review each of the annual required tasks and provide the results of whether the SC accomplished each of the required tasks at the December 2016 meeting.


Standards Committee Meeting Dates and Locations for 2017

Action Approve either Option 1 or Option 2 of the following schedule of dates and times for the Standards Committee (SC) during 2017.

Schedule Option 1 The schedule below would be based on the Standards Committee Process Subcommittee (SCPS) meeting the day before and the Project Management Oversight Subcommittee (PMOS) meeting two hours prior to the SC in-person meetings. The PMOS has indicated a preference to meet the day of the SC meeting for two hours rather than the day before.

There are a number of benefits to this schedule:

• SC members can observe and/or participate in both the SCPS and the PMOS meetings.We would encourage SC members to participate more fully in the PMOS discussions,perhaps giving them even better insight into the work of the individual drafting teams.

• For joint activities requiring certain members of both SCPS and PMOS, such as thereview of the Standard Authorization Request document, it will be easier to synchronizeagendas and meetings.

• PMOS members who provide management oversight for standard drafting teams willhave a greater opportunity to observe and participate in, as appropriate, the larger SCmeeting. They will have exposure to our discussions at the SC meeting, giving themgreater insight and understanding of priorities and concerns.

• It has been difficult in the past to gauge how long SC meetings would last; however, it isalso important to meet face-to-face on a regular basis. This schedule option would allowa full day to discuss important standards topics.

Date Location/Time January 18, 2017 Conference Call (1:00 - 4:00 p.m.) March 15, 2017 WECC (10:00 a.m. – 3:00 p.m.) April 19, 2017 Conference Call (1:00 - 4:00 p.m.) June 14, 2017 Atlanta (10:00 a.m. – 3:00 p.m.) July 19, 2017 Conference Call (1:00 - 4:00 p.m.) September 7, 20171 MRO (10:00 a.m. – 3:00 p.m.) October 18, 2017 Conference Call (1:00 - 4:00 p.m.) December 6, 2017 Atlanta (10:00 a.m. – 3:00 p.m.)

1 On Thursday, due to Monday holiday in United States.


Option 2Same as 2016. SCPS and the PMOS meeting the day before.

Date Location/Time January 18, 2017 Conference Call (1:00 - 4:00 p.m.) March 15, 2017 WECC (8:00 a.m. – 2:00 p.m.) April 19, 2017 Conference Call (1:00 - 4:00 p.m.) June 14, 2017 Atlanta (8:00 a.m. – 2:00 p.m.) July 19, 2017 Conference Call (1:00 - 4:00 p.m.) September 7, 20172 MRO (8:00 a.m. – 2:00 p.m.) October 18, 2017 Conference Call (1:00 - 4:00 p.m.) December 6, 2017 Atlanta (8:00 a.m. –2:00 p.m.)

2 On Thursday, due to Monday holiday in United States.


Cleco Corporation Request for Interpretation of CIP-006-6 Requirement R1

Action Reject the Request for Interpretation (RFI) of CIP-006-6 Requirement R1 submitted by Cleco Corporation (Cleco).

Background Pursuant to Section 7.0 of the Standard Processes Manual (SPM), NERC staff recommends that the RFI should be rejected on the grounds that the Reliability Standard language is plain on its face and the RFI is seeking a determination as to whether particular implementation approaches are compliant.

Section 7.0 of the SPM states, in part,

Any entity that is directly and materially affected by the reliability of the North American Bulk Power Systems may request an Interpretation of any Requirement in any continent-wide Reliability Standard that has been adopted by the NERC Board of Trustees.

*** The entity requesting the Interpretation shall submit a Request for Interpretation form to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the Interpretation provided. The NERC Reliability Standards and Legal Staffs shall review the request for interpretation to determine whether it meets the requirements for a valid interpretation. Based on this review, the NERC Standards and Legal Staffs shall make a recommendation to the Standards Committee whether to accept the request for Interpretation and move forward in responding to the Interpretation request.

An Interpretation must only clarify or interpret the Requirements of an approved Reliability Standard, including, if applicable, any attachment referenced in the Requirement being clarified.

Section 7.0 provides a number of examples of the grounds for which the Standards Committee (SC) is authorized to reject a RFI. Among other things, the SC may reject an RFI where (1) it “[r]equests approval of a particular compliance approach”1 or (2) “[w]here the meaning of a Reliability Standard is plain on its face.”2

1See, NERC Rules of Procedure, Appendix 3A: Standards Process Manual, p.31. 2 Id.


The Requirement subject to Cleco’s RFI is CIP-006-6 Requirement R1, Parts 1.2 and 1.3. Requirement R1 provides:

R1. Each Responsible Entity shall implement one or more documented physical security plan(s) that collectively include all of the applicable requirement parts in CIP-006-6 Table R1 – Physical Security Plan.

Part 1.2 of Table R1, which applies to Medium Impact Bulk Electric System (BES) Cyber Systems with External Routable Connectivity and their associated Electronic Access Control or Monitoring Systems (EACMS) and Protected Cyber Assets (PCAs), provides:

Utilize at least one physical access control to allow unescorted physical access into each applicable Physical Security Perimeter to only those individuals who have authorized unescorted physical access.

Part 1.3 of Table R1, which applies to High Impact BES Cyber Systems and their associated EACMS and PCAs, provides:

Where technically feasible, utilize two or more different physical access controls (this does not require two completely independent physical access control systems) to collectively allow unescorted physical access into Physical Security Perimeters to only those individuals who have authorized unescorted physical access.

Also relevant to the RFI is CIP-004-6 Requirement R4, Part 4.1, which requires entities to have a “process to authorize, based on need, as determined by the Responsible Entity,” (1) electronic access; (2) unescorted physical access into a Physical Security Perimeter (PSP); and (3) access to designated storage locations, whether physical or electronic, for BES Cyber System Information. In the Glossary of Terms Used in NERC Reliability Standards, a “Physical Security Perimeter” is defined as “[t]he physical border surrounding locations in which BES Cyber Assets, BES Cyber Systems, or Electronic Access Control or Monitoring Systems reside, and for which access is controlled.” The meaning of these Requirements is clear on its face. Under CIP-004-6 Requirement R4, Part 4.1, Responsible Entities must have a process for authorizing individuals to have unescorted physical access into a PSP based on the need identified by the Responsible Entity, and under CIP-006-6 Requirement R1, Parts 1.2 or 1.3, the Responsible Entity must implement controls to only allow unescorted physical access to the PSP to those individuals authorized under the CIP-004-6 process. As a results-based set of standards, they provide the flexibility for entities to establish PSPs according to their operations (e.g., an entity may choose to establish a PSP around an entire area or separately within a larger area). In addition to the language of the Requirements being plain on their face, the RFI appears to seek confirmation of what constitutes compliance given a certain set of facts. In its RFI, Cleco


provides a hypothetical scenario and requests clarification regarding the application of CIP-006-6, Requirement R1, Parts 1.2 and 1.3 to that scenario. In particular, under a particular set of facts, the instances in which a Responsible Entity must declare and manage separate Physical Security Perimeters (PSPs). An RFI is not the appropriate means for resolving questions regarding compliance of certain implementation approaches. There are other mechanisms more appropriate to pursue endorsement of specific implementation approaches, particularly through the Electric Reliability Organization Enterprise’s compliance guidance process related to implementation guidance.3 For the reasons stated above, NERC staff recommends that the SC reject the RFI. Under Section 7.0, if the SC rejects the RFI, it shall provide a written explanation for rejection to the entity submitting the RFI within 10 business days of the decision to reject. If the SC accepts the RFI request, the NERC standards staff shall (i) form a ballot pool and (ii) assemble an Interpretation drafting team with the relevant expertise to address the interpretation for approval by the SC.

3 http://www.nerc.com/pa/comp/guidance/Pages/default.aspx

Note: an Interpretation cannot be used to change a standard.

Interpretation 2010-xx: Request for an Interpretation of CIP-006-6, Requirement R1, for Cleco

Date submitted: 04/22/2016

Contact information for person requesting the interpretation:

Name: Louis Guidry

Organization: Cleco Corporation

Telephone: 318-484-7495

Email: [email protected]

Identify the standard that needs clarification:

Standard Number (include version number): CIP-006-6

(example: PRC-001-1)

Standard Title: Cyber Security — Physical Security of BES Cyber Systems

Identify specifically what requirement needs clarification:

Requirement Number and Text of Requirement:

Requirement R1, Part 1.2 (applicable to Medium Impact BES Cyber Systems with External Routable Connectivity and their associated EACMS and PCA): Utilize at least one physical access control to allow unescorted physical access into each applicable Physical Security Perimeter to only those individuals who have authorized unescorted physical access.

Requirement R1, Part 1.3 (applicable to High Impact BES Cyber Systems and their associated EACMS and PCA): Where technically feasible, utilize two or more different physical access controls (this does not require two completely independent physical access control systems) to collectively allow unescorted physical access into Physical Security Perimeters to only those individuals who have authorized unescorted physical access.

Clarification needed: Consider a scenario where the Responsible Entity has an access-controlled building, designated as the Control Center, containing staff office space, a control room and a computer room. The Responsible Entity has declared the entire building to be the CIP-006-6 Physical Security Perimeter (PSP) for compliance purposes, and access into the overall building is controlled as prescribed in CIP-006-6, Part 1.2 or 1.3 as applicable. Within the CIP PSP, the Responsible

When completed, email this form to: [email protected]


Request for Interpretation 2

Entity has implemented zoned access controls for entry into the control room and the computer room. The Responsible has defined different access permissions for the control room and the computer room. For example, a subset of authorized personnel are permitted into the office space, but are not authorized badge access into the control room or computer room. Similarly, certain personnel are authorized access into the office space and the control room, but are not authorized badge access into the computer room.

Given the above scenario, must the control room and the computer room be declared and managed as separate PSPs? What about a telecomm closet outside of the control room and computer room, currently secured via either a badge reader or brass key, that contains network equipment subject to the CIP Standards and where access is restricted to the network support staff? Would the telecomm closet need to be a separate PSP? What about the room, also secured by a badge reader or brass key and restricted to facilities support personnel, containing the Uninterruptible Power Supply system for the control room and computer room? The UPS is not connected to the Electronic Security Perimeter network and there are no Cyber Assets in the UPS room. Would the UPS room need to be a separate PSP? And finally, what if the Control Center manager has an office inside the control room? The manager’s office has a SCADA workstation that is inside the Electronic Security Perimeter and is subject to the CIP Standards. The manager locks his office door at night when he is not present. Does the manager’s office have to be treated as a separate PSP?

Identify the material impact associated with this interpretation:

Identify the material impact to your organization or others caused by the lack of clarity or an incorrect interpretation of this standard.

The CIP Standards require that the Responsible Entity restrict unescorted access into the Physical Security Perimeter to only authorized personnel and that authorization for such access be based upon need as determined by the Responsible Entity. Because authorization based upon need is prescribed by a different Standard and Requirement, it is not clear whether CIP-004-6, Requirement R4, Part 4.1 prescribes the need for separate Physical Security Perimeters where access permissions differ, or only that access is appropriately controlled into a defined PSP. The Responsible Entity has determined that all personnel with authorized unescorted access into the Control Center Building have need for that access. The Responsible Entity has chosen to further restrict access within the PSP as a good security practice.

The Responsible Entity is at risk of a violation if its Regional Entity believes one or more access controlled spaces within the Control Center building, with different access permissions, must be separate Physical Security Perimeters. Cleco understands that no consensus has been reached between the Regional Entities much less between the Regional Entities and their Responsible Entities regarding this issue. Regional consistency and audit certainty is required one way or the other.

Version History Version Date Owner Change Tracking

1 April 22, 2011

Request for Interpretation 3

1 May 27, 2014 Standards Information Staff Updated template and email address for submittal.


Request for Interpretation of BAL-001-2 Submitted by Orlando Utilities Commission

Action Reject the Request for Interpretation (RFI) of BAL-001-2 submitted by Orlando Utilities Commission (OUC).

Background Pursuant to Section 7.0 of the Standard Processes Manual, NERC staff recommends that the RFI should be rejected on the grounds that the question has already been addressed in the record and the meaning of the Reliability Standard is plain on its face.

Section 7.0 of the Standard Processes Manual states, in part,

Any entity that is directly and materially affected by the reliability of the North American Bulk Power Systems may request an Interpretation of any Requirement in any continent-wide Reliability Standard that has been adopted by the NERC Board of Trustees.

*** The entity requesting the Interpretation shall submit a Request for Interpretation form to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the Interpretation provided. The NERC Reliability Standards and Legal Staffs shall review the request for interpretation to determine whether it meets the requirements for a valid interpretation. Based on this review, the NERC Standards and Legal Staffs shall make a recommendation to the Standards Committee whether to accept the request for Interpretation and move forward in responding to the Interpretation request.

An Interpretation must only clarify or interpret the Requirements of an approved Reliability Standard, including, if applicable, any attachment referenced in the Requirement being clarified.

Section 7.0 provides a number of examples of the grounds for which the Standards Committee is authorized to reject an RFI. One basis for rejecting an RFI is, “[w]here a question has already been addressed in the record.” Another basis for rejecting an RFI is, “[w]here the meaning of a Reliability Standard is plain on its face.”

The RFI submitted by OUC requests clarification of BAL-001-2, Requirement R2, and whether actual frequency (FA) in the BAAL equation could be measured as clock-minute average.

The Reliability Standard and record of Project 2010-14.1 Balancing Authority Reliability-based Controls – Reserves - BAL-001 are already clear that FA should be measured by clock-minute


average frequency in Hz; therefore, an interpretation is not necessary. The NERC staff standards developer and leadership of the Project 2010-14.1 standard drafting team have also reviewed the RFI and agree that the Reliability Standard supports use of clock-minute average frequency in Hz. Specifically, Attachment 2 of the Reliability Standard, in defining FA, describes the average actual frequency in terms of one-minute intervals. It also specifies that requiring “at least 50% of the actual frequency sample data during that one-minute interval is valid.” Attachment 2 does not explicitly state the phrase “clock-minute average,” but it is clear that the equation within Attachment 2 for calculating BAAL that identifies FA as “the measured frequency in Hz” supports using the measured clock-minute average frequency in Hz. Under Section 7.0, if the SC rejects the RFI, the committee shall provide a written explanation for rejection to the entity submitting the RFI within 10 business days of the decision to reject. If the SC accepts the RFI request, the NERC standards staff shall (i) form a ballot pool and (ii) assemble an Interpretation drafting team with the relevant expertise to address the interpretation for approval by the SC.

Note: an Interpretation cannot be used to change a standard.

Interpretation 2010-xx: Request for an Interpretation of [Insert Standard Number], Requirement Rx, for [Insert Name of Company]

Date submitted: 3/30/2016

Contact information for person requesting the interpretation:

Name: Richard Kinas

Organization: Orlando Utilities Commission

Telephone: 407-434-4261

Email: [email protected]

Identify the standard that needs clarification:

Standard Number (include version number): BAL-001-2

(example: PRC-001-1)

Standard Title: Real Power Balancing Control Performance

Identify specifically what requirement needs clarification:

Requirement Number and Text of Requirement: R2 “Each Balancing Authority shall operate such that its clock-minute average of Reporting ACE does not exceed its clock-minute Balancing Authority ACE Limit (BAAL) for more than 30 consecutive clock-minutes, calculated in accordance with Attachment 2…”

Clarification needed: Within Attachment 2 the equation for calculating BAAL identifies FA as “is the measured frequency in Hz.” However based on the additional information provided “To ensure that the average actual frequency calculated for any one-minute interval is representative of that time interval…” it appears that what the drafting team’s intent was that FA, in the equation, is actually “average of measured (actual) frequency during the same clock-minute used to average Reporting ACE”. As currently written the language in Attachment 2 contradicts itself and creates regulatory uncertainty when attempting to comply with Requirement 2. Clarification is needed to correctly identify the intent of the value of FA and to clearly demonstrate how the term FA is calculated. Without this clarification, the applicable Balancing Authority will be uncertain as to how to calculate BAAL since “clock-minute BAAL” contradicts BAAL (according to the equation) being comprised of actual frequency, which changes during the minute. An Interpretation should be developed to eliminate this contradiction prior to the 7/1/2016 effective date of BAL-001-2.

Identify the material impact associated with this interpretation:

When completed, email this form to: [email protected]



Interpretation Request: BAL-001-2 2

Identify the material impact to your organization or others caused by the lack of clarity or an incorrect interpretation of this standard.

Incorrect implementation of the calculation will result in a compliance violation which can have significant financial considerations. Additionally an incorrect implementation could have a negative effect on reliability, with system operators taking action based on incorrect calculations.

Version History Version Date Owner Change Tracking

1 April 22, 2011

1 May 27, 2014 Standards Information Staff Updated template and email address for submittal.


Standards Committee Process Subcommittee - Revisions to NERC Standard Processes Manual (SPM)

Section 6: Processes for Conducting Field Tests

Action Endorse the Standards Committee Process Subcommittee’s (SCPS) proposed revisions to Section 6 Process for Conducting Field Tests of the Standard Processes Manual (SPM).

Background The NERC technical committees have identified a need to develop revisions to the Standards Committee (SC) Charter Section 101 and Section 6 of the SPM to provide NERC’s technical committees with additional technical oversight of field tests associated with a Standards Authorization Request (SAR) and standards projects.

The SCPS has collaboratively worked with NERC staff (Standards, Compliance, and Legal) and with the leadership of the Operating Committee (OC), Planning Committee (PC), Critical Infrastructure Protection Committee (CIPC), and the SC, developed revisions to Section 6 of the SPM, which address the coordination and oversight involvements of the NERC technical committees.

NERC staff (Standards, Compliance and Legal) and the leadership of the NERC Standing Committees (OC, PC, CIPC, and SC) have endorsed the proposed revisions to Section 6 of the SPM.

The SCPS is presenting the results of this portion (Section 6) of the overall Revisions to NERC Standard Processes Manual (SPM) project for endorsement which will allow the SCPS to develop the necessary revisions to Section 10 of the SC Charter for SC consideration.

The SCPS will seek SC authorization to post for industry consideration in accordance with the SPM when the revisions to Section 7 (Interpretation Process) and Section 11 (Process for Approving Supporting Documents) are completed.

1 Revisions to Section 10 of the Standards Committee (SC) Charter will be fully developed and presented to the SC following SC endorsement of the proposed revisions to Section 6 of the SPM.

Standard Processes Manual

VERSION TBD

Effective: TBD


Introduction

Standard Processes Manual VERSION 3.0: Effective: 2

Table of Contents Section 1.0: Introduction ................................................................................................................ 3

Section 2.0: Elements of a Reliability Standard ............................................................................ 6

Section 3.0: Reliability Standards Program Organization ........................................................... 10

Section 4.0: Process for Developing, Modifying, Withdrawing or Retiring a Reliability Standard....................................................................................................................................................... 14

Section 5.0: Process for Developing a Defined Term.................................................................. 26

Section 6.0: Process for Conducting Field Tests ......................................................................... 28

Section 7.0: Process for Developing an Interpretation ................................................................ 31

Section 8.0: Process for Appealing an Action or Inaction ........................................................... 35

Section 9.0: Process for Developing a Variance .......................................................................... 37

Section 10.0: Processes for Developing a Reliability Standard Related to a Confidential Issue 39

Section 11.0: Process for Approving Supporting Documents ..................................................... 46

Section 12.0: Process for Correcting Errata ................................................................................. 47

Section 13.0: Process for Conducting Periodic Reviews of Reliability Standards ...................... 48

Section 14.0: Public Access to Reliability Standards Information .............................................. 49

Section 15.0: Process for Updating Standard Processes .............................................................. 50

Section 16.0: Waiver .................................................................................................................... 51

Introduction


Section 1.0: Introduction

1.1: Authority This manual is published by the authority of the NERC Board of Trustees. The Board of Trustees, as necessary to maintain NERC’s certification as the Electric Reliability Organization (“ERO”), may file the manual with Applicable Governmental Authorities for approval as an ERO document. When approved, the manual is appended to and provides implementation detail in support of the ERO Rules of Procedure Section 300 — Reliability Standards Development. Capitalized terms not otherwise defined herein, shall have the meaning set forth in the Definitions Used in the Rules of Procedure, Appendix 2 to the Rules of Procedure. 1.2: Scope The policies and procedures in this manual shall govern the activities of the North American Electric Reliability Corporation (“NERC”) related to the development, approval, revision, reaffirmation, and withdrawal of Reliability Standards, Interpretations, Violation Risk Factors (“VRFs”), Violation Severity Levels (“VSLs”), definitions, Variances, and reference documents developed to support standards for the Reliable Operation and planning of the North American Bulk Power Systems. This manual also addresses the role of the Standards Committee, drafting team and ballot body in the development and approval of Compliance Elements in conjunction with standard development. 1.3: Background NERC is a nonprofit corporation formed for the purpose of becoming the North American ERO. NERC works with all stakeholder segments of the electric industry, including electricity users, to develop Reliability Standards for the reliability planning and Reliable Operation of the North American Bulk Power Systems. In the United States, the Energy Policy Act of 2005 added Section 215 to the Federal Power Act for the purpose of establishing a framework to make Reliability Standards mandatory for all Bulk Power System owners, operators, and users. Similar authorities are provided by Applicable Governmental Authorities in Canada. NERC was certified as the ERO effective July 2006. North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g and compliance, 117 FERC ¶ 61,126 (2006), order on compliance, 118 FERC ¶ 61,030 (2007). 1.4: Essential Attributes of NERC’s Reliability Standards Processes NERC’s Reliability Standards development processes provide reasonable notice and opportunity for public comment, due process, openness, and balance of interests in developing a proposed Reliability Standard consistent with the attributes necessary for American National Standards Institute (“ANSI”) accreditation. The same attributes, as well as transparency, consensus-building, and timeliness, are also required under the ERO Rules of Procedure Section 304.

• Open Participation Participation in NERC’s Reliability Standards development balloting and approval processes shall be open to all entities materially affected by NERC’s Reliability Standards. There shall be no financial barriers to participation in NERC’s Reliability Standards balloting and approval processes. Membership in the Registered Ballot Body shall not be conditional upon membership in any organization, nor unreasonably restricted on the basis of technical qualifications or other such requirements.

Introduction


• Balance NERC’s Reliability Standards development processes shall not be dominated by any two interest categories, individuals, or organizations and no single interest category, individual, or organization is able to defeat a matter.

NERC shall use a voting formula that allocates each industry Segment an equal weight in determining the final outcome of any Reliability Standard action. The Reliability Standards development processes shall have a balance of interests. Participants from diverse interest categories shall be encouraged to join the Registered Ballot Body and participate in the balloting process, with a goal of achieving balance between the interest categories. The Registered Ballot Body serves as the consensus body voting to approve each new or proposed Reliability Standard, definition, Variance, and Interpretation.

• Coordination and harmonization with other American National Standards activities

NERC is committed to resolving any potential conflicts between its Reliability Standards development efforts and existing American National Standards and candidate American National Standards.

• Notification of standards development

NERC shall publicly distribute a notice to each member of the Registered Ballot Body, and to each stakeholder who indicates a desire to receive such notices, for each action to create, revise, reaffirm, or withdraw a Reliability Standard, definition, or Variance; and for each proposed Interpretation. Notices shall be distributed electronically, with links to the relevant information, and notices shall be posted on NERC’s Reliability Standards web page. All notices shall identify a readily available source for further information.

• Transparency

The process shall be transparent to the public.

• Consideration of views and objections Drafting teams shall give prompt consideration to the written views and objections of all participants as set forth herein. Drafting teams shall make an effort to resolve each objection that is related to the topic under review.

• Consensus Building

The process shall build and document consensus for each Reliability Standard, both with regard to the need and justification for the Reliability Standard and the content of the Reliability Standard.

• Consensus vote

NERC shall use its voting process to determine if there is sufficient consensus to approve a proposed Reliability Standard, definition, Variance, or Interpretation. NERC shall form a ballot pool for each Reliability Standard action from interested members of its Registered Ballot Body. Approval of any Reliability Standard action requires:

• A quorum, which is established by at least 75% of the members of the ballot pool submitting a response excluding unreturned ballots; and

• A two-thirds majority of the weighted Segment votes cast shall be affirmative. The number of votes cast during all stages of balloting except the final ballot is the sum of affirmative and negative votes with comments, excluding abstentions, non-responses, and negative votes without comments. During the final ballot, the number of votes cast is the sum of affirmative and negative votes, excluding abstentions and non-responses.

Introduction


• Timeliness

Development of Reliability Standards shall be timely and responsive to new and changing priorities for reliability of the Bulk Power System.

• Metric Policy

The International System of units is the preferred units of measurement in NERC Reliability Standard. However, because NERC’s Reliability Standards apply in Canada, the United States and portions of Mexico, where applicable, measures are provided in both the metric and English units.

1.5: Ethical Participation All participants in the NERC Standard development process, including drafting teams, quality reviewers, Standards Committee members and members of the Registered Ballot Body, are obligated to act in an ethical manner in the exercise of all activities conducted pursuant to the terms and conditions of the Standard Processes Manual and the standard development process.

Elements of a Reliability Standard


Section 2.0: Elements of a Reliability Standard 2.1: Definition of a Reliability Standard A Reliability Standard includes a set of Requirements that define specific obligations of owners, operators, and users of the North American Bulk Power Systems. The Requirements shall be material to reliability and measurable. A Reliability Standard is defined as follows:

“Reliability Standard” means a requirement, approved by the United States Federal Energy Regulatory Commission under Section 215 of the Federal Power Act, or approved or recognized by an applicable governmental authority in other jurisdictions, to provide for Reliable Operation of the Bulk Power System. The term includes requirements for the operation of existing Bulk Power System facilities, including cybersecurity protection, and the design of planned additions or modifications to such facilities to the extent necessary to provide for Reliable Operation of the Bulk Power System, but the term does not include any requirement to enlarge such facilities or to construct new transmission capacity or generation capacity. (In certain contexts, this term may also refer to a “Reliability Standard” that is in the process of being developed, or not yet approved or recognized by FERC or an applicable governmental authority in other jurisdictions). See Appendix 2 to the NERC Rules of Procedure, Definitions Used in the Rules of Procedure.

2.2: Reliability Principles NERC Reliability Standards are based on certain reliability principles that define the foundation of reliability for North American Bulk Power Systems.1 Each Reliability Standard shall enable or support one or more of the reliability principles, thereby ensuring that each Reliability Standard serves a purpose in support of reliability of the North American Bulk Power Systems. Each Reliability Standard shall also be consistent with all of the reliability principles, thereby ensuring that no Reliability Standard undermines reliability through an unintended consequence. 2.3: Market Principles Recognizing that Bulk Power System reliability and electricity markets are inseparable and mutually interdependent, all Reliability Standards shall be consistent with the market interface principles.2 Consideration of the market interface principles is intended to ensure that Reliability Standards are written such that they achieve their reliability objective without causing undue restrictions or adverse impacts on competitive electricity markets. 2.4: Types of Reliability Requirements Generally, each Requirement of a Reliability Standard shall identify what Functional Entities shall do, and under what conditions, to achieve a specific reliability objective. Although Reliability Standards all follow this format, several types of Requirements may exist, each with a different approach to measurement.

• Performance-based Requirements define a specific reliability objective or outcome achieved by one or more entities that has a direct, observable effect on the reliability of the Bulk Power System, i.e. an effect that can be measured using power system data or

1 The intent of the set of NERC Reliability Standards is to deliver an adequate level of reliability. The latest set of reliability principles and the latest set of characteristics associated with an adequate level of reliability are posted on the Reliability Standards Resources web page.

2 The latest set of market interface principles is posted on the Reliability Standards Resources web page.



trends. In its simplest form, a performance-based requirement has four components: who, under what conditions (if any), shall perform what action, to achieve what particular result or outcome.

• Risk-based Requirements define actions by one or more entities that reduce a stated risk to the reliability of the Bulk Power System and can be measured by evaluating a particular product or outcome resulting from the required actions. A risk-based reliability requirement should be framed as: who, under what conditions (if any), shall perform what action, to achieve what particular result or outcome that reduces a stated risk to the reliability of the Bulk Power System.

• Capability-based Requirements define capabilities needed by one or more entities to perform reliability functions and can be measured by demonstrating that the capability exists as required. A capability-based reliability requirement should be framed as: who, under what conditions (if any), shall have what capability, to achieve what particular result or outcome to perform an action to achieve a result or outcome or to reduce a risk to the reliability of the Bulk Power System.

The body of reliability Requirements collectively provides a defense-in-depth strategy supporting reliability of the Bulk Power System. 2.5: Elements of a Reliability Standard A Reliability Standard includes several components designed to work collectively to identify what entities must do to meet their reliability-related obligations as an owner, operator or user of the Bulk Power System. The components of a Reliability Standard may include the following:

Title: A brief, descriptive phrase identifying the topic of the Reliability Standard.

Number: A unique identification number assigned in accordance with a published classification system to facilitate tracking and reference to the Reliability Standards.3

Purpose: The reliability outcome achieved through compliance with the Requirements of the Reliability Standard.

Applicability: Identifies which entities are assigned reliability requirements. The specific Functional Entities and Facilities to which the Reliability Standard applies.

Effective Dates: Identification of the date or pre-conditions determining when each Requirement becomes effective in each jurisdiction.

Requirement: An explicit statement that identifies the Functional Entity responsible, the action or outcome that must be achieved, any conditions achieving the action or outcome, and the reliability-related benefit of the action or outcome. Each Requirement shall be a statement for which compliance is mandatory.

3 Reliability Standards shall be numbered in accordance with the NERC Standards Numbering Convention as provide on the Reliability Standards Resources web page.



Compliance Elements: Elements to aid in the administration of ERO compliance monitoring and enforcement responsibilities.4

• Measure: Provides identification of the evidence or types of evidence that may demonstrate

compliance with the associated requirement.

• Violation Risk Factors and Violation Severity Levels: Violation risk factors (VRFs) and violation severity levels (VSLs) are used as factors when determining the size of a penalty or sanction associated with the violation of a requirement in an approved reliability standard.5 Each requirement in each reliability standard has an associated VRF and a set of VSLs. VRFs and VSLs are developed by the drafting team, working with NERC Staff, at the same time as the associated reliability standard, but are not part of the reliability standard. The Board of Trustees is responsible for approving VRFs and VSLs. • Violation Risk Factors

VRFs identify the potential reliability significance of noncompliance with each requirement. Each requirement is assigned a VRF in accordance with the latest approved set of VRF criteria.6

• Violation Severity Levels

VSLs define the degree to which compliance with a requirement was not achieved. Each requirement shall have at least one VSL. While it is preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and may have only one, two, or three VSLs. Each requirement is assigned one or more VSLs in accordance with the latest approved set of VSL criteria.7

Version History: The version history is provided for informational purposes and lists information regarding prior versions of Reliability Standards.

Variance: A Requirement (to be applied in the place of the continent-wide Requirement) that is applicable to a specific geographic area or to a specific set of Registered Entities.

Compliance Enforcement Authority: The entity that is responsible for assessing performance or outcomes to determine if an entity is compliant with the associated Reliability Standard. The Compliance Enforcement Authority will be NERC or the Regional Entity in their respective roles of monitoring and enforcing compliance with the NERC Reliability Standards.

Application guidelines: Guidelines to support the implementation of the associated Reliability Standard. Procedures: Procedures to support implementation of the associated Reliability Standard.

4 It is the responsibility of the ERO staff to develop compliance tools for each standard; these tools are not part of the standard but are referenced in this manual because the preferred approach to developing these tools is to use a transparent process that leverages the technical and practical expertise of the drafting team and ballot pool.. 5 The Sanction Guidelines of the North American Electric Reliability Corporation identifies the factors used to determine a penalty or sanction for violation of reliability standard and is posted on the NERC Web Site. 6 The latest set of approved VRF Criteria is posted on the Reliability Standards Resources Web Page. 7 The latest set of approved VSL Criteria is posted on the Reliability Standards Resources Web Page.



The only mandatory and enforceable components of a Reliability Standard are the: (1) applicability, (2) Requirements, and the (3) effective dates. The additional components are included in the Reliability Standard for informational purposes, to establish the relevant scope and technical paradigm, and to provide guidance to Functional Entities concerning how compliance will be assessed by the Compliance Enforcement Authority.

Reliability Standards Program Organization


Section 3.0: Reliability Standards Program Organization 3.1: Board of Trustees The NERC Board of Trustees shall consider for adoption Reliability Standards, definitions, Variances and Interpretations and associated implementation plans that have been processed according to the processes identified in this manual. Once the Board adopts a Reliability Standard, definition, Variance or Interpretation, the Board shall direct NERC Staff to file the document(s) for approval with Applicable Governmental Authorities. 3.2: Registered Ballot Body The Registered Ballot Body comprises all entities or individuals that qualify for one of the Segments approved by the Board of Trustees8, and are registered with NERC as potential ballot participants in the voting on Reliability Standards. Each member of the Registered Ballot Body is eligible to join the ballot pool for each Reliability Standard action. 3.3: Ballot Pool Each Reliability Standard action has its own ballot pool formed of interested members of the Registered Ballot Body. The ballot pool comprises those members of the Registered Ballot Body that respond to a pre-ballot request to participate in that particular Reliability Standard action. The ballot pool votes on each Reliability Standards action. The ballot pool remains in place until all balloting related to that Reliability Standard action has been completed. 3.4: Standards Committee The Standards Committee serves at the pleasure and direction of the NERC Board of Trustees, and the Board approves the Standards Committee’s Charter.9 Standards Committee members are elected by their respective Segment’s stakeholders. The Standards Committee consists of two members of each of the Segments in the Registered Ballot Body.10 A member of the NERC Reliability Standards Staff shall serve as the non-voting secretary to the Standards Committee. The Standards Committee is responsible for managing the Reliability Standards processes for development of Reliability Standards, definitions, Variances and Interpretations in accordance with this manual. The responsibilities of the Standards Committee are defined in detail in the Standards Committee’s Charter. The Standards Committee is responsible for ensuring that the Reliability Standards, definitions, Variances and Interpretations developed by drafting teams are developed in accordance with the processes in this manual and meet NERC’s benchmarks for Reliability Standards as well as criteria for governmental approval.11 The Standards Committee has the right to remand work to a drafting team, to reject the work of a drafting team, or to accept the work of a drafting team. The Standards Committee may disband a drafting team if it determines (a) that the drafting team is not producing a standard in a timely manner; (b) the drafting team 8 The industry Segment qualifications are described in the Development of the Registered Ballot Body and Segment Qualification Guidelines document posted on the Reliability Standards Resources web page and are included in Appendix 3D of the NERC Rules of Procedure. 9 The Standards Committee Charter is posted on the Reliability Standards Resources web page. 10 In addition to balanced Segment representation, the Standards Committee shall also have representation that is balanced among countries based on Net Energy for Load (“NEL”). As needed, the Board of Trustees may approve special procedures for the balancing of representation among countries represented within NERC. 11 The Ten Benchmarks of an Excellent Reliability Standard and FERC’s Criteria for Approving Reliability Standards are posted on the Reliability Standards Resources web page.



is not able to produce a standard that will achieve industry consensus; (c) the drafting team has not addressed the scope of the SAR; or (d) the drafting team has failed to fully address a regulatory directive or otherwise provided a responsive or equally efficient and effective alternative. The Standards Committee may direct a drafting team to revise its work to follow the processes in this manual or to meet the criteria for NERC’s benchmarks for Reliability Standards, or to meet the criteria for governmental approval; however, the Standards Committee shall not direct a drafting team to change the technical content of a draft Reliability Standard. The Standards Committee shall meet at regularly scheduled intervals (either in person, or by other means). All Standards Committee meetings are open to all interested parties. 3.5: NERC Reliability Standards Staff The NERC Reliability Standards Staff, led by the Director of Standards, is responsible for administering NERC’s Reliability Standards processes in accordance with this manual. The NERC Reliability Standards Staff provides support to the Standards Committee in managing the Reliability Standards processes and in supporting the work of all drafting teams. The NERC Reliability Standards Staff works to ensure the integrity of the Reliability Standards processes and consistency of quality and completeness of the Reliability Standards. The NERC Reliability Standards Staff facilitates all steps in the development of Reliability Standards, definitions, Variances, Interpretations and associated implementation plans. The NERC Reliability Standards Staff is responsible for presenting Reliability Standards, definitions, Variances, and Interpretations to the NERC Board of Trustees for adoption. When presenting Reliability Standards-related documents to the NERC Board of Trustees for adoption or approval, the NERC Reliability Standards Staff shall report the results of the associated stakeholder ballot, including identification of unresolved stakeholder objections and an assessment of the document’s practicality and enforceability. 3.6: Drafting Teams The Standards Committee shall appoint industry experts to drafting teams to work with stakeholders in developing and refining Standard Authorization Requests (“SARs”), Reliability Standards, definitions, and Variances. The NERC Reliability Standards Staff shall appoint drafting teams that develop Interpretations. The NERC Reliability Standards Staff shall provide, or solicit from the industry, essential support for each of the drafting teams in the form of technical writers, legal, compliance, and rigorous and highly trained project management and facilitation support personnel. Each drafting team may consist of a group of technical, legal, and compliance experts that work cooperatively with the support of the NERC Reliability Standards Staff.12 The technical experts provide the subject matter expertise and guide the development of the technical aspects of the Reliability Standard, assisted by technical writers, legal and compliance experts. The technical experts maintain authority over the technical details of the Reliability Standard. Each drafting team appointed to develop a Reliability Standard is responsible for following the processes identified in this manual as well as procedures developed by the Standards Committee from the inception of the assigned project through the final acceptance of that project by Applicable Governmental Authorities. Collectively, each drafting team:

• Drafts proposed language for the Reliability Standards, definitions, Variances, and/or Interpretations and associated implementation plans.

12 The detailed responsibilities of drafting teams are outlined in the Drafting Team Guidelines, which is posted on the Reliability Standards Resources web page.



• Develops and refines technical documents that aid in the understanding of Reliability Standards.

• Works collaboratively with NERC Compliance Monitoring and Enforcement Staff to develop Reliability Standard Audit Worksheets (“RSAWs”) at the same time Reliability Standards are developed.

• Provides assistance to NERC Staff in the development of Compliance Elements of proposed Reliability Standards.

• Solicits, considers, and responds to comments related to the specific Reliability Standards development project.

• Participates in industry forums to help build consensus on the draft Reliability Standards, definitions, Variances, and/or Interpretations and associated implementation plans.

• Assists in developing the documentation used to obtain governmental approval of the Reliability Standards, definitions, Variances, and/or Interpretations and associated implementation plans.

All drafting teams report to the Standards Committee. 3.7: Governmental Authorities The Federal Energy Regulatory Commission (“FERC”) in the United States of America, and where permissible by statute or regulation, the provincial government of each of the eight Canadian Provinces (Manitoba, Nova Scotia, Saskatchewan, Alberta, Ontario, British Columbia, New Brunswick and Quebec) and the National Energy Board of Canada have the authority to approve each new, revised or withdrawn Reliability Standard, definition, Variance, VRF, VSL and Interpretation following adoption or approval by the NERC Board of Trustees. 3.8: Committees, Subcommittees, Working Groups, and Task Forces NERC’s technical committees, subcommittees, working groups, and task forces provide technical research and analysis used to justify the development of new Reliability Standards and provide guidance, when requested by the Standards Committee, in overseeing field tests or collection and analysis of data. The technical committees, subcommittees, working groups, and task forces provide feedback to drafting teams during both informal and formal comment periods. The Standards Committee may request that a NERC technical committee or other group prepare a Technical document to support development of a proposed Reliability Standard. The technical committees, subcommittees, working groups, and task forces share their observations regarding the need for new or modified Reliability Standards or Requirements with the NERC Reliability Standards Staff for use in identifying the need for new Reliability Standards projects for the three-year Reliability Standards Development Plan. 3.9: Compliance and Certification Committee The Compliance and Certification Committee is responsible for monitoring NERC’s compliance with its Reliability Standards processes and procedures and for monitoring NERC’s compliance with the Rules of Procedure regarding the development of new or revised Reliability Standards, definitions, Variances, and Interpretations. The Compliance and Certification Committee may assist in verifying that each proposed Reliability Standard is enforceable as written before the Reliability Standard is posted for formal stakeholder comment and balloting.



3.10: Compliance Monitoring and Enforcement Program As applicable, the NERC Compliance Monitoring and Enforcement Program Staff manages and enforces compliance with approved Reliability Standards. Compliance Monitoring and Enforcement Staff are responsible for the development of select compliance tools. The drafting team and the Compliance Monitoring and Enforcement Program Staff shall work together during the Reliability Standard development process to ensure an accurate and consistent understanding of the Requirements and their intent, and to ensure that applicable compliance tools accurately reflect that intent. The goal of this collaboration is to ensure that application of the Reliability Standards in the Compliance Monitoring and Enforcement Program by NERC and the Regional Entities is consistent. The Compliance Monitoring and Enforcement Program is encouraged to share its observations regarding the need for new or modified Requirements with the NERC Reliability Standards Staff for use in identifying the need for new Reliability Standards projects. 3.11: North American Energy Standards Board (“NAESB”) While NERC has responsibility for developing Reliability Standards to support reliability, NAESB has responsibility for developing business practices and coordination between reliability and business practices as needed. NERC and NAESB developed and approved a procedure13 to guide the development of Reliability Standards and business practices where the reliability and business practice components are intricately entwined within a proposed Reliability Standard.

13 The NERC NAESB Template Procedure for Joint Standards Development and Coordination is posted on the Reliability Standards Resources web page.

Process for Developing, Modifying, Withdrawing or Retiring a Reliability Standard


Section 4.0: Process for Developing, Modifying, Withdrawing or Retiring a Reliability Standard There are several steps to the development, modification, withdrawal or retirement of a Reliability Standard.14

The development of the Reliability Standards Development Plan is the appropriate forum for reaching agreement on whether there is a need for a Reliability Standard and the scope of a proposed Reliability Standard. A typical process for a project identified in the Reliability Standards Development Plan that involves a revision to an existing Reliability Standard is shown below. Note that most projects do not include a field test.

14 The process described is also applicable to projects used to propose a new or modified definition or Variance or to propose retirement of a definition or Variance.



FIGURE 1: Process for Developing or Modifying a Reliability Standard

STEP 9: Submit all BOT-approved documents to Applicable Governmental Authorities for approval

STEP 8: Submit Reliability Standard and Implementation Plan to BOT for Adoption and Approval

STEP 7: Conduct Final Ballot

10 day Period

STEP 6: Post Response to Comments

If significant changes are needed to the Draft Reliability Standard then conduct Additional Ballot (Repeat Step 5)

STEP 5: Comment Period and Ballot

Form Ballot Pool During First 30 calendar days of 45-day Comment Period

Conduct Ballot During Last 10 Days of Comment Period Conduct Non-Binding Poll of VRFs and VSLs

STEP 4: Obtain Standards Committee Approval to Post for Comment and Ballot

STEP 3: Develop Draft of Standard, Implementation Plan and VRFs and VSLs

Form Drafting Team If needed, conduct Field Test of Requirements Conduct Quality Review Collect Informal Feedback

STEP 2: Post SAR for 30-day Informal Comment Period

STEP 1: Project Identified in Reliability Standards Development Plan or initiated by the Standards Committee

Draft SAR



4.1: Posting and Collecting Information on SARs

Standard Authorization Request A Standard Authorization Request (“SAR”) is the form used to document the scope and reliability benefit of a proposed project for one or more new or modified Reliability Standards or definitions or the benefit of retiring one or more approved Reliability Standards. Any entity or individual, including NERC committees or subgroups and NERC Staff, may propose the development of a new or modified Reliability Standard, or may propose the retirement of a Reliability Standard (in whole or in part), by submitting a completed SAR15 to the NERC Reliability Standards Staff. The Standards Committee has the authority to approve the posting of all SARs for projects that propose (i) developing a new or modified Reliability Standard or definition or (ii) propose retirement of an existing Reliability Standard (or elements thereof). The NERC Reliability Standards Staff sponsors an open solicitation period each year seeking ideas for new Reliability Standards projects (using Reliability Standards Suggestions and Comments forms). The open solicitation period is held in conjunction with the annual revision to the Reliability Standards Development Plan. While the Standards Committee prefers that ideas for new projects be submitted during this annual solicitation period through submittal of a Reliability Standards Suggestions and Comments Form,16 a SAR proposing a specific project may be submitted to the NERC Reliability Standards Staff at any time. Each SAR that proposes a “new” or substantially revised Reliability Standard or definition should be accompanied by a technical justification that includes, as a minimum, a discussion of the reliability-related benefits and costs of developing the new Reliability Standard or definition, and a technical foundation document (e.g., research paper) to guide the development of the Reliability Standard or definition. The technical document should address the engineering, planning and operational basis for the proposed Reliability Standard or definition, as well as any alternative approaches considered during SAR development. The NERC Reliability Standards Staff shall review each SAR and work with the submitter to verify that all required information has been provided. All properly completed SARs shall be submitted to the Standards Committee for action at the next regularly scheduled Standards Committee meeting. When presented with a SAR, the Standards Committee shall determine if the SAR is sufficiently complete to guide Reliability Standard development and whether the SAR is consistent with this manual. The Standards Committee shall take one of the following actions:

• Accept the SAR. • Remand the SAR back to the requestor or to NERC Reliability Standards Staff for

additional work. • Reject the SAR. The Standards Committee may reject a SAR for good cause. If the

Standards Committee rejects a SAR, it shall provide a written explanation for rejection to the sponsor within ten days of the rejection decision.

• Delay action on the SAR pending one of the following: (i) development of a technical justification for the proposed project; or (ii) consultation with another NERC Committee to determine if there is another approach to addressing the issue raised in the SAR.

If the Standards Committee is presented with a SAR that proposes developing a new Reliability Standard or definition but does not have a technical justification upon which the Reliability Standard or definition can be developed, the Standards Committee shall direct the NERC Reliability Standards Staff to post the

15 The SAR form can be downloaded from the Reliability Standards Resources web page. 16 The Reliability Standards Suggestions and Comments Form can be downloaded from the Reliability Standards Resources web page.



SAR for a 30-day comment period solely to collect stakeholder feedback on the scope of technical foundation, if any, needed to support the proposed project. If a technical foundation is determined to be necessary, the Standards Committee shall solicit assistance from NERC’s technical committees or other industry experts to provide that foundation before authorizing development of the associated Reliability Standard or definition. During the SAR comment process, the drafting team may become aware of potential regional Variances related to the proposed Reliability Standard. To the extent possible, any regional Variances or exceptions should be made a part of the SAR so that if the SAR is authorized, such variations shall be made a part of the draft new or revised Reliability Standard. If the Standards Committee accepts a SAR, the project shall be added to the list of approved projects. The Standards Committee shall assign a priority to the project, relative to all other projects under development, and those projects already identified in the Reliability Standards Development Plan that are already approved for development. The Standards Committee shall work with the NERC Reliability Standards Staff to coordinate the posting of SARs for new projects, giving consideration to each project’s priority. 4.2: SAR Posting When the Standards Committee determines it is ready to initiate a new project, the Standards Committee shall direct NERC Staff to post the project’s SAR in accordance with the following:

• For SARs that are limited to addressing regulatory directives, or revisions to Reliability Standards that have had some vetting in the industry, authorize posting the SAR for a 30-day informal comment period with no requirement to provide a formal response to the comments received.

• For SARs that address the development of new projects or Reliability Standards, authorize posting the SAR for a 30-day formal comment period.

If a SAR for a new Reliability Standard is posted for a formal comment period, the Standards Committee shall appoint a drafting team to work with the NERC Staff coordinator to give prompt consideration of the written views and objections of all participants. The Standards Committee may use a public nomination process to populate the Reliability Standard drafting team, or may use another method that results in a team that collectively has the necessary technical expertise and work process skills to meet the objectives of the project. In some situations, an ad hoc team may already be in place with the requisite expertise, competencies, and diversity of views that are necessary to refine the SAR and develop the Reliability Standard, and additional members may not be needed. The drafting team shall address all comments submitted, which may be in the form of a summary response addressing each of the issues raised in comments received, during the public posting period. An effort to resolve all expressed objections shall be made, and each objector shall be advised of the disposition of the objection and the reasons therefore. If the drafting team concludes that there is not sufficient stakeholder support to continue to refine the SAR, the team may recommend that the Standards Committee direct curtailment of work on the SAR. While there is no established limit on the number of times a SAR may be posted for comment, the Standards Committee retains the right to reverse its prior decision and reject a SAR if it believes continued revisions are not productive. The Standards Committee shall notify the sponsor in writing of the rejection within 10 calendar days. If stakeholders indicate support for the project proposed with the SAR, the drafting team shall present its work to the Standards Committee with a request that the Standards Committee authorize development of the associated Reliability Standard.



The Standards Committee, once again considering the public comments received and their resolution, may then take one of the following actions:

• Authorize drafting the proposed Reliability Standard or revisions to a Reliability Standard.

• Reject the SAR with a written explanation to the sponsor and post that explanation. 4.3: Form Drafting Team When the Standards Committee is ready to have a drafting team begin work on developing a new or revised Reliability Standard, the Standards Committee shall appoint a drafting team, if one was not already appointed to develop the SAR. If the Standards Committee appointed a drafting team to refine the SAR, the same drafting team shall work to develop the associated Reliability Standard. If no drafting team is in place, then the Standards Committee may use a public nomination process to populate the Reliability Standard drafting team, or may use another method that results in a team that collectively has the necessary technical expertise, diversity of views and work process skills to accomplish the objectives of the project on a timely basis. In some situations, an ad hoc team may already be in place with the requisite expertise, competencies, and diversity of views that are necessary to develop the Reliability Standard, and additional members may not be needed. The NERC Reliability Standards Staff shall provide one or more members as needed to support the team with facilitation, project management, compliance, legal, regulatory and technical writing expertise and shall provide administrative support to the team, guiding the team through the steps in completing its project. In developing the Reliability Standard, the individuals provided by the NERC Reliability Standards Staff serve as advisors to the drafting team and do not have voting rights but share accountability along with the drafting team members assigned by the Standards Committee for timely delivery of a final draft Reliability Standard that meets the quality attributes identified in NERC’s Benchmarks for Excellent Standards. The drafting team members assigned by the Standards Committee shall have final authority over the technical details of the Reliability Standard, while the technical writer shall provide assistance to the drafting team in assuring that the final draft of the Reliability Standard meets the quality attributes identified in NERC’s Benchmarks for Excellent Standards. Once it is appointed by the Standards Committee, the Reliability Standard drafting team is responsible for making recommendations to the Standards Committee regarding the remaining steps in the Reliability Standards process. Consistent with the need to provide for timely standards development, the Standards Committee may decide a project is so large that it should be subdivided and either assigned to more than one drafting team or assigned to a single drafting team with clear direction on completing the project in specified phases. The normally expected timeframes for standards development within the context of this manual are applicable to individual standards and not to projects containing multiple standards. Alternatively, a single drafting team may address the entire project with a commensurate increase in the expected duration of the development work. If a SAR is subdivided and assigned to more than one drafting team, each drafting team will have a clearly defined portion of the work such that there are no overlaps and no gaps in the work to be accomplished.

The Standards Committee may supplement the membership of a Reliability Standard drafting team or provide for additional advisors, as appropriate, to ensure the necessary competencies and diversity of views are maintained throughout the Reliability Standard development effort. 4.4: Develop Preliminary Draft of Reliability Standard, Implementation Plan and VRFs and VSLs

4.4.1: Project Schedule



When a drafting team begins its work, either in refining a SAR or in developing or revising a proposed Reliability Standard, the drafting team shall develop a project schedule which shall be approved by the Standards Committee. The drafting team shall report progress to the Standards Committee, against the initial project schedule and any revised schedule as requested by the Standards Committee. Where project milestones cannot be completed on a timely basis, modifications to the project schedule must be presented to the Standards Committee for consideration along with proposed steps to minimize unplanned project delays. 4.4.2: Draft Reliability Standard The team shall develop a Reliability Standard that is within the scope of the associated SAR that includes all required elements as described earlier in this manual with a goal of meeting the quality attributes identified in NERC’s Benchmarks for Excellent Standards and criteria for governmental approval. The team shall document its justification for the Requirements in its proposed Reliability Standard by explaining how each meets these criteria. The standard drafting team shall document its justification for selecting each reference by explaining how each Requirement fits the category chosen. 4.4.3: Implementation Plan As a drafting team drafts its proposed revisions to a Reliability Standard, that team is also required to develop an implementation plan to identify any factors for consideration when approving the proposed effective date or dates for the associated Reliability Standard or Standards. As a minimum, the implementation plan shall include the following:

• The proposed effective date (the date entities shall be compliant) for the Requirements.

• Identification of any new or modified definitions that are proposed for approval with the associated Reliability Standard.

• Whether there are any prerequisite actions that need to be accomplished before entities are held responsible for compliance with one or more of the Requirements.

• Whether approval of the proposed Reliability Standard will necessitate any conforming changes to any already approved Reliability Standards – and identification of those Reliability Standards and Requirements.

• The Functional Entities that will be required to comply with one or more Requirements in the proposed Reliability Standard.

A single implementation plan may be used for more than one Reliability Standard. The implementation plan is posted with the associated Reliability Standard or Standards during the 45 (calendar) day formal comment period and is balloted with the associated Reliability Standard. 4.4.4: Violation Risk Factors and Violation Severity Levels The drafting team shall work with NERC Staff in developing a set of VRFs and VSLs that meet the latest criteria established by NERC and Applicable Governmental Authorities. The drafting team shall document its justification for selecting each VRF and for setting each set of proposed VSLs by explaining how its proposed VRFs and VSLs meet these criteria. NERC Staff is responsible for ensuring that the VRFs and VSLs proposed for stakeholder review meet these criteria. Before the drafting team has finalized its Reliability Standard, implementation plan, and VRFs and VSLs, the team should seek stakeholder feedback on its preliminary draft documents.



4.5: Informal Feedback17 Drafting teams may use a variety of methods to collect informal stakeholder feedback on preliminary drafts of its documents, including the use of informal comment periods,18 webinars, industry meetings, workshops, or other mechanisms. Information gathered from informal comment forms shall be publicly posted. While drafting teams are not required to provide a written response to each individual comment received, drafting teams are encouraged, where possible, to post a summary response that identifies how it used comments submitted by stakeholders. Drafting teams are encouraged, where possible, to reach out directly to individual stakeholders in order to facilitate resolution of identified stakeholder concerns. The intent is to gather stakeholder feedback on a “working document” before the document reaches the point where it is considered the “final draft.” 4.6: Conduct Quality Review The NERC Reliability Standards Staff shall coordinate a quality review of the Reliability Standard, implementation plan, and VRFs and VSLs in parallel with the development of the Reliability Standard and implementation plan, to assess whether the documents are within the scope of the associated SAR, whether the Reliability Standard is clear and enforceable as written, and whether the Reliability Standard meets the criteria specified in NERC’s Benchmarks for Excellent Standards and criteria for governmental approval of Reliability Standards. The drafting team shall consider the results of the quality review, decide upon appropriate changes, and recommend to the Standards Committee whether the documents are ready for formal posting and balloting. The Standards Committee shall authorize posting the proposed Reliability Standard, and implementation plan for a formal comment period and ballot and the VRFs and VSLs for a non-binding poll as soon as the work flow will accommodate. If the Standards Committee finds that any of the documents do not meet the specified criteria, the Standards Committee shall remand the documents to the drafting team for additional work. If the Reliability Standard is outside the scope of the associated SAR, the drafting team shall be directed to either revise the Reliability Standard so that it is within the approved scope, or submit a request to expand the scope of the approved SAR. If the Reliability Standard is not clear and enforceable as written, or if the Reliability Standard does not meet the specified criteria, the Reliability Standard shall be returned to the drafting team by the Standards Committee with specific identification of any Requirement that is deemed to be unclear or unenforceable as written. 4.7: Conduct Formal Comment Period and Ballot Proposed new or modified Reliability Standards require a formal comment period where the new or modified Reliability Standard, implementation plan and associated VRFs and VSLs or the proposal to retire a Reliability Standard, implementation plan and associated VRFs and VSLs are posted. The formal comment period shall be at least 45-days long. Formation of the ballot pool and Ballot of the Reliability Standard take place during this formal 45-day comment period. The intent of the formal comment period(s) is to solicit very specific feedback on the final draft of the Reliability Standard, implementation plan and VRFs and VSLs.

17 While this discussion focuses on collecting stakeholder feedback on proposed Reliability Standards and implementation plans, the same process is used to collect stakeholder feedback on proposed new or modified Interpretations, definitions and Variances.

18 The term “informal comment period” refers to a comment period conducted outside of the ballot process and where there is no requirement for a drafting team to respond in writing to submitted comments.



Comments in written form may be submitted on a draft Reliability Standard by any interested stakeholder, including NERC Staff, FERC Staff, and other interested governmental authorities. If stakeholders disagree with some aspect of the proposed set of products, comments provided should explain the reasons for such disagreement and, where possible, suggest specific language that would make the product acceptable to the stakeholder. 4.8: Form Ballot Pool The NERC Reliability Standards Staff shall establish a ballot pool during the first 30 calendar days of the 45-day formal comment period. The NERC Reliability Standards Staff shall post the proposed Reliability Standard, along with its implementation plan, VRFs and VSLs and shall send a notice to every entity in the Registered Ballot Body to provide notice that there is a new or revised Reliability Standard proposed for approval and to solicit participants for the associated ballot pool. All members of the Registered Ballot Body are eligible to join each ballot pool to vote on a new or revised Reliability Standard and its implementation plan and to participate in the non-binding poll of the associated VRFs and VSLs. Any member of the Registered Ballot Body may join or withdraw from the ballot pool until the ballot window opens. No Registered Ballot Body member may join or withdraw from the ballot pool once the first ballot starts through the point in time where balloting for that Reliability Standard action has ended. The Director of Standards may authorize deviations from this rule for extraordinary circumstances such as the death, retirement, or disability of a ballot pool member that would prevent an entity that had a member in the ballot pool from eligibility to cast a vote during the ballot window. Any approved deviation shall be documented and noted to the Standards Committee. 4.9: Conduct Ballot and Non-binding Poll of VRFs and VSLs19 The NERC Reliability Standards Staff shall announce the opening of the Ballot window and the non-binding poll of VRFs and VSLs. The Ballot window and non-binding poll of VRFs and VSLs shall take place during the last 10 calendar days of the 45-day formal comment period and for the Final Ballot shall be no less than 10 calendar days. If the last day of the ballot window falls on a Saturday or Sunday, the period does not end until the next business day.20 The ballot and non-binding poll shall be conducted electronically. The voting window shall be for a period of 10 calendar days but shall be extended, if needed, until a quorum is achieved. During a ballot window, NERC shall not sponsor or facilitate public discussion of the Reliability Standard action under ballot. There is no requirement to conduct a new non-binding poll of the revised VRFs and VSLs if no changes were made to the associated standard, however if the requirements are modified and conforming changes are made to the associated VRFs and VSLs, another non-binding poll of the revised VRFs and VSLs shall be conducted.

19 While RSAWs are not part of the Reliability Standard, they are developed through collaboration of the SDT and NERC Compliance Staff. A non-binding poll, similar to what is done for VRFs and VSLs may be conducted for the RSAW developed through this process to gauge industry support for the companion RSAW to be provided for informational purposes to the NERC Board of Trustees.

20 Closing dates may be extended as deemed appropriate by NERC Staff.



4.10: Criteria for Ballot Pool Approval Ballot pool approval of a Reliability Standard requires:

A quorum, which is established by at least 75% of the members of the ballot pool submitting a response; and A two-thirds majority of the weighted Segment votes cast shall be affirmative. The number of votes cast is the sum of affirmative votes and negative votes with comments. This calculation of votes for the purpose of determining consensus excludes (i) abstentions, (ii) non-responses, and (iii) negative votes without comments. The following process21 is used to determine if there are sufficient affirmative votes.

• For each Segment with ten or more voters, the following process shall be used: The number of affirmative votes cast shall be divided by the sum of affirmative and negative votes with comments cast to determine the fractional affirmative vote for that Segment. Abstentions, non-responses, and negative votes without comments shall not be counted for the purposes of determining the fractional affirmative vote for a Segment.

• For each Segment with less than ten voters, the vote weight of that Segment shall be proportionally reduced. Each voter within that Segment voting affirmative or negative with comments shall receive a weight of 10% of the Segment vote.

• The sum of the fractional affirmative votes from all Segments divided by the number of Segments voting22 shall be used to determine if a two-thirds majority has been achieved. (A Segment shall be considered as “voting” if any member of the Segment in the ballot pool casts either an affirmative vote or a negative vote with comments.)

• A Reliability Standard shall be approved if the sum of fractional affirmative votes from all Segments divided by the number of voting Segments is at least two thirds.

4.11: Voting Positions Each member of the ballot pool may only vote one of the following positions on the Ballot and Additional Ballot(s):

• Affirmative; • Affirmative, with comment; • Negative with comments; • Abstain.

Given that there is no formal comment period concurrent with the Final Ballot, each member of the ballot pool may only vote one of the following positions on the Final Ballot:

• Affirmative; • Negative;23 • Abstain.

21 Examples of weighted segment voting calculation are posted on the Reliability Standards Resources web page. 22 When less than ten entities vote in a Segment, the total weight for that Segment shall be determined as one tenth per entity voting, up to ten.

23 The Final Ballot is used to confirm consensus achieved during the Formal Comment and Ballot stage. Ballot Pool members voting negative on the Final Ballot will be deemed to have expressed the reason for their negative ballot in their own comments or the comments of others during prior Formal Comment periods.



4.12: Consideration of Comments If a stakeholder or balloter proposes a significant revision to a Reliability Standard during the formal comment period or concurrent Ballot that will improve the quality, clarity, or enforceability of that Reliability Standard, then the drafting team may choose to make such revisions and post the revised Reliability Standard for another 45 calendar day public comment period and ballot. Prior to posting the revised Reliability Standard for an additional comment period, the drafting team must communicate this decision to stakeholders. This communication is intended to inform stakeholders that the drafting team has identified that significant revisions to the Reliability Standard are necessary and should note that the drafting team is not required to respond in writing to comments from the previous ballot. The drafting team will respond to comments received in the last Additional Ballot prior to conducting a Final Ballot. There is no formal comment period concurrent with the Final Ballot and no obligation for the drafting team to respond to any comments submitted during the Final Ballot. 4.13: Additional Ballots A drafting team must respond in writing to every stakeholder written comment submitted in response to a ballot prior to conducting a Final Ballot. These responses may be provided in summary form, but all comments and objections must be responded to by the drafting team. All comments received and all responses shall be publicly posted. However, a drafting team is not required to respond in writing to comments to the previous ballot when it determines that significant changes are needed and an Additional Ballot will be conducted. 4.14: Conduct Final Ballot When the drafting team has reached a point where it has made a good faith effort at resolving applicable objections and is not making any substantive changes from the previous ballot, the team shall conduct a “Final Ballot.” A non-substantive revision is a revision that does not change the scope, applicability, or intent of any Requirement and includes but is not limited to things such as correcting the numbering of a Requirement, correcting the spelling of a word, adding an obviously missing word, or rephrasing a Requirement for improved clarity. Where there is a question as to whether a proposed modification is “substantive,” the Standards Committee shall make the final determination. In the Final Ballot, members of the ballot pool shall again be presented the proposed Reliability Standard along with the reasons for negative votes from the previous ballot, the responses of the drafting team to those concerns, and any resolution of the differences. All members of the ballot pool shall be permitted to reconsider and change their vote from the prior ballot. Members of the ballot pool who did not respond to the prior ballot shall be permitted to vote in the Final Ballot. In the Final Ballot, votes shall be counted by exception only members on the Final Ballot may indicate a revision to their original vote; otherwise their vote shall remain the same as in their prior ballot. 4.15: Final Ballot Results There are no limits to the number of public comment periods and ballots that can be conducted to result in a Reliability Standard or interpretation that is clear and enforceable, and achieves a quorum and sufficient affirmative votes for approval. The Standards Committee has the authority to conclude this process for a particular Reliability Standards action if it becomes obvious that the drafting team cannot develop a Reliability Standard that is within the scope of the associated SAR, is sufficiently clear to be enforceable, and achieves the requisite weighted Segment approval percentage. The NERC Reliability Standards Staff shall post the final outcome of the ballot process. If the Reliability Standard is rejected, the Standards Committee may decide whether to end all further work on the proposed standard, return the project to informal development, or continue holding ballots to attempt to reach



consensus on the proposed standard. If the Reliability Standard is approved, the Reliability Standard shall be posted and presented to the Board of Trustees by NERC management for adoption and subsequently filed with Applicable Governmental Authorities for approval. 4.16: Board of Trustees Adoption of Reliability Standards, Implementation Plan and VRFs and VSLs If a Reliability Standard and its associated implementation plan are approved by its ballot pool, the Board of Trustees shall consider adoption of that Reliability Standard and its associated implementation plan and shall direct the standard to be filed with Applicable Governmental Authorities for approval. In making its decision, the Board shall consider the results of the balloting and unresolved dissenting opinions. The Board shall adopt or reject a Reliability Standard and its implementation plan, but shall not modify a proposed Reliability Standard. If the Board chooses not to adopt a Reliability Standard, it shall provide its reasons for not doing so. The board shall consider approval of the VRFs and VSLs associated with a reliability standard. In making its determination, the board shall consider the following:

• The Standards Committee shall present the results of the non-binding poll conducted and a summary of industry comments received on the final posting of the proposed VRFs and VSLs.

• NERC Staff shall present a set of recommended VRFs and VSLs that considers the views of the standard drafting team, stakeholder comments received on the draft VRFs and VSLs during the posting for comment process, the non-binding poll results, appropriate governmental agency rules and directives, and VRF and VSL assignments for other Reliability Standards to ensure consistency and relevance across the entire spectrum of Reliability Standards.

4.17: Compliance For a Reliability Standard to be enforceable, it shall be approved by its ballot pool, adopted by the NERC Board of Trustees, and approved by Applicable Governmental Authorities, unless otherwise approved by the NERC Board of Trustees pursuant to the NERC Rules of Procedure (e.g, Section 321) and approved by Applicable Governmental Authorities. Once a Reliability Standard is approved or otherwise made mandatory by Applicable Governmental Authorities, all persons and organizations subject to jurisdiction of the ERO will be required to comply with the Reliability Standard in accordance with applicable statutes, regulations, and agreements. 4.18: Withdrawal of a Reliability Standard, Interpretation, or Definition The term “withdrawal” as used herein, refers to the discontinuation of a Reliability Standard, Interpretation, Variance or definition that has been approved by the Board of Trustees and (1) has not been filed with Applicable Governmental Authorities, or (2) has been filed with, but not yet approved by, Applicable Governmental Authorities. The Standards Committee may withdraw a Reliability Standard, Interpretation or definition for good cause upon approval by the Board of Trustees. Upon approval by the Board of Trustees, NERC Staff will petition the Applicable Governmental Authorities, as needed, to allow for withdrawal. The Board of Trustees also has an independent right of withdrawal that is unaffected by the terms and conditions of this Section. 4.19: Retirement of a Reliability Standard, Interpretation, or Definition The term “retirement” refers to the discontinuation of a Reliability Standard, Interpretation or definition that has been approved by Applicable Governmental Authorities. A Reliability Standard, Variance or Definition may be retired when it is superseded by a revised version, and in such cases the retirement of the



earlier version is to be noted in the implementation plan presented to the ballot pool for approval and the retirement shall be considered approved by the ballot pool upon ballot pool approval of the revised version.

Upon identification of a need to retire a Reliability Standard, Variance, Interpretation or definition, where the item will not be superseded by a new or revised version, a SAR containing the proposal to retire a Reliability Standard, Variance, Interpretation or definition will be posted for a comment period and ballot in the same manner as a Reliability Standard. The proposal shall include the rationale for the retirement and a statement regarding the impact of retirement on the reliability of the Bulk Power System. Upon approval by the Board of Trustees, NERC Staff will petition the Applicable Governmental Authorities to allow for retirement.

Process for Developing a Defined Term


Section 5.0: Process for Developing a Defined Term

NERC maintains a glossary of approved terms, entitled the Glossary of Terms Used in NERC Reliability Standards24 (“Glossary of Terms”). The Glossary of Terms includes terms that have been through the formal approval process and are used in one or more NERC Reliability Standards. Definitions shall not contain statements of performance Requirements. The Glossary of Terms is intended to provide consistency throughout the Reliability Standards. There are several methods that can be used to add, modify or retire a defined term used in a continent-wide Reliability Standard.

• Anyone can use a Standard Authorization Request (“SAR”) to submit a request to add, modify, or retire a defined term.

• Anyone can submit a Standards Comments and Suggestions Form recommending the addition, modification, or retirement of a defined term. (The suggestion would be added to a project and incorporated into a SAR.)

• A drafting team may propose to add, modify, or retire a defined term in conjunction with the work it is already performing.

5.1: Proposals to Develop a New or Revised Definition The following considerations should be made when considering proposals for new or revised definitions:

• Some NERC Regional Entities have defined terms that have been approved for use in Regional Reliability Standards, and where the drafting team agrees with a term already defined by a Regional Entity, the same definition should be adopted if needed to support a NERC Reliability Standard.

• If a term is used in a Reliability Standard according to its common meaning (as found in a collegiate dictionary), the term shall not be proposed for addition to the Glossary of Terms.

• If a term has already been defined, any proposal to modify or delete that term shall consider all uses of the definition in approved Reliability Standards, with a goal of determining whether the proposed modification is acceptable, and whether the proposed modification would change the scope or intent of any approved Reliability Standards.

• When practical, where NAESB has a definition for a term, the drafting team shall use the same definition to support a NERC Reliability Standard.

Any definition that is balloted separately from a proposed new or modified Reliability Standard or from a proposal for retirement of a Reliability Standard shall be accompanied by an implementation plan. If a SAR is submitted to the NERC Reliability Standards Staff with a proposal for a new or revised definition, the Standards Committee shall consider the urgency of developing the new or revised definition and may direct NERC Staff to post the SAR immediately, or may defer posting the SAR until a later time based on its priority relative to other projects already underway or already approved for future development. If the SAR identifies a term that is used in a Reliability Standard already under revision by a drafting team, the Standards Committee may direct the drafting team to add the term to the scope of the existing project. Each time the Standards Committee accepts a SAR for a project that was not identified in the Reliability Standards Development Plan, the project shall be added to the list of approved projects.

24 The latest approved version of the Glossary of Terms is posted on the NERC website on the Standards web page.



5.2: Stakeholder Comments and Approvals Any proposal for a new or revised definition shall be processed in the same manner as a Reliability Standard and quality review shall be conducted in parallel with this process. Once authorized by the Standards Committee, the proposed definition and its implementation plan shall be posted for at least one formal stakeholder comment period and shall be balloted in the same manner as a Reliability Standard. If a new or revised definition is proposed by a drafting team, that definition may be balloted separately from the associated Reliability Standard. Each definition that is approved by its ballot pool shall be submitted to the NERC Board of Trustees for adoption and then filed with Applicable Governmental Authorities for approval in the same manner as a Reliability Standard.

Process for Conducting Field Tests


Section 6.0: Process for Conducting Field Tests

While most drafting teams can develop Reliability Standards without the need to conduct any field tests and without the need to collect and analyze data, some Reliability Standard development efforts may benefit from field tests to analyze data and validate concepts in the development of Reliability Standards. Drafting teams are not required to collect and analyze data or to conduct a field test to validate a Reliability Standard. A field test is initiated by either a SAR or Reliability Standard drafting team. The drafting team may be supplemented with other individuals based on the required technical expertise needed to support the field test. The drafting team is responsible for developing the field test plan, including the implementation schedule, and for identifying compliance related issues such as the potential need for compliance waivers. 6.1: Field Tests and Data Analysis (collectively “field test”)

• Field tests to validate concepts that support the development of Reliability Standards should be conducted, to the extent possible, before the SAR for a project is finalized.

• To conduct a field test of a technical concept in a proposed new or revised Reliability Standard, the drafting team must work with NERC Staff to identify one of NERC’s technical committees to oversee the field test as well as other technical committees with relevant technical expertise.

• The field test is conducted by the drafting team, in coordination with NERC Staff and under the oversight of the assigned technical committee, in accordance with an approved field test plan.

6.1.1. Field Test Approval The request to conduct a field test must include, at a minimum:

• the field test plan, • the implementation schedule, and • an expectation for periodic updates of the analysis of the results to the lead NERC technical

committee. Prior to the drafting team conducting a field test, the drafting team must first receive approval from the lead NERC technical committee. Second, the drafting team must receive approval from the Standards Committee.

The lead NERC technical committee’s approval shall be based on the technical adequacy of the field test plan. Following approval, the lead NERC technical committee shall provide a recommendation to the Standards Committee for the disposition of the field test plan requests. The lead NERC technical committee shall coordinate all entity participation in the field test such as accepting, adding to, and withdrawals of the individual entities from the field tests, as well as coordinating and communicating status of the results of the field tests. The Standards Committee’s decision to approve the field test plan request shall be based solely on whether the Standards Committee, via a majority vote, agrees or disagrees with the lead NERC technical committee’s recommendation. If the Standards Committee disagrees with the lead NERC technical committee’s recommendation, the Standards Committee will inform the lead NERC technical committee with an explanation of the basis for the decision.



6.1.2: Field Test Suspension for Reliability Concerns During the field test, if the lead NERC technical committee overseeing the field test determines that the field test is creating a reliability risk to the Bulk Power System:

• the lead NERC technical committee shall stop or modify the activity; • the lead NERC technical committee shall inform the Standards Committee that the activity was

stopped or modified; • the Standards Committee, with the assistance of NERC Staff, shall document the cessation or

modification of the field test; and • the Standards Committee, with the assistance of NERC staff, shall notify NERC Compliance

Monitoring and Enforcement Program Staff to coordinate any compliance related issues such as continuance or cessation of waivers (see Section 6.2).

Prior to the field test being restarted after it has been stopped, the drafting team must resubmit the field test request and receive approval as outlined in Section 6.1.1. 6.1.3: Continuing, Modifying or Terminating a Field Test If the drafting team concludes that a field test does not provide sufficient information to formulate a conclusion within the time allotted in the plan, the drafting team shall provide a recommendation to either continue (including extending the duration of the field test beyond the period of standard development), modify or terminate the field test to the lead NERC technical committee and the chair of the Standards Committee. The lead NERC technical committee shall either approve or reject a request to continue, modify or terminate the field test, and, thereafter, provide notice to the chair of the Standards Committee of its selection. If the duration of the field test is extended beyond the period of standard development, the preliminary report and results shall be publicly posted on the NERC web site prior to the final ballot of the Reliability Standard. 6.2: Communication and Coordination for All Types of Field Tests After approval of the field test, the drafting team may request waivers of compliance for field test participants that would be rendered incapable of complying with the Requirement(s) of the currently enforceable Reliability Standard due to their participation. The NERC Compliance Monitoring and Enforcement Program Staff shall determine whether to approve the requested waivers, and shall be responsible for approving any modifications or terminations that may become necessary following the start of the field test. The NERC Reliability Standards Staff shall inform the affected Registered Entities. Prior to initiation of the field test, the chair of the Standards Committee, in conjunction with the lead NERC technical committee chair, shall inform the Board of Trustees of the pending field test, the expected duration, and any requested waivers from compliance for Registered Entities. During the field test, the drafting team conducting the field test shall provide periodic updates (no less than quarterly) on the progress of the field test to the Standards Committee and the NERC technical committees. Prior to the ballot of any standard involving a field test, the drafting team shall provide to the Standards Committee either a preliminary report of the results of the field test to date, if the field test will continue beyond standard development, or a final report if the field test has been completed. The chair of the Standards Committee shall keep the Board of Trustees informed.



The field test plan and all reports and results shall be publicly posted on the NERC web site. This posting shall include the participant list, unless it is determined that posting this list would present confidentiality or other concerns.

Process for Developing an Interpretation


Section 7.0: Process for Developing an Interpretation A valid Interpretation request is one that requests additional clarity about one or more Requirements in approved NERC Reliability Standards, but does not request approval as to how to comply with one or more Requirements. 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 of any Requirement in any continent-wide Reliability Standard that has been adopted by the NERC Board of Trustees. Interpretations will only be provided for Board of Trustees-approved Reliability Standards i.e. (i) the current effective version of a Reliability Standard; or (ii) a version of a Reliability Standard with a future effective date. An Interpretation may only clarify or interpret the Requirements of an approved Reliability Standard, including, if applicable, any attachment referenced in the Requirement being clarified. No other elements of an approved Reliability Standard are subject to Interpretation. The entity requesting the Interpretation shall submit a Request for Interpretation form25 to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the Interpretation provided. The NERC Reliability Standards and Legal Staffs shall review the request for interpretation to determine whether it meets the requirements for a valid interpretation. Based on this review, the NERC Standards and Legal Staffs shall make a recommendation to the Standards Committee whether to accept the request for Interpretation and move forward in responding to the Interpretation request. For example, an Interpretation request may be rejected where it:

(1) Requests approval of a particular compliance approach; (2) Identifies a gap or perceived weakness in the approved Reliability Standard; (3) Where an issue can be addressed by an active standard drafting team; (4) Where it requests clarification of any element of a Reliability Standard other than a

Requirement; (5) Where a question has already been addressed in the record; (6) Where the Interpretation identifies an issue and proposes the development of a new or modified Reliability Standard, (such issues should be addressed via submission of a SAR); (7) Where an Interpretation seeks to expand the scope of a Reliability Standard; or (8) Where the meaning of a Reliability Standard is plain on its face.

If the Standards Committee rejects the Interpretation request, it shall provide a written explanation for rejecting the Interpretation to the entity requesting the Interpretation within 10 business days of the decision to reject. If the Standards Committee accepts the Interpretation request, the NERC Standards Staff shall (i) form a ballot pool and (ii) assemble an Interpretation drafting team with the relevant expertise to address the interpretation for approval by the Standards Committee. As soon as practical, the team shall develop a “final draft” Interpretation providing the requested clarity. Interpretations will be balloted in the same manner as Reliability Standards.

25 The Request for Interpretation form is posted on the NERC Standards web page.



If stakeholder comments indicate that there is not a consensus for the Interpretation, and the Interpretation drafting team cannot revise the Interpretation without violating the basic expectations outlined above, the Interpretation drafting team shall notify the Standards Committee of its conclusion and may submit a SAR with the proposed modification to the Reliability Standard. The entity that requested the Interpretation shall be notified and the disposition of the Interpretation shall be posted. If, during its deliberations, the Interpretation drafting team identifies a reliability gap in the Reliability Standard that is highlighted by the Interpretation request, the Interpretation drafting team shall notify the Standards Committee of its conclusion and may submit a SAR with the proposed modification to the Reliability Standard at the same time it provides its proposed Interpretation. The NERC Reliability Standards and Legal Staffs shall review the final Interpretation to determine whether it has met the requirements for a valid Interpretation. Based on this review, the NERC Standards and Legal Staffs shall make a recommendation to the NERC Board of Trustees regarding adoption. If approved by its ballot pool, the Interpretation shall be forwarded to the NERC Board of Trustees for adoption.26 If an Interpretation drafting team proposes a modification to a Reliability Standard as part of its work in developing an Interpretation, the Board of Trustees shall be notified of this proposal at the time the Interpretation is submitted for adoption. Following adoption by the Board of Trustees, NERC Staff shall file the Interpretation for approval by Applicable Governmental Authorities and the Interpretation shall become effective when approved by those Applicable Governmental Authorities. The Interpretation shall stand until such time as the Interpretation can be incorporated into a future revision of the Reliability Standard or the Interpretation is retired due to a future modification of the applicable Requirement.

26 NERC will maintain a record of all interpretations associated with each standard on the Reliability Standards page of the NERC website.



If significant changes are needed to the Interpretatation then conduct Additional Ballot (Repeat Step 6) If, during its deliberations, the Interpretation drafting team identifies a reliability gap in the Reliability Standard that is highlighted by the Interpretation request, the Interpretation drafting team shall notify the Standards Committee of its

conclusion and shall submit a SAR with the proposed modification to the Reliability Standard at the same time it provides itsproposed Interpretation.


Form Ballot Pool during first 30 calendar days of 45-day Comment Period Conduct Ballot during last 10 days of Comment Period

STEP 5: Obtain Standards Committee Approval to Post Interpretation for Comment and Ballot

STEP 4: Develop Draft of Interpretation

Conduct Quality Review Collect Informal Feedback

STEP 3: Standards Committee Accepts/Rejects the Interpretation request

If the Standards Committee rejects the Interpretation request, it shall provide a written explanation for rejecting the Interpretation to the entity requesting the

interpretation within 10 business days of the decision to reject.

If the Standards Committee accepts the Interpretation request, the NERC Standards staff shall form a ballot pool and assemble an Interpretation drafting

team with the relevant expertise to address the interpretation.

STEP 2: Request for Interpretation reviewed by NERC Reliability Standards and Legal Staffs and Recommendation submitted to the Standards Committee

STEP1: Request for Interpretation Form submitted



FIGURE 2: Process for Developing an Interpretation

STEP 11: Submit BOT-approved Interpretation to Applicable Gvernmental Authorities for approval

STEP 10: Submit Interpretation to BOT for Adoption and Approval

STEP 9: Review by NERC Reliability Standards and Legal Staff of the Interpretation to determine whether it has met the requirements for a valid Interpretation

Recommendation submitted by NERC Standards and Legal Staff to BOT regarding adoption



Process for Appealing an Action or Inaction


Section 8.0: Process for Appealing an Action or Inaction

Any entity that has directly and materially affected interests and that has been or will be adversely affected by any procedural action or inaction related to the development, approval, revision, reaffirmation, retirement or withdrawal of a Reliability Standard, definition, Variance, associated implementation plan, or Interpretation shall have the right to appeal. This appeals process applies only to the NERC Reliability Standards processes as defined in this manual, not to the technical content of the Reliability Standards action. The burden of proof to show adverse effect shall be on the appellant. Appeals shall be made in writing within 30 days of the date of the action purported to cause the adverse effect, except appeals for inaction, which may be made at any time. The final decisions of any appeal shall be documented in writing and made public. The appeals process provides two levels, with the goal of expeditiously resolving the issue to the satisfaction of the participants. 8.1: Level 1 Appeal Level 1 is the required first step in the appeals process. The appellant shall submit (to the Director of Standards) a complaint in writing that describes the procedural action or inaction associated with the Reliability Standards process. The appellant shall describe in the complaint the actual or potential adverse impact to the appellant. Assisted by NERC Staff and industry resources as needed, the Director of Standards shall prepare a written response addressed to the appellant as soon as practical but not more than 45 days after receipt of the complaint. If the appellant accepts the response as a satisfactory resolution of the issue, both the complaint and response shall be made a part of the public record associated with the Reliability Standard. 8.2: Level 2 Appeal If after the Level 1 Appeal the appellant remains unsatisfied with the resolution, as indicated by the appellant in writing to the Director of Standards, the Director of Standards shall convene a Level 2 Appeals Panel. This panel shall consist of five members appointed by the Board of Trustees. In all cases, Level 2 Appeals Panel members shall have no direct affiliation with the participants in the appeal. The NERC Reliability Standards Staff shall post the complaint and other relevant materials and provide at least 30 days notice of the meeting of the Level 2 Appeals Panel. In addition to the appellant, any entity that is directly and materially affected by the procedural action or inaction referenced in the complaint shall be heard by the panel. The panel shall not consider any expansion of the scope of the appeal that was not presented in the Level 1 Appeal. The panel may, in its decision, find for the appellant and remand the issue to the Standards Committee with a statement of the issues and facts in regard to which fair and equitable action was not taken. The panel may find against the appellant with a specific statement of the facts that demonstrate fair and equitable treatment of the appellant and the appellant’s objections. The panel may not, however, revise, approve, disapprove, or adopt a Reliability Standard, definition, Variance or Interpretation or implementation plan as these responsibilities remain with the ballot pool and Board of Trustees respectively. The actions of the Level 2 Appeals Panel shall be publicly posted. In addition to the foregoing, a procedural objection that has not been resolved may be submitted to the Board of Trustees for consideration at the time the Board decides whether to adopt a particular Reliability Standard, definition, Variance or Interpretation. The objection shall be in writing, signed by an officer of the objecting entity, and contain a concise statement of the relief requested and a clear demonstration of the



facts that justify that relief. The objection shall be filed no later than 30 days after the announcement of the vote by the ballot pool on the Reliability Standard in question.

Process for Developing a Variance


Section 9.0: Process for Developing a Variance A Variance is an approved, alternative method of achieving the reliability intent of one or more Requirements in a Reliability Standard. No Regional Entity or Bulk Power System owner, operator, or user shall claim a Variance from a NERC Reliability Standard without approval of such a Variance through the relevant Reliability Standard approval procedure for the Variance. Each Variance from a NERC Reliability Standard that is approved by NERC and Applicable Governmental Authorities shall be made an enforceable part of the associated NERC Reliability Standard. NERC’s drafting teams shall aim to develop Reliability Standards with Requirements that apply on a continent-wide basis, minimizing the need for Variances while still achieving the Reliability Standard’s reliability objectives. If one or more Requirements cannot be met or complied with as written because of a physical difference in the Bulk Power System or because of an operational difference (such as a conflict with a federally or provincially approved tariff), but the Requirement’s reliability objective can be achieved in a different fashion, an entity or a group of entities may pursue a Variance from one or more Requirements in a continent-wide Reliability Standard. It is the responsibility of the entity that needs a Variance to identify that need and initiate the processing of that Variance through the submittal of a SAR27 that includes a clear definition of the basis for the Variance. There are two types of Variances – those that apply on an Interconnection-wide basis, and those that apply to one or more entities on less than an Interconnection-wide basis. 9.1: Interconnection-wide Variances Any Variance from a NERC Reliability Standard Requirement that is proposed to apply to Registered Entities within a Regional Entity organized on an Interconnection-wide basis shall be considered an Interconnection-wide Variance and shall be developed through that Regional Entity’s NERC-approved Regional Reliability Standards development procedure. While an Interconnection-wide Variance may be developed through the associated Regional Reliability Standards development process, Regional Entities are encouraged to work collaboratively with existing continent-wide drafting teams to reduce potential conflicts between the two efforts. An Interconnection-wide Variance from a NERC Reliability Standard that is determined by NERC to be just, reasonable, and not unduly discriminatory or preferential, and in the public interest, and consistent with other applicable standards of governmental authorities shall be made part of the associated NERC Reliability Standard. NERC shall rebuttably presume that an Interconnection-wide Variance from a NERC Reliability Standard that is developed, in accordance with a Regional Reliability Standards development procedure approved by NERC, by a Regional Entity organized on an Interconnection-wide basis, is just, reasonable, and not unduly discriminatory or preferential, and in the public interest. 9.2: Variances that Apply on Less than an Interconnection-wide Basis Any Variance from a NERC Reliability Standard Requirement that is proposed to apply to one or more entities but less than an entire Interconnection (e.g., a Variance that would apply to a regional transmission organization or particular market or to a subset of Bulk Power System owners, operators, or users), shall be considered a Variance. A Variance may be requested while a Reliability Standard is under development or a Variance may be requested at any time after a Reliability Standard is approved. Each request for a

27 A sample of a SAR that identifies the need for a Variance and a sample Variance are posted as resources on the Reliability Standards Resources web page.



Variance shall be initiated through a SAR, and processed and approved in the same manner as a continent-wide Reliability Standard, using the Reliability Standards development process defined in this manual.

Processes for Developing a Reliability Standard Related to a Confidential Issue


Section 10.0: Processes for Developing a Reliability Standard Related to a Confidential Issue While it is NERC’s intent to use its ANSI-accredited Reliability Standards development process for developing its Reliability Standards, NERC has an obligation as the ERO to ensure that there are Reliability Standards in place to preserve the reliability of the interconnected Bulk Power Systems throughout North America. When faced with a national security emergency situation, NERC may use one of the following special processes to develop a Reliability Standard that addresses an issue that is confidential. Reliability Standards developed using one of the following processes shall be called, “special Reliability Standards” and shall not be filed with ANSI for approval as American National Standards. The NERC Board of Trustees may direct the development of a new or revised Reliability Standard to address a national security situation that involves confidential issues. These situations may involve imminent or long-term threats. In general, these Board directives will be driven by information from the President of the United States of America or the Prime Minister of Canada or a national security agency or national intelligence agency of either or both governments indicating (to the ERO) that there is a national security threat to the reliability of the Bulk Power System.28 There are two special processes for developing Reliability Standards responsive to confidential issues – one process where the confidential issue is “imminent,” and one process where the confidential issue is “not imminent.” 10.1: Process for Developing Reliability Standards Responsive to Imminent, Confidential Issues If the NERC Board of Trustees directs the immediate development of a new or revised Reliability Standard to address a confidential national security emergency situation, the NERC Reliability Standards Staff shall develop a SAR, form a ballot pool (to vote on the Reliability Standard and its implementation plan) and assemble a slate of pre-defined subject matter experts as a proposed drafting team for approval by the Standards Committee’s officers. All members of the Registered Ballot Body shall have the opportunity to join the ballot pool. 10.2: Drafting Team Selection The Reliability Standard drafting team selection process shall be limited to just those candidates who have already been identified as having the appropriate security clearance, the requisite technical expertise, and either have signed or are willing to sign a strict confidentiality agreement. 10.3: Work of Drafting Team The Reliability Standard drafting team shall perform all its work under strict security and confidential rules. The Reliability Standard drafting team shall develop the new or revised Reliability Standard and its implementation plan. The Reliability Standard drafting team shall review its work, to the extent practical, as it is being developed with officials from the appropriate governmental agencies in the U.S. and Canada, under strict security and confidentiality rules. 10.4: Formal Stakeholder Comment & Ballot Window

28 The NERC Board may direct the immediate development and issuance of a Level 3 (Essential Action) alert and then may also direct the immediate development of a new or revised Reliability Standard.



The draft Reliability Standard and its implementation plan shall be distributed for a formal comment period, under strict confidentiality rules, only to those entities that are listed in the NERC Compliance Registry to perform one of the functions identified in the applicability section of the Reliability Standard and have identified individuals from their organizations that have signed confidentiality agreements with NERC.29 At the same time, the Reliability Standard shall be distributed to the members of the ballot pool for review and ballot. The NERC Reliability Standards Staff shall not post or provide the ballot pool with any confidential background information. The drafting team, working with the NERC Reliability Standards Staff, shall consider and respond to all comments, make any necessary conforming changes to the Reliability Standard and its implementation plan, and shall distribute the comments, responses and any revision to the same population as received the initial set of documents for formal comment and ballot. 10.5: Board of Trustee Actions Each Reliability Standard and implementation plan developed through this process shall be submitted to the NERC Board of Trustees for adoption. 10.6: Governmental Approvals All approved documents shall be filed for approval with Applicable Governmental Authorities.

29 In this phase of the process, only the proposed Reliability Standard shall be distributed to those entities expected to comply, not the rationale and justification for the Reliability Standard. Only the special drafting team members, who have the appropriate security credentials, shall have access to this rationale and justification.



10.7: Developing a Reliability Standard Responsive to an Imminent, Confidential Issue

Step 7: Submit all BOT-approved documents to Applicable Governmental Authorities for approval

STEP 6: Submit Reliability Standard and Implementation Plan to BOT for Approval


STEP 4: Respond to Comments

Responses distributed to the same population that received the initial set of documents for comment and ballot


Distribute Standard for Comment only to entities that: (1) have signed confidentiality agreements; (2) are in the NERC Compliance Registry; and (3) perform an applicable function Conduct Ballot During Last 10 Days of Comment Period

STEP 2: Develop Draft of Reliability Standard, Implementation Plan and VRFs and VSLs

STEP 1: Add to List of Projects in Reliability Standards Development Plan

Draft SAR Form Drafting Team from Pre-identified List of Subject Matter Experts Form Ballot Pool



FIGURE 3: Process for Developing a Standard Responsive to an Imminent, Confidential Issue



10.8: Process for Developing Reliability Standards Responsive to Non-imminent, Confidential Issues If the NERC Board of Trustees directs the immediate development of a new or revised Reliability Standard to address a confidential national security emergency situation, the NERC Reliability Standards Staff shall develop a SAR, form a ballot pool (to vote on the Reliability Standard and its implementation plan) and assemble a slate of pre-defined subject matter experts as a proposed drafting team for approval by the Standards Committee’s officers. All members of the Registered Ballot Body shall have the opportunity to join the ballot pool. 10.9: Drafting Team Selection The drafting team selection process shall be limited to just those candidates who have already been identified as having the appropriate security clearance, the requisite technical expertise, and either have signed or are willing to sign a strict confidentiality agreement. 10.10: Work of Drafting Team The drafting team shall perform all its work under strict security and confidential rules. The Reliability Standard drafting team shall develop the new or revised Reliability Standard and its implementation plan. The drafting team shall review its work, to the extent practical, as it is being developed with officials from the Applicable Governmental Authorities, under strict security and confidentiality rules. 10.11: Formal Stakeholder Comment & Ballot Window The draft Reliability Standard and its implementation plan shall be distributed for a formal comment period, under strict confidentiality rules, only to those entities that are listed in the NERC Compliance Registry to perform one of the functions identified in the applicability section of the Reliability Standard and have identified individuals from their organizations that have signed confidentiality agreements with NERC.30 At the same time, the Reliability Standard shall be distributed to the members of the ballot pool for review and ballot. The NERC Reliability Standards Staff shall not post or provide the ballot pool with any confidential background information. 10.12: Revisions to Reliability Standard, Implementation Plan and VRFs and VSLs The drafting team, working with the NERC Reliability Standards Staff, shall work to refine the Reliability Standard, implementation plan and VRFs and VSLs in the same manner as for a new Reliability Standard following the “normal” Reliability Standards development process described earlier in this manual with the exception that distribution of the comments, responses, and new drafts shall be limited to those entities that are in the ballot pool and those entities that are listed in the NERC Compliance Registry to perform one of the functions identified in the applicability section of the Reliability Standard and have identified individuals from their organizations that have signed confidentiality agreements with NERC. 10.13: Board of Trustee Action Each Reliability Standard, implementation plan, and the associated VRFs and VSLs developed through this process shall be submitted to the NERC Board of Trustees for adoption. 10.14: Governmental Approvals All BOT-approved documents shall be filed for approval with Applicable Governmental Authorities.




Developing a Reliability Standard Responsive to a Non-imminent, Confidential Issue






If significant changes are needed to the draft Reliability Standard then conduct Additional Ballot (Repeat Step 3)

STEP 3: Formal Comment Period and Ballot (Comment Period and Ballot Window may be abbreviated)

Distribute Standard for Comment only to entities that: (1) have signed confidentiality agreements; (2) are in the NERC Compliance Registry; and (3) perform an applicable function

Conduct Ballot During Last 10 Days of Comment Period



Conduct Quality Review





FIGURE 4: Developing a Standard Responsive to a Non-Imminent, Confidential Issue

Process for Approving Supporting Documents


Section 11.0: Process for Approving Supporting Documents The following types of documents are samples of the types of supporting documents that may be developed to enhance stakeholder understanding and implementation of a Reliability Standard. These documents may explain or facilitate implementation of Reliability Standards but do not themselves contain mandatory Requirements subject to compliance review. Any Requirements that are mandatory shall be incorporated into the Reliability Standard in the Reliability Standard development process. While most supporting documents are developed by the standard drafting team working to develop the associated Reliability Standard, any entity may develop a supporting document associated with a Reliability Standard. The Standards Committee shall authorize the posting of all supporting references31 that are linked to an approved Reliability Standard. Prior to granting approval to post a supporting reference with a link to the associated Reliability Standard, the Standards Committee shall verify that the document has had stakeholder review to verify the accuracy of the technical content. While the Standards Committee has the authority to approve the posting of each such reference, stakeholders, not the Standards Committee, verify the accuracy of the document’s contents.

Type of Document Description

Reference Descriptive, technical information or analysis or explanatory information to support the understanding and interpretation of a Reliability Standard. A standard reference may support the implementation of a Reliability Standard or satisfy another purpose consistent with the reliability and market interface principles.

Guideline Recommended process that identifies a method of meeting a Requirement under specific conditions.

Supplement Data forms, pro forma documents, and associated instructions that support the implementation of a Reliability Standard.

Training Material Documents that support the implementation of a Reliability Standard.

Procedure Step-wise instructions defining a particular process or operation. Procedures may support the implementation of a Reliability Standard or satisfy another purpose consistent with the reliability and market interface principles.

White Paper An informal paper stating a position or concept. A white paper may be used to propose preliminary concepts for a Reliability Standard or one of the documents above.

31 The Standards Committee’s Procedure for Approving the Posting of Reference Documents is posted on the Reliability Standards Resources web page.

Process for Correcting Errata


Section 12.0: Process for Correcting Errata From time to time, an error may be discovered in a Reliability Standard. Such errors may be corrected (i) following a Final Ballot prior to Board of Trustees adoption, (ii) following Board of Trustees adoption prior to filing with Applicable Governmental Authorities; and (iii) following filing with Applicable Governmental Authorities. If the Standards Committee agrees that the correction of the error does not change the scope or intent of the associated Reliability Standard, and agrees that the correction has no material impact on the end users of the Reliability Standard, then the correction shall be filed for approval with Applicable Governmental Authorities as appropriate. The NERC Board of Trustees has resolved to concurrently approve any errata approved by the Standards Committee.

Process for Conducting Periodic Review of Reliability Standards


Section 13.0: Process for Conducting Periodic Reviews of Reliability Standards All Reliability Standards shall be reviewed at least once every ten years from the effective date of the Reliability Standard or the date of the latest Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. If a Reliability Standard is approved by ANSI as an American National Standard, it shall be reviewed at least once every five years from the effective date of the Reliability Standard or the date of the latest Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. The Reliability Standards Development Plan shall include projects that address this five or ten-year review of Reliability Standards.

• If a Reliability Standard is nearing its five or ten-year review and has issues that need resolution, then the Reliability Standards Development Plan shall include a project for the complete review and associated revision of that Reliability Standard that includes addressing all outstanding governmental directives, all approved Interpretations, and all unresolved issues identified by stakeholders.

• If a Reliability Standard is nearing its five or ten-year review and there are no outstanding governmental directives, Interpretations, or unresolved stakeholder issues associated with that Reliability Standard, then the Reliability Standards Development Plan shall include a project solely for the “five-year review” of that Reliability Standard.

For a project that is focused solely on the five-year review, the Standards Committee shall appoint a review team of subject matter experts to review the Reliability Standard and recommend whether the American National Standard Institute-approved Reliability Standard should be reaffirmed, revised, or withdrawn. Each review team shall post its recommendations for a 45 calendar day formal stakeholder comment period and shall provide those stakeholder comments to the Standards Committee for consideration.

• If a review team recommends reaffirming a Reliability Standard, the Standards Committee shall submit the reaffirmation to the Board of Trustees for adoption and then to Applicable Governmental Authorities for approval. Reaffirmation does not require approval by stakeholder ballot.

• If a review team recommends modifying, or retiring a Reliability Standard, the team shall develop a SAR with such a proposal and the SAR shall be submitted to the Standards Committee for prioritization as a new project. Each existing Reliability Standard recommended for modification, or retirement shall remain in effect in accordance with the associated implementation plan until the action to modify or withdraw the Reliability Standard is approved by its ballot pool, adopted by the Board of Trustees, and approved by Applicable Governmental Authorities.

In the case of reaffirmation of a Reliability Standard, the Reliability Standard shall remain in effect until the next five or ten-year review or until the Reliability Standard is otherwise modified or withdrawn by a separate action.

Public Access to Reliability Standards Information


Section 14.0: Public Access to Reliability Standards Information 14.1: Online Reliability Standards Information System The NERC Reliability Standards Staff shall maintain an electronic copy of information regarding currently proposed and currently in effect Reliability Standards. This information shall include current Reliability Standards in effect, proposed revisions to Reliability Standards, and proposed new Reliability Standards. This information shall provide a record, for at a minimum the previous five years, of the review and approval process for each Reliability Standard, including public comments received during the development and approval process. 14.2: Archived Reliability Standards Information The NERC Staff shall maintain a historical record of Reliability Standards information that is no longer maintained online. Archived information shall be retained indefinitely as practical, but in no case less than five years or one complete standard cycle from the date on which the Reliability Standard was no longer in effect. Archived records of Reliability Standards information shall be available electronically within 30 days following the receipt by the NERC Reliability Standards Staff of a written request.

Process for Updating Standard Processes


Section 15.0: Process for Updating Standard Processes 15.1: Requests to Revise the Standard Processes Manual Any person or entity may submit a request to modify one or more of the processes contained within this manual. The Standards Committee shall oversee the handling of each request. The Standards Committee shall prioritize all requests, merge related requests, and respond to each sponsor within 30 calendar days. The Standards Committee shall post the proposed revisions for a 45 (calendar) day formal comment period. Based on the degree of consensus for the revisions, the Standards Committee shall:

a. Submit the revised process or processes for ballot pool approval; b. Repeat the posting for additional inputs after making changes based on comments received; c. Remand the proposal to the sponsor for further work; or d. Reject the proposal.

The Registered Ballot Body shall be represented by a ballot pool. The ballot procedure shall be the same as that defined for approval of a Reliability Standard, including the use of an Additional Ballot if needed. If the proposed revision is approved by the ballot pool, the Standards Committee shall submit the revised procedure to the Board for adoption. The Standards Committee shall submit to the Board a description of the basis for the changes, a summary of the comments received, and any minority views expressed in the comment and ballot process. The proposed revisions shall not be effective until approved by the NERC Board of Trustees and Applicable Governmental Authorities.

Waiver


Section 16.0: Waiver While it is NERC’s intent to use its ANSI-accredited Reliability Standards development process for developing its Reliability Standards, NERC may need to develop a new or modified Reliability Standard, definition, Variance, or implementation plan under specific time constraints (such as to meet a time constrained regulatory directive) or to meet an urgent reliability issue such that there isn’t sufficient time to follow all the steps in the normal Reliability Standards development process. The Standards Committee may waive any of the provisions contained in this manual for good cause shown, but limited to the following circumstances:

• In response to a national emergency declared by the United States or Canadian government that

involves the reliability of the Bulk Electric System or cyber attack on the Bulk Electric System; • Where necessary to meet regulatory deadlines; • Where necessary to meet deadlines imposed by the NERC Board of Trustees; or • Where the Standards Committee determines that a modification to a proposed Reliability Standard

or its Requirement(s), a modification to a defined term, a modification to an interpretation, or a modification to a variance has already been vetted by the industry through the standards development process or is so insubstantial that developing the modification through the processes contained in this manual will add significant time delay.

In no circumstances shall this provision be used to modify the requirements for achieving quorum or the voting requirements for approval of a standard. A waiver request may be submitted to the Standards Committee by any entity or individual, including NERC committees or subgroups and NERC Staff. Prior to consideration of any waiver request, the Standards Committee must provide five business days notice to stakeholders. Action on the waiver request will be included in the minutes of the Standards Committee. Following the approval of the Standards Committee to waive any provision of the Standard Process Manual, the Standards Committee will report this decision to the Standards Oversight and Technology Committee.32 Actions taken pursuant to an approved waiver request will be posted on the Standard Project page and included in the next project announcement. In addition, the Standards Committee shall report the exercise of this waiver provision to the Board of Trustees prior to adoption of the related Reliability Standard, Interpretation, definition or Variance. Reliability Standards developed as a result of a waiver of any provision of the Standard Processes Manual shall not be filed with ANSI for approval as American National Standards.

32 Any entity may appeal a waiver decision or any other procedural decision by the Standards Committee pursuant to Section 8.0 of the NERC Standard Processes Manual.

Agenda Item 14b Standards Committee September 14, 2016

Standard Processes Manual

VERSION 3TBD

Effective: June 26, 2013TBD

Introduction

Standard Processes Manual VERSION 3.0: Effective: June 26, 2013 2

Table of Contents Section 1.0: Introduction ................................................................................................................ 3

Section 2.0: Elements of a Reliability Standard ............................................................................ 6

Section 3.0: Reliability Standards Program Organization ........................................................... 10

Section 4.0: Process for Developing, Modifying, Withdrawing or Retiring a Reliability Standard....................................................................................................................................................... 14

Section 5.0: Process for Developing a Defined Term.................................................................. 26

Section 6.0: Processes for Conducting Field Tests and Collecting and Analyzing Data ............ 28

Section 7.0: Process for Developing an Interpretation ................................................................ 32

Section 8.0: Process for Appealing an Action or Inaction ........................................................... 36

Section 9.0: Process for Developing a Variance .......................................................................... 38

Section 10.0: Processes for Developing a Reliability Standard Related to a Confidential Issue 40

Section 11.0: Process for Approving Supporting Documents ..................................................... 47

Section 12.0: Process for Correcting Errata ................................................................................. 48

Section 13.0: Process for Conducting Periodic Reviews of Reliability Standards ...................... 49

Section 14.0: Public Access to Reliability Standards Information .............................................. 50

Section 15.0: Process for Updating Standard Processes .............................................................. 51

Section 16.0: Waiver .................................................................................................................... 52

Introduction


Section 1.0: Introduction

1.1: Authority This manual is published by the authority of the NERC Board of Trustees. The Board of Trustees, as necessary to maintain NERC’s certification as the Electric Reliability Organization (“ERO”), may file the manual with Applicable Governmental Authorities for approval as an ERO document. When approved, the manual is appended to and provides implementation detail in support of the ERO Rules of Procedure Section 300 — Reliability Standards Development. Capitalized terms not otherwise defined herein, shall have the meaning set forth in the Definitions Used in the Rules of Procedure, Appendix 2 to the Rules of Procedure. 1.2: Scope The policies and procedures in this manual shall govern the activities of the North American Electric Reliability Corporation (“NERC”) related to the development, approval, revision, reaffirmation, and withdrawal of Reliability Standards, Interpretations, Violation Risk Factors (“VRFs”), Violation Severity Levels (“VSLs”), definitions, Variances, and reference documents developed to support standards for the Reliable Operation and planning of the North American Bulk Power Systems. This manual also addresses the role of the Standards Committee, drafting team and ballot body in the development and approval of Compliance Elements in conjunction with standard development. 1.3: Background NERC is a nonprofit corporation formed for the purpose of becoming the North American ERO. NERC works with all stakeholder segments of the electric industry, including electricity users, to develop Reliability Standards for the reliability planning and Reliable Operation of the North American Bulk Power Systems. In the United States, the Energy Policy Act of 2005 added Section 215 to the Federal Power Act for the purpose of establishing a framework to make Reliability Standards mandatory for all Bulk Power System owners, operators, and users. Similar authorities are provided by Applicable Governmental Authorities in Canada. NERC was certified as the ERO effective July 2006. North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g and compliance, 117 FERC ¶ 61,126 (2006), order on compliance, 118 FERC ¶ 61,030 (2007). 1.4: Essential Attributes of NERC’s Reliability Standards Processes NERC’s Reliability Standards development processes provide reasonable notice and opportunity for public comment, due process, openness, and balance of interests in developing a proposed Reliability Standard consistent with the attributes necessary for American National Standards Institute (“ANSI”) accreditation. The same attributes, as well as transparency, consensus-building, and timeliness, are also required under the ERO Rules of Procedure Section 304.

• Open Participation Participation in NERC’s Reliability Standards development balloting and approval processes shall be open to all entities materially affected by NERC’s Reliability Standards. There shall be no financial barriers to participation in NERC’s Reliability Standards balloting and approval processes. Membership in the Registered Ballot Body shall not be conditional upon membership in any organization, nor unreasonably restricted on the basis of technical qualifications or other such requirements.

Introduction


• Balance NERC’s Reliability Standards development processes shall not be dominated by any two interest categories, individuals, or organizations and no single interest category, individual, or organization is able to defeat a matter.

NERC shall use a voting formula that allocates each industry Segment an equal weight in determining the final outcome of any Reliability Standard action. The Reliability Standards development processes shall have a balance of interests. Participants from diverse interest categories shall be encouraged to join the Registered Ballot Body and participate in the balloting process, with a goal of achieving balance between the interest categories. The Registered Ballot Body serves as the consensus body voting to approve each new or proposed Reliability Standard, definition, Variance, and Interpretation.

• Coordination and harmonization with other American National Standards activities

NERC is committed to resolving any potential conflicts between its Reliability Standards development efforts and existing American National Standards and candidate American National Standards.

• Notification of standards development

NERC shall publicly distribute a notice to each member of the Registered Ballot Body, and to each stakeholder who indicates a desire to receive such notices, for each action to create, revise, reaffirm, or withdraw a Reliability Standard, definition, or Variance; and for each proposed Interpretation. Notices shall be distributed electronically, with links to the relevant information, and notices shall be posted on NERC’s Reliability Standards web page. All notices shall identify a readily available source for further information.

• Transparency

The process shall be transparent to the public.

• Consideration of views and objections Drafting teams shall give prompt consideration to the written views and objections of all participants as set forth herein. Drafting teams shall make an effort to resolve each objection that is related to the topic under review.

• Consensus Building

The process shall build and document consensus for each Reliability Standard, both with regard to the need and justification for the Reliability Standard and the content of the Reliability Standard.

• Consensus vote

NERC shall use its voting process to determine if there is sufficient consensus to approve a proposed Reliability Standard, definition, Variance, or Interpretation. NERC shall form a ballot pool for each Reliability Standard action from interested members of its Registered Ballot Body. Approval of any Reliability Standard action requires:

• A quorum, which is established by at least 75% of the members of the ballot pool submitting a response excluding unreturned ballots; and

• A two-thirds majority of the weighted Segment votes cast shall be affirmative. The number of votes cast during all stages of balloting except the final ballot is the sum of affirmative and negative votes with comments, excluding abstentions, non-responses, and negative votes without comments. During the final ballot, the number of votes cast is the sum of affirmative and negative votes, excluding abstentions and non-responses.

Introduction


• Timeliness

Development of Reliability Standards shall be timely and responsive to new and changing priorities for reliability of the Bulk Power System.

• Metric Policy

The International System of units is the preferred units of measurement in NERC Reliability Standard. However, because NERC’s Reliability Standards apply in Canada, the United States and portions of Mexico, where applicable, measures are provided in both the metric and English units.

1.5: Ethical Participation All participants in the NERC Standard development process, including drafting teams, quality reviewers, Standards Committee members and members of the Registered Ballot Body, are obligated to act in an ethical manner in the exercise of all activities conducted pursuant to the terms and conditions of the Standard Processes Manual and the standard development process.



Section 2.0: Elements of a Reliability Standard 2.1: Definition of a Reliability Standard A Reliability Standard includes a set of Requirements that define specific obligations of owners, operators, and users of the North American Bulk Power Systems. The Requirements shall be material to reliability and measurable. A Reliability Standard is defined as follows:

“Reliability Standard” means a requirement to provide for Reliable Operation of the Bulk Power System, including without limiting the foregoing, requirements for the operation of existing Bulk Power System Facilities, including cyber security protection, and including the design of planned additions or modifications to such Facilities to the extent necessary for Reliable Operation of the Bulk Power System, but the term does not include any requirement to enlarge Bulk Power System Facilities or to construct new transmission capacity or generation capacity. A Reliability Standard shall not be effective in the United States until approved by the Federal Energy Regulatory Commission and shall not be effective in other jurisdictions until made or allowed to become effective by the Applicable Governmental Authority. See Appendix 2 to the NERC Rules of Procedure, Definitions Used in the Rules of Procedure. “Reliability Standard” means a requirement, approved by the United States Federal Energy Regulatory Commission under Section 215 of the Federal Power Act, or approved or recognized by an applicable governmental authority in other jurisdictions, to provide for Reliable Operation of the Bulk Power System. The term includes requirements for the operation of existing Bulk Power System facilities, including cybersecurity protection, and the design of planned additions or modifications to such facilities to the extent necessary to provide for Reliable Operation of the Bulk Power System, but the term does not include any requirement to enlarge such facilities or to construct new transmission capacity or generation capacity. (In certain contexts, this term may also refer to a “Reliability Standard” that is in the process of being developed, or not yet approved or recognized by FERC or an applicable governmental authority in other jurisdictions). See Appendix 2 to the NERC Rules of Procedure, Definitions Used in the Rules of Procedure.

2.2: Reliability Principles NERC Reliability Standards are based on certain reliability principles that define the foundation of reliability for North American Bulk Power Systems.1 Each Reliability Standard shall enable or support one or more of the reliability principles, thereby ensuring that each Reliability Standard serves a purpose in support of reliability of the North American Bulk Power Systems. Each Reliability Standard shall also be consistent with all of the reliability principles, thereby ensuring that no Reliability Standard undermines reliability through an unintended consequence. 2.3: Market Principles Recognizing that Bulk Power System reliability and electricity markets are inseparable and mutually interdependent, all Reliability Standards shall be consistent with the market interface principles.2 Consideration of the market interface principles is intended to ensure that Reliability Standards are written

1 The intent of the set of NERC Reliability Standards is to deliver an adequate level of reliability. The latest set of reliability principles and the latest set of characteristics associated with an adequate level of reliability are posted on the Reliability Standards Resources web page.

2 The latest set of market interface principles is posted on the Reliability Standards Resources web page.



such that they achieve their reliability objective without causing undue restrictions or adverse impacts on competitive electricity markets. 2.4: Types of Reliability Requirements Generally, each Requirement of a Reliability Standard shall identify what Functional Entities shall do, and under what conditions, to achieve a specific reliability objective. Although Reliability Standards all follow this format, several types of Requirements may exist, each with a different approach to measurement.

• Performance-based Requirements define a specific reliability objective or outcome achieved by one or more entities that has a direct, observable effect on the reliability of the Bulk Power System, i.e. an effect that can be measured using power system data or trends. In its simplest form, a performance-based requirement has four components: who, under what conditions (if any), shall perform what action, to achieve what particular result or outcome.

• Risk-based Requirements define actions by one or more entities that reduce a stated risk to the reliability of the Bulk Power System and can be measured by evaluating a particular product or outcome resulting from the required actions. A risk-based reliability requirement should be framed as: who, under what conditions (if any), shall perform what action, to achieve what particular result or outcome that reduces a stated risk to the reliability of the Bulk Power System.

• Capability-based Requirements define capabilities needed by one or more entities to perform reliability functions and can be measured by demonstrating that the capability exists as required. A capability-based reliability requirement should be framed as: who, under what conditions (if any), shall have what capability, to achieve what particular result or outcome to perform an action to achieve a result or outcome or to reduce a risk to the reliability of the Bulk Power System.

The body of reliability Requirements collectively provides a defense-in-depth strategy supporting reliability of the Bulk Power System. 2.5: Elements of a Reliability Standard A Reliability Standard includes several components designed to work collectively to identify what entities must do to meet their reliability-related obligations as an owner, operator or user of the Bulk Power System. The components of a Reliability Standard may include the following:

Title: A brief, descriptive phrase identifying the topic of the Reliability Standard.

Number: A unique identification number assigned in accordance with a published classification system to facilitate tracking and reference to the Reliability Standards.3

Purpose: The reliability outcome achieved through compliance with the Requirements of the Reliability Standard.

Applicability: Identifies which entities are assigned reliability requirements. The specific Functional Entities and Facilities to which the Reliability Standard applies.

3 Reliability Standards shall be numbered in accordance with the NERC Standards Numbering Convention as provide on the Reliability Standards Resources web page.



Effective Dates: Identification of the date or pre-conditions determining when each Requirement becomes effective in each jurisdiction.

Requirement: An explicit statement that identifies the Functional Entity responsible, the action or outcome that must be achieved, any conditions achieving the action or outcome, and the reliability-related benefit of the action or outcome. Each Requirement shall be a statement for which compliance is mandatory.

Compliance Elements: Elements to aid in the administration of ERO compliance monitoring and enforcement responsibilities.4

• Measure: Provides identification of the evidence or types of evidence that may demonstrate

compliance with the associated requirement.

• Violation Risk Factors and Violation Severity Levels: Violation risk factors (VRFs) and violation severity levels (VSLs) are used as factors when determining the size of a penalty or sanction associated with the violation of a requirement in an approved reliability standard.5 Each requirement in each reliability standard has an associated VRF and a set of VSLs. VRFs and VSLs are developed by the drafting team, working with NERC Staff, at the same time as the associated reliability standard, but are not part of the reliability standard. The Board of Trustees is responsible for approving VRFs and VSLs. • Violation Risk Factors

VRFs identify the potential reliability significance of noncompliance with each requirement. Each requirement is assigned a VRF in accordance with the latest approved set of VRF criteria.6

• Violation Severity Levels

VSLs define the degree to which compliance with a requirement was not achieved. Each requirement shall have at least one VSL. While it is preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and may have only one, two, or three VSLs. Each requirement is assigned one or more VSLs in accordance with the latest approved set of VSL criteria.7

Version History: The version history is provided for informational purposes and lists information regarding prior versions of Reliability Standards.

Variance: A Requirement (to be applied in the place of the continent-wide Requirement) that is applicable to a specific geographic area or to a specific set of Registered Entities.

Compliance Enforcement Authority: The entity that is responsible for assessing performance or outcomes to determine if an entity is compliant with the associated Reliability Standard. The Compliance Enforcement Authority will be NERC or the Regional Entity in their respective roles of monitoring and enforcing compliance with the NERC Reliability Standards.

4 It is the responsibility of the ERO staff to develop compliance tools for each standard; these tools are not part of the standard but are referenced in this manual because the preferred approach to developing these tools is to use a transparent process that leverages the technical and practical expertise of the drafting team and ballot pool.. 5 The Sanction Guidelines of the North American Electric Reliability Corporation identifies the factors used to determine a penalty or sanction for violation of reliability standard and is posted on the NERC Web Site. 6 The latest set of approved VRF Criteria is posted on the Reliability Standards Resources Web Page. 7 The latest set of approved VSL Criteria is posted on the Reliability Standards Resources Web Page.



Application guidelines: Guidelines to support the implementation of the associated Reliability Standard. Procedures: Procedures to support implementation of the associated Reliability Standard.

The only mandatory and enforceable components of a Reliability Standard are the: (1) applicability, (2) Requirements, and the (3) effective dates. The additional components are included in the Reliability Standard for informational purposes, to establish the relevant scope and technical paradigm, and to provide guidance to Functional Entities concerning how compliance will be assessed by the Compliance Enforcement Authority.



Section 3.0: Reliability Standards Program Organization 3.1: Board of Trustees The NERC Board of Trustees shall consider for adoption Reliability Standards, definitions, Variances and Interpretations and associated implementation plans that have been processed according to the processes identified in this manual. Once the Board adopts a Reliability Standard, definition, Variance or Interpretation, the Board shall direct NERC Staff to file the document(s) for approval with Applicable Governmental Authorities. 3.2: Registered Ballot Body The Registered Ballot Body comprises all entities or individuals that qualify for one of the Segments approved by the Board of Trustees8, and are registered with NERC as potential ballot participants in the voting on Reliability Standards. Each member of the Registered Ballot Body is eligible to join the ballot pool for each Reliability Standard action. 3.3: Ballot Pool Each Reliability Standard action has its own ballot pool formed of interested members of the Registered Ballot Body. The ballot pool comprises those members of the Registered Ballot Body that respond to a pre-ballot request to participate in that particular Reliability Standard action. The ballot pool votes on each Reliability Standards action. The ballot pool remains in place until all balloting related to that Reliability Standard action has been completed. 3.4: Standards Committee The Standards Committee serves at the pleasure and direction of the NERC Board of Trustees, and the Board approves the Standards Committee’s Charter.9 Standards Committee members are elected by their respective Segment’s stakeholders. The Standards Committee consists of two members of each of the Segments in the Registered Ballot Body.10 A member of the NERC Reliability Standards Staff shall serve as the non-voting secretary to the Standards Committee. The Standards Committee is responsible for managing the Reliability Standards processes for development of Reliability Standards, definitions, Variances and Interpretations in accordance with this manual. The responsibilities of the Standards Committee are defined in detail in the Standards Committee’s Charter. The Standards Committee is responsible for ensuring that the Reliability Standards, definitions, Variances and Interpretations developed by drafting teams are developed in accordance with the processes in this manual and meet NERC’s benchmarks for Reliability Standards as well as criteria for governmental approval.11 The Standards Committee has the right to remand work to a drafting team, to reject the work of a drafting team, or to accept the work of a drafting team. The Standards Committee may disband a drafting team if it determines (a) that the drafting team is not producing a standard in a timely manner; (b) the drafting team 8 The industry Segment qualifications are described in the Development of the Registered Ballot Body and Segment Qualification Guidelines document posted on the Reliability Standards Resources web page and are included in Appendix 3D of the NERC Rules of Procedure. 9 The Standards Committee Charter is posted on the Reliability Standards Resources web page. 10 In addition to balanced Segment representation, the Standards Committee shall also have representation that is balanced among countries based on Net Energy for Load (“NEL”). As needed, the Board of Trustees may approve special procedures for the balancing of representation among countries represented within NERC. 11 The Ten Benchmarks of an Excellent Reliability Standard and FERC’s Criteria for Approving Reliability Standards are posted on the Reliability Standards Resources web page.



is not able to produce a standard that will achieve industry consensus; (c) the drafting team has not addressed the scope of the SAR; or (d) the drafting team has failed to fully address a regulatory directive or otherwise provided a responsive or equally efficient and effective alternative. The Standards Committee may direct a drafting team to revise its work to follow the processes in this manual or to meet the criteria for NERC’s benchmarks for Reliability Standards, or to meet the criteria for governmental approval; however, the Standards Committee shall not direct a drafting team to change the technical content of a draft Reliability Standard. The Standards Committee shall meet at regularly scheduled intervals (either in person, or by other means). All Standards Committee meetings are open to all interested parties. 3.5: NERC Reliability Standards Staff The NERC Reliability Standards Staff, led by the Director of Standards, is responsible for administering NERC’s Reliability Standards processes in accordance with this manual. The NERC Reliability Standards Staff provides support to the Standards Committee in managing the Reliability Standards processes and in supporting the work of all drafting teams. The NERC Reliability Standards Staff works to ensure the integrity of the Reliability Standards processes and consistency of quality and completeness of the Reliability Standards. The NERC Reliability Standards Staff facilitates all steps in the development of Reliability Standards, definitions, Variances, Interpretations and associated implementation plans. The NERC Reliability Standards Staff is responsible for presenting Reliability Standards, definitions, Variances, and Interpretations to the NERC Board of Trustees for adoption. When presenting Reliability Standards-related documents to the NERC Board of Trustees for adoption or approval, the NERC Reliability Standards Staff shall report the results of the associated stakeholder ballot, including identification of unresolved stakeholder objections and an assessment of the document’s practicality and enforceability. 3.6: Drafting Teams The Standards Committee shall appoint industry experts to drafting teams to work with stakeholders in developing and refining Standard Authorization Requests (“SARs”), Reliability Standards, definitions, and Variances. The NERC Reliability Standards Staff shall appoint drafting teams that develop Interpretations. The NERC Reliability Standards Staff shall provide, or solicit from the industry, essential support for each of the drafting teams in the form of technical writers, legal, compliance, and rigorous and highly trained project management and facilitation support personnel. Each drafting team may consist of a group of technical, legal, and compliance experts that work cooperatively with the support of the NERC Reliability Standards Staff.12 The technical experts provide the subject matter expertise and guide the development of the technical aspects of the Reliability Standard, assisted by technical writers, legal and compliance experts. The technical experts maintain authority over the technical details of the Reliability Standard. Each drafting team appointed to develop a Reliability Standard is responsible for following the processes identified in this manual as well as procedures developed by the Standards Committee from the inception of the assigned project through the final acceptance of that project by Applicable Governmental Authorities. Collectively, each drafting team:

• Drafts proposed language for the Reliability Standards, definitions, Variances, and/or Interpretations and associated implementation plans.

12 The detailed responsibilities of drafting teams are outlined in the Drafting Team Guidelines, which is posted on the Reliability Standards Resources web page.



• Develops and refines technical documents that aid in the understanding of Reliability Standards.

• Works collaboratively with NERC Compliance Monitoring and Enforcement Staff to develop Reliability Standard Audit Worksheets (“RSAWs”) at the same time Reliability Standards are developed.

• Provides assistance to NERC Staff in the development of Compliance Elements of proposed Reliability Standards.

• Solicits, considers, and responds to comments related to the specific Reliability Standards development project.

• Participates in industry forums to help build consensus on the draft Reliability Standards, definitions, Variances, and/or Interpretations and associated implementation plans.

• Assists in developing the documentation used to obtain governmental approval of the Reliability Standards, definitions, Variances, and/or Interpretations and associated implementation plans.

All drafting teams report to the Standards Committee. 3.7: Governmental Authorities The Federal Energy Regulatory Commission (“FERC”) in the United States of America, and where permissible by statute or regulation, the provincial government of each of the eight Canadian Provinces (Manitoba, Nova Scotia, Saskatchewan, Alberta, Ontario, British Columbia, New Brunswick and Quebec) and the National Energy Board of Canada have the authority to approve each new, revised or withdrawn Reliability Standard, definition, Variance, VRF, VSL and Interpretation following adoption or approval by the NERC Board of Trustees. 3.8: Committees, Subcommittees, Working Groups, and Task Forces NERC’s technical committees, subcommittees, working groups, and task forces provide technical research and analysis used to justify the development of new Reliability Standards and provide guidance, when requested by the Standards Committee, in overseeing field tests or collection and analysis of data. The technical committees, subcommittees, working groups, and task forces provide feedback to drafting teams during both informal and formal comment periods. The Standards Committee may request that a NERC technical committee or other group prepare a Technical document to support development of a proposed Reliability Standard. The technical committees, subcommittees, working groups, and task forces share their observations regarding the need for new or modified Reliability Standards or Requirements with the NERC Reliability Standards Staff for use in identifying the need for new Reliability Standards projects for the three-year Reliability Standards Development Plan. 3.9: Compliance and Certification Committee The Compliance and Certification Committee is responsible for monitoring NERC’s compliance with its Reliability Standards processes and procedures and for monitoring NERC’s compliance with the Rules of Procedure regarding the development of new or revised Reliability Standards, definitions, Variances, and Interpretations. The Compliance and Certification Committee may assist in verifying that each proposed Reliability Standard is enforceable as written before the Reliability Standard is posted for formal stakeholder comment and balloting.



3.10: Compliance Monitoring and Enforcement Program As applicable, the NERC Compliance Monitoring and Enforcement Program Staff manages and enforces compliance with approved Reliability Standards. Compliance Monitoring and Enforcement Staff are responsible for the development of select compliance tools. The drafting team and the Compliance Monitoring and Enforcement Program Staff shall work together during the Reliability Standard development process to ensure an accurate and consistent understanding of the Requirements and their intent, and to ensure that applicable compliance tools accurately reflect that intent. The goal of this collaboration is to ensure that application of the Reliability Standards in the Compliance Monitoring and Enforcement Program by NERC and the Regional Entities is consistent. The Compliance Monitoring and Enforcement Program is encouraged to share its observations regarding the need for new or modified Requirements with the NERC Reliability Standards Staff for use in identifying the need for new Reliability Standards projects. 3.11: North American Energy Standards Board (“NAESB”) While NERC has responsibility for developing Reliability Standards to support reliability, NAESB has responsibility for developing business practices and coordination between reliability and business practices as needed. NERC and NAESB developed and approved a procedure13 to guide the development of Reliability Standards and business practices where the reliability and business practice components are intricately entwined within a proposed Reliability Standard.

13 The NERC NAESB Template Procedure for Joint Standards Development and Coordination is posted on the Reliability Standards Resources web page.



Section 4.0: Process for Developing, Modifying, Withdrawing or Retiring a Reliability Standard There are several steps to the development, modification, withdrawal or retirement of a Reliability Standard.14

The development of the Reliability Standards Development Plan is the appropriate forum for reaching agreement on whether there is a need for a Reliability Standard and the scope of a proposed Reliability Standard. A typical process for a project identified in the Reliability Standards Development Plan that involves a revision to an existing Reliability Standard is shown below. Note that most projects do not include a field test.

14 The process described is also applicable to projects used to propose a new or modified definition or Variance or to propose retirement of a definition or Variance.



FIGURE 1: Process for Developing or Modifying a Reliability Standard


STEP 8: Submit Reliability Standard and Implementation Plan to BOT for Adoption and Approval


10 day Period


If significant changes are needed to the Draft Reliability Standard then conduct Additional Ballot (Repeat Step 5)


Form Ballot Pool During First 30 calendar days of 45-day Comment Period

Conduct Ballot During Last 10 Days of Comment Period Conduct Non-Binding Poll of VRFs and VSLs


STEP 3: Develop Draft of Standard, Implementation Plan and VRFs and VSLs

Form Drafting Team If needed, conduct Field Test of Requirements Conduct Quality Review Collect Informal Feedback


STEP 1: Project Identified in Reliability Standards Development Plan or initiated by the Standards Committee

Draft SAR



4.1: Posting and Collecting Information on SARs

Standard Authorization Request A Standard Authorization Request (“SAR”) is the form used to document the scope and reliability benefit of a proposed project for one or more new or modified Reliability Standards or definitions or the benefit of retiring one or more approved Reliability Standards. Any entity or individual, including NERC committees or subgroups and NERC Staff, may propose the development of a new or modified Reliability Standard, or may propose the retirement of a Reliability Standard (in whole or in part), by submitting a completed SAR15 to the NERC Reliability Standards Staff. The Standards Committee has the authority to approve the posting of all SARs for projects that propose (i) developing a new or modified Reliability Standard or definition or (ii) propose retirement of an existing Reliability Standard (or elements thereof). The NERC Reliability Standards Staff sponsors an open solicitation period each year seeking ideas for new Reliability Standards projects (using Reliability Standards Suggestions and Comments forms). The open solicitation period is held in conjunction with the annual revision to the Reliability Standards Development Plan. While the Standards Committee prefers that ideas for new projects be submitted during this annual solicitation period through submittal of a Reliability Standards Suggestions and Comments Form,16 a SAR proposing a specific project may be submitted to the NERC Reliability Standards Staff at any time. Each SAR that proposes a “new” or substantially revised Reliability Standard or definition should be accompanied by a technical justification that includes, as a minimum, a discussion of the reliability-related benefits and costs of developing the new Reliability Standard or definition, and a technical foundation document (e.g., research paper) to guide the development of the Reliability Standard or definition. The technical document should address the engineering, planning and operational basis for the proposed Reliability Standard or definition, as well as any alternative approaches considered during SAR development. The NERC Reliability Standards Staff shall review each SAR and work with the submitter to verify that all required information has been provided. All properly completed SARs shall be submitted to the Standards Committee for action at the next regularly scheduled Standards Committee meeting. When presented with a SAR, the Standards Committee shall determine if the SAR is sufficiently complete to guide Reliability Standard development and whether the SAR is consistent with this manual. The Standards Committee shall take one of the following actions:

• Accept the SAR. • Remand the SAR back to the requestor or to NERC Reliability Standards Staff for

additional work. • Reject the SAR. The Standards Committee may reject a SAR for good cause. If the

Standards Committee rejects a SAR, it shall provide a written explanation for rejection to the sponsor within ten days of the rejection decision.

• Delay action on the SAR pending one of the following: (i) development of a technical justification for the proposed project; or (ii) consultation with another NERC Committee to determine if there is another approach to addressing the issue raised in the SAR.

If the Standards Committee is presented with a SAR that proposes developing a new Reliability Standard or definition but does not have a technical justification upon which the Reliability Standard or definition can be developed, the Standards Committee shall direct the NERC Reliability Standards Staff to post the

15 The SAR form can be downloaded from the Reliability Standards Resources web page. 16 The Reliability Standards Suggestions and Comments Form can be downloaded from the Reliability Standards Resources web page.



SAR for a 30-day comment period solely to collect stakeholder feedback on the scope of technical foundation, if any, needed to support the proposed project. If a technical foundation is determined to be necessary, the Standards Committee shall solicit assistance from NERC’s technical committees or other industry experts to provide that foundation before authorizing development of the associated Reliability Standard or definition. During the SAR comment process, the drafting team may become aware of potential regional Variances related to the proposed Reliability Standard. To the extent possible, any regional Variances or exceptions should be made a part of the SAR so that if the SAR is authorized, such variations shall be made a part of the draft new or revised Reliability Standard. If the Standards Committee accepts a SAR, the project shall be added to the list of approved projects. The Standards Committee shall assign a priority to the project, relative to all other projects under development, and those projects already identified in the Reliability Standards Development Plan that are already approved for development. The Standards Committee shall work with the NERC Reliability Standards Staff to coordinate the posting of SARs for new projects, giving consideration to each project’s priority. 4.2: SAR Posting When the Standards Committee determines it is ready to initiate a new project, the Standards Committee shall direct NERC Staff to post the project’s SAR in accordance with the following:

• For SARs that are limited to addressing regulatory directives, or revisions to Reliability Standards that have had some vetting in the industry, authorize posting the SAR for a 30-day informal comment period with no requirement to provide a formal response to the comments received.

• For SARs that address the development of new projects or Reliability Standards, authorize posting the SAR for a 30-day formal comment period.

If a SAR for a new Reliability Standard is posted for a formal comment period, the Standards Committee shall appoint a drafting team to work with the NERC Staff coordinator to give prompt consideration of the written views and objections of all participants. The Standards Committee may use a public nomination process to populate the Reliability Standard drafting team, or may use another method that results in a team that collectively has the necessary technical expertise and work process skills to meet the objectives of the project. In some situations, an ad hoc team may already be in place with the requisite expertise, competencies, and diversity of views that are necessary to refine the SAR and develop the Reliability Standard, and additional members may not be needed. The drafting team shall address all comments submitted, which may be in the form of a summary response addressing each of the issues raised in comments received, during the public posting period. An effort to resolve all expressed objections shall be made, and each objector shall be advised of the disposition of the objection and the reasons therefore. If the drafting team concludes that there is not sufficient stakeholder support to continue to refine the SAR, the team may recommend that the Standards Committee direct curtailment of work on the SAR. While there is no established limit on the number of times a SAR may be posted for comment, the Standards Committee retains the right to reverse its prior decision and reject a SAR if it believes continued revisions are not productive. The Standards Committee shall notify the sponsor in writing of the rejection within 10 calendar days. If stakeholders indicate support for the project proposed with the SAR, the drafting team shall present its work to the Standards Committee with a request that the Standards Committee authorize development of the associated Reliability Standard.



The Standards Committee, once again considering the public comments received and their resolution, may then take one of the following actions:

• Authorize drafting the proposed Reliability Standard or revisions to a Reliability Standard.

• Reject the SAR with a written explanation to the sponsor and post that explanation. 4.3: Form Drafting Team When the Standards Committee is ready to have a drafting team begin work on developing a new or revised Reliability Standard, the Standards Committee shall appoint a drafting team, if one was not already appointed to develop the SAR. If the Standards Committee appointed a drafting team to refine the SAR, the same drafting team shall work to develop the associated Reliability Standard. If no drafting team is in place, then the Standards Committee may use a public nomination process to populate the Reliability Standard drafting team, or may use another method that results in a team that collectively has the necessary technical expertise, diversity of views and work process skills to accomplish the objectives of the project on a timely basis. In some situations, an ad hoc team may already be in place with the requisite expertise, competencies, and diversity of views that are necessary to develop the Reliability Standard, and additional members may not be needed. The NERC Reliability Standards Staff shall provide one or more members as needed to support the team with facilitation, project management, compliance, legal, regulatory and technical writing expertise and shall provide administrative support to the team, guiding the team through the steps in completing its project. In developing the Reliability Standard, the individuals provided by the NERC Reliability Standards Staff serve as advisors to the drafting team and do not have voting rights but share accountability along with the drafting team members assigned by the Standards Committee for timely delivery of a final draft Reliability Standard that meets the quality attributes identified in NERC’s Benchmarks for Excellent Standards. The drafting team members assigned by the Standards Committee shall have final authority over the technical details of the Reliability Standard, while the technical writer shall provide assistance to the drafting team in assuring that the final draft of the Reliability Standard meets the quality attributes identified in NERC’s Benchmarks for Excellent Standards. Once it is appointed by the Standards Committee, the Reliability Standard drafting team is responsible for making recommendations to the Standards Committee regarding the remaining steps in the Reliability Standards process. Consistent with the need to provide for timely standards development, the Standards Committee may decide a project is so large that it should be subdivided and either assigned to more than one drafting team or assigned to a single drafting team with clear direction on completing the project in specified phases. The normally expected timeframes for standards development within the context of this manual are applicable to individual standards and not to projects containing multiple standards. Alternatively, a single drafting team may address the entire project with a commensurate increase in the expected duration of the development work. If a SAR is subdivided and assigned to more than one drafting team, each drafting team will have a clearly defined portion of the work such that there are no overlaps and no gaps in the work to be accomplished.

The Standards Committee may supplement the membership of a Reliability Standard drafting team or provide for additional advisors, as appropriate, to ensure the necessary competencies and diversity of views are maintained throughout the Reliability Standard development effort. 4.4: Develop Preliminary Draft of Reliability Standard, Implementation Plan and VRFs and VSLs

4.4.1: Project Schedule



When a drafting team begins its work, either in refining a SAR or in developing or revising a proposed Reliability Standard, the drafting team shall develop a project schedule which shall be approved by the Standards Committee. The drafting team shall report progress to the Standards Committee, against the initial project schedule and any revised schedule as requested by the Standards Committee. Where project milestones cannot be completed on a timely basis, modifications to the project schedule must be presented to the Standards Committee for consideration along with proposed steps to minimize unplanned project delays. 4.4.2: Draft Reliability Standard The team shall develop a Reliability Standard that is within the scope of the associated SAR that includes all required elements as described earlier in this manual with a goal of meeting the quality attributes identified in NERC’s Benchmarks for Excellent Standards and criteria for governmental approval. The team shall document its justification for the Requirements in its proposed Reliability Standard by explaining how each meets these criteria. The standard drafting team shall document its justification for selecting each reference by explaining how each Requirement fits the category chosen. 4.4.3: Implementation Plan As a drafting team drafts its proposed revisions to a Reliability Standard, that team is also required to develop an implementation plan to identify any factors for consideration when approving the proposed effective date or dates for the associated Reliability Standard or Standards. As a minimum, the implementation plan shall include the following:

• The proposed effective date (the date entities shall be compliant) for the Requirements.

• Identification of any new or modified definitions that are proposed for approval with the associated Reliability Standard.

• Whether there are any prerequisite actions that need to be accomplished before entities are held responsible for compliance with one or more of the Requirements.

• Whether approval of the proposed Reliability Standard will necessitate any conforming changes to any already approved Reliability Standards – and identification of those Reliability Standards and Requirements.

• The Functional Entities that will be required to comply with one or more Requirements in the proposed Reliability Standard.

A single implementation plan may be used for more than one Reliability Standard. The implementation plan is posted with the associated Reliability Standard or Standards during the 45 (calendar) day formal comment period and is balloted with the associated Reliability Standard. 4.4.4: Violation Risk Factors and Violation Severity Levels The drafting team shall work with NERC Staff in developing a set of VRFs and VSLs that meet the latest criteria established by NERC and Applicable Governmental Authorities. The drafting team shall document its justification for selecting each VRF and for setting each set of proposed VSLs by explaining how its proposed VRFs and VSLs meet these criteria. NERC Staff is responsible for ensuring that the VRFs and VSLs proposed for stakeholder review meet these criteria. Before the drafting team has finalized its Reliability Standard, implementation plan, and VRFs and VSLs, the team should seek stakeholder feedback on its preliminary draft documents.



4.5: Informal Feedback17 Drafting teams may use a variety of methods to collect informal stakeholder feedback on preliminary drafts of its documents, including the use of informal comment periods,18 webinars, industry meetings, workshops, or other mechanisms. Information gathered from informal comment forms shall be publicly posted. While drafting teams are not required to provide a written response to each individual comment received, drafting teams are encouraged, where possible, to post a summary response that identifies how it used comments submitted by stakeholders. Drafting teams are encouraged, where possible, to reach out directly to individual stakeholders in order to facilitate resolution of identified stakeholder concerns. The intent is to gather stakeholder feedback on a “working document” before the document reaches the point where it is considered the “final draft.” 4.6: Conduct Quality Review The NERC Reliability Standards Staff shall coordinate a quality review of the Reliability Standard, implementation plan, and VRFs and VSLs in parallel with the development of the Reliability Standard and implementation plan, to assess whether the documents are within the scope of the associated SAR, whether the Reliability Standard is clear and enforceable as written, and whether the Reliability Standard meets the criteria specified in NERC’s Benchmarks for Excellent Standards and criteria for governmental approval of Reliability Standards. The drafting team shall consider the results of the quality review, decide upon appropriate changes, and recommend to the Standards Committee whether the documents are ready for formal posting and balloting. The Standards Committee shall authorize posting the proposed Reliability Standard, and implementation plan for a formal comment period and ballot and the VRFs and VSLs for a non-binding poll as soon as the work flow will accommodate. If the Standards Committee finds that any of the documents do not meet the specified criteria, the Standards Committee shall remand the documents to the drafting team for additional work. If the Reliability Standard is outside the scope of the associated SAR, the drafting team shall be directed to either revise the Reliability Standard so that it is within the approved scope, or submit a request to expand the scope of the approved SAR. If the Reliability Standard is not clear and enforceable as written, or if the Reliability Standard does not meet the specified criteria, the Reliability Standard shall be returned to the drafting team by the Standards Committee with specific identification of any Requirement that is deemed to be unclear or unenforceable as written. 4.7: Conduct Formal Comment Period and Ballot Proposed new or modified Reliability Standards require a formal comment period where the new or modified Reliability Standard, implementation plan and associated VRFs and VSLs or the proposal to retire a Reliability Standard, implementation plan and associated VRFs and VSLs are posted. The formal comment period shall be at least 45-days long. Formation of the ballot pool and Ballot of the Reliability Standard take place during this formal 45-day comment period. The intent of the formal comment period(s) is to solicit very specific feedback on the final draft of the Reliability Standard, implementation plan and VRFs and VSLs.

17 While this discussion focuses on collecting stakeholder feedback on proposed Reliability Standards and implementation plans, the same process is used to collect stakeholder feedback on proposed new or modified Interpretations, definitions and Variances.

18 The term “informal comment period” refers to a comment period conducted outside of the ballot process and where there is no requirement for a drafting team to respond in writing to submitted comments.



Comments in written form may be submitted on a draft Reliability Standard by any interested stakeholder, including NERC Staff, FERC Staff, and other interested governmental authorities. If stakeholders disagree with some aspect of the proposed set of products, comments provided should explain the reasons for such disagreement and, where possible, suggest specific language that would make the product acceptable to the stakeholder. 4.8: Form Ballot Pool The NERC Reliability Standards Staff shall establish a ballot pool during the first 30 calendar days of the 45-day formal comment period. The NERC Reliability Standards Staff shall post the proposed Reliability Standard, along with its implementation plan, VRFs and VSLs and shall send a notice to every entity in the Registered Ballot Body to provide notice that there is a new or revised Reliability Standard proposed for approval and to solicit participants for the associated ballot pool. All members of the Registered Ballot Body are eligible to join each ballot pool to vote on a new or revised Reliability Standard and its implementation plan and to participate in the non-binding poll of the associated VRFs and VSLs. Any member of the Registered Ballot Body may join or withdraw from the ballot pool until the ballot window opens. No Registered Ballot Body member may join or withdraw from the ballot pool once the first ballot starts through the point in time where balloting for that Reliability Standard action has ended. The Director of Standards may authorize deviations from this rule for extraordinary circumstances such as the death, retirement, or disability of a ballot pool member that would prevent an entity that had a member in the ballot pool from eligibility to cast a vote during the ballot window. Any approved deviation shall be documented and noted to the Standards Committee. 4.9: Conduct Ballot and Non-binding Poll of VRFs and VSLs19 The NERC Reliability Standards Staff shall announce the opening of the Ballot window and the non-binding poll of VRFs and VSLs. The Ballot window and non-binding poll of VRFs and VSLs shall take place during the last 10 calendar days of the 45-day formal comment period and for the Final Ballot shall be no less than 10 calendar days. If the last day of the ballot window falls on a Saturday or Sunday, the period does not end until the next business day.20 The ballot and non-binding poll shall be conducted electronically. The voting window shall be for a period of 10 calendar days but shall be extended, if needed, until a quorum is achieved. During a ballot window, NERC shall not sponsor or facilitate public discussion of the Reliability Standard action under ballot. There is no requirement to conduct a new non-binding poll of the revised VRFs and VSLs if no changes were made to the associated standard, however if the requirements are modified and conforming changes are made to the associated VRFs and VSLs, another non-binding poll of the revised VRFs and VSLs shall be conducted.

19 While RSAWs are not part of the Reliability Standard, they are developed through collaboration of the SDT and NERC Compliance Staff. A non-binding poll, similar to what is done for VRFs and VSLs may be conducted for the RSAW developed through this process to gauge industry support for the companion RSAW to be provided for informational purposes to the NERC Board of Trustees.

20 Closing dates may be extended as deemed appropriate by NERC Staff.



4.10: Criteria for Ballot Pool Approval Ballot pool approval of a Reliability Standard requires:

A quorum, which is established by at least 75% of the members of the ballot pool submitting a response; and A two-thirds majority of the weighted Segment votes cast shall be affirmative. The number of votes cast is the sum of affirmative votes and negative votes with comments. This calculation of votes for the purpose of determining consensus excludes (i) abstentions, (ii) non-responses, and (iii) negative votes without comments. The following process21 is used to determine if there are sufficient affirmative votes.

• For each Segment with ten or more voters, the following process shall be used: The number of affirmative votes cast shall be divided by the sum of affirmative and negative votes with comments cast to determine the fractional affirmative vote for that Segment. Abstentions, non-responses, and negative votes without comments shall not be counted for the purposes of determining the fractional affirmative vote for a Segment.

• For each Segment with less than ten voters, the vote weight of that Segment shall be proportionally reduced. Each voter within that Segment voting affirmative or negative with comments shall receive a weight of 10% of the Segment vote.

• The sum of the fractional affirmative votes from all Segments divided by the number of Segments voting22 shall be used to determine if a two-thirds majority has been achieved. (A Segment shall be considered as “voting” if any member of the Segment in the ballot pool casts either an affirmative vote or a negative vote with comments.)

• A Reliability Standard shall be approved if the sum of fractional affirmative votes from all Segments divided by the number of voting Segments is at least two thirds.

4.11: Voting Positions Each member of the ballot pool may only vote one of the following positions on the Ballot and Additional Ballot(s):

• Affirmative; • Affirmative, with comment; • Negative with comments; • Abstain.

Given that there is no formal comment period concurrent with the Final Ballot, each member of the ballot pool may only vote one of the following positions on the Final Ballot:

• Affirmative; • Negative;23 • Abstain.

21 Examples of weighted segment voting calculation are posted on the Reliability Standards Resources web page. 22 When less than ten entities vote in a Segment, the total weight for that Segment shall be determined as one tenth per entity voting, up to ten.

23 The Final Ballot is used to confirm consensus achieved during the Formal Comment and Ballot stage. Ballot Pool members voting negative on the Final Ballot will be deemed to have expressed the reason for their negative ballot in their own comments or the comments of others during prior Formal Comment periods.



4.12: Consideration of Comments If a stakeholder or balloter proposes a significant revision to a Reliability Standard during the formal comment period or concurrent Ballot that will improve the quality, clarity, or enforceability of that Reliability Standard, then the drafting team may choose to make such revisions and post the revised Reliability Standard for another 45 calendar day public comment period and ballot. Prior to posting the revised Reliability Standard for an additional comment period, the drafting team must communicate this decision to stakeholders. This communication is intended to inform stakeholders that the drafting team has identified that significant revisions to the Reliability Standard are necessary and should note that the drafting team is not required to respond in writing to comments from the previous ballot. The drafting team will respond to comments received in the last Additional Ballot prior to conducting a Final Ballot. There is no formal comment period concurrent with the Final Ballot and no obligation for the drafting team to respond to any comments submitted during the Final Ballot. 4.13: Additional Ballots A drafting team must respond in writing to every stakeholder written comment submitted in response to a ballot prior to conducting a Final Ballot. These responses may be provided in summary form, but all comments and objections must be responded to by the drafting team. All comments received and all responses shall be publicly posted. However, a drafting team is not required to respond in writing to comments to the previous ballot when it determines that significant changes are needed and an Additional Ballot will be conducted. 4.14: Conduct Final Ballot When the drafting team has reached a point where it has made a good faith effort at resolving applicable objections and is not making any substantive changes from the previous ballot, the team shall conduct a “Final Ballot.” A non-substantive revision is a revision that does not change the scope, applicability, or intent of any Requirement and includes but is not limited to things such as correcting the numbering of a Requirement, correcting the spelling of a word, adding an obviously missing word, or rephrasing a Requirement for improved clarity. Where there is a question as to whether a proposed modification is “substantive,” the Standards Committee shall make the final determination. In the Final Ballot, members of the ballot pool shall again be presented the proposed Reliability Standard along with the reasons for negative votes from the previous ballot, the responses of the drafting team to those concerns, and any resolution of the differences. All members of the ballot pool shall be permitted to reconsider and change their vote from the prior ballot. Members of the ballot pool who did not respond to the prior ballot shall be permitted to vote in the Final Ballot. In the Final Ballot, votes shall be counted by exception only members on the Final Ballot may indicate a revision to their original vote; otherwise their vote shall remain the same as in their prior ballot. 4.15: Final Ballot Results There are no limits to the number of public comment periods and ballots that can be conducted to result in a Reliability Standard or interpretation that is clear and enforceable, and achieves a quorum and sufficient affirmative votes for approval. The Standards Committee has the authority to conclude this process for a particular Reliability Standards action if it becomes obvious that the drafting team cannot develop a Reliability Standard that is within the scope of the associated SAR, is sufficiently clear to be enforceable, and achieves the requisite weighted Segment approval percentage. The NERC Reliability Standards Staff shall post the final outcome of the ballot process. If the Reliability Standard is rejected, the Standards Committee may decide whether to end all further work on the proposed standard, return the project to informal development, or continue holding ballots to attempt to reach



consensus on the proposed standard. If the Reliability Standard is approved, the Reliability Standard shall be posted and presented to the Board of Trustees by NERC management for adoption and subsequently filed with Applicable Governmental Authorities for approval. 4.16: Board of Trustees Adoption of Reliability Standards, Implementation Plan and VRFs and VSLs If a Reliability Standard and its associated implementation plan are approved by its ballot pool, the Board of Trustees shall consider adoption of that Reliability Standard and its associated implementation plan and shall direct the standard to be filed with Applicable Governmental Authorities for approval. In making its decision, the Board shall consider the results of the balloting and unresolved dissenting opinions. The Board shall adopt or reject a Reliability Standard and its implementation plan, but shall not modify a proposed Reliability Standard. If the Board chooses not to adopt a Reliability Standard, it shall provide its reasons for not doing so. The board shall consider approval of the VRFs and VSLs associated with a reliability standard. In making its determination, the board shall consider the following:

• The Standards Committee shall present the results of the non-binding poll conducted and a summary of industry comments received on the final posting of the proposed VRFs and VSLs.

• NERC Staff shall present a set of recommended VRFs and VSLs that considers the views of the standard drafting team, stakeholder comments received on the draft VRFs and VSLs during the posting for comment process, the non-binding poll results, appropriate governmental agency rules and directives, and VRF and VSL assignments for other Reliability Standards to ensure consistency and relevance across the entire spectrum of Reliability Standards.

4.17: Compliance For a Reliability Standard to be enforceable, it shall be approved by its ballot pool, adopted by the NERC Board of Trustees, and approved by Applicable Governmental Authorities, unless otherwise approved by the NERC Board of Trustees pursuant to the NERC Rules of Procedure (e.g, Section 321) and approved by Applicable Governmental Authorities. Once a Reliability Standard is approved or otherwise made mandatory by Applicable Governmental Authorities, all persons and organizations subject to jurisdiction of the ERO will be required to comply with the Reliability Standard in accordance with applicable statutes, regulations, and agreements. 4.18: Withdrawal of a Reliability Standard, Interpretation, or Definition The term “withdrawal” as used herein, refers to the discontinuation of a Reliability Standard, Interpretation, Variance or definition that has been approved by the Board of Trustees and (1) has not been filed with Applicable Governmental Authorities, or (2) has been filed with, but not yet approved by, Applicable Governmental Authorities. The Standards Committee may withdraw a Reliability Standard, Interpretation or definition for good cause upon approval by the Board of Trustees. Upon approval by the Board of Trustees, NERC Staff will petition the Applicable Governmental Authorities, as needed, to allow for withdrawal. The Board of Trustees also has an independent right of withdrawal that is unaffected by the terms and conditions of this Section. 4.19: Retirement of a Reliability Standard, Interpretation, or Definition The term “retirement” refers to the discontinuation of a Reliability Standard, Interpretation or definition that has been approved by Applicable Governmental Authorities. A Reliability Standard, Variance or Definition may be retired when it is superseded by a revised version, and in such cases the retirement of the



earlier version is to be noted in the implementation plan presented to the ballot pool for approval and the retirement shall be considered approved by the ballot pool upon ballot pool approval of the revised version.

Upon identification of a need to retire a Reliability Standard, Variance, Interpretation or definition, where the item will not be superseded by a new or revised version, a SAR containing the proposal to retire a Reliability Standard, Variance, Interpretation or definition will be posted for a comment period and ballot in the same manner as a Reliability Standard. The proposal shall include the rationale for the retirement and a statement regarding the impact of retirement on the reliability of the Bulk Power System. Upon approval by the Board of Trustees, NERC Staff will petition the Applicable Governmental Authorities to allow for retirement.



Section 5.0: Process for Developing a Defined Term

NERC maintains a glossary of approved terms, entitled the Glossary of Terms Used in NERC Reliability Standards24 (“Glossary of Terms”). The Glossary of Terms includes terms that have been through the formal approval process and are used in one or more NERC Reliability Standards. Definitions shall not contain statements of performance Requirements. The Glossary of Terms is intended to provide consistency throughout the Reliability Standards. There are several methods that can be used to add, modify or retire a defined term used in a continent-wide Reliability Standard.

• Anyone can use a Standard Authorization Request (“SAR”) to submit a request to add, modify, or retire a defined term.

• Anyone can submit a Standards Comments and Suggestions Form recommending the addition, modification, or retirement of a defined term. (The suggestion would be added to a project and incorporated into a SAR.)

• A drafting team may propose to add, modify, or retire a defined term in conjunction with the work it is already performing.

5.1: Proposals to Develop a New or Revised Definition The following considerations should be made when considering proposals for new or revised definitions:

• Some NERC Regional Entities have defined terms that have been approved for use in Regional Reliability Standards, and where the drafting team agrees with a term already defined by a Regional Entity, the same definition should be adopted if needed to support a NERC Reliability Standard.

• If a term is used in a Reliability Standard according to its common meaning (as found in a collegiate dictionary), the term shall not be proposed for addition to the Glossary of Terms.

• If a term has already been defined, any proposal to modify or delete that term shall consider all uses of the definition in approved Reliability Standards, with a goal of determining whether the proposed modification is acceptable, and whether the proposed modification would change the scope or intent of any approved Reliability Standards.

• When practical, where NAESB has a definition for a term, the drafting team shall use the same definition to support a NERC Reliability Standard.

Any definition that is balloted separately from a proposed new or modified Reliability Standard or from a proposal for retirement of a Reliability Standard shall be accompanied by an implementation plan. If a SAR is submitted to the NERC Reliability Standards Staff with a proposal for a new or revised definition, the Standards Committee shall consider the urgency of developing the new or revised definition and may direct NERC Staff to post the SAR immediately, or may defer posting the SAR until a later time based on its priority relative to other projects already underway or already approved for future development. If the SAR identifies a term that is used in a Reliability Standard already under revision by a drafting team, the Standards Committee may direct the drafting team to add the term to the scope of the existing project. Each time the Standards Committee accepts a SAR for a project that was not identified in the Reliability Standards Development Plan, the project shall be added to the list of approved projects.

24 The latest approved version of the Glossary of Terms is posted on the NERC website on the Standards web page.



5.2: Stakeholder Comments and Approvals Any proposal for a new or revised definition shall be processed in the same manner as a Reliability Standard and quality review shall be conducted in parallel with this process. Once authorized by the Standards Committee, the proposed definition and its implementation plan shall be posted for at least one formal stakeholder comment period and shall be balloted in the same manner as a Reliability Standard. If a new or revised definition is proposed by a drafting team, that definition may be balloted separately from the associated Reliability Standard. Each definition that is approved by its ballot pool shall be submitted to the NERC Board of Trustees for adoption and then filed with Applicable Governmental Authorities for approval in the same manner as a Reliability Standard.

Processes for Conducting a Field Tests and Collecting and Analyzing Data


Section 6.0: Processes for Conducting Field Tests and Collecting and Analyzing Data

While most drafting teams can develop their Reliability Standards without the need to conduct any field tests and without the need to collect and analyze data, some Reliability Standard development efforts may require benefit from field tests to analyze data and validate concepts in the development of Reliability Standards. Drafting teams are not required to collect and analyze data or to conduct a field test to validate a Reliability Standard. There are two types of field tests – tests of concepts and tests of requirements. A field test is initiated by either a SAR or Reliability Standard requestingdrafting team. AThe requestingdrafting team may consist solely of members of a drafting team, or it may consist of members of a drafting team andbe supplemented with other individuals based on the required technical expertise and the timing of the identification of the need for aneeded to support the field test. The requestingdrafting team is responsible for developing the field test plan, including the implementation schedule, and for identifying compliance related issues such as the potential need for compliance waivers. 6.1: Field Tests and Data Analysis for Validation of Concepts (collectively “Ffield Ttest”)

• 1. Field tests Ttests or collection and analysis of data to validate concepts that support the

development of Requirements Reliability Standards should be conducted, to the extent possible, before the SAR for a project is finalized. If an entity wants to test a technical concept in support of a proposal for a new or revised Reliability Standard, the entity should either work with one of NERC’s technical committees in collecting and analyzing the data or in conducting the field test, or the entity should submit a SAR with a request to collect and analyze data or conduct a field test to validate the concept prior to developing a new or revised Reliability Standard. The request to collect and analyze data or conduct a field test should include, at a minimum, either the data collection and analysis or field test plan, the implementation schedule, and an expectation for periodic updates of the analysis of the results. If the SAR sponsor has not collected and analyzed the data or conducted the field test, the Standards Committee may solicit support from NERC’s technical committees or others in the industry. The results of the data collection and analysis or field test shall then be used to determine whether to add the SAR to the list of projects in the Reliability Standard Development Plan.

• 2. To conduct a Ffield Ttest of a technical concept in a proposed new or revised Reliability Standard, the requestingdrafting team must work with NERC sStaff to identify one of NERC’s technical committees to lead the effort in conductingoversee the Ffield Ttest as well as other technical committees with relevant technical expertise..

• The field test is conducted by the requestingdrafting team, in coordination with NERC Staff and under the oversight of the assigned technical committee, in accordance with an approved field test plan.

6.1.1. Field Test Approval The request to conduct a Ffield Ttest must include, at a minimum:

• the Ffield Ttest plan, • the implementation schedule, and



• an expectation for periodic updates of the analysis of the results to the lead NERC technical committee.

Prior to the requestingdrafting team conducting a Ffield Ttest, itthe drafting team must:

first receive approval from the lead NERC technical committee, and

subsequently receive approval from the Standards Committee. Second, the drafting team must receive approval from the Standards Committee.

The lead NERC technical committee’s approval shall review be based on the technical adequacy of the field test plan. Following approval, the lead NERC technical committee and shall provide a recommendation to the Standards Committee for the disposition of individualthe field test plan requests. The lead NERC technical committee shall coordinate all entity participation in the field test such as accepting, adding to, and withdrawals of the individual entities from the field tests, as well as coordinating and communicating status of the results of the field tests. The Standards Committee’s decision to approve the field test plan request shall be based solely on whether the Standards Committee, via a majority vote, agrees or disagrees with the lead NERC technical committee’s recommendation. If the Standards Committee disagrees with the lead NERC technical committee’s recommendation, the Standards Committee will inform the lead NERC technical committee with an explanation of the basis for the decision. 6.1.2: Field Test Suspension for Reliability Concerns During the Ffield Ttest, if the lead NERC technical committee overseeing the Ffield Ttest determines therethat the field test is creating a reliability risk to the BESBulk Power System:

• the lead NERC technical committee shall stop or modify the activity; • the lead NERC technical committee shall inform the Standards Committee that the activity was

stopped or modified; • the Standards Committee, with the assistance of NERC sStaff, shall document the cessation or

modification of the Ffield Ttest; and • the Standards Committee, with the assistance of NERC staff, shall notify NERC cCompliance

Monitoring and Enforcement Program Sstaff to coordinate any compliance related issues such as continuance or cessation of waivers (see Section 6.2).

Prior to the Ffield Ttest being restarted after it has been stopped, the requesting drafting team must resubmit the Ffield Ttest request and receive approval as outlined in Ssection 6.1.1. 6.1.3: Continuing, Modifying or Terminating a Field Test If the drafting team concludes that a Ffield Ttest does not provide sufficient information to formulate a conclusion within the time allotted in the plan, the drafting team shall provide a recommendation to either continue (including extending the duration of the field test beyond the period of standard development), modify or terminate the field test to the lead NERC technical committee and the Cchair of the Standards Committee. The lead NERC technical committee willshall either approve or reject a request work with the requesting team and the lead NERC technical committee to determine whether to continue, modify or



terminate the Ffield Ttest, and, thereafter, provide notice to the chair of the Standards Committee of its selection.. If the duration of the field test is extended beyond the period of standard development, the preliminary report and results shall be publicly posted on the NERC web site prior to the final ballot of the Reliability Standard. 6.2: Field Tests and Data Analysis for Validation of Requirements If a drafting team wants to conduct a field test or collect and analyze data to validate its proposed Requirements in a Reliability Standard, the team shall first obtain approval from the Standards Committee.25 Drafting teams are not required to collect and analyze data or to conduct a field test to validate a Reliability Standard. The request should include at a minimum the data collection and analysis or field test plan, the implementation schedule, and an expectation for periodic updates of the results. When authorizing a drafting team to collect and analyze data or to conduct a field test of one or more Requirements, the Standards Committee may request inputs on technical matters related from NERC’s technical committees or industry experts, and may request the assistance of the Compliance Monitoring and Enforcement Program. All data collection and analysis and all field tests shall be concluded and the results incorporated into the Reliability Standard Requirements as necessary before proceeding to the formal comment period and subsequent balloting. 6.32: Communication and Coordination for All Types of Field Tests and Data Analyses If the conduct of a field test (concepts or Requirements) or data collection and analysis couldAfter approval of the Ffield Ttest, the requestingdrafting team may request waivers of compliance for Ffield Ttest participants that would be rendered Registered Entities incapable of complying with the current Requirement(s) of an approvedthe currently enforceable Reliability Standard that is undergoing revision, the drafting team shall request a temporary waiver from compliance to those Requirements for entities participating in the field testdue to their participation. Upon request, the Standards Committee shall seek approval for the waiver from tThe NERC Compliance Monitoring and Enforcement Program prior to the approval of the field test or data collection and analysis sStaff shall determine whether to approve the requested waivers, and shall be responsible for approving any modifications or terminations that may become necessary following the start of the field test. and tThe NERC Reliability Standards sStaff shall inform the affected rRegistered eEntities. Prior to initiation of the Ffield Ttest, the Cchair of the Standards Committee, in conjunction with the lead NERC technical committee chair, shall inform the NERC Board of Trustees of the pending fField Ttest, the expected duration, and any requested waivers from compliance for rRegistered eEntities. During the Ffield Ttest, the requestingdrafting team conducting the Ffield Ttest shall provide periodic updates (no less than quarterly) on the progress of the Ffield Ttests to the Standards Committee and the applicable NERC technical committees. Prior to the ballot of any standard involving a field testAt the conclusion of the field test, the requestingdrafting team shall provide to the Standards Committee either a preliminary report of the results of the field test to date, if the field test will continue beyond standard

25 The Process for Approving Data Collection and Analysis and Field Tests Associated with a Reliability Standard is posted on the Reliability Standards Resources web page.



development, or a final report if the field test has been completedto the Standards Committee. The Cchair of the Standards Committee shall keep the NERC Board of Trustees informed. Once a plan for a field test or a plan for data collection and analysis is approved, the NERC Reliability Standards Staff shall, under the direction of the Standards Committee, coordinate the implementation of the field test or data collection and analysis and shall provide official notice to the participants in the field test or data collection of any applicable temporary waiver to compliance with specific noted Requirements. The drafting team conducting the field test shall provide periodic updates on the progress of the field tests or data collection and analysis to the Standards Committee. The Standards Committee has the right to curtail a field test or data collection and analysis that is not implemented in accordance with the approved plan. The field test plan or data collection and analysis plan, its approval, its participants, and all reports and results shall be publicly posted for stakeholder review on the NERC Reliability Standards web pagesite. This posting shall include the participant list, unless it is determined that posting this list would present confidentiality or other concerns. If a drafting team conducts or participates in a field test or in data collection and analysis (of concepts or Requirements), it shall provide a final report that identifies the results and how those results will be used.



Section 7.0: Process for Developing an Interpretation A valid Interpretation request is one that requests additional clarity about one or more Requirements in approved NERC Reliability Standards, but does not request approval as to how to comply with one or more Requirements. 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 of any Requirement in any continent-wide Reliability Standard that has been adopted by the NERC Board of Trustees. Interpretations will only be provided for Board of Trustees-approved Reliability Standards i.e. (i) the current effective version of a Reliability Standard; or (ii) a version of a Reliability Standard with a future effective date. An Interpretation may only clarify or interpret the Requirements of an approved Reliability Standard, including, if applicable, any attachment referenced in the Requirement being clarified. No other elements of an approved Reliability Standard are subject to Interpretation. The entity requesting the Interpretation shall submit a Request for Interpretation form26 to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the Interpretation provided. The NERC Reliability Standards and Legal Staffs shall review the request for interpretation to determine whether it meets the requirements for a valid interpretation. Based on this review, the NERC Standards and Legal Staffs shall make a recommendation to the Standards Committee whether to accept the request for Interpretation and move forward in responding to the Interpretation request. For example, an Interpretation request may be rejected where it:

(1) Requests approval of a particular compliance approach; (2) Identifies a gap or perceived weakness in the approved Reliability Standard; (3) Where an issue can be addressed by an active standard drafting team; (4) Where it requests clarification of any element of a Reliability Standard other than a

Requirement; (5) Where a question has already been addressed in the record; (6) Where the Interpretation identifies an issue and proposes the development of a new or modified Reliability Standard, (such issues should be addressed via submission of a SAR); (7) Where an Interpretation seeks to expand the scope of a Reliability Standard; or (8) Where the meaning of a Reliability Standard is plain on its face.

If the Standards Committee rejects the Interpretation request, it shall provide a written explanation for rejecting the Interpretation to the entity requesting the Interpretation within 10 business days of the decision to reject. If the Standards Committee accepts the Interpretation request, the NERC Standards Staff shall (i) form a ballot pool and (ii) assemble an Interpretation drafting team with the relevant expertise to address the interpretation for approval by the Standards Committee. As soon as practical, the team shall develop a “final draft” Interpretation providing the requested clarity. Interpretations will be balloted in the same manner as Reliability Standards.

26 The Request for Interpretation form is posted on the NERC Standards web page.



If stakeholder comments indicate that there is not a consensus for the Interpretation, and the Interpretation drafting team cannot revise the Interpretation without violating the basic expectations outlined above, the Interpretation drafting team shall notify the Standards Committee of its conclusion and may submit a SAR with the proposed modification to the Reliability Standard. The entity that requested the Interpretation shall be notified and the disposition of the Interpretation shall be posted. If, during its deliberations, the Interpretation drafting team identifies a reliability gap in the Reliability Standard that is highlighted by the Interpretation request, the Interpretation drafting team shall notify the Standards Committee of its conclusion and may submit a SAR with the proposed modification to the Reliability Standard at the same time it provides its proposed Interpretation. The NERC Reliability Standards and Legal Staffs shall review the final Interpretation to determine whether it has met the requirements for a valid Interpretation. Based on this review, the NERC Standards and Legal Staffs shall make a recommendation to the NERC Board of Trustees regarding adoption. If approved by its ballot pool, the Interpretation shall be forwarded to the NERC Board of Trustees for adoption.27 If an Interpretation drafting team proposes a modification to a Reliability Standard as part of its work in developing an Interpretation, the Board of Trustees shall be notified of this proposal at the time the Interpretation is submitted for adoption. Following adoption by the Board of Trustees, NERC Staff shall file the Interpretation for approval by Applicable Governmental Authorities and the Interpretation shall become effective when approved by those Applicable Governmental Authorities. The Interpretation shall stand until such time as the Interpretation can be incorporated into a future revision of the Reliability Standard or the Interpretation is retired due to a future modification of the applicable Requirement.

27 NERC will maintain a record of all interpretations associated with each standard on the Reliability Standards page of the NERC website.



If significant changes are needed to the Interpretatation then conduct Additional Ballot (Repeat Step 6) If, during its deliberations, the Interpretation drafting team identifies a reliability gap in the Reliability Standard that is highlighted by the Interpretation request, the Interpretation drafting team shall notify the Standards Committee of its

conclusion and shall submit a SAR with the proposed modification to the Reliability Standard at the same time it provides itsproposed Interpretation.


Form Ballot Pool during first 30 calendar days of 45-day Comment Period Conduct Ballot during last 10 days of Comment Period

STEP 5: Obtain Standards Committee Approval to Post Interpretation for Comment and Ballot

STEP 4: Develop Draft of Interpretation

Conduct Quality Review Collect Informal Feedback

STEP 3: Standards Committee Accepts/Rejects the Interpretation request

If the Standards Committee rejects the Interpretation request, it shall provide a written explanation for rejecting the Interpretation to the entity requesting the

interpretation within 10 business days of the decision to reject.

If the Standards Committee accepts the Interpretation request, the NERC Standards staff shall form a ballot pool and assemble an Interpretation drafting

team with the relevant expertise to address the interpretation.

STEP 2: Request for Interpretation reviewed by NERC Reliability Standards and Legal Staffs and Recommendation submitted to the Standards Committee

STEP1: Request for Interpretation Form submitted



FIGURE 2: Process for Developing an Interpretation

STEP 11: Submit BOT-approved Interpretation to Applicable Gvernmental Authorities for approval

STEP 10: Submit Interpretation to BOT for Adoption and Approval

STEP 9: Review by NERC Reliability Standards and Legal Staff of the Interpretation to determine whether it has met the requirements for a valid Interpretation

Recommendation submitted by NERC Standards and Legal Staff to BOT regarding adoption





Section 8.0: Process for Appealing an Action or Inaction

Any entity that has directly and materially affected interests and that has been or will be adversely affected by any procedural action or inaction related to the development, approval, revision, reaffirmation, retirement or withdrawal of a Reliability Standard, definition, Variance, associated implementation plan, or Interpretation shall have the right to appeal. This appeals process applies only to the NERC Reliability Standards processes as defined in this manual, not to the technical content of the Reliability Standards action. The burden of proof to show adverse effect shall be on the appellant. Appeals shall be made in writing within 30 days of the date of the action purported to cause the adverse effect, except appeals for inaction, which may be made at any time. The final decisions of any appeal shall be documented in writing and made public. The appeals process provides two levels, with the goal of expeditiously resolving the issue to the satisfaction of the participants. 8.1: Level 1 Appeal Level 1 is the required first step in the appeals process. The appellant shall submit (to the Director of Standards) a complaint in writing that describes the procedural action or inaction associated with the Reliability Standards process. The appellant shall describe in the complaint the actual or potential adverse impact to the appellant. Assisted by NERC Staff and industry resources as needed, the Director of Standards shall prepare a written response addressed to the appellant as soon as practical but not more than 45 days after receipt of the complaint. If the appellant accepts the response as a satisfactory resolution of the issue, both the complaint and response shall be made a part of the public record associated with the Reliability Standard. 8.2: Level 2 Appeal If after the Level 1 Appeal the appellant remains unsatisfied with the resolution, as indicated by the appellant in writing to the Director of Standards, the Director of Standards shall convene a Level 2 Appeals Panel. This panel shall consist of five members appointed by the Board of Trustees. In all cases, Level 2 Appeals Panel members shall have no direct affiliation with the participants in the appeal. The NERC Reliability Standards Staff shall post the complaint and other relevant materials and provide at least 30 days notice of the meeting of the Level 2 Appeals Panel. In addition to the appellant, any entity that is directly and materially affected by the procedural action or inaction referenced in the complaint shall be heard by the panel. The panel shall not consider any expansion of the scope of the appeal that was not presented in the Level 1 Appeal. The panel may, in its decision, find for the appellant and remand the issue to the Standards Committee with a statement of the issues and facts in regard to which fair and equitable action was not taken. The panel may find against the appellant with a specific statement of the facts that demonstrate fair and equitable treatment of the appellant and the appellant’s objections. The panel may not, however, revise, approve, disapprove, or adopt a Reliability Standard, definition, Variance or Interpretation or implementation plan as these responsibilities remain with the ballot pool and Board of Trustees respectively. The actions of the Level 2 Appeals Panel shall be publicly posted. In addition to the foregoing, a procedural objection that has not been resolved may be submitted to the Board of Trustees for consideration at the time the Board decides whether to adopt a particular Reliability Standard, definition, Variance or Interpretation. The objection shall be in writing, signed by an officer of the objecting entity, and contain a concise statement of the relief requested and a clear demonstration of the



facts that justify that relief. The objection shall be filed no later than 30 days after the announcement of the vote by the ballot pool on the Reliability Standard in question.



Section 9.0: Process for Developing a Variance A Variance is an approved, alternative method of achieving the reliability intent of one or more Requirements in a Reliability Standard. No Regional Entity or Bulk Power System owner, operator, or user shall claim a Variance from a NERC Reliability Standard without approval of such a Variance through the relevant Reliability Standard approval procedure for the Variance. Each Variance from a NERC Reliability Standard that is approved by NERC and Applicable Governmental Authorities shall be made an enforceable part of the associated NERC Reliability Standard. NERC’s drafting teams shall aim to develop Reliability Standards with Requirements that apply on a continent-wide basis, minimizing the need for Variances while still achieving the Reliability Standard’s reliability objectives. If one or more Requirements cannot be met or complied with as written because of a physical difference in the Bulk Power System or because of an operational difference (such as a conflict with a federally or provincially approved tariff), but the Requirement’s reliability objective can be achieved in a different fashion, an entity or a group of entities may pursue a Variance from one or more Requirements in a continent-wide Reliability Standard. It is the responsibility of the entity that needs a Variance to identify that need and initiate the processing of that Variance through the submittal of a SAR28 that includes a clear definition of the basis for the Variance. There are two types of Variances – those that apply on an Interconnection-wide basis, and those that apply to one or more entities on less than an Interconnection-wide basis. 9.1: Interconnection-wide Variances Any Variance from a NERC Reliability Standard Requirement that is proposed to apply to Registered Entities within a Regional Entity organized on an Interconnection-wide basis shall be considered an Interconnection-wide Variance and shall be developed through that Regional Entity’s NERC-approved Regional Reliability Standards development procedure. While an Interconnection-wide Variance may be developed through the associated Regional Reliability Standards development process, Regional Entities are encouraged to work collaboratively with existing continent-wide drafting teams to reduce potential conflicts between the two efforts. An Interconnection-wide Variance from a NERC Reliability Standard that is determined by NERC to be just, reasonable, and not unduly discriminatory or preferential, and in the public interest, and consistent with other applicable standards of governmental authorities shall be made part of the associated NERC Reliability Standard. NERC shall rebuttably presume that an Interconnection-wide Variance from a NERC Reliability Standard that is developed, in accordance with a Regional Reliability Standards development procedure approved by NERC, by a Regional Entity organized on an Interconnection-wide basis, is just, reasonable, and not unduly discriminatory or preferential, and in the public interest. 9.2: Variances that Apply on Less than an Interconnection-wide Basis Any Variance from a NERC Reliability Standard Requirement that is proposed to apply to one or more entities but less than an entire Interconnection (e.g., a Variance that would apply to a regional transmission organization or particular market or to a subset of Bulk Power System owners, operators, or users), shall be considered a Variance. A Variance may be requested while a Reliability Standard is under development or a Variance may be requested at any time after a Reliability Standard is approved. Each request for a

28 A sample of a SAR that identifies the need for a Variance and a sample Variance are posted as resources on the Reliability Standards Resources web page.



Variance shall be initiated through a SAR, and processed and approved in the same manner as a continent-wide Reliability Standard, using the Reliability Standards development process defined in this manual.



Section 10.0: Processes for Developing a Reliability Standard Related to a Confidential Issue While it is NERC’s intent to use its ANSI-accredited Reliability Standards development process for developing its Reliability Standards, NERC has an obligation as the ERO to ensure that there are Reliability Standards in place to preserve the reliability of the interconnected Bulk Power Systems throughout North America. When faced with a national security emergency situation, NERC may use one of the following special processes to develop a Reliability Standard that addresses an issue that is confidential. Reliability Standards developed using one of the following processes shall be called, “special Reliability Standards” and shall not be filed with ANSI for approval as American National Standards. The NERC Board of Trustees may direct the development of a new or revised Reliability Standard to address a national security situation that involves confidential issues. These situations may involve imminent or long-term threats. In general, these Board directives will be driven by information from the President of the United States of America or the Prime Minister of Canada or a national security agency or national intelligence agency of either or both governments indicating (to the ERO) that there is a national security threat to the reliability of the Bulk Power System.29 There are two special processes for developing Reliability Standards responsive to confidential issues – one process where the confidential issue is “imminent,” and one process where the confidential issue is “not imminent.” 10.1: Process for Developing Reliability Standards Responsive to Imminent, Confidential Issues If the NERC Board of Trustees directs the immediate development of a new or revised Reliability Standard to address a confidential national security emergency situation, the NERC Reliability Standards Staff shall develop a SAR, form a ballot pool (to vote on the Reliability Standard and its implementation plan) and assemble a slate of pre-defined subject matter experts as a proposed drafting team for approval by the Standards Committee’s officers. All members of the Registered Ballot Body shall have the opportunity to join the ballot pool. 10.2: Drafting Team Selection The Reliability Standard drafting team selection process shall be limited to just those candidates who have already been identified as having the appropriate security clearance, the requisite technical expertise, and either have signed or are willing to sign a strict confidentiality agreement. 10.3: Work of Drafting Team The Reliability Standard drafting team shall perform all its work under strict security and confidential rules. The Reliability Standard drafting team shall develop the new or revised Reliability Standard and its implementation plan. The Reliability Standard drafting team shall review its work, to the extent practical, as it is being developed with officials from the appropriate governmental agencies in the U.S. and Canada, under strict security and confidentiality rules. 10.4: Formal Stakeholder Comment & Ballot Window

29 The NERC Board may direct the immediate development and issuance of a Level 3 (Essential Action) alert and then may also direct the immediate development of a new or revised Reliability Standard.



The draft Reliability Standard and its implementation plan shall be distributed for a formal comment period, under strict confidentiality rules, only to those entities that are listed in the NERC Compliance Registry to perform one of the functions identified in the applicability section of the Reliability Standard and have identified individuals from their organizations that have signed confidentiality agreements with NERC.30 At the same time, the Reliability Standard shall be distributed to the members of the ballot pool for review and ballot. The NERC Reliability Standards Staff shall not post or provide the ballot pool with any confidential background information. The drafting team, working with the NERC Reliability Standards Staff, shall consider and respond to all comments, make any necessary conforming changes to the Reliability Standard and its implementation plan, and shall distribute the comments, responses and any revision to the same population as received the initial set of documents for formal comment and ballot. 10.5: Board of Trustee Actions Each Reliability Standard and implementation plan developed through this process shall be submitted to the NERC Board of Trustees for adoption. 10.6: Governmental Approvals All approved documents shall be filed for approval with Applicable Governmental Authorities.




10.7: Developing a Reliability Standard Responsive to an Imminent, Confidential Issue







Distribute Standard for Comment only to entities that: (1) have signed confidentiality agreements; (2) are in the NERC Compliance Registry; and (3) perform an applicable function Conduct Ballot During Last 10 Days of Comment Period






FIGURE 3: Process for Developing a Standard Responsive to an Imminent, Confidential Issue



10.8: Process for Developing Reliability Standards Responsive to Non-imminent, Confidential Issues If the NERC Board of Trustees directs the immediate development of a new or revised Reliability Standard to address a confidential national security emergency situation, the NERC Reliability Standards Staff shall develop a SAR, form a ballot pool (to vote on the Reliability Standard and its implementation plan) and assemble a slate of pre-defined subject matter experts as a proposed drafting team for approval by the Standards Committee’s officers. All members of the Registered Ballot Body shall have the opportunity to join the ballot pool. 10.9: Drafting Team Selection The drafting team selection process shall be limited to just those candidates who have already been identified as having the appropriate security clearance, the requisite technical expertise, and either have signed or are willing to sign a strict confidentiality agreement. 10.10: Work of Drafting Team The drafting team shall perform all its work under strict security and confidential rules. The Reliability Standard drafting team shall develop the new or revised Reliability Standard and its implementation plan. The drafting team shall review its work, to the extent practical, as it is being developed with officials from the Applicable Governmental Authorities, under strict security and confidentiality rules. 10.11: Formal Stakeholder Comment & Ballot Window The draft Reliability Standard and its implementation plan shall be distributed for a formal comment period, under strict confidentiality rules, only to those entities that are listed in the NERC Compliance Registry to perform one of the functions identified in the applicability section of the Reliability Standard and have identified individuals from their organizations that have signed confidentiality agreements with NERC.31 At the same time, the Reliability Standard shall be distributed to the members of the ballot pool for review and ballot. The NERC Reliability Standards Staff shall not post or provide the ballot pool with any confidential background information. 10.12: Revisions to Reliability Standard, Implementation Plan and VRFs and VSLs The drafting team, working with the NERC Reliability Standards Staff, shall work to refine the Reliability Standard, implementation plan and VRFs and VSLs in the same manner as for a new Reliability Standard following the “normal” Reliability Standards development process described earlier in this manual with the exception that distribution of the comments, responses, and new drafts shall be limited to those entities that are in the ballot pool and those entities that are listed in the NERC Compliance Registry to perform one of the functions identified in the applicability section of the Reliability Standard and have identified individuals from their organizations that have signed confidentiality agreements with NERC. 10.13: Board of Trustee Action Each Reliability Standard, implementation plan, and the associated VRFs and VSLs developed through this process shall be submitted to the NERC Board of Trustees for adoption. 10.14: Governmental Approvals All BOT-approved documents shall be filed for approval with Applicable Governmental Authorities.




Developing a Reliability Standard Responsive to a Non-imminent, Confidential Issue






If significant changes are needed to the draft Reliability Standard then conduct Additional Ballot (Repeat Step 3)

STEP 3: Formal Comment Period and Ballot (Comment Period and Ballot Window may be abbreviated)

Distribute Standard for Comment only to entities that: (1) have signed confidentiality agreements; (2) are in the NERC Compliance Registry; and (3) perform an applicable function

Conduct Ballot During Last 10 Days of Comment Period



Conduct Quality Review





FIGURE 4: Developing a Standard Responsive to a Non-Imminent, Confidential Issue

Process for Approving Supporting Documents


Section 11.0: Process for Approving Supporting Documents The following types of documents are samples of the types of supporting documents that may be developed to enhance stakeholder understanding and implementation of a Reliability Standard. These documents may explain or facilitate implementation of Reliability Standards but do not themselves contain mandatory Requirements subject to compliance review. Any Requirements that are mandatory shall be incorporated into the Reliability Standard in the Reliability Standard development process. While most supporting documents are developed by the standard drafting team working to develop the associated Reliability Standard, any entity may develop a supporting document associated with a Reliability Standard. The Standards Committee shall authorize the posting of all supporting references32 that are linked to an approved Reliability Standard. Prior to granting approval to post a supporting reference with a link to the associated Reliability Standard, the Standards Committee shall verify that the document has had stakeholder review to verify the accuracy of the technical content. While the Standards Committee has the authority to approve the posting of each such reference, stakeholders, not the Standards Committee, verify the accuracy of the document’s contents.

Type of Document Description

Reference Descriptive, technical information or analysis or explanatory information to support the understanding and interpretation of a Reliability Standard. A standard reference may support the implementation of a Reliability Standard or satisfy another purpose consistent with the reliability and market interface principles.

Guideline Recommended process that identifies a method of meeting a Requirement under specific conditions.

Supplement Data forms, pro forma documents, and associated instructions that support the implementation of a Reliability Standard.

Training Material Documents that support the implementation of a Reliability Standard.

Procedure Step-wise instructions defining a particular process or operation. Procedures may support the implementation of a Reliability Standard or satisfy another purpose consistent with the reliability and market interface principles.

White Paper An informal paper stating a position or concept. A white paper may be used to propose preliminary concepts for a Reliability Standard or one of the documents above.

32 The Standards Committee’s Procedure for Approving the Posting of Reference Documents is posted on the Reliability Standards Resources web page.

Process for Correcting Errata


Section 12.0: Process for Correcting Errata From time to time, an error may be discovered in a Reliability Standard. Such errors may be corrected (i) following a Final Ballot prior to Board of Trustees adoption, (ii) following Board of Trustees adoption prior to filing with Applicable Governmental Authorities; and (iii) following filing with Applicable Governmental Authorities. If the Standards Committee agrees that the correction of the error does not change the scope or intent of the associated Reliability Standard, and agrees that the correction has no material impact on the end users of the Reliability Standard, then the correction shall be filed for approval with Applicable Governmental Authorities as appropriate. The NERC Board of Trustees has resolved to concurrently approve any errata approved by the Standards Committee.

Process for Conducting Periodic Review of Reliability Standards


Section 13.0: Process for Conducting Periodic Reviews of Reliability Standards All Reliability Standards shall be reviewed at least once every ten years from the effective date of the Reliability Standard or the date of the latest Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. If a Reliability Standard is approved by ANSI as an American National Standard, it shall be reviewed at least once every five years from the effective date of the Reliability Standard or the date of the latest Board of Trustees adoption to a revision of the Reliability Standard, whichever is later. The Reliability Standards Development Plan shall include projects that address this five or ten-year review of Reliability Standards.

• If a Reliability Standard is nearing its five or ten-year review and has issues that need resolution, then the Reliability Standards Development Plan shall include a project for the complete review and associated revision of that Reliability Standard that includes addressing all outstanding governmental directives, all approved Interpretations, and all unresolved issues identified by stakeholders.

• If a Reliability Standard is nearing its five or ten-year review and there are no outstanding governmental directives, Interpretations, or unresolved stakeholder issues associated with that Reliability Standard, then the Reliability Standards Development Plan shall include a project solely for the “five-year review” of that Reliability Standard.

For a project that is focused solely on the five-year review, the Standards Committee shall appoint a review team of subject matter experts to review the Reliability Standard and recommend whether the American National Standard Institute-approved Reliability Standard should be reaffirmed, revised, or withdrawn. Each review team shall post its recommendations for a 45 calendar day formal stakeholder comment period and shall provide those stakeholder comments to the Standards Committee for consideration.

• If a review team recommends reaffirming a Reliability Standard, the Standards Committee shall submit the reaffirmation to the Board of Trustees for adoption and then to Applicable Governmental Authorities for approval. Reaffirmation does not require approval by stakeholder ballot.

• If a review team recommends modifying, or retiring a Reliability Standard, the team shall develop a SAR with such a proposal and the SAR shall be submitted to the Standards Committee for prioritization as a new project. Each existing Reliability Standard recommended for modification, or retirement shall remain in effect in accordance with the associated implementation plan until the action to modify or withdraw the Reliability Standard is approved by its ballot pool, adopted by the Board of Trustees, and approved by Applicable Governmental Authorities.

In the case of reaffirmation of a Reliability Standard, the Reliability Standard shall remain in effect until the next five or ten-year review or until the Reliability Standard is otherwise modified or withdrawn by a separate action.

Public Access to Reliability Standards Information


Section 14.0: Public Access to Reliability Standards Information 14.1: Online Reliability Standards Information System The NERC Reliability Standards Staff shall maintain an electronic copy of information regarding currently proposed and currently in effect Reliability Standards. This information shall include current Reliability Standards in effect, proposed revisions to Reliability Standards, and proposed new Reliability Standards. This information shall provide a record, for at a minimum the previous five years, of the review and approval process for each Reliability Standard, including public comments received during the development and approval process. 14.2: Archived Reliability Standards Information The NERC Staff shall maintain a historical record of Reliability Standards information that is no longer maintained online. Archived information shall be retained indefinitely as practical, but in no case less than five years or one complete standard cycle from the date on which the Reliability Standard was no longer in effect. Archived records of Reliability Standards information shall be available electronically within 30 days following the receipt by the NERC Reliability Standards Staff of a written request.

Process for Updating Standard Processes


Section 15.0: Process for Updating Standard Processes 15.1: Requests to Revise the Standard Processes Manual Any person or entity may submit a request to modify one or more of the processes contained within this manual. The Standards Committee shall oversee the handling of each request. The Standards Committee shall prioritize all requests, merge related requests, and respond to each sponsor within 30 calendar days. The Standards Committee shall post the proposed revisions for a 45 (calendar) day formal comment period. Based on the degree of consensus for the revisions, the Standards Committee shall:

a. Submit the revised process or processes for ballot pool approval; b. Repeat the posting for additional inputs after making changes based on comments received; c. Remand the proposal to the sponsor for further work; or d. Reject the proposal.

The Registered Ballot Body shall be represented by a ballot pool. The ballot procedure shall be the same as that defined for approval of a Reliability Standard, including the use of an Additional Ballot if needed. If the proposed revision is approved by the ballot pool, the Standards Committee shall submit the revised procedure to the Board for adoption. The Standards Committee shall submit to the Board a description of the basis for the changes, a summary of the comments received, and any minority views expressed in the comment and ballot process. The proposed revisions shall not be effective until approved by the NERC Board of Trustees and Applicable Governmental Authorities.

Waiver


Section 16.0: Waiver While it is NERC’s intent to use its ANSI-accredited Reliability Standards development process for developing its Reliability Standards, NERC may need to develop a new or modified Reliability Standard, definition, Variance, or implementation plan under specific time constraints (such as to meet a time constrained regulatory directive) or to meet an urgent reliability issue such that there isn’t sufficient time to follow all the steps in the normal Reliability Standards development process. The Standards Committee may waive any of the provisions contained in this manual for good cause shown, but limited to the following circumstances:

• In response to a national emergency declared by the United States or Canadian government that

involves the reliability of the Bulk Electric System or cyber attack on the Bulk Electric System; • Where necessary to meet regulatory deadlines; • Where necessary to meet deadlines imposed by the NERC Board of Trustees; or • Where the Standards Committee determines that a modification to a proposed Reliability Standard

or its Requirement(s), a modification to a defined term, a modification to an interpretation, or a modification to a variance has already been vetted by the industry through the standards development process or is so insubstantial that developing the modification through the processes contained in this manual will add significant time delay.

In no circumstances shall this provision be used to modify the requirements for achieving quorum or the voting requirements for approval of a standard. A waiver request may be submitted to the Standards Committee by any entity or individual, including NERC committees or subgroups and NERC Staff. Prior to consideration of any waiver request, the Standards Committee must provide five business days notice to stakeholders. Action on the waiver request will be included in the minutes of the Standards Committee. Following the approval of the Standards Committee to waive any provision of the Standard Process Manual, the Standards Committee will report this decision to the Standards Oversight and Technology Committee.33 Actions taken pursuant to an approved waiver request will be posted on the Standard Project page and included in the next project announcement. In addition, the Standards Committee shall report the exercise of this waiver provision to the Board of Trustees prior to adoption of the related Reliability Standard, Interpretation, definition or Variance. Reliability Standards developed as a result of a waiver of any provision of the Standard Processes Manual shall not be filed with ANSI for approval as American National Standards.

33 Any entity may appeal a waiver decision or any other procedural decision by the Standards Committee pursuant to Section 8.0 of the NERC Standard Processes Manual.


Project 2015-04 – Alignment of Terms Phase II Recommendations of the Drafting Team

Action Endorse (1) the Standards Committee Executive Committee (SCEC), working with NERC staff, reviewing the Phase II Recommendations of the Alignment of Terms drafting team and the comments of the Project Management Oversight Subcommittee liaisons on those recommendations, and (2) after the review, presenting a proposal by the SCEC to the Standards Committee (SC) on how to proceed with the recommendations by the December 2016 SC meeting.

Background The purpose of Project 2015-04 was to (1) align the existing defined terms in the NERC Glossary of Terms (Glossary) and NERC Rules of Procedure (ROP), and (2) develop recommendations for enhancing the current definition development process in the Standard Processes Manual and ROP to prevent misalignment or inconsistencies during future development of defined terms.1 The team accomplished the first phase. The latter phase of the team’s work resulted in the attached report. Given the process implications, both Andrew Gallo and Brian Murphy attempted to provide input to the team so that the attached draft would more closely align with what they viewed as the SC’s current processes, etc. Their redline is also attached. In the end, the drafting team elected not to adopt Andrew and Brian’s input. As a result, it appears appropriate for the SCEC to review these attachments and make recommendations rather than proceeding directly to an SC vote on the team’s process recommendations. This will also provide the SCEC with time to consider the team’s recommendations and the Project Management Oversight Subcommittee liaison’s’ input, along with providing the SC with the SCEC’s thoughts on how to move forward with any recommendations adopted by the SC.

1 For further information regarding the project scope, purpose and objectives, please see the Standards Authorization Request (SAR) located on the project page.

http://www.nerc.com/pa/Stand/Glossary%20of%20Terms/Glossary_of_Terms.pdf


http://www.nerc.com/AboutNERC/Pages/Rules-of-Procedure.aspx

http://www.nerc.com/pa/Stand/Project201504AlignmentofGlossaryofTermsNERCRSRPDL/2015-02-25-Project2015-04AlignmentofTerms-SAR.pdf


http://www.nerc.com/pa/Stand/Pages/Project-2015-04-Alignment-of-Glossary-of-Terms-(NERC-Reliability-Standards-and-the-Rules-of-Procedure).aspx

Phase 2 Recommendations Project 2015-04 – Alignment of Terms

Part I. Executive Summary The purpose of Project 2015-04 is to (1) align the existing defined terms in the NERC Glossary of Terms (Glossary) and NERC Rules of Procedure (ROP), and (2) develop recommendations for enhancing the current definition development process in the Standards Process Manual and ROP to prevent misalignment or inconsistencies during future development of defined terms.1 During Phase 1 of the project, the drafting team focused on alignment of the existing definitions of “cross-over terms.” A “cross-over term” refers to a term that is defined in both the Glossary and ROP. As part of Phase 2 of the project, and in support of the second purpose statement above, the drafting team developed five (5) recommendations related to enhancement of the current definition development processes. The team believes implementation of these recommendations will allow for future development of high-quality definitions that are written in a clear, consistent and uniform manner.

Recommendation No. 1: Cross-over terms should be defined identically in the Glossary and ROP

Recommendation No. 2: Definitions should be written in a consistent and uniform manner

Recommendation No. 3: Use correct and consistent capitalization to indicate a NERC defined term

Recommendation No. 4: Eliminate all standard-only or section-only definitions

Recommendation No. 5: Revise existing definitions that are lacking in quality, content, technical accuracy or are not reflective of how the industry uses the term today

Part II of this document provides relevant background information on the Glossary and ROP definitions, and an overview of the purpose, scope and work completed by the drafting team as part of Phase 1. Part III provides greater detail regarding each of the five recommendations, including an issue statement, background information, observations of the drafting team, discussion of the recommendation, and the drafting team proposal regarding how to address the issue. Finally, Part IV provides the drafting team’s conclusions.

Part II. Background Information

History of NERC Glossary and ROP definitions In 2007, when FERC approved Version 0 of the Reliability Standards, it also approved the NERC Glossary of Terms. See, FERC Order No. 693. In Order No. 693, FERC noted the importance of the defined terms in establishing a consistent understanding of the Reliability Standards Requirements and implementation. See, FERC Order No. 693 at P 1893. The NERC Glossary provides continuity in the application of the Glossary definitions industry-wide and eliminates multiple interpretations of the same term or function, which could otherwise create miscommunication or jeopardize reliability.

1 For further information regarding the project scope, purpose and objectives, please see the Standards Authorization Request (SAR) located on the project page.



http://www.nerc.com/AboutNERC/Pages/Rules-of-Procedure.aspx

http://www.ferc.gov/whats-new/comm-meet/2007/031507/e-13.pdf


http://www.nerc.com/pa/Stand/Pages/Project-2015-04-Alignment-of-Glossary-of-Terms-(NERC-Reliability-Standards-and-the-Rules-of-Procedure).aspx

Similarly, FERC approved the ROP, which contained a number of FERC-approved defined terms. Later, in 2011, as a result of a 2010 Commission Order inviting NERC to submit a filing making consistent use of defined terms throughout the ROP and Appendices, NERC petitioned to move all of the defined terms contained in the various sections and Appendices of the ROP into one central location, Appendix 2 to the ROP. See, FERC Order Conditionally Approving Amendments to the ROP. As outlined by NERC in the petition, “the purposes of the proposed revisions are (1) to place all definitions of defined terms used anywhere in the ROP in a single, readily accessible location; (2) to capitalize defined terms throughout the ROP where such terms are intended to be used in their defined meanings; and (3) to lower-case other terms that are currently capitalized in the ROP but are not defined terms.” See, NERC Petition, p. 4.

Following FERC’s approval of the Glossary and Appendix 2 to the ROP, there have been a number of revisions to the defined terms. However, the revision processes for the Glossary and ROP are separate and distinct. Glossary terms are revised through the Reliability Standards development process (see, Section 5 of the Standards Process Manual); whereas ROP terms are revised through the ROP revision process (see, Section 1400 of the ROP). As a result of various changes made to defined terms over the years through these distinct revision processes, a number of cross-over terms, which were once identical, now contain differences in their definition narratives. Project 2015-04 purpose, scope and objectives As indicated above, the Standards Authorization Request (SAR) provides that the project purpose is to (1) align the existing cross-over terms, and (2) develop recommendations regarding how to enhance the current definition development processes in the Standards Process Manual and ROP to prevent misalignment or inconsistencies during future development of defined terms. Phase 1 work. In April 2015, the drafting team began the Phase 1 work. The drafting team first identified all cross-over terms, and then compared the Glossary and ROP definitions to determine which definitions were not identical or “aligned.” There were a total of 55 cross-over terms, and of those terms, 40 contained definitional differences and were not aligned. For the 40 cross-over terms that were not identical, the team identified common issues and categorized the terms into “groups” based upon the type of alignment issue (e.g., substantive differences, capitalization, errata). Over one-fourth of the cross-over terms had substantive definitional differences, and over half of the definitions were not aligned on capitalization (indicating use of a NERC defined term). To achieve consistency and alignment of the cross-over terms, the drafting team proposed revisions to 26 Glossary terms and 16 ROP terms. In September 2015, all 26 Glossary terms received industry approval through the formal balloting process. Additionally, the industry was supportive of the proposed revisions to the 16 ROP terms. Thereafter, all Glossary and ROP revisions were adopted by the NERC Board of Trustees in November 2015. Recently, in January 2016, FERC approved the proposed Glossary and ROP revisions. See, FERC Letter Order Approving Revised Definitions (Docket No. RD-16-3-000) and FERC Letter Order Accepting ROP Revisions (Docket No. RM15-14-000). It is important to note that prior to proposing revisions to the cross-over terms, the drafting team undertook substantial background research to determine whether alignment revisions were appropriate, including an examination of the history of the term’s definition, previous drafting teams’ intent, relevant NERC filings to FERC, and any FERC orders approving the definition. Additionally, the drafting team examined how each term is used in the Glossary, Reliability Standards, and ROP provisions. Based on this thorough examination, the drafting team determined whether alignment revisions were appropriate. For a comprehensive overview of the Phase 1 “groupings” and research conducted by the drafting team for each cross-over term under revision,

Project 2015-04 – Alignment of Terms Phase 2 Recommendations March 2016 Page 2 of 39

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/ROP_Order_Cap_Project_20120131.pdf

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/NERCPetAppRevROPDefCap11-29-2011.pdf

http://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/Appendix_3A_StandardProcessesManual_20130626.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Letter%20Order%20Approving%20Revised%20Definitions%20of%20Terms.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Letter_Order_ROP_20160121_RR16-2.pdf


please see the “Summary of Proposed Revisions to Align Cross-Over Terms” document posted on the project page. Phase 2 work. During completion of Phase 1, the drafting team identified a number of issues with inconsistency and the quality of the definitions of certain terms found in the ROP and Glossary. As part of Phase 2 of the project, and in support of the second purpose statement above, the drafting team developed five (5) recommendations related to enhancement of the current definition development processes. Also, the recommendations address the inconsistency and quality issues identified during Phase 1. The team believes implementation of the recommendations will allow for future development of high-quality definitions that are drafted in a clear, consistent and uniform manner.

Part III. Drafting Team Recommendations Recommendation No. 1: Cross-over terms should be defined identically in the Glossary and ROP Issue statement: A number of cross-over terms are not defined identically in the Glossary and ROP. Definitional differences between the Glossary and ROP cause industry confusion and may result in multiple interpretations of the same term or function, leading to miscommunication or jeopardizing reliability. Recommendation: Cross-over terms should be defined identically in the Glossary and ROP to provide for industry-wide continuity in the application of definitions and to eliminate multiple interpretations of the same term or function. It is recommended that once a term is designated as a “cross-over term,” the definition of the term should be identical in the Glossary and ROP. Special rules should be created for development of cross-over terms to ensure that revisions to the term result in aligned and identical definitions in both the Glossary and ROP. In very limited circumstances, it may not be possible to develop a single definition for a cross-over term. The special rule should identify the limited circumstances when it is acceptable for a cross-over term to be defined differently in the Glossary and ROP. Background and Observations of the Drafting Team: During Phase 1 of this project, the drafting team identified a total of 55 cross-over terms, 40 of which contained differences and were not aligned. The drafting team undertook substantial research to determine how the inconsistencies or differences came about. For the overwhelming majority of cases, the research revealed that the cross-over definitions were originally identical or aligned, but subsequent revisions were made to only one definition. For example, a number of Glossary definitions were adopted in the ROP when Appendix 2 was created in 2012. These definitions are marked with a double asterisk (**) to indicate they were taken from the Glossary. However, when revisions were later made to a number of Glossary definitions, the ROP definitions were not revised to reflect the updated Glossary language. This situation arises out of the fact that defined terms are developed or revised according to separate and distinct processes. Defined terms in the Glossary are developed through the revision process outlined in the ROP, Appendix 3A: Standards Process Manual (SPM), which does not require consideration of, or alignment with, an existing ROP definition of the same term. Likewise, defined terms in the ROP are developed through the ROP revision process, which does not require consideration of, or alignment with, an existing Glossary definition of the same term. For example, the term “Interconnection” is a cross-over term found in both the Glossary and ROP. Recently, the Glossary definition of this term was revised through the revision process


http://www.nerc.com/pa/Stand/Project201504AlignmentofGlossaryofTermsNERCRSRPDL/Project_2015-04_Summary_of_Proposed_Revisions_to_Align_Definitions_in_the_Glossary_and_ROP_06102015.pdf

outlined in the SPM during Project 2010-14.1 Phase 1 of Balancing Authority Reliability-based Controls: Reserves.2 However, no corresponding change was made to the definition of “Interconnection” in the ROP. The separate and distinct development processes for Glossary definitions and ROP definitions are described below. Overview of the Existing Development Process for Glossary definitions: In general, the development process for Glossary definitions follows the same process in place for Reliability Standards, which is found in Section 300 of the ROP. From a high-level perspective, this process includes three phases for developing or revising Glossary definitions:

(1) Procedural Phase: during this phase, drafting team develops or revises the definition and then submits it for approval by a ballot pool;

(2) Board Adoption Phase: during this phase, the NERC Board of Trustees decides whether to adopt the new or revised definition; and,

(3) Governmental Approval Phase: during this phase, NERC files the new or revised definition with FERC or the Applicable Governmental Authority for final approval.

The details of these three phases are illustrated on the following page, in Figure 1:

2 The Project 2010-14.1 webpage can be found here. Notably, the definition of “Interconnection” was revised in both the Glossary and ROP for alignment purposes during Phase 1 of Project 2015-04 Alignment of Terms. Project 2015-04 – Alignment of Terms Phase 2 Recommendations March 2016 Page 4 of 39

http://www.nerc.com/pa/Stand/Pages/Project2010-14-1-Phase-1-of-Balancing-Authority-RBC.aspx

Figure 1. Process for Developing or Modifying a Reliability Standard (including Glossary definitions). See,

Section 4.0 of the Standards Process Manual. Overview of the Existing Development Process for the ROP: In contrast to the standards development process, the amendment process for the ROP is found in Article XI, Section 2 of the NERC Bylaws and Section 1400 of the ROP. This process, which is more streamlined than the process for developing Reliability Standards or Glossary definitions, is illustrated in Figure 2 (on the following page):


STEP 8: Submit Reliability Standard/Definition and Implementation Plan to BOT for Adoption and Approval


10 day period


If significant changes are needed to the Draft Reliability Standard/Definition then conduct Additional Ballot(Repeat Step 5)

STEP 5: Comment Period and Ballott

Form Ballot Pool During First 30 calendar days of 45-day Comment Period Conduct Ballot During Last 10 Days of Comment Period Conduct Non-Binding Poll of VRFs and VSLs


STEP 3: Develop Draft of Standard/Definition, Implementation Plan and VRFs and VSLs

Form Drafting Team If needed, conduct Field Test of Requirement Conduct Quality Review Collect Informal Feedback


STEP 1: Project Identified in Reliability Standards Development Plan or initiated by the Standard Committee

Draft SAR


Figure 2. Process for Modifying the NERC Rules of Procedure (including Appendix 2 definitions). See, Section

1400 of the Rules of Procedure. The two separate and distinct development processes are required because the Reliability Standards, including the applicable definitions found in the Glossary, and the ROP are two separate documents serving two distinct purposes. Consequently, there may be situations in which the definition of a term in the Glossary may not be appropriate or workable in the context in which that term is used in the ROP, and vice-versa.3 In such cases, it may be necessary for the term to be defined differently in each document. Therefore, maintaining these two separate and distinct development processes ensures that each term is defined in accord with the context in which that term is used in each document. Justification for Coordination between these Two Development Processes: As noted above, these two separate and distinct development processes are necessary. Nevertheless, they may result in a situation where a cross-over term could be needlessly defined differently or inconsistently. Therefore, the drafting team believes that these two processes should be coordinated when a cross-over term is under revision. The substantive details of this coordination, including the timing of coordinated efforts, are described below. Discussion: A majority of the drafting team believes that the ROP and Glossary development processes should run concurrently or in a parallel manner. Every best effort should be made to undertake the revision process to

3 See NERC Petition for Approval of Revision to the Rules of Procedure of the North American Electric Reliability Corporation, Docket No. RR12-000, Nov. 29, 2011, at p. 26.


STEP 4: Submit Proposal to BOT for Approval


If significant changes are needed to the Proposal then Repeat Step 2

STEP 2: Proposal posted on the NERC website for 45-day public comment period

STEP 1: Proposal for amendment submitted to NERC Board by any one of the following groups or individuals

The Member Representatives Committee Any 50 members of NERC, which shall include members in at least three sectors

A committee of NERC to whose purpose and functions the ROP pertains An officer of NERC



allow for completion of the revisions at the same time or in a similar time frame. For cross-over terms, NERC Board of Trustees (Board) approval should be sought after revisions are made to both the ROP and Glossary definitions, and the definitions are identical. For example, a drafting team seeking to modify a cross-over term would be required to undertake identical modifications to both the Glossary definition and the ROP definition. In order to achieve this desired result, changes would be required to the definition revision processes outlined in the ROP and SPM. In short, if a revision to the definition of a cross-over term is deemed necessary during a Standards development project or a ROP amendment project, the individual(s) or team responsible for the primary project must simultaneously initiate the revision process in the other source, so that ultimately, the Board can review and adopt the definition revisions to both the Glossary and ROP at the same time. For example, if a drafting team determines that it must revise the definition of a cross-over term to complete its project, the drafting team must not only draft and obtain industry approval of the proposed Glossary revisions, but also obtain a qualified sponsor to submit a proposal for a corresponding change to the ROP definition. As part of the process, the drafting team would collaborate with NERC staff (including NERC legal staff) to ensure that the revised definition is appropriate for use in the ROP, and that all required ROP processes are followed. The drafting team has illustrated these suggested process changes in Attachment 1.4 Recommendation No. 2: Definitions should be written in a consistent and uniform manner Issue statement: Definitions contained in the Glossary and ROP are not written in a consistent and uniform manner. Lack of consistency in word usage, sentence structure, style, grammar, punctuation, and formatting creates unnecessary complication and causes industry confusion. Recommendation: All Glossary and ROP definitions should be written in a clear, consistent and uniform manner. NERC defined terms should be precise and easy to understand to allow for consistent continent-wide application. A “definition manual” should be created for the purpose of outlining the proper approach for development and construction of all NERC definitions. Background and Observations of the Drafting Team: During Phase 1 of the project, the drafting team and industry identified the following consistency or uniformity issues:

1. Word, number and unit usage a. inconsistent or incorrect use of defined term - e.g., Bulk Electric System (BES) vs. Bulk Power

System (BPS); Real-time vs. real-time in Dynamic Interchange Schedule & Dynamic Transfer b. interchangeable defined terms - e.g., Special Protection System (SPS) and Remedial Action

Scheme (RAS); Planning Coordinator (PC) and Planning Authority (PA)

4 A minority view of the drafting team is that concurrent development of a cross-over term is not necessary, but instead alignment could be achieved by sequential use of the existing revision processes in the ROP and Glossary. In short, an individual or team seeking to modify a cross-over term would be required to first obtain Board approval for the revision in the initial source document, and then initiate the revision process in the second source. For example, if a drafting team determines that a revision to the Glossary definition of a cross-over term is necessary during its project, the drafting team would follow the current revision process in the SPM; once the revision is approved by the Board, the drafting team would then initiate the revision process for the ROP definition by obtaining a qualified sponsor to submit the proposed ROP amendment. The drafting team would then be responsible for carrying the ROP amendment process through to the end. This approach would allow for more flexibility and efficiency in the revision process when it is required. For example, if a change was needed to the Glossary definition of a cross-over term in order to accommodate a new or revised Standard with an effective date in the near future, the drafting team would have the flexibility to proceed first with the Glossary revision to ensure that the change would be approved by the effective date, and then subsequently undertake the ROP amendment process to align the definitions at a later date. Project 2015-04 – Alignment of Terms Phase 2 Recommendations March 2016 Page 7 of 39

c. consecutive use or placement of two (or more) defined terms - e.g., “Transmission” “Element” vs. “Transmission Element”

d. inconsistent references to both the singular and plural version of term - e.g., Facility(ies) e. inconsistent references to units of measurement and time - e.g., kVar vs. kvar; Mvar vs. MVAr

2. Sentence structure and formatting a. inconsistent approach to defining functional entities - e.g., “the entity that…” b. inconsistent types of information or content included in definition

i. a formal definition contains three parts: (1) the term to be defined, (2) the class or object or concept to which the term belongs; and (3) the differentiating characteristics that distinguish it from all others in its class.

ii. a number of Glossary terms contain only a conceptual definition; others contain an illustration or even actual application of the definition in the definition itself. E.g.:

1. Interconnection (first sentence contains the definition; followed by second sentence with definition application)

2. Special Protection System and System Operating Limit (contain an additional parenthetical sentence or illustrative listing but the definition is unclear if it is intended to be an exhaustive listing)

c. inconsistent use of adjective splitting - e.g., Real and Reactive Power vs. Real Power and Reactive Power

d. inconsistent use of sentence structure and usage of lists - e.g., bulleted vs. numbered 3. Grammar

a. inconsistent use of active vs. passive voice b. definitions should be written to provide a positive expression or clarification of what the term

is intended to mean; definitions should not define the term in the negative c. define nouns with nouns

4. Punctuation /Capitalization a. terms are improperly capitalized – (i.e., terms should be capitalized when it is a NERC defined

term, proper noun, or the first word of a sentence) (e.g., definition of ATC Path – “Posted Path” is capitalized but it is not a NERC defined term) See, Recommendation No. 3.

b. inconsistent usage of commas, colons, semicolons, hyphens c. inconsistent usage of quotation marks to offset a term – e.g., “wires” in definition of

Distribution Provider Through the course of its research and work on this project, the drafting team identified multiple resources that serve to provide “guidance” to drafting teams in their development of standards and defined terms. See, for example, the “Drafting Team Reference Manual.” However, these resources provide little to no detail regarding what type of information should be included in a high-quality, clearly defined term. Instead, the resources focus on the conditions under which it is appropriate for a team to develop a new defined term or revise an existing term. For example, with regard to definition development, the Drafting Team Reference Manual provides as follows:

1) A definition is a single phrase that can replace the term wherever used. It should not take the form of, or contain, a requirement or recommendation;

2) When a term can be defined with a small number of words, it may make sense to just use those words in the requirements, rather than creating a new defined term. In such cases, the DT should consider using the phrase rather than trying to obtain stakeholder consensus on the new term;

3) If a term is used in a standard and the term is defined in a collegiate dictionary, then there is no need to also include the term in the Glossary of Terms Used in NERC Reliability Standards.


http://www.nerc.com/pa/Stand/Resources/Documents/DT_Ref_Manual_092614_final.pdf

4) DTs may decide to create a new defined term when the same term would be used repeatedly within a standard or group of standards, and defining the term would improve the clarity of the standards. (this can only be done if the term doesn’t meet the requirements in #2). See, Drafting Team Reference Manual, pp. 16-17.

Discussion: During the course of its work on this project, the drafting team identified a number of problematic inconsistency and uniformity issues with definition drafting and construction. These issues cause industry confusion regarding the intended meaning or application of a number of defined terms. As previously indicated, for those currently charged with drafting a defined term, there is no authoritative resource or instruction manual that provides detailed information or instruction regarding any of the quality and consistency issues identified above. As a result, various teams (or individuals) draft definitions guided by their own personal preferences or styles. The drafting team therefore recommends development of a “definition manual” for the purpose of outlining the proper approach for development and construction of all NERC definitions. The manual could be developed by a team of NERC, regional and industry staff – as the NERC-defined terms are used by everyone. The intended audience/user of the manual would be primarily drafting teams and NERC in the development of all NERC-defined terms (i.e., both ROP and Glossary definitions). However, the manual could also serve as a useful resource for committees or working groups to the extent it is necessary to develop a definition for a report, white paper or otherwise. The manual should address the fundamental parts or type of information that should be included in the definition. The manual should provide instruction regarding all of the consistency and uniformity issues identified above. Recommendation No. 3: Correct and consistent use of capitalization to indicate a NERC defined term Issue statement: Capitalization of a term indicates that it is a NERC-defined term and has been assigned a specific meaning. Therefore, capitalization of (or failure to capitalize) a defined term has great significance and should occur only when the term is intended to have the NERC-defined meaning. Currently there are a number of significant capitalization issues within the text of Reliability Standards, Glossary definitions and ROP definitions, including (1) capitalization of terms that are not NERC-defined terms; (2) failure to capitalize a term when it has the definitional meaning; and, (3) capitalization of a term that is a defined term, but should not be capitalized because it does not have the intended definitional meaning. Recommendation: Use of capitalization to indicate a term has the NERC-defined meaning should be applied consistently and correctly throughout the Reliability Standards and definitions. In Recommendation No. 2, the team proposed the development of a definition drafting manual. The manual should identify criteria for a drafting team to use when determining whether to capitalize a term. Additionally, once the definition manual is developed and available for use, an effort should be undertaken to conduct a comprehensive review of the Reliability Standards, Glossary definitions and ROP definitions, for the purpose of uniformly applying the criteria and correcting any existing capitalization issues or errors. Discussion: During Phase 1 of this project, the team identified hundreds of capitalization issues contained in the Reliability Standards, Glossary and ROP. Due to the limited scope of the project, the team was able to propose revisions to address the capitalization issues only if it involved alignment of a cross-over term. Thus, a number of capitalization issues continue to exist, and should be corrected. The types of capitalization issues include: (1) capitalization of terms that are not NERC-defined terms; (2) failure to capitalize a term when it has


the definitional meaning; and, (3) capitalization of a term that is a defined term, but should not be capitalized because it does not have the intended definitional meaning. The “definition manual” (see, Recommendation No. 2) should include a section that outlines the rules for when it is appropriate to use capitalization, specifically when the word is: a NERC-defined term, a proper noun, or appears at the beginning of a sentence. After the “definition manual” is created, a team should be assembled for the purpose of conducting a comprehensive review of all existing Reliability Standards, Glossary definitions and ROP provisions to identify and address all capitalization errors. Recommendation No. 4: Eliminate all standard-only or section-only definitions Issue statement: There are a number of NERC “defined terms” that exist outside of the Glossary and ROP, Appendix 2, including, standard-only definitions (e.g., PRC-005-6), ROP section-only definitions (e.g., Section 1501), and informal or unofficial definitions (e.g., within the footnote of a Reliability Standard) (hereinafter collectively referred to as “stand-alone definitions”). These stand-alone definitions cause great industry confusion because the scope of the definition’s applicability is not always clear, the definitions are difficult to locate, and in some instances, the stand-alone definition is improperly used in other resources despite the fact that it is not an approved continent-wide definition. Recommendation: NERC should discontinue the use of stand-alone definitions, and instead require that all NERC “defined terms” are contained in the Glossary, ROP, or both.5 All existing stand-alone terms should be moved to the Glossary, Appendix 2 of the ROP, or both (as appropriate). Alternatively, if the practice of allowing stand-alone definitions is continued, these definitions should be included in the continent-wide resources with a notation that it is a standard-only or section-only defined term. Background and Observations of the Drafting Team: As part of the work undertaken in this project, the drafting team identified a number of standard-only definitions contained in various Reliability Standards. These standard-only definitions are not included or repeated in the continent-wide Glossary. See, for example, PRC-005-6, with seven standard-only definitions (Automatic Reclosing, Component Type, Component, Countable Event, Sudden Pressure Relaying, Unresolved Maintenance Issues, Segment) that are not included as part of the continent-wide Glossary. Also, the team noted that some ROP sections and appendices contain a “Definition” section, while others do not. See, for example, Section 1500; Appendix 4E – CCC Hearing Procedures; Appendix 5A – Organization Registration and Certification Manual; and, Appendix 5C – BES Exception Procedure. The ROP sections and appendices containing a “Definitions” section repeat the definition found in Appendix 2; however, it is unclear why certain ROP sections contain a designated “Definition” section, while others do not. The lack of uniformity causes confusion and may be mistaken to mean that the definition has a special or different meaning than the Appendix 2 definition. Additionally, the drafting team identified a number of other informally defined terms contained in other widely-used NERC resources, such as the Functional Model and Drafting Team Reference Manual. During the Phase 1 work for this project, the drafting team received a number of industry comments indicating a strong dislike for stand-alone definitions. Commenters indicated that the stand-alone definitions are difficult

5 If the defined term is used in the Reliability Standards and ROP, then it should be defined in both the Glossary and ROP, Appendix 2. If the defined term is used only in the Reliability Standards, and not in the ROP, then the term should only be defined in the Glossary. Likewise, if the defined term is only used in the ROP, and not the Reliability Standards, then it should be defined only Appendix 2 of the ROP. Project 2015-04 – Alignment of Terms Phase 2 Recommendations March 2016 Page 10 of 39

to locate, easy to overlook, and in some instances may be duplicative of, or in conflict with, other continent-wide defined terms. There is overwhelming support for eliminating stand-alone definitions and instead housing all NERC defined terms in certain designated resources (i.e., either the Glossary or Appendix 2, or both). Additionally, a commenter pointed out that, while unlikely, there is a possibility that two inconsistent or different standard-only definitions could be developed for the same term, but for different standards. For instance, if there is an existing standard-only definition for a particular term, a drafting team would not be precluded from developing a second standard-only definition (for a different standard) if the team wanted to define the term differently. Discussion: The drafting team recommends discontinuing the use of stand-alone definitions. Instead, all NERC “defined terms” should be contained in certain designated resources, such as the Glossary and Appendix 2 of the ROP. For the reasons outlined above, stand-alone definitions cause unnecessary confusion and create the potential for inconsistent or differing use or application of a defined term. The team recommends that an effort is undertaken, possibly by NERC staff (or if necessary, by a drafting team), to move all existing stand-alone definitions to the continent-wide Glossary or Appendix 2, or both. Alternatively, if the practice of allowing stand-alone definitions is continued, these definitions should be included in the continent-wide resources with a notation that it is a standard-only or section-only defined term with limited applicability. Recommendation No. 5: Revise existing definitions that are lacking in quality, content, technical accuracy or are not reflective of how the industry currently uses the term Issue statement: A number of the definitions in the Glossary and ROP are lacking in quality, content, technical accuracy or are not reflective of how the industry uses the term today. Over 180 of the definitions are “Version 0” definitions, and have never been revised or assessed as part of a periodic review since FERC approved the definitions. See, FERC Order No. 693. Additionally, there are a number of defined terms in the Glossary and ROP that are no longer used in any Reliability Standard or ROP provision. Recommendation: It is extremely important that NERC definitions are high-quality, technically sound, and sufficiently clear such that the definition can be easily understood and applied by the industry in a consistent and correct manner. To achieve this, the drafting team recommends as follows: First, in order to fix the current state of things, a team should be established to conduct a comprehensive review of the current Glossary and ROP definitions. The definitions should be reviewed (and revised, as needed) for quality, content, technical accuracy, and to ensure that the definition is well-suited for current day industry usage. Also, the review team should identify those defined terms that are no longer used in any Reliability Standards or ROP provisions, and determine whether it is appropriate to retire the definition. Second, the SPM should be revised to include a periodic review for definitions, similar to the periodic review undertaken for all Reliability Standards. To address this issue, NERC could include a requirement that, when a periodic review team undertakes the review of a Reliability Standard, the team must also conduct a periodic review of any defined term(s) contained in any of the requirements of the Reliability Standard. As noted above, a large majority of the defined terms in the Glossary are Version 0 terms and have not been assessed or reviewed for quality since 2007, when FERC initially approved the Glossary. Lastly, through the Phase 1 work undertaken by the drafting team, and based upon comments received from the industry, the drafting team identified four Glossary definitions that it is recommending for immediate revision, specifically: Facility, Interconnection, Load, and Net Energy for Load. Included as Attachments (2) through (5) are the Standards Authorization Requests (SARs) that will be submitted through the NERC SAR-submittal process.


Background and Observations of the Drafting Team: As noted above, the drafting team believes that many of the definitions contained in the Glossary and ROP are either unclear, incorrect, or outdated. As recognized in the introduction section of the Glossary:

Most of the terms identified in [the] [G]lossary were adopted as part of the development of NERC’s initial set of reliability standards, called the “Version 0” standards. Subsequent to the development of Version 0 standards, new definitions have been developed and approved following NERC’s Reliability Standards Development Process, and added to this [G]lossary following board adoption, with the “FERC approved” date added following a final Order approving the definition.6

The drafting team determined that at least 187 definitions out of 300 definitions within the Glossary have not been revised since the original 2007 effective date of the Glossary. In addition, several definitions have the effective date of 2008. Further, a number of defined terms are no longer used in any of the Reliability Standards. For example, “Fire-Risk” is defined, however, not used in any current Reliability Standard. Discussion: To address these issues, the drafting team recommends the following four-step action plan: First, the Standards Committee should establish a team (drafting team or otherwise) to conduct a comprehensive review of the current Glossary and ROP definitions. The team should review the definitions (and revise, as needed) for quality, content, technical accuracy and to ensure that the definition is well-suited for current industry usage. Also, the team should identify those defined terms that are no longer used in any Reliability Standards or ROP provisions, and determine whether it is appropriate to retire the definition. In addition, the team should add definitions to the Glossary where necessary. Second, the SPM should be revised to provide for a periodic review for Glossary definitions, similar to the periodic review undertaken for all Reliability Standards. This action could be accomplished by requiring that, when a periodic review of a standard is undertaken, the team must also conduct a periodic review of any defined terms that are contained in that particular Reliability Standard. Third, a drafting team should be assigned the task of addressing the four SARs submitted by the Project 2015-04 drafting team. As mentioned above, during the course of its Phase 1 work, and largely based upon comments received from the industry in undertaking the Phase 1 work, the drafting team identified four Glossary definitions that are recommended for immediate revision; specifically: Facility, Interconnection, Load, and Net Energy for Load. Included for convenience (as Attachments 2 through 5) are the SARs that will be submitted through the NERC SAR-submittal process.

Part IV. Conclusion The Project 2015-04 team respectfully submits these recommendations to the Standards Committee and NERC staff for their consideration. The team believes that implementation of the five recommendations will allow for future development of high-quality definitions that are drafted in a clear, consistent and uniform manner.

6 Glossary of Terms Used in the NERC Reliability Standards, click here. Project 2015-04 – Alignment of Terms Phase 2 Recommendations March 2016 Page 12 of 39


ATTACHMENT 1


Coordinated Cross-Over Term Definition Development Process

Step 1

•Revision to definition of cross-over term deemed necessary in either Glossary or ROP project•If SDT already working on project, then revise definition•If no SDT is in place, draft SAR for revision to Glossary definition•Obtain qualified sponsor(s) to submit proposal for amended ROP definition to NERC Board

Step 2•Post SAR for 30-day informal comment period

Step 3

•Develop Draft of Glossary Definition and Implementation Plan •Conduct Quality Review•Consult with NERC staff regarding proposed revisions to the ROP term

Step 4•Obtain Standards Committee Approval to Post Glossary Definition for Comment and Ballot

Step 5

•Comment Period and Ballot (45-day Comment Period for ROP runs concurrently with Glossary Comment Period)•Post ROP definition to NERC website for industry comment•Form Ballot Pool for Glossary Definition During First 30 calendar days of 45-day Comment Period•Conduct Ballot for Glossary Definition During Last 10 days of Comment Period

•If significant changes are needed to the draft Glossary Definition then conduct Additional Ballot

Step 6•Post Responses to Comments on both Glossary and ROP definitions

Step 7•Conduct Final Ballot for Glossary definition (10 day period)

Step 8•Submit Glossary Definition, Implementation Plan, and ROP amendment to Board for Adoption

Step 9•Submit all Board-approved documents (both Glossary and ROP documents) to Applicable Governmental Authorities for

approval


ATTACHMENT 2




Request to propose a new or a revision to a Definition

Title of Proposed Standard: Definition of Interconnection

Date Submitted: March 9, 2016

SAR Requester Information

Name: Project 2015-04 – Alignment of Terms Drafting Team

Telephone: Jerry Rust (chair): 503-816-8977

Chris Scanlon (co-chair): 847-721-8197 Email: [email protected]


New Standard

Revision to Existing Definition


Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Interconnection is, “A geographic area in which the operation of Bulk Power System components is synchronized such that the failure of one or more of such components may adversely affect the ability of the operators of other components within the system to maintain Reliable Operation of the Facilities within their control. When capitalized, any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec.”

The Glossary definition of Interconnection should be revised because it is ambiguous, overly broad, subject to multiple interpretations, and technically incorrect. The drafting team received a large number of industry comments requesting revisions to the definition. Below are examples of industry comments received:

Industry comment: The current definition is overly-broad because temporarily islanded areas would meet this definition despite the fact that they are not meant to be included. Second, the quoted portion of the current definition is imprecise because it fails to capture the concept that Interconnections operate asynchronously from

When completed, please email this form to: [email protected]




SAR Information

one another. In other words, the accurate distinction between Interconnections is that they operate asynchronously from one another. Industry comment: With the use of Bulk Power System and to maintain Reliable Operation of the Facilities in the same sentence, the Project Team is sending mixed signals. The term “Facility” is directly related to the BES definition where the Bulk Power System includes the distribution of energy to end use customers, mostly outside the scope of the NERC Reliability Standards.

Industry comment: We agree with the first part of the proposed addition to clarify the synchronized operation condition but not the qualifier on the reliable operation part, which is the fundamental objective of the Reliability Standards but not required to describe an Interconnection. We therefore suggest the definition be stated as: “A geographic area in which the operation of Bulk Power System components is synchronized. When capitalized, any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec.”

Industry comment: Within an Interconnection, Elements and resources may be operated asynchronously as well. We propose: "The System of Bulk Power System components that are operated asynchronously to other Systems of Bulk Power System components."

Industry comment: Commenter proposes not to align the ROP and the NERC Glossary definition of Interconnection since Bulk Power System components can be asynchronous. We also propose not specifying in the definition, ‘When capitalized’. Commenter would like to include this term in Phase 2 so the SDT can create a more appropriate definition.

Industry comment: Concerned with the phrasing “When capitalized…” When defined terms are used in Reliability Standards, they are capitalized as an indication that the term is defined in the Glossary of Terms. By utilizing the caveat that the definition is specific “when capitalized” it could only ever be defined as “…any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec” in a Reliability Standard. Otherwise it would not be capitalized and therefore an undefined term in the Reliability Standard. Suggest removing “When capitalized” and identify specifically or rely on context when the four major electric system networks in North America are intended. Industry comment: This is a disjointed definition which makes little or no sense and needs to either be completely rewritten or dropped from the glossary altogether. The final phrase/sentence is just kind of hanging out there.

Industry comment: Commenter agrees with the first part of the proposed addition to clarify the synchronized operation as a defining characteristic of an Interconnection, but does not support the additional qualifiers regarding failures and reliable operation. These qualifiers are not essential to the definition of an Interconnection. It further suggests that, following consideration of the proposed modifications to the definition of Bulk Power System, use of the term Bulk Electric System is more appropriate. The commenter therefore suggests the definition be stated as: “A defined geographic area within which the operation of Bulk Electric System components is synchronized. When capitalized, any one of the four major electric system networks in


SAR Information

North America: Eastern, Western, ERCOT and Quebec.” To the extent that the SDT views this recommendation as a substantive change to the definitions, the commenter would request that this revision be addressed the later, proposed phases of this project or as noted below as part of specific standard revision processes.

Industry comment: Commenter suggests removing “such that the failure of one or more of such components may adversely affect the ability of the operators of other components within the system to maintain Reliable Operation of the Facilities within their control” and changing “Bulk Power System” to “Bulk Electric System.” Commenter believes the qualifier is not appropriate and the term BPS provides issues for entities outside the U.S.

Industry comment: Commenter is not opposed to the concept of the definition in the ROP. However, combining these two terms could be problematic because there are small hydro facilities that may be part of the Bulk Electric System that are operated at a different frequency and are asynchronous. By definition, these small hydro project would not be part of the Interconnection since they are not synchronized to the rest of the Interconnection. Industry commenter: Commenter questions why the words "such that failure of one or more of such components may adversely affect the ability of the operations of other components within the system to maintain Reliable Operation of the Facilities within their control" are needed after "synchronized". While this is a true statement there are facilities within each interconnection that probably don't affect the ability of the operations of other components but they are still within the interconnection. It seems like just stopping after "synchronized" and then including the second sentence would suffice.


The Glossary definition should be revised to address the issues outlined in the previous section.


Clear and consistent industry understanding and application of the definition of Interconnection. The term is used in 16 Glossary definitions and at least 35 times throughout the Complete Set of Reliability Standards.


Revise the definition of Interconnection to reflect the correct usage of the term as described in the Industry Need section. The definition must take into account the fact that Interconnections operate asynchronously from one another.


Revise the definition of Interconnection to reflect the correct usage of the term and take into account the fact that Interconnections operate asynchronously from one another. Also, revisions to the definition should address the


SAR Information

industry comments outlined above, and provide for a clear and consistent understanding and application of the term throughout the Reliability Standards.












Transmission Operator Ensures the real-time operating reliability of the transmission assets within a Transmission Operator Area.




Purchasing-Selling Entity Purchases or sells energy, capacity, and necessary reliability-related services as required.






1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to perform

reliably under normal and abnormal conditions as defined in the NERC Standards.

2. The frequency and voltage of interconnected bulk power systems shall be controlled within defined

limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected bulk power systems shall be

made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected bulk power systems shall be

developed, coordinated, maintained and implemented.

5. Facilities for communication, monitoring and control shall be provided, used and maintained for the

reliability of interconnected bulk power systems.

6. Personnel responsible for planning and operating interconnected bulk power systems shall be trained,

qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected bulk power systems shall be assessed, monitored and maintained on

a wide area basis.


Does the proposed Standard comply with all of the following Market Interface Principles? Enter (yes/no)

1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes

2. A reliability standard shall neither mandate nor prohibit any specific market structure. Yes


Yes


Yes

Related Standards


The term is used at least 35 times throughout the Complete Set of Reliability Standards and in 16 Glossary of Terms definitions.

Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Load, Facility, and Net Energy for Load.


Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A

Version History Version Date Owner Change Tracking 1 June 3, 2013 Revised



ATTACHMENT 3





Title of Proposed Standard: Definition of Load







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Load is, “An end-use device or customer that receives power from the electric system.”

The Glossary definition should be revised because it is lacking in quality, content, and is not reflective of how the Reliability Standards and industry use the term today. The definition should include a measurement of consumption, both instantaneous (Demand) and through time (energy). The current definition fails to include any component related to usage; but instead refers only to a customer or end-use device. The term Load, either capitalized or lower case is used in an inconsistent manner in at least 60 Glossary definitions and approximately 150 Reliability Standards.


The Glossary definition should be revised to address the issues outlined in the previous section. Also, an assessment should be undertaken to determine whether it is appropriate to align the Glossary and ROP definitions.





SAR Information


Clear and consistent use of the definition of Load will allow the Balancing Authorities to better balance Demand and resources, and allow for better planning in the real time, operational horizon, and long term horizon. Since the terms appears in at least 60 Glossary definitions and approximately 150 Reliability Standards, the industry must be clear and consistent in the use of the term.


Revise the definition of Load to reflect industry usage of the term as described in the Industry Need section.


Revise the definition of Load to reflect industry usage of the term, and address the need for clear and consistent use of the term throughout the Reliability Standards.




































a wide area basis.




Yes





Yes


Yes

Related Standards


The term “Load” appears in at least 60 Glossary definitions and approximately 150 Reliability Standards.

Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Net Energy for Load, Facility, Interconnection and Transmission Customer.

Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A





ATTACHMENT 4





Title of Proposed Standard: Definition of Facility







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Facility is, “A set of electrical equipment that operates as a single Bulk Electric System Element (e.g., a line, a generator, a shunt compensator, transformer, etc.)”

The Glossary definition of Facility should be revised because it is ambiguous, overly broad and subject to multiple interpretations. The drafting team received a number of industry comments requesting revisions to the definition. Below are examples of industry comments received:

Industry commenter: The definition of "Facilities" is ambiguous and in need of revision. Commenter recommends that the terms Generator Operator and Generator Owner be placed in Category 2 and remain unchanged until the definition of Facility is improved so the impacts of the change in definition can be better understood. Industry commenter: Considering the definition of Facility listed in the Glossary, a TOP operating a synchronous condenser or shunt compensator, which generates Mvars, could potentially qualify as





SAR Information

operating a “generating Facility”. Would the TOP therefore be under an obligation to register as a GOP? Even though Footnote 3 on page 6 preceding mentions that “the clarity and content of the current definition could be improved”, and a SAR will be drafted, this should be taken care of now under this project.

Industry commenter: Although we are in agreement with the alignment of terms with the ROP, we feel the term "Facilities" is too general or ambiguous when related to generation.

Industry commenters: Multiple commenters suggest clearly defining ‘Facilities’ to prevent the confusion from Transmission Operator (TOP) versus Generator Operator (GOP).

Industry comment: Inconsistent approach is used for referencing defined terms with different suffixes. For defined term "Facility", sometimes referenced as "Facilities" and other times "Facility(ies)."

Industry comment: For example, FAC-008-3: Facility Ratings stated purpose is “To ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles. A Facility Rating is essential for the determination of System Operating Limits.” Transmission Owners and Generator Owners need to be certain what the scope of their “Facility” is in order to correctly and accurately develop their Facility Ratings (“The maximum or minimum voltage, current, frequency, or real or reactive power flow through a facility that does not violate the applicable equipment rating of any equipment comprising the facility.”). The current definition of Facility with the inclusion of examples (e.g. a line, a generator, a shunt compensator, transformer, etc.) is open to interpretation and leads to confusion when Registered Entities develop their Facility Ratings.




Clear and consistent industry understanding and application of the definition of Facility. The term is used in at least 26 Glossary definitions and throughout the Complete Set of Reliability Standards.


Revise the definition of Facility.


Revise the definition of Facility to ensure that the term is defined in a manner that allows for consistent use and application of the definition throughout the Reliability Standards.























1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to

perform reliably under normal and abnormal conditions as defined in the NERC Standards.











7. The security of the interconnected bulk power systems shall be assessed, monitored and maintained

on a wide area basis.




Yes



Yes


Yes

Related Standards


The term is used in at least 26 Glossary definitions and throughout the Complete Set of Reliability Standards.


Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Load, Net Energy for Load, and Interconnection.

Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A




ATTACHMENT 5





Title of Proposed Standard: Definition of Net Energy for Load







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Net Energy for Load is, “Net Balancing Authority Area generation, plus energy received from other Balancing Authority Areas, less energy delivered to Balancing Authority Areas through interchange. It includes Balancing Authority Area losses but excludes energy required for storage at energy storage facilities.”

The ROP definition provides that, “Net Energy for Load” or “NEL” means net generation of an electric system plus energy received from others less energy delivered to others through interchange. It includes system losses but excludes energy required for the storage of energy at energy storage facilities.

The Glossary definition of Net Energy for Load should be revised because it is lacking in quality, content, and is not reflective of how the Reliability Standards and industry use the term today. The Glossary definition is specific to Balancing Authorities, while the use of the term within the Reliability Standards indicates the term could be applied to other entities, such as a Regional Entity, Transmission Operators, Transmission Planners and others.





SAR Information

Additionally, the Glossary definition is substantially different than the definition provided in Appendix 2 of the NERC Rules of Procedure (ROP). The Glossary definition is very specifically limited in application, whereas the ROP definition is not.

The definition should be revised to eliminate confusion and ensure that the definition is well-suited for current day usage.




Clear and consistent industry understanding and application of the definition of Net Energy for Load. Net Energy for Load is used in multiple Reliability Standards (e.g., MOD-016-1.1, MOD-017-0.1, MOD-018-0, MOD-021-1, MOD-031-1) and one Glossary definition (Peak Demand).


Revise the definition of Net Energy for Load to ensure clear and consistent application and use of the term throughout the Reliability Standards.


Revise the definition of Net Energy for Load to eliminate confusion and ensure that the definition is well-suited for current day usage.


The Definition will Apply to the Following Functions (Check each one that applies.)






































Does the proposed Standard comply with all of the following Market Interface Principles? Enter

(yes/no)


Yes



Yes


Yes

Related Standards


MOD-016 This Reliability Standard uses the term Net Energy for Load.

MOD-017 See above.

MOD-018 See above.

MOD-031 See above.

Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Load, Facility, and Interconnection.

Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A


Regional Variances

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A




Phase 2 Recommendations Project 2015-04 – Alignment of Terms

Part I. Executive Summary The Standards Authorization Request of Project 2015-04 stated as a second goal:

Assess the current process(es) in place for development and maintenance of defined terms, and provide recommendations to the Standards Committee (SC) and NERC regarding changes or improvements to the existing definition development process(es) to allow for future development of defined terms that are consistent and aligned.

Thus, the purpose of these recommendations is to address this second goal.

Recommendation No. 1 for NERC: The Glossary and ROP should define cross-over terms identically

Recommendation No. 2 for NERC and SC: Definitions should be consistent and uniform

Recommendation No. 4 for NERC and SC: Eliminate all standard-only or section-only definitions

Recommendation No. 5 for NERC and SC: Revise existing definitions which lack quality, content, technical accuracy or do not reflect how the industry uses the term

Part II of this document provides relevant background information on the Glossary and ROP definitions and an overview of the purpose, scope and work the drafting team completed as part of Phase 1. Part III provides greater detail regarding each recommendation, including an issue statement, background information, observations, discussion and a proposal regarding how to address the issue. Finally, Part IV provides the drafting team’s conclusions.

Part II. Background Information

History of NERC Glossary and ROP definitions In 2007, FERC approved the NERC Glossary of Terms. See, FERC Order No. 693. In Order No. 693, FERC noted the importance of the defined terms in establishing a consistent understanding of the Reliability Standards’ Requirements and implementation. See, FERC Order No. 693 at P 1893. The NERC Glossary provides continuity in applying the definitions industry-wide and eliminates multiple interpretations of the same term or function.

Similarly, FERC approved the ROP, which also contained a number of defined terms.In 2011, NERC petitioned to move all the defined terms in the various sections and Appendices of the ROP into one central location, Appendix 2 to the ROP. See, FERC Order Conditionally Approving Amendments to the ROP. As outlined by NERC in the petition, “the purposes of the proposed revisions are (1) to place all definitions of defined terms used anywhere in the ROP in a single, readily accessible location; (2) to capitalize defined terms throughout the ROP where such terms are intended to be used in their defined meanings; and (3) to lower-case other terms that are currently capitalized in the ROP but are not defined terms.” See, NERC Petition, p. 4.

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Deleted: The purpose of Project 2015-04 is to: (1) align the existing defined terms in the NERC Glossary of Terms (Glossary) and NERC Rules of Procedure (ROP), and (2) develop recommendations for enhancing the current definition development process in the Standards Process Manual and ROP to prevent misalignment or inconsistencies during future development of defined terms.1 During Phase 1 of the project, the drafting team focused on aligningment of the existing definitions of “cross-over terms.”2 A ...

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Agenda Item 15bStandards CommitteeSeptember 14, 2016

http://www.ferc.gov/whats-new/comm-meet/2007/031507/e-13.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/ROP_Order_Cap_Project_20120131.pdf



Following FERC’s approval of the Glossary and Appendix 2 to the ROP, a number of defined terms have been revised. However, the revision processes for the Glossary and ROP are separate. Glossary terms are revised through the Reliability Standards development process (see, Section 5 of the Standards Process Manual); whereas ROP terms are revised through the ROP revision process (see, Section 1400 of the ROP). As a result of various changes made to defined terms over the years through these distinct processes, a number of cross-over terms, originally identical, now contain differences.

Project 2015-04 purpose, scope and objectives As indicated above, the Standards Authorization Request (SAR) states the project purpose as: (1) align the existing cross-over terms, and (2) develop recommendations regarding how to enhance the current definition development processes in the Standards Process Manual and ROP to prevent misalignment or inconsistencies during future development of defined terms.

Phase 1 work. In April 2015, the drafting team began the Phase 1 work by identifying all cross-over terms and comparing the Glossary and ROP definitions to determine which definitions did not “align.” The team identified a total of 55 cross-over terms and, of those terms, 40 did not align. For the 40 non-aligned cross-over terms, the team identified common issues and categorized the terms into “groups” based upon the type of alignment issue (e.g., substantive differences, capitalization, errata). Over one-fourth of the cross-over terms had substantive differences and over half differed on capitalization (indicating use of a NERC defined term). To achieve consistency and alignment of the cross-over terms, the drafting team proposed revisions to 26 Glossary terms and 16 ROP terms. In September 2015, all 26 Glossary terms received industry approval through the formal balloting process. Additionally, the industry supported the proposed revisions to the 16 ROP terms. Thereafter, the NERC Board of Trustees adopted all Glossary and ROP revisions in November 2015. In January 2016, FERC approved the proposed Glossary and ROP revisions. See, FERC Letter Order Approving Revised Definitions (Docket No. RD-16-3-000) and FERC Letter Order Accepting ROP Revisions (Docket No. RM15-14-000).

Prior to proposing revisions to the cross-over terms, the drafting team undertook substantial background research to determine whether alignment revisions were appropriate, including examining the history of the term’s definition, previous drafting teams’ intent, relevant NERC filings to FERC, and any FERC orders approving the definition. Additionally, the drafting team examined how each term is used in the Glossary, Reliability Standards, and ROP. Based on this thorough examination, the drafting team determined whether alignment revisions were appropriate. For a comprehensive overview of the Phase 1 “groupings” and research conducted for each cross-over term, please see the “Summary of Proposed Revisions to Align Cross-Over Terms” document posted on the project page.

Phase 2 work. During Phase 1, the drafting team identified issues with inconsistency and quality of the definitions of certain terms found in the ROP and Glossary. As part of Phase 2 and in support of the second purpose statement above, the drafting team developed two recommendations to: (1) enhance the current definition development processes and (2) address inconsistency and quality issues. The team believes implementing the recommendations will allow for developing high-quality definitions drafted in a clear, consistent and uniform manner.

Part III. Drafting Team Recommendations

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http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Letter%20Order%20Approving%20Revised%20Definitions%20of%20Terms.pdf





Recommendation No. 1: Define cross-over terms identically in Glossary and ROP Issue statement: The Glossary and ROP do not define a number of cross-over terms identically. Different definitions in the Glossary and ROP cause confusion and may result in multiple interpretations of the same term or function, leading to miscommunication. . Recommendation: The Glossary and ROP should define cross-over terms identically to provide continuity and eliminate multiple interpretations. Once a term is designated as a “cross-over term,” the definition of the term should be identical in the Glossary and ROP. NERC should consider creating either additional processes or use current processes in parallel for developing cross-over terms to ensure revisions of such terms are the same in the Glossary and ROP. In very limited circumstances, it may not be possible to develop a single definition for a cross-over term. The development of additional processes or the use of current processes in parallel should identify the limited circumstances when cross-over terms may be defined differently in the Glossary and ROP. In sum, we recommended that NERC consider either developing a new process that combines the Standards Process for cross-over definitions with the ROP process or run the two processes in parallel when a new definition is proposed. Background and Observations of the Drafting Team: During Phase 1, the drafting team identified 55 cross-over terms, 40 of which contained differences. The drafting team undertook substantial research to determine how the inconsistencies arose. For the overwhelming majority, the research revealed the cross-over definitions were originally identical or aligned but one term was subsequent revised. For example, a number of Glossary definitions were adopted in the ROP when Appendix 2 was created in 2012. Those definitions are marked with a double asterisk (**) to indicate they were taken from the Glossary. However, when revisions were later made to a number of Glossary definitions, the ROP definitions were not revised to reflect the updated Glossary language. The situation arises when defined terms are developed or revised in separate processes. Defined terms in the Glossary are developed through the revision process outlined in the ROP, Appendix 3A: Standards Process Manual (SPM), which does not require considering or aligning with, an existing ROP definition of the same term. Likewise, defined terms in the ROP are developed through the ROP revision process, which does not require considering or aligning with, an existing Glossary definition of the same term. For example, the term “Interconnection” appears in the Glossary and ROP. Recently, NERC revised the Glossary definition in Project 2010-14.1 Phase 1 of Balancing Authority Reliability-based Controls: Reserves.3 However, no corresponding change occurred in the definition of “Interconnection” in the ROP. To facilitate an understanding of the current processes, the separate development processes for Glossary definitions and ROP definitions appear below. Development Process for Glossary definitions: In general, the development process for Glossary definitions follows the same process as that of Reliability Standards found in Section 300 of the ROP. From a high-level perspective, this process includes three phases for developing or revising Glossary definitions:

(1) Procedural Phase: drafting team develops or revises the definition and submits for ballot approval;

3 The Project 2010-14.1 webpage can be found here. Notably, the definition of “Interconnection” was revised in both the Glossary and ROP for alignment purposes during Phase 1 of Project 2015-04 Alignment of Terms.

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Commented [b3]: BJM: define cross-over term; not ever “term” that is used in Std and ROP is necessarily a cross over term that needs to be defined identically ; only those terms are that to have the same meaning in the same context.

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(2) Board Adoption Phase: the NERC Board of Trustees decides whether to adopt the new or revised definition; and

(3) Governmental Approval Phase: The Applicable Governmental Authority decides whether to approve the definition.

Figure 1 illustrates the three phases:

Figure 1. Process for Developing or Modifying a Reliability Standard (including Glossary definitions). See, Section 4.0 of the Standards Process Manual.

Development Process for the ROP: The process to revise terms in the ROP appears in Article XI, Section 2 of the NERC Bylaws and ROP Section 1400. Figure 2 illustrates the process:


STEP 8: Submit Reliability Standard/Definition and Implementation Plan to BOT for Adoption and Approval


10 day period


If significant changes are needed to the Draft Reliability Standard/Definition then conduct Additional Ballot(Repeat Step 5)

STEP 5: Comment Period and Ballott

Form Ballot Pool During First 30 calendar days of 45-day Comment Period Conduct Ballot During Last 10 Days of Comment Period Conduct Non-Binding Poll of VRFs and VSLs


STEP 3: Develop Draft of Standard/Definition, Implementation Plan and VRFs and VSLs

Form Drafting Team If needed, conduct Field Test of Requirement Conduct Quality Review Collect Informal Feedback


STEP 1: Project Identified in Reliability Standards Development Plan or initiated by the Standard Committee

Draft SAR

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Figure 2. Process for Modifying the NERC Rules of Procedure (including Appendix 2 definitions). See, Section 1400 of NERC Rules of Procedure.

These separate processes can run in parallel or one may be conducted while the other is not conducted. Therefore, we recommended that NERC consider either developing a new process that combines the Standards Process for cross-over definitions with the ROP process or run the two processes in parallel when a new definition is proposed.

The drafting team has illustrated a hypothetical combined process in Attachment 1.5

5 A minority of the drafting team believes concurrently developing a cross-over term is not necessary and NERC could achieve alignment by sequential use of existing revision processes. In short, an individual or team seeking to modify a cross-over term would have to first obtain Board approval for the revision in the initial source document and then initiate the revision process for the second source, allowing more flexibility and efficiency in the revision process. For example, if a Glossary definition of a cross-over term required revising to accommodate a new or revised Standard with an effective date in the near future, the drafting team would have the flexibility to proceed first with the Glossary revision to ensure the change would be approved by the effective date and subsequently undertake the ROP amendment process to align the definitions at a later date.


STEP 4: Submit Proposal to BOT for Approval


If significant changes are needed to the Proposal then Repeat Step 2

STEP 2: Proposal posted on the NERC website for 45-day public comment period

STEP 1: Proposal for amendment submitted to NERC Board by any one of the following groups or individuals

The Member Representatives Committee Any 50 members of NERC, which shall include members in at least three sectors

A committee of NERC to whose purpose and functions the ROP pertains An officer of NERC

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Deleted: The two separate and distinct development processes are required because the Reliability Standards, including the applicable definitions found in the Glossary, and the ROP are two separate documents serving two distinct purposes. Consequently, there may be situations could exist wherein which the definition of a term in the Glossary may not be appropriate or workable in the context in which that term is used in the ROP, and vice-versa.4 In such cases, it may be necessary for each document to define the term to be defined differently in each document. Therefore, maintaining these two separate and distinct development processes ensures that each term is defined in accord with the term’s context in which that term is used in each document.¶

Deleted: Justification for Coordinationg between these Two Development Processes: As noted above, these two separate and distinct development processes are necessary. Nevertheless, they may result in a situation where a cross-over terms could be needlessly defined differently or inconsistently. Therefore, the drafting team believes NERC should coordinate that these two processes should be coordinated when revising a cross-over term is under revision. The substantive details of this coordination, including the timing of coordinated efforts, are described below.¶¶Discussion: A majority of the drafting team believes that the ROP and Glossary development processes should run concurrently or in a parallel manner. Every best effort should be made to undertake the revision process to allow for completiong of the revisions at substantially the same time or in a similar time frame. For cross- ...

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Recommendation No. 2: Definitions should be consistent and uniform; training; NERC and SC coordination Issue statement: Definitions in the Glossary and ROP sometimes lack consistency and uniformity in word usage, sentence structure, style, grammar, punctuation or formatting. Recommendation: All Glossary and ROP definitions should be clear, consistent and uniform. NERC-defined terms should be precise and easy to understand to allow for consistent continent-wide application. Capitalizing should indicate a term is defined and should be applied consistently and correctly throughout the Reliability Standards. In Recommendation No. 2, the team proposed creating a definition-drafting manual. The manual should identify criteria for determining whether to capitalize a term (specifically, when the word is a NERC-defined term, a proper noun, or appears at the beginning of a sentence). Additionally, once the definition manual is developed and available for use, NERC should conduct a comprehensive review of the Reliability Standards, Glossary definitions and ROP definitions to uniformly apply the criteria and correct any existing capitalization issues. To provide for greater consistency and uniformity, part of the training for drafting teams should include attention to definitions, and the NERC standards develop and Standards Committee Project Management and Oversight (PMOS) representative should work to facilitate the drafting teams work and attention to definitions, particularly cross-over definitions. For any cross-over definations, the NERC stndards developer and PMOS representative shall coordinate the creation or modification of the definition with NERC legal, so there may be concurrent changes to the ROP. NERC may also wish to create a “definition manual” to outline the proper approach for all NERC definitions. Background and Observations of the Drafting Team: During Phase 1, the drafting team identified the following consistency or uniformity issues:

1. Word, number and unit usage a. inconsistent or incorrect use of defined term - e.g., Bulk Electric System (BES) vs. Bulk Power

System (BPS); Real-time vs. real-time b. interchangeable defined terms - e.g., Special Protection System (SPS) and Remedial Action

Scheme (RAS); Planning Coordinator (PC) and Planning Authority (PA) c. consecutive use or placement of two (or more) defined terms - e.g., “Transmission” “Element”

vs. “Transmission Element” d. inconsistent references to the singular and plural version of term - e.g., Facility(ies) e. inconsistent references to units of measure and time - e.g., kVar vs. kvar; Mvar vs. MVAr

2. Sentence structure and formatting a. inconsistent approach to defining functional entities - e.g., “the entity that…” b. inconsistent types of information or content included in definition

i. a formal definition contains three parts: (1) the defined term, (2) the class or object or concept to which the term belongs; and (3) the differentiating characteristics distinguishing it from all others in its class.

ii. a number of Glossary terms contain only a conceptual definition; others contain an illustration or even actual application of the definition in the definition itself. E.g.:

1. Interconnection (first sentence contains the definition; followed by second sentence with definition application)

2. Special Protection System and System Operating Limit (contain an additional parenthetical sentence or illustrative listing but the definition does not state whether the list is exhaustive)


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c. inconsistent use of adjective splitting - e.g., Real and Reactive Power vs. Real Power and Reactive Power

d. inconsistent use of sentence structure and usage of lists - e.g., bulleted vs. numbered 3. Grammar

a. inconsistent use of active vs. passive voice b. definitions should be written to provide a positive expression or clarification of what the term

means; definitions should not define the term in the negative c. define nouns with nouns

4. Punctuation /Capitalization a. improper capitalization – (i.e., terms should be capitalized when defined, a proper noun, or the

first word of a sentence) (e.g., definition of ATC Path – “Posted Path” is capitalized but is not a NERC defined term) See, Recommendation No. 3.

b. inconsistent use of commas, colons, semicolons, hyphens c. inconsistent use of quotation marks to offset a term – e.g., “wires” in definition of Distribution

Provider The drafting team identified multiple resources providing “guidance” to drafting teams in developing standards and defined terms. See, for example, the “Drafting Team Reference Manual.” However, the resources provide little to no detail regarding what type of information should appear in a high-quality, clearly defined term. Instead, the resources focus on the conditions under which a team should develop a new defined term or revise an existing term. For example, with regard to definition development, the Drafting Team Reference Manual provides as follows:

1) A definition is a single phrase that can replace the term wherever used. It should not take the form of, or contain, a requirement or recommendation;

2) When a term can be defined with a small number of words, it may make sense to just use those words in the requirements, rather than creating a new defined term. In such cases, the DT should consider using the phrase rather than trying to obtain stakeholder consensus on the new term;

3) If a term is used in a standard and the term is defined in a collegiate dictionary, there is no need to also include the term in the Glossary.

4) DTs may decide to create a new defined term when the same term would be used repeatedly within a standard or group of standards and defining the term would improve the clarity of the standards (this can occur only if the term doesn’t meet the requirements in #2). See, Drafting Team Reference Manual, pp. 16-17.

5) Capitalizing a term indicates it is a NERC-defined term with a specific meaning. Therefore, capitalizing (or failing to capitalize) a defined term has significance and should occur only when the term has the NERC-defined meaning. Currently, a number of capitalization issues exist in the Reliability Standards, Glossary definitions and ROP definitions, including: (1) capitalizing terms not NERC-defined; (2) failing to capitalize a term when needed; and, (3) capitalizing a defined term which should not be capitalized because it does not have the intended definitional meaning.

Issue statement:

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Deleted: : During the course of its work on this project, Tthe drafting team identified a number of problematic inconsistency and uniformity issues with definition drafting and construction. These issues cause industry confusion regarding the intended meaning or application of a number of defined terms. As previously indicated, for those currently charged with drafting a defined term, there is no authoritative resource or instruction manual that providinges detailed information or instruction regarding any of the quality and consistency issues identified above. As a result, various teams (or individuals) draft definitions guided by their own personal preferences or styles. ¶¶The drafting team therefore recommends developingment of a “definition manual” for the purpose of outlining a consistent the proper approach for developingment and constructiong of all NERC ...

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http://www.nerc.com/pa/Stand/Resources/Documents/DT_Ref_Manual_092614_final.pdf


Recommendation No. 3: Move all standard-only or section-only definitions to the Glossary Issue statement: A number of NERC “defined terms” exist outside the Glossary and ROP, Appendix 2, including standard-only (e.g., PRC-005-6), ROP section-only (e.g., Section 1501), and informal or unofficial definitions (e.g., in a Reliability Standard’s footnote) (“stand-alone definitions”). These stand-alone definitions cause confusion because the scope of the definition’s applicability is not always clear, the definitions are difficult to locate and, in some instances, other resources improperly use the stand-alone definition despite the fact it is not an approved continent-wide definition. Recommendation: Either NERC standards developer and PMOS should develop and training on specific criteria when a Standard-only definition is permissible; or preferably, NERC standards developers and the PMOS representative should work together to ensure that all Standard definitions be included in the Gloossary of terms, including during Periodic Reviews moving any Standard only definations to the Glossary, developing a process to move Standard only terms to the Glossary and faciliting that first time definition be contained in the Glossary. should not allow stand-alone definitions and, instead, require all NERC “defined terms” be located in the Glossary, ROP, or both.6 NERC should move all existing stand-alone terms to the Glossary, ROP, or both (as appropriate).. Background and Observations of the Drafting Team: The drafting team identified a number of standard-only definitions not included in the continent-wide Glossary. See, for example, PRC-005-6, with seven standard-only definitions (Automatic Reclosing, Component Type, Component, Countable Event, Sudden Pressure Relaying, Unresolved Maintenance Issues, Segment). Also, the team noted some ROP sections and appendices contain a “Definition” section, while others do not. See, for example, Section 1500; Appendix 4E – CCC Hearing Procedures; Appendix 5A – Organization Registration and Certification Manual; and, Appendix 5C – BES Exception Procedure. The ROP sections and appendices containing a “Definitions” section repeat the definition found in Appendix 2; however, it is unclear why certain ROP sections contain a designated “Definition” section, while others do not. The lack of uniformity causes confusion and may be mistaken to mean the definition has a special or different meaning than the Appendix 2 definition. Additionally, the drafting team identified a number of other informally-defined terms contained in other widely-used NERC resources, such as the Functional Model and Drafting Team Reference Manual. The drafting team received a number of industry comments regarding stand-alone definitions. Commenters indicated stand-alone definitions are difficult to locate, easy to overlook and, in some instances, duplicating or conflicting with other defined terms. The team saw significant support for eliminating stand-alone definitions and housing all NERC-defined terms in designated resources (i.e., the Glossary or ROP, or both). Recommendation No. 4: Revise certain existing definitions to clarify or correct them Issue statement: It is the drafting team’s opinion that a number of definitions may not technically accurate or could be more technically accurate or do not reflect how the industry currently uses the term. Over 180 definitions are “Version 0” definitions and never been revised or assessed as part of a periodic review

6 If the defined term is used in a Reliability Standard and ROP, the Glossary and ROP (Appendix 2) should define it. If the defined term appears only in the Reliability Standards and not the ROP, the term should be defined only in the Glossary. Likewise, if the defined term appear only in the ROP and not the Reliability Standards, it should be defined in only ROP Appendix 2.

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Commented [b17]: BJM: to NERC legal – what is the process needed to move Std only definitions to the glossary?

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since FERC approved the definitions. Additionally, a number of defined terms are no longer used in any Reliability Standard or ROP provision. Recommendation: As with Standards, definations should be high-quality, technically sound and clearly written. The drating team believes there are definitions that are due for incremental improvements. The drafting team recognizes and is encouraged that the Enhanced Periodic Reviews (EPR) specifically require the review of any definitions used in a Standard. If the Standards Committee desires to review the definitions more quickly than during the EPR, it could adopted one or more of the following: (1) issue the attached SARs to address specific terms that seem in need of revision; (2) convene a drafting team to review all definitions used and Standards to issue SARs and Standard revisions. The advantages of these latter options is the definitions may be revised sooner than during the ERP process depending on the Standards the ERP will consider over the next year or so. The disadvantage is these recommendations are one-off Standard definition projects which will lilely require broad cross section or SMEs and coordinatio0n with other existing Standard drafting teams, which may not produce optimal results. Background and Observations of the Drafting Team: As recognized in the Glossary’s introduction section:

Most of the terms identified in [the] [G]lossary were adopted as part of the development of NERC’s initial set of reliability standards, called the “Version 0” standards. Subsequent to the development of Version 0 standards, new definitions have been developed and approved following NERC’s Reliability Standards Development Process, and added to this [G]lossary following board adoption, with the “FERC approved” date added following a final Order approving the definition.7

The drafting team determined at least 187 definitions (of 300 in the Glossary) have not been revised since the Glossary’s original 2007 effective date. In addition, several definitions became effective in 2008. Further, a number of defined terms are no longer used in any Reliability Standard. For example, “Fire-Risk” is defined but not used in any current Reliability Standard.

Part IV. Conclusion The Project 2015-04 team respectfully submits these recommendations to the Standards Committee and NERC staff for consideration. The team believes implementing the recommendations will allow for developing high-quality definitions in a clear, consistent and uniform manner.

7 Glossary of Terms Used in the NERC Reliability Standards, click here.

Commented [b19]: BJM: so what? This in itself is not proof; provide examples of specific concerns, back up with technical justifications or make observations more general and less pointed.

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Commented [b20]: BJM: to include this recommendation; need to technically justify why these SARs are needed and how they would not overlap with either recently approved Stds or existing drafting teams or soon to be initiated EPRs

Deleted: Recommendation: It is extremely important that NERC definitions must be are high-quality, technically sound, and sufficiently clear to allow such readers to that the definition can be easily understoounderstand and applyied by them industry in a consistent and correct manner. To achieve this goal, the drafting team recommends as follows:¶ ¶

(1) First, in order to fix the current state of things, a team should be established to conduct a comprehensive review of the current Glossary and ROP definitions. The definitions should be reviewed (and revised, as needed) for quality, content, technical accuracy, ...

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ATTACHMENT 1


Hypothical Coordinated Cross-Over Term Definition Development Process

Step 1

•Revising a cross-over term becomes necessary•If SDT already working on project, revise definition•If no SDT in place, draft SAR to revise the Glossary definition•Obtain qualified sponsor(s) to submit proposal to amend ROP definition to NERC Board

Step 2•Post SAR for 30-day informal comment period

Step 3

•Develop draft Glossary definition and Implementation Plan •Conduct Quality Review•Consult with NERC staff regarding proposed revisions to the ROP term

Step 4•Obtain Standards Committee approval to post Glossary definition for comment and ballot

Step 5

•Comment period and ballot (45-day comment period for ROP runs concurrently with Glossary comment period)•Post ROP definition to NERC website for industry comment•Form Ballot Pool for Glossary definition during first 30 calendar days of 45-day comment period•Conduct ballot for Glossary definition during last 10 days of comment period

•If significant changes are needed to the draft Glossary definition, conduct Additional Ballot

Step 6•Post responses to comments on Glossary and ROP definitions

Step 7•Conduct Final Ballot for Glossary definition (10 day period)

Step 8•Submit Glossary definition, Implementation Plan, and ROP amendmentto Board for approval

Step 9•Submit all Board-approved documents (both Glossary and ROP documents) to Applicable Governmental Authorities for

approval


ATTACHMENT 2

Commented [b25]: BJM – unclear what these SARs are suppose to do and why – EPRs????





Title of Proposed Standard: Definition of Interconnection







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Interconnection is, “A geographic area in which the operation of Bulk Power System components is synchronized such that the failure of one or more of such components may adversely affect the ability of the operators of other components within the system to maintain Reliable Operation of the Facilities within their control. When capitalized, any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec.”

The Glossary definition of Interconnection should be revised because it is ambiguous, overly broad, subject to multiple interpretations, and technically incorrect. The drafting team received a large number of industry comments requesting revisions to the definition. Below are examples of industry comments received:

Industry comment: The current definition is overly-broad because temporarily islanded areas would meet this definition despite the fact that they are not meant to be included. Second, the quoted portion of the current definition is imprecise because it fails to capture the concept that Interconnections operate asynchronously from one another. In other words, the accurate distinction between Interconnections is that they operate





SAR Information

asynchronously from one another. Industry comment: With the use of Bulk Power System and to maintain Reliable Operation of the Facilities in the same sentence, the Project Team is sending mixed signals. The term “Facility” is directly related to the BES definition where the Bulk Power System includes the distribution of energy to end use customers, mostly outside the scope of the NERC Reliability Standards.

Industry comment: We agree with the first part of the proposed addition to clarify the synchronized operation condition but not the qualifier on the reliable operation part, which is the fundamental objective of the Reliability Standards but not required to describe an Interconnection. We therefore suggest the definition be stated as: “A geographic area in which the operation of Bulk Power System components is synchronized. When capitalized, any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec.”

Industry comment: Within an Interconnection, Elements and resources may be operated asynchronously as well. We propose: "The System of Bulk Power System components that are operated asynchronously to other Systems of Bulk Power System components."

Industry comment: Commenter proposes not to align the ROP and the NERC Glossary definition of Interconnection since Bulk Power System components can be asynchronous. We also propose not specifying in the definition, ‘When capitalized’. Commenter would like to include this term in Phase 2 so the SDT can create a more appropriate definition.

Industry comment: Concerned with the phrasing “When capitalized…” When defined terms are used in Reliability Standards, they are capitalized as an indication that the term is defined in the Glossary of Terms. By utilizing the caveat that the definition is specific “when capitalized” it could only ever be defined as “…any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec” in a Reliability Standard. Otherwise it would not be capitalized and therefore an undefined term in the Reliability Standard. Suggest removing “When capitalized” and identify specifically or rely on context when the four major electric system networks in North America are intended. Industry comment: This is a disjointed definition which makes little or no sense and needs to either be completely rewritten or dropped from the glossary altogether. The final phrase/sentence is just kind of hanging out there.

Industry comment: Commenter agrees with the first part of the proposed addition to clarify the synchronized operation as a defining characteristic of an Interconnection, but does not support the additional qualifiers regarding failures and reliable operation. These qualifiers are not essential to the definition of an Interconnection. It further suggests that, following consideration of the proposed modifications to the definition of Bulk Power System, use of the term Bulk Electric System is more appropriate. The commenter therefore suggests the definition be stated as: “A defined geographic area within which the operation of Bulk Electric System components is synchronized. When capitalized, any one of the four major electric system networks in North America: Eastern, Western, ERCOT and Quebec.” To the extent that the SDT views this recommendation


SAR Information

as a substantive change to the definitions, the commenter would request that this revision be addressed the later, proposed phases of this project or as noted below as part of specific standard revision processes.

Industry comment: Commenter suggests removing “such that the failure of one or more of such components may adversely affect the ability of the operators of other components within the system to maintain Reliable Operation of the Facilities within their control” and changing “Bulk Power System” to “Bulk Electric System.” Commenter believes the qualifier is not appropriate and the term BPS provides issues for entities outside the U.S.

Industry comment: Commenter is not opposed to the concept of the definition in the ROP. However, combining these two terms could be problematic because there are small hydro facilities that may be part of the Bulk Electric System that are operated at a different frequency and are asynchronous. By definition, these small hydro project would not be part of the Interconnection since they are not synchronized to the rest of the Interconnection. Industry commenter: Commenter questions why the words "such that failure of one or more of such components may adversely affect the ability of the operations of other components within the system to maintain Reliable Operation of the Facilities within their control" are needed after "synchronized". While this is a true statement there are facilities within each interconnection that probably don't affect the ability of the operations of other components but they are still within the interconnection. It seems like just stopping after "synchronized" and then including the second sentence would suffice.




Clear and consistent industry understanding and application of the definition of Interconnection. The term is used in 16 Glossary definitions and at least 35 times throughout the Complete Set of Reliability Standards.


Revise the definition of Interconnection to reflect the correct usage of the term as described in the Industry Need section. The definition must take into account the fact that Interconnections operate asynchronously from one another.


Revise the definition of Interconnection to reflect the correct usage of the term and take into account the fact that Interconnections operate asynchronously from one another. Also, revisions to the definition should address the industry comments outlined above, and provide for a clear and consistent understanding and application of the term


SAR Information

throughout the Reliability Standards.



































a wide area basis.



1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes



Yes


Yes

Related Standards


The term is used at least 35 times throughout the Complete Set of Reliability Standards and in 16 Glossary of Terms definitions.

Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Load, Facility, and Net Energy for Load.


Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A




ATTACHMENT 3





Title of Proposed Standard: Definition of Load







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Load is, “An end-use device or customer that receives power from the electric system.”

The Glossary definition should be revised because it is lacking in quality, content, and is not reflective of how the Reliability Standards and industry use the term today. The definition should include a measurement of consumption, both instantaneous (Demand) and through time (energy). The current definition fails to include any component related to usage; but instead refers only to a customer or end-use device. The term Load, either capitalized or lower case is used in an inconsistent manner in at least 60 Glossary definitions and approximately 150 Reliability Standards.







SAR Information


Clear and consistent use of the definition of Load will allow the Balancing Authorities to better balance Demand and resources, and allow for better planning in the real time, operational horizon, and long term horizon. Since the terms appears in at least 60 Glossary definitions and approximately 150 Reliability Standards, the industry must be clear and consistent in the use of the term.


Revise the definition of Load to reflect industry usage of the term as described in the Industry Need section.


Revise the definition of Load to reflect industry usage of the term, and address the need for clear and consistent use of the term throughout the Reliability Standards.




































a wide area basis.




Yes





Yes


Yes

Related Standards


The term “Load” appears in at least 60 Glossary definitions and approximately 150 Reliability Standards.

Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Net Energy for Load, Facility, Interconnection and Transmission Customer.

Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A





ATTACHMENT 4





Title of Proposed Standard: Definition of Facility







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Facility is, “A set of electrical equipment that operates as a single Bulk Electric System Element (e.g., a line, a generator, a shunt compensator, transformer, etc.)”

The Glossary definition of Facility should be revised because it is ambiguous, overly broad and subject to multiple interpretations. The drafting team received a number of industry comments requesting revisions to the definition. Below are examples of industry comments received:

Industry commenter: The definition of "Facilities" is ambiguous and in need of revision. Commenter recommends that the terms Generator Operator and Generator Owner be placed in Category 2 and remain unchanged until the definition of Facility is improved so the impacts of the change in definition can be better understood. Industry commenter: Considering the definition of Facility listed in the Glossary, a TOP operating a synchronous condenser or shunt compensator, which generates Mvars, could potentially qualify as





SAR Information

operating a “generating Facility”. Would the TOP therefore be under an obligation to register as a GOP? Even though Footnote 3 on page 6 preceding mentions that “the clarity and content of the current definition could be improved”, and a SAR will be drafted, this should be taken care of now under this project.

Industry commenter: Although we are in agreement with the alignment of terms with the ROP, we feel the term "Facilities" is too general or ambiguous when related to generation.

Industry commenters: Multiple commenters suggest clearly defining ‘Facilities’ to prevent the confusion from Transmission Operator (TOP) versus Generator Operator (GOP).

Industry comment: Inconsistent approach is used for referencing defined terms with different suffixes. For defined term "Facility", sometimes referenced as "Facilities" and other times "Facility(ies)."

Industry comment: For example, FAC-008-3: Facility Ratings stated purpose is “To ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles. A Facility Rating is essential for the determination of System Operating Limits.” Transmission Owners and Generator Owners need to be certain what the scope of their “Facility” is in order to correctly and accurately develop their Facility Ratings (“The maximum or minimum voltage, current, frequency, or real or reactive power flow through a facility that does not violate the applicable equipment rating of any equipment comprising the facility.”). The current definition of Facility with the inclusion of examples (e.g. a line, a generator, a shunt compensator, transformer, etc.) is open to interpretation and leads to confusion when Registered Entities develop their Facility Ratings.




Clear and consistent industry understanding and application of the definition of Facility. The term is used in at least 26 Glossary definitions and throughout the Complete Set of Reliability Standards.


Revise the definition of Facility.


Revise the definition of Facility to ensure that the term is defined in a manner that allows for consistent use and application of the definition throughout the Reliability Standards.

























1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to

perform reliably under normal and abnormal conditions as defined in the NERC Standards.
















Yes



Yes


Yes

Related Standards


The term is used in at least 26 Glossary definitions and throughout the Complete Set of Reliability Standards.

Related SARs


Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Load, Net Energy for Load, and Interconnection.

Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A




ATTACHMENT 5





Title of Proposed Standard: Definition of Net Energy for Load







New Standard



Urgent Action

SAR Information


The current NERC Glossary of Terms (Glossary) definition of Net Energy for Load is, “Net Balancing Authority Area generation, plus energy received from other Balancing Authority Areas, less energy delivered to Balancing Authority Areas through interchange. It includes Balancing Authority Area losses but excludes energy required for storage at energy storage facilities.”

The ROP definition provides that, “Net Energy for Load” or “NEL” means net generation of an electric system plus energy received from others less energy delivered to others through interchange. It includes system losses but excludes energy required for the storage of energy at energy storage facilities.

The Glossary definition of Net Energy for Load should be revised because it is lacking in quality, content, and is not reflective of how the Reliability Standards and industry use the term today. The Glossary definition is specific to Balancing Authorities, while the use of the term within the Reliability Standards indicates the term could be applied to other entities, such as a Regional Entity, Transmission Operators, Transmission Planners and others.





SAR Information

Additionally, the Glossary definition is substantially different than the definition provided in Appendix 2 of the NERC Rules of Procedure (ROP). The Glossary definition is very specifically limited in application, whereas the ROP definition is not.

The definition should be revised to eliminate confusion and ensure that the definition is well-suited for current day usage.




Clear and consistent industry understanding and application of the definition of Net Energy for Load. Net Energy for Load is used in multiple Reliability Standards (e.g., MOD-016-1.1, MOD-017-0.1, MOD-018-0, MOD-021-1, MOD-031-1) and one Glossary definition (Peak Demand).


Revise the definition of Net Energy for Load to ensure clear and consistent application and use of the term throughout the Reliability Standards.


Revise the definition of Net Energy for Load to eliminate confusion and ensure that the definition is well-suited for current day usage.


The Definition will Apply to the Following Functions (Check each one that applies.)






































Does the proposed Standard comply with all of the following Market Interface Principles? Enter

(yes/no)


Yes



Yes


Yes

Related Standards


MOD-016 This Reliability Standard uses the term Net Energy for Load.

MOD-017 See above.

MOD-018 See above.

MOD-031 See above.

Related SARs

SAR ID Explanation

See, SARs submitted by Project 2015-04 requesting revisions to definitions of: Load, Facility, and Interconnection.

Regional Variances

Region Explanation

ERCOT N/A

FRCC N/A

MRO N/A


Regional Variances

NPCC N/A

RFC N/A

SERC N/A

SPP N/A

WECC N/A




Standards Committee Process Subcommittee Update

Action For information only.

• The Standards Committee Process Subcommittee (SCPS) Work Plan is included in theagenda package for your review. Significant progress has been made on several projects andthis has been noted on the Work Plan and is identified below:

Revisions to NERC Standard Processes Manual (SPM) (Lead: Peter Heidrich)

o Section 6: Processes for Conducting Field Tests and Collecting and Analyzing Data

• Resolved all outstanding issues and reached consensus between the SCPS, theStanding Committee leads (Operating, Planning, CIPC and Standards) and NERCstaff on the proposed revisions to Section 6.

• SCPS will bring the proposed Section 6 revisions to the September 14, 2016Standards Committee (SC) Meeting for endorsement.

o Section 11: Process for Approving Supporting Documents

• SCPS will continue to seek resolution of fundamental issues surrounding theintent and use of Section 11 for the development of supporting documents.

o Section 7: Process for Developing an Interpretation

• SCPS Subgroup provided a proposal for comment to the SCPS, SC Leadership andNERC staff. Currently reviewing comments and making associated revisions tothe proposal for consideration. SCPS Subgroup meeting/call will be scheduled todiscuss the revised proposal.

Cost of Risk Reduction Analysis (CRRA) (Lead: TBD)

o Project is ‘on hold’ pending the results of the Cost Effectiveness Pilot project and adetermination is made on the future role of the SCPS concerning ‘pilot’ resultsanalysis and process development.

SAR Submittal Form/SAR Comment Form (Common Question Development) (Lead:Ben Li)

o Project has begun formal development and the SCPS intends to present a finalrecommendation to the SC at the December meeting.

• Resource Document Continuing Project (Lead: Linn Oelker)

Resource Document spreadsheet is included in the agenda package for review.

The SCPS is currently reviewing the Guidance Document for Management of RemandedInterpretations as it was last revised on April 9, 2014, as well as the Standard DraftingTeam Scope and Acceptance Criteria of a Reliability Standard which were last revised onMay 16, 2014. These documents all have a periodic review frequency of 24 months.


The SCPS will present each of the revised documents to the SC for its approval at an upcoming SC meeting. The SC is the document owner for each of the documents being reviewed by the SCPS.

The SCPS will provide an update on the review/revision activities associated with the Drafting Team Reference Manual. The SCPS will present an overview of the comments received, refinements needed prior to bring the document forward to the SC for endorsement.

• Standard Balloting System (SBS) Enhancements (Lead: Wendy Muller, NERC)

The enhancement selections are finalized1.

The enhancements are expected to be rolled out late October/early November 2016.

• Registered Ballot Body (RBB) Annual Self-Selection Process Update (Lead: Mat Bunch, NERC)

NERC has received attestations/self-selections from nearly all RBB members and continues to reach out to those who have not submitted;

Additional requests continue to result in case-by-case education/outreach and ballot pool clean-up.

1 Standards Balloting and Commenting System (SBS) Enhancements presentation included in the agenda package for review.

SCPS Work Plan Activities Document—August 30, 2016

Agenda Item 16b(i) Standards Committee September 14, 2016

Standards Committee Process Subcommittee Work Plan (SC Endorsed Project Scopes)

Task General Scope of Task Task Initiated

Target Completion

Status/Remarks

1. Cost of Risk ReductionAnalysis (CRRA)

Team Lead: TBD

Pete Heidrich

Randy Crissman

Steven Rueckert

Guy Zito (consulting)

To conduct CEAP pilots via:

a. Conducting the CEA portion of theCEAP on the second project of thepilot. The Team will develop areport for the SC and the Industry.

b. Proposing a list of standardsdevelopment projects to conductthe CEAP on along with potentialcriteria for choosing projects for2014 and beyond and bring theseto the SC for endorsement

c. Revise the current CEAP guidelinedocument into a secondgeneration document to reflectlessons learned during the pilotand to address potential “benefits”of standard projects and bring tothe SC for endorsement.

Task was initiated prior to use of scope documents

April 2012 a)March 2014 SC Meeting

b)August 2014 SC Meeting

c)September 2015 SC Meeting

a) Completed

b) Complete (note: proposalsubmitted to NERC staff in lieu of SC)

c) On hold pending CostEffectiveness Pilot project and results.

In progress

Scope of the project was revised to reflect a Cost of Risk Reduction Analysis (CRRA) approach. Endorsed at Sept. 23, 2015 Standards Committee meeting.

SCPS continue working with Standards Leadership to evaluate this item and determine next steps.

A draft document has been presented to H. Gugel for review. The MRC may need to review some of the issues






SCPS Work Plan Activities Document--August 10, 2016


Task

General Scope of Task

Task Initiated

Target Completion

Status/Remarks

contained within the document. H. Gugel stated that the NERC Board and others may request input from the MRC, and that NERC staff is currently working to determine the mechanism by which this should occur.

UPDATE: Michelle D’Antuono has assumed the role of Project Liaison to coordinate efforts between NERC staff and the SCPS.

Project is ‘on hold’ pending the results of the Cost Effectiveness Pilot project and a determination is made on the future role of the SCPS concerning ‘pilot’ results analysis and process development.



Task


Task Initiated

Target Completion

Status/Remarks

2. Revisions to NERC Standard Processes Manual (SPM)

a. Section 6: Processes for Conducting Field Tests and Collecting and Analyzing Data

b. Section 7: Process for Developing an Interpretation

c. Section 11.0: Process for Approving Supporting Documents

Team Lead: Pete Heidrich

John Bussman

Ben Li

Jennifer Flandermeyer

Andy Pusztai

Steve Rueckert

Jason Smith

Chris Gowder

Sean Bodkin

Guy Zito (consulting)

Andrew Wills (NERC Legal)

a. Develop and propose recommendations to the SC for revisions and/or modifications to the SC Charter Section 10 and Section 6 of the Standards Processes Manual (SPM), which will address the coordination and oversight involvements of the NERC technical committees.

b. Develop and propose recommendations to the SC for revisions and/or modifications to the Interpretation Process in Section 7 of the SPM which will improve the effectiveness and efficiency of (i) validation of a request for Interpretation (RFI), and (ii) development of an interpretation of an approved Reliability Standard or individual Requirement(s) within an approved Reliability Standard.

c. Develop and propose recommendations to the SC for revisions and/or modifications to the Technical Document Approval Process in Section 11 of the SPM.

July, 2015

Feb., 2017

UPDATE:

Section 6: Processes for Conducting Field Tests and Collecting and Analyzing Data • Resolved all outstanding

issues and reached consensus between the SCPS, the Standing Committee leads (Operating, Planning, CIPC and Standards) and NERC staff on the proposed revisions to Section 6.

Section 11: Process for Approving Supporting Documents • SCPS will bring two (2)

separate proposals (one (1) developed by the SCPS Subgroup and one (1) developed by NERC staff) to the 09.13.2016 SCPS Meeting for discussion.



Task


Task Initiated

Target Completion

Status/Remarks

Lauren Perotti (NERC Legal)

Ryan Stewart (NERC Standards)

Sean Cavote (NERC)

Steve Crutchfield (NERC)

Section 7: Process Developing an interpretation • SCPS Subgroup provided a

proposal for comment to the SCPS, SC Leadership and NERC staff. Currently reviewing comments and making associated revisions to the proposal for consideration. SCPS Subgroup meeting/call will be scheduled to discuss the revised proposal.


Task


Task Initiated

Target Completion

Status/Remarks

3. SAR Submittal Form/SAR Comment Form (Common Question Development)

Team Lead: Ben Li

Chris Gowder

Andy Pusztai

Ron Sporseen

Sean Bodkin

The objective of this project is to review the SAR and related comment form, and propose recommendations to the Standards Committee on:

a. Revisions and/or modifications to the

SAR Form, b. Explore the merit of developing

certain common questions for the comment form for SAR posting.

July 2016

TBD

Project has begun formal development and the SCPS intends to present a final recommendation to the Standards Committee at the December meeting.

Standards Committee Process Subcommittee 2014 Work Plan (Conceptual Project Stage-No Scope or Endorsement)

Proposed Task


Presented to SC for Project

Initiation

Scope, Development

Initiated

SC Approval of Scope *

Status/Remarks

*Upon approval of project Scope, the project will be moved to the “Standards Committee Process Subcommittee Work Plan (SC Endorsed Project Scopes) section.

Resources for StandardsToday is: June 1, 2016

Approved by SC December 9, 2015

DT Ref Manual? DOCUMENT TITLE DOCUMENT OWNER Document Last RevisedAge of Document (in

Months)Periodic review

frequency (months):Party responsible for periodic review

and proposed updates:Overdue by (months): Notes / Comments

Y Standard Drafting Team ScopeSTANDARDS COMMITTEE (SC) May 16, 2014 25 24 SCPS 1

Y Acceptance Criteria of a Reliability StandardSTANDARDS COMMITTEE (SC) May 16, 2014 25 24 SCPS 1

Y SC Procedure ‐ Processing Requests for an InterpretationSTANDARDS COMMITTEE (SC) December 9, 2014 18 24 SCPS CURRENT

YStandards Committee Procedure ‐ Approving the Posting of Reliability Standard Supporting References

STANDARDS COMMITTEE (SC) December 9, 2014 18 24 SCPS CURRENT

N Approving Errata in an Approved Reliability StandardSTANDARDS COMMITTEE (SC) December 9, 2014 18 24 SCPS CURRENT

NStandards Committee Procedure ‐ NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure

STANDARDS COMMITTEE (SC) December 9, 2014 18 24 SCPS CURRENT

N Standards Committee CharterSTANDARDS COMMITTEE (SC) December 9, 2014 18 24 SCPS CURRENT

Document had been approved by SC 12/9/2014.SCPS reviewing as discussed in 3/8/16 SCPS meeting

N Reliability Standard Quality Review Form STANDARDS COMMITTEE (SC) September 23, 2015 8 24 SCPS CURRENT Endorsed by the SC 9/23/2015

NNERC NAESB Template Procedure for Joint Standard Development And Coordination

STANDARDS COMMITTEE (SC) February 22, 2006 123 24 SCPS 99

SCPS team / NERC staff question ownership 5/26/16SCPS reviewing as discussed in 3/8/16 SCPS meeting

YStandards Committee Guideline ‐ Approving a Field Test Associated with a Reliability Standard

STANDARDS COMMITTEE (SC) March 10, 2008 99 24 SCPS 75

Document not finalized during phase I due to objection by the Operating Committee.3/8/16 SCPS ‐ This document will be retired after SPM changes and will require SC approval to retire.

Y Reliability Functional Model Function Definitions and Functional EntitiesSTANDARDS COMMITTEE (SC) November 30, 2009 78 24 FMAG 54 Being reviewed by FMAG as noted in 3/8/16 SCPS meeting

N Rapid Revision ProcedureSTANDARDS COMMITTEE (SC) June 5, 2013 36 24 SCPS 12

SCPS reviewing as discussed in 3/8/16 SCPS meetingWebsite link titled Standards Committee Procedure for Rapid Revision

Y Guidelines for Interpretation Drafting TeamsSTANDARDS COMMITTEE (SC) September 19, 2013 33 24 SCPS 9 3/8/16 SCPS meeting ‐ this document being reviewed with SPM revisions project.

N Drafting Team Reference ManualSTANDARDS COMMITTEE (SC) January 7, 2014 29 24 SCPS 5

SCPS reviewing as discussed in 3/8/16 SCPS meetingPosted version indicates updated May 19, 2014 by NERC Staff to Coordinate with NERC Drafting Team Resources posting.

N Guidance Document for Management of Remanded InterpretationsSTANDARDS COMMITTEE (SC) April 9, 2014 26 24 SCPS 2

Y1

NERC Drafting Team Resources ‐ Companion Document to DT Reference Manual (POSTED 2/2/2015) Standards Staff December 9, 2014 18 N/A Standards Staff N/A

This document is a conglomoration of individual documents with individual review periods and in of itself does not need a periodic review.

Y Violation Severity Level Guidelines Standards Staff NONE UNKNOWN 24 Standards Staff N/AY FERCs Criteria for Approving Reliability Standards from Order 672 Standards Staff May 16, 2014 25 24 Standards Staff 1Y NERC Standards Numbering System Standards Staff September 30, 2014 20 24 Standards Staff CURRENTN NERC Standards Numbering System ‐ NEW Standards Staff September 30, 2014 20 24 Standards Staff CURRENTN SAR Form Identifying the Need for a Variance Standards Staff September 10, 2014 21 24 Standards Staff CURRENTN Weighted Segment Voting Examples Standards Staff November 4, 2009 79 24 Standards Staff 55Y Time Horizons Standards Staff 1/28/2010 76 24 Standards Staff 52Y Violation Risk Factors Standards Staff 1/28/2010 76 24 Standards Staff 52Y Ten Benchmarks of an Excellent Reliability Standard Standards Staff 3/16/2010 75 24 Standards Staff 51Y Market Principles Standards Staff March 18, 2010 75 24 Standards Staff 51Y Reliability Principles Standards Staff March 18, 2010 75 24 Standards Staff 51N Results‐Based Reliability Standard Development Guidance Standards Staff June 7, 2010 72 24 Standards Staff 48N Request for Interpretation Form Standards Staff April 22, 2011 61 24 Standards Staff 37N Reliability Standards Suggestions and Comments Form Standards Staff June 1, 2011 60 24 Standards Staff 36N Request to Develop a Definition Form Standards Staff July 13, 2011 59 24 Standards Staff 35Y Standards Development Process ‐ Participant Conduct Policy Standards Staff May 20, 2013 37 24 Standards Staff 13N Standards Authorization Request Form Standards Staff June 3, 2013 36 24 Standards Staff 12Y Nomination Form Standard Drafting Team Standards Staff January 28, 2014 28 24 NERC STAFF? 4

N Standards Drafting Team Nomination Form Standards Staff January 28, 2014 28 24 NERC STAFF? 4 Also listed as a DT Reference manual resource as Nomination Form Standard Drafting Team

Agemda Item 16b(ii) Standards Committee September 14, 2016

Standards Balloting andCommenting System (SBS) EnhancementsWendy MullerSpecialist, Standards DevelopmentAugust 17, 2016

Agenda Item 16b(iii)Standards CommitteeSeptember 14, 2016


•Ability for user to vote, delegate proxy rights, and join ballots and ballot pools from the “View Ballot Events” page

•All current references to the term “Survey(s)” will be replaced with the term “Comment(s)”

•Ability for user to proceed directly to Social Survey (real-time commenting page) without first having to provide comments

•Ability for user to sort and filter when selecting group members

Overview of 2016 SBS Enhancements


•Voters/proxies will no longer be prompted to confirm negative votes (opinions) for Non-binding Polls

•The system will return to user’s selected sorting view instead of reverting back to the default view

Overview of 2016 SBS Enhancements


•NERC is in the process of reviewing the contract and pulling together a schedule for deployment

•The enhancements are expected to be rolled out late October/early November 2016

•After deployment, a webinar will be scheduled to review and demonstrate the enhancements to the industry

Timeline and Next Steps

Agenda Item 16c Standards Committee September 14, 2016

Functional Model Advisory Group Update


• The 45-day informal comment period on the Reliability Functional Model (FM) andReliability Functional Model Technical Document (FMTD) concluded on September 7,2016.

• The Functional Model Advisory Group (FMAG) will determine if the comments warrantadditional revisions to the Reliability FM and/or the Reliability FMTD.

• On August 30, 2016 the FMAG conducted an Industry Outreach Webinar on the FM andthe FMTD. The webinar topics, such as purpose and intent of the FM and the FMAG, the‘use as a reference’ of the FM, and the FMTD and an overview of the proposed revisionsto the documents. (Webinar materials can be found on the NERC website.)

Target Milestones:

• October 25 – 27, 2016 – Finalize comment responses and proposed revisions to the FMand the FMTD.

• TBD - Present final revisions to the FM and FMTD to NERC Technical Committees(Operating Committee, Planning Committee, and Critical Infrastructure ProtectionCommittee) for endorsement

Scheduled Meetings:

• October 25 – 27, 2016 in Portland, OR (face-to-face)


NERC Legal and Regulatory Update July 19, 2016 – August 19, 2016

NERC FILINGS TO FERC SUBMITTED SINCE LAST SC UPDATE

FERC Docket No. Filing Description FERC Submittal

Date

RM16-15-000

Comments of NERC on NOPR Proposing Regulations Implementing FAST Act Provisions on CEII NERC submits comments in response to the Commission’s Notice of Proposed Rulemaking (NOPR) proposing to implement provisions of the Fixing America’s Surface Transportation Act that require the designation, protection and sharing of Critical Energy Infrastructure Information (CEII).

8/19/2016

RR16-5-000

Petition for Approval of Proposed ROP Revisions NERC submits a petition requesting approval to incorporate Frequency Response Sharing Group and Regulation Reserve Sharing Group, as defined in the Glossary of Terms Used in NERC Reliability Standards and used in BAL-003-1.1 and BAL-001-2, to the following parts of the NERC Rules of Procedure:

• Appendix 2 - Definitions Used in the Rules of Procedure;• Appendix 5A - Organization Registration and Certification

Manual; and• Appendix 5B - Statement of Compliance Registry Criteria.

8/15/2016

RD16-9-000

Petition of NERC for Approval of Proposed Reliability Standard COM-001-3NERC submits a petition for approval of proposed Reliability Standard COM-001-3 (Communications).

8/15/2016

RM16-20-000 Petition of NERC for Approval of Reliability Standard PRC-012-2 NERC submits a petition for approval of Reliability Standard PRC-012-2 (Remedial Action Schemes).

8/5/2016

RM16-7-000

Comments of NERC in Response to NOPR BAL-002-2 (Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event) NERC submits comments in response to the Commission’s NOPR proposing to approve Reliability Standard BAL-002-2 (Disturbance Control Standard-Contingency Reserve for Recovery from a Balancing Contingency Event).

7/25/2016

http://elibrary.ferc.gov/idmws/search/eSave.asp?dt=All&cat=submittal,%20issuance&dkt=RM16%2D15&ft=fulltext&dsc=description

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/FASTAct_NOPR_Comments_RM16-15_08192016.pdf

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/FASTAct_NOPR_Comments_RM16-15_08192016.pdf

http://elibrary.ferc.gov/idmws/search/eSave.asp?dt=All&cat=submittal,%20issuance&dkt=RR16%2D5&ft=fulltext&dsc=description

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/Final_Petition_ROP_Rev_RSG_08152016.pdf

http://elibrary-backup.ferc.gov/idmws/search/eSave.asp?dt=All&cat=submittal,%20issuance&dkt=RD16%2D9&ft=fulltext&dsc=description

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/COM-001-3_Petition.pdf

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/COM-001-3_Petition.pdf

http://elibrary-backup.ferc.gov/idmws/search/eSave.asp?dt=All&cat=submittal,%20issuance&dkt=RM16%2D20&ft=fulltext&dsc=description

http://www.nerc.com/FilingsOrders/us/Lists/NERC%20Filings%20to%20FERC%202012%20CL/PRC-012-2_Final_08052016.pdf

http://elibrary.ferc.gov/idmws/search/eSave.asp?dt=All&cat=submittal,%20issuance&dkt=RM16%2D7&ft=fulltext&dsc=description

http://www.nerc.com/FilingsOrders/us/NERC%20Filings%20to%20FERC%20DL/BAL-002-2%20NOPR%20Comments.pdf



2

FERC ISSUANCES SINCE LAST SC UPDATE (any standard development related directives or proposed directives are noted in the summary)

FERC Docket No. Issuance Description FERC Issuance

Date

RD16-8-000

Letter Order Approving the Retirement of Regional Reliability Standard PRC-002-NPCC-01 FERC issues a letter order approving NERC and NPCC’s joint petition for approval for the retirement of NPCC Regional Reliability Standard PRC-002-NPCC-01 (Disturbance Monitoring) as well as two NPCC regional definitions, Current Zero and Generating Plant.

8/16/2016

RM15-14-001 Order No. 822-A Denying Rehearing FERC issues an order denying rehearing of Order No. 822, issued on January 21, 2016, that approved seven CIP Reliability Standards.

7/21/2016

RM15-14-002

Order No. 829 Directing Standard for Supply Chain Cyber Controls Errata Notice FERC issues a final rule requiring the development of a new or modified Reliability Standard on supply chain risk management for industrial control system hardware, software, and computing and networking services associated with Bulk Electric System operations within one year.

7/21/2016

RM16-18-000

NOI Regarding Cyber Systems in Control Centers FERC issues a Notice of Inquiry (NOI) seeking comment on possible modifications to the CIP standards regarding the cybersecurity of Control Centers that are used to monitor and control the Bulk Electric System in real-time.

7/21/2016

http://elibrary.ferc.gov/idmws/search/eSave.asp?dt=All&cat=submittal,%20issuance&dkt=RD16%2D8&ft=fulltext&dsc=description

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Letter%20Order%20Approving%20PRC-002-NPCC-01%20Retirement.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Letter%20Order%20Approving%20PRC-002-NPCC-01%20Retirement.pdf


http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order_822-A_Deny_Rehear_20160721_RM15-14.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20Approving%20Revised%20CIP%20Reliability%20Standards.pdf



http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Errata_Order_SupplyChain_20160722_RM15-14.pdf


http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/NOI_CyberSystems_20160721_RM16-18.pdf

3

UPCOMING FERC FILING DATES

FERC Docket No. Filing Description Projected FERC

Filing Date

NERC will submit proposed Reliability Standard PER-006-1 (Specific Training for Personnel) for approval. 9/9/2016

NERC will submit proposed Reliability Standard PRC-027-1 (Coordination of Protection Systems for Performance During Faults) for approval.

9/9/2016

RM16-18-000 NERC will submit comments on FERC’s NOI regarding BES Cyber Systems in Control Centers. 9/26/2016

RM13-13-000

NERC will submit an informational filing after the first two years of implementation of regional Reliability Standard BAL-002-WECC-02 (Contingency Reserve) that addresses the adequacy of contingency reserve in the Western Interconnection, in accordance with FERC Order No. 789.

10/3/2016



http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order789_BAL-002-WECC-2_RM13-13_20131121.pdf


Project 2016-02 Modifications to CIP Standards

Information Only Resignation of Zachariah Trublood from the standard drafting team (SDT) for Project 2016-02 –Modifications to CIP Standards.

Background Due to a job change, Zachariah Trublood of Sacramento Municipal Utility District has resigned as a member of the SDT. The CIP SDT chair and NERC staff do not currently plan to ask the Standards Committee for an additional SDT member.


Standards Committee 2017-2018 Member Elections


Background There are members representing ten segments whose term will conclude at the end of December 2016. Therefore, an election will be held to fill the two-year terms (2017-2018) for each of the ten segments. Please see Table 1 below for the ten members whose terms will conclude.

According to the Procedures for Election of Members of the Standards Committee, Appendix 3B to the NERC Rules of Procedure, nominations will be requested approximately 90 days prior to the start of a new term to fill Standards Committee positions that will become open with the expiration of the current term. Membership terms will start on January 1, 2017.

NERC will announce and publish a notice of the nominations process for segment representatives on or about September 19, 2016, with a nomination period of 21 days and an election conducted in accordance with Appendix 3B to the Rules of Procedure.

Table 1: Membership Terms Concluding Segment Representative Title Organization

1 Lou Oberski Managing Director, NERC Compliance Policy


2 Charles Yeung Executive Director Interregional Affairs Southwest Power Pool 3 John Bussman Manager, Reliability Compliance Associated Electric Cooperative,

Inc. 4 Barry Lawson Associate Director, Power Delivery and

Reliability National Rural Electric Cooperative Association

5 Colt Norrish Compliance Director PacifiCorp 6 Brenda Hampton Regulatory Policy Energy Future Holdings –

Luminant Energy Company LLC 7 Marion Lucas APGI Chief Compliance Officer,

President & Director Alcoa Power Marketing LLC

8 David Kiguel Independent 9 Mark Harris Electrical Engineer Public Utilities Commission of

Nevada 10 Steve Rueckert Director of Standards Western Electricity Coordinating

Council

Standards Committee Expectations Approved by Standards Committee January 12, 2012

Background Standards Committee (SC) members are elected by members of their segment of the Registered Ballot Body, to help the SC fulfill its purpose. According to the Standards Committee Charter, the SC’s purpose is:

In compliance with the NERC Reliability Standards Development Procedure, the Standards Committee manages the NERC standards development process for the North American-wide reliability standards with the support of the NERC staff to achieve broad bulk power system reliability goals for the industry. The Standards Committee protects the integrity and credibility of the standards development process.

The purpose of this document is to outline the key considerations that each member of the SC must make in fulfilling his or her duties. Each member is accountable to the members of the Segment that elected them, other members of the SC, and the NERC Board of Trustees for carrying out their responsibilities in accordance with this document.

Expectations of Standards Committee Members

1. SC Members represent their segment, not their organization or personal views. Each member isexpected to identify and use mechanisms for being in contact with members of the segment inorder to maintain a current perspective of the views, concerns, and input from that segment. NERCcan provide mechanisms to support communications if an SC member requests such assistance.

2. SC Members base their decisions on what is best for reliability and must consider not only what isbest for their segment, but also what is in the best interest of the broader industry and reliability.

3. SC Members should make every effort to attend scheduled meetings, and when not available arerequired to identify and brief a proxy from the same segment. Standards Committee businesscannot be conducted in the absence of a quorum, and it is essential that each Standards Committeemake a commitment to being present.

4. SC Members should not leverage or attempt to leverage their position on the SC to influence theoutcome of standards projects.

5. The role of the Standards Committee is to manage the standards process and the quality of theoutput, not the technical content of standards.

Agenda Item 18c Standards Committee

June 15, 2016

http://www.nerc.com/comm/SC/Documents/SC%20approved%20Item_7-Att_2_SC_Charter-SC_Approved_January_16_2013_Revised_11_26_13_clean.pdf

Standards Committee Meeting Dates and Locations for 2016

The time for face-to-face meetings is based on the ‘local’ time zone. The time specified for all conference calls is based on Eastern Time.

January 21, 2016 – Conference Call | 1:00-4:00 p.m.

March 9, 2016 – Atlanta, GA (NERC) 8:00 a.m.-2:00 p.m.

April 20, 2016 – Conference Call | 1:00-4:00 p.m.

June 15, 2016 – St. Louis, MO (Ameren) | 8:00 a.m.-2:00 p.m.

July 20, 2016 – Conference Call | 1:00-4:00 p.m.

September 14, 2016 – San Francisco, CA (PG&E) | 8:00 a.m.-2:00 p.m.

October 19, 2016 – Conference Call | 1:00-4:00 p.m.

December 14, 2016 – Atlanta, GA (NERC) 8:00 a.m.-2:00 p.m.

This schedule was designed so that the SC subcommittee face-to-face meetings could occur either the afternoon (day) before or the afternoon of the SC face-to-face meetings. Scheduling of subcommittee face-to-face meetings is handled by the chairs of the subcommittees in consultation with the subcommittees’ members and NERC staff.

Agenda Item 18d Standards Committee

June 15, 2016

Standards Committee 2016 Segment Representatives

Segment and Term Representative Organization

Chair 2016-17

Brian Murphy Senior Attorney

NextEra Energy, Inc.

Vice-Chair 2016-17

Michelle D’Antuono Manager, Energy

Occidental Energy Ventures, LLC

Segment 1-2015-16 Lou Oberski Managing Director, NERC Compliance Policy


Segment 1-2016-17 Laura Lee Manager of ERO Support and Event Analysis, System Operations

Duke Energy

Segment 2-2015-16 Charles Yeung Executive Director Interregional Affairs

Southwest Power Pool

Segment 2-2016-17 Ben Li Consultant

Independent Electric System Operator

Segment 3-2015-16 John Bussman Manager, Reliability Compliance

Associated Electric Cooperative, Inc.

Segment 3-2016-17 Scott Miller Manager Regulatory Policy

MEAG Power

Segment 4-2015-16 Barry Lawson Associate Director, Power Delivery and Reliability

National Rural Electric Cooperative Association

Segment 4-2016-17 Chris Gowder Regulatory Compliance Specialist

Florida Municipal Power Agency

Segment 5-2015-16 Colt Norrish Compliance Director

PacifiCorp

Segment 5-2016-17 Randy Crissman Vice President – Technical Compliance

New York Power Authority

Agenda Item 18e Standards Committee

June 15, 2016

Standards Committee 2016 Roster 2

Segment 6-2015-16 Brenda Hampton Regulatory Policy

Energy Future Holdings – Luminant Energy Company LLC

Segment 6-2016-17 Andrew Gallo Director, Reliability Compliance

City of Austin dba Austin Energy

Segment 7-2015-16 Marion Lucas APGI Chief Compliance Officer, President & Director

Alcoa Power Generating Inc.

Segment 7-2016-17 Frank McElvain Senior Manager, Consulting

Siemens Power Technologies International

Segment 8-2015-16 David Kiguel Independent

Segment 8-2016-17 Robert Blohm, Managing Director

Keen Resources Ltd.

Segment 9-2015-16 Mark Harris Electrical Engineer

Public Utilities Commission of Nevada

Segment 9-2016-17 Vacant

Segment 10-2015-16 Steve Rueckert Director of Standards

Western Electricity Coordinating Council

Segment 10-2016-17 Guy Zito Assistant Vice President of Standards


Parliamentary Procedures

Agenda Item 18f Standards Committee

June 15, 2016

Based on Robert’s Rules of Order, Newly Revised, 11th Edition, plus “Organization and Procedures Manual for the NERC Standing Committees”

Motions Unless noted otherwise, all procedures require a “second” to enable discussion.

When you want to… Procedure Debatable Comments Raise an issue for discussion

Move Yes The main action that begins a debate.

Revise a Motion currently under discussion

Amend Yes Takes precedence over discussion of main motion. Motions to amend an amendment are allowed, but not any further. The amendment must be germane to the main motion, and cannot reverse the intent of the main motion.

Reconsider a Motion already approved

Reconsider Yes Allowed only by member who voted on the prevailing side of the original motion.

End debate Call for the Question or End Debate

No If the Chair senses that the committee is ready to vote, he may say “if there are no objections, we will now vote on the Motion.” The vote is subject to a 2/3 majority approval. Also, any member may call the question. This motion is not debatable. The vote is subject to a 2/3 vote.

Record each member’s vote on a Motion

Request a Roll Call Vote

No Takes precedence over main motion. No debate allowed, but the members must approve by 2/3 majority.

Postpone discussion until later in the meeting

Lay on the Table Yes Takes precedence over main motion. Used only to postpone discussion until later in the meeting.

Postpone discussion until a future date

Postpone until Yes Takes precedence over main motion. Debatable only regarding the date (and time) at which to bring the Motion back for further discussion.

Remove the motion for any further consideration

Postpone indefinitely

Yes Takes precedence over main motion. Debate can extend to the discussion of the main motion. If approved, it effectively “kills” the motion. Useful for disposing of a badly chosen motion that can not be adopted or rejected without undesirable consequences.

Request a review of procedure

Point of order No Second not required. The Chair or secretary shall review the parliamentary procedure used during the discussion of the Motion.

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Notes on Motions Seconds. A Motion must have a second to ensure that at least two members wish to discuss the issue. The “seconder” is not recorded in the minutes. Neither are motions that do not receive a second.

Announcement by the Chair. The Chair should announce the Motion before debate begins. This ensures that the wording is understood by the membership. Once the Motion is announced and seconded, the Committee “owns” the motion, and must deal with it according to parliamentary procedure.

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Voting Voting Method When Used How Recorded in Minutes Unanimous Consent The standard practice.

When the Chair senses that the Committee is substantially in agreement, and the Motion needed little or no debate. No actual vote is taken.

The minutes show “by unanimous consent.”

Vote by Voice The standard practice. The minutes show Approved or Not Approved (or Failed).

Vote by Show of Hands (tally)

To record the number of votes on each side when an issue has engendered substantial debate or appears to be divisive. Also used when a Voice Vote is inconclusive. (The Chair should ask for a Vote by Show of Hands when requested by a member).

The minutes show both vote totals, and then Approved or Not Approved (or Failed).

Vote by Roll Call To record each member’s vote. Each member is called upon by the Secretary, and the member indicates either “Yes,” “No,” or “Present” if abstaining.

The minutes will include the list of members, how each voted or abstained, and the vote totals. Those members for which a “Yes,” “No,” or “Present” is not shown are considered absent for the vote.

Notes on Voting (Recommendations from DMB, not necessarily Mr. Robert)

Abstentions. When a member abstains, he is not voting on the Motion, and his abstention is not counted in determining the results of the vote. The Chair should not ask for a tally of those who abstained.

Determining the results. The results of the vote (other than Unanimous Consent) are determined by dividing the votes in favor by the total votes cast. Abstentions are not counted in the vote and shall not be assumed to be on either side.

“Unanimous Approval.” Can only be determined by a Roll Call vote because the other methods do not determine whether every member attending the meeting was actually present when the vote was taken, or whether there were abstentions.

Majorities. Robert’s Rules use a simple majority (one more than half) as the default for most motions. NERC uses 2/3 majority for all motions.

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Standards Committee Action Without a Meeting Results July 28, 2016

In an email ballot was sent on July 25, 2016 requesting the Standards Committee (SC) to vote by 8:00 p.m. Eastern on July 28, 2016 on the following motion:

• Authorize NERC staff to solicit members for an Order No. 829 Cyber Security Supply ChainManagement Standard Authorization Request and standard drafting team (SDT). Thesolicitation period shall be no less than 21 days, and NERC staff shall present a recommendedSDT to the SC at its September 14, 2016 meeting.

As indicated below, SC voted and the motion passed. The motion and results will be added to the September 19, 2016 minutes of the SC as an informational attachment.

Representative Item Vote

Lou Oberski Yes

Laura Lee

Charles Yeung Yes

Ben Li Yes

John Bussman

Scott Miller Yes

Barry Lawson Yes

Chris Gowder Yes

Colt Norrish

Randy Crissman Yes

Brenda Hampton Yes

Andrew Gallo Yes

Marion Lucas

Frank McElvain Yes

David Kiguel Abstain

Robert Blohm Yes

Agenda Item 18g Standards Committee September 14, 2016

Standards Committee Action Without a Meeting Results – July 28, 2016 2

Mark Harris Yes

Steven Rueckert Yes

Guy Zito Yes