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Emerging Environmental Regulations Impacting Bulk Power System Reliability: Next Steps on NERC Assessments
Thomas Burgess, Vice President and Director, RAPAMember Representatives Committee MeetingMay 6, 2015
RELIABILITY | ACCOUNTABILITY2
Phase I: Key Findings
1. Accelerates a fundamental change in the generation mix and transforms grid-level reliability services, diversity, and flexibility
2. Industry needs more time to develop coordinated plans to address shifts in generation and corresponding transmission reinforcements
3. Remaining coal-fired generation fleet may need to change operational dispatch from baseload to seasonal peaking, potentially eroding plant economics and operating feasibility
4. Energy and capacity will shift to gas-fired generation, requiring additional infrastructure and pipeline capacity
RELIABILITY | ACCOUNTABILITY3
Phase I: Scope of Assessment
• Part 1: Resource adequacy evaluation Scenarios evaluated Generation capacity and resource changes Energy dispatch changes
• Part 2: Transmission implications Infrastructure needed Industry survey of implementation
• Part 3: Overview of studies by reliability authorities
RELIABILITY | ACCOUNTABILITY4
Phase I: Recommendations
• Continue NERC’s assessment strategy • Coordinated regional industry planning groups’ assessments and
state partnerships • Infrastructure deployment requires more time • Include a formal reliability assurance mechanism in the final rule • State and regional plans developed in consultation with reliability
authorities
RELIABILITY | ACCOUNTABILITY5
NERC Advisory Role
• Serve as a resource to discuss and advise on reliability implications with regulators and industry decision-makers
• Provide reliability guidance and considerations by which plans would be developed, reviewed, and evaluated
• Reliability assurance mechanism needed Assured reliability provisions in place Plan development Plan implementation
• Continue to assess long and short-term reliability, and incorporate state or regional plans as they merge into existing planning
RELIABILITY | ACCOUNTABILITY6
November 2014
April2015
December2016
Q22016
EPA Special Assessment
Phase III• Placeholder for
assessment completed once SIPs are developed
• Potentially integrate with 2016 LTRA
EPA Special Assessment
Initial Reliability Review
• High-level reliability considerations
• Assessment of EPA’s rule assumptions
EPA Special Assessment
Phase II• Additional
assessment of emerging SIPs
• Reflects final rule• Based on known
requirements • Complete before
states submit SIPs
EPA Special AssessmentPhase I
• Evaluation of resource and transmission adequacy
• Sensitivity analysis used to provide range of potential outcomes
EPA Reliability Impacts AssessmentMultiple Phase Approach
RELIABILITY | ACCOUNTABILITY7
State of Reliability ReportPreview of Key Findings
Howard Gugel, Director of Performance Analysis Member Representatives Committee MeetingMay 6, 2015
RELIABILITY | ACCOUNTABILITY2
Weather Stresses BPS Reliability
RELIABILITY | ACCOUNTABILITY3
Continued Decline in Average Transmission Outage Severity
Misoperation
Failed AC Substation Equipment
Power System Condition
Lightning
Failed AC Circuit Equipment
Weather, Excluding Lightning
0.1
0.11
0.12
0.13
0.14
0.15
0.16
0.17
0.18
0.19
0.2
-0.1 -0.08 -0.06 -0.04 -0.02 0 0.02 0.04 0.06 0.08 0.1
Expe
cted
Tra
nsm
issi
on O
utag
e Se
verit
y
Correlation with Transmission Outage Severity
RELIABILITY | ACCOUNTABILITY4
Significant Decrease in Unplanned Transmission Outages Resulting in Loss of Load
RELIABILITY | ACCOUNTABILITY5
Frequency Response Trend Remains Stable
Eastern Interconnection Western Interconnection
ERCOT Interconnection Québec Interconnection
RELIABILITY | ACCOUNTABILITY6
No Load Loss Due To Physical or Cyber Security Events
• BES Security Metric 1: Reportable Cyber Security Incidents 3 Reportable Cyber Security Incidents in 2014 None resulted in loss of load
• BES Security Metric 2: Reportable Physical Security Events 47 reports of physical security threat events 9 caused physical damage or destruction None resulted in loss of load
RELIABILITY | ACCOUNTABILITY7
Use of EEA Level 3 Continues to Decline
0
5
10
15
20
25
30
35
40
45
2006 2007 2008 2009 2010 2011 2012 2013 2014
Num
ber o
f EEA
3 Ev
ents
Year
EEA3 Events NERC-Wide
0
5
10
15
20
25
30
35
40
2006 2007 2008 2009 2010 2011 2012 2013 2014
Num
ber o
f EEA
3 Ev
ents
EEA3 Events by Region
FRCC MRO NPCC RF
SERC SPP TRE WECC
Steady decline NERC-wide since 2011
Overall regional rate declining
RELIABILITY | ACCOUNTABILITY8
State of Reliability 2015 Schedule
May 6 Report Sent to Board of Trustees for Review
May 14 BOT Teleconference and Vote to Accept Report
May 19 Target Release
RELIABILITY | ACCOUNTABILITY9
2015 Summer Reliability AssessmentThomas Burgess, Vice President and Director, RAPAMember Representatives Committee MeetingMay 6, 2015
RELIABILITY | ACCOUNTABILITY2
Reliability Topics and Findings
1. Impacts of ongoing California drought on hydro output 2. Pipeline upgrade and impacts on resources in New England3. Improved coal inventories in the Midwest 4. Improved reserve margin in MISO, TRE-ERCOT and NPCC-New
York5. New operational risk assessment utilizes scenario analysis to
test severe conditions
RELIABILITY | ACCOUNTABILITY3
Improved reserve margin in MISO, TRE-ERCOT and NPCC-New York• MISO Reserve margin - 17.3%, versus 15% for 2014 Includes any capacity in the south in excess of south demand, reserve
requirement, and 1,000 MW contract path limitation
• TRE-ERCOT Reserve margin - 15.7%, 3.76% higher than 2014 reserve margin Change in methodology for on-peak wind capacity contributiono 12% non-coastal, 56% coastal
• NPCC-New York 1000 MW of additional generation Decreased industrial load in upstate area
Key Finding #4
RELIABILITY | ACCOUNTABILITY4
Pilot: Operational Risk Assessment
Example of Operational Risk Assessment - FRCC Region
Resource Margin
RELIABILITY | ACCOUNTABILITY5
2015 SRA Schedule
May 6 Planning Committee vote to accept report
May 6 Report sent to NERC Technical Publications for final review
May 11 Report sent to Board of Trustees for review
May 14 BOT teleconference and vote to accept report
Week of May 18 Target release
RELIABILITY | ACCOUNTABILITY6
ERO Reliability Assessments: Strategic Plan for Process and Analytic Improvements
Thomas Burgess, Vice President and Director, RAPAMember Representatives Committee MeetingMay 6, 2015
RELIABILITY | ACCOUNTABILITY2
• Adopting additional measures on Essential Reliability Services (ERS)
• Integrating probabilistic approaches to identify high- and low-probability conditions
• Development of wide-area transmission adequacy and deliverability analysis
• Using performance data (GADS, TADS, and DADS) to evaluate potential system conditions and resource availability
Analytical Improvements Considered for Long-Term Reliability Assessment
RELIABILITY | ACCOUNTABILITY3
Analytical Improvements Considered for Short-Term Reliability Assessment
• Non-seasonal peak (shoulder and light load) periods due to high transfers
• Increased focus on operational risks• Adopting probabilistic approaches and examination of a wider
range of impacts and risks (i.e., 90/10 conditions)• ERS measures
RELIABILITY | ACCOUNTABILITY4
• Accelerated changes in resource mix with greater reliance on natural gas and renewable resources
• Declining planning reserve margins in several areas impacting overall system flexibility
• Existing and proposed environmental regulations and policy initiatives expected to impact the electric industry
• Rapid integration of variable generation and distributed energy resources
MRC input and insights on emerging reliability issues for inclusion in the 2015 LTRA are greatly appreciated
2015 LTRA Preliminary Reliability Issues
RELIABILITY | ACCOUNTABILITY5
Summer Reliability Assessment• Board/MRC embargoed version release – May 11• Board consideration for approval – May 14• Target release – May 18
Winter Reliability Assessments• Board/MRC embargoed version release – Early November• Board consideration for approval – Early November• Target release – Mid-November
Long-Term Reliability Assessment• Board/MRC embargoed version release – November 6• Board consideration for approval – November 20• Target release – December 1
2015 Reliability Assessments Milestones
RELIABILITY | ACCOUNTABILITY6
ERO Enterprise Effectiveness Survey ResultsKristin Iwanechko, Associate Director, Member Relations and MRC SecretaryMember Representatives Committee MeetingMay 6, 2015
RELIABILITY | ACCOUNTABILITY2
• NERC partnered with TalentQuest to conduct survey on ERO Enterprise effectiveness
• 73 survey questions across 10 topic areas• Issued January 2015 to 1,112 individuals 247 responses on behalf of 441 NERC Compliance Registry (NCR) numbers 19 responses with no associated NCR number
• Overall results were positive ERO Enterprise averages ranged from 3.42 to 4.45 NERC ratings ranged from 3.04 to 4.42
Overview
RELIABILITY | ACCOUNTABILITY3
• Audit teams conduct themselves in a professional and credible manner (4.45)
• Most recent audit process conducted in a timely manner (4.33)• Audit team is prepared and organized (4.31)• Audit team adheres to established rules and processes (4.18)• Audit report identifies clear, definitive, and actionable items to
address (4.16)
Highest Rated Items
RELIABILITY | ACCOUNTABILITY4
• Registration Registers and deregister entities commensurate with risk to the BES (3.42) Timely and effective response during the Registry Appeals Process (3.24)
Risk-based registration phase I implementation and phase II analysis
• Risk-Based Compliance Monitoring and Enforcement Consistency in tools, processes, and templates where necessary (3.42) Efficiency and effectiveness of compliance activities (3.39)
Implement risk-based compliance monitoring and enforcement program
Areas for Improvement
RELIABILITY | ACCOUNTABILITY5
• Standards Cost-effectiveness in addressing the risk (3.04) Practicality to implement (3.14) Clarity of standards (3.20)
Request policy input on the future of standards development
Areas for Improvement
RELIABILITY | ACCOUNTABILITY6
• Review comment analysis for additional insights• Implement action plans to address areas for improvement• Provide quarterly progress reports to NERC Board of Trustees• Incorporate lessons learned into 2015 survey
Next Steps
RELIABILITY | ACCOUNTABILITY7
Revised Pro Forma and Individual Regional Delegation Agreement
Charles A. Berardesco, Senior Vice President, General Counsel and Corporate SecretaryMember Representatives Committee MeetingMay 6, 2015
RELIABILITY | ACCOUNTABILITY2
• Regional Delegation Agreements (RDAs) expire on December 31, 2015
• Proposed NERC Board action: Approve revised, pro forma RDA Authorize NERC to execute individual RDAs
• Pro forma RDA and individual RDAs are also pending approval of the Regional Entity boards
• FERC may approve (with or without modifications) or reject the RDAs
Background
RELIABILITY | ACCOUNTABILITY3
• Develop guidance, policies and procedures, and oversight parameters
• Confirm that the NERC President may issue a directive to bind a Regional Entity when collaboration is not successful
• Conclude the directive process once the NERC President approves a directive
Regional Entity Collaboration
RELIABILITY | ACCOUNTABILITY4
• Define the types of confidential information that may be exchanged within the ERO
• Recognize each Regional Entity as a “third party beneficiary” to better ensure confidentiality
• Clarify that Section 1500 of the NERC Rules of Procedure (NERC ROP) continues to govern the use and permitted disclosure of registered entity confidential information outside of the ERO
Confidentiality
RELIABILITY | ACCOUNTABILITY5
• Remove Regional Entity-specific bylaws and Reliability Standards development procedures as exhibits to the RDAs
• Ensure that future changes to such procedures remain consistent with NERC ROP and Commission directives
• Continue to submit changes for NERC Board of Trustees and FERC approval
Regional Entity Bylaws and Standards Development Procedures
RELIABILITY | ACCOUNTABILITY6
• Update provisions that are not consistent with current, risk-based practices
• Maintain NERC’s authority to review all Regional Entity dispositions of noncompliance
• Recognize NERC’s ability to develop and implement policies and procedures for the review and approval of such dispositions
Compliance Monitoring and Enforcement
RELIABILITY | ACCOUNTABILITY7
• Assess the Regional Entities’ performance beyond compliance with the RDAs and the NERC ROP
• Identify policies and procedures, guidance and directives as additional oversight tools
• Monitor Regional Entities’ implementation of policies and procedures, guidance, and directives
• Emphasize that oversight tools pertain to Regional Entities’ delegated authority
General Oversight
RELIABILITY | ACCOUNTABILITY8
• Allow for a five-year term, with one automatic five-year extension
• Remove five-year audit renewal condition• Continue Commission-mandated ERO five-year performance
assessments
Term and Termination
RELIABILITY | ACCOUNTABILITY9