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- 1 - LRP 3162011 922 AM
1040 Avenue of the Americas - 10th Floor New York New York 10018-3703
NPCC Regional Standards Committee Preliminary Agenda--Draft
Meeting 11-2
March 16 2011 1000 am - 500 pm March 17 2011 800 am - 1000 am
March 17 2011 1000 am - noon--Joint Meeting with the CC
Dominion Resources Services Inc Dominion Riverside Campus
Pump House Building--Second Floor 120 Tredegar Street Richmond Virginia
Dress Business Casual
RSCnpccorg Call in 719-785-1707 Guest Code 8287
1 Introductions-Agenda Review-Roster a NPCC Board of Directors approved Ben Wu (Orange and Rockland Utilities
Sector 1) and Donald Weaver (New Brunswick System Operator Sector 2) for RSC membership
2 RSC February 2011 Meeting Minute Approval and Antitrust Guidelines (in Meeting Materials Package) a
3 Action Item Assignment List and Ongoing Assignments (in Meeting Materials
Package) (Refer to Action Item Table [Item 65] at the back of Agenda) a NPCC Members on NERC Drafting Teams
- 2 - LRP 3162011 922 AM
4 Review Executive Tracking Summary (in Meeting Materials Package)
a Review entries
5 FERC (in Meeting Materials Package) a FERC Feb 17 2011 Meeting Agenda b FERC March 10 2011 Meeting Agenda Item NOPR Docket No Posted End Date When
Effective T1 Integration of Variable
Energy Resources Docket No RM10-11-000
22511 3111
T2 Fourth Quarter 2010 Compliance Filing Of The North American Electric Reliability Corporation In Response To Paragraph 629 Of Order No 693 And Request To Terminate Compliance Filing Obligation
Docket No RM06-16-000
22811
Item FERC Orders Docket No Posted Summary U1 Order Dismissing
Compliance Filing--Mandatory Reliability Standards for Critical Infrastructure Protection
RM06-22-014 31011 FERC dismisses NERCrsquos 9910 compliance filing in response to FERCrsquos 31810 Order regarding CIP Standards with respect to nuclear power plants as moot
- 3 - LRP 3162011 922 AM
6 Current and Pending Ballots (in Meeting Materials Package)
a
b
7 Overlapping Postings (in Meeting Materials Package)
a
8 Join Ballot Pools (in Meeting Materials Package)
a
9 Posted for Comment (in Meeting Materials Package)
a
Project 2009-02 - Real-time Reliability Monitoring and Analysis Capabilities
Concept White Paper Comment Form (link to Word Version) Announcement
Comment Form 21611 4411
b Notice of proposed Changes to RFC Rules of
Procedure and Request for Comments
Comments-- Electronic submission to ropcommentsnercnet
3111 41511
c Proposed Amendments to NERC Rules of Procedure Appendices 3B and 3D
Comments-- Electronic submission to ropcommentsnercnet
3111 41511
d
Project 2010-07 - Generator Requirements at the Transmission Interface - Various BAL CIP EOP FAC IRO MOD PER PRC TOP and VAR standards
White Paper Attachment 1 Attachment 2 Announcement
Informal Comment Period--Click on Submit
Comments--Comments to be sent to
Malloryhugginsnercnet
3411 4411
- 4 - LRP 3162011 922 AM
e
Project 2009-01 - Disturbance and Sabotage Reporting - CIP-001 and EOP-004
EOP-004-2 Redline to last posted Comment Form (link to Word Version) Implementation Plan CIP-001-1 EOP-004-1 Announcement
Comment Form 3911 4811
Item 9a--Will not make NERCrsquos active project list 10 Reference Documents Posted For Comment
a
11 Concluded Ballots (in Meeting Materials Package) httpsstandardsnercnetBallotsaspx
(clicking in the column to the right of ldquoBallot Periodsrdquo column links to the Ballot Results)
Results of Ballot
RSC RecommendDate
a Project 2010-11 - TPL Table 1
Footnote B Recirculation
Ballot 12611 2511
Quorum 9361
Approval 8654
Yes 1511
b Project 2007-07 - Vegetation
Management - FAC-003
Successive Ballot and
Non-Binding Poll
21811 22811
Quorum 7928
Approval 7934
Yes 22211
c
Project 2006-06 - Reliability Coordination - COM-001 COM-002 IRO-001 and IRO-014
Initial Ballot 22511 3711
Quorum 8710
Approval 4954
Yes 3211
d Project 2007-23 - Violation
Severity Levels Non-binding
Poll 2911 21811
Ballot Pool 310
Opinions 141
Yes 102810
72 Support
- 5 - LRP 3162011 922 AM
e Project 2010-13 - Relay Loadability
Order - PRC-023
Successive Ballot and
Non-Binding Poll
12411 21311
Quorum 8395
Approval 6571
Yes 21111
f Project 2010-13 - Relay Loadability Order - PRC-023
Recirculation Ballot
22411 3611
Quorum 8735
Approval 6883
Yes 21111
12 Posted For 30-Day Pre-Ballot Review (Open Ballot Pools) Between RSC
Meetings
a
13 Concluded Comment Forms (in Meeting Materials Package)
a Standards Project Prioritization Reference Document and Tool
Comment Form
12111 21011
b Project 2007-12 - Frequency Response Comment
Form 2411 3711
c Project 2007-07 - Vegetation Management - FAC-003 Comment Form
12711 22811
d Project 2007-23 - Violation Severity Levels Comment
Form 12011 21811
e Project 2006-06 - Reliability Coordination - COM-001
COM-002 IRO-001 and IRO-014 Comment
Form 11811 3711
f Regional Reliability Standards - PRC-006-NPCC-1 -
Automatic Underfrequency Load Shedding
Comment Form
(no comments submitted)
11011 22411
g CAN-0015--Draft CAN-0015 Unavailability of NERC Tools Comments 2411 21811
h CAN-0016--Draft CAN-0016 CIP-001-1 R1 - Applicability to Non-BES
Comments 2411 21811
i CAN-0017--Draft CAN-0017 CIP-007 R5 System Access
and Password Controld Comments 21111 3411
j CAN-0018--Draft CAN-0018 FAC-008 R121 - Terminal
Equipment Comments 2411 21811
k Proposed Changes to Rules of Procedure to Add Section
1700 - Challenges to Determinations Comments 21411 3711
- 6 - LRP 3162011 922 AM
14 Reference Documents Posted For Comment Between RSC Meetings
a
15 Drafting Team Nominations Open (Current and between RSC Meetings)
a
16 NERC Meetings (in Meeting Materials Package) a ERO-RAPA b MRC and BOT Meetings
1 Member Representatives Committee and Board of Trustees Meeting Feb 16-17 2011
2 Board of Trustees Conference Call March 10 2011 a The NERC 2011-2013 Workplan with the prioritized standards b The PRC-023-1 Standard (Relay Loadability) Phase 1 due to FERC
by March 16 2011 c The VSLs for the CIP Version 4 d A set of VSLs for various other standards
e The NERC filing in response to the FERC performance assessment was reviewed discussed and approved as an Informational filing for FERC due date for filing is March 18 2011
17 NERC RSG RRSWG (in Meeting Materials Package) a RSG Feb 14 2011 Conference Call agenda b RSG March 15 2011 Conference Call agenda
18 Standards Committee Report (in Meeting Materials Package) a Two Standards Committee Positions open Nominations closed March 8
2011 b Ballot results of the Standards Committee E-mail ballot of the proposed
Reliability Standards Development Plan 2011-2013 c Notes March 10 2011 Standards Committee Meeting 19 SCPS Meeting a SDT selection criteria 20 NERC Compliance Application Notices a Comments to the CAN process
21 NERC Bulk Electric System Definition (in Meeting Materials Package) a Drafting Team members b NERC Staff Comments on Bulk Electric System (BES) Concept
Document c Drafting Team meetings 1 March 2-4 2011 meeting
- 7 - LRP 3162011 922 AM
d Summary of Definition of BES Drafting Team meetings sent to the NPCC Board of Directors
1 Feb 9-11 2011 2 March 2-4 2011 e Work of the RBESDCG f Brian Evans-Mongeon presentationdiscussion
22 NPCC Regional Standards--Update (in Meeting Materials Package)
a Disturbance Monitoring (PRC-002-NPCC-01) 1 VSLs approved by NPCC membership NERC Board of Trustees
approved Nov 4 2010 Being prepared for FERC and Canadian Provincial authority filings
b Underfrequency Load Shedding 1 Regional Standard Drafting Team has responded to all comments
received in the 2nd Open Process Posting TFSS has recommended RCC endorsement for RSC approval of a 30 day pre-ballot review
a Ten day ballot concluded on Jan 28 2011 Did not get quorum RSC remanded back to Drafting Team
b Drafting Team Meeting scheduled for March 21-22 2011 at the NPCC Offices to answer comments received to the NERC posting and address outstanding issues
c Special Protection System d Regional Reserve Sharing 1 Draft RSAR developed 2 TFCO soliciting for Drafting Team members
23 NY adoption of more stringentspecific NPCC Criteria
a Status of the filing 24 Directory and Regional Work Plan Status
a Directory effective dates Directory Number
Title Lead Group Status
Current Activity
1 (A-2) Design and Operation of the Bulk Power System
Approved on 1212009
TFCP has charged CP11 with a comprehensive review of Directory 1 to include the triennial document review an examination of the NERC TPL standards the existing NPCC planning criteria and the implementation of Phase 2 of the Directory Project which will reformat existing Directory criteria into NERC style requirements CP11 received additional direction and feedback from TFCP at the February 2011 TFCP meeting CP11rsquos schedule calls for presenting a final draft to RCC in November 2011
2 (A-3) Emergency Operation
Approved on 102108
Automatic UFLS language transferred to Directory 12 Next TFCO review Oct 21 2011
- 8 - LRP 3162011 922 AM
3 (A-4) Maintenance Criteria for BPS Protection
Approved on 71108
TFSP review underway
4 (A-5) Bulk Power System Protection Criteria
Approved on 12109
TFSP review underway
5 (A-6) Operating Reserve
TFCO Directory5 was approved by the Full Members on December 2 2010 TFCO working to resolve outstanding reserve issues associated with Directory 5 TFCO expects to post a revised version of Directory 5 to the Open Process this spring
6 New Reserve Sharing
TFCO TFCO considering draft of a new Directory on Regional Reserve Sharing which would replace C38 until a Regional Standard is developed TFCO expects to psot draft of Directory 6 this spring
7 (A-11)
Special Protection Systems
Approved on 122707
TFSP currently reviewing Directory 7 in accordance with the NPCC Reliability Assessment Program TFCP and TFSS will agree on revisions to the SPS approval and retirement and send any proposed changes to TFSP
8 (A-12)
System Restoration
Approved on 102108
TFCO made revisions to criteria for battery testing in October 2010 Next review date July 9 2012
9 (A-13)
Verification of Generator Real Power Capability
Approved on 122208
Directories 9 and 10 have been identified to be reformatted in accordance with Phase 2 of the Directory Project Additionally TFCO to incorporate draft language that would revise section 70 to ensure that documentation is not sent to TFCO The next TFCO review is scheduled for July 2012
10(A14) Verification of Generator Reactive Power Capability
Approved on 122208
Refer to Directory 9 preceding
12 UFLS Program Requirements
Approved on 62609
Small entity (less than 100MW) revision approved by Full Members on 332010 The RCC approved one additional year for Quebec to complete UFLS implementation (Quebec implementation term is now three years) Open Process posting concluded on Jan 21 2011 that considered revisions to the UFLS Implementation Plan
- 9 - LRP 3162011 922 AM
25 Review RFC MRO Standards Relevant to NPCC (in Meeting Materials
Package) a RFC Standards Under Development webpage
httpsrsvprfirstorgdefaultaspx b RFC Standard Voting Process (RSVP) webpage ReliabilityFirst Corporation - Reliability Standards Voting Process MOD-025-RFC-01 - Verification and Data Reporting of Generator Gross
and Net Reactive Power Capability passed its 15 day Category vote and was approved by the RFC Board of Directors at their March 3 2011 Meeting
Standard Under
Development Status Start Date End Date
1
2
c Midwest Reliability Organization Approved Standards
httpwwwmidwestreliabilityorgSTA_approved_mro_standardshtml (click on RSVP under the MRO header)
d Midwest Reliability Organization Reliability Standard Voting Process webpage (table lists standards under development) Midwest Reliability Organization - Reliability Standards Voting Process
e As of June 14 2010 MRO suspended its regional standards development
26 Report on NERC NAESB and Regional Activities (in Meeting Materials
Package) a Report on NERC NAESB and Regional Activities 1 Jan 31 2011 2 Feb 28 2011
27 Task Force Assignments
Standard Under Development Status Start Date End Date
1 PRC-006-MRO-01 - Underfrequency Load Shedding Requirements (see e below)
Was posted for second 30 day
comment period 51910 - 61710
2
- 10 - LRP 3162011 922 AM
28 Future Meetings and Other Issues (in Meeting Materials Package)
a Department of Energy Launches Cyber Security Initiative b FERC Cybersecurity Efforts c Severe Impact Resilience Task Force (SIRTF) formed d Remarks of Gerry Cauley to the House Armed Services Committee
Subcommittee on Emerging Threats and Capabilities e NERC Critical Infrastructure Protection Committee Dec 8-9 2010
Meeting Minutes f Draft for Comment NPCC Board Minutes 2-8-11 Meeting and NERC MRC
and BOT Summary Notes g Draft 7 of SERC Underfrequency Load Shedding Standard Posted for
Comments Due March 24 2011 h SPP RE UFLS Regional Standard- Balloting Results-Proposed Standard
Fails i CIP implementation questions
j Cyber Attack Task Force Formed as Part of Coordinated Action Plan k Presentations from the 2011 NARUC Winter Committee Meetings httpwwwnarucorgmeetingpresentationscfm92 l NERC Operating Committee March 8-9 2011 Meeting--notes m NERC Planning Committee March 8-9 2011 Meeting--notes
RSC 2011 Meeting Dates
May 18-19 2011 Saratoga New York
October 19-20 2011 Boston Massachusetts
August 3-4 2011 Montreal Quebec
Nov 30 - Dec 1 2011 Toronto Ontario
2011 RSC Conference Call Schedule (call 212-840-1070--ask for the RSC [Guyrsquos or Leersquos] Conference Call)
April 1 2011 August 19 2011 April 15 2011 Sept 2 2011 April 29 2011 Sept 16 2011 May 13 2011 Sept 30 2011 June 3 2011 Oct 28 2011 June 17 2011 Nov 10 2011 (Thursday) July 1 2011 Dec 16 2011 July 15 2011 Dec 30 2011
- 11 - LRP 3162011 922 AM
BOD 2011 Meeting Dates
May 3 2011 Teleconference September 20 2011 NPCC June 30 2011 NPCC October 26 2011 Teleconference
July 28 2011 Teleconference November 30 2011 Toronto
RCC CC and Task Force Meeting Dates--2011
RCC June 1 Sept 8 Nov 29 CC April 13 May 16 June 14-15 July 13
August 17 Sept 21-22 Oct 19 Nov 16 Dec 13-15
TFSS TFCP May 11 August 17 Nov 2 TFCO April 14-15 August 11-12 Oct 6-7 TFIST TFSP March 22-24 May 24-26 July 19-21
Sept 27-29 Nov 15-17
- 12 - LRP 3162011 922 AM
Joint Meeting With CC
1 Directory Revision Schedule 2 NPCC Compliance Schedule for 2011 and 2012 3 CCRSC Involvement with Review of Directories 4 Directory Format to clearly identify more Stringent NPCC Criteria 5 CANs enforcement 6 Transformation of the NPCC Directories and other Criteria Documents that
support the non-approved NERC fill-in-the blank standards into Regional Reliability Standards
Examples
Directory 1MOD-11 amp MOD-13
Directory 12 PRC-006 (Continent Wide UFLS once approved) and the presently approved PRC-007 (to be retired by Project 2007-1)
Directory 9 MOD-024-1
Directory 10MOD-025-1
7 Original intent of FERC Order 693 was for NERCRegions to produce Regional Standards to replace-fill-in-the-blank standards
8 Status of Standard PRC-006-NPCC-1 Automatic Underfrequency Load Shedding
9 Progress on the proposed revisions for Directory 12 and the proposed revisions to the Directory 12 Implementation Plan approved by TFSS
10 The Policy of continued use of NPCC Task Forces in the development of new Criteria in the present timeframe in which NERC is accelerating its roll out of more stringent enforceable Standards
Example - Proposed PRC-005-2 and Directory 3 - Is a more specific or more stringent protection system maintenance really needed within NPCC
Respectfully Submitted Guy V Zito Chair RSC Assistant Vice President-Standards
- 13 - LRP 3162011 922 AM
Northeast Power Coordinating Council Inc
Northeast Power Coordinating Council Inc (NPCC)
Antitrust Compliance Guidelines
It is NPCCrsquos policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition The antitrust laws make it important that meeting participants avoid discussion of topics that could result in charges of anti-competitive behavior including restraint of trade and conspiracies to monopolize unfair or deceptive business acts or practices price discrimination division of markets allocation of production imposition of boycotts exclusive dealing arrangements and any other activity that unreasonably restrains competition It is the responsibility of every NPCC participant and employee who may in any way affect NPCCrsquos compliance with the antitrust laws to carry out this commitment Participants in NPCC activities (including those participating in its committees task forces and subgroups) should refrain from discussing the following throughout any meeting or during any breaks (including NPCC meetings conference calls and informal discussions)
bull Industry-related topics considered sensitive or market intelligence in nature that are outside of their committeersquos scope or assignment or the published agenda for the meeting
bull Their companyrsquos prices for products or services or prices charged by their competitors
bull Costs discounts terms of sale profit margins or anything else that might affect prices
bull The resale prices their customers should charge for products they sell them bull Allocating markets customers territories or products with their competitors bull Limiting production bull Whether or not to deal with any company and bull Any competitively sensitive information concerning their company or a
competitor
Any decisions or actions by NPCC as a result of such meetings will only be taken in the interest of promoting and maintaining the reliability and adequacy of the bulk power system Any NPCC meeting participant or employee who is uncertain about the legal ramifications of a particular course of conduct or who has doubts or concerns about whether NPCCrsquos antitrust compliance policy is implicated in any situation should call NPCCrsquos Secretary Andrianne S Payson at 212-259-8218
- 14 - LRP 3162011 922 AM
Action Item List
Action Item
Number
Agenda Item
Number Description Owner Due Status
32 16b To discuss with Herbert Schrayshuen how HQ because of its unique operational requirements will be addressed in standards development
Guy Zito--member of Standards Committee Process Subcommittee
RSC Meeting
Ongoing as of 21010 Sylvain
Clermont and David Kiguel
working with Guy Zito Herbert Schrayshuen
replaced Gerry Adamski at NERC
The new NERC management team
will have to be made familiar with
this item August 20-21 2008
Feb 17-18 2009
June 17-18 2009
August 6-7 2009
60 3a NPCC representatives from NERC drafting teams that have documents posted for comments report at RSC Meetings
Lee Pedowicz RSC Meeting
Ongoing
61 21 Notify NPCC Drafting Team members that the RSC is available for advice at any time
Lee Pedowicz RSC Meeting
Ongoing
- 15 - LRP 3162011 922 AM
Action Item
Number
Agenda Item
Number Description Owner Due Status
and that they will be invited to call in with status reports
Sept 24-25 2009
Nov 4-5 2009
April 21-22 2010
63 ---- Coordination with the Compliance Committee to develop Joint Activity Action List
Greg Campoli RSC Meeting
Outgrowth of RSCCC joint
session April 21 2010 Ongoing Joint RSCCC Meeting this
meeting Ralph Rufrano rejoined the RSC in the
capacity of NPCC Compliance liaison Comments not to be
submitted on the CCEP
June 29-30 2010
65 ---- RSC to review the
NPCC Members on NERC Drafting Teams list Saurabh Saksena to maintain Will get input from Carol Sedewitz
RSC RSC Meeting
Ongoing
August 18-19 2010
- 16 - LRP 3162011 922 AM
Action Item
Number
Agenda Item
Number Description Owner Due Status
66 ---- Status of Memorandum of Understanding
Si-Truc Phan RSC Meeting
Provide update
67 ---- Effectively communicating to the RSC
Guy Zito Lee Pedowicz Michael Lombardi Saurabh Saksena Kurtis Chong Sylvain Clermont
RSC Meeting
Achieve RSC consensus
Nov 30 2010 Dec 2 2010
68 ---- Revise Regional Reliability Standards Development Procedure
Guy Zito Lee Pedowicz Michael Lombardi Saurabh Saksena Kurtis Chong Sylvain Clermont
RSC Meeting
Initial draft with revisions made
69 ---- Revise RSC Scope RSC RSC Meeting
Feb 2-3 2011
70 20 Talk to Stan Kopman and the CC about the process for submitting comments after Valerie Agnew (NERC) drafts CANs for their first posting Industry will have two weeks for comments
Guy Zito Lee Pedowicz
RSC Meeting
71 ---- Talk to Compliance about Reliability Standard RSAWs
Guy Zito RSC Meeting
- 17 - LRP 3162011 922 AM
Action Item
Number
Agenda Item
Number Description Owner Due Status
There should be a Compliance Committee representative on the Drafting Team
72 ---- Find out what other Regions are doing regarding interpretations
Guy Zito RSC Meeting
73 ---- Discuss consistency with the RSG
Guy Zito RSC Meeting
Northeast Power Coordinating Council Inc
Regional Reliability Standards Development Procedure Process Manual
Approved by NPCC Board of Directors September 19 2007
Approved by NERC BOT October 23 2007 Adopted by FERC March 21 2008
1
NPCC
REGIONAL RELIABILITY STANDARDS DEVELOPMENT PROCEDUREPROCESS MANUAL
TABLE OF CONTENTS
NO TABLE OF CONTENTS ENTRIES FOUNDERROR NO TABLE OF CONTENTS ENTRIES FOUNDI EXECUTIVE SUMMARY 2
II REGIONAL RELIABILITY STANDARD DEVELOPMENT PROCEDURE 1 CHARACTERISTIC ATTRIBUTES 2 2 ELEMENTS OF A REGIONAL STANDARD 5 3 TERMS AND FUNCTIONS 8 4 PROCEDURE DESCRIPTION 10 5 FLOWCHART 15 6 ERO AND REGULATORY APPROVALS 16
7 APPEALS 16 III APPENDIX
A) RSAR FORM 19
2
Formatted Indent Left 0 Hanging 025Numbered + Level 1 + Numbering Style I IIIII hellip + Start at 1 + Alignment Left + Alignedat 025 + Indent at 075
3
I I EXECUTIVE SUMMARY The purpose of the Northeast Power Coordinating Council Inc (NPCC) is to enhance the reliability of the international interconnected bulk power system in Northeastern North America through the development of more stringent and specific regional reliability standards and compliance assessment and enforcement of continent-wide and regional reliability standards pursuant to the execution and implementation of a Regional Delegation Agreement with the Electric Reliability Organization (ERO) and applicable Canadian Memoranda of Understanding that are backstopped by the Federal Energy Regulatory Commission (FERC) and Canadian Provincial authorities In the development and enforcement of Regional Reliability Standards NPCC to the extent possible facilitates attainment of fair effective efficient and competitive electric markets
General Membership in NPCC is voluntary and is open to any person or entity including any entity participating in the Registered Ballot Body of the ERO that has an interest in the reliable operation of the Northeastern North American bulk power system
The This NPCC Regional Reliability Standards Development ProcedureProcess Manual describes the procedures policies and practices approved by NPCC members and implemented to ensure an ldquoopen fair and inclusiverdquo process for the transparent initiation development implementation and revision of NPCC Rregional Rreliability Sstandards (regional standards) necessary for the reliable operation of the international and interconnected bulk power system in Northeast North America These Sstandards will in all cases not be inconsistent with or less stringent than any requirements of the North American Electric Reliability CouncilElectric Reliability Organization (NERCERO) Reliability Standards The procedure will not unnecessarily delay the development of the proposed reliability standards Each regional reliability standard shall enable or support one or more of the-NERCERO reliability principles1
II REGIONAL RELIABILITY STANDARD DEVELOPMENT PROCEDUREPROCESS MANUAL
thereby ensuring that each standard serves a purpose in support of the reliability of the regional bulk power system Each standard shall also be consistent with all of pertinent reliability principles and criteria thereby ensuring that no standard undermines reliability through as an unintended consequence
The NPCC Regional Reliability Standards Development ProcedureProcess Manual is
1 CHARACTERISTIC ATTRIBUTES
bull Open mdash The NPCC Regional Reliability Standards Development ProcedureProcess Manual provides any person the ability to participate in the development of a standard Anyor entity that is directly and materially affected by the reliability of the NPCCrsquos bulk power system has the ability to participate in the development and approval of reliability standards NPCC
1 Available on the NERC website wwwnerccom
Comment [kbc1] Very longwindede COnsider revising
Comment [kbc2] See general note about consistency in the text box at the end of the document and make appropriate changes throughout the document if agree with this approach
Comment [kbc3] Why do we need this Consider deleting
Formatted Indent Left 0 Hanging 025
Comment [kbc4] Dont agree with change This manual describes the process
Formatted Indent Left 025 Hanging 025 Dont adjust space between Latin andAsian text
Comment [kbc5] Dont agree the manual describes the process so changed to Process
Comment [kbc6] Some repetition revised to remove
Formatted English (Canada)
4
utilizes a website to accomplish this Online posting and review of standards and the real time sharing of comments uploaded to the website allow complete transparency There are no undue financial barriers to participation Participation in the open comment process is not conditional upon membership in the ERO NPCC or any organization and participation is not unreasonably restricted on the basis of technical qualifications or other such requirements There are no undue financial barriers to participationNPCC utilizes a website to accomplish this Online posting and review of standards and the real time sharing of comments uploaded to the website allow complete transparency
bull Inclusive mdash The NPCC Regional Reliability Standards Development ProcedureProcess Manual provides any person with a direct and material interest the right to participate by expressing an opinion and its basis have that position considered and in the event they are not satisfied with the response to their opinion appealed the response through an established appeals process if adversely affecteddesired
bull Balanced mdash The NPCC Regional Reliability Standards Development ProcedureProcess Manual has seeks to achieve a balance of interests and all those entities that are directly and materially affected by the reliability of the NPCCrsquos bulk power system are welcome to participate and shall not be dominated by any two interest categories and no single interest category shall be able to defeat a matter This will be accomplished through the NPCC Bylaws 2
bull Fair Due Process mdash The NPCC Regional Reliability Standards Development ProcedureProcess Manual provides for reasonable notice and opportunity for public comment The procedure includes public notice of the intent to develop a standard a 45 calendar day public comment period on the proposed standard request or standard with due consideration of those public comments and responses to those comments will to be posted on the NPCC website A final draft of the notice of intent to develop the standard or the draft standard itself will be posted for a 30 calendar day pre-balloting period and thenafter which a ballot of NPCC Members will be conducted Upon approval by the NPCC Members the NPCC Board then votes to approve submittal of the Regional Reliability Standard to NERC
which defineing eight six sectors (categories) for voting All individuals and entities that are directly and materially affected by the reliability of the NPCCrsquos bulk power system are welcome to participate
bull Transparent mdash All actions material to the development of Regional Reliability Standards are transparent and information regarding the progress of a standards development action is made available to the public through postingsed on the NPCC website as well as through extensive email lists
In as much as NPCC is one of several regional entities within the Eastern Interconnection of North America there will be no presumption of validity by the ERO for any NPCC Regional Reliability Standard In order to receive the approval of
2 Available on the NPCC website wwwnpccorg
Comment [kbc7] Moved for better flow of ideas
Comment [kbc8] Vague and perhaps not needed unless there is some legal angle to this consider removing
Comment [kbc9] Needed
Comment [kbc10] Vague and perhaps not needed unless there is some legal angle to this consider removing
Comment [kbc11] Change to process
Comment [kbc12] The appellant need not be adversely affected must they
Comment [kbc13] Change to process
Comment [kbc14] We recall that the number of sectors is to be reduced from 8 to 6 Please confirm If Bylaws will not be amended to reflect this before themanual is approved leave as 8 and revise later
Comment [kbc15] Change to process
Formatted Indent Left 025
Field Code Changed
Formatted English (Canada)
5
the ERO the NPCC Reliability Standards Development Process must also achieve the following objectives
bull No Adverse Impact on Reliability of the Interconnection mdash An NPCC
Regional Reliability Standard provides a level of bulk power system reliability that is necessary and adequate to protect public health safety welfare and North American security and will not have an adverse impact on the reliability of the Interconnection or other Regions within the Interconnection
bull Justifiable Difference mdash An NPCC Regional Reliability Standard is based
on justifiable differences between Regions such as different electrical systems or facilities sensitivity of load to disruptions sensitivity of generation to disruptions frequency and voltage sensitivity system operating limit development and facilities ratings process electrical system interactions etc
bull Uniformity- mdash NPCC Regional Reliability Standards shall provide for as
much uniformity as possible with reliability standards across the interconnected bulk power system of the North American continent A NPCC Reliability Standard shall be more stringent than a continent-wide reliability standard may include a regional variation that addresses matters that the continent-wide reliability standard does not or shall be a regional difference necessitated by a physical difference in the northeastrsquos bulk power system3
where the interpretation of the phrase ldquophysical differencerdquo will be consistent with FERCrsquos Order issued September 22 2004 Granting Request For Clarification regarding Docket No PL04-5-000 Policy Statement on Matters Related to Bulk Power System Reliability
bull No Undue Adverse Impact on Commerce mdash An NPCC Regional Reliability Standard will not cause any undue adverse impact on business activities that are not necessary for reliability of the Region and its interconnected Regions All regional reliability standards shall be consistent with NERCrsquos market principles4
Other Attributes provisions of the NPCC Regional Reliability Standards Development ProcedureProcess Manual include
bull Maintenance of Regional Reliability Standards - NPCC Regional
Reliability Standards will be reviewed for possible revision at least every three years after FERC approval and follow the same process as in the case of a new standard If no changes are warranted the Regional Standards Committee (RSC) shall recommend to the NPCC Board that the standard be reaffirmed If the review indicates a need to revise or withdraw a standard a Regional Standard Authorization Request shall be prepared by the RSC and submitted in accordance with the NPCC Regional Reliability Standards Process The old
3 The interpretation of the phrase ldquophysical differencerdquo will be consistent with FERCrsquos Order issued
September 22 2004 Granting Request For Clarification regarding Docket No PL04-5-000 Policy Statement on Matters Related to Bulk Power System Reliability
4 Available on the NERC website wwwnerccom
Formatted Highlight
Comment [kbc16] There are two ways to approach using the indefinite article when placed in from of an acronym We just need to be consistent throughout the document I have flagged the cases I have seen
Formatted Highlight
Formatted Highlight
Comment [kbc17] Very unwieldy We have made this a footnote
Formatted Highlight
Formatted Font Not Bold
Formatted Indent Left 025
Formatted Font Not Bold
Formatted Font Not Bold
Comment [kbc18] We recommend moving this entire section and inserting it after the process for developing a new standard is described That way all of the players involved would have been described as well as the process for developing the new standard Also each of these three items should be placed in a separate section and written as a process with a flowchart included for each as necessary These changes should help to minimize some of the repetition that exists in the document as currently structured
Comment [kbc19] By whom See general comments in the text box on page 2
Comment [kbc20] From FERC (and Canadian Authority) approval or from NERC BOT approval Need to make this clear so a date can be clearly defined Since there can be
Comment [kbc21] Moved for better sequencing
Formatted Indent Left 0 Hanging 013Space After 6 pt
Formatted English (Canada)
Formatted English (Canada)
6
existing approved standard subject to revision will remain in place effect until such time as the revised version has received FERC or applicable Canadian Regulatory Authority approvals as appropriate passed through the entire process at which point the old standard it will be retired in accordance with any applicable new implementation plan associated with the newly approved regional revised standard The review process shall be conducted by soliciting comments from the stakeholders and through open posting on the NPCC website If no changes are warranted Regional Standards Committee (RSC) shall recommend to the NPCC Board that the standard be reaffirmed If the review indicates a need to revise or withdraw a standard a regional standard authorization request shall be prepared by the RSC and submitted in accordance with the standards development process contained in this procedure
bull Maintenance of the Regional Reliability Standards Development
ProcedureProcess Manual - This NPCC Regional Reliability Standards Development ProcedureProcess Manual will be reviewed for possible revision at least once every five years or more frequently if needed and subject to the same procedure as that ofapplies to the development of a regional standard All such revisions shall be subject to approval by the NPCC Board NERC FERC and could be subject to approval if required by applicable authorities in Canada The NPCC RSC has the authority to make non-substantive changes to this procedure and subsequently notify the NPCC Board for their concurrence at the Boardrsquosir next scheduled meeting
bull Interpretation of Standards - All persons who are directly and materially
affected by the NPCCrsquos bulk power system reliability shall be permitted to request an interpretation of an NPCC regional reliability standard The person requesting an interpretation will shall send an email request to the Regional Standards Process Manager (RSPMManager of Reliability Standards) as noted on the NPCC website explaining the specific circumstances surrounding the request and what clarifications are required as applied to those circumstances The request should shall indicate the material impact to the requesting party or others caused by the lack of clarity or a possibly incorrect interpretation of the regional standard The RSPMManager of Reliability Standards along with guidance from the RSC will forward the request to the originating Task Force to whom responsibility was originally assigned for which acted as the drafting team for that regional reliability standard The Task Force will address through a written response the request for clarification as soon as practical but not more than 45 business days from its receipt by the Task Force This written interpretation will be posted along with the final approved and adopted regional standard and will stand until such time as the regional standard is revised through the normal RSAR process at which time the regional standard will be modified to incorporate the clarifications provided by the interpretation
2 ELEMENTS OF A RELIABILITY STANDARD
bull Elements of a Regional Reliability Standard
Comment [kbc22] When does the process come to an end After FERC or NERC BOT this gives the impression that after NERC BOT adoption the standard will become effective Better to say after FERC or applicable Canadian Regulatory approvals or something similar
Comment [kbc23] Not strictly necessary since weve already said above that well be following the same process as for a new standard Reinstate if deemed necessary
Comment [kbc24] From when FERC date
Comment [kbc25] Too much detail since this will be repeated in Section 4 Prune this down
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Formatted Highlight
Comment [kbc26] why specify
Comment [kbc27] Stronger
Comment [kbc28] Should there be a step here for RSC or MRS review
7
To ensure uniformity of regional reliability standards and notavoid inconsistentcy with NERC continent-wide standards a regional reliability standard shall consist of the elements identified in this section of the procedure These elements are intended to apply a systematic discipline in the development and revision of regional standards This discipline is necessary to for achieving regional standards that are measurable enforceable and consistent as well as results-oriented56
ie
Performance-based Risk-based and CompetencyCapability-based
as well as being measurable enforceable and consistent The Standard Drafting Team (SDT) should strive to achieve a portfolio of performance risk and competencycapability-based mandatory reliability requirements that support an effective defense-in-depth strategy Each requirement should identify a clear and measurable expected outcome such as a) a stated level of reliability performance b) a reduction in a specified reliability risk or c) a necessary competency a) Performance-based - defines a specific reliability objective or outcome that has a direct observable effect on the reliability of the bulk power system ie an effect that can be measured using power system data or trendsdefines a particular reliability objective or outcome to be achieved In its simplest form a results-based requirement has four components who under what conditions (if any) shall perform what action to achieve what particular result or outcome b) Risk-based - defines actions of 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 actionspreventive requirements to reduce the risks of failure to acceptable tolerance levels 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 c) CompetencyCapability-based - defines capabilities needed to perform reliability functions and can be measured by demonstrating that the capability exists as requireddefines a minimum set of capabilities an entity needs to have to demonstrate it is able to perform its designated reliability functions A competency-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 All mandatory requirements of a regional reliability standard shall be within the standard document Supporting documents to aid in the implementation of
5 Results-based Standards see httpwwwnerccomfilezstandardsProject2010-06_Results-
based_Reliability_Standardshtml 6 Results-based Standards presentation see httpwwwnerccomfilesResults-Based-Standards-
102010pdf
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Comment [kbc29] See consistency comment in text box
Comment [kbc30] Need something stronger or more definitive
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8
a standard may be referenced by the standard but are not part of the standard itself The most current version of the approved NERC Reliability Standard template and its associated elements as or if applicable will be used at the time of the development of the NPCC Regional Reliability Standard to ensure all essential elements are contained therein to achieve consistency and uniformity and meet all statutory requirements A sample of the elements contained in the standard appears in Table 1 below however the latest ERO Board approved Standard template that may be found on the NERC website will supersede the list below at the time the regional standard is developed
Each regional reliability standard shouldshall enable or support one or more of the reliability principles as identified in the most recent set posted on the NERC website (see below) Each reliability standard shouldshall also be consistent with all of the reliability principles The intent of the set of NPCC regional reliability standards is to deliver an Adequate Level of Reliability as defined by NERC
a) 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 and Regional Reliability Standards Directories and Criteria
b) 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
c) 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
d) Plans for emergency operation and system restoration of interconnected bulk power systems shall be developed coordinated maintained and implemented
e) Facilities for communication monitoring and control shall be provided used and maintained for the reliability of interconnected bulk power systems
f) Personnel responsible for planning and operating interconnected bulk power systems shall be trained qualified and have the responsibility and authority to implement actions
g) The reliability of the interconnected bulk power systems shall be assessed monitored and maintained on a wide-area basis
h) Bulk power systems shall be protected from malicious physical or cyber attacks
Recognizing that bulk power system reliability and electricity markets are inseparable and mutually interdependent all regional reliability standards shall be
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9
consistent with the most recent set of mMarket iInterface pPrinciples as posted on the NERC website Consideration of the mMarket iInterface pPrinciples is intended to ensure that regional reliability standards are written such that they achieve their reliability objective without causing undue restrictions or adverse impacts on competitive electricity markets Elements of a Regional Reliability Standard A regional 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 regional reliability standard include mandatory and enforceable sections and informational sections of the standard Mandatory and Enforceable Sections of a Standard Title A brief descriptive phrase identifying the topic of the standard Number A unique identification number assigned in accordance with a published classification system to facilitate tracking and reference to the standards Purpose The reliability outcome achieved through compliance with the requirements of the standard Applicability Effective Dates Identification of 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 Measure Provides identification of the evidence or types of evidence needed to demonstrate compliance with the associated requirement Each requirement shall have at least one measure Each measure shall clearly refer to the requirement(s) to which it applies Evidence Retention Identification for each requirement in the standard of the entity that is responsible for retaining evidence to demonstrate compliance and the duration for retention of that evidence Variance A requirement (to be applied in the place of the continent-wide requirement) and its associated measure and compliance information that is applicable to a specific geographic area or to a specific set of functional entities Informational Sections of a Standard Application Guidelines Guidelines to support the implementation of the associated standard Procedures Procedures to support implementation of the associated standard Time Horizon The time period an entity has to mitigate an instance of violating the associated requirement4 Compliance Enforcement Authority The entity that is responsible for assessing performance or outcomes to determine if an entity is compliant with the associated standard
Comment [kbc31] Are these Market Interface Principles general enough that they apply to Canadian markets Can we include language to cater for Canadian market principles
Comment [kbc32] This looks like a cut and paste from the NERC Standards Process Manual so no editing done here Major reformatting is required
Comment [kbc33] Is this the end of the mandatory and enforceable section Heading required to indicated informationand a compliance section
10
Compliance Monitoring and Assessment Processes Identification of the processes that will be used to evaluate data or information for the purpose of assessing performance or outcomes with the associated standard Additional Compliance Information Any other information related to assessing compliance such as the criteria or periodicity for filing specific reports Compliance Elements Associated with a Standard 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 standard5 Each requirement in each reliabilityregional standard has an associated VRF and a set of VSLs VRFs and VSLs are developed by the drafting team working with NERCNPCC staff at the same time as the associated regional reliability standard but are not part of the reliabilityregional standard The NPCC Board of TrusteesDirectors is responsible for approving VRFs and VSLs Violation Risk Factors VRFs identify the potential reliability significance of non-compliance with each requirement Each requirement is assigned a VRF in accordance with the latest approved set of VRF criteria6 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 ldquodegreesrdquo of non-compliant 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 criteria7
The most current version of the approved NERC Reliability Standard template and its associated elements as or if applicable will be used at the time of the development of the NPCC Rregional Rreliability Sstandard to ensure all essential elements are contained therein to achieve consistency and uniformity and meet all statutory requirements
Table 1- Elements of a Regional Reliability Standard [update or delete]
Identification Number
A unique identification number assigned in accordance with an administrative classification system to facilitate tracking and reference (ie ldquoNPCC- BAL-002-0-Daterdquo which refers to NPCC Regional Standard referencing NERC BAL-002 Version 0 with NPCC Effective Date-final adoption by all Regional Authorities)
Title A brief descriptive phrase identifying the topic of the standard
Applicability Clear identification of the functional classes of entities responsible for complying with the standard noting any specific additions or exceptions
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Comment [kbc34] Will we maintain footnote from NERC document
Comment [kbc35] Is this how we envisage the process to work in NPCC
Formatted Highlight
Comment [kbc36] Will we maintain footnote
Comment [kbc37] Maintain footnote
11
The standard will be applicable to the Bulk Power System unless otherwise noted
Effective Date and Status
The effective date of the standard or prior to approval of the standard the proposed effective date If the effective date is tied to a regulatory approval the verbal formula indicating when the Regional standard is to become effective
Purpose The Results-Based purpose of the standard The purpose shall explicitly state what outcome end result will be achieved or is expected by from this Regional standard
Requirement(s) Explicitly stated Results-Based technical performance and preparedness requirements Each requirement identifies what entity is responsible and what action is to be performed or what outcome result is to be achieved Each statement in the requirements section shall be a statement for which compliance is mandatory
Risk Factor(s)
The potential reliability significance of each requirement designated as a High Medium or Lower Risk Factor in accordance with the criteria listed below
A High Risk Factor requirement (a) is one that if violated could directly cause or contribute to bulk power system instability separation or a cascading sequence of failures or could place the bulk power system at an unacceptable risk of instability separation or cascading failures or (b) is a requirement in a planning timeframe that if violated could under emergency abnormal or restorative conditions anticipated by the preparations directly cause or contribute to bulk power system instability separation or a cascading sequence of failures or could place the bulk power system at an unacceptable risk of instability separation or cascading failures or could hinder restoration to a normal condition
A Medium Risk Factor requirement (a) is a requirement that if violated could directly affect the electrical state or the capability of the bulk power system or the ability to effectively monitor and control the bulk power system but is unlikely to lead to bulk power system instability separation or cascading failures or (b) is a requirement in a planning timeframe that if violated could under emergency abnormal or restorative conditions anticipated by the preparations directly affect the electrical state or capability of the bulk power system or the ability to effectively monitor control or restore the bulk power system but is unlikely under emergency abnormal or restoration conditions anticipated by the preparations to lead to bulk power system instability separation or cascading failures nor to hinder restoration to a normal condition
A Lower Risk Factor requirement is administrative in nature and (a) is a requirement that if violated would not be expected to affect the electrical state or capability of the bulk power system
12
or the ability to effectively monitor and control the bulk power system or (b) is a requirement in a planning time frame that if violated would not under the emergency abnormal or restorative conditions anticipated by the preparations be expected to affect the electrical state or capability of the bulk power system or the ability to effectively monitor control or restore the bulk power system
Measure(s) Each requirement shall be addressed by one or more measures Measures are used to assess performance and outcomes for the purpose of determining compliance with the requirements stated above Each measure will identify to whom the measure applies and the expected level of performance or outcomes required demonstrating compliance Each measure shall be tangible practical and as objective as is practical It is important to realize that measures are proxies to assess required performance or outcomes Achieving the measure should be a necessary and sufficient indicator that the requirement was met Each measure shall clearly refer to the requirement(s) to which it applies
Table 2 Compliance Elements of a Regional Reliability Standard Compliance Monitoring Process
Defines for each measure
bull The specific data or information that is required to measure performance or outcomes
bull The entity that is responsible for providing the data or information for measuring performance or outcomes
bull The process that will be used to evaluate data or information for the purpose of assessing performance or outcomes
bull The entity that is responsible for evaluating data or information to assess performance or outcomes
bull The time period in which performance or outcomes is measured evaluated and then reset
bull Measurement data retention requirements and assignment of responsibility for data archiving
bull Violation severity levels Supporting Information Elements Interpretation Any interpretation of regional reliability standard that is
developed and approved in accordance with the ldquoInterpretation of Standardsrdquo section of Appendix A of this procedure to expound on the application of the standard for unusual or unique situations or to provide clarifications
Implementation Each regional reliability standard shall have an associated
13
Plan implementation plan describing the effective date of the standard or effective dates if there is a phased implementation The implementation plan may also describe the implementation of the standard in the compliance program and other considerations in the initial use of the standard such as necessary tools training etc The implementation plan must be posted for at least one public comment period and is approved as part of the ballot of the standard
Supporting References
This section references related documents that support reasons for or otherwise provide additional information related to the regional reliability standard Examples include but are not limited to
bull Glossary of terms
bull Developmental history of the standard and prior versions
bull Notes pertaining to implementation or compliance
bull Standard references
bull Standard supplements
bull Procedures
bull Practices
bull Training references
bull Technical references
bull White papers
bull Internet links to related information
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14
3 3 KEY PARTICIPANTS ROLES TERMS AND FUNCTIONS
bull NPCC Board of Directors (BOD Board) - The NPCC BOD shall consider for adoption regional reliability standards definitions variances and interpretations and associated implementation plans that have been processed according to the processes identified in this manual In addition the bBoard shall consider for approval VRFs and VSLs associated with each approved regional standard Once the BOD adopts a regional reliability standard definition variance or interpretation or implementation plan or once the BOD approves VRFs or VSLs the Bboard shall direct NPCC staff to submit the document(s) for approval by the NERC Board of Trustees
bull NPCC Members - The ballot body is comprised of all entities or individuals that
qualify for one of the stakeholder sectors within NPCC and as approved bystated in the NPCC BODBylaws All General and Full Members of NPCC can participate in the balloting of regional standards
bull Regional Standards Committee (RSC)mdashAn NPCC committee BOD -
appointed committee charged with management and oversight of the NPCC Regional Reliability Standards Procedure Process for development of regional standards VRFs VSLs definitions variances interpretations and implementation plans in accordance with this manual under a the sector based voting structure as described in the NPCC Bylaws
The RSC is an open and balanced stakeholder committee inclusive of all stakeholder interests that provide for or are materially impacted by the reliability of the bulk power system Its responsibilities are defined in detail in the NPCC RSC Scope
bull The NPCC RSC will consider requests for new or revised regional reliability standards and be available for advisement to the NPCC Board BOD on theregional standards and standards related issues in general
The RSC may not itself materially modify mandatory and enforceable sections of the a regional standard except without issuing a new notice to stakeholders regarding a vote of the modified standard Any RSC action will only be activated in the event of a minor corrections of to a the standard such as errata The RSC may make or revisions to the sections of the regional standard that are not mandatory and enforceable The RSC is responsible for managing the standards processes for development of standards VRFs VSLs definitions variances and interpretations in accordance with this manual The responsibilities of the RSC are defined in detail in the NPCC RSC Scope The RSC is responsible for ensuring that the regional standards VRFs VSLs definitions variances and interpretations and implementation plans developed by drafting teams are developed in accordance with the processes in this manual and meet NERCrsquos and FERCrsquos benchmarks for reliability standards including criteria for all governmental approvals
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Comment [kbc38] For consistency with whats stated on page 4
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Formatted Bullets and Numbering
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Comment [kbc39] The original text seems to confuse two ideas What do we really want to say
Comment [kbc40] Reference needed
Formatted Indent Left 075 No bullets ornumbering
Comment [kbc41] Not necessary since the RSC itself does not change the standard even after issuing this notice
Comment [kbc42] We need to describe guidelines or criteria for these modifications to be undertaken by the RSC and the process to be followed including some notification to members and request for comments Revisions to the compliance elements of a regional standard say without stakeholder notice and input could be controversial
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Comment [kbc43] The process for developing VRFs and VSLs is not described
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Comment [kbc44] Whats this Clarification needed
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Comment [kbc45] Reference needed()
15
The RSC is an open and balanced stakeholder committee inclusive of all stakeholder interests that provide for or are materially impacted by the reliability of the bulk power system
The RSC disposition regarding the rRegional sStandard aAuthorization rRequest (RSAR) which will in all cases be within 60 calendar days of receipt of a completed standard requestRSAR shall includebe one of the following
bull Accept the standard request as a candidate for development of a new standard revision of an existing standard or deletion of an existing standard The RSC may at its discretion expand or narrow the scope of the standard request under consideration The RSC shall prioritize the development of standards in relation to other proposed standards as may be required based on the volume of requests and resources
bull Reject the standard request If the RSC rejects a standard request a written explanation for rejection will be delivered to the requester within 30 calendar days of the decision
bull Remand the standard request back to the requester for additional work The NPCC standards process managerstaff will make reasonable efforts to assist the requester in addressing the deficiencies identified by the RSC The requester may then resubmit the modified standard request using the process above The requester may choose to withdraw the standard request from further consideration prior to acceptance by the RSC
The NPCC Standard Process responsibilities of the RSC will include
bull Review of NPCC Draft Standards (for such factors as completeness sufficient detail rational result and compatibility with existing NERC and other Regional standards) and clarifying standard development issues not specified in this procedure Under no circumstance will the RSC unilaterally make anysubstantial changes to the substancemandatory and enforceable sections essence of a draft standard
bull Ensure that the drafting team has given Ddue consideration to the work of the drafting team as well as the comments of stakeholders and minority objections in approving a proposed regional reliability standard to go to ballot
bull Approve standards for pre-ballot posting under a sector based voting structure as described later in the NPCC Inc Bylaws or
bull Remand the standard back to the Task Force acting as the drafting team for further work or recommend a change in those participating in the drafting team (ie a new drafting team)
bull NPCC Standards Staff mdash- The standards staff led by the Assistant Vice-
President of Standards is responsible for administering NPCCrsquos Rregional rReliability sStandards pProcesses in accordance with this manual The standards staff provides support to the RSC in managing the standards processes and in supporting the work of all regional drafting teams The
Comment [kbc46] The original text seems to confuse two ideas What do we really want to say
Comment [kbc47] Here weve started getting into process details which are repeated in the process description later on (Steps 1 amp 2) Suggest removing this paragraph and the next 3 bullets and placing withing the section describing steps 1 amp 2
Comment [kbc48] Shouldnt this be an NPCC staff function Does RSC have the resources to do this
Comment [kbc49] Repetition See above Delete one occurrence
Comment [kbc50] If the TF is involved in drafting the regional standard who would this work
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16
standards staff works to ensure the integrity of the standards processes and consistencyt of quality and completeness of the reliabilityregional standards through drafting team support and conducting quality reviews The standards staff facilitates all steps in the development of regional standards definitions variances interpretations and associated implementation plans The standards staff works with drafting teams in developing VRFs and VSLs for each regional standard The standards staff is responsible for presenting regional standards definitions variances and interpretations and associated implementation plans to the NPCC BOD for adoption When presenting standards-related documents to the NPCC BOD for adoption or approval the standards staff shall report the results of the associated stakeholder ballot including identification of unresolved stakeholder objections and an assessment of the documentsrsquos practicality and enforceability as well as any polling information obtained during standard development
bull Regional Standards Process Manager (RSPM) - The Regional Reliability
Standards Procedure shall be administered by a NPCC staff Regional Standards Process Manager The RSPM is responsible for ensuring that the development and revision of standards is in accordance with this manual The RSPM works to ensure the integrity of the process format consistency of quality and completeness of the reliability standards The RSPM facilitates all steps in the process
bull Reliability Coordinating Committee (RCC) mdash The RCC will support the
standards development process through the assignment of NPCC Task Forces They will may also provide perform a technical advisory role in the Regional Reliability Standards development procedureprocess through comments and recommendations
bull Requester mdash A Requester is any individual or an entity (organization company government authority including the RSC etc) that submits a completed request for development revision or withdrawal of a regional standard Any person or an entity that is directly and materially affected by an existing standard or the need for a new standard may submit a request for a new standard or revision to a standard The Requester is assisted by the RSAR drafting team (if one is appointed by the RSC) or NPCC standards staff to respond to comments and to decide if and whencomplete the drafting of the RSAR is prior to it being forwarded to the RSC with a request to draft a regional standard The Requester is responsible for the RSAR assisted by the RSAR drafting team and or Regional Standards Process ManagerNPCC standards staff until such time the RSC authorizes development of the standard The Requester has the option at any time to allow the RSAR drafting team to assume full responsibility for the RSAR The Requester may choose to participate in subsequent standard drafting efforts related to the RSAR
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Comment [kbc51] At what point do they do this During Open Process postings or are there other occasions
Comment [kbc52] Where did this come from It was not highlighted earlier as one of the RSCs responsibilities not in flow chart currently
17
bull Task Forces and Working Groups mdash The committees task forces and working groups within NPCC serve an active role in the standards process as follows
bull Identify the need for new or modified regional standards bull Initiate NPCC Standards actions by developing Regional Standard
Authorization Requests (RSARs) bull Develop comments (views and objections) to standards actions bull Participate in NPCC Standard drafting activities bull Provide technical oversight in response to changing industry conditions
and ERO Requirements bull Determine the need for and Cconduct Field field Teststests as required bull bull Determine the need for and perform necessary data collection and
surveys to develop the standard as required bull NPCC Compliance Committee (CC) - [Stanley to provide write up]
bull Compliance Monitoring and Enforcement Program - The NERC
compliance monitoring and enforcement program manages and enforces compliance with approved regional and NERC reliability standards The compliance program area shall provide feedback to drafting teams during the standards development process to ensure the compliance enforcement program can be practically implemented for the standards under development The compliance enforcement program may conduct field tests or data collection related to compliance elements of proposed standards and may provide assistance with field tests or data collection when requested The compliance enforcement program shares its observations regarding the need for new or modified requirements with the standards staff for use in identifying the need for new standards projects
4 4 PROCEDURE DESCRIPTION
STEPS 1 AND 2 REQUEST TO DEVELOP A NEW REGIONAL STANDARD A Requester may Rrequests to the development of
a new Rregional Reliability Sstandard
or revision of an existing standard by submitting a Regional Standard Authorization Request (RSAR) form shall be submitted to the NPCC Manager of Reliability Standards who will promptly acknowledge receipt RSPM by completing a Regional Standard Authorization Request (RSAR) which may be found on the NPCC website(see Appendix A) The RSAR is a description of the new or revised regional standard in sufficient detail to clearly define the its scope purpose and importance of the Regional Standard impacted parties or and other relevant information A ldquoneedsrdquo statement will provide the justification for the development of the standard including an assessment of the reliability and market interface impacts of implementing or not implementing the standard The RSPMManager of Reliability Standards shall maintain retain the RSAR form and make it available electronically on the NPCC website Any person or entity (ldquoRequesterrdquo) directly or materially affected by an existing standard or the need for a new or revised standard may initiate a RSAR
Comment [kbc53] Are there guidelines on the setup approval approval etc of drafting teams
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Comment [kbc54] Vague Should this be NPCC Compliance staff
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Comment [kbc55] When how How long - eg 5 business days Before posting May need an extra step
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Formatted Indent Left 05
Formatted Font Bold Underline
Formatted
Formatted Font Bold
Formatted Font Bold Underline
Comment [kbc56] The left margin indent in this section needs to be made consistent with the rest of the document Also check for consistency in tense The procedure is for the most part written in future tense will Is this appropriate or should it be written in the present tense
Formatted Font Bold Underline
Formatted Font Not Bold
Comment [kbc57] Repetition
18
The Requester will submit the RSAR to the RSPMManager of Reliability Standards electronically and the RSPMManager of Reliability Standards will acknowledge receipt of the RSAR immediately through electronic receipt The RSAR as a minimum needs shall to contain the following information in order to be qualified for consideration The NPCC RSPMManager of Reliability Standards will assist the Requester to ensure all required the following information is submitted (on the RSAR) such as in a form appearing in Appendix A
1 Proposed Title and Date of New RSAR 2 Requesterrsquos Name and Contact Information 3 Purpose of the Regional Standard 4 Description of Industry Need 5 Provide a Brief Description of the Standard 6 Identification of the Entities in the Functional Model as being responsible to
adhere to the standard 7 Necessary information to assist the drafting the team to the extent feasible to
allow them to draft the standard 8 Any existing known cross references to existing NPCC or NERC documents 89Technical background for the RSAR to properly address the need for the standard
The RSPMManager of Reliability Standards shall forward all properly completed RSARs to the RSC The RSC shall meet at established intervals to review all pending RSARs The frequency of this review process will depend on workload but in no case shall a properly completed RSAR wait for RSC action more than 60 calendar days from the date of receipt The RSC may take one of the following actions
bull Remand the RSAR back to the RSPMManager of Reliability Standards for additional work In this case the RSPMManager of Reliability Standards may request additional information or clarification for the RSAR from the Requester
bull Accept the RSAR as a candidate for a new or revised standard In this case the RSC will forward the RSAR to the RCC to assign a NPCC Task Force to provide technical support and analysis of comments for that RSAR and assist the Requester and the RSPMManager of Reliability Standards in drafting the RSARthe remaining steps of the process The RSPMManager of Reliability Standards shall within 60 calendar days of acceptance post notification of intent to develop a standard on both the NPCC website and notify the ERO to post the notification on its websites within 30 calendar days of acceptance
bull Reject the RSAR In this case the RSC will provide its determination to the Manager of Reliability Standards who will then provide a written explanation for rejection to the Requester within 30 60 calendar days of the rejection decision
STEPS 3 4 AND 5 RSC ACCEPTS RSAR AND RCC ASSIGNS TF TO DRAFT NEW OR REVISED STANDARD A RSAR that is accepted by the RSC will shall be submitted to the RCC who shall assign the development of the regional standard to a Task Force Wwithin 60 calendar days the RCC shall assign the development of the standard to a Task Force Drafting Team The RSPMManager of Reliability Standards shall oversee solicitation and recommendation of a list of additional candidates for appointment to the Drafting Tteam and shall submit the
Comment [kbc58] Not to the VP first
Comment [kbc59] No need to specify how
Comment [kbc60] of the completed RSAR
Comment [kbc61] The RSAR has been drafted already Is theis correct or does the TF assist with further refining of the RSAR This does not seem consistent with what follows in steps 3 4 and 5
Formatted Highlight
Comment [kbc62] By whom - MRS
19
list to the RSC This list shall include the Requester The RSC may select other individuals to serve in with the Task Force to drafting the Standard This The Drafting tTeam shall consist of a small group of people who collectively have the necessary technical expertise and work process skills to effectively and efficiently produce a quality standard andand the Drafting Team shall remain in place until such time as the NERC BOT adopts the regional standard Inquiries arising after a standardrsquos development shall be directed by the RSC to the tTask fForce to which the drafting of the standard was assigned The RSPMManager of Reliability Standards shall serve coordinate or assign NPCC staff personnel to assist in the drafting of the standard including compliance measures process and elements The drafting of measures and compliance administration aspects of the standard will be coordinated with the NPCC Compliance Program Staffarea When a drafting team begins its work either in refining an RSAR or in developing or revising a proposed standard the drafting team shall develop a project schedule and report its progress against that schedule to the RSC as requested through the Manager of Reliability Standards to the RSC against that schedule as requested by the RSC Once the Drafting Team has produceds a draft of the regional reliability standard VRFs VSLs variances and its associated implementation plan NPCC standards staff shall coordinates Quality Review of the draft standard consisting of technical writing legal and compliance reviews prior to submission to RSC
STEP 6 SOLICIT PUBLIC COMMENTS ON DRAFT REGIONAL STANDARD Once a draft standard has been verified by the RSC to be within the scope and purpose of the RSAR and the results of the Quality Review are deemed to be satisfactory the RSPMManager of Reliability Standards will post the draft standard for the purpose of soliciting public comments The posting of the draft standard will be linked to the RSAR for reference by its title In addition to the standard an implementation plan shall be posted to provide additional details to the public and aid in their commenting and decision process This implementation plan will be drafted and posted with draft standards upon the availability of sufficient information data or targeted survey results to determine a realistic schedule for implementation Comments on the draft standard will be accepted for a 45 calendar day period from the public notice of posting Comments will be accepted on-line using the NPCC Open Process web-based application The Manager of Reliability Standards will notify NERC to concurrently post fFinalthe draft standard and all associated documents will be concurrently posted on the ERO website for comments
STEPS 7 8 AND 9 OPEN PROCESS POSTING AND ANALYSIS OF THE COMMENTS The RSPMManager of Reliability Standards will assemble the comments on the new draft standard and distribute those comments to the Task Force acting as the standard dDrafting tTeam The Task ForceDrafting Team shall give prompt consideration to the written views and comments of all participants An effort to address all expressed submitted comments shall be madeaddressed and each commenter shall be advised of the disposition of their comments and the reasons therefore in addition toThe Manager of
Comment [kbc63] What is this intended to mean Standard development process What elements
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Formatted Font 12 pt
Comment [kbc64] Who does the quality review Any criteria for this Where would the guidelines be found
Comment [kbc65] Not necessary since the Quality Review must be completed successfully before the draft standard gets to RSC
Comment [kbc66] We need more than just an effort
20
Reliability Standards shall publicly posting all of the Drafting Teamrsquos responses to stakeholder comments on the NPCC website The Task Force acting as the Standard Drafting Team shall take one of the following actions
bull Submit the draft standard for RCC endorsement as it stands along with the comments received and responses to the comments Based on the comments received the Drafting Team Task Force acting as the standard drafting team may include revisions that are not substantive A substantive change is one that directly and materially affects the application of the standard including for example changing ldquoshallrdquo to ldquoshouldrdquo changing ldquoshouldrdquo to ldquoshallrdquo adding deleting or revising requirements or adding deleting or revising measures for which compliance is mandatory
bull Make substantive revisions to the draft standard and reposts it for further open review and comment
bull Drafting Team Task Force recommends Field Test if necessary to RSC
Requester also may withdraw the request for the development of the regional standard at any time during the Regional Reliability Standard Processwithdraw the request for a standard
Upon receipt the RCC submits the proposed regional reliability standardRRS to the RSC along with its recommendation based on comments Drafting Team Task Force statements and any field test results
STEPS 10 AND 11 RSC APPROVES OF THE NEW OR REVISED STANDARD FOR POSTING If the RSC acting with consideration of any recommendations by the RCC and utilizing the composite sector voting structure as outlined in the NPCC Bylaws votes to post the draft regional standard for approval the draft standard all comments received and the responses to those comments shall be posted publicly electronically for the NPCC Members by the RSPMManager of Reliability Standards and made public throughon the NPCC Website website (wwwnpccorg) for a 30 calendar day ldquopre-ballot reviewrdquo and request for ballotingto be followed by an NPCC Member approval ballot If the RSC decides more work is needed the draft standard will be remanded back to the Drafting Teamdrafting Task Force All actions of the RCC Drafting Teams Task Forces acting as drafting teams and the Regional Standards Committee will be recorded in regular minutes of the group(s) and posted on the NPCC website Once the notice for a ballot has been issued no substantive modifications may be made to the proposed standard unless the revisions are posted and a new notice of the vote is issued STEPS 12 13 AND 14 BALLOT OF STANDARD Upon notification of a ballot the Members of NPCCrsquos registered ballot body will cast their vote consistent with the NPCC Bylaws This ballot shall commence no sooner than 15 calendar days and no later than 30 calendar days following the notification of ballot All members of the NPCC are eligible to participate in the voting on proposed standard revisions or deletions of regional standards The ballot period will typically begin immediately following the 30 calendar day pre-ballot posting and will last at least 10 business days
Comment [kbc67] Not consistent with flowchart Box 9 in the flowchart needs to be corrected
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Comment [kbc68] This statement just hangs here Perhaps it is better located in the section that describes Steps 1 and 2
Formatted Indent Left 0
Comment [kbc69] Change in tense
Comment [kbc70] Confusing Alternative text provided Is this okay
Comment [kbc71] This should either be the RCC or the Task Force to whom responsibility for drafting the regional standard was assigned
Formatted Keep with next
Formatted Indent First line 0
21
The NPCC registered ballot body comprises all entities or individuals that qualify for one of the eight NPCC stakeholder sectors and are registered with NPCC as potential ballot participants in the voting on standards Each member of the NPCC registered ballot body is eligible to vote on standards
In order for a NPCC Regional Standard to be approved
bull A quorum must be established by at least 50 of the NPCC Members of at least 60 of the Voting Sectors on the roster of Members maintained by NPCC
bull A two-thirds majority of the total weighted sector votes cast must be affirmative The number of votes cast is the sum of affirmative and negative votes excluding abstentions and non-responses Weighted sector vote will be calculated as follows o Affirmative votes cast in each sector will be divided by the sum of
affirmative and negative votes cast in that same sector to determine the fractional affirmative vote for each sector Abstentions and non-responses will not be counted for the purposes of determining the fractional affirmative vote for a sector
o The sum of the fractional affirmative votes from all sectors divided by the number of sectors voting will be used to determine if a two-thirds majority has been achieved (A sector will be considered as ldquovotingrdquo if any member of the sector in the ballot pool casts either an affirmative or a negative vote)
o A standard will be approved if the sum of fractional affirmative votes from all sectors divided by the number of voting sectors is at least 23
Ballots will be cast electronically and alternatives are as follows
bull Affirmative bull Affirmative with Comments bull Negative bull Negative with Comments bull Abstain
The RSPMManager of Reliability Standards shall post the final outcome of the ballot process If the regional standard is rejected it may be withdrawn by either the RCCRSC or the original Requester or the standard may be remanded by the RSC back to the Drafting TeamTask Force acting as the drafting team to address the issuesballotersrsquo comments In the event the proposed regional standard is withdrawn Aall comments submitted during the process will be posted and archived for consideration when redrafting the standard upon review The standard oOnce the Member ballot approvesd by ballotthe regional standard the Manager of Reliability Standards shall and a recommend final regional approval ation will be forwarded to the NPCC Board BOD for final Regional approval The Board NPCC BOD may not make substantive modifications to the standard If the Board NPCC BOD does not approve the standard for transmittal to NERC it will be remanded back to the RSC to address RCC comments
Comment [kbc72] Not consistent with flow chart This should be RSC
Comment [kbc73] Task Force to whom responsibility for drafting the standard was assigned
Comment [kbc74] From the context it seems the following actions will be take under these conditions
Comment [kbc75] The process does not address comments submitted with a ballot if the standard passes the vote As a result dissenting balloters concerns will be ignored (filed in the issues database for future reference) That is there is no equivalent of a recirculation ballot
22
If the RCC approves the regional standard is approved the Manager of Reliability Standards standard will be submitted the standard to the NERCERO Board of Trustees for approval STEPS 15 16 AND 17 IMPLEMENTATION OF THE NPCC REGIONAL STANDARD Upon approval within by the NPCC BOD the Manager of Reliability Standards shall submit the regional standard will be submitted to the NERCERO for approval(s) and filing with FERC and applicable Canadian Governmental andor Regulatory Authorities for adoption Once a reliability regional standard is adopted by the NERC BOT and submitted to and approved by either FERC andor applicable Canadian Governmental andor Regulatory Authorities andit shall made becomes effective in the applicable jurisdiction in accordance with its associated implementation plan aAll users owners planners and operators of the Bulk Power System in the NPCC geographic area of the Northeast North America are will be required to comply with the standard at this time The NERCERO Board of Trustees has established its Compliance Monitoring and Enforcement Programa separate compliance program also administered in the Northeast by NPCC to measure compliance with the reliability standards and administer sanctions as appropriate After adoption of a NPCC Rregional Sstandard the standard will be included in the forwarded to the compliance program for NERCERO compliance Compliance mMonitoring and eEnforcement Program STEP 18 WITHDRAWAL ORF REMAND OF A REGIONAL STANDARD Upon voter rejection or upon the request for the withdrawal of a proposed standard made to the the RSC CC or the requester may the RSC may elect to withdraw the standard completely or remand it back to the Task ForceDrafting Team acting as the standard drafting team for further work The Assistant Vice President-Standards will inform NERC and the industry of the actions taken
Comment [kbc76] Include VRFs VSLs Implementation Plan or do we interpret standard to include all these items
Comment [kbc77] At what time when approved or as defined in the implementation plan
Formatted Highlight
Comment [kbc78] Correct
23
RSRSubmissionto RSPM
1
RSC Review
2
Valid 3
RCC Assigns TF and also RSPM
posting Of intent to draft a
standard4
Task Force Drafts Standard
5
Open Process Postings
6
Comments7
TF Addresses Comments
Redrafts StdFTwithdrawn
8
TF Submits to RSC for Review
with all backgound and Recs
9
RSC Approves10
Post for Preballot Review
11
Standard Balloted
12
Passed13
Standard Submitted to ERO
15
Filed wFERC and Canadian Authorities
Adopted and Standard
Implemented17
RSC or Requester Withdraws
14
Yes
No
Yes
No
Yes
No
Yes
NoNo
5 FlowchartRegional Standards
Development Procedure(Open Process)
ERO Process of Approval and BOT
Approval
16
Complete Withdrawal or sent back to the
Drafting Team
18
24
6 ERO AND REGULATORY PROCESS AND APPROVALS
bull NERCERO Comment Period mdash Concurrent with regional posting of final drafts the final drafts will be forwarded to NERC for posting on the NERC website to ensure full industry awareness of the standard and expedite and coordinate all commenting NERCERO shall publicly notice and request comment on the NPCC Rregional Rreliability Sstandard and associated implementation plan allowing a minimum of 45 calendar days for comment on NERCrsquos website and actively notify all adjoining Regions Concurrent with this regional posting of final drafts the final drafts will be forwarded to NERC for posting on the NERC website to ensure full industry awareness of the standard and expedite and coordinate all commenting All comments will be responded to electronically by the Drafting Team through a posted response on the NPCC website or a link on the NERC website NPCC shall have an opportunity to resolve any objections identified in the comments and may choose to withdraw the requestposting for comment revise the NPCC Rregional Reliability Sstandard and request another posting for comment or submit the NPCC Rregional Rreliability Sstandard along with a response to any objections received for approval by NERC
bull NERCERO Approval of NPCC Regional Reliability Standards mdash
Proposed regional reliability standards shall be subject to approval by the NERCERO who shall have a process to evaluate and recommend whether a proposed non-Interconnection-wide NPCC Rregional Rreliability Sstandard has been developed in accordance with all applicable procedural requirements and whether NPCC has considered and addressed stakeholder objections NPCC BoardBOD having been notified of the results of the regional ballot concerning a NPCC Rregional Rreliability Sstandard shall vote to submit the Sstandard to the NERCERO Board BOT for approval as a NERC Rreliability Standardstandard The NERCERO Board BOT shall consider NPCCrsquos request the scope and implications of the Sstandard the recommendation for action on the Sstandard any unresolved stakeholder comments and NPCCrsquos consideration of comments and unresolved issues if any in determining whether to approve the NPCC Rregional Rreliability Sstandard as a NERC Rreliability Sstandard
bull Regulatory Authority Approval mdash An NPCC Rregional Rreliability
Sstandard that has been approved by the NERCERO board BOT shall be filed with FERC and applicable Canadian Governmental andor Regulatory Authorities for approval and shall become effective and enforceable within the US per Section 215 of the Federal Power Act only when adopted by FERC and within individual Canada provinces only when adopted by applicable Canadian Governmental andor Regulatory Authorities in accordance with any associated implementation plan The regional reliability standard once adopted will be made part of the body of NERC reliability standards and shall be mandatory and enforceable on all applicable bulk power system owners operators and users within the NPCC Region in accordance with any associated implementation plan regardless of membership status
Comment [kbc79] Consider including a list with acronyms explained for the convenience of the reader
Formatted Underline Small caps
Comment [kbc80] Should this be 16 and 17
Formatted Underline Small caps
Formatted Small caps
Comment [kbc81] Posting for pre-ballot review or comment
Comment [kbc82] anything else
Comment [kbc83] Moved above for better sequencing
Comment [kbc84] The possible outcomes have not been specified ie Accept Remand Reject What happens if NERCERO does not approve the regional standard
25
7
Appeals
bull Persons who have directly and materially affected interests and who have been or will be adversely affected by any substantive or procedural action or inaction related to the development approval revision reaffirmation or withdrawal of a regional reliability standard shall have the right to appeal This appeals process applies only to the standards process as defined in this procedure The burden of proof to show adverse effect shall be on the appellant Appeals shall be made within 30 calendar days of the date of the action purported to cause the adverse effect except appeals for inaction which may be made at any time In all cases the request for appeal must be made prior to the next step in the process The appeal must be in writing signed by an officer of the appellant
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
bull Level 1 Appeal
Level 1 is the required first step in the appeals process The appellant submits a complaint in writing to the RSPMManager of Reliability Standards that describes the substantive or procedural action or inaction associated with a reliability standard or the standards process The appellant describes in the complaint the actual or potential adverse impact to the appellant Assisted by any necessary staff and committee resources the RSPMManager of Reliability Standards shall prepare a written response addressed to the appellant as soon as practical but not more than 45 calendar days after receipt of the complaint If the appellant accepts the response as a satisfactory resolution of the issue both the complaint and response will be made a part of the public record associated with the standard and posted with the standard
bull 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 NPCC regional standards process manager the RSPMAssistant Vice-President of Standards the NPCC Assistant Vice-President of Standards shall request the BOD to convene a Level 2 Appeals Panel This panel shall consist of five members total appointed by the NPCCrsquos bBoard
In all cases Level 2 Appeals Panel members shall have no direct affiliation with the participants in the appeal
The RSPMManager of Reliability Standards shall post the complaint and other relevant materials and provide at least 30 calendar days notice of the
Comment [kbc85] Ensure this appeals process is consistent with MOUs with Canadian entities The CCEP document currently posted for ballot has been amended to achieve consistency with the Ontario appeals process contained in the MOU
Comment [kbc86] Form of the appeal Could also add language similar to the objection lower down ie contain a concise statement of
Comment [kbc87] How much time does the appellant have to write
Comment [kbc88] Is sector representation needed here if so how will this work with only 6 sectors
26
meeting of the Level 2 Appeals Panel In addition to the appellant any person that is directly and materially affected by the substantive or 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 RSC 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 appellantrsquos objections The panel may not however revise approve disapprove or adopt a reliability standard 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 NPCC Board for consideration at the time the board decides whether to adopt a particular regional reliability standard The objection must 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 must be filed no later than 30 calendar days after the announcement of the vote on the standard in question Process for Developing an Interpretation 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 regional standard that has been adopted by the NERC BOT A valid interpretation request is one that requests additional clarity about one or more requirements in approved NPCC regional 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 regional standard that has been adopted by the NERC BOT The entity requesting the interpretation shall submit a Request for Interpretation form to the NPCC Manager of Reliability Standards explaining the clarification required the specific circumstances surrounding the request and the impact of not having the interpretation provided The NPCC Manager of Reliability Standards shall work with the requester to ensure that the request for interpretation form is complete and necessary The NPCC Manager of Reliability Standards utilizing the NPCC Task Force structure shall assemble an interpretation drafting team with the relevant expertise to address the clarification As soon as practical the team shall
Formatted Font 12 pt Font color Auto
Formatted Indent Left 075
Formatted Font 12 pt
Comment [kbc89] May also need processes to develop a definition and retire a standard along with flowcharts
Formatted Font 12 pt Font color Auto
Comment [kbc90] Is this to be restricted to within the NPCC area or will any entity anywhere in North America be able to make a request
Comment [kbc91] Moved for better sequencing
Formatted Font 12 pt Font color Auto
Comment [kbc92] Who makes this determination - NPCC staff
Formatted Font 12 pt Font color Auto
Comment [kbc93] What about other parts of the standard
Formatted Font 12 pt Font color Auto
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Comment [kbc94] Who makes this determination
Formatted Font 12 pt Font color Auto
Comment [kbc95] Only requirements
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Comment [kbc96] Why do we need this
Formatted Font 12 pt Font color Auto
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Comment [kbc97] For development of a new standard the RCC assigned the standard development to a Task Force Shouldnt we adopt a similar approach here
Formatted Font 12 pt Font color Auto
27
develop a ldquofinal draftrdquo interpretation providing the requested clarity RCC need to get involved The NPCC Manager of Reliability Standards shall coordinate a quality review of the interpretation to assess whether the interpretation is clear and provides the requested clarity without expanding on any requirement The detailed results of this review shall be provided to the regional standard drafting team and the RSC with a recommendation on whether the documents are ready for formal posting and balloting and iIf the RSC agrees that the proposed interpretation passes this review the RSC shall authorize posting the proposed interpretation to the NPCC website The first formal comment period shall be 30- days long If the drafting team makes substantive revisions to the interpretation following the initial formal comment period then the interpretation shall undergo another quality review before it is posted for its second formal comment period The second formal comment period shall have a 45-day duration and shall start after the drafting team has posted its consideration of stakeholder comments and any conforming changes to the associated regional standard Notification of a ballot shall take place during the first 30 days of the 45-day formal comment period and the ballot of the interpretation shall take place during the last 10 days of that formal comment period The interpretation drafting team shall consider and respond to all comments submitted during the formal comment period at the same time and in the same manner as specified for addressing comments submitted with ballots All comments received and all responses shall be publicly posted to the NPCC website Stakeholders who submit comments objecting to some aspect of the interpretation shall determine if the response provided by the drafting team satisfies the objection All objectors shall be informed of the appeals process contained within this manual A ballot will be conducted utilizing quorum and approval requirements as outlined in the NPCC Bylaws If stakeholder comments indicate that there is not 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 RSC of its conclusion and shall submit a RSAR with the proposed modification to the standard The entity that requested the interpretation shall be notified and the disposition of the interpretation shall be posted to the NPCC website If during its deliberations the interpretation drafting team identifies a reliability gap in the regional standard that is highlighted by the interpretation request the interpretation drafting team shall notify the RSC of its conclusion and shall submit a RSAR with the proposed modification to the standard at the same time it provides its proposed interpretation
Comment [kbc98] Not at this stage
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Comment [kbc99] Whats the significance of this
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Formatted Indent Left 075 Space After 0 pt
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Formatted Highlight
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Formatted Font 12 pt Highlight
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28
If approved by its ballot the interpretation shall be appended to the standard and forwarded to the NPCC BOD for adoption If an interpretation drafting team proposes a modification to a regional standard as part of its work in developing an interpretation the BOD shall be notified of this proposal at the time the interpretation is submitted for adoption Following adoption by the BOD NPCC standards staff shall submit the interpretation for approval by the NERC BOT Once approved by the NERC BOT NPCC standards staff shall file the interpretation with FERC and applicable Canadian Governmental andor Regulatory Authorities for approval The standard shall become effective and enforceable within the US only when adopted by FERC and within individual Canada provinces only when adopted by applicable Canadian Governmental andor Regulatory Authorities in accordance with any associated implementation plan and the interpretation shall not become effective until approved by applicable governmental authorities The interpretation shall stand until such time as the interpretationit can be incorporated into a future revision of the regional standard or the interpretation is retired due to a future modification of the applicable requirement
Some general comments bull Complete quality check required bull ldquoProcessrdquo and ldquoprocedurerdquo are used interchangeably throughout Check for and achieve consistency bull Check for and ensure consistency in usage ldquoAn NPCCrdquo or ldquoA NPCChelliprdquo Eg see highlights on pg 4 bull Process Qn Maintenance of standards Who performs the review to determine the need to revise an existing
reliability standard ndash NPCC Staff RSC Task Force NPCC staff may trigger the review but who will do it bull Consistency check When ldquoregional reliability standardsrdquo is not used as part of a title (eg Regional Reliability
Standards Processrdquo it should be preceded by ldquoNPCCrdquo Also we must decide whether it will be capitalized or not We suggest at the first occurrence introduce a short description ie ldquohellipNPCC regional reliability standards (regional standards)helliprdquo and then use ldquoregional standardsrdquo throughout the remainder of the document
bull Consistency check Drafting Team vs Standard Drafting Team We prefer the former for consistency with NERC bull
Formatted Font 12 pt
Comment [kbc100] By whom
Formatted Font 12 pt
Formatted Font 12 pt
Formatted Font 12 pt
Formatted Font 12 pt
Formatted Font 12 pt
Formatted Font (Default) Calibri 10 pt
Formatted Indent Left 0 Hanging 013Bulleted + Level 1 + Aligned at 025 +Indent at 05
Formatted Font (Default) Calibri 10 ptEnglish (Canada)
29
30
Appendix A
Information in a Regional Standard Authorization Request (RSAR)
The tables below identify information to be submitted in a Regional Standard Authorization Request to the NPCC Regional Standards Process Manager
NPCCstandardnpccorg The NPCC Regional Standards Process Manager shall be responsible for implementing and maintaining this form as needed to support the information requirements of the standards process
Regional Standard Authorization Request Form
Title of Proposed Standard
Request Date
RSAR Requester Information
Name RSAR Type (Check box for one of these selections)
Company New Standard
Telephone Revision to Existing Standard
Fax Withdrawal of Existing Standard
31
Email Urgent Action
Purpose (Describe the purpose of the proposed standard ndash what the standard will achieve in support of reliability)
Industry Need (Provide a detailed statement justifying the need for the proposed standard along with any supporting documentation)
Brief Description (Describe the proposed standard in sufficient detail to clearly define the scope in a manner that can be easily understood by others)
Reliability Functions
The Standard will Apply to the Following Functions (Check all applicable boxes)
Reliability Coordinator
The entity that is the highest level of authority who is responsible for the reliable operation of the Bulk Electric System has the Wide Area view of the Bulk Electric System and has the operating tools processes and procedures including the authority to prevent or mitigate emergency operating situations in both next-day analysis and real-time operations The Reliability Coordinator has the purview that is
32
broad enough to enable the calculation of Interconnection Reliability Operating Limits which may be based on the operating parameters of transmission systems beyond any Transmission Operatorrsquos vision
Balancing Authority
The responsible entity that integrates resource plans ahead of time maintains load-interchange-generation balance within a Balancing Authority Area and supports Interconnection frequency in real time
Interchange Authority
Authorizes valid and balanced Interchange Schedules
Planning Authority
The responsible entity that coordinates and integrates transmission facility and service plans resource plans and protection systems
Transmission Service Provider
The entity that administers the transmission tariff and provides Transmission Service to Transmission Customers under applicable transmission service agreements
Transmission Owner
The entity that owns and maintains transmission facilities
Transmission Operator
The entity responsible for the reliability of its ldquolocalrdquo transmission system and that operates or directs the operations of the transmission facilities
Transmission
The entity that develops a long-term (generally one year and beyond) plan for the reliability
33
Planner (adequacy) of the interconnected bulk electric transmission systems within its portion of the Planning Authority Area
Resource Planner
The entity that develops a long-term (generally one year and beyond) plan for the resource adequacy of specific loads (customer demand and energy requirements) within a Planning Authority Area
Generator Operator
The entity that operates generating unit(s) and performs the functions of supplying energy and Interconnected Operations Services
Generator Owner
Entity that owns and maintains generating units
Purchasing-Selling Entity
The entity that purchases or sells and takes title to energy capacity and Interconnected Operations Services Purchasing-Selling Entities may be affiliated or unaffiliated merchants and may or may not own generating facilities
Distribution Provider
Provides and operates the ldquowiresrdquo between the transmission system and the customer
Load-Serving Entity
Secures energy and transmission service (and related Interconnected Operations Services) to serve the electrical demand and energy requirements of its end-use customers
Reliability and Market Interface Principles
34
Applicable Reliability Principles (Check all boxes that apply)
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
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
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
Plans for emergency operation and system restoration of interconnected bulk power systems shall be developed coordinated maintained and implemented
Facilities for communication monitoring and control shall be provided used and maintained for the reliability of interconnected bulk power systems
Personnel responsible for planning and operating interconnected bulk power systems shall be trained qualified and have the responsibility and authority to implement actions
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 (Select lsquoyesrsquo or lsquonorsquo from the drop-down box)
35
Recognizing that reliability is an Common Attribute of a robust North American economy
A reliability standard shall not give any market participant an unfair competitive advantageYes
A reliability standard shall neither mandate nor prohibit any specific market structure Yes
A reliability standard shall not preclude market solutions to achieving compliance with that standard Yes
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
Detailed Description (Provide enough detail so that an independent entity familiar with the industry could draft a standard based on this description)
Related Standards
36
Standard No
Explanation
-t
Related SARs or RSARs
SAR ID Explanation
37
Page 1 of 5
Formatted Font color Auto
Approved by NPCC Board of Directors 9-17-08XX-XX-XXXX
Draft Scope of Work for the
Regional Standards Committee (RSC)
The NPCC Regional Standards Committee (RSC) a committee of the NPCC Board of Directors (BOD) is charged with
(a) managing the NPCC Regional Standards Ddevelopment Procedureprocess and
(b) managing the NPCC Directory and Criteria development process (bc) providing consolidated NPCC Regional review and comment to the
existing and proposed NERC Standards and participatinge in the NERC Reliability Standards Development Pprocessdure
(d) reviewing the FERC Orders Rulings and Notice of Proposed Rulemakings (NOPRs) related to reliability standards and providinge a forum for developing consensus viewpoints and submitting comments to FERC as necessary
(e) reviewing NERC Compliance Application Notices (CANs) working in coordination with the NPCC Compliance Committee (CC) and submitting comments to NERC as necessary
(e) responding to emerging standards related issues and providing support to members on an ad hoc basis for information related to NERC Alerts and Standards
(f) providing oversight and process for interpretation of Regional Standards and Criteria
(g) initiate changes to NERC and Regional Standards and Criteria after event analysis and lessons learned to reflect improvements to reliability
The RSC is an open and balanced stakeholder committee inclusive of all stakeholder interests that provide for or are materially impacted by the reliability of the bulk power system The RSC meetings will be open to all stakeholders who want to attend and will be publicly posted on the NPCC website
Decisions of the NPCC RSC RSC will be adopted under a sector based voting structure as described in the NPCC Bylaws
The RSC will coordinate its work with the Assistant Vice PresidentmdashStandards who will
Formatted Indent Left 05 Hanging 05 No bullets or numbering
Page 2 of 5
be the administrator for the NPCC Regional Standards Process and the coordinator of the review and submission of comments
The RSC will be chaired by an NPCC member of staff who will be assisted by the NPCC Regional Standards Process Manager (also a member of NPCC staff) along with co-vice chairs elected by the RSC from the existing members of the committee at the time the vote is taken Co-vice chairs will serve a term of two years with an additional extension of time available through a motion and subsequent vote by the committee in accordance with the NPCC Bylaws
Members of the RSC will be elected by the NPCC Board The eight[] NPCC Sectors as outlined in the NPCC Bylaws each will be represented on the RSC
Subcommittees and ad hoc Working Groups will be formed upon request of the RSC by NPCC standards program area staff and all associated scopes or charters developed will be approved by the RSC in accordance with the most recent approved and adopted NPCC Bylaws
The NPCC RSC will work in coordination with the Assistant Vice PresidentmdashStandards who will be the administrator for the NPCC Regional Standards processDevelopment Procedure and the coordinator of the review and submission of comments to the NERC Reliability Standards
The RSC is an open and balanced stakeholder committee inclusive of all stakeholder interests that provide for or are materially impacted by the reliability of the bulk power system The RSC meetings will be open to all stakeholders who want to attend and will be publicly posted on the NPCC website
The RSC is responsible for managing the standards process for development of standards VRFs VSLs definitions variances and interpretations in accordance with the NPCC Regional Reliability Standard Process Manual The RSC is responsible for ensuring the quality of all standards related materials
A Management of the NPCC Regional Standards ProcessDevelopment Procedure
The NPCC RSC RSC will consider requests and regulatory directives for new or revised regional standards and be available for to advisement to the NPCC Board BOD on these standards or any standards related matters
The RSC may not itself modify a draft regional standard The RSC will only act on a draft standard in the event of a minor correction such as errata Substantive changes to a draft standard by the drafting team requires issuing a new notice to stakeholders regarding a vote of the modified standard
GZ and LP to work on how to incorporate language to reflect the ability to change VSLs and VRFs to continually adhere to changing FERC and NERC guidelines and requirements
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Page 3 of 5
The RSCrsquos disposition regarding a regional standard authorization request which will in all cases be within 60 calendar days of receipt of a completed standard request shall include(one of the following-requires RSPM revhellip)
bull ACCEPT the standard request as a candidate for development of a new standard revision of an existing standard or cancellation of an existing standard The RSC may at its discretion expand or narrow the scope of the standard request under consideration The RSC shall prioritize the development of standards in relation to other proposed standards as may be required based on the volume of requests and resources
bull REJECT the standard request If the RSC rejects a standard request a written explanation for the rejection will be delivered to the requester within 30 calendar days of the decision
bull REMAND the standard request back to the requester for additional work The Assistant Vice PresidentmdashStandards will make reasonable efforts to assist the requester in addressing the deficiencies identified by the RSC The requester may then re-submit the standard request using the process above The requester may choose to withdraw the standard request from further consideration prior to acceptance by the RSC
The NPCC Regional Standards processDevelopment Procedure responsibilities of the RSC will include
bull Overseeing quality rReview of NPCC Regional Draft Standards for such factors as completeness sufficient detail rational result format and compatibility with existing standards clarifying standard development issues not specified in this procedure Under no circumstance will the RSC change the substance of a draft standardrsquos purpose applicability or requirements
bull Due consideration to the work of the drafting team as well as the comments of stakeholders and minority objections in approving a proposed regional reliability standard to go to ballot (VSL and VRF polling)
bull Approve standards for pre-ballot posting and VSL and VRF polling under a sector based voting structure as described in the NPCC Bylaws or
bull Remand the standard back to the Task Force acting as the drafting team for further work or recommend a change in those participating in the drafting team (ie a new drafting team)
Provide an oversight role in the development and maintenance of the NPCC Regional Reliability Directories
bull Provide decisions for clarifications
All regional standard related decisional making activities made by the RSC will be approved or rejected by a vote as outlined in the NPCC Bylaws as they pertain to quorum and voting rules
The RSC is responsible for managing the processes for development of NPCC Directories and Criteria The RSC is responsible for ensuring the quality of all directory and criteria
Formatted UnderlineB Management of the NPCC Directory and Criteria Process
Page 4 of 5
related materials
The RSC will be available to advise the NPCC BOD on any directory and criteria related matters
The RSC will
C NERC Reliability Standards
bull Provide NPCC review and coordinate the submission of NPCC comments to existing and developing NERC Reliability Standards when posted for NERC ldquoOpen Process Reviewrdquo
bull Provide a forum for NPCC to participate solicit and provide Regional comments as new Standard Authorization Requests (SARs) and their respective Reliability Standards are developed as part of the NERC Reliability Standards Development Procedure
bull Identify upcoming issues associated with new NERC Reliability Standards and their potential impact to the NPCC Region (ie Regional Difference) Propose solutions or guide the development of the Standards through effective and timely comments and soliciting NPCC participation on the SAR and Reliability Standards drafting teams
bull Develop and maintain a Web-Based Database for tracking and scheduling Standards development activities from a Regional perspective
bull Target a broader range of participation in the commenting process Develop databases and e-mail list servers to engage market participants and different perspectives
bull Develop an entire process for notification solicitation commenting on and revision to Standards
bull Follow up on the NERC Reliability Standards Procedure evolution and provide NPCC members with basic information (or pointers to NERC website) for a common understanding of the process
bull Coordinate activities of NPCC members on standard drafting teams
The RSC will review FERC Orders Rulings and Notice of Proposed Rulemakings (NOPRs) related to reliability standards The RSC will discuss develop comments and if necessary submit the comments to FERC The RSC will coordinate the NPCC response with that of NERC
D FERC Activities Affecting Standards
The RSC will review NERC CANs for reliability standard and compliance implications and submit comments to NERC
E NERC Compliance Application Notices (CANs)
The RSC will
bull Provide NPCC review and submit comments to draft NERC CANs bull Target a broader range of participation in the commenting process
Committee Members
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Formatted Bullets and Numbering
Page 5 of 5
Members of the RSC will be elected by the NPCC Board The eight NPCC Sectors as outlined in the NPCC Bylaws each will be represented on the RSC
The RSC will be chaired by an NPCC member of staff who will be acting as the Regional Standards Process Manager with co-vice chairs elected by the RSC from the existing members of the committee at the time the vote is taken Co-vice chairs will serve a term of two years with a one year extension available through a motion and subsequent vote by the committee in accordance with the NPCC Bylaws
Subcommittees and ad hoc Working Groups will be formed at the behest ofupon request of the RSC by NPCC standards program area staff and all associated scopes or charters developed will be approved by the RSC in accordance with the most recent approved and adopted NPCC Bylaws
Formatted Highlight
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
Northeast Power Coordinating Council Inc Board of Directors Meeting Draft Minutes for Comment
February 8 2011 | 830 am NPCC Offices 1040 Avenue of the Americas 10th Floor New York New York The Chairman called to order a duly noticed meeting of the Board of Directors (Board) of Northeast Power Coordinating Council Inc (NPCC) held on February 8 2011 at 830 am A quorum was declared present during the meeting by the President and CEO Edward Schwerdt Andrianne Payson acted as Recording Secretary The meeting announcement agenda and list of attendees are attached as Exhibits A B and C respectively NPCC Antitrust Guidelines The Chairman recommended that a reading of the NPCC Antitrust Guidelines that was distributed via email with the Board agenda package and reviewed by directors upon commencement of the meeting be waived A motion to waive the reading of the NPCC Antitrust Guidelines was duly made seconded and unanimously approved Minutes The President and CEO presented for approval a draft of the minutes of the Board meeting held on December 1 2010 which incorporated all comments received Following discussion the Board agreed that the NERC Matters section of the minutes should be further revised to increase clarification A motion to approve the minutes as revised of the NPCC Board of Directors meeting held on December 1 2010 was duly made seconded and unanimously approved by the Directors in each active Sector of the Board Presidentrsquos Report The President and CEO indicated that the Boards Strategy Meeting yesterday afternoon (February 7) and earlier this morning were worthwhile and that as part of his report to the Board he would highlight the key issues facing NPCC for 2011 and beyond bull During the process of implementing the initiative associated with the development of risk-based
standards it became apparent that there was a lack of common understanding between industry and the regulators as to (i) whether the reliability objective of risk-based standards was to prevent cascading or prevent loss of load and (ii) what constitutes an adequate level of international interconnected bulk power system reliability that appropriately balances costs and benefits to consumers The President and CEO explained that achieving consensus on these fundamental concepts including their applicability to cyber-security related reliability issues was essential to the development of standards with clear performance expectations and accountabilities He further noted that successful efforts to revise the Bulk Electric System (BES) definition and to establish consistent and technically justifiable criteria for BES definition exceptions would be critical to focusing reliability efforts in the future
bull On a procedural level it will be a challenge adapting NPCCs processes to NERCs evolving process for developing reliability standards in order to continue providing Northeast leadership The President and CEO emphasized the importance of maintaining NPCCs leadership role in the standards development process
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
2
bull Within the Compliance Monitoring and Enforcement Program NERC and the Regional Entities intend to introduce a more risk-based approach to compliance monitoring by considering risk and materiality in the depth and rigor of audits as well as a streamlined administrative citation process for enforcing minor violations The President and CEO explained that this approach would increase the focus on the entities and types of violations that pose the greatest risks to reliability of the bulk power system
bull In connection with the implementation of the revised Regional Delegation Agreement the Regional Entities are working with NERC to build the ERO One Enterprise model with the objectives of enhancing reliability and improving efficiency and effectiveness in working with registered entities The President and CEO noted that NERC and Regional Entity leaders attended a collaborative planning meeting in mid-January to prepare an initial draft of ERO-wide strategic goals through 2015 He explained that these draft goals would be reviewed at the February 16th NERC Member Representatives Committee meeting and that the Boards help me help you message to NERC management would be delivered
bull In connection with the development of NERC and Regional Entity 2012 Business Plans and Budgets NERCs Chief Accounting Officer recently released a preliminary draft of common business planning assumptions that would be reviewed by NERC and the Regional Entities at upcoming meetings next week The President and CEO noted that the purpose of establishing consistent planning goals and assumptions was to promote an enterprise-wide outlook for reliability related activities performed by NERC and the Regional Entities
The President and CEO indicated that he would distribute copies of his remarks to the Board shortly after meetings going forward Membership Category and Sector Designations The President and CEO stated that a Board vote would be required for the sector designations of Maine Public Service Company (General Member) and Groton Electric Light (Full Member) both in Sector 3 (Transmission Dependent Utilities Distribution Companies and Load-Serving Entities) and Penobscot Energy Recovery Company (Full Member) in Sector 4 (Generator Owners) The President and CEO also noted without the requirement for a vote a change in the designation of the Alternate Member Representative for First Wind A motion to approve the sector designations of Maine Public Service Company (General Member) in Sector 3 (Transmission Dependent Utilities Distribution Companies and Load-Serving Entities) Groton Electric Light (Full Member) in Sector 3 (Transmission Dependent Utilities Distribution Companies and Load-Serving Entities) and Penobscot Energy Recovery Company (Full Member) in Sector 4 (Generator Owners) was duly made seconded and unanimously approved by the Directors in each active Sector of the Board Committee Membership Changes The President and CEO informed the Board that there were several changes to NPCCs operating committees
bull Reliability Coordinating Committee ndash Sector 1 (Transmission Owners) (1) Michael Paris to serve as the New York Power Authority alternate replacing Gerald LaRose who recently retired and (2) Michael Schiavone to serve as the National Grid representative replacing Dana Walters Mr Fedora also noted that the RCCs Nominating Committee was currently seeking a new co-Vice Chair for the RCC
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
3
bull Compliance Committee ndash Sector 1 (Transmission Owners) Michael Bilheimer to serve as the United Illuminating Company alternate
bull Regional Standards Committee ndash Sector 1 (Transmission Owners) Ben Wu to serve as the Orange and Rockland Utilities representative
bull Regional Standards Committee ndash Sector 2 (Reliability Coordinators) Donald Weaver to serve as the New Brunswick System Operator representative replacing Randy MacDonald
A motion to approve these committee changes was duly made seconded and unanimously approved by the Directors in each active Sector of the Board NPCC Committee Reports Regional Standards Committee (RSC) ndash Mr Zito presented the RSC report to the Board which included a discussion of the following (1) there is a draft ballot underway for the draft Underfrequency Load Shedding (UFLS) Regional Standard but quorum has not yet been obtained (2) the RSC is currently reviewing processes to ensure that it can react quickly and more efficiently to any new standards requirements issued by NERC and FERC and (3) the RSC is currently developing a filing for Directories for Nova Scotia and is preparing to do the same for New York State Public Service Commission In response to questions from the Board regarding NPCCrsquos review of NERCs Compliance Application Notice (CANs) postings Mr Buffamante clarified that NERCs CANs are used by compliance auditors to provide guidance while assessing an entitys compliance with reliability standards He noted that NPCC faced the challenge of ensuring that CANs do not change or expand standards requirements Mr Zito then presented the Draft 2011 RSC Work Plan which reflected significant increases in resources that would be required to (i) develop standards including 36 projects of continent-wide standards identified in the NERC Reliability Standards Development Plan 2011-2013 (ii) coordinate NPCCs participation in the revision of CIP standards and (3) assist the Compliance Committee through the development of more auditable requirements in the Phase 2 of the Directories project Board members then suggested that (i) the RSC Work Plan should include an analysis of cost effectiveness of proposed NPCC Regional Standards to convey the seriousness of this issue for NPCC (ii) the RSC reach out to NPCCs GovernmentalRegulatory Affairs Advisory Group to request they advocate for adding an analysis of cost effectiveness as part of the standards development process and (iii) the RSC recommend consolidation of NERC standards projects where appropriate A motion to approve the 2011 RSC Work Plan as revised was duly made seconded and unanimously approved by the Directors in each active Sector of the Board Reliability Coordinating Committee (RCC) ndash Mr Fedora presented the RCC report to the Board which included information on the following (1) the approval of NPCCs long-range adequacy overview (2) endorsement of the NPCC Criteria Compliance and Enforcement Program and (3) the RCCrsquos intent to coordinate the significant increase in written requests for data from NERC The Board then discussed (i) the potential for coordinating reliability metrics data requests from NERC with information developed by the Northeast ISOs (ii) the possible development of a report reflecting the data assembled to date and (iii) the process for transitioning all NPCC criteria (A ldquoBrdquo and ldquoCrdquo Documents) into auditable requirements as appropriate in Regional Reliability Directories by the end of 2011 Mr Fedora then presented the Draft 2011 RCC Work Plan A motion to approve the 2011 RCC Work Plan was duly made seconded and unanimously approved by the Directors in each active Sector of the Board Compliance Committee (CC) ndash Mr Kopman presented the CC report to the Board which included information on the following (1) approval of the Registered Entity Culture of Compliance Survey its initial distribution to 25 entities and the upcoming webinar on February 16 2011 to introduce the survey and answer questions (2) ongoing review of the Compliance Registry and (3) the issuance of 116 compliance
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
4
violation notices in 2010 (compared with 45 in 2009) and (4)the submission to NERC of mitigation plans associated with these violations (none of which have been rejected by NERC) Mr Buffamante then presented the 2011 Compliance Audit Program which reflects 21 on-site audits scheduled for 2011 11 on-site CIP audits 21 off-site CIP audits and 98 off-site audits (of which two are in progress) He informed the Board that NPCC had received and accepted 423 Technical Feasibility Exception (TFE) submissions to date and that 329 submissions had their Part B substantive assessments completed and approved He noted that NPCC is on schedule to complete assessments of the remaining submissions within a one year period Mr Penstone commended Mr Kopman and the CC for providing the Board with the CMEP metrics table which he found helpful in facilitating the Boards review and evaluation of the CCs work Mr Kopman then presented the Draft 2011 CC Work Plan which reflected the development of more comprehensive performance related to expediting the enforcement process A motion to approve the 2011 CC Work Plan was duly made seconded and unanimously approved by the Directors in each active Sector of the Board MDCC Recommendations The Board Chair reported that the Management Development and Compensation Committee (MDCC) met on January 20 2011 to discuss the 2010 Corporate Goal Attainment Report and the 2010 President and CEO Incentive Compensation Award He stated that the MDCC determined that NPCC had met its 2010 corporate goals and that NPCCs performance with respect to its Regional Entity Division and Criteria Services Division was higher than Meets Target with a composite score of 932 Board members did not have any questions for the President and CEO or the Vice President and COO in connection with the 2010 Corporate Goal Attainment Report However Mr Longhi requested that in the future a scorecard (similar to the CMEP metrics table) be prepared to show measurement of the corporate goals The President and CEO and the Vice President and COO then left the meeting The Board Chair discussed the process by which the MDCC evaluated the overall performance of the President and CEO for 2010 which included a review of the 2010 Exceptional Achievements summary prepared by the President and CEO and supporting detail for each achievement as well as the solicitation of feedback from Board members The Board Chair then distributed copies of draft resolutions with recommendations from the MDCC for Board approval A motion to approve the implementation of a 2010 Variable Incentive Program releasing incentive awards to the NPCC staff to be accrued to the salaries subaccount for 2010 for distribution in early March 2011 was duly made seconded and approved by a majority of the Directors Directors Hans Mertens and Tammy Mitchell in Sector 7 abstained from voting on this motion A motion to approve the implementation of a 2010 Variable Incentive Program releasing an incentive award to the President and CEO to be accrued to the salaries subaccount for 2010 for distribution to the President and CEO in early March 2011 was duly made seconded and approved by a majority of the Directors Directors Hans Mertens and Tammy Mitchell in Sector 7 abstained from voting on this motion The President and CEO and the Vice President and COO then returned to the meeting NPCC 2011 Corporate Goals The President and CEO presented NPCCs Proposed 2011 Corporate Goals to the Board for discussion In response to questions from the Board the President and CEO noted the following (1) the attainment of Bulk Power System revisions would be included in Goal 6a (2) following the issuance of the NERC mid-
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
5
year report listing certain reliability metrics discussed in Mr Fedoras RCC Report there would be a review of a few key areas for follow-up action (3) the stretch goal for Goal 6a would be revised to reflect FERC approval of a BES filing that contains key provisions that are important to NPCC (4) the corporate goals would be reviewed generally and revised as appropriate to ensure that the development of any draft document is not listed as a stretch goal and (5) each NPCC operating committee should be tasked to develop its own scorecard so the Board can assess the committee work being completed and scorecards should show separate goals relating to improving the efficiency of NPCC as an organization The Board Chair reminded Board members that comments on NPCCs Proposed 2011 Corporate Goals were due on February 18 2011 Organizational Matters CGNC Activities ndash Ms Courville briefly explained the activities of the CGNC in connection with the proposed changes to NPCCs governance structure She then asked Ms Payson to review the proposed changes to NPCCs Amended and Restated Bylaws that are intended to reflect the new governance structure Proposed Bylaw Changes Rules of Procedure for Electing Directors ndash Ms Payson discussed the proposed changes to NPCCs Amended and Restated Bylaws by reviewing the matrix summarizing the revisions to various Bylaw provisions and the Rules of Procedure for Electing Directors The Board provided several comments to the Bylaws and the Rules of Procedure which Ms Payson agreed to revise The Board discussed the proposed timeline for approval of the Amended and Restated Bylaws and agreed to send a complete package of materials to Members containing the mark-up of the Bylaws the matrix summarizing the Bylaw changes and the slide presentation providing an overview of the changes to NPCCs governance structure immediately following the next Board meeting Presentation to Members of NPCC Governance Changes ndash The President and CEO reminded Board members that a draft slide presentation to Members providing an overview of the governance structure changes was discussed during the Board Strategy Meeting on February 7 2011 Report by the Treasurer Mr Weir reported to the Board consistent with the unaudited Statement of Activities for both the Regional Entity and Criteria Services divisions for the period from January 1 2010 through December 31 2010 which had been provided to the NPCC members and Board of Directors in later January by NPCCrsquos Vice President and COO Additionally the Treasurer informed the Board that the independent auditors PricewaterhouseCoopers LLP (PwC) would likely have a draft of NPCCs audited financial statements for 2010 prepared by the end of February He reminded the Board that an unaudited Statement of Activities for 2010 for the Regional Entity Division was required by NERC as are regular quarterly reports and had been previously circulated The Treasurer indicated that NPCCs total expenditures were under budget by nearly $18 million for the year He then asked the Vice President and COO to provide an overview of NPCCs year end results for 2010 The Vice President and COO provided the Board with a breakdown of 2010 funding and comparative expenditure amounts for the total ERO Enterprise (ie NERC and the eight Regional Entities) On an enterprise basis combined funding was nearly$165 million with a variance of more than $10 million She explained that the overall variance as a percentage of total budgeted funding was under budget by 61 She noted that WECC was under budget by less than 1 NERC by 6 FRCC by 18 SPP by 22 and NPCC under by approximately 116 She further noted that total funding was largely on target with the exception of WECC where grant funding was $14 million under budget She then explained that (i) NERCs total funding was over budget by more than $800000 due to increases in fees for system operator
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
6
tests certificate renewals and continuing education provider fees (ii) NERC and all of the Regional Entities were under budget except for MRO which had added staff to manage processing Technical Feasibility Exceptions (iii) staff for the total ERO enterprise was approximately 98 by year end (iv) meeting expenses on an ERO wide basis were under budget by 24 compared with NPCC which was under budget by 22 (under budget variances ranged from 8 to 44 for this expense) and (v) operating expenses on an ERO wide basis were under budget by 26 or approximately $137 million compared with NPCCs under budget of 14 due mainly to lower fees and expenses for consultants professional services and legal fees She noted that NPCCs Criteria Services Division similar to the Regional Entity Division was also under budget by 42 or $463240 for 2010 The Vice President and COO informed the Directors that a NERC teleconference for its Finance and Audit Committee was being held tomorrow (February 9) where concerns would likely be expressed as to whether a Regional Entitys under spending could be viewed as underperformance of that entitys Regional Delegation Agreement (RDA) and that while expenditures were under budget NPCC would indicate that all requirements under the RDA were met during 2010 Regulatory Matters Mr Fedora provided an update of revisions to the BES definition He noted that the first meeting of the BES standard drafting team would be held on February 9-11 2011 and that he would circulate unofficial summary notes to the Board within one week after drafting team meetings NERC Matters The Board Chair noted that the meetings of the NERC Member Representatives Committee and the NERC Board of Trustees were scheduled for February 16 and 17 2011 respectively The President and CEO explained that Board policy input was requested for four items (1) ERO Enterprise Strategic Direction (2) Bulk Electric System Definition-Policy Issues and Questions (3) Priorities for Addressing Risks to Reliability and (4) Alerts and the Alerts Process Following Board discussion the President and CEO agreed to revise the draft Board Policy Input to clarify certain comments and to include recommendations for (i) any proposed implementation strategy for the BES definition to include an adequate transition period incorporating cost-effective modifications into the schedules for system modifications and (ii) the expansion of Issue 6 Integration of New Technologies to reflect a working partnership among manufacturers providers and public policy makers in order to achieve the desired reliable integration A motion to approve the draft Board Policy Input subject to revisions by the President and CEO was duly made seconded and unanimously approved by the Directors in each active Sector of the Board Administrative Matters The Board Chair reminded Board members that all Directors needed to execute the Annual Code of Conduct Implementation Agreement Other Matters Mr Haake informed the Board that he would be leaving Dynegy at the beginning of April 2011 and this would be his last Board meeting The President and CEO then informed the Board that Mr Janega had changed roles within Nova Scotia and planned to resign from the Board shortly Mr Mertens requested that Resolutions of Appreciation be prepared for both Mr Haake and Mr Janega for their efforts and contributions to the Board A motion directing the President and CEO to prepare Resolutions of Appreciation for Mr Haake and Mr Janega was duly made seconded and approved by a majority of the Directors Mr Haake abstained from voting on this motion
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
7
Future Meetings The President and CEO presented the schedule of Board meetings for the remainder of calendar year 2011 which was distributed via email with the Board agenda package Adjournment There being no further business the Chairman adjourned the meeting of the NPCC Board of Directors at 1240 pm Approved by Board action on _______________ 2011 Submitted by ______________________ Andrianne S Payson NPCC Secretary
NPCC Board of Directors Draft for Comment Meeting Minutes February 8 2011
8
EXHIBIT C LIST OF ATTENDEES
February 8 2011
Present Harvey J Reed Chairman Edward A Schwerdt President and CEO Jennifer Budd Mattiello Vice President and COO Christopher Weir CPA Treasurer Andrianne S Payson Esq Secretary And the following members of the Board of Directors Sector 1 (TOs) William G Longhi Orange amp Rockland Utilities
Isabelle Courville Hydro-Queacutebec TransEacutenergie (by teleconference)
Sector 2 (RCs) Peter Brandien ISO New England Inc Bruce B Campbell Independent Electricity System Operator Rick Gonzales New York Independent System Operator Inc (via proxy to President)
Sector 3 (TDUs DCs LSEs)
Douglas McCracken National Grid Michael Penstone Hydro One
Sector 4 (GOs) Glenn D Haake Dynegy Andrew Barrett Ontario Power Generation Inc Rick Janega Nova Scotia Power Inc (via proxy to President)
Sector 5 (Marketers Brokers and Aggregators)
Glen McCartney Constellation Energy Commodities Group Inc Matthew J Picardi Shell Energy NA (via proxy to President) Daniel Whyte Brookfield Power Generation
Sector 6 (Customers) ndash
Sector 7 (Regulatory) Hans Mertens Vermont Department of Public Service Tammy Mitchell NYS Department of Public Service
Sector 8 (Others) Michael Forte New York State Reliability Council LLC Guests Wes Yeoman New York Independent System Operator
Guy V Zito NPCC Assistant Vice President ndash Standards Stanley Kopman NPCC Assistant Vice President ndash Compliance Enforcement Philip Fedora NPCC Assistant Vice President ndash Reliability Services Salvatore Buffamante NPCC Assistant Vice President ndash Compliance Audits and Investigations
- 1 - LRP 312011 1027 AM
1040 Avenue of the Americas - 10th Floor New York New York 10018-3703
NPCC Regional Standards Committee Draft Minutes for Approval
Meeting 11-1
February 2 2011 1000 am - 500 pm (severe weather)
February 3 2011 800 am - 300 pm
NPCC Offices 1040 Avenue of the Americas
10th Floor New York New York
Dress Business Casual
RSCnpccorg Call in 719-785-1707 Guest Code 8287
Items in red from Feb 2 2011 Items in green from Feb 3 2011
1 Introductions-Agenda Review-Roster a RSC membership changes Randy MacDonald (New Brunswick System Operator) moved from Sector 2 (Reliability Coordinators) to Sector 1 (Transmission Owners) Donald Weaver (New Brunswick System Operator) will replace Randy MacDonald in Sector 2 Ben Wu (Orange and Rockland Utilities Inc) will join
- 2 - LRP 312011 1027 AM
the RSC in Sector 1 Both memberships on the agenda for the Feb 8 2011 NPCC Board of Directors Meeting Wayne Sipperly (NYPA) new member (Sector 4--Generator Owner) Kal Ayoub has been promoted to Manager Reliability Standards at FERC Attendees
Name Organization Sector 1 Michael R Lombardi Northeast Utilities 1 2 Si Truc Phan Hydro-Quebec TransEnergie 2 3 Brian Gooder Ontario Power Generation Incorporated 4 4 Saurabh Saksena National Grid 3 5 Chris de Graffenried Consolidated Edison Co of New York Inc 1 6 Brian Evans-Mongeon Utility Services 5 7 Gerry Dunbar Northeast Power Coordinating Council 8 Randy MacDonald New Brunswick System Operator 1 9 Lee Pedowicz Northeast Power Coordinating Council 10 Guy Zito Northeast Power Coordinating Council 11 Bruce Metruck New York Power Authority 5 12 Wayne Sipperly New York Power Authority 4 13 Kal Ayoub (guest) FERC 14 Ben Wu (guest) Orange and Rockland Utilities Inc 1
On the Phone (Webex made available)
Name Organization Sector 1 Kurtis Chong Independent Electricity System Operator 2 2 Sylvain Clermont Hydro-Quebec TransEnergie 1 3 Ron Falsetti (guest) AESI (consultant) 4 Kathleen Goodman ISO - New England 2 5 David Kiguel Hydro One Networks Inc 1 6 Mike Garton Dominion Resources Services Inc 4 7 Diane Barney New York State Department of Public Service 7 8 Bohdan Dackow US Power Generating Company (USPG) 4 9 Greg Campoli New York Independent System Operator 2 10 Ronnie Epstein (guest) New York Power Authority 11 Donald Weaver (guest) New Brunswick System Operator 2
Guy Zito discussed the addition of Agenda Items 9c 21e 21f and 23 (Directory Development Manual)
- 3 - LRP 312011 1027 AM
2 RSC November-December 2010 Meeting Minute Approval and Antitrust Guidelines (in Meeting Materials Package) a Includes December 2 2010 joint meeting with the Compliance Committee Lee Pedowicz read the Antitrust Compliance Guidelines at the outset of the meeting David Kiguel and Randy MacDonald made changes to the Meeting Minutes Michael R Lombardi made a motion to approve the Minutes as revised Seconded by Chris de Graffenried All members present with the exception of Bruce Metruck voted to approve Bruce Metruck abstained
3 Action Item Assignment List and Ongoing Assignments (in Meeting Materials
Package) (Refer to table at the back of Agenda) a NPCC Members on NERC Drafting Teams
Saurabh Saksena to maintain He will get updates from Carol Sedewitz
4 Review Executive Tracking Summary (in Meeting Materials Package) a Review entries
Michael R Lombardi was thanked for the work he has put into revising and maintaining the Executive Tracking Summary It is still a work in progress and it will ultimately provide ldquoone stop shoppingrdquo for RSC information There is a button on the RSC home page that takes you to the Executive Tracking Summary David Kiguel commented that it would be beneficial to access earlier versions of the Executive Tracking summary and histories of documents Saurabh Saksena discussed combining the Executive Tracking Summary with the NPCC members on NERC Drafting Teams Guy Zito expressed a desire not to do it because it would expose individualsrsquo information Guy Zito reported that on the new NPCC Website being developed (that is scheduled to be tested in March) the need for archiving will be considered
5 FERC (in Meeting Materials Package) a December 2010 Meeting Summaries
Guy Zito discussed b January 2011 Meeting Summaries
Guy Zito discussed Guy Zito proposed establishing a RSC team to develop a response to NOPRs
- 4 - LRP 312011 1027 AM
Lee Pedowicz to make a table for this item that will include the effective date the Docket Number and any other pertinent information from a posting
c Federal Register 1 Mandatory Reliability Standards for Interconnection Reliability
Operating Limits 2 System Restoration Reliability Standards 3 Revision to Electric Reliability Organization Definition of Bulk Electric
System a Request for Rehearing of the New York State Public Service
Commission of Docket No RM09-18-000 - Revision to Electric Reliability Organization Definition of Bulk Electric System
The Standards Committee had a meeting last month Brian Evans-Mongeon and Phil Fedora (NPCC) are on the Drafting Team et al are NPCC representatives on the Drafting Team The exception process is going to have to be dealt with This will depend on the comments received from the SAR posting and could result in having to dedicate resources to do studies The scope is being increased Sylvain Clermont commented that he discussed the exception process with Herb Schrayshuen A working group within NERC will be put together to look at the exception process Will also have to deal with NERC Rules and Procedures The working group will consist of stakeholders as well as NERC Staff Itrsquos not known if this will be a ldquoformalrdquo working group Brian Evans-Mongeon reported that there is a meeting next week and there is room for twenty five observers Elizabeth Crouch had sent out the notice If you signed up to be an observer yoursquod have to be physically at the meeting There were 199 pages of comments submitted for the Exception Process The Drafting Team hasnrsquot seen the comments for the Bulk Electric System definition Brian Evans-Mongeon forwarded the E-mail that contained the announcement for observers Chris de Graffenried commented that there is a jurisdiction issue that FERC and NERC donrsquot recognize Canadian Provinces are not being considered
4 System Personnel Training Reliability Standards For information only
5 Interpretation of Protection System Reliability Standard Comments on the NOPR are due Feb 25 2011
6 Version One Regional Reliability Standard for Transmission Operations Concerned with WECC
7 For information compliance filing of Proposed Violation Risk Factors and Violation Severity Levels for Available Transfer Capability Reliability Standards
8 Priorities for Addressing Risks to the Reliability of the Bulk- Power System
9 Electric Reliability Organization Interpretations of Interconnection Reliability Operations and Coordination and Transmission Operations Reliability Standards
10 Version One Regional Reliability Standards for Facilities Design Connections and Maintenance Protection and Control and Voltage
- 5 - LRP 312011 1027 AM
and Reactive Concerned with WECC
6 Current and Pending Ballots (in Meeting Materials Package)
a
Project 2010-13 - Relay Loadability Order - PRC-023 PRC-023-2 Redline to last posting PRC-023-2 Redline to last approval Implementation Plan Redline to last posting VRFVSL Justification Mapping Document Announcement
Successive Ballot and
Non-Binding Poll
012411 021311
b
Project 2010-11 - TPL Table 1 Order Implementation Plan TPL-001-1 Redline to last posting TPL-001-1 Redline to last approval TPL-002-1b Redline to last posting TPL-002-1b Redline to last approval TPL-003-1a Redline to last posting TPL-003-1a Redline to last approval TPL-004-1 Redline to last posting TPL-004-1 Redline to last approval Announcement
Recirculation Ballot 012611 020511
Item 6a--Kurtis Chong sent his comments to the group The meeting attendees agreed with his comments Item 6b--This Recirculation Ballot will be the last ballot Discussion ensued over the grouprsquos understanding of the footnote
- 6 - LRP 312011 1027 AM
7 Overlapping Postings (in Meeting Materials Package)
a
Project 2006-06 - Reliability Coordination - COM-001 COM-002 IRO-001 and IRO-014
COM-001-2 Redline to last posting Implementation Plan Redline to last posting COM-002-3 Redline to last posting Implementation Plan Redline to last posting IRO-001-2 Redline to last posting Implementation Plan Redline to last posting IRO-005-2 Redline to last posting Implementation Plan Redline to last posting IRO-014-2 Redline to last posting Implementation Plan Redline to last posting Comment Form (link to Word version) Announcement (initial Announcement) Announcement (latest with extension)
Comment Form
011811
030711
Initial Ballot 022511 030711
Join Ballot Pool 012511 022511
b
Project 2007-23 - Violation Severity Levels VSLs Redline to last Approval Comment Form (link to Word Version) Announcement
Comment Form
012011 021811
Non-Binding Poll
020911 021811
Join Ballot Pool
012011 020911
c
Project 2007-07 - Vegetation Management - FAC-003 FAC-003-2 Redline to Last Posting Implementation Plan Redline to Last Posting FAC-003-1 Comment Form (link to Word Version) Technical White Paper Redline to Last Posting
Comment Form
012711 022811
Successive Ballot and
Non-Binding Poll
021811 022811
- 7 - LRP 312011 1027 AM
Announcement
Item 7a--It was noted that the ballot starts Feb 25 2011 It appears to be restricted to emergency communications Kathleen Goodman to send comments to the RSC for their consideration Some historical information offered was that a Request for Interpretation had been submitted on clarification of three part communication The RSC didnrsquot think three part communication was needed for everything The Request for Interpretation was submitted about two years ago There was a bulletin issued that stipulated that communications be three part Kathleen Goodman got no response Kathleen Goodman will be asking the Standards Committee for a status She will also send the comments that shersquoll be submitting to the IRC to the group Item 7b--Kurtis Chong discussed the IESOrsquos response to question 2 on the Comment Form Kurtis Chong to reformat the response in the form of a comment Kurtis Chong will redo the Comment Form and submit to the group Item 7c--A recommendation for the vote is needed by Feb 18 2011 Chris de Graffenried reported that Con Edisonrsquos subject matter expert suggests voting ldquoforrdquo Guy Zito told the assembled that members with overhead transmission lines should have their subject matter experts review 8 Join Ballot Pools (in Meeting Materials Package)
9 Posted for Comment (in Meeting Materials Package)
a
Regional Reliability Standards - PRC-006-NPCC-1 - Automatic Underfrequency Load Shedding
Comment Form (link to Word version) PRC-006-NPCC-1 Implementation Plan
Comment Form 11011 022411
b
Standards Committee Project Prioritization Tool Standards Committee Project Prioritization
Worksheet (link to Excel Spreadsheet)
Informal Comment Period 012111 021011
- 8 - LRP 312011 1027 AM
Standards Committee Reference Document for
Project Comment Form (link to Word Version) Announcement
Item 9a--This Regional Standard is going back to the Drafting Team See Item 21b1a below Kurtis Chong inquired as to why there was no quorum on the ballot for the Standard Guy Zito replied that NPCC did everything it could to get the members to vote David Kiguel brought up that NERC had ldquoticklersrdquo for balloted items Item 9b--This item was discussed earlier It will probably be approved by the NERC Board of Trustees There are a lot of open questions Guy Zito reported that this is going to be used by the Standards Committee for input to the Work Plan Brian Evans-Mongeon commented that it is still very subjective Chris de Graffenried discussed his comments Item 9c--(independent of above table)--How can the RSC be more efficient with successive ballots and all the concurrent activities taking place Guy Zito suggested the necessity of having more frequent meetings of the Executive Committee set up sub-groups within the RSC Guy Zito is trying to get a skill set of the NPCC employees to identify those that can assist with comment submissions Guy Zito is seeking observations from the participants Need to have better Task Force cooperation Better notifications would make the process more efficient and improve the cooperation of the Task Forces This should be brought to the attention of the RCC Kurtis Chong commented that when NERC makes postings on a Friday for a ten day comment period it includes two weekends It was suggested that an improvement would be to post on a Monday or a Tuesday so there is only one weekend in the comment period Guy Zito said that the Standards Committee will be informed that regional standards arenrsquot posted in the right places on the NERC Website Guy Zito reported that April 1 Stephanie Monzon (NERC) will be leaving her present standards assignment in NERC to go work for Tom Calloway (NERC) Guy Zito requested that RSC members send him their thoughts 10 Reference Documents Posted For Comment
a
- 9 - LRP 312011 1027 AM
11 Concluded Ballots (in Meeting Materials Package)
httpsstandardsnercnetBallotsaspx (clicking in the ldquoBallotrdquo column links to the Ballot Results)
Results of Ballot
RSC RecommendDate
a Project 2010-13 - Relay Loadability
Order Initial Ballot 120710 121610
Quorum--8800 Appd--5151
No 121010
b
Project 2007-04 - Certifying System Operators - PER-003
Recirculation Ballot
120210 121310
Quorum--9550 Appd--8691
Yes 91410
c Project 2010-15 - Urgent Action
Revisions to CIP-005-3
Initial Ballot and Non-
Binding Poll 120210 121110
Quorum-- 8446 Appd--
4289
No 12810
d
Project 2008-06 - Cyber Security - Order 706 - CIP-002 through CIP-009
Successive Ballot
120110 121010
Quorum-- 8707 Appd-- 7706
No Consensus
e
Project 2007-17 - Protection System Maintenance amp Testing
Successive Ballot
121010 121910
Quorum--7988 Appd--4465
Yes 10410
Non-binding Poll for VRFs
and VSLs 121010 121910
Quorum--7806
Supportive Opinion--5273
f
Project 2009-17 - Interpretation of PRC-004-1 and PRC-005-1 for Y-W Electric and Tri-State GampT
Recirculation Ballot
112910 12310
Quorum--8781 Appd--8241
Yes RSC Meeting
113010
g
Project 2008-06 - Cyber Security - Order 706 - CIP-002 through CIP-009
Recirculation Ballot
122010 123010
Quorum--9049 Appd--8056
Yes 11210
h Project 2010-10 - FAC Order 729 Successive Ballot
123010 010811
Quorum--8323 Appd--5816
Yes 10511
i Project 2010-11 - TPL Table 1 Order Initial Ballot 122710 010511
Quorum--9042 Appd--
Yes 10511
- 10 - LRP 312011 1027 AM
8333
k Project 2010-10 - FAC Order 729 Recirculation
Ballot 011411 012311
Quorum--8665 Appd--6898
Yes 10511
Item 11k--FAC-013-2 its Implementation Plan and new definitions adopted and its
VRFs and VSLs approved approved by the NERC Board of Trustees Jan 24 2011 These documents will be filed for regulatory approval by Jan 28 2011
This added section provides good information and will be included in future agendas 12 Posted For 30-Day Pre-Ballot Review (Open Ballot Pools) Between RSC
Meetings
a
13 Concluded Comment Forms (in Meeting Materials Package)
a Project 2008-06 - Cyber Security - Order 706 - CIP-002
through CIP-009 Comment
Form 120110 121010
b Project 2010-11 - TPL Table 1 Order Comment Form
111910 10511
c Project 2009-22 - Interpretation of COM-002-2 R2 by
the IRC Comment
Form 111810 121810
d Project 2007-17 - Protection System Maintenance and
Testing - PRC-005 Comment
Form 111710 121710
e Project 2010-15 - Urgent Action Revisions to CIP-005-3
- CIP-005 Comment
Form 111210 121110
f Project 2010-13 - Relay Loadability Order - PRC-023 Comment
Form 110110 121610
g Project 2010-16 - Definition of System Operator Comment Form
110310 120310
h Project 2010-10 - FAC Order 729 Comment
Form 121010 10811
i Project 2010-17 - Definition of Bulk Electric System Comment Form
121710 012111
j Resources Subcommittee White Paper on Frequency
Response Comments 1210 020111
- 11 - LRP 312011 1027 AM
14 Reference Documents Posted For Comment Between RSC Meetings
a
15 Drafting Team Nominations Open (Current and between RSC Meetings)
a Project 2010-17 - Definition of Bulk Electric System Nomination
Form 121710 010411
16 NERC Meetings (in Meeting Materials Package) a ERO-RAPA b MRC and BOT Meetings 17 NERC RSG RRSWG (in Meeting Materials Package) a Update The RSG will be replacing the RRSWG The RSG will strive to achieve uniformity between regions
18 Standards Committee Report (in Meeting Materials Package) a Dec 8 2010 Meeting
At its January Meeting the Bulk Electric System Drafting Team was selected Regional Standards will be given a Quality Review--legal technical writer NERC will have a Quality Review Team for postings The review will be conducted before a ballot and the Quality Review Working Group will include a legal review It has been speculated that this review will lengthen the process
19 SCPS Meeting
Guy Zito and David Kiguel are on the SCPS Involved with the NERC processes The Standards Prioritization Project originated in this group
20 NERC Compliance Application Notices a Comments to the CAN process
Guy Zitorsquos comments from the joint meeting with the CC in December 2010 It was thought that the CAN process was closed Stan Kopman was to be the RSCrsquos conduit for comments Subsequent to the joint meeting the request for comments was made public Guy Zito to talk to Stan Kopman about how CANs will be dealt with in the future CANs 15 16 and 18 were sent out
- 12 - LRP 312011 1027 AM
David Kiguel reminded the participants to send in their responses to CANs 12 and 13 Brian Evans-Mongeon commented on a possible ldquotriagerdquo for CANs and Guy Zito stressed the need for a coordinated review of CANs This will be considered as the RSC Scope is developed
21 NPCC Regional Standards--Update (in Meeting Materials Package) a Disturbance Monitoring (PRC-002-NPCC-01)
1 VSLs approved by NPCC membership NERC Board of Trustees approved Nov 4 2010 Being prepared for FERC and Canadian entity filings
b Underfrequency Load Shedding 1 Regional Standard Drafting Team has responded to all comments
received in the 2nd Open Process Posting TFSS has recommended RCC endorsement for RSC approval of a 30 day pre-ballot review
a Ten day ballot concluded on Jan 28 2011 Did not get quorum RSC to remand back to Drafting Team
c Special Protection System d Regional Reserve Sharing 1 Draft RSAR developed 2 TFCO soliciting for members
22 NY adoption of more stringentspecific NPCC Criteria
a Status of the filing Compliance Attorney looking at Phase 1 of the Directories Expect report in two weeks
23 Directory and Regional Work Plan Status Directory Number
Title Lead Group Status
Current Activity
1 (A-2) Design and Operation of the Bulk Power System
Approved on 1212009
TFCP has charged CP11 with a comprehensive review of Directory 1 to include the triennial document review and an examination of the NERC TPL standards the existing NPCC planning criteria and the implementation of Phase 2 of the Directory Project which will reformat existing Directory criteria into NERC style requirements CP11 expects to present a first draft of the reformatted Directory 1 to TFCP and other Task Forces at the TFCP Meeting on Feb 9 2011 for comments CP11rsquos initial schedule called for presenting a final draft to RCC in November 2011
2 (A-3) Emergency Operation
Approved on 102108
Automatic UFLS language transferred to Directory 12 Next TFCO review Oct 21 2011
3 (A-4) Maintenance Criteria for BPS Protection
Approved on 71108
TFSP review underway
- 13 - LRP 312011 1027 AM
4 (A-5) Bulk Power System Protection Criteria
Approved on 12109
TFSP review underway
5 (A-6) Operating Reserve
TFCO Directory5 was approved by the Full Members on December 2 2010 TFCO working to resolve outstanding reserve issues associated with Directory 5 TFCO expects to post a revised version of Directory 5 to the Open Process after their February meeting
7 (A-11)
Special Protection Systems
Approved on 122707
TFSP currently reviewing Directory 7 in accordance with the NPCC Reliability Assessment Program TFCP and TFSS will agree on revisions to the SPS approval and retirement and send any proposed changes to TFSP
8 (A-12)
System Restoration
Approved on 102108
TFCO made revisions to criteria for battery testing in October 2010 Next review date July 9 2012
9 (A-13)
Verification of Generator Real Power Capability
Approved on 122208
TFCO to consider draft language that would revise section 70 to ensure that documentation is not sent to TFCO The next TFCO review is scheduled for July 2012
10(A14) Verification of Generator Reactive Power Capability
Approved on 122208
TFCO to consider draft language that would revise section 70 to ensure that documentation is not sent to TFCO The next TFCO review is scheduled for July 2012
12 UFLS Program Requirements
Approved on 62609
Small entity (less than 100MW) revision approved by Full Members on 332010 The RCC approved one additional year for Quebec to complete UFLS implementation (Quebec implementation term is now three years) Open Process posting concluded on Jan 21 2011 that considered revisions to the UFLS Implementation Plan
X Reserve Sharing
TFCO TFCO considering draft of a new Directory on Regional Reserve Sharing which would replace C38 until a Regional Standard is developed TFCO expects to post draft of Directory X after the TFCO meeting in February
Phase 1 of the Directory Project the initial translation of criteria completed December 2010 Directory 5 was the last Directory approved RCC told TFCO to continue working on Directory 5 to resolve outstanding issues TFCO is also working on a new Directory for Regional Reserve Sharing TFCO hopes to have a draft ready for posting this spring (TFCO also has the Regional Standard on Regional Reserve Sharing) Phase 2 is underway with the reformatting of Directory 1 A Directory Development Manual is to be developed this year Developing a new NPCC Glossary of Terms is also being considered The goal is to complete Phase 2 this year and to make the Directories a real requirement
- 14 - LRP 312011 1027 AM
24 Review RFC MRO Standards Relevant to NPCC (in Meeting Materials Package)
a RFC Standards Under Development webpage httpsrsvprfirstorgdefaultaspx
b RFC Standard Voting Process (RSVP) webpage ReliabilityFirst Corporation - Reliability Standards Voting Process MOD-025-RFC-01 - Verification and Data Reporting of Generator Gross
and Net Reactive Power Capability passed its 15 day Category vote Anticipated RFC Board of Directors action to approve to approve during their March 3 2011 meeting
Standard Under
Development Status Start Date End Date
1
PRC-006-RFC-01 - Automatic Under Frequency Load Shedding Requirements
Post Comment 011211 021011
2
c Midwest Reliability Organization Approved Standards
httpwwwmidwestreliabilityorgSTA_approved_mro_standardshtml (click on RSVP under the MRO header)
d Midwest Reliability Organization Reliability Standard Voting Process webpage (table lists standards under development) Midwest Reliability Organization - Reliability Standards Voting Process
e As of June 14 2010 MRO suspended its regional standards development
Adding this item to the RSC Scope to be considered A suggestion was made to make this item for information only and only when the documents listed are posted at NERC
Standard Under Development Status Start Date End Date
1 PRC-006-MRO-01 - Underfrequency Load Shedding Requirements (see e below)
Was posted for second 30 day
comment period 51910 - 61710
2
- 15 - LRP 312011 1027 AM
25 Report on NERC NAESB and Regional Activities (in Meeting Materials Package)
a Report on NERC NAESB and Regional Activities 1
Lee Pedowicz to continue calling in
26 Task Force Assignments If any members want to be added to the Regional Reserve Sharing Drafting Team let Guy Zito or Lee Pedowicz know 27 Future Meetings and Other Issues (in Meeting Materials Package)
a RSC--Procedure For Handling Comments To NERC Revise procedure to better handle received comments for consensus Consider NERCrsquos latest comment issuance and resolution procedures
b NERC NPCC--Reliability Standards filed with the Nova Scotia Utility Review Board (UARB) for approval
1 Nova Scotia Information Requests for filing NPCC Criteria c Proposed Amendments To NERC Rules Of Procedure Section 300
Comments Of The Canadian Electricity Association d NERC Newsletter 1 December 2010 2 January 2011 e Link to SERC httpserccentraldesktopcomstandardhomepagedoc10275904amppgref f NERC Compliance Application Notices Guy Zito mentioned that someone needs to evaluate CANs and if it is felt
that it is needed it should be brought to the RSCrsquos attention g NERC Drafting Team vacancies
Item 27a--Lee Pedowicz is going to review and consider changing the process to more effectively capture the RSC consensus opinion Kathleen Goodman suggested incorporating a ldquodrop deadrdquo deadline to encourage timely submission of comments Other options to consider are the selective issuance to Task Forces of materials posted for comments and have a greater utilization of conference calls Suggested that when Lee Pedowicz sends out a Meeting Materials posting notification (prior to RSC Meetings) state in the transmittal that any Comment Forms will have a ldquodrop deadrdquo deadline at the RSC Meeting or at a conference call whichever is applicable Comments received late will still be issued to the RSC for informational purposes Item 27b--Informational item Item 27c--Sylvain Clermont submitted comments that specifically related to FERC Directives
- 16 - LRP 312011 1027 AM
Item 27d--Informational item Item 27e--SERC changed their home page Item 27f--discussed under Item 20 above Item 27g--For information
It was mentioned the New Brunswick automatically accepts NERC criteria Meeting adjourned 1639 on Feb 2 2011
Guy Zito opened the Feb 3 2011 session with a request for any additional items to discuss There was a discussion of NERC Successive Ballots Brian Evans-Mongeon said that regarding EOP-004 a document is being prepared to be posted for a comment period 225 pages of comments had been received Revisions made to reflect those comments Expected to go to the NERC Board of Trustees in the May-June timeframe Formal comments will be solicited in the March-April timeframe The RSC November Meeting dates have to be changed because of a conflict with the NPCC Annual and General Meetings Meeting adjourned 1221 Feb 3 2011
RSC 2011 Meeting Dates
March 16-17 2011 Richmond Virginia
October 19-20 2011 Burlington Vermont
May 18-19 2011 Saratoga New York
Nov 30 - Dec 1 2011 Toronto Ontario
August 3-4 2011 Montreal Quebec
- 17 - LRP 312011 1027 AM
2011 RSC Conference Call Schedule (call 212-840-1070--ask for the RSC [Guyrsquos or Leersquos] Conference Call)
Feb 18 2011 July 15 2011 March 4 2011 August 19 2011 April 1 2011 Sept 2 2011 April 15 2011 Sept 16 2011 April 29 2011 Sept 30 2011 May 13 2011 Oct 28 2011 June 3 2011 Nov 10 2011 (Thursday) June 17 2011 Dec 16 2011 July 1 2011 Dec 30 2011
BOD 2011 Meeting Dates
February 7-8 2011 NPCC July 28 2011 Teleconference March 15 2011 Teleconference on Bylaws September 20 2011 NPCC
May 3 2011 Teleconference October 26 2011 Teleconference June 30 2011 NPCC November 30 2011 Toronto
RCC CC and Task Force Meeting Dates--2011
RCC March 3 June 1 Sept 8 Nov 29 CC Feb 15 April 13 May 16 June 14-15
July 13 August 17 Sept 21-22 Oct 19 Nov 16 Dec 13-15
TFSS Jan 20-21 TFCP Feb 9 May 11 August 17 Nov 2 TFCO Feb 24-25 April 14-15 August 11-12
Oct 6-7 TFIST TFSP Jan 18-20 March 22-24 May 24-26 July
19-21 Sept 27-29 Nov 15-17
Respectfully Submitted Guy V Zito Chair RSC Assistant Vice President-Standards Northeast Power Coordinating Council Inc
- 18 - LRP 312011 1027 AM
Northeast Power Coordinating Council Inc (NPCC) Antitrust Compliance Guidelines
It is NPCCrsquos policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition The antitrust laws make it important that meeting participants avoid discussion of topics that could result in charges of anti-competitive behavior including restraint of trade and conspiracies to monopolize unfair or deceptive business acts or practices price discrimination division of markets allocation of production imposition of boycotts exclusive dealing arrangements and any other activity that unreasonably restrains competition It is the responsibility of every NPCC participant and employee who may in any way affect NPCCrsquos compliance with the antitrust laws to carry out this commitment Participants in NPCC activities (including those participating in its committees task forces and subgroups) should refrain from discussing the following throughout any meeting or during any breaks (including NPCC meetings conference calls and informal discussions)
bull Industry-related topics considered sensitive or market intelligence in nature that are outside of their committeersquos scope or assignment or the published agenda for the meeting
bull Their companyrsquos prices for products or services or prices charged by their competitors
bull Costs discounts terms of sale profit margins or anything else that might affect prices
bull The resale prices their customers should charge for products they sell them bull Allocating markets customers territories or products with their competitors bull Limiting production bull Whether or not to deal with any company and bull Any competitively sensitive information concerning their company or a
competitor
Any decisions or actions by NPCC as a result of such meetings will only be taken in the interest of promoting and maintaining the reliability and adequacy of the bulk power system Any NPCC meeting participant or employee who is uncertain about the legal ramifications of a particular course of conduct or who has doubts or concerns about whether NPCCrsquos antitrust compliance policy is implicated in any situation should call NPCCrsquos Secretary Andrianne S Payson at 212-259-8218
- 19 - LRP 312011 1027 AM
Action Item List
Action Item
Number
Agenda Item
Number Description Owner Due Status
32 16b To discuss with Jerry Adamski how HQ because of its unique operational requirements will be addressed in standards development
Guy Zito--member of Standards Committee Process Subcommittee
RSC Meeting
Ongoing as of 21010 Sylvain
Clermont and David Kiguel
working with Guy Zito Herbert Schrayshuen
replaced Gerry Adamski at NERC
The new NERC management team
will have to be made familiar with
this item August 20-21 2008
Feb 17-18 2009
June 17-18 2009
August 6-7 2009
60 3a NPCC representatives from NERC drafting teams that have documents posted for comments report at RSC Meetings
Lee Pedowicz RSC Meeting
Ongoing
61 21 Notify NPCC Drafting Team members that the RSC is available for advice at any time and that they will be invited to call in with status reports
Lee Pedowicz RSC Meeting
Ongoing
- 20 - LRP 312011 1027 AM
Action Item
Number
Agenda Item
Number Description Owner Due Status
Sept 24-25 2009
Nov 4-5 2009
April 21-22 2010
63 ---- Coordination with the Compliance Committee to develop Joint Activity Action List
Greg Campoli RSC Meeting
Outgrowth of RSCCC joint
session April 21 2010 Ongoing There will be a joint RSCCC
Meeting in December Ralph Rufrano will be
rejoining the RSC in the capacity of
NPCC Compliance liaison Comments not to be submitted
on the CCEP June 29-30 2010
65 ---- RSC to review the
NPCC Members on NERC Drafting Teams list and provide David Kiguel with updates Lee Pedowicz sent E-mail to update individual memberrsquos status
RSC RSC Meeting
Ongoing
- 21 - LRP 312011 1027 AM
Action Item
Number
Agenda Item
Number Description Owner Due Status
August 18-19 2010
66 ---- Status of Memorandum of Understanding
Si-Truc Phan RSC Meeting
Provide update
67 ---- Effectively communicating to the RSC
Guy Zito Lee Pedowicz Michael Lombardi Saurabh Saksena Kurtis Chong Sylvain Clermont
RSC Meeting
Achieve RSC consensus
Nov 30 2010 Dec 2 2010
68 ---- Revise Regional Reliability Standards Development Procedure
Guy Zito Lee Pedowicz Michael Lombardi Saurabh Saksena Kurtis Chong Sylvain Clermont
RSC Meeting
Initial draft with revisions made
69 ---- Revise RSC Scope RSC RSC Meeting
Feb 2-3 2011
70 20 Talk to Stan Kopman and the CC about the process for submitting comments after Valerie Agnew (NERC) drafts CANs for their first posting Industry will have two weeks for
Guy Zito Lee Pedowicz
RSC Meeting
- 22 - LRP 312011 1027 AM
Action Item
Number
Agenda Item
Number Description Owner Due Status
comments 71 Talk to Compliance
about Reliability Standard RSAWs There should be a Compliance Committee representative on the Drafting Team
Guy Zito RSC meeting
72 Find out what other
Regions are doing regarding interpretations
Guy Zito RSC Meeting
73 Discuss consistency
with the RSG Guy Zito RSC
Meeting
Action Item 68--Guy Zito Lee Pedowicz Chris de Graffenried and Michael Lombardi worked on making a revision to the Regional Reliability Standards Development Procedure Guy Zito sought volunteers to review the document with the changes made Brian Gooder and Kurtis Chong volunteered and will review by mid-February The RSAW process should minimize the number of documents that when changed have to go to the Board for approval Will go in the NPCC Open Process and at NERC for approval Does the NPCC membership have to approve Action Item 69--The question was raised whether NERC Alerts should be included David Kiguel said that there are different levels of Alerts The distribution of Alerts is determined by the entity types The RSC apparently wouldnrsquot get everything Even though all Sectors are represented the representatives arenrsquot necessarily the ones receiving the Alerts Guy Zito--Eventually there will be a Regional Standard process for review of Standards and Criteria Guy Zito--Will present revised Scope ideas to the NPCC Board of Directors at their May 3 2011 Meeting (teleconference)
- 23 - LRP 312011 1027 AM
Guy Zito--NPCC organization changing from an eight sector membership to a six sector membership The Board of Directors will have a hybrid makeup The Small Customer Sector is being eliminated Guy Zito Lee Pedowicz and Michael Lombardi will work on the RSC Scope After a draft completed will distribute to the RSC Saurabh Saksena asked whether the Scope will include the review of other Regionrsquos standards RSC will stop doing it Chris de Graffenried commented that the RSC should be comparing similar regional standards Guy Zito--Presented the idea to the members of the RSC taking on more responsibility and authority
Page 1 of 3
Revised 3102011
Line No Project No TitleHigh
Priority Associated Standard SAR PostedPosted for Comment
Posted For Ballot
Industry Approved
NERC BOT Approved
Petitioned for FERC Approval FERC Approved Comments Project Status
1 Project 2006-01 ― System Personnel Training No PER-004-2 and PER-005-1Yes 2nd (Thru
32006)Yes 4th (Thru
71708)Yes 5th (Recirc Thru 122208) Yes (122208) Yes (040109) Yes (93009) Yes (111810) Completed
2 Project 2007-05 ― Balancing Authority Controls No NA NA NA NA NA NA NA NA
As of July 28 2010 this project has been merged with Project 2007-18 - Reliability-based Controls and is now Project 2010-14 - Balancing Authority Reliability-based Control NA
3 Project 2007-18 ― Reliability-based Control No NA NA NA NA NA NA NA NA
As of July 28 2010 this project has been merged with Project 2007-18 - Reliability-based Controls and is now Project 2010-14 - Balancing Authority Reliability-based Control NA
4 Project 2007-24 - Interpretation of TPL-002 and TPL-003 No TPL-002-0a and TPL-003-0a x xYes 2nd (Thru
7708) Yes ( 7708) Yes (73008) Yes (102408) Yes (42310) Completed
5 Project 2008-06 ― Cyber Security ― Order 706 (VRFs and VSLs) No CIP VRFs and VSLs xYes 1st (Thru
42009)Yes (Recirc Thru
111209) Yes (111209) Yes (121609) Yes (121809) Yes (12011) Completed
6 Project 2008-07 ― Interpretation of EOP-002-2 R63 and R71 by Brookfield Power No EOP-002-2 R63 and R71 x xYes (Recirc Thru
83109) Yes (83109)No (Remanded
21610) NA NA
21610 NERC BOT(1) Remands the proposed interpretation of EOP-002-2 Requirements R63 and R71 to the Standards Committee because the proposed interpretation adds requirements not in the standard thereby exceeding the permissible scope of an interpretation and(2) Directs the Standards Committee to initiate action to revise EOP-002-2 as appropriate NA
7 Project 2008-11 ― Interpretation of VAR-002a by ICF Consulting No VAR-002-11b x xYes (Recirc Thru
1609) Yes (1609) Yes (21009) Yes (3509) Yes (91610) Completed
8 Project 2009-08 ― Nuclear Plant Interface Coordination No NUC-001-2Yes 1st (Thru
31809)Yes 1st (Thru
31809)Yes (Recirc Thru
72009) Yes (72009) Yes (8509) Date Yes (12110) Completed
9 Project 2009-13 ― interpretation of CIP-006-1 by PacifiCorp No CIP-006-2c x xYes (Recirc Thru
122309) Yes (122309) Yes (21610) Yes (42010) Yes (71510) Completed
10Project 2009-15 ― Interpretation of MOD-001-1 R2 and R8 and MOD-029-1 R5 and R6 by NYISO No MOD-001-1 R2 and R8 and MOD-029-1 R5 and R6 x x
Yes (Recirc Thru 71709) Yes (71709) Yes (11509) Yes (12209) Yes (91610) Completed
11Project 2009-16 mdash Interpretation minus CIP-007-1 R2 mdash Systems Security Management No CIP-007-2a x x
Yes (Intitial Thru 92109) Yes (92109) Yes (11509) Yes (111709) Yes (31810) Completed
12 Project 2009-18 ― Withdraw Three Midwest ISO Waivers No BAL-006-2 and INT-003-3 x xYes (Intitial Thru
9809) Yes (9809) Yes (11509) Yes (112009) Yes (1611) Completed
13Project 2009-21 ― Cyber Security Ninety-day Response ― CIP Family of Standards No CIP-002 through CIP-009 V3
Yes 1st (Thru 111209)
Yes 1st (Thru 111209)
Yes (Recirc Thru 121409) Yes (121409) Yes Yes (11910) Yes (31810) Completed
14 Project 2010-12 ― Order 693 Directives NoBAL-002-1 EOP-002-3 FAC-002-1 MOD-021-1 PRC-004-2 and VAR-001-2
Yes 1st (Thru 71310)
Yes 1st (Thru 71310)
Yes 2nd (Recirc Thru 73110) Yes (73110) Yes (8510) Yes (9910) Yes (11011) Completed
15 Pre-2006 ― Operate Within Interconnection Reliability Operating Limits No IRO-008-1 IRO-009-1 and IRO-010-1aYes 2nd (Thru
92302)Yes 9th (Thru
42508)Yes 1st (Recirc Thru 82108) Yes (82108) Yes (101708) Yes (123109) NOPR issued 111810 - Comments were due 12411 Pending Regulatory Approval
16 Project 2006-03 ― System Restoration and Blackstart No EOP-001-2 EOP-005-2 and EOP-006-2Yes 2nd (Thru
30907)Yes 4 th (Thru
111808)Yes 5th (Recirc Thru 51809) Yes (51809) Yes (8509) Yes (123109) NOPR issued 111810 - Comments were due 12411 Pending Regulatory Approval
17 Project 2006-04 ― Backup Facilities No EOP-008-1Yes 2nd (Thru
31607)Yes 5th (Thru
3810)Yes 7th (Recirc Thru 72610) Yes (72610) Yes (85010) Yes (21111) Pending Regulatory Approval
18 Project 2006-08 ― Transmission Loading Relief No IRO-006-5 and IRO-006-East-1
Yes (For DT Nomination
11207)Yes 4th (Thru
113009)Yes 6th (Recirc Thru 83010) Yes (83010) Yes (11410) Yes (11311) Pending Regulatory Filing
19 Project 2007-27 ― Interpretation of CIP-006 R11 by SCEampG No CIP-006 R11 x xYes (Recirc Thru
12407) Yes (12407) Yes (21208) Yes (122209) Pending Regulatory Approval
20 Project 2008-06 ― Cyber Security ― Order 706 (CIP-002-4) Yes CIP-002-4 thru CIP-009-4 xYes 1st (Thru
11310)Yes Recirc Thru
123010) - passed Yes (123010) Yes (12411) Yes (21011) Pending Regulatory Approval
21 Project 2008-14 ― Cyber Security Violation Severity Levels No CIP family of standardsYes 2nd (Thru
042009)Yes 1st (Thru
042009)Yes (Recirc Thru
71609) Yes (71609) Date Date Pending Regulatory Approval
22 Project 2008-15 ― Interpretation of CIP-006-1a By US Army Corps of Engineers No CIP-006-1a R4 x xYes (Recirc Thru
21609) Yes (21609) Yes (8509) Yes (122209) Pending Regulatory Approval
23 Project 2008-18 ― Interpretation of TOP-005-1 and IRO-005-1 by Manitoba Hydro No TOP-005-1 R3 and IRO-005-1 R12 x xYes (Recirc Thru
42709) Yes (42709) Yes (11509) Yes (112409) NOPR issued 121610 - Comments are due 22711 Pending Regulatory Approval
24 Project 2009-09 ― Interpretation of CIP-001-1 by Covanta No CIP-001-1 R2 x xYes (Recirc Thru
10909) Yes (100909) Yes (21610) Yes (42110) Pending Regulatory Approval
25Project 2009-10 ― Interpretation of PRC-005-1 R1 by Compliance Monitoring Processes Working Group (CMPWG) No PRC-005-1 R1 x x
Yes (Recirc Thru 8609) Yes (8609) Yes (11509) Yes (111709) NOPR issued 121610 - Comments are due 22511 Pending Regulatory Approval
26Project 2009-11 ― Interpretation of IRO-010-1 R12 and R3 by WECC Reliability Coordination Subcommittee No IRO-010-1 R12 and R3 --gt IRO-010-1a x x
Yes (Recirc Thru 6509) Yes (6509) Yes (8509) Yes (123109) NOPR issued 111810 Comments were due 12411 Pending Regulatory Approval
27 Project 2009-12 ― Interpretation of CIP-005-1 by PacifiCorp No CIP-005-1 R13 x xYes (Recirc Thru
102609) Yes (102609) Yes (21610) Yes (42110) Pending Regulatory Approval
28 Project 2009-14 ― Interpretation of TPL-002-0 R1310 by PacifiCorp No TPL-002-0 R1310 x xYes (Recirc Thru
8609) Yes (8609) Yes (11509) Yes (111709)
bull FERC NOPR [Docket RM10-6-000] - FERC reject NERCrsquos proposed interpretation and instead proposes an alternative interpretation of the provision 31810 Pending Resolution of FERC NOPR
29 Project 2009-31 ― Interpretation of TOP-001-1 R8 by FMPP No TOP-001-1 R8 x xYes 1st (Intitial Thru 31610) Yes (31610) Yes (51210) Yes (71610)
bull On 21411 NERC responded to FERCrsquos request for databull On 12811 FERC requested additional information from NERC Pending Regulatory Approval
30 Project 2010-10 ― FAC Order 729 Yes FAC-013-2Yes 1st (Thru
42910)Yes 3rd (Thru
1811)Yes 3rd (Recirc Thru 12311) Yes (12311) Yes (12411) Yes (12811) Under Development
31 Urgent Action SAR for Revision No BAL-004-1 Yes 2nd (Thru
101807)Yes 2nd (Thru
101807)Yes 1st (Recirc Thru 12407) Yes (12407) Yes (32608) Yes (31109)
FERC NOPR [Docket RM09-13-000 (March 18 2010)] - Commission proposes to remand BAL-004-1 Pending Regulatory Approval
32 Project 2007-01 ― Underfrequency Load Shedding Yes EOP-003-1 and PRC-006-1Yes 3rd (Thru
32907)Yes 3rd (Thru
71610)Yes 6th (Recirc Thru 102810) Yes (102810) Yes (11410) Pending Regulatory Filing
33 Project 2007-04 ― Certifying System Operators No PER-003-1Yes 2nd (Thru
13108)Yes 1st (Thru
112009)Yes 3rd (Recirc Thru 121310) Yes (123110) Yes (21711) Pending Regulatory Filing
34Project 2008-09 ― Interpretation of EOP-001-0 R1 by Regional Entity Compliance Managers No EOP-001-0 R1 x x
Yes 4th (Recirc Thru 101410) Yes (101410) Yes (11410) Pending Regulatory Filing
NERC Reliability Standards Executive Tracking Summary
Page 2 of 3
Revised 3102011
Line No Project No TitleHigh
Priority Associated Standard SAR PostedPosted for Comment
Posted For Ballot
Industry Approved
NERC BOT Approved
Petitioned for FERC Approval FERC Approved Comments Project Status
NERC Reliability Standards Executive Tracking Summary
35 Project 2009-06 ― Facility Ratings No FAC-008-2Yes 2nd (Thru
9909)Yes 2nd (Thru
9909)Yes 4th (Recirc Thru 31810) Yes (31810) Yes (51210) Pending Regulatory Filing
36Project 2009-17 ― Interpretation of PRC-004-1 and PRC-005-1 R2 by Y-W Electric and Tri-State G amp T No PRC-004-1 and PRC-005-1 x x
Yes 3rd (Recirc Thru 12310) Yes (12310) Yes (21711) Pending Regulatory Filing
37 Project 2009-27 ― Interpretation of TOP-002-2a R10 by FMPP No TOP-002-2a R10 x xYes (Recirc Thru
101610) Yes (101610) Yes (11410) Pending Regulatory Filing
38 Project 2009-28 ― Interpretation of EOP-001-1 and EOP-001-2 R22 by FMPP No EOP-001-1 and EOP-001-2 x xYes (Recirc Thru
101510) Yes (101510) Yes (11410) Pending Regulatory Filing
39Project 2010-09 ― Cyber Security Order 706B ― Nuclear Plant Implementation Plan No Various CIP Standards
Yes 1st (Thru 31510)
Yes 1st (Thru 31510)
Yes (Recirc Thru 7210) Yes (7210) Yes (8510) Pending Regulatory Filing
40 Project 2010-11 ― TPL Table 1 Order Yes TPL-002 Footnote bYes 1st (Thru
52610)Yes 3rd (Thru
1511)Yes 3rd (Recirc
Thru 2511) Yes (2511) Yes (21711)Ref FERC 31810 Order Setting Deadline for Compliance [Docket RM06-16-009] -- NERC to clarify Std TPL 002-0 Pending Regulatory Filing
41 Project 2010-13 ― Relay Loadability Order Yes PRC-023-2Yes 1st (Thru
91910)Yes 3rd (Thru
121610)
Yes 3rd (Recirculation Thru
3611) Yes (3611) Yes (31011)
On 31011 the NERC BOT approved PRC-023-2 and NERC Rules of Procedure Section 1700 - Challenges to Determinations Under Development
42 Project 2007-23 ― Violation Severity Levels No Six sets of VSLs for various standardsYes 2nd Supp (Thru 91610)
Yes 6th (Thru 21811)
Yes (Non-Binding Poll Thru 21811
NA - Non Binding Poll Only
Next StepsThe revised VSLs will be presented to the Board of Trustees for approval Under Development
43 Project 2009-20 ― Interpretation of BAL-003-0 R2 and R5 by Energy Mark Inc No BAL-003-01b x xYes (Recirc Thru
22610) Yes (22610) Under Development
44 Project 2006-02 ― Assess Transmission and Future Needs Yes TPL-001-2Yes 3rd (Thru
31607)Yes 5th (Informal
Thru 9210)Yes (Initial Thru
3110)Response to informal comments posted - Formal comments will be solicited later
On Hold - pending completion of Project 2010-11
45 Project 2006-06 ― Reliability Coordination YesCOM-001-2 COM-002-3 IRO-001-2 and IRO-014-2 (possibly IRO-003-2 - see comments)
Yes 3rd Supp (Thru 9310)
Yes 4th (Thru 3711)
Yes 1st (Intitial Thru 3711)
DT to address comments on Supplemental SAR SAR proposes to expand the scope of work under to address some directives from Order 693 that are associated with IRO-003-2 Under Development
46 Project 2007-07 ― Vegetation Management Yes FAC-003-2Yes 3rd (Thru
71707)Yes 5th (Thru
22811)Yes 4th (Initial Thru
71910) Under Development
47 Project 2007-17 ― Protection System Maintenance amp Testing Yes PRC-005-2Yes 1st (Thru
71007)
Yes 3rd (30 day formal Thru 121710)
Yes 6th (Successive Thru
122010) Under Development
48 Project 2008-10 ― Interpretation of CIP-006-1 R11 by Progress Energy No CIP-006 R11 x xYes 2nd (Initial Thru 101209)
Since at least one negative ballot included a comment the results are not final A second (or recirculation) ballot must be conducted Under Development
49Project 2009-19 ― Interpretation of BAL-002-0 R4 and R5 by NWPP Reserve Sharing Group No BAL-002-0 R4 and R5 x x
Yes (Intitial Thru 22610)
1) Pending recirculation ballot2) NERC Staff recommends that no further effort be spent on this interpretation instead allowing the BACSDT to use that energy to rewrite the standard Under Development
50 Project 2009-23 ― Interpretation of CIP-004-2 R3 by Army Corps of Engineers No CIP-004-2 x xYes 2nd (Intitial
Thru 4810) Pending recirculation ballot Under Development
51 Project 2009-24 ― Interpretation of EOP-005-1 R7 by FMPA No EOP-005-1 R7 x xYes 1st (Intitial Thru 11510) Balloting Deferred per Standards Committee Under Development
52 Project 2009-25 ― Interpretation of BAL-001-01 and BAL-002-0 by BPA No BAL-001-01a and BAL-002-0 x xYes 1st (Intitial Thru 11510) Pending recirculation ballot Under Development
53 Project 2009-26 ― Interpretation of CIP-004-1 by WECC No CIP-004-1 R2 R3 and R4 x xYes 1st (Intitial Thru 11910) Balloting Deferred per Standards Committee Under Development
54 Project 2009-29 ― Interpretation of TOP-002-2a R6 by FMPP No TOP-002-2a R6 x xYes 1st (Intitial Thru 22210) Pending recirculation ballot Under Development
55 Project 2009-30 ― Interpretation of PRC-001-1 R1 by WPSC No PRC-001-1 x xYes 1st (Intitial Thru 22610) Pending recirculation ballot Under Development
56 Project 2009-32 ― Interpretation of EOP-003-1 R3 and R5 by FMPP No EOP-003-1 R3 and R5 x xYes 2nd (Re-ballot
Thru 33110) Pending recirculation ballot Under Development
57 Project 2010-15 ― Urgent Action Revisions to CIP-005-3 No CIP-005-4Yes 1st (Thru
92710)Yes 2nd (Thru
121110)Yes 2nd (Initial Thru 121110)
Standard clasification downgraded from Urgent Action to Expedited Action Under Development
58 Project 2007-02 ― Operating Personnel Communications Protocols Yes COM-003-1 and COM-002-2Yes 2nd (Thru
5207)Yes 1st (Thru
11510) Under Development
59 Project 2007-03 ― Real-time Operations Yes TOP-001-2 TOP-002-3 and TOP-003-2Yes 2nd (Thru
90707)Yes 4th (Thru
9310) Under Development
60 Project 2007-06 ― System Protection Coordination No PRC-001-1Yes 1st (Thru
71007)Yes 1st (Thru
102609) Under Development
61 Project 2007-09 ― Generator Verification YesMOD-026-1 and PRC-024-1MOD-024-2
Yes 1st (Thru 52107)
Yes 1st (Thru 4209)
Yes 1st (Thru 21810) Under Development
62 Project 2007-11 ― Disturbance Monitoring No PRC-002-1 and PRC-018-1Yes 1st (Thru
42007)Yes 1st (Thru
31809) Under Development
63 Project 2007-12 ― Frequency Response Yes BAL-003-1Yes 3rd (Thru
30907)Yes 1st
(Thru 3711) Posted for 30 day formal comment period Under Development
64 Project 2008-06 ― Cyber Security ― Order 706 (CIP-010-1 and CIP-011-1) Yes CIP-010-1 and CIP-011-1 xYes 1st (Informal
Thru 6310) Under Development
65 Project 2008-08 ― EOP VSL Revisions No EOP family of standardsYes 1st (Thru
51908)Yes 2nd (Thru
12309)
Subsequent to the last ballot (August 2009) of the VSLs for Projects 2007-23 and 2008-08 NERC staff reviewed the VSLs again for consistency with the FERC Guidelines The review identified some discrepancies and inconsistencies in the VSL assignments and some minor typographical errors NERC Staff along with members of the VSL drafting team proposed changes to VSLs and re-started process Under Development
66 Project 2008-12 ― Coordinate Interchange Standards No INT-004- INT-006-4 INT-009-2 INT-010-2 and INT-011-1Yes 1st (Thru
73108)Yes 1st (Thru
121109) Under Development
67 Project 2009-01 ― Disturbance and Sabotage Reporting Yes EOP-004-2Yes 1st (Thru
52109)Yes 2nd (Formal
Thru 4811) Under Development
Page 3 of 3
Revised 3102011
Line No Project No TitleHigh
Priority Associated Standard SAR PostedPosted for Comment
Posted For Ballot
Industry Approved
NERC BOT Approved
Petitioned for FERC Approval FERC Approved Comments Project Status
NERC Reliability Standards Executive Tracking Summary
68 Project 2009-02 ― Real-time Reliability Monitoring and Analysis Capabilities Yes NewYes 2nd (Thru
21810)Yes 1st (Informal
Thru 4411) Concept White Paper posted for informal comment period Under Development
69 Project 2009-22 ― Interpretation of COM-002-2 R2 by the IRC No COM-002-2 x1st (30 day formal
thru 121810)
The team met Nov 17-18 2009 to draft a response Due to differences of opinion by the team they conducted a follow-up conference call on Dec 4 2009 NERC staff has disagreed with the interpretation and has asked that the team reconsider Under Development
70 Project 2010-07 ― Transmission Requirements at the Generator Interface NoVarious BAL CIP EOP FAC IRO MOD PER PRC TOP and VAR standards
Yes 1st (Thru 31510)
Yes 1st(Thru 4411) Concept White Paper posted for informal comment period Project Deferred
71 Project 2010-16 ― Definition of System Operator No NERC Glossary Of TermsYes 1st (Thru
12310)Yes 1st (Thru
12310) Under Development
72 Project 2010-17 ― Definition of Bulk Electric System Yes NERC Glossary Of TermsYes 1st (Thru
12111)Yes 1st (Thru
12111)
73 Project 2010-INT-05 CIP-002-1 Requirement R3 for Duke Energy No CIP-002-1 R3 xYes 1st (Thru
10810)
74 Project 2008-01 ― Voltage and Reactive planning and control Yes VAR-001 and VAR-002Yes 2nd (Thru
32610) Under Development
75 Project 2008-02 ― Undervoltage Load Shedding No PRC-010-0 and PRC-022-1Yes 1st (Thru
021910)June 2010 SC meeting - Project deferred until Higher Priority projects are completed Project Deferred
76 Project 2009-03 ― Emergency Operations Yes EOP-001 EOP-002 EOP-003 and IRO-001Yes 1st (Thru
11510) Under Development
77 Project 2009-05 ― Resource Adequacy Assessments No NewYes 2nd (Thru
33006) Under Development
78 Project 2009-07 ― Reliability of Protection Systems No NewYes 1st (Thru
21809) Pending prioritization - may be postponed Under Development
79 Project 2010-08 ― Functional Model Glossary Revisions NoYes 1st (Thru
22210)June 2010 SC meeting - Project deferred until Higher Priority projects are completed Project Deferred
80 Project 2009-04 ― Phasor Measurement Units No Project has not started81 Project 2010-01 ― Support Personnel Training No Project has not started82 Project 2010-02 ― Connecting New Facilities to the Grid No Project has not started83 Project 2010-03 ― Modeling Data No Project has not started84 Project 2010-04 ― Demand Data No Project has not started85 Project 2010-05 ― Protection Systems No Project has not started86 Project 2010-06 ― Results-based Reliability Standards No Results-based Reliability Standards Transistion Plan Transistion Plan posted 72610
87 Project 2010-14 ― Balancing Authority Reliability-based Control No
As of July 28 2010 this project has merges Project 2007-18 - Reliability-based Controls and is now Project 2010-14 - Balancing Authority Reliability-based Control into a single project Under Development
88 Project 2010-INT-01 Interpretation of TOP-006-2 R12 and R3 for FMPP No TOP-006-2 R12 and R3 Balloting Deferred per Standards Committee On Hold89 Project 2010-INT-02 Interpretation of TOP-003-1 R2 for FMPP No TOP-003-1 R2 Balloting Deferred per Standards Committee On Hold90 Project 2010-INT-03 Interpretation of TOP-002-2a R2 R8 and R19 for FMPP No TOP-002-2a R2 R8 and R19 Balloting Deferred per Standards Committee On Hold91 Project 2010-INT-04 Interpretation of EOP-001-1 R24 for FMPP No EOP-001-1 R24 Balloting Deferred per Standards Committee On Hold
AcronymsSAR- Standards Authorization RequestRS- Reliability StandardDT- Drafting TeamSC - NERC Standards CommitteeTBD- To Be DeterminedBOT- NERC Board of Trustee
Page 1 of 1
Revised 2282011 Further details regarding the individual documents may be found at httpwwwnpccorgregStandardsUnderDevaspx
Line No Regional Standard ID Regional Reliability Standard TitleRSAR
PostedPosted for Comment
Posted For Ballot
Industry Approved
NPCC BOD Approved
NERC BOT Approved FERC Approved Comments Project Status
1 BPS-501-NPCC-01 Classification of Bulk Power System Elements (Withdrawn by RSC 80709)Yes 1st (Thru
2408) NA NA NA NA NA NA Withdrawn by RSC 80709 Withdrawn
2 PRC-002-NPCC-01 Disturbance MonitoringYes 1st (Thru
91008)Yes 3rd (Thru
102409)Yes 1st (Thru
1610) Yes (1610) Yes (1910) Yes (11410) Pending Regulatory Approval
3 PRC-006-NPCC-01 Automatic Underfrequency Load Shedding ProgramYes 1st (Thru
82508)Yes 2nd (Thru
7910)Yes 1st (Thru
12811)
- On 2611 NPCC RSC remanded standard back to the drafting team- Replaces Directory 12 Under frequency Load Shedding Program Requirements Under Development
4 BAL-002-NPCC-01 Regional Reserve SharingYes 1st (Thru
11210) Under Development
5 PRC-012-NPCC-01 Special Protection SystemsYes 1st (thru
81808) On Hold678910
AcronymsRSAR- Regional Standards Authorization RequestRRS- Regional Reliability StandardDT- Drafting TeamSC - NERC Standards CommitteeTBD- To Be DeterminedBOD- NPCC Board of DirectorsBOT- NERC Board of Trustee
NPCC Regional Reliability Standards Executive Tracking Summary
Page 1 of 2
Revised 1282011 Further details regarding the individual documents may be found at httpwwwnpccorgregStandardsopOtheraspx
Line No Type Document DescriptionEffective
Date Comments Status1 Criteria A-01 Criteria for Review and Approval of Documents2 Criteria A-03 Emergency Operation Criteria 3 Criteria A-05 Bulk Power System Protection Criteria A5 retired Directory 4 established4 Criteria A-07 Revise Critical Component Definition (Glossary of Tterms)5 Criteria A-08 NPCC Reliability Compliance and Enforcement Program 6 Criteria A-10 Classification of BPS Elements7 Criteria A-15 Disturbance Monitoring Equipment Criteria 8 Guideline B-01 NPCC Guide for the Application of Autoreclosing to the Bulk Power System9 Guideline B-12 Guidelines for On-Line Computer System Performance During Disturbances10 Guideline B-21 NPCC Guide for Analysis and Reporting of Protection System Misoperations To be retired - See C-4511 Guideline B-22 Guidelines for Implementation of the NPCC Compliance Program12 Guideline B-25 Guide to Time Suynchronization13 Guideline B-26 Guide for Application of Disturbance Recording Equipement 14 Guideline B-27 Regional Critical Asset Identification Methodology15 Guideline B-28 Guide for Generator Sequence of Events Monitoring16 Procedure C-00 Listing of NPCC Documents by Type
17 Procedure C-01NPCC Emergency Preparedness Conference Call Procedures - NPCC Security Conference Call Procedures
18 Procedure C-05 Monitoring Procedures for Emergency Operation Criteria19 Procedure C-07 Monitoring Procedures for the Guide for Rating Generating Capability
20 Procedure C-15 Procedures for Solar Magnetic Disturbances Which Affect Electric Power Systems21 Procedure C-17 Procedures for Monitoring and Reporting Critical Operating Tool Failures
22 Procedure C-21Monitoring Procedures for Conformance with Normal and Emergency Transfer Limits
23 Procedure C-25 Procedure to Collect Power System Event Data24 Procedure C-29 Procedures for System ModelingData Requirements and Facility Ratings
25 Procedure C-30Procedure for Task Force on System Protection Review of Disturbances and Protection Misoperations
26 Procedure C-32 Review Process for NPCC Reliability Compliance Enforcement Program27 Procedure C-33 Procedure for Analysis and Classification of Dynamic Control Systems28 Procedure C-36 Procedures for Communications During Emergencies29 Procedure C-39 Procedure to Collect Major Disturbance Event Data30 Procedure C-42 Procedure for Reporting and Reviewing System Disturbances31 Procedure C-43 NPCC Operational Review for the Integration of New facilities32 Procedure C-44 NPCC Regional Methodology and Procedures for Forecasting TTC and ATC
33 Procedure C-45
Procedure for Analysis and Reporting of Protection System Misoperations[CO-12 Seasonal Assessment Methodology (previously proposed but not issued - information included in the CO-12 Working Group scope instead )]
Procedure C-45 (re Protection System Misoperations) under development - will replace Guide B-21 (last updated 3111)
34 Criteria A-02 (retired) Basic Criteria for Design and Operation Of Interconnected Power Systems A2 retired Directory 1 established35 Criteria A-04 (retired) Maintenance Criteria for Bulk Power System Protection A4 retired 7112008 Directory 3 established36 Criteria A-06 (retired) Operating Reserve Criteria A6 retired 1222010 Directory 5 established37 Criteria A-11 (retired) Special Protection System Criteria Directory 7 established38 Criteria A-12 (retired) System Restoration Criteria A12 draft replaced by Directory 8 102108 Directory 8 established39 Criteria A-13 (retired) NPCC Inc Verification of Generator Gross and Net Real Power Capability A13 retired 1222200840 Criteria A-14 (retired) Verification of Generator Gross and Net Reactive Power Capability A14 retired 1222200841 Guideline B-02 (retired) Control Performance Guide B2 retired Content transferred to Directory 5 App 542 Guideline B-03 (retired) Guidelines for Inter-AREA Voltage Control B3 retired Replaced by Procedure C-4043 Guideline B-04 (retired) Guidelines for NPCC Area Transmission Reviews B4 retired Content transferred to Directory 1 AppB44 Guideline B-05 (retired) Bulk Power System Protection Guide B5 retired Content transferred to Directory 4 App A
NPCC Document Open Process Executive Tracking Summary
Page 2 of 2
Revised 1282011 Further details regarding the individual documents may be found at httpwwwnpccorgregStandardsopOtheraspx
Line No Type Document DescriptionEffective
Date Comments Status
NPCC Document Open Process Executive Tracking Summary
45 Guideline B-06 (retired) Automatic Load Shedding Employing Underfrequency Threshold Relays B6 retired Replaced by Guideline B-0746 Guideline B-07 (retired) Automatic Underfrequency Load Shedding Program B7 retired Content transferred to Directory 4 App A47 Guideline B-08 (retired) Guidelines for Area Review of Resource Adequacy B8 retired Content transferred to Directory 1 AppD48 Guideline B-09 (retired) Guide for Rating Generating Capability B9 retired Replaced by Criteria A-13 Document on July 18 200749 Guideline B-10 (retired) Guidelines for Requesting Exclusions B10 retired Content transferred to Directory 1 App E50 Guideline B-11 (retired) Special Protection System Guideline B11 retired Replaced by Criteria A-1151 Guideline B-13 (retired) Guide for Reporting System Disturbances B13 retired Replaced by Procedure C-4252 Guideline B-24 (retired) Security Guidelines for Protection System IEDS B24 retired Content transferred to Directory 4 App A53 Procedure C-03 (retired) C3 retired Replaced by Procedure C-3654 Procedure C-04 (retired) Monitoring Procedure for Guides Inter-AREA Volt Control C4 retired Content transferred to Directory 1 App G55 Procedure C-08 (retired) Monitoring Procedures for Control Performance Guide C8 retired Content transferred to Directory 5 App 556 Procedure C-09 (retired) Monitoring Procedures for Operating Reserve Criteria C9 retired Content transferred to Directory 5 App 2 57 Procedure C-10 (discontinued) C10 discontinued58 Procedure C-11 (retired) Monitoring Procedures for Interconnected System Freq Response C11 retired Content transferred to Directory 5 App 159 Procedure C-12 (retired) Procedure Shared Activation Ten Minute Reserve C12 retired Content transferred to Directory 5 Sect 58 amp App 460 Procedure C-13 (retired) Operational Planning Coordination C13 retired Content transferred to Directory 1 App F61 Procedure C-14 (retired) C14 retired Procedure C-14 was incorporated in Procedure C-1362 Procedure C-16 (retired) Procedure for Review of New or Modified BPS SPS C16 retired Content transferred to Directory 7 AppB63 Procedure C-18 (retired) Procedure for Test amp Analysis Extreme Contingencies C18 retired Content transferred to Directory 1 AppC64 Procedure C-20 (retired) Procedures During Abnormal Operating Conditions C20 retired Content transferred to Directory 5 App 365 Procedure C-22 (retired) Procedure for Reporting amp Review Proposed BPS Protection Systems C22 retired Content transferred to Directory 4 App A66 Procedure C-35 (retired) NPCC Inter-Area Power System Restoration Procedure C35 retired Incorporated within Directory 8 System Restoration67 Procedure C-37 (retired) Operating Procedures for ACE Diversity Interchange C37 retired Content transferred to Directory 5 Sect51168 Procedure C-38 (retired) Procedure for Operating Reserve Assistance Content will be transferred to new Directory 5 Reserve
69 Procedure C-40 (retired) Procedures for Inter-AREA Voltage Control C40 retiredContent transferred to Directory 1 App G amp Directory 2 App B
Acronyms
Page 1 of 1
Revised 2282011 Further details regarding the individual documents may be found at httpwwwnpccorgregStandardsopOtheraspx
Line No DocumentDeveloped
From Description Version Date PhaseTask Force
ReviewPosted Open
ProcessRCC
Approval
Full Membership
Ballot Comments Status
1 Directory 1 Criteria A-2 Design and Operation of the Bulk Power System 12109 (V0)Yes 1st (Thru
22811) TFCO comments due 22811 Revision Under Development2 Directory 2 Criteria A-3 Emergency Operations 1611 (V3) V3 - Errata3 Directory 3 Criteria A-4 Maintenance Criteria for Bulk Power System Protection 6309 (V1)4 Directory 4 Criteria A-5 Bulk Power System Protection Criteria 12109 (V0)
5 Directory 5 Criteria A-6 Reserve 12210 (V0)Yes 1st (Thru
xxxx)Revision sent to TFCO for review on 11111 Revision Under Development
6 Directory 67 Directory 7 Criteria A-11 Special Protection Systems 122707 (V0)8 Directory 8 Criteria A-12 System Restoration 102210 (V1)9 Directory 9 Criteria A-13 Verification of Generator Gross and Net Real Power Capability 7709 (V1)
10 Directory 10 Criteria A-14 Verification of Generator Gross and Net Reactive Power Capability 7709 (V1)11 Directory 11
12 Directory 12 Under frequency Load Shedding Program Requirements 1611 (V2) V2 - ErrataWill be replaced by Regional Standard PRC-006-NPCC-01
13 NEW Regional Reserve Sharing
RCC has directed TFCO to develop solutions to regional reserve Sharing issues contained in a new draft Directory on Regional reserve Sharing
AcronymsMC - Members CommitteeRCC - Reliability Coordinating Committee
NPCC Directory Executive Tracking Summary
UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION
SUNSHINE ACT MEETING NOTICE
February 10 2011
The following notice of meeting is published pursuant to section 3(a) of the government in the Sunshine Act (Pub L No 94-409) 5 USC 552b
AGENCY HOLDING MEETING FEDERAL ENERGY REGULATORY COMMISSION DATE AND TIME February 17 2011 1000 AM PLACE Room 2C 888 First Street NE Washington DC 20426 STATUS OPEN MATTERS TO BE CONSIDERED Agenda
NOTE - Items listed on the agenda may be deleted without further notice
CONTACT PERSON FOR Kimberly D Bose MORE INFORMATION Secretary Telephone (202) 502-8400 For a recorded message listing items
struck from or added to the meeting call (202) 502-8627
This is a list of matters to be considered by the Commission It does not include a listing of all documents relevant to the items on the agenda All public documents however may be viewed on line at the Commissionrsquos website at httpwwwfercgov using the eLibrary link or may be examined in the Commissionrsquos Public Reference Room
967TH - MEETING
REGULAR MEETING
February 17 2011
1000 AM Item No Docket No Company
ADMINISTRATIVE A-1
AD02-1-000 Agency Business Matters
A-2
AD02-7-000
Customer Matters Reliability Security and Market Operations
ELECTRIC
E-1 ER03-563-066 Devon Power LLC
E-2 EL10-71-000 Puget Sound Energy Inc
E-3 RM11-9-000
Locational Exchanges of Wholesale Electric Power
E-4 RM11-7-000 AD10-11-000
Frequency Regulation Compensation in the Organized Wholesale Power Markets
E-5 RM10-17-000 Demand Response Compensation in Organized Wholesale Energy Markets
E-6 RM10-13-001 Credit Reforms in Organized Wholesale Electric Markets
E-7 RM08-13-001 Transmission Relay Loadability Reliability Standard
E-8 RM08-19-004 Mandatory Reliability Standards for the Calculation of Available Transfer Capability Capacity Benefit Margins Transmission Reliability Margins Total Transfer Capability and Existing Transmission Commitments and Mandatory Reliability Standards for the Bulk-Power System
E-9 ER11-2411-000 ER11-2572-000
Southern California Edison Company California Independent System Operator Corporation
E-10 ER11-2455-000 ER11-2451-000
Southern California Edison Company California Independent System Operator Corporation
E-11 ER05-1056-005 Chehalis Power Generating LP
E-12 ER10-2869-000 Midwest Independent Transmission System Operator Inc
E-13 ER11-2427-000 ISO New England Inc
E-14 EL10-62-000 Alta Wind I LLC Alta Wind II LLC Alta Wind III LLC Alta Wind IV LLC Alta Wind V LLC Alta Wind VI LLC Alta Wind VII LLC Alta Wind VIII LLC Alta Windpower Development LLC TGP Development Company LLC
GAS
G-1 RP08-306-000 Portland Natural Gas Transmission System
G-2 IS08-390-002 SFPP LP
HYDRO
H-1 RM11-6-000 Annual Charges for Use of Government Lands
H-2 P-2210-209 Appalachian Power Company
H-3 P-2210-206 Appalachian Power Company
H-4 P-12532-003 P-13317-001 P-13689-001
Pine Creek Mine LLC Bishop Paiute Tribe KC LLC
CERTIFICATES
C-1 CP10-485-000
Tennessee Gas Pipeline Company
Kimberly D Bose Secretary
A free webcast of this event is available through wwwfercgov Anyone with Internet access who desires to view this event can do so by navigating to wwwfercgovrsquos Calendar of Events and locating this event in the Calendar The event will contain a link to its webcast The Capitol Connection provides technical support for the free webcasts It also offers access to this event via television in the DC area and via phone bridge for a fee If you have any questions visit wwwCapitolConnectionorg or contact Danelle Springer or David Reininger at 703-993-3100 Immediately following the conclusion of the Commission Meeting a press briefing will be held in the Commission Meeting Room Members of the public may view this briefing in the designated overflow room This statement is intended to notify the public that the press briefings that follow Commission meetings may now be viewed remotely at Commission headquarters but will not be telecast through the Capitol Connection service
From Philip A FedoraTo grpStaffCc Kenneth Lotterhos pheidrichfrcccomSubject March 17 FERC Open Meeting AgendaDate Thursday March 10 2011 75308 PMAttachments 20110310163753-CA03-17-011pdfImportance High
Of Note
E-4 RM09-18-001 Revision to ElectricReliabilityOrganization Definitionof Bulk Electric System
E-5 RM11-14-000 Analysis of HorizontalMarket Power under theFederal Power Act
E-6 RM10-16-000 System RestorationReliability Standards
E-7 RM10-10-000 Planning ResourceAdequacy AssessmentReliability Standard
E-8 RM10-15-000 Mandatory ReliabilityStandards forInterconnectionReliability OperatingLimits
UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION
SUNSHINE ACT MEETING NOTICE
March 10 2011
The following notice of meeting is published pursuant to section 3(a) of the government in the Sunshine Act (Pub L No 94-409) 5 USC 552b
AGENCY HOLDING MEETING FEDERAL ENERGY REGULATORY COMMISSION DATE AND TIME March 17 2011 1000 AM PLACE Room 2C 888 First Street NE Washington DC 20426 STATUS OPEN MATTERS TO BE CONSIDERED Agenda
NOTE - Items listed on the agenda may be deleted without further notice
CONTACT PERSON FOR Kimberly D Bose MORE INFORMATION Secretary Telephone (202) 502-8400 For a recorded message listing items
struck from or added to the meeting call (202) 502-8627
This is a list of matters to be considered by the Commission It does not include a listing of all documents relevant to the items on the agenda All public documents however may be viewed on line at the Commissionrsquos website at httpwwwfercgov using the eLibrary link or may be examined in the Commissionrsquos Public Reference Room
968TH - MEETING
REGULAR MEETING
March 17 2011
1000 AM Item No Docket No Company
ADMINISTRATIVE A-1
AD02-1-000 Agency Business Matters
A-2
AD02-7-000
Customer Matters Reliability Security and Market Operations
ELECTRIC E-1 ER03-563-066
Devon Power LLC
E-2 OMITTED
E-3 NP10-18-000 North American Electric Reliability Corporation
E-4 RM09-18-001 Revision to Electric Reliability Organization Definition of Bulk Electric System
E-5 RM11-14-000
Analysis of Horizontal Market Power under the Federal Power Act
E-6 RM10-16-000
System Restoration Reliability Standards
E-7 RM10-10-000 Planning Resource Adequacy Assessment Reliability Standard
E-8 RM10-15-000 Mandatory Reliability Standards for Interconnection Reliability Operating Limits
E-9 RM09-19-000 Western Electric Coordinating Council Qualified Transfer Path Unscheduled Flow Relief Regional Reliability Standard
E-10 RR09-6-003 North American Electric Reliability Corporation
E-11 OMITTED
E-12 ER11-2256-000
California Independent System Operator Corporation
E-13 EL08-47-006 PJM Interconnection LLC
E-14
EL11-12-000 Idaho Wind Partners 1 LLC
E-15 EL10-1-001 Southern California Edison Company
E-16 EL10-84-002 CAlifornians for Renewable Energy Inc v Pacific Gas and Electric Company Southern California Edison Company San Diego Gas amp Electric Company and the California Public Utilities Commission
GAS G-1 OMITTED
G-2 RP11-1495-002 Ozark Gas Transmission LLC
G-3 RP10-315-002
Columbia Gulf Transmission Company
G-4 OR07-7-000 Tesoro Refining and Marketing Company v Calnev Pipe Line LLC
OR07-18-000 America West Airlines Inc and US Airways Inc Chevron Products Company Continental Airlines Inc Southwest Airlines Co and Valero Marketing and Supply Company v Calnev Pipe Line LLC
OR07-19-000 ConocoPhillips Co v Calnev Pipe Line LLC OR07-22-000 BP West Coast Products LLC v Calnev Pipe
Line LLC OR09-15-000 Tesoro Refining and Marketing Company v Calnev
Pipe Line LLC OR09-20-000 BP West Coast Products LLC v Calnev Pipe
Line LLC
HYDRO
H-1 P-2539-061 Erie Boulevard Hydropower LP
H-2 P-2195-025 Portland General Electric Company
H-3 P-1390-063 Southern California Edison Company
CERTIFICATES C-1 OMITTED
C-2 CP10-492-000 Columbia Gas Transmission LLC
C-3 OMITTED
C-4 CP10-22-000
Magnum Gas Storage LLC Magnum Solutions LLC
C-5 CP10-486-000 Colorado Interstate Gas Company
Kimberly D Bose Secretary A free webcast of this event is available through wwwfercgov Anyone with Internet access who desires to view this event can do so by navigating to wwwfercgovrsquos Calendar of Events and locating this event in the Calendar The event will contain a link to its webcast The Capitol Connection provides technical support for the free webcasts It also offers access to this event via television in the DC area and via phone bridge for a fee If you have any questions visit wwwCapitolConnectionorg or contact Danelle Springer or David Reininger at 703-993-3100 Immediately following the conclusion of the Commission Meeting a press briefing will be held in the Commission Meeting Room Members of the public may view this briefing in the designated overflow room This statement is intended to notify the public that the press briefings that follow Commission meetings may now be viewed remotely at Commission headquarters but will not be telecast through the Capitol Connection service
UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION
SUNSHINE ACT MEETING NOTICE
March 10 2011
The following notice of meeting is published pursuant to section 3(a) of the government in the Sunshine Act (Pub L No 94-409) 5 USC 552b
AGENCY HOLDING MEETING FEDERAL ENERGY REGULATORY COMMISSION DATE AND TIME March 17 2011 1000 AM PLACE Room 2C 888 First Street NE Washington DC 20426 STATUS OPEN MATTERS TO BE CONSIDERED Agenda
NOTE - Items listed on the agenda may be deleted without further notice
CONTACT PERSON FOR Kimberly D Bose MORE INFORMATION Secretary Telephone (202) 502-8400 For a recorded message listing items
struck from or added to the meeting call (202) 502-8627
This is a list of matters to be considered by the Commission It does not include a listing of all documents relevant to the items on the agenda All public documents however may be viewed on line at the Commissionrsquos website at httpwwwfercgov using the eLibrary link or may be examined in the Commissionrsquos Public Reference Room
968TH - MEETING
REGULAR MEETING
March 17 2011
1000 AM Item No Docket No Company
ADMINISTRATIVE A-1
AD02-1-000 Agency Business Matters
A-2
AD02-7-000
Customer Matters Reliability Security and Market Operations
ELECTRIC E-1 ER03-563-066
Devon Power LLC
E-2 OMITTED
E-3 NP10-18-000 North American Electric Reliability Corporation
E-4 RM09-18-001 Revision to Electric Reliability Organization Definition of Bulk Electric System
E-5 RM11-14-000
Analysis of Horizontal Market Power under the Federal Power Act
E-6 RM10-16-000
System Restoration Reliability Standards
E-7 RM10-10-000 Planning Resource Adequacy Assessment Reliability Standard
E-8 RM10-15-000 Mandatory Reliability Standards for Interconnection Reliability Operating Limits
E-9 RM09-19-000 Western Electric Coordinating Council Qualified Transfer Path Unscheduled Flow Relief Regional Reliability Standard
E-10 RR09-6-003 North American Electric Reliability Corporation
E-11 OMITTED
E-12 ER11-2256-000
California Independent System Operator Corporation
E-13 EL08-47-006 PJM Interconnection LLC
E-14
EL11-12-000 Idaho Wind Partners 1 LLC
E-15 EL10-1-001 Southern California Edison Company
E-16 EL10-84-002 CAlifornians for Renewable Energy Inc v Pacific Gas and Electric Company Southern California Edison Company San Diego Gas amp Electric Company and the California Public Utilities Commission
GAS G-1 OMITTED
G-2 RP11-1495-002 Ozark Gas Transmission LLC
G-3 RP10-315-002
Columbia Gulf Transmission Company
G-4 OR07-7-000 Tesoro Refining and Marketing Company v Calnev Pipe Line LLC
OR07-18-000 America West Airlines Inc and US Airways Inc Chevron Products Company Continental Airlines Inc Southwest Airlines Co and Valero Marketing and Supply Company v Calnev Pipe Line LLC
OR07-19-000 ConocoPhillips Co v Calnev Pipe Line LLC OR07-22-000 BP West Coast Products LLC v Calnev Pipe
Line LLC OR09-15-000 Tesoro Refining and Marketing Company v Calnev
Pipe Line LLC OR09-20-000 BP West Coast Products LLC v Calnev Pipe
Line LLC
HYDRO
H-1 P-2539-061 Erie Boulevard Hydropower LP
H-2 P-2195-025 Portland General Electric Company
H-3 P-1390-063 Southern California Edison Company
CERTIFICATES C-1 OMITTED
C-2 CP10-492-000 Columbia Gas Transmission LLC
C-3 OMITTED
C-4 CP10-22-000
Magnum Gas Storage LLC Magnum Solutions LLC
C-5 CP10-486-000 Colorado Interstate Gas Company
Kimberly D Bose Secretary A free webcast of this event is available through wwwfercgov Anyone with Internet access who desires to view this event can do so by navigating to wwwfercgovrsquos Calendar of Events and locating this event in the Calendar The event will contain a link to its webcast The Capitol Connection provides technical support for the free webcasts It also offers access to this event via television in the DC area and via phone bridge for a fee If you have any questions visit wwwCapitolConnectionorg or contact Danelle Springer or David Reininger at 703-993-3100 Immediately following the conclusion of the Commission Meeting a press briefing will be held in the Commission Meeting Room Members of the public may view this briefing in the designated overflow room This statement is intended to notify the public that the press briefings that follow Commission meetings may now be viewed remotely at Commission headquarters but will not be telecast through the Capitol Connection service
From Philip A FedoraTo grpStaffSubject FW NERCs Draft Response to FERCs Notice of Proposed Rulemaking (NOPR) The Integration of Variable Energy ResourcesDate Friday February 25 2011 50342 PMAttachments NERC_draft_VER_NOPR_comments_02-25-11docxImportance High
Nothing like giving adequate review time hellip
By the way Monday is February 28th hellip If you have any comments please provide to me by then Thanks Phil
From Mark Lauby [mailtoMarkLaubynercnet] Sent Friday February 25 2011 446 PMSubject NERCs Draft Response to FERCs Notice of Proposed Rulemaking (NOPR) The Integration of Variable Energy Resources
DraftNERCrsquos Comments Addressing FERCrsquos Notice of Proposed Rulemaking (NOPR) Dear Planning and Operating Committee Members On December 6 2010 NERC requested comments from the Operating and Planning Committee members (see below) on its directionalresponse to FERCrsquos Notice of Proposed Rulemaking (NOPR) titled Notice of Proposed Rulemaking (NOPR) Integration of Variable EnergyResources With input from both committees as well as the Integration of Variable Generation Task Force (IVGTF) leadership team andobservers NERC has developed its final draft comments (enclosed) which must filed on March 2 2011 Please submit your incremental comments to assessmentsnercnet by noon EST on Monday March 1 2011
Chrissy VegsoNorth American Electric Reliability Corporation
116-390 Village BlvdPrinceton NJ 08540
6094528060 | wwwnerccomchrissyvegsonercnet
From Chrissy Vegso Sent Monday December 06 2010 1007 AMTo Chrissy VegsoSubject DRAFT POSTED NERCs Directional Topics Addressing NERCs Response to FERCs Notice of Proposed Rulemaking (NOPR)
Draft PostedNERCrsquos Directional Topics Addressing NERCrsquos Response to FERCrsquos Notice ofProposed Rulemaking (NOPR) Dear Planning and Operating Committee Members The United States Federal Energy Regulatory Commission (FERC) recently released their Notice of Proposed Rulemaking (NOPR)
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
INTEGRATION OF VARIABLE)Docket No RM10-11-000
ENERGY RESOURCES)
COMMENTS OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION IN RESPONSE TO THE FEDERAL ENERGY REGULATORY COMMISSIONrsquoS NOVEMBER 18 2010 NOTICE OF PROPOSED RULEMAKING ON THE INTEGRATION OF VARIABLE ENERGY RESOURCES
March 2 2011
TABLE OF CONTENTS IINTRODUCTION 1 IINOTICES AND COMMUNICATIONS 2 IV DISCUSSION 3 a Inconsistency with Reliability Standards b NERC Definition of Variable Energy Resource c Reliability Impacts from Use of Existing or New Ancillary Services to Address Extreme Ramp Events VCONCLUSION I INTRODUCTION The North American Electric Reliability Corporation (ldquoNERCrdquo) is pleased to provide these comments in response to the Federal Energy Regulatory Commissionrsquos (ldquoFERCrdquo or the ldquoCommissionrdquo) November 18 2010 Notice of Proposed Rulemaking (ldquoNOPRrdquo) on the Integration of Variable Energy Resources (ldquoVERsrdquo)[footnoteRef1] In the NOPR FERC proposes to ldquoreform the pro forma Open Access Transmission Tariff to remove unduly discriminatory practices and to ensure just and reasonable rates for Commission-jurisdictional servicesrdquo[footnoteRef2] [1 Integration of Variable Energy Resources 133 FERC para61149 (November 18 2010)(ldquoNOPRrdquo)] [2 NOPR at p 1] NERCrsquos mission as the FERC-designated Electric Reliability Organization (ldquoEROrdquo)[footnoteRef3] is to ensure the reliability of the bulk power system in North America by in part developing and enforcing mandatory Reliability Standards NERCrsquos reliability mandate under section 215 of the Federal Power Act does not include authority to monitor and enforce market-based issues[footnoteRef4] Accordingly NERCrsquos comments herein focus on three separate areas related to the impact of the Integration of VERs on Reliability [3 See North American Electric Reliability Corporation ldquoOrder Certifying North American Electric Reliability Corporation as the Electric Reliability Organization and Ordering Compliance Filingrdquo 116 FERC para 61062 (July 20 2006)] [4 See Mandatory Reliability Standards for the Calculation of Available Transfer Capability Capacity Benefit Margins Transmission Reliability Margins Total Transfer Capability and Existing Transmission Commitments and Mandatory Reliability Standards for the Bulk-Power System Order No 729 129 FERC para 61155 at P 109 (2009)] II NOTICES AND COMMUNICATIONS Notices and communications with respect to this filing may be addressed to the following III BACKGROUND On January 21 2010 FERC issued a Notice of Inquiry (ldquoNOIrdquo) on the Integration of Variable Energy Resources[footnoteRef5] In the NOI FERC sought comment on the extent to which barriers may exist that impede the reliable and efficient integration of VERs into the electric grid and whether reforms are needed to eliminate those barriers A 60-day comment period was set for interested parties to provide input NERC submitted comments in response to the NOI on April 12 2010[footnoteRef6] NERCrsquos comments provided responses that focused on the reliability impacts of integrating VERs into the grid and NERCrsquos ongoing efforts to address reliability considerations On November 18 2010 FERC issued its NOPR regarding the Integration of VERs in which it proposed to reform the pro forma Open Access Transmission Tariff to remove unduly discriminatory practices and to ensure just and reasonable rates for Commission-jurisdictional services[footnoteRef7] By this filing NERC provides comments in response to the NOPR [5 Integration of Variable Energy Resources 130 FERC para 61053 (January 21 2010) (ldquoNOIrdquo)] [6 See Comments Of The North American Electric Reliability Corporation In Response To The Federal Energy Regulatory Commissionrsquos January 21 2010 Notice Of Inquiry On The Integration Of Variable Energy Resources Docket No RM10-11-000 (April 12 2010)] [7 ldquoIntegration of Variable Energy Resourcesrdquo 133 FERC para 61149 (Nov 18 2010) (ldquoNOPRrdquo)] IV DISCUSSION In formulating its response to the NOPR NERC sought input from industry stakeholders the NERC Operating Committee NERC Planning Committee and the Integration of Variable Resources Task Force (ldquoIVGTFrdquo) To this end NERC posted to its website a letter addressed to its Planning and Operating Committees titled NERCrsquos Directional Topics Addressing NERCrsquos Response to FERCrsquos Notice of Proposed Rulemaking on Integration of Variable Energy Resources[footnoteRef8] In this posting NERC provided reliability considerations and sought input from the committee members on the three separate areas relating to the integration of VERs discussed below [8 httpwwwnerccomfilezpchtml ] a Inconsistency with NERC Reliability Standards In the NOPR the Commission proposed ldquoto amend sections 138 and 146 of the pro forma OATT to provide transmission customers the option to schedule transmission service on an intra-hour basis at intervals of 15 minutesrdquo[footnoteRef9] Noting that the proposed 15-minute interval was ldquoconsistent with the ideal time increments ( ie 5 to 15 minutes) recommended by NERCrdquo the Commission requested comment on whether there was any inconsistency among relevant NERC Reliability Standards and the proposed intra-hour scheduling tariff reform [9 NOPR at P 37] Yet NERC acknowledges that making a 15-minute scheduling interval more routine including (critically) for inter-Balancing Area (BA) transactions would likely require review and refinements to several existing Reliability Standards[footnoteRef10] In particular there would likely be a need for changes to NERCrsquos Interchange Scheduling and Maintenance Coordination (INT) Reliability Standards which were largely written based on the assumption that many schedules will be on an hourly basis To the extent that this assumption has resulted in wording that is consistent with an hourly regime interpretations or modifications to the INT Reliability Standards would likely be required While it is expected that only minor wording changes to affected standards may be necessary adopting interconnection-wide intra-hour scheduling could have a substantial impact on practices and tools used by transmission operators to maintain reliable operations Time and attention to the details (regarding impacts and changes to Reliability Standards practices and tools) would be required but a transition to more widespread use of intra-hour scheduling flexibility is achievable in a reasonable time frame [10 See eg NERC Reliability Standards BAL-005 R121 (Automatic Generation Control) BAL-006 R1 (Inadvertent Interchange) EOP-008 (Plans for Loss of Control Center Functionality) INT-001 R11 (Interchange Information) INT-004-2 (Dynamic Interchange Transaction Modifications) INT-005-003 (Interchange Authority Distributes Arranged Interchange) INT-006-3 (Response to Interchange Authority) INT-008 R1 (Interchange Authority Distributes Status)] However it should be noted that all creation and modification of Reliability Standards must be considered as part of the NERC Reliability Standards Committee prioritization process This prioritization process considers the regulatory reliability and logistical issues associated with projects to create or modify NERC standards and helps determine the manner in which industry resources and NERC staff are deployed to create or modify Reliability Standards Additionally such changes must be developed in accordance with the steps outlined in the NERC Standards Process Manual which ensures an open and inclusive process through adherence to the standards development principles of the American National Standards Institute In the NOPR the Commission proposed to ldquoallow all transmission customers the option of submitting intra-hour schedules up to 15 minutes before the scheduling intervalrdquo[footnoteRef11] NERC notes that the INT Reliability Standards have been written so that nearly all schedules are received at least 20 minutes ahead of the block-schedule start This 20-minute period was set to provide the operator sufficient time to evaluate approve and implement the schedule request For example if an Eastern Interconnection schedule request is submitted at 0040 for a schedule that starts at 0100 then industry actions may include [11 NOPR at 41] middot communication time will be required as the request is transmitted received and processed middot the entities reviewing the request will require sufficient time to evaluate the request middot communication time will be required to verify that all entities have agreed to implement the requested schedule and coordinate that agreement between all entities and middot entities will need time to input the request into their scheduling systems When combined the required time is at least 15 minutes (0055) to perform these tasks with the remaining time allowing for the initiation of the ramp which in the Eastern Interconnection is based on the standard ramp of 10 minutes that straddles across the block-schedule start ( eg begin ramping at 0055 and complete ramping at 0105) Changes that impact this timing will need to be accounted for in modifications to the associated INT Reliability Standards ( ie INT-005 and INT-008) and will result in significant changes in the way in which operators currently process such requests As a result of this fairly tight advance notice time frame for processing schedule changes any change to the existing 20-minute prior notice evaluation period for schedules should be undertaken with caution The Commission also requested comments regarding any changes that might be necessary in hardware software or personnel As indicated above NERC is informed that transmission providers offering and executing on 15 minute scheduling would require changes (some substantial) to existing tools and processes used to perform scheduling and curtailment activities For example the Interchange Distribution Calculator a tool which is used in the Eastern Interconnection to manage congestion generally operates on an hourly basis as does the Western Interconnections WebSAS tool In addition wide-spread intra-hour scheduling may require system operators to adopt increasingly automated processes as significant aspects of existing processes ( ie check out) are often performed manually The need to account for shorter-term schedules combined with the potential increase in volume of transactions processed would in some instances require changes to both hardware and software NERC believes such analysis would need to be performed subsequent to the issuance of a Final Rule (so the requirements are known) but before implementation becomes mandatory While NERC does not have personnel that would be directly impacted by the proposed change NERC believes that entities that review and implement schedule requests would likely see their personnel needs increase Such entities would also likely see increased demands on their software and hardware associated with processing schedule requests b NERC Definition of Variable Energy Resource In the NOPR FERC proposed to define a VER as ldquoenergy source that (1) is renewable (2) cannot be stored by the facility owner or operator and (3) has variability that is beyond the control of the facility owner or operatorrdquo[footnoteRef12] Noting that this definition is consistent with NERCrsquos characterization of variable generation the Commission sought comment on the proposed VER definition NERC supports the VER definition proposed by the Commission and believes it is sufficient [12 NOPR at P 64 (citing NERC Accommodating High Levels of Variable Generation at 13-14 (2009) available at httpwwwnerccomfilesIVGTF_Report_041609pdf)] c Reliability Impacts from Use of Existing or New Ancillary Services to Address Extreme Ramp Events In the NOPR the Commission requested comments ldquoon the extent to which some additional type of contingency reserve service (beyond the services provided under Schedule 5 and 6 of the pro forma OATT) would ensure that VERs are integrated into the interstate transmission system in a non-discriminatory manner while remaining consistent with NERC Reliability Standardsrdquo[footnoteRef13] [13 NOPR at P 100] Large wind ramping events have characteristics that are both similar to and different than conventional generator contingency events They are similar in that the large events are large and infrequent They differ in that wind ramps are much slower than instantaneous contingency events and the extreme wind ramps may be possible to forecast Figure 1 below shows a large (1500 MW) wind ramp event that occurred in February 2007 in the Electric Reliability Council of Texas (ldquoERCOTrdquo) region While this event is large and can present a serious operational challenge it is a rare event occurring about once a year and it emerges slowly compared with a conventional generation contingency which happens essentially instantaneously Figure 1 ERCOT 2242007 wind event The use of contingency reserves is similar to what is used to address large infrequent wind ramps because contingency reserves are seldom deployed Typically contingency reserves are split between spinning and non-spinning For large ramps lasting several hours the ramp duration make it difficult to include wind ramps as actual contingencies Resource and Demand Balancing (BAL) Reliability Standard BAL-002 (Disturbance Control Performance) requires ACE to be restored 15 minutes following the disturbance (R4) and the contingency reserves to be restored within 105 minutes (90 minutes after the 15 minute disturbance recovery period ndash R6) Both of these requirements can be problematic for wind ramps since they can be longer than the disturbance recovery period as well as the reserve restoration period System operators typically restore reserves much faster (within approximately ten minutes following the disturbance recovery period) Therefore including two hour wind ramps as contingencies would also be problematic A further issue with a large long ramp is the point at which the event can be identified For example during the ERCOT event in the Figure 1 above a full 20 minutes into the event it may not be clear to the operator whether the wind power will continue declining or whether the ramp is (nearly) over This highlights the importance of an accurate wind forecast so that wind generators can schedule a reasonable forecast of their expected output Still it may be appropriate to use contingency reserves in response to a portion of a wind ramp Shared contingency reserves could be used to initiate the response allowing time for alternate supply (or load reduction) to be implemented The frequency of ramp events would need to be studied to determine which ramps are compatible with contingency reserve use The industry should consider developing rules governing reserve deployment and restoration similar to those that currently address conventional contingencies would also need to be developed Some entities are considering rules that will allow contingency reserves to be deployed to help manage large infrequent wind ramping events NERC believes that the industry should consider how best to deal with this incremental risk Specifically NERC believes that further analysis of how wind ramps can be recovered using contingency reserves should be undertaken as well as consideration of how wind generation can minimize the impacts of wind ramps through improved forecasting and market tools products and requirements The predictability duration magnitude and ramp rate of an event are all important factors that are used in determining how reserves for these events should be held If Balancing Authorities can predict an occurring event and to some degree know the duration magnitude and ramp rate of a future event they can use that information to ensure that the correct reserve is ready to be deployed This type of analysis could potentially be done with historic data that demonstrates the characteristics of the wind regime of the particular balancing area (as shown in the Figure 1) With improved forecasting systems real-time forecast information should also be used to assist in determining what reserve requirements to hold for such events V CONCLUSION NERC is pleased to provide these comments in response to the Commissionrsquos NOPR and looks forward to working with the Commission to ensure the successful integration of VERs while maintaining the reliability of the bulk power system Respectfully submitted 6 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing document upon all parties listed on the official service list compiled by the Secretary in this proceeding Dated at Washington DC this 2nd day of March 2011 s Willie L Phillips Willie L Phillips Attorney for North American Electric Reliability Corporation Integration of Variable Energy Resources NERC has posted a draft letter to the Planning and Operating Committees identifying threeareas of FERCrsquos Notice to which it intends to provide comments (httpwwwnerccomfilezpchtml) In this letter NERC providesdirectional reliability considerations and seeks input from the Planning and Operating Committee members In addition to the Operating and Planning Committees NERC plans to seek detailed input from the Integration of the Variable ResourcesTask Force (IVGTF) Before filing NERC staffrsquos draft comments will be sent for your final consideration Please submit your comments to assessmentsnercnet by Monday December 20 2010 Chrissy VegsoNorth American Electric Reliability Corporation 116-390 Village BlvdPrinceton NJ 08540 6094528060 | wwwnerccomchrissyvegsonercnet ---You are currently subscribed to pc_plus as pfedoranpccorgTo unsubscribe send a blank email to leave-1249359-159822efb8cca4334e86463d80bb177caa7b75listservnerccom UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION INTEGRATION OF VARIABLE ) Docket No RM10-11-000 ENERGY RESOURCES ) COMMENTS OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION IN RESPONSE TO THE FEDERAL ENERGY REGULATORY COMMISSIONrsquoS NOVEMBER 18 2010 NOTICE OF PROPOSED RULEMAKING ON THE INTEGRATION OF VARIABLE ENERGY RESOURCES Gerald W Cauley President and Chief Executive Officer David N Cook Sr Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton NJ 08540-5721 (609) 452-8060 (609) 452-9550 ndash facsimile davidcooknercnet Holly A Hawkins Attorney Willie L Phillips Attorney North American Electric Reliability Corporation 1120 G Street NW Suite 990 Washington DC 20005-3801 (202) 393-3998 (202) 393-3955 ndash facsimile hollyhawkinsnercnet williephillipsnercnet March 2 2011 TABLE OF CONTENTS I INTRODUCTION 1 II NOTICES AND COMMUNICATIONS 2 III BACKGROUND 2 IV DISCUSSION 3 a Inconsistency with Reliability Standards b NERC Definition of Variable Energy Resource c Reliability Impacts from Use of Existing or New Ancillary Services to Address Extreme Ramp Events V CONCLUSION 1 I The North American Electric Reliability Corporation (ldquoNERCrdquo) is pleased to provide these comments in response to the Federal Energy Regulatory Commissionrsquos (ldquoFERCrdquo or the ldquoCommissionrdquo) November 18 2010 Notice of Proposed Rulemaking (ldquoNOPRrdquo) on the Integration of Variable Energy Resources (ldquoVERsrdquo) INTRODUCTION 1 In the NOPR FERC proposes to ldquoreform the pro forma Open Access Transmission Tariff to remove unduly discriminatory practices and to ensure just and reasonable rates for Commission-jurisdictional servicesrdquo2 NERCrsquos mission as the FERC-designated Electric Reliability Organization (ldquoEROrdquo) 3 is to ensure the reliability of the bulk power system in North America by in part developing and enforcing mandatory Reliability Standards NERCrsquos reliability mandate under section 215 of the Federal Power Act does not include authority to monitor and enforce market-based issues4 Accordingly NERCrsquos comments herein focus on three separate areas related to the impact of the Integration of VERs on Reliability 1 Integration of Variable Energy Resources 133 FERC para61149 (November 18 2010)(ldquoNOPRrdquo) 2 NOPR at p 1 3 See North American Electric Reliability Corporation ldquoOrder Certifying North American Electric Reliability Corporation as the Electric Reliability Organization and Ordering Compliance Filingrdquo 116 FERC para 61062 (July 20 2006) 4 See Mandatory Reliability Standards for the Calculation of Available Transfer Capability Capacity Benefit Margins Transmission Reliability Margins Total Transfer Capability and Existing Transmission Commitments and Mandatory Reliability Standards for the Bulk-Power System Order No 729 129 FERC para 61155 at P 109 (2009) 2 II Notices and communications with respect to this filing may be addressed to the following NOTICES AND COMMUNICATIONS Gerald W Cauley President and Chief Executive Officer David N Cook Sr Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton NJ 08540-5721 (609) 452-8060 (609) 452-9550 ndash facsimile davidcooknercnet Persons to be included on FERCrsquos service list are indicated with an asterisk NERC requests waiver of FERCrsquos rules and regulations to permit the inclusion of more than two people on the service list Holly A Hawkins Attorney Willie L Phillips Attorney North American Electric Reliability Corporation 1120 G Street NW Suite 990 Washington DC 20005-3801 (202) 393-3998 (202) 393-3955 ndash facsimile hollyhawkinsnercnet williephillipsnercnet III BACKGROUND On January 21 2010 FERC issued a Notice of Inquiry (ldquoNOIrdquo) on the Integration of Variable Energy Resources5 5 Integration of Variable Energy Resources 130 FERC para 61053 (January 21 2010) (ldquoNOIrdquo) In the NOI FERC sought comment on the extent to which barriers may exist that impede the reliable and efficient integration of VERs into the electric grid and whether reforms are needed to eliminate those barriers A 60-day comment period was set for interested parties to provide input NERC submitted comments in response to the NOI on April 3 12 20106 NERCrsquos comments provided responses that focused on the reliability impacts of integrating VERs into the grid and NERCrsquos ongoing efforts to address reliability considerations On November 18 2010 FERC issued its NOPR regarding the Integration of VERs in which it proposed to reform the pro forma Open Access Transmission Tariff to remove unduly discriminatory practices and to ensure just and reasonable rates for Commission-jurisdictional services7 By this filing NERC provides comments in response to the NOPR IV In formulating its response to the NOPR NERC sought input from industry stakeholders the NERC Operating Committee NERC Planning Committee and the Integration of Variable Resources Task Force (ldquoIVGTFrdquo) To this end NERC posted to its website a letter addressed to its Planning and Operating Committees titled NERCrsquos Directional Topics Addressing NERCrsquos Response to FERCrsquos Notice of Proposed Rulemaking on Integration of Variable Energy Resources DISCUSSION 8 a Inconsistency with NERC Reliability Standards In this posting NERC provided reliability considerations and sought input from the committee members on the three separate areas relating to the integration of VERs discussed below In the NOPR the Commission proposed ldquoto amend sections 138 and 146 of the pro forma OATT to provide transmission customers the option to schedule transmission service on 6 See Comments Of The North American Electric Reliability Corporation In Response To The Federal Energy Regulatory Commissionrsquos January 21 2010 Notice Of Inquiry On The Integration Of Variable Energy Resources Docket No RM10-11-000 (April 12 2010) 7 ldquoIntegration of Variable Energy Resourcesrdquo 133 FERC para 61149 (Nov 18 2010) (ldquoNOPRrdquo) 8 httpwwwnerccomfilezpchtml 4 an intra-hour basis at intervals of 15 minutesrdquo9 In response to the Commissionrsquos request for comment NERC worked with industry stakeholders to perform a preliminary review of its Reliability Standards NERC has not identified any insurmountable hurdles that would prevent the industry from providing intra-hour scheduling flexibility NERC notes that certain entities currently offer various forms of scheduling on a 15-minutes basis and to date NERC is not aware of this causing any conflicts with NERCrsquos Reliability Standards Noting that the proposed 15-minute interval was ldquoconsistent with the ideal time increments (ie 5 to 15 minutes) recommended by NERCrdquo the Commission requested comment on whether there was any inconsistency among relevant NERC Reliability Standards and the proposed intra-hour scheduling tariff reform Yet NERC acknowledges that making a 15-minute scheduling interval more routine including (critically) for inter-Balancing Area (BA) transactions would likely require review and refinements to several existing Reliability Standards10 9 NOPR at P 37 In particular there would likely be a need for changes to NERCrsquos Interchange Scheduling and Maintenance Coordination (INT) Reliability Standards which were largely written based on the assumption that many schedules will be on an hourly basis To the extent that this assumption has resulted in wording that is consistent with an hourly regime interpretations or modifications to the INT Reliability Standards would likely be required While it is expected that only minor wording changes to affected standards may be necessary adopting interconnection-wide intra-hour scheduling could have a substantial impact on practices and tools used by transmission operators to maintain 10 See eg NERC Reliability Standards BAL-005 R121 (Automatic Generation Control) BAL-006 R1 (Inadvertent Interchange) EOP-008 (Plans for Loss of Control Center Functionality) INT-001 R11 (Interchange Information) INT-004-2 (Dynamic Interchange Transaction Modifications) INT-005-003 (Interchange Authority Distributes Arranged Interchange) INT-006-3 (Response to Interchange Authority) INT-008 R1 (Interchange Authority Distributes Status) 5 reliable operations Time and attention to the details (regarding impacts and changes to Reliability Standards practices and tools) would be required but a transition to more widespread use of intra-hour scheduling flexibility is achievable in a reasonable time frame However it should be noted that all creation and modification of Reliability Standards must be considered as part of the NERC Reliability Standards Committee prioritization process This prioritization process considers the regulatory reliability and logistical issues associated with projects to create or modify NERC standards and helps determine the manner in which industry resources and NERC staff are deployed to create or modify Reliability Standards Additionally such changes must be developed in accordance with the steps outlined in the NERC Standards Process Manual which ensures an open and inclusive process through adherence to the standards development principles of the American National Standards Institute In the NOPR the Commission proposed to ldquoallow all transmission customers the option of submitting intra-hour schedules up to 15 minutes before the scheduling intervalrdquo11 bull communication time will be required as the request is transmitted received and processed NERC notes that the INT Reliability Standards have been written so that nearly all schedules are received at least 20 minutes ahead of the block-schedule start This 20-minute period was set to provide the operator sufficient time to evaluate approve and implement the schedule request For example if an Eastern Interconnection schedule request is submitted at 0040 for a schedule that starts at 0100 then industry actions may include bull the entities reviewing the request will require sufficient time to evaluate the request 11 NOPR at 41 6 bull communication time will be required to verify that all entities have agreed to implement the requested schedule and coordinate that agreement between all entities and bull entities will need time to input the request into their scheduling systems When combined the required time is at least 15 minutes (0055) to perform these tasks with the remaining time allowing for the initiation of the ramp which in the Eastern Interconnection is based on the standard ramp of 10 minutes that straddles across the block-schedule start (eg begin ramping at 0055 and complete ramping at 0105) Changes that impact this timing will need to be accounted for in modifications to the associated INT Reliability Standards (ie INT- 005 and INT-008) and will result in significant changes in the way in which operators currently process such requests As a result of this fairly tight advance notice time frame for processing schedule changes any change to the existing 20-minute prior notice evaluation period for schedules should be undertaken with caution The Commission also requested comments regarding any changes that might be necessary in hardware software or personnel As indicated above NERC is informed that transmission providers offering and executing on 15 minute scheduling would require changes (some substantial) to existing tools and processes used to perform scheduling and curtailment activities For example the Interchange Distribution Calculator a tool which is used in the Eastern Interconnection to manage congestion generally operates on an hourly basis as does the Western Interconnections WebSAS tool In addition wide-spread intra-hour scheduling may require system operators to adopt increasingly automated processes as significant aspects of existing processes (ie check out) are often performed manually The need to account for shorter-term schedules combined with the potential increase in volume of transactions 7 processed would in some instances require changes to both hardware and software NERC believes such analysis would need to be performed subsequent to the issuance of a Final Rule (so the requirements are known) but before implementation becomes mandatory While NERC does not have personnel that would be directly impacted by the proposed change NERC believes that entities that review and implement schedule requests would likely see their personnel needs increase Such entities would also likely see increased demands on their software and hardware associated with processing schedule requests b NERC Definition of Variable Energy Resource In the NOPR FERC proposed to define a VER as ldquoenergy source that (1) is renewable (2) cannot be stored by the facility owner or operator and (3) has variability that is beyond the control of the facility owner or operatorrdquo12 c Reliability Impacts from Use of Existing or New Ancillary Services to Address Extreme Ramp Events Noting that this definition is consistent with NERCrsquos characterization of variable generation the Commission sought comment on the proposed VER definition NERC supports the VER definition proposed by the Commission and believes it is sufficient In the NOPR the Commission requested comments ldquoon the extent to which some additional type of contingency reserve service (beyond the services provided under Schedule 5 and 6 of the 12 NOPR at P 64 (citing NERC Accommodating High Levels of Variable Generation at 13-14 (2009) available at httpwwwnerccomfilesIVGTF_Report_041609pdf) 8 pro forma OATT) would ensure that VERs are integrated into the interstate transmission system in a non-discriminatory manner while remaining consistent with NERC Reliability Standardsrdquo13 Large wind ramping events have characteristics that are both similar to and different than conventional generator contingency events They are similar in that the large events are large and infrequent They differ in that wind ramps are much slower than instantaneous contingency events and the extreme wind ramps may be possible to forecast Figure 1 below shows a large (1500 MW) wind ramp event that occurred in February 2007 in the Electric Reliability Council of Texas (ldquoERCOTrdquo) region While this event is large and can present a serious operational challenge it is a rare event occurring about once a year and it emerges slowly compared with a conventional generation contingency which happens essentially instantaneously Figure 1 ERCOT 2242007 wind event The use of contingency reserves is similar to what is used to address large infrequent wind ramps because contingency reserves are seldom deployed Typically contingency reserves are split between spinning and non-spinning For large ramps lasting several hours the ramp 13 NOPR at P 100 9 duration make it difficult to include wind ramps as actual contingencies Resource and Demand Balancing (BAL) Reliability Standard BAL-002 (Disturbance Control Performance) requires ACE to be restored 15 minutes following the disturbance (R4) and the contingency reserves to be restored within 105 minutes (90 minutes after the 15 minute disturbance recovery period ndash R6) Both of these requirements can be problematic for wind ramps since they can be longer than the disturbance recovery period as well as the reserve restoration period System operators typically restore reserves much faster (within approximately ten minutes following the disturbance recovery period) Therefore including two hour wind ramps as contingencies would also be problematic A further issue with a large long ramp is the point at which the event can be identified For example during the ERCOT event in the Figure 1 above a full 20 minutes into the event it may not be clear to the operator whether the wind power will continue declining or whether the ramp is (nearly) over This highlights the importance of an accurate wind forecast so that wind generators can schedule a reasonable forecast of their expected output Still it may be appropriate to use contingency reserves in response to a portion of a wind ramp Shared contingency reserves could be used to initiate the response allowing time for alternate supply (or load reduction) to be implemented The frequency of ramp events would need to be studied to determine which ramps are compatible with contingency reserve use The industry should consider developing rules governing reserve deployment and restoration similar to those that currently address conventional contingencies would also need to be developed Some entities are considering rules that will allow contingency reserves to be deployed to help manage large infrequent wind ramping events NERC believes that the industry should consider how best to deal with this incremental risk Specifically NERC believes that further 10 analysis of how wind ramps can be recovered using contingency reserves should be undertaken as well as consideration of how wind generation can minimize the impacts of wind ramps through improved forecasting and market tools products and requirements The predictability duration magnitude and ramp rate of an event are all important factors that are used in determining how reserves for these events should be held If Balancing Authorities can predict an occurring event and to some degree know the duration magnitude and ramp rate of a future event they can use that information to ensure that the correct reserve is ready to be deployed This type of analysis could potentially be done with historic data that demonstrates the characteristics of the wind regime of the particular balancing area (as shown in the Figure 1) With improved forecasting systems real-time forecast information should also be used to assist in determining what reserve requirements to hold for such events V CONCLUSION NERC is pleased to provide these comments in response to the Commissionrsquos NOPR and looks forward to working with the Commission to ensure the successful integration of VERs while maintaining the reliability of the bulk power system Respectfully submitted Gerald W Cauley President and Chief Executive Officer David N Cook Sr Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton NJ 08540-5721 (609) 452-8060 (609) 452-9550 ndash facsimile davidcooknercnet s Willie L Phillips Holly A Hawkins Attorney Willie L Phillips Attorney North American Electric Reliability Corporation 1120 G Street NW Suite 990 Washington DC 20005-3801 (202) 393-3998 11 (202) 393-3955 ndash facsimile hollyhawkinsnercnet williephillipsnercnet CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing document upon all parties listed on the official service list compiled by the Secretary in this proceeding Dated at Washington DC this 2nd day of March 2011 s Willie L Phillips Willie L Phillips Attorney for North American Electric Reliability Corporation Critical Energy Infrastructure Information Has Been Redacted From This Public Version February 28 2011 VIA ELECTRONIC FILING Ms Kimberly D Bose Secretary Federal Energy Regulatory Commission 888 First Street NE Washington DC 20426 Re North American Electric Reliability Corporation Docket No RM06-16-000 Dear Ms Bose The North American Electric Reliability Corporation (ldquoNERCrdquo) hereby submits this filing in compliance with Paragraph 629 of the Federal Energy Regulatory Commissionrsquos (ldquoFERCrdquo) Order No 693 Order No 693 requires that NERC provide a quarterly informational filing regarding the timeframe to restore power to the auxiliary power systems of US nuclear power plants following a blackout as determined during simulations and drills of system restoration plans This filing contains the referenced material pertaining to the fourth quarter of 2010 NERC also submits a request to terminate its obligation to file quarterly informational filings as required by Paragraph 629 of Order No 693 on the basis that NERC has fulfilled the intent of the directive With the implementation of the NUC-001-2 standard that was approved by FERC on April 1 2010 more explicit requirements are now in place to address the off-site power concerns expressed by the NRC Accordingly as explained in more detail herein the 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version express purpose of this data request that is the subject of these quarterly filings has been superseded and the Commissionrsquos directives have been addressed NERCrsquos filing consists of the following bull This transmittal letter bull A table of contents for the entire filing bull A narrative description summarizing the data collected bull Official Data Request to Fulfill FERC Order No 693 Requirements Restoration of Nuclear Power Plant Off-site Power Sources (Exhibit A) and bull Restoration of Nuclear Power Plant Off-site Power Sources Data 4th Quarter 2010 (Exhibit B) Please contact the undersigned if you have any questions Respectfully submitted Holly Hawkins s Holly Hawkins Attorney for North American Electric Reliability Corporation 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION MANDATORY RELIABILITY STANDARDS ) Docket No RM06-16-000 FOR THE BULK POWER SYSTEM ) FOURTH QUARTER 2010 COMPLIANCE FILING OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION IN RESPONSE TO PARAGRAPH 629 OF ORDER No 693 AND REQUEST TO TERMINATE COMPLIANCE FILING OBLIGATION Gerald W Cauley President and Chief Executive Officer David N Cook Senior Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton NJ 08540-5721 (609) 452-8060 (609) 452-9550 ndash facsimile davidcooknercnet Holly A Hawkins Assistant General Counsel for Standards and Critical Infrastructure Protection North American Electric Reliability Corporation 1120 G Street NW Suite 990 Washington DC 20005-3801 (202) 393-3998 (202) 393-3955 ndash facsimile hollyhawkinsnercnet February 28 2011 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version TABLE OF CONTENTS I Introduction 1 II Notices and Communications 2 III Summary of Restoration of Nuclear Power Plant Off-site Power Sources Data 2 IV Request to Terminate Data Collection Exercise 9 V Conclusion 13 EXHIBIT A ndash Official Data Request to Fulfill FERC Order No 693 Requirements Restoration of Nuclear Power Plant Off-site Sources EXHIBIT B ndash Restoration of Nuclear Power Plant Off-site Power Sources Data 4th Quarter 2010 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION MANDATORY RELIABILITY STANDARDS ) Docket No RM06-16-000 FOR THE BULK POWER SYSTEM ) FOURTH QUARTER 2010 COMPLIANCE FILING OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION IN RESPONSE TO PARAGRAPH 629 OF ORDER No 693 AND REQUEST TO TERMINATE COMPLIANCE FILING OBLIGATION I In its March 16 2007 Order INTRODUCTION 1 1 Mandatory Reliability Standards for the Bulk-Power System 118 FERC para 61218 FERC Stats amp Regs para 31242 (2007) (Order No 693) Order on rehrsquog Mandatory Reliability Standards for the Bulk-Power System 120 FERC para 61053 (Order No 693-A) (2007) the Federal Energy Regulatory Commission (ldquoFERCrdquo) directed the North American Reliability Corporation (ldquoNERCrdquo) to provide a quarterly informational filing regarding the timeframe to restore power to the auxiliary power systems of US nuclear power plants following a blackout as determined during simulations and drills of system restoration plans This filing includes information for the fourth quarter of 2010 This filing also includes an explanation regarding why the data collection exercise directed by FERC in Order No 693 is no longer necessary with the implementation of the NUC-001-2 standard and the proposed EOP-005-2 standard Given that the goal of the directive has been fulfilled continuing this reporting diverts precious stakeholder regional entity and ERO resources from other activities 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 2 II Notices and communications with respect to this filing may be addressed to the following NOTICES AND COMMUNICATIONS Gerald W Cauley President and Chief Executive Officer David N Cook Senior Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton NJ 08540-5721 (609) 452-8060 (609) 452-9550 ndash facsimile davidcooknercnet Persons to be included on the FERCrsquos service list are indicated with an asterisk Holly A Hawkins Assistant General Counsel for Standards and Critical Infrastructure Protection North American Electric Reliability Corporation 1120 G Street NW Suite 990 Washington DC 20005-3801 (202) 393-3998 (202) 393-3955 ndash facsimile hollyhawkinsnercnet III SUMMARY OF RESTORATION OF NUCLEAR POWER PLANT OFF-SITE POWER SOURCES DATA Background In response to comments offered by the US Nuclear Regulatory Commission during the Notice of Proposed Rulemaking process FERC expressed in Order No 693 its concern regarding the role and priority that nuclear power plants should have in bulk power system restoration plans FERC addressed the concern in the discussion of the EOP-005-1 mdash System Restoration Plans Reliability Standard Specifically in Paragraph 629 of Order No 693 FERC directed NERC as follows 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 3 In addition the [FERC] directs the ERO to gather data pursuant to sect395(f) of the [FERCrsquos] regulations from simulations and drills of system restoration on the time it takes to restore power to the auxiliary power systems of nuclear power plants under its data gathering authority and report that information to [FERC] on a quarterly basis EOP-005-1 Requirement R11 and sub-requirement R114 identify the expected priority for restoring off-site power to nuclear stations They state R11 Following a disturbance in which one or more areas of the Bulk Electric System become isolated or blacked out the affected Transmission Operators and Balancing Authorities shall begin immediately to return the Bulk Electric System to normal R114 The affected Transmission Operators shall give high priority to restoration of off-site power to nuclear stations Importantly while the requirement provides the instruction to give high priority to off-site power restoration it does not specify target timeframes NERC in its role as the Electric Reliability Organization (ldquoEROrdquo) and in accordance with 18 CFR sect 392(d) is required to provide information as necessary to FERC in order to implement section 215 of the Federal Power Act As such users owners and operators of the bulk power system are required to provide the ERO with information in support of this same objective To collect the data necessary to respond to the FERC directive for nuclear power plant off-site power source data NERC issued a data request process that was at that time drafted as a proposed rule of procedure This procedure required NERC to post a proposed ERO data request for industry comment followed by NERC Board of Trustees approval before issuing it as a formal data request2 2 FERC has since approved Section 1600 of the Rules of Procedure known as the Data Rule which establishes the process for issuing ERO data requests NERC posted the ldquonuclear data requestrdquo for a 30-day industry comment period that began on June 26 2007 NERC 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 4 reviewed the comments received and presented a final version of the data request that was adopted by the NERC Board of Trustees at its August 2 2007 meeting The data presented in Exhibit B to this filing contains critical energy infrastructure information Specifically the information set forth in Exhibit B to the instant filing includes critical energy infrastructure information as defined by FERC Rules of Practice and Procedure (18 CFR Part 388) FERC Orders and NERC Rules of Procedure The information pertains to proprietary or business design information including design information related to vulnerabilities of critical energy infrastructure information that is not publicly available Accordingly the information set forth in Exhibit B has been redacted from the public filing In accordance with the FERC Rules of Practice and Procedure 18 CFR sect 388112 a non-public version of the information redacted from the public filing is being provided under separate cover NERC requests that the confidential non-public information be provided special treatment in accordance with the above regulation The ERO data request for nuclear power plant off-site power source restoration data as approved by the NERC Board of Trustees is found in Exhibit A Following Board of Trustees approval NERC began to collect nuclear data from US Transmission Operators during the fourth quarter 2007 and will continue to collect the data quarterly until otherwise directed by FERC This filing represents data captured for the fourth quarter of 2010 The specific data requested of the Transmission Operators requests the following information bull Reporting entity bull Name of exercise drill or simulation 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 5 bull Date of exercise drill or simulation bull Name of nuclear plant bull Unit designation (each unit must be included separately) bull Identifier of off-site power source bull Time duration when off-site power sources are lost to the restoration of first off-site power source (For this request the loss of off-site power sources is the simulated physical interruption of power in support of EOP-005-1 requirements) and bull Discussion of scenario assumptions or constraints impacting the restoration of the initial off-site power source to the nuclear power plant In addition the following clarifying language was included in the data request to guide the Transmission Operators when supplying the requested data Simulations drills or exercises that are implemented for individualized operator training requirements are not included in this request Simulations drills and exercises conducted to support the requirements of EOP-005-1 are included in this request This request is not intended to require additional simulations or studies to those conducted to satisfy EOP-005-1 requirements It is important to note that EOP-005 focuses on restoration plans and does not contain any requirement for restoration plans specific to nuclear plants Accordingly the reporting conducted under this data request so far will not result in a tabulation resulting in reports for each US nuclear plant Exhibit B presents the raw data collected through this period of observation As noted above for the public version of this report Exhibit B has been redacted to remove the actual raw data collected through the period of observation in accordance with the data survey and in recognition that the information requested constitutes confidential critical energy infrastructure information Specifically Exhibit B contains information that if released could identify system weaknesses and pose a risk of attack on existing infrastructure NERC respectfully requests that the critical energy infrastructure 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 6 information be protected consistent with national energy security objectives and in accordance with the cited regulation NERC has not analyzed this data to identify the impact of the reported off-site power source restoration times relative to the ability of the US nuclear power plants to remain in a mode that permits a timely return to service However NERC will utilize the information contained herein to ensure applicable entities are supporting their reliability standard obligations as defined in EOP-005-1 relative to the priority of off-site power source restoration to nuclear power plants in plans for system restoration Summary of Data There are a total of 104 nuclear units in the US Of these 44 were included in exercises drills or simulations in support of EOP-005-1 in the fourth quarter of 2010 Overall Transmission Operators conducted a total of 41 individual exercises drills or simulations during this period that included the restoration of off-site power sources to the 44 units with many events impacting more than one nuclear unit For example an entity conducted one system restoration exercise on October 12 2010 that involved the restoration of offsite power sources to a total of three nuclear units In the summary chart that follows below each offsite power source restoration ldquoeventrdquo is reported separately for purposes of data analysis In total one hundred twenty two (122) off-site power source restoration ldquoeventsrdquo are included in the raw data presented in Exhibit B of this filing 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 7 Of the one hundred twenty two (122) events there were ninety-four (94)3 NERC categorized the restoration of first off-site sources in two-hour windows Over eighty-eight (88) percent (83 of 94) of the initial off-site power source restorations occurred within the first six hours following the simulated blackout event with over forty-eight (48) percent (46 of 94) occurring in two hours or less Twenty-three (23) sources were simulated to be restored in the 2 to 4 hour window potential initial off-site source restorations (some units have multiple off-site sources) The remaining twenty-eight (28) events included in the data involved the restoration of a subsequent off-site source beyond the first source restored Of the twenty-eight (28) events one (1) subsequent source was simulated to be restored in less than 2 hours three (3) sources in the 2 to 4 hour window thirteen (13) sources were simulated to be restored in the 4 to 6 hour window three (3) sources were simulated to be restored in the 6 to 8 hour window eight (8) sources were simulated to be restored in the 8 to 10 hour window Total Number Offsite Power Source Restoration Events Included in EOP-005-1 Exercises Drills or Simulations 94 Potential first off-site source restorations 46 Exercises Drills or Simulations in which the first off-site source was restored in 2 hours or less following the loss of power 23 Exercises Drills or Simulations in which the first off-site source was restored 2-4 hours following the loss of power 14 Exercises Drills or Simulations in which the first off-site source was restored 4-6 hours following the loss of power 0 Exercises Drills or Simulations in which the first off-site source was restored 6-8 hours following the loss of power 0 3 Not all units provided data for off-site sources beyond the first source restored The data included represents only the units that provided the data and does not include the entire spectrum of off-site sources beyond the initial source for the rest of the units 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 8 Exercises Drills or Simulations in which the first off-site source was restored 8-10 hours following the loss of power 1 Exercises Drills or Simulations in which the first off-site source was restored more than 10 hours following the loss of power 10 Exercises Drills or Simulations that did not achieve the restoration of the first off-site power source to a nuclear power plant or that did not report a time for source restoration 0 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 9 IV REQUEST TO TERMINATE DATA COLLECTION EXERCISE NERC has collected data in support of the FERC request for twelve quarters Paragraph 625 of Order No 693 summarized the comments from the Nuclear Regulatory Commission (ldquoNRCrdquo) in response to the then-proposed EOP-005-1 Reliability Standard 625 NRC suggests that this Reliability Standard include (1) a requirement to record the time it takes to restore power to the auxiliary power systems of nuclear power plants (2) a provision stating that the affected transmission operators shall give high priority to restoration of off-site power to nuclear power plants whether or not a nuclear power plant is being powered from the nuclear power plantrsquos onsite power supply and (3) a provision stating that restoration shall not violate nuclear power plant minimum voltage and frequency requirements In response FERC noted in Paragraph 629 that 629 NRC raises several issues concerning the role and priority that nuclear power plants should have in system restorations The Commission shares these concerns and directs the ERO to consider the issues raised by NRC in future revisions of the Reliability Standard through the Reliability Standards development process In addition the Commission directs the ERO to gather data pursuant to sect 395(f) of the Commissionrsquos regulations from simulations and drills of system restoration on the time it takes to restore power to the auxiliary power systems of nuclear power plants under its data gathering authority and report that information to the Commission on a quarterly basis Since the issuance of FERCrsquos Order No 693 in March 2007 NERC has addressed the issues raised by the NRC in its development of the NUC-001-2 Reliability Standardmdash Nuclear Plant Interface Coordination that was approved by FERC on April 1 2010 The NUC-001-2 standard requires a Nuclear Plant Generator Operator to coordinate operations and planning with Transmission Entities providing services relating to nuclear plant operating and off-site power delivery requirements NUC-001-2 also requires Nuclear Plant Generator Operators and Transmission Entities to execute and 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 10 implement interface agreements setting forth expectations and procedures for coordinating operations to meet the nuclear plant licensing requirements and system operating limits affecting nuclear plant operations The Commissionrsquos specific concerns in Paragraph 629 of Order No 693 are addressed by the Requirements of the NUC-001-2 standard For example in Order No 693 the Commission directed NERC to gather data from simulations and drills of system restoration on the time it takes to restore power to the auxiliary power systems of nuclear power plants The currently-effective Requirement R922 of NUC-001-2 requires Nuclear Plant Generator Operators to identify facilities components and configuration restrictions that are essential for meeting the Nuclear Interface Plant Requirements (ldquoNPIRsrdquo) Requirement R934 includes provisions to address mitigating actions needed to avoid violating NPIRs and to address periods when responsible Transmission Entities lose the ability to assess the capability of the electric system to meet the NPIRs (emphasis added) These provisions also include the obligation to notify the Nuclear Plant Generator Operator of this information within a specified time frame Additionally Requirement R935 of NUC-001-2 includes provisions for considering within the restoration process the requirements and urgency of a nuclear plant that has lost all off-site and on-site AC power Requirement R4 provides that the applicable Transmission Entities shall incorporate the NPIRs into their operating analyses of the electric system operate the electric system to meet the NPIRs and inform the Nuclear Plant Generator Operator when the ability to assess the operation of the electric system affecting NPIRs is lost 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 11 The current data request that NERC issued in 2007 to begin collecting the data required by these quarterly compliance filings was limited to those instances where drills were conducted under EOP-005 Given the fact that a broader approach involving the establishment of NPIRs under the NUC-001-2 standard is now in place specifically to address the off-site power capability concerns of the NRC the Commissionrsquos concerns on this issue that were raised in Order No 693 have been addressed Similarly NERC filed EOP-005-2 mdash System Restoration from Blackstart Resources for FERC approval on December 31 2009 In it the Transmission Operator shall have a Reliability Coordinator-approved restoration plan that includes ldquo[a] description of how all Agreements or mutually agreed upon procedures or protocols for off-site power requirements of nuclear power plants including priority of restoration will be fulfilled during System restorationrdquo The Commission issued a Notice of Proposed Rulemaking on the System Restoration Reliability Standards which includes NERCrsquos proposed EOP-005-2 Reliability Standard on November 18 2010 (lsquoNovember 18 NOPRrdquo)4 In the November 18 NOPR FERC proposed to approve the EOP-005-2 standard stating that the proposed Reliability Standard effectively addresses the Commissionrsquos directive in Order No 693 to develop timeframes for training and review of restoration plan requirements to simulate contingencies and prepare operators for anticipated and unforeseen events5 On the basis that the more explicit requirements contained in the FERC-approved NUC-001-2 standard and the proposed EOP-005-2 standard are now either in place or NERC responded to the Commissionrsquos November 18 NOPR on January 24 2011 4 System Restoration Reliability Standards Notice of Proposed Rulemaking 133 FERCpara61161 (November 18 2010) 5 Id at P 19 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 12 awaiting FERC approval NERC submits that the express purpose of conducting the data request that is the subject of this filing has been superseded Considering this point and the significant level of effort for Transmission Operators to collect and forward the information to the Regional Entity the Regional Entityrsquos effort to accumulate and assemble the data and NERCrsquos efforts to combine the information into the filings that have been submitted NERC believes it is appropriate to redirect these resources to other reliability activities with greater impact on the reliability of the bulk power system and more efficient use of industry regional and ERO resources NERC therefore respectfully requests that FERC terminate NERCrsquos obligation to collect and file the data called for under this program 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version 13 IV NERC respectfully requests that FERC accept this informational filing for the fourth quarter of 2010 in accordance with FERCrsquos directive that NERC provide information regarding the time it takes to restore off-site power sources to nuclear power plants following a blackout as determined by drills and simulations Additionally NERC requests that FERC terminate the ongoing obligation to collect and file such data on the basis that new standards approved by FERC or pending FERC approval contain more explicit instructions regarding expectations of the Transmission Operators for restoring off-site power sources to nuclear power plants following a service interruption CONCLUSION Respectfully submitted Gerald W Cauley President and Chief Executive Officer David N Cook Senior Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton NJ 08540-5721 (609) 452-8060 (609) 452-9550 ndash facsimile davidcooknercnet s Holly Hawkins Holly A Hawkins Assistant General Counsel for Standards and Critical Infrastructure Protection North American Electric Reliability Corporation 1120 G Street NW Suite 990 Washington DC 20005-3801 (202) 393-3998 (202) 393-3955 ndash facsimile hollyhawkinsnercnet 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing document upon all parties listed on the official service list compiled by the Secretary in this proceeding Dated at Washington DC this 28th day of November 2010 Holly A Hawkins s Holly A Hawkins Attorney for North American Electric Reliability Corporation 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version Exhibit A Official Data Request to Fulfill FERC Order No 693 Requirements Restoration of Nuclear Power Plant Off-site Power Sources 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version August 24 2007 TRANSMISSION OPERATOR CONTACT TITLE COMPANY ADDRESS CITY STATE ZIP CODE (TNR 12pt) Dear XXXXX Official Data Request to Fulfill FERC Order No 693 Requirements Restoration of Nuclear Power Plant Off-site Power Sources Pursuant to the authority granted by FERC Order 672 and as implemented in Title 18 Section 392 of the Code of Federal Regulations NERC as the appointed electric reliability organization issues this official data request as described in Attachment 1 The legal basis in the United States for this authority is explained in FERCrsquos Order 672 paragraph 114 114 The Commission agrees with commenters that to fulfill its obligations under this Final Rule the ERO or a Regional Entity will need access to certain data from users owners and operators of the Bulk-Power System Further the Commission will need access to such information as is necessary to fulfill its oversight and enforcement roles under the statute Section 392 of the regulations will include the following requirement (d) Each user owner or operator of the Bulk-Power System within the United States (other than Alaska and Hawaii) shall provide the Commission the Electric Reliability Organization and the applicable Regional Entity such information as is necessary to implement section 215 of the Federal Power Act as determined by the Commission and set out in the Rules of the Electric Reliability Organization and each applicable Regional Entity The Electric Reliability Organization and each Regional Entity shall provide the Commission such information as is necessary to implement section 215 of the Federal Power Act Within the United States failure to comply with an official data request would constitute a violation of FERC regulations Enforcement action is available to FERC to deal with Gerry Adamski Vice President and Director of Standards 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version violations of its regulations This is authority FERC could exercise not authority available to NERC NERCrsquos Compliance Monitoring and Enforcement Program including the ability to impose penalties and sanctions is limited to violations of reliability standards Please note the following additional pieces of information relative to this data request bull An Excel spreadsheet (attached) to serve as a template for providing the requested information bull Regional entities are requested to submit the requested information to sarcommnercnet Thank you for your support of this effort Please contact me should you have any questions Sincerely Enclosure cc James D Castle Chairman Operating Reliability Subcommittee Regional Entity Management Group 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version Exhibit A Restoration of Nuclear Power Plant Offsite Power Source Data Request Background In paragraph 629 of Order No 693 FERC directs NERC to provide an informational filing regarding the timeframe to restore auxiliary power to nuclear power plants following a blackout as determined during simulations and drills of system restoration plans 629 ldquoIn addition the Commission directs the ERO to gather data pursuant to sect 395(f) of the Commissionrsquos regulations from simulations and drills of system restoration on the time it takes to restore power to the auxiliary power systems of nuclear power plants under its data gathering authority and report that information to the Commission on a quarterly basisrdquo Description of Data Requested This request is an ongoing request that begins in the fourth quarter of 2007 If an exercise drill or simulation includes the restoration of one or more offsite power sources to a nuclear power plant the following information is to be prepared and provided for each offsite power source in a format developed and provided by NERC bull Reporting entity bull Name of exercise drill or simulation bull Date of exercise drill or simulation bull Name of nuclear plant bull Unit designation (each unit must be included separately) bull Identifier of offsite power source bull Time duration when offsite power sources are lost to the restoration of first offsite power source (For this request the loss of offsite power sources is the simulated physical interruption of power in support of EOP-005-1 requirements) bull Discussion of scenario assumptions or constraints impacting the restoration of the initial offsite power source to the nuclear power plant Simulations drills or exercises that are implemented for individualized operator training requirements are not included in this request Simulations drills and exercises conducted to support the requirements of EOP-005-1 are included in this request This request is not intended to require additional simulations or studies to those conducted to satisfy EOP-005-1 requirements The individual data submissions should be submitted to the regional entity who will compile the data in a consolidated format The regional entity will then forward the complied data to NERCrsquos director of standards on a quarterly basis To comply with FERC directives NERC will make a quarterly filing with FERC that includes the compiled data 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version How the Data Will Be Used The data will be provided to FERC per its directive in Order 693 FERC agrees with issues raised by the Nuclear Regulatory Commission (NRC) concerning the role and priority nuclear power plants should have in system restorations and directs the collection of this data to aid in its review of this issue How the Data Will Be Collected and Validated The regional entities are requested to coordinate the collection and composite presentation of the requested data from its member participants Transmission operators responsive to this request are expected to validate the data to be correct prior to submittal Reporting Entities Each transmission operator in the United States who has a nuclear power plant tied to a transmission line that it controls and who is participating in an exercise drill or simulation in support of the EOP-005-1 standard will report Transmission operators that do not have a nuclear power plant tied to a transmission line it controls are exempt from this request Transmission operators outside the United States subject to EOP-005-1 are voluntarily encouraged to submit this information as well NERC will seek permission from these non-US entities for inclusion of its data in the information filed with FERC Due Date for the Information If a transmission operator subject to this data request conducts a drill simulation or exercise that includes restoration of the initial offsite power source to a nuclear power plant the transmission operator is to submit the requested information to its regional entity by the fifteenth of the month following the end of the previous three-month quarter The regional entity is to provide a quarterly report of all such submissions by April 30 July 31 October 31 and January 31 for the three-month period that concludes on these dates This data request begins in the fourth quarter of 2007 If no drill exercise or simulation meeting the criteria described above is conducted during a quarter no submission by the transmission operator and regional entity is required This data request does not direct transmission operators to conduct quarterly exercises drills or simulations to satisfy this data request It does require the data to be reported if such a simulation drill or exercise is conducted Restrictions on Disseminating Data (ConfidentialCEII) NERC will provide this data to FERC per its Order No 693 directives This information will be treated as critical energy infrastructure information when submitted to FERC Estimate on Burden Imposed to Collect Data There will be ongoing costs for the staff of responsible entities to respond and for regional entities to collect compile and report to NERC the requested data 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Critical Energy Infrastructure Information Has Been Redacted From This Public Version Exhibit B Restoration of Nuclear Power Plant Off-site Source Data 4th Quarter 2010 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM Document Content(s) Final_NUC_filing_DraftQ42010_20110228(PUBLIC)PDF1-24 20110228-5264 FERC PDF (Unofficial) 2282011 44800 PM From Guy V ZitoTo grpStaffSubject FW AnswerResponse to a PleadingMotion submitted in FERC RM06-16-000 by North American Electric Reliability Corporationet alDate Wednesday March 02 2011 95543 AM NERC had filed a motion to cease developing and submitting quarterly reports for the timeframe torestore auxiliary power to Nuclear units The submission states that with the new NUC-001-2 theprevious directives in Order 693 have been addressed I will keep staff informed as FERC rules on this Thanks Guy V ZitoAssistant Vice President-StandardsNortheast Power Coordinating Council Inc1040 Avenue of the Americas 10 th FloorNew York NY 10018212-840-1070212-302-2782 fax________________________________________From FERC eSubscription [eSubscriptionfercgov]Sent Tuesday March 01 2011 740 AMSubject AnswerResponse to a PleadingMotion submitted in FERC RM06-16-000 by North AmericanElectric Reliability Corporationet al On 2282011 the following Filing was submitted to the Federal Energy Regulatory Commission (FERC)Washington DC Filer North American Electric Reliability Corporation North American Electric Reliability Corp (as Agent) North American Electric Reliability Corporation North American Electric Reliability Corp (as Agent) Docket(s) RM06-16-000Filing Type AnswerResponse to a PleadingMotionDescription Fourth Quarter 2010 Compliance Filing of the North American Electric ReliabilityCorporation in Response to Paragraph 629 Of Order No 693 and Request to Terminate ComplianceFiling Obligation in Docket No RM06-16-000 To view the document for this Filing click herehttpelibraryFERCgovidmwsfile_listaspaccession_num=20110228-5264 To modify your subscriptions click here httpsferconlinefercgoveSubscriptionaspx ------------------------------------------------------------------------Please do not respond to this emailOnline help is available herehttpwwwfercgovefiling-helpaspor for phone support call 866-208-3676Comments and Suggestions can be sent to this email address mailtoFERCOnlineSupportFercgov From Guy V ZitoTo rscSubject FW Commission OrderOpinion issued in FERC RM06-22-014Date Thursday March 10 2011 73744 PMImportance High FYI Guy V ZitoAssistant Vice President-StandardsNortheast Power Coordinating Council Inc1040 Avenue of the Americas 10 th FloorNew York NY 10018212-840-1070212-302-2782 fax________________________________________From Guy V ZitoSent Thursday March 10 2011 726 PMTo grpStaffSubject FW Commission OrderOpinion issued in FERC RM06-22-014 To All FYI FERC dismisses the NERCs compliance filing regarding Implementation Plans and ldquoscope ofsystems determinationrdquo for Nuclear units The ldquoscope of systems determinationrdquo identifies whichsystems structures and components within the balance of plant at nuclear power facilities will besubject to NRCrsquos cyber security regulations and which will be subject to NERCrsquos CIP Standards This ispursuant to the MOU between the NRC and FERC NRCs cyber security rule covers the balance of plantof the Nuclear Units that was in question Thank-you Guy V ZitoAssistant Vice President-StandardsNortheast Power Coordinating Council Inc1040 Avenue of the Americas 10 th FloorNew York NY 10018212-840-1070212-302-2782 fax________________________________________From FERC eSubscription [eSubscriptionfercgov]Sent Thursday March 10 2011 606 PMSubject Commission OrderOpinion issued in FERC RM06-22-014 On 3102011 the Federal Energy Regulatory Commission (FERC) Washington DC issued thisdocument Docket(s) RM06-22-014Filing Type Commission OrderOpinionDescription Order dismissing compliance filing re Mandatory Reliability Standards for CriticalInfrastructure Protection under RM06-22 To view the document for this Issuance click herehttpelibraryFERCgovidmwsfile_listaspaccession_num=20110310-3042 To modify your subscriptions click here httpsferconlinefercgoveSubscriptionaspx ------------------------------------------------------------------------Please do not respond to this emailOnline help is available herehttpwwwfercgovefiling-helpaspor for phone support call 866-208-3676Comments and Suggestions can be sent to this email address mailtoFERCOnlineSupportFercgov 130 FERC para 61185 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners Jon Wellinghoff Chairman Marc Spitzer Philip D Moeller and John R Norris Mandatory Reliability Standards for Critical Infrastructure Protection Docket No RM06-22-011 ORDER ADDRESSING COMPLIANCE FILING AND APPROVING IMPLEMENTATION PLAN (Issued March 18 2010) 1 On January 19 2010 the North American Electric Reliability Corporation (NERC) submitted a compliance filing in response to the Commissionrsquos December 17 2009 order1 addressing NERCrsquos plan for the implementation of eight Critical Infrastructure Protection Reliability Standards CIP-002-1 through CIP-009-1 (CIP Standards) by generator owners and operators of nuclear power plants located in the United States (Implementation Plan) 2 In this order we accept NERCrsquos compliance filing and approve the Implementation Plan for nuclear power plant generator ownersrsquo and operatorsrsquo compliance with Version 1 of the CIP Standards to become effective on the date of this order In addition the Commission directs NERC to make a compliance filing submitting implementation plans for the implementation of Versions 2 and 3 of the CIP Standards by owners and operators of US nuclear power plants on the same schedule established for Version 1 under the Implementation Plan I Background 3 In Order No 706 the Commission approved Version 1 of the CIP Standards CIP-002-1 through CIP-009-12 The CIP Standards require certain users owners and (continuedhellip) 1 Mandatory Reliability Standards for Critical Infrastructure Protection 129 FERC para 61224 (2009) (December 17 Order) 2 Mandatory Reliability Standards for Critical Infrastructure Protection Order No 706 122 FERC para 61040 at P 86-90 order on rehrsquog Order No 706-A 123 FERC Docket No RM06-22-010 - 2 - operators of the Bulk-Power System to comply with specific requirements to safeguard critical cyber assets The Commission also directed NERC to develop certain modifications to the CIP Standards3 4 Each Version 1 CIP Standard provides that facilities regulated by the US Nuclear Regulatory Commission (NRC) are exempt from complying with the CIP Standard4 On March 19 2009 the Commission issued Order No 706-B clarifying that because the NRC regulations do not extend to all equipment within a nuclear power plant the CIP Standards apply to the ldquobalance of plantrdquo equipment within a nuclear power plant located in the United States that is not regulated by the NRC5 In Order No 706-B the Commission directed NERC to engage in a stakeholder process to develop a more appropriate timeframe for nuclear power plantsrsquo full compliance with the CIP Standards and to submit a compliance filing that sets forth a proposed implementation plan for nuclear power plants to comply with the CIP Standards6 5 On May 22 2009 NERC filed revised CIP Standards Version 2 in compliance with Order No 706 By order issued September 30 2009 the Commission approved the Version 2 CIP Standards to become effective on April 1 20107 The Commission clarified that the September 30 Order does not alter its findings in Order No 706-B regarding the applicability of the CIP Standards and associated implementation timetables to facilities located at nuclear power plants8 6 On September 15 2009 in compliance with Order No 706-B NERC filed the Implementation Plan for the implementation of Version 1 of the CIP Standards by generator owners and operators of nuclear power plants9 With the exception of CIP- para 61174 (2008) order on clarification Order No 706-B 126 FERC para 61229 (2009) 3 Order No 706 122 FERC para 61040 at P 25 4 Order No 706-B 126 FERC para 61229 at P 1 5 Id 6 Id P 60 7 North American Electric Reliability Corp 128 FERC para 61291 (2009) (September 30 Order) 8 Id P 13 9 NERC Sept 15 2009 Compliance Filing and Petition for Approval of Implementation Plan Docket No RM06-22-10 (NERC September 15 Petition) Docket No RM06-22-010 - 3 - 002-1 R1 and R210 the Implementation Plan is structured such that the timelinecompliance for each requirement within the CIP Standards is the later of (i) the Commission-approved effective date of the Implementation Plan (designated as ldquoRrdquo) plus 18 months (R + 18 months) (ii) the date the scope of systems determination is completed (designated as ldquoSrdquo) plus 10 months (S + 10 months) or (iii) if an outage is required for implementation six months following the completion of the first refueling outage at least 18 months following the Commissionrsquos effective date for 11 NERC stated that the ldquoscope of systems determinationrdquo includes establishing the NERC and NRC jurisdictional delineation for systems structures and components12 that is predicated upon the completion of a NERC-NRC memorandum of understanding as well as the creation of an exemption process for excluding certain systems structures and components from the scope of NERC CIP Standards as provided for in Order No 706-B13 7 By order issued on December 17 2009 the Commission requested that NERC submit additional information regarding the scope of systems determination to assist the Commissionrsquos evaluation of the Implementation Plan14 Specifically we directed NERC to provide the following information to help the Commission evaluate whether the Implementation Plan provides an appropriate schedule to make the CIP Standards mandatory and enforceable for generator owners and operators of US nuclear power plants the anticipated date the scope of systems determination framework will be finalized the status of the development of the exemption process 10 CIP-002-1 R1 and R2 pertain to the identification of critical assets which is a preliminary step for implementing of the remainder of the CIP Standards Accordingly the Implementation Plan calls for CIP-002-1 R1 and R2 to be completed within 12 months of the Commission-approved effective date of the Implementation Plan See NERC September 15 Petition at Exhibit A 3 11 Id at Exhibit A 2 12 The phrase ldquostructures systems and componentsrdquo refers to any element of equipment systems or networks of equipment or portions within a nuclear power plant within an entityrsquos ownership or control See Order No 706-B at P 15 13 See NERC Petition at Exhibit A 2 see also Order No 706-B at P 50 14 December 17 Order 129 FERC para 61224 at P 2 and 14 Docket No RM06-22-010 - 4 - whether the exemption process will include (i) an application deadline and (ii) a deadline for a determination on an exemption request and a description of any other time parameters that may be included in the exemption process15 In addition the Commission directed NERC to make a compliance filing incorporating into the Implementation Plan the implementation of Version 2 of the CIP Standards by nuclear power plants on the same schedule established for Version 116 II NERC Compliance Filing 8 In response to the Commissionrsquos information request NERCrsquos January 19 Compliance Filing explains its process for making the scope of systems determination and provides a project timeline for completing the scope of systems determination17 According to NERCrsquos Compliance Filing it will use a ldquoBright-Line Testrdquo to make its scope of systems determination18 The Bright-Line Test will identify which systems structures and components in a nuclear power plantrsquos balance of plant are subject to NERCrsquos CIP Standards and which are subject to the NRCrsquos jurisdiction In its Compliance Filing NERC reiterates its request that the Commission approve the Implementation Plan as it relates to the implementation of Version 1 of the CIP Standards with an immediate effective date 9 NERC stated in its September 15 2009 Petition that the scope of systems determination would be predicated upon the completion of a memorandum of understanding (MOU) between NERC and the NRC The MOU was executed on December 30 200919 The MOU sets forth and coordinates NERCrsquos and the NRCrsquos (continuedhellip) 15 Id P 14 16 Id P 15 17 NERC January 19 2010 Compliance Filing in Response to the Commissionrsquos December 17 2009 Order Addressing Compliance Filing and Requiring Further Compliance Filing (Compliance Filing) 18 NERCrsquos Compliance Filing appears to use the terms ldquoBright-Line Testrdquo ldquoBright-Line exemption processrdquo and ldquoBright-Line determinationrdquo interchangeably to refer to the ldquoexemption processrdquo NERC has developed to make its scope of systems determination 19 Compliance Filing at 6 NERC submitted a copy of the MOU as Exhibit 1 to Docket No RM06-22-010 - 5 - respective roles and responsibilities related to the application of each of their cyber security requirements20 Under the rubric of the MOU NERC and NRC are collaborating on the development of an ldquoin-scoperdquo system list to clarify which systems structures and components at nuclear power facilities will be subject to NRCrsquos security regulations and which will be subject to the CIP Reliability Stand 21 cyber ards 10 According to NERC to make the scope of systems determination using its Bright-Line Test NERC will follow a two part process First NERC will conduct workshops followed by the Bright-Line documentation process Specifically NERC states that it plans to conduct a series of regional workshops for nuclear plants licensed by the NRC (licensees) to facilitate the development of a Bright-Line Survey and to communicate expectations for licenseesrsquo completion of the Survey22 At the workshops NERC will present a preliminary Bright-Line Survey that the licensees will modify to the specifics of their respective facilities The Survey is intended to gather detailed information about each licenseersquos systems structures and components and will require the licensees to identify all systems structures and components with cyber assets Shortly after the workshops NERC will distribute the Bright-Line Survey to each licensee The completed surveys will be due back to NERC within 30 days Beginning in June or July of 2010 NERC will verify the survey results through facility site visits if necessary Once verified NERC and the NRC will use the survey results to make the scope of systems determination A Date the Scope of Systems Determination Framework Will Be Finalized 11 With respect to the anticipated date the scope of systems determination framework will be finalized NERC states that it plans to finalize the scope of systems determinations within 8 months of the date the Implementation Plan becomes effective (referred to by NERC as ldquoR + 8 monthsrdquo) This projected timeframe is based on the assumption that the effective date for the Implementation Plan will be April 1 2010 This timeline would ensure that there would be no significant gap between the compliance date linked to the Commission effective date (scenario (i) under the Implementation Plan R + 18) and the compliance deadline linked to the scope of systems the Compliance Filing 20 See MOU at I3 21 Compliance Filing at 6 22 Id at 7-8 Docket No RM06-22-010 - 6 - determination (scenario (ii) under the Implementation Plan S + 10) NERC further notes that the scope of systems determination may be later for entities with requirements tied to a specific plant outage B Status of the Development of the Exemption Process 12 In response to the Commissionrsquos question regarding the status of the development of the exemption process NERC states that the exemption process ie the Bright-Line Test started with the planning of the regional workshops NERCrsquos Bright-Line determination project timeline broken down by task is included with its Compliance Filing as Exhibit 2 C Whether the Exemption Process Includes Deadlines for Applications and Determinations 13 With regard to whether the exemption process will include an application deadline or a determination deadline NERC states that there will be a deadline for submitting ldquothe necessary informationrdquo presumably the Bright-Line Survey Based on NERCrsquos statement that ldquothe determination of a Licenseesrsquo scope of systems to be exempted from compliance with the NERC CIP Reliability Standards must be made no later than R + 8 monthsrdquo23 it appears that NERC intends to complete the exemption process within eight months of the Commission-approved effective date for the Implementation Plan According to NERC this timeframe will ensure that the compliance deadline for licensees subject to a scope of systems determination will track the standard compliance deadline ie R + 18 months D Other Time Parameters 14 In response to the question regarding any other time parameters that may be included in the exemption process NERC notes that its projected schedule is ldquocontingent upon NRC resourcesrdquo24 E Implementation of Version 2 and 3 of the CIP Standards 15 In response to the Commissionrsquos directive regarding the inclusion of the implementation of Version 2 of the CIP Standards into the Implementation Plan NERC requests permission to submit an additional compliance filing requesting Commission approval of the Version 2 and Version 3 implementation plans for US nuclear owners 23 Id at 9 24 Id at 9-10 Docket No RM06-22-010 - 7 - and operators after the plans have been balloted by the industry and approved by the NERC Board of Trustees NERC states that it is in the process of developing the CIP Version 2 and 3 implementation plans for nuclear facilities but could not complete the balloting process within the 30 day compliance deadline set by the December 17 Order NERC asserts that the deadline for US nuclear power plant ownersrsquo and operatorsrsquo compliance with the Version 2 and Version 3 CIP Standards will mirror the Implementation Plan for Version 1 of the CIP Standards as required by the December 17 Order25 In addition NERC states that it ldquowill include for all future filings of proposed new versions of the CIP-002 through CIP-009 standards an associated Implementation Plan that addresses US Nuclear Power Plant Owners and Operators compliance to the proposed requirementsrdquo26 III Notice and Responsive Pleadings 16 Notice of NERCrsquos Compliance Filing was published in the Federal Register with interventions and protests due on or before February 9 201027 On February 9 2010 Exelon Corporation (Exelon) filed comments 17 Exelon notes that NERCrsquos plan for completing the Bright-Line determination does not include a contingency for delays Thus Exelon is concerned with NERCrsquos assertion that ldquothe determination of a Licenseesrsquo scope of systems to be exempted from compliance with the NERC CIP Reliability Standards must be made no later then R + 8 monthsrdquo28 Exelon states that NERCrsquos ldquoformula R + 8 months may not give licensees the full time intendedrdquo to seek an exemption29 Exelon asserts that licensees must know what systems are subject to NERCrsquos jurisdiction before they can invoke NERCrsquos exemptions process to avoid dual regulation To resolve this issue Exelon requests that the Commission condition its approved effective date (R) on the actual date that the Bright-Line determination is finalized 18 Exelon raises two additional concerns First Exelon states that the Bright-Line determination may conflict with the NRCrsquos Critical Digital Asset assessment process noting that as the NRCrsquos Critical Digital Asset assessments progress ldquothe rationale for 25 Id at 11 26 Id at 10 27 75 Fed Reg 4374 (Jan 27 2010) 28 Exelon Comments (quoting Compliance Filing at 9) 29 Id Docket No RM06-22-010 - 8 - NERC exemptions may become more clearly definedrdquo30 To alleviate this concern Exelon requests that the Commission direct NERC either to consider the timing of the NRCrsquos Critical Digital Asset assessment process in its Bright-Line determination plan or to provide for an ongoing exemptions process in lieu of a finite completion date Second Exelon ldquorequests that NERC provide clear guidance on the scope of the proposed [Bright-Line] surveyrdquo and asks that the Commission direct NERC to extend the 30 day deadline for licensees to complete the survey31 IV Commission Determination 19 In the December 17 Order we stated that the ldquogeneral structure of the Implementation Plan comports with the directives in Order No 706-Brdquo32 However because the Implementation Plan is structured such that the compliance date is the later of three scenarios one of which is tied to the completion of NERCrsquos scope of systems determination absent information regarding NERCrsquos scope of systems determination the Commission could not determine whether the implementation timeline established an adequate degree of finality for compliance with the CIP Standards NERCrsquos January 19 2010 Compliance Filing provides a description of NERCrsquos process for determining the scope of systems that must comply with the NERC CIP Standards and those systems that fall under the NRCrsquos regulations The Commission is not reviewing NERCrsquos scope of systems determination process itself ie the Bright-Line Test as the Commission in Order No 706-B left it to the ERO to formulate and implement an ldquoexceptions processrdquo33 Rather the Commission is evaluating whether NERCrsquos exemption process the scope of systems determination will unduly delay the date the CIP Standards become mandatory and enforceable for nuclear power plant licensees 30 Id at 4 31 Id 32 December 17 Order 129 FERC para 61224 at P 14 33 Order No 706-B 126 FERC para 61229 at P 50 (holding that with respect to the delineation of which balance of plant equipment may be subject to the NRC cyber security regulation ldquo[t]he Commission believes that with the above two-part approach ie subjecting all balance of plant equipment within a nuclear power plant to the CIP Reliability Standards with exceptions allowed via a process implemented by the ERO nuclear power plant licensees will have a bright-line rule that eliminates the potential regulatory gap and provides certainty and a plant-specific equipment exception process to avoid dual regulation where appropriaterdquo) Docket No RM06-22-010 - 9 - 20 The Commission finds that NERCrsquos process for the scope of systems determination the Bright-Line Test along with NERCrsquos projected timeline for completing the Bright-Line Test provides for a final determination that will be made with a reasonable timeframe We note that while NERC states that it intends to finalize the scope of systems determination within eight months of the date the Implementation Plan becomes effective there remains the possibility that NERC will not meet that schedule NERC itself notes that the implementation schedule is ldquocontingent upon NRC resourcesrdquo34 For that reason the Commission remains concerned about potential delays in the compliance date Accordingly the Commission accepts NERCrsquos compliance filing and approves NERCrsquos Implementation Plan for US nuclear power plant ownersrsquo and operatorsrsquo compliance with Version 1 of the CIP Standards However should NERC become aware that it will be unable to complete the scope of systems determinations within NERCrsquos projected timeframe (R + 8 months) NERC must timely notify the Commission of the reason for the delay and propose an alternate deadline 21 Exelon requests that in recognition of the potential for delays in the scope of systems determination the Commission ldquocondition the effective date of its approval of NERCrsquos CIP Version 1 Implementation Plan for nuclear generator owners and operators based on the actual date that NERC and the NRC finalize the Bright-Line determinationrdquo35 The Commission finds that Exelonrsquos concern does not warrant action In the first instance NERC should meet the implementation schedule it has proposed and we approve in this order However as stated above NERC must notify the Commission give reason and propose an alternative deadline if it is unable to meet its projected timeframe of R + 8 months We believe this adequately resolves Exelonrsquos concern 22 Further Exelonrsquos request is unnecessary given the existing structure of the Implementation Plan As the Commission understands Exelonrsquos request Exelon wants the effective date of the Implementation Plan to be tied to the date NERC and the NRC complete the scope of systems determination The Implementation Plan is structured such that the compliance date is the latter of three scenarios one of which is tied to the date the scope of systems determination is completed Thus the CIP Standards will not become mandatory and enforceable against generator owners and operators of nuclear plants until at a minimum 10 months after the date NERC completes the scope of systems determination (designated as S + 10 months in the Implementation Plan) regardless of when the scope of systems determination is concluded Under this 34 Compliance Filing at 9-10 35 Exelon Comments at 4-5 Docket No RM06-22-010 - 10 - structure if NERCrsquos scope of systems determination (ie completion of the Bright-Line test) is delayed the compliance deadline will also be delayed In other words NERCrsquos projected timeframe of R + 8 months36 for completing the scope of systems determination does not affect the amount of time licensees will have to become compliantwith the CIP Standards 23 With respect to Exelonrsquos remaining concerns the Commission believes that they are beyond the scope of this order In this proceeding the Commission is ruling on the timeline of the proposed Implementation Plan and the adequacy by which it will ensure timely compliance with the CIP Standards The Commission has left the specific details of the development and implementation of the scope of systems determination to the discretion of the NRC and NERC 24 Last with respect to NERCrsquos request to submit after completion of its balloting process its compliance filing establishing implementation plans for Version 2 and Version 3 of the CIP Standards the Commission grants NERCrsquos request NERC is directed upon completion of its balloting process to make a compliance filing submitting implementation plans for the implementation of Versions 2 and 3 of the CIP Standards by owners and operators of US nuclear power plants on the same schedule established for Version 1 under the Implementation Plan The Commission orders (A) NERCrsquos compliance filing is hereby accepted as discussed in the body of this order (B) NERCrsquos Implementation Plan governing ownersrsquo and operatorsrsquo of US nuclear power plants implementation of Version 1 of the CIP Standards CIP-002-1 through CIP-009-1 is hereby approved as discussed in the body of this order effective as of the date of this order (C) NERC is hereby directed upon completion of its balloting process related to the implementation plans applicable to generator owners and operators of US nuclear power plants for Versions 2 and 3 of the CIP Standards to make a compliance filing submitting implementation plans for the implementation of Versions 2 and 3 of the CIP 36 ldquoRrdquo is the Commission-approved effective date of the Implementation Plan Docket No RM06-22-010 - 11 - Standards by owners and operators of US nuclear power plants on the same schedule established for Version 1 under the Implementation Plan as discussed in the body of this order By the Commission ( S E A L ) Kimberly D Bose Secretary 116-390 Village Blvd Princeton NJ 08540 6094528060 | wwwnerccom116-390 Village Boulevard Princeton New Jersey 08540-5721 Phone 6094528060 Fax 6094529550 wwwnerccom Standard Authorization Request Form Title of Proposed Standard Project 2009-02 Real-time Reliability Monitoring and Analysis Capabilities Original Request Date June 4 2009 Revised Date January 15 2010 Revised Date March 31 2010 SAR Requester Information SAR Type (Check a box for each one that applies) Name Jack Kerr New Standard(s) X Primary Contact Dominion Virginia Power Revision to existing Standard X Telephone 18042733393 Fax 18042732405 Withdrawal of existing Standard E-mail jackkerrdomcom Urgent Action Purpose (Describe what the standard action will achieve in support of bulk power system reliability) The new or revised standard(s) will establish requirements for the functionality performance and change managementmaintenance of Real-time Monitoring and Analysis capabilities for Reliability Coordinators Transmission Operators Generator Operators and Balancing Authorities for use by their System Operators in support of reliable System operations Standards Authorization Request Form SARndash2 Industry Need (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) According to the Final Report on the August 14 2003 Blackout in the United States and Canada Causes and Recommendations dated April 2004 a principal cause of the August 14 blackout was a lack of situational awareness which was in turn the result of inadequate reliability tools In addition the failure of control computers and alarm systems incomplete tool sets and the failure to supply network analysis tools with correct System data on August 14 contributed directly to this lack of situational awareness Also the need for improved visualization capabilities over a wide geographic area has been a recurrent theme in blackout investigations Recommendation 22 of the Blackout Report states ldquoEvaluate and adopt better real-time tools for operators and reliability coordinatorsrdquo NERCrsquos Operating Committee formed the Real-time Tools Best Practices Task Force (RTBPTF) to evaluate real-time tools and their usage within the industry The Task Force produced a report ldquoReal-Time Tools Survey Analysis and Recommendationsrdquo dated March 13 2008 that included recommendations for the functionality performance and management of Real-time tools There are 2 directives in FERC Order 693 relating to minimum tool capabilities that need to be addressed One directive pertains to IRO-002 and is described in paragraphs 905 amp 906 of Order 693 The second directive pertains to TOP-006 and is described in paragraph 1660 These directives clearly indicate the desire for a minimum set of capabilities as opposed to specific tools The existing projects that would have handled these issues (Project 2006-02 for IRO-002 and Project 2007-03 for TOP-006) have clearly indicated that they expect this SAR (Project 2009-02) to address the issues raised by FERC This SAR addresses selected recommendations in the RTBPTF Report as determined by the Real-time Best Practices Standards Study Group Project 2009-02 and addresses the directives in Order 693 referenced above Brief Description (Provide a paragraph that describes the scope of this standard action) The scope of the SAR is to establish requirements for the monitoring and analysis capabilities provided to System Operators and used to support Real-time System Operations The SAR addresses availability parameters performance metrics and procedures for failure notification maintenance coordination and change management The intent is to describe lsquowhatrsquo needs to be done but not lsquohowrsquo to do it Detailed Description (Provide a description of the proposed project with sufficient details for the standard drafting team to execute the SAR) Develop or revise standard(s) to describe the capability characteristics such as availability parameters performance metrics and procedures for failure notification and maintenance Standards Authorization Request Form SARndash3 coordination and change management (vetted by the industry through the Reliability Standards comment process)of functionality for bull bull Monitoring power System data in Real-time bull Exchanging power System data in Real-time bull Emitting Real-time visible and audible signals to aAlerting System Operators in Real-time to events and conditions affecting the state of the Bulk Electric System (BES) This functionality shall include an independent process monitor (eg watchdog) bull Determining the current state of the BES bullEvaluating the impact of lsquowhat ifrsquo events on the current or future state of the BES bull Standards Authorization Request Form SARndash4 Reliability Functions The Standard will Apply to the Following Functions (Check box for each one that applies) X Responsible for the real-time operating reliability of its Reliability Coordinator Area in coordination with its neighboring Reliability Coordinatorrsquos wide area view Reliability Coordinator X 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 gtone year plan for the resource adequacy of its specific loads within a Planning Coordinator area Transmission Planner Develops a gtone 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 (eg the pro forma tariff) Transmission Owner Owns and maintains transmission facilities X 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 X 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 Secures energy and transmission service (and reliability-related services) to serve the End-use Customer Load-Serving Entity Standards Authorization Request Form SARndash5 116-390 Village Blvd Princeton NJ 08540 6094528060 | wwwnerccom Reliability and Market Interface Principles Applicable Reliability Principles (Check box for all that apply) 1 X 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 X 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 X 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 X 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 X 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 1 (Select lsquoyesrsquo or lsquonorsquo from the drop-down box) 2 A reliability standard shall not give any market participant an unfair competitive advantage Yes 3 A reliability standard shall neither mandate nor prohibit any specific market structure Yes 4 A reliability standard shall not preclude market solutions to achieving compliance with that standard Yes 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 Standards Authorization Request 7 Related Standards Standard No Explanation TOP-xxx The TOP family of standards is undergoing revision The eventual SDT should have the flexibility to revise these standards or write new standards as best fits the task IRO-xxx The IRO family of standards is undergoing revision The eventual SDT should have the flexibility to revise these standards or write new standards as best fits the task COM-001-11 The eventual SDT should have the flexibility to revise this standard or write new standards as best fits the task BAL-xxx The BAL family of standards should be included in the scope of this SAR because they do address reliability-based data Therefore the eventual SDT should have the flexibility to revise these standards or write new standards as best fits the task Related SARs SAR ID Explanation Regional Variances Region Explanation ERCOT FRCC MRO NPCC SERC RFC SPP WECC Concept White Paper Concepts for Proposed Content of Eventual Standard(s) for Project 2009-02 Real-Time Monitoring and Analysis Capabilities Real-time Monitoring and Analysis Capabilities Standard Drafting Team February 15 2011 2 of 9 10 INTRODUCTION FERC Order 693 indicates the need for a minimum set of capabilities to be available for System Operators to assist in making Real-time decisions The work done by the Real-time Tools Best Practices Task Force (RTBPTF) which was formed by NERC in response to the Final Report on the August 14 2003 Blackout in the United States and Canada Causes and Recommendations is the basis for the Real-time Monitoring and Analysis Capabilities SAR that was approved by the Standards Committee in April 2010 and the subsequent appointment by NERC of a Standard Drafting Team (RMACSDT) to develop a standard to satisfy the proposed issues described in the SAR utilizing the results-based standards methodology This White Paper is a description of the present thinking of the RMACSDT regarding standard requirements for Real-time monitoring and analysis capabilities The paper consists of four sections that describe the major areas proposed to be addressed by the eventual standard(s) These areas are Section 2 - Monitoring Section 3 - Data exchange Section 4 - Alarming Section 5 ndash Analysis The SDT will also be crafting an Implementation Plan for any eventual standard(s) that will be vetted by the industry through comments and that will allow for sufficient time for applicable entities to bring their systems into compliance with any new requirements 20 MONITORING Monitoring is the first component in the process of establishing situational awareness for the System Operators so that they can rapidly assess the state of the Bulk Electric System (BES) In the context of this standard ldquomonitoringrdquo implies System Operators viewing data in a manner that allows them to determine the state of the BES in Real-time and to take corrective and preventive actions when necessary The types of data to be considered by the standard are Real-time analog and status o Scanned o Calculated For purposes of monitoring as described in this paper this is data scanned by a central system from Data Collection Units (DCU) such as Remote Terminal Units (RTUs) Calculated values are treated the same as scanned values in this paper It is proposed that requirements for monitoring will be applicable to Reliability Coordinators Transmission Operators and Balancing Authorities 3 of 9 The following requirements are proposed for monitoring of Real-time data These requirements assume that the Responsible Entity is utilizing an Energy Management System (EMS) andor Supervisory Control and Data Acquisition (SCADA) system to collect the Real-time data 21 PERFORMANCE A performance parameter is proposed for each category of data collected and the data displayed to the operator 211 Status Data Status data shall be collected at a scan rate not to exceed 4 seconds 212 Analog Data In many systems analog data is collected at multiple scan rates depending on the applications in which the data is being used It is proposed that all analog data except the data identified in the BAL standards is scanned at a rate not to exceed 10 seconds - the rate suggested in the RTBPTF report 213 Data Display All active displays utilized for visualization of the data discussed above shall update by the end of the next status or analog scan cycle as stated above following the scan in which the data was received by the central system For example status data should be updated within 4 seconds following the receipt of the scan by the central system 22 AVAILABILITY The SDT proposes two requirements for availability A demonstrable procedure shall be developed describing the alternate plans andor mitigating measures entities have in place when the data used to monitor BES or perform analyses on BES (see Section 5) becomes unavailable For each DCU availability shall be calculated by dividing the number of ldquogoodrdquo scans received at the central system by the number of scans scheduled to be received in a calendar month (A lsquogoodrsquo scan is a complete packet of requested data returned to the central system) The ratio of scans received to scans scheduled shall exceed 99 for a 4 of 9 calendar month This calculation can include alternate or backup data sources that provide data when the primary DCU is unavailable 23 FAILURE NOTIFICATION lsquoFailurersquo is assumed to occur when a scan is not completed for any reason and it shall be notified after the 9th consecutive lsquofailurersquo occurs The System Operator shall be notified of such failure within 60 seconds of the 9th consecutive lsquofailurersquo 24 MAINTENANCE Each Responsible Entity shall provide the System Operator with approval authority for planned maintenance that impact monitoring capabilities 30 DATA EXCHANGE Data exchange as discussed in this paper refers to electronic exchange of data between two computer based control systems (EMS andor SCADA) whether they are internal or external to each other It is assumed that the data links discussed will utilize ICCP or an equivalent protocol Data exchange in this context does not include RTUs or other similar types of DCUs Required data sets to be exchanged are covered in proposed IRO-010-2 and TOP-003-2 ICCP is the Inter-Control Center Communications Protocol (ICCP or IEC 60870-6TASE2 or latest release) It is an international standard used by utility organizations to provide data exchange over wide area networks (WANs) between utility control centers utilities power pools regional control centers and Non-Utility Generators Collecting and exchanging real-time data on power system status is one of the elementary steps in the complex process of developing the information that System Operators need to maintain situational awareness Real-time reliability tools such as the state estimator and contingency analysis can only provide results that accurately represent current and potential reliability problems if these tools have Real-time analog and status data The accuracy of the information that Real-time reliability tools provide depends on the accuracy of the data supplied to the tools The quality of the results that Real-time reliability tools produce is also influenced by the breadth and depth of the portion of the BES for which Real-time data are collected relative to the breadth and depth of the relevant Reliability Entityrsquos area of responsibility It is proposed that requirements for data exchange will be applicable to the Reliability Coordinator Transmission Operator Balancing Authority and Generation Operator 5 of 9 The following requirements are proposed for data exchange of Real-time data These requirements assume that the Responsible Entity is utilizing an EMS andor SCADA system utilizing ICCP or an equivalent protocol to exchange data 31 PERFORMANCE The SDT proposes the following requirements for data exchange performance ICCP (or equivalent) data exchange must be redundant and the redundancy must be supplied through diverse routing Entities shall develop data exchange agreements and comply with data specifications Data exchange agreements must include the following bull Interoperability of ICCP and equivalent systems bull Data access restrictions bull Data naming conventions bull Data management and coordination including data quality bull Joint testing and data checkout bull Monitoring of availability bull Responsibility for failures bull Restoration process 32 AVAILABILITY The SDT proposes the following requirements for data exchange availability Establish procedure for actions to be taken if some or all of the data exchanged is not available for a 30 minute timeframe 33 FAILURE NOTIFICATION Notification of link failure must be made to the System Operator within 60 seconds of when link failure occurred Failure is identified as the inability to receive a complete data set regardless of reason 34 MAINTENANCE Each functional entity shall provide System Operators with approval authority for planned maintenance of its data exchange capabilities Coordination with affected entities is required 6 of 9 40 ALARMING Alarms must be generated to alert System Operators in Real-time to events and conditions affecting the state of the BES Alarms can be audible andor visual Alarms must be generated for the following reasons bull Limit violations (for any defined limits including multiple limits on a single point) bull Uncommanded status changes bull DCU unavailability bull Data exchange link unavailability Alarms are important to the safe and secure operation of the BES System Operators depend on alarms to identify problems occurring or about to occur All values measured or calculated by the EMS andor SCADA must be subject to processing to determine either change of state or limit violations If either of these conditions occurs an alarm must be generated It is proposed that requirements for alarming will be applicable to Reliability Coordinators Transmission Operators and Balancing Authorities The following requirements are proposed for alarming of measured and calculated data 41 PERFORMANCE Performance issues such as volume and throughput of alarms are recognized as potential concerns but are generally handled in initial EMSSCADA vendor specifications It would be difficult if not impossible to measure in a production system Therefore no performance requirement is anticipated as part of this project 42 AVAILABILITY The SDT proposes the following requirements for alarming availability bull No specific numeric value will be proposed for alarming availability bull Establish a procedure for actions to be taken when the alarming functionality is unavailable for 10 consecutive minutes (see RTBPTF report page 117 paragraph 4) For example the Reliability Coordinator lsquobacks uprsquo the Transmission OperatorBalancing Authority and vice versa and entities inform each other of failure of their alarming capability 7 of 9 43 FAILURE NOTIFICATION Notification of failure of the alarm processing function must be made to the System Operator within 60 seconds of when failure is detected Notification of failure of alarming capability must be accomplished through independent failure notification where the system creating and presenting the notification is independent of the alarming functionality 44 MAINTENANCE Each functional entity shall provide System Operators with approval authority for planned maintenance of its alarming capabilities 50 ANALYSIS The intent of analysis in the context of this white paper is to focus on determining the current condition or state of the BES and evaluate the impact of lsquowhat ifrsquo events on the state of the BES The meanings of ldquocurrentrdquo and ldquowhat-ifrdquo are bull Current - The current system condition or state is a function of the most recent system bus voltages system topology frequency and line flows bull lsquoWhat ifrsquo - Analyze the impact on the security of the current power system state of specific Contingencies or simulated outages of the BES such as lines generators or other equipment This analysis should also include other system condition changes that would affect the BES such as Load The analysis identifies problems such as line overloads or voltage violations that will occur if the system event or Contingency takes place The capability to determine the current state of the BES is critical for the System Operator to determine violations of reliability criteria in their area By accurately determining the current state of the BES the System Operator is thus capable of evaluating various lsquowhat ifrsquo scenarios Having the results of the lsquowhat ifrsquo events before they happen allows System Operators to take the appropriate actions to prevent violations or have plans ready if such Contingencies were to occur It is proposed that requirements for analysis will be applicable to the Reliability Coordinator and Transmission Operator The following requirements are proposed for analysis of the current and ldquowhat-ifrdquo states of the BES 8 of 9 51 PERFORMANCE The requirements for Performance will address periodicity and quality 511 Periodicity The current and ldquowhat-ifrdquo analyses shall run based on the following conditions bull Current analysis - Automated program required that runs periodically at no more than a 5 minute interval to determine the systemrsquos current condition or state The analysis may be either a program that runs on the Reliability Coordinatorrsquos or Transmission Operatorrsquos EMS or through contracted services (3rd party Reliability Coordinator or other Transmission Operator) bull ldquoWhat ifrdquo analysis - Automated program required that runs periodically at no more than a 10 minute interval (from pg 117 of Blackout Report - 4b) to analyze the impact on the security of the current power system state for specific Contingencies or simulated outages of the BES such as lines generators or other equipment The analysis may be either a program that runs on the Reliability Coordinatorrsquos or Transmission Operatorrsquos EMS or through contracted services (3rd party Reliability Coordinator or other Transmission Operator) 512 Results Quality Quality needs to be measured to ensure that the base case used by the automated analysis program(s) accurately represent the state of the system bull For both current amp ldquowhat ifrdquo analyses o For Reliability Coordinator amp Transmission Operator o Compare physical lsquotiersquo line values and generator injections plus selected interconnected transmission line flows from the automated analysis program(s) to actual metered values every time the program runs These values have been selected because of the accuracy of the metering at those locations and their impact on the BES o Compute the percentage deviation of the program values versus actual metered values o Compute the average of the percentages on a periodic basis and compare to the tolerance value (Actual periodicity will be selected based on industry feedback) o Tolerance must be +- x (Actual value will be selected based on industry feedback) 9 of 9 52 AVAILIBILITY Responsible entities must establish a procedure for what to do if the program(s) is not available for more than 30 consecutive minutes Current - The automated programs must provide a solution every five minutes 99 of the time on a monthly basis lsquoWhat ifrsquo - The automated programs must provide a solution every ten minutes 99 of the time on a monthly basis 53 FAILURE NOTIFICATION Notification of failure of the analysis capability to provide a solution to the System Operator must be made to the System Operator within 60 seconds of when failure is detected 54 MAINTENANCE Each functional entity shall provide System Operators with approval rights for planned maintenance of its analysis capabilities From scottvidlerHydroOnecomTo Lee R PedowiczSubject RE RSC Meeting--March 16-17 2011Date Monday February 28 2011 25358 PM Hi LeeEven though we posted the white paper to solicit industry feedback so that we couldconsider them in the drafting of the standard we donrsquot expect the project to continue at thistime NERC has performed an analysis of the outstanding standards that are in the hopperand used a prioritizing method to attempt to get the most important standards movingtowards completion At this time the Real-time Reliability Monitoring and AnalysisCapabilities standard is not going to make this yearrsquos active project list We will collect thedata from the white paper and the team members will be able to use it to guide any of ourdiscussions and when we reconvene hopefully we will be able to come out of the blocksand do a 100 metre dash to the finishI can certainly join a conference call ndash but there will not be much to say Irsquom available onMarch 17RegardsScott VidlerManager - Grid OperationsOperating Performance amp Customer SupportOntario Grid Control CentreHydro One Networks IncPhone 7057923020Cell 7056271436Internet scottvidlerhydroonecomGood ideas are not adopted automatically They must be driven into practice with courageous patience mdash HymanRickoverldquoThis e-mail and any attached files are privileged and may contain confidential information intended only for the person or personsnamed above Any other distribution reproduction copying disclosure or other dissemination is strictly prohibited If you havereceived this e-mail in error please notify the sender immediately by reply e-mail and delete the transmission received by yourdquo From Lee R Pedowicz [mailtolpedowicznpccorg] Sent Monday February 28 2011 100 PMTo VIDLER ScottCc Guy V Zito Gerard J DunbarSubject RSC Meeting--March 16-17 2011 Good afternoon Scott At our upcoming NPCC RSC Meeting March 16-17 2011 we discuss the NERC Standards that areposted for comment or under development I checked our information and it lists you as being amember of the Drafting Team for Project 2009-02 - Real-time Reliability Monitoring and AnalysisCapabilities Being that it will still be posted when we have our meeting would you be able to callin and give us a summary of its status Our meeting is from 1000 am until 500 pm March 16and then 800 am until 300 pm on March 17 Wersquoll arrange our agenda for you Thanks Lee PedowiczManager Reliability StandardsNPCCThis email and any of its attachments may contain information that is privilegedconfidential classified as CEII or subject to copyright belonging to NPCC This email isintended solely for the use of the individual or entity to which it is addressed If you are notthe intended recipient of this email you are hereby notified that any disseminationdistribution copying or action taken in relation to the contents of and attachments to thisemail is strictly prohibited and may be unlawful If you receive this email in error pleasenotify the sender immediately and permanently delete the original and any copy of this emailand any printout From Monica BensonTo monicabensonnercnetSubject Standards Announcement - Informal Comment Period Open - Project 2009-02 Real-time Monitoring and Analysis CapabilitiesDate Wednesday February 16 2011 30000 PM Standards AnnouncementProject 2009-02 Real-time Monitoring and Analysis CapabilitiesInformal Comment Period OpenFebruary 16 ndash April 4 2011 Now available at httpwwwnerccomfilezstandardsProject2009-02_Real-Time_Monitoring_Analysis_Capabilitieshtml Informal Comment Period Open through 8 pm on Monday April 4 2011The Project 2009-02 Real-time Monitoring and Analysis Capabilities Standard Drafting Team has posted for a 45-day informal commentperiod a White Paper on proposed concepts to support the development of real-time monitoring and analysis standards The White Paperalong with an unofficial Word version of the comment form have been posted on the project Web page athttpwwwnerccomfilezstandardsProject2009-02_Real-Time_Monitoring_Analysis_Capabilitieshtml InstructionsPlease submit comments using the electronic form Next StepsThe drafting team will consider the input received on the concept White Paper as it begins preparing to draft standards Project BackgroundThe need for improved visualization capabilities over a wide geographic area has been a recurrent theme in blackout investigationsAccording to the Final Report on the August 14 2003 Blackout in the United States and Canada Causes and Recommendations dated April2004 a principal cause of the August 2003 blackout was a lack of situational awareness a result of inadequate reliability tools NERCrsquos Operating Committee formed the Real-time Tools Best Practices Task Force (RTBPTF) to evaluate real-time tools and their usagewithin the industry The Task Force produced a report ldquoReal-Time Tools Survey Analysis and Recommendationsrdquo dated March 13 2008that included recommendations for the functionality performance and management of real-time tools This project addresses recommendations from the August 2003 Blackout Report the RTBPTF report and two directives from FERC Order693 Standards ProcessThe Standard Processes Manual contains all the procedures governing the standards development process The success of the NERCstandards development process depends on stakeholder participation We extend our thanks to all those who participate For more information or assistance please contact Monica Benson at monicabensonnercnet North American Electric Reliability Corporation 116-390 Village BlvdPrinceton NJ 08540 6094528060 | wwwnerccom ---You have received this email because you are a registered representative in the Registered Ballot Body From Elizabeth HeenanTo Elizabeth HeenanSubject Comment Period Opens for Proposed Changes to ReliabilityFirst Corporation Rules of Procedure Pertaining to Regional Standards Development ProcessDate Tuesday March 01 2011 63525 PM Comment Period Opens for Proposed Changes to ReliabilityFirstCorporationrsquos Rules of Procedure ndash Regional Standards DevelopmentProcess NERC Stakeholders Now available at httpwwwnerccomfilesFinal_Posting_RFC_Standards_Process_Changes_20110301pdf NERC requests comments on the proposed revisions to ReliabilityFirst Corporationrsquos reliability standards development procedure OnJanuary 14 2011 NERC received a request from ReliabilityFirst Corporation to modify its proposed regional standard developmentprocess changes approved by the ReliabilityFirst Corporation Board of Directors In accordance with Section 311 of the NERC Rules of Procedure NERC is required to publicly notice and request comment on anyproposed changes to a regional standards development procedure for a minimum 45-day comment period Any objections identified bystakeholders during the posting period shall be resolved by ReliabilityFirst Corporation before the proposed changes are presented to theNERC Board of Trustees for approval Upon NERC Board of Trustee approval NERC shall file the proposed changes pursuant to 18 CFRsect 3910 (2010) with the Federal Energy Regulatory Commission for approval Materials Included in this Request for Comments Letter from Timothy R Gallagher to David Cook outlining process and changes Attachment A- ReliabilityFirst Corporation Reliability Standards Development Procedure ndashVersion 3 (Clean) Attachment B - ReliabilityFirst Corporation Reliability Standards Development Procedure ndashVersion 3 (Redline) and Attachment C ndash Corresponding changes to Exhibit C to ReliabilityFirst Regional Delegation Agreement (Redline) Comments are due April 15 2011 and must be submitted electronically to ropcommentsnercnet For more information or assistance please contact Elizabeth Heenan at elizabethheenannercnet North American Electric Reliability Corporation 116-390 Village BlvdPrinceton NJ 08540 6094528060 | wwwnerccom ---You are currently subscribed to nerc-info as lpedowicznpccorgTo unsubscribe send a blank email to leave-1249731-3256541ca6f85fb1574a8515cc07df72d3bfe0listservnerccom 116-390 Village Blvd Princeton NJ 08540 6094528060 | wwwnerccom Notice of Proposed Changes to RFC Rules of Procedure and Request for Comments Proposed Changes to ReliabilityFirst Corporation Rules of Procedure Comments Due April 15 2011 The North American Electric Reliability Corporation (ldquoNERCrsquo) hereby requests comments on the proposed revisions to ReliabilityFirst Corporationrsquos reliability standards development procedure On January 14 2011 NERC received a request from ReliabilityFirst Corporation to modify its proposed regional standard development process changes approved by the ReliabilityFirst Corporation Board of Directors NERC has determined that ReliabilityFirst Corporationrsquos proposed regional reliability standards development procedure meets the criteria included in Section 31131 of the NERC Rules of Procedure (open inclusive balanced due process and transparent) In accordance with Section 311 of the NERC Rules of Procedure NERC is required to publicly notice and request comment on any proposed changes to a regional standards development procedure for a minimum 45-day comment period Any objections identified by stakeholders during the posting period shall be resolved by ReliabilityFirst Corporation before the proposed changes are presented to the NERC Board of Trustees for approval Upon NERC Board of Trustee approval NERC shall file the proposed changes pursuant to 18 CFR sect 3910 (2010) with the Federal Energy Regulatory Commission for approval Materials Included in this Request for Comments - Letter from Timothy R Gallagher to David Cook outlining process and changes - Attachment A- ReliabilityFirst Corporation Reliability Standards Development Procedure ndashVersion 3 (Clean) - Attachment B - ReliabilityFirst Corporation Reliability Standards Development Procedure ndashVersion 3 (Redline) and - Attachment C ndash Corresponding changes to Exhibit C to ReliabilityFirst Regional Delegation Agreement (Redline) Submission of Comments Comments are due April 15 2011 and must be submitted electronically to ropcommentsnercnet NERC intends to submit the proposed changes to the ReliabilityFirst standards development procedure to the NERC Board of Trustees for approval at its May 11 2011 meeting For further information please contact Elizabeth Heenan at elizabethheenannercnet 320 SPRINGSIDE DRIVE SUITE 300 AKRON OH 44333-4500 (330) 456-2488 Fax (330) 456-5408 January 14 2011 Mr David Cook Senior Vice President and General Counsel North American Electric Reliability Corporation Princeton Forrestal Village 116-390 Village Boulevard Princeton NJ 08540-5721 Dear David Please find attached to this letter the revised Standards Development Procedure (the ldquoProcedurerdquo) of ReliabilityFirst Corporation (ldquoReliabilityFirstrdquo) reflecting revisions to the Procedure approved by the Board of Directors of ReliabilityFirst on December 15 2010 (Attachments A and Bmdashclean and redlined versions) and a redline version of Exhibit C (Attachment C) to the Regional Delegation Agreement (ldquoRDArdquo) The redline Exhibit C is included to demonstrate that the revisions to the Procedure continue to adhere to the Attributes specified in Exhibit C for the development of Regional Reliability Standards ReliabilityFirst revised the Procedure to improve the openness of the process to increase the requirement on affirmative votes to align with the North American Electric Reliability Corporation (ldquoNERCrdquo) process to better align the ReliabilityFirst process with the NERC process and to improve clarity and understanding of the process With this filing ReliabilityFirst seeks to satisfy the requirements of the Federal Energy Regulatory Commissionrsquos (ldquoFERCrdquo or the ldquoCommissionrdquo) regulations regarding changes to Regional Entity Rules As specified in 18 CFR sect 391 (2010) the Standards Development Procedure of a Regional Entity such as ReliabilityFirst are Regional Entity Rules As such the Commissionrsquos regulations require that NERC as the Electric Reliability Organization must approve any modifications or revisions to the Procedure and then submit any approved modifications or revisions to the Commission for approval 18 CFR sect 3910 (2010) and North American Electric Reliability Council et al 119 FERC para 61060 at P 333 (2007) The Commissionrsquos regulations require that when NERC submits changes in Regional Entity Rules to the Commission NERC must explain ldquothe basis and purpose for the Rule or Rule change together with a description of the proceedings conducted by the Regional Entity to develop the proposalrdquo 18 CFR sect 3910 (2010) To assist NERC in complying with this requirement and to aid NERC in its independent consideration of the revisions to the Procedure ReliabilityFirst is supplying the information requested by the regulations Timothy R GallagherPresident and Chief Executive Officer Direct Dial (330) 247-3040timgallagherrfirstorg 2 I The Basis and Purpose for the Revisions to the Procedure A Substantive Revisions The revised Procedure contains the following substantive revisions 1 Include an informal Standard Authorization Request (ldquoSARrdquo) comment period step a Added a SAR comment step to assist the ReliabilityFirst Standards Committee (ldquoSCrdquo) in determining if the SAR should move into the standard drafting phase 2 Make the Category Ballot approval percentage consistent with NERC (super-majority vs simple majority a Changed the approval percentage to two-thirds or greater 3 Modifications to the voting and Ballot Pool structure a Modified the voting and Ballot Pool structure to further align with the NERC process b Corporations or organizations will be able to cast one vote in each ReliabilityFirst registered voting category as long as a different individual is registered in each registered voting category If a corporation or organization is registered in each one of the ReliabilityFirst voting categories the maximum number of votes possible is five including corporation and organization affiliates 4 Inclusion of a Recirculation Ballot period a A Recirculation Ballot period will be required if ReliabilityFirst received any negative ballot comments during the initial 15-Day Category Ballot b The addition of a recirculation ballot will give stakeholders the opportunity to review the comments submitted by other entities during the initial Category Ballot to determine if they wish to reconsider their voting position 5 Inclusion of an informal comment period within the Interpretation section a Added an informal comment period to the Interpretation section which will increase the transparency of the Procedure and allow stakeholders to weigh in on interpretations developed by ReliabilityFirst 6 Inclusion of language referencing the use of the NERC Standards Template a Added additional language referencing the use of NERC Standards Template to allow ReliabilityFirst standards and NERC standards to follow a consistent format and template 320 SPRINGSIDE DRIVE SUITE 300 AKRON OH 44333-4500 (330) 456-2488 Fax (330) 456-5408 7 Further clarification regarding ldquoEffective Datesrdquo a Added language to further clarify ldquoEffective Datesrdquo for ReliabilityFirst standards i ReliabilityFirst standards are mandatory and enforceable without monetary penalties for non-compliance upon the effective date for applicable entities that are members of ReliabilityFirst ii ReliabilityFirst standards are mandatory and enforceable with monetary penalties for non-compliance for all applicable registered entities within the ReliabilityFirst footprint upon approval by the Commission B Changes to Correct TypographicalTechnical Issues The revised Procedure contains the following minor revisions 8 Removal of references to the ldquoInterim Compliance Committee (ldquoICCrdquo) from the Interpretation section since the ICC no longer exists 9 A number of format and editorial changes to further clarify certain sections II Proceedings Conducted by ReliabilityFirst to Revise the Procedure ReliabilityFirst followed the current FERC-approved Standards Development procedure to develop the revisions submitted with this filing See 119 FERC para 61060 at P 339 Specifically on January 20 2010 the SC authorized a SAR to modify two specific items of the Procedure The scope of the SAR consisted of items 1 and 2 above On April 30 2010 the SC authorized a supplemental SAR (based on the recommendation of the ReliabilityFirst Standard Drafting Team) in which the scope consisted of the remaining items identified above Upon completion of the items listed in the two SARs ReliabilityFirst posted the revised Standards Procedure for one 30-Day Comment period (June 16 2010 through July 15 2010) in which a total of 17 commenters provided comments After responding to all comments and modifying the Procedure accordingly ReliabilityFirst posted the Procedure for the required 15-Day period prior to Category Ballot (August 17 2010 through August 31 2010) followed by the 15-Day Category Ballot (September 1 2010 through September 15 2010) The Procedure passed the 15-Day Category Ballot achieving quorum (972) with an overwhelming affirmative category vote (100) Following the Category Ballot the Procedure was publically posted for the required 30 days prior to ReliabilityFirst Board action (September 24 2010 through October 23 2010) The ReliabilityFirst Board of Directors unanimously approved the Procedure on December 15 2010 4 III Conclusion ReliabilityFirst believes these revisions do not affect its delegated authority under 18 CFR sect 398 ReliabilityFirst respectfully requests that NERC consider and approve the foregoing amendments to the ReliabilityFirst Standards Development Procedure and submit the revised Procedure to the Commission for its approval as changes to the rules of a Regional Entity in accordance with 18 CFR sect 3910 Sincerely RELIABILITYFIRST CORPORATION Timothy R Gallagher President and Chief Executive Officer cc Susan O Ivey ReliabilityFirst Corporation Chair Board of Directors Kenneth Defontes ReliabilityFirst Corporation Vice-Chair Board of Directors Larry E Bugh ReliabilityFirst Corporation Director of Corporate Affairs L Jason Blake ReliabilityFirst Corporation Corporate Counsel Anthony E Jablonski ReliabilityFirst Corporation Standard Process Manager Attachment A ReliabilityFirst Standards Development Procedure Revised December 15 2010 (Clean) ReliabilityFirst Corporation Reliability Standards Development Procedure Version 3 ReliabilityFirst Board Approval December 15th 2010 ReliabilityFirst Board Approval December 15th 2010 ReliabilityFirst Corporation Reliability Standards Development Procedure Table of Contents Introduction 1 Background 2 Regional Reliability Standard Definition Characteristics and Elements 3 Roles in the Regional Reliability Standards Development Process 7 Regional Reliability Standards Development Process 8 Appendix A Maintenance of Regional Reliability Standards Development Processhelliphelliphellip17 Appendix B Standard Authorization Request 21 Appendix C Flowchart for Standards Process 28 Appendix D Ballot Pool Categories and Registration 30 ReliabilityFirst Corporation Reliability Standards Development Procedure Introduction This procedure establishes the process for adoption of a Regional Reliability Standard1 (hereinafter referred to as ldquoStandardrdquo) of the ReliabilityFirst Corporation (ReliabilityFirst) and the development of consensus for adoption approval revision reaffirmation and deletion of such Standards1 ReliabilityFirst Standards provide for the reliable regional and sub-regional planning and operation of the Bulk Power System2 (BPS) consistent with Good Utility Practice2 within the ReliabilityFirst geographical footprint This procedure was developed under the direction of the ReliabilityFirst Board of Directors (Board) who may request changes to this ReliabilityFirst Reliability Standards Development Procedure (hereinafter referred to as ldquothis Procedurerdquo) as deemed appropriate A procedure for revising this Procedure is contained in Appendix A This Procedure is consistent with the North American Electric Reliability Corporation (NERC) Reliability Standards Development Procedure ReliabilityFirst standards shall be subject to approval by NERC as the electric reliability organization and by the Federal Energy Regulatory Commission (FERC) before becoming mandatory and enforceable under Section 215 of the FPA The approval date of each ReliabilityFirst standard is upon ReliabilityFirst Board approval The effective date will depend on the implementation plan that is provided with each new or revised standard The ReliabilityFirst standard is mandatory and enforceable (without monetary penalties for non-compliance) upon the effective date after ReliabilityFirst Board approval for applicable entities that are members of ReliabilityFirst3 The ReliabilityFirst standard is mandatory and enforceable (with monetary penalties for non-compliance) to all applicable entities within the ReliabilityFirst footprint upon approval by FERC The effective date for non-members upon the FERC approval will be determined by the implementation plan that is provided with each new or revised standard ReliabilityFirst Standards shall provide for as much uniformity as possible with NERC reliability standards across the interconnected BPS A ReliabilityFirst Standard shall be more stringent than a NERC reliability standard including a regional difference that addresses matters that the NERC reliability standard does not or shall be a regional 1 Legacy standards such as ECAR Documents MAIN Guides and MAAC Procedures shall be considered ReliabilityFirst Regional Reliability Standards for the purposes of this document until otherwise acted upon by the ReliabilityFirst Board 2 As defined in the ReliabilityFirst By-laws 3 By applying for and becoming a Regular or Associate Member of the Corporation each Member agrees to comply with all Reliability Standards all NERC standards and requirements and the other obligations of Members of the Corporation set forth in the ReliabilityFirst Bylaws or duly adopted by the Board in order to achieve the purposes of the Corporation ReliabilityFirst Board Approval December 15th 2010 Page 1 of 31 difference necessitated by a physical difference in the BPS A ReliabilityFirst Standard that satisfies the statutory and regulatory criteria for approval of proposed NERC reliability standards and that is more stringent than a NERC reliability standard would generally be acceptable ReliabilityFirst Standards when approved by FERC shall be made part of the body of NERC reliability standards and shall be enforced upon all applicable BPS owners operators and users within the ReliabilityFirst area regardless of membership in the region Background Regions may develop through their own processes separate ldquoRegional Standardsrdquo (ReliabilityFirst Standards) that go beyond add detail to or aid implementation of NERC reliability standards or otherwise address issues that are not addressed in NERC reliability standards As a condition of ReliabilityFirst membership all ReliabilityFirst Members2 agree to adhere to the NERC reliability standards As such the ReliabilityFirst and its Members will adhere to the NERC reliability standards in addition to the ReliabilityFirst Standards NERC reliability standards and the ReliabilityFirst Standards are both to be included within the ReliabilityFirst Compliance Program ReliabilityFirst Standards are intended to apply only to that part of the Eastern Interconnection within the ReliabilityFirst geographical footprint The development of these ReliabilityFirst Standards is developed according to the following principles via the process contained within this Procedure bull Developed in a fair and open process that provided an opportunity for all interested parties to participate bull Does not have an adverse impact on commerce that is not necessary for reliability bull Provides a level of BPS reliability that is adequate to protect public health safety welfare and national security and would not have a significant adverse impact on reliability and bull Based on a justifiable difference between Regions or between sub-Regions within the Regional geographic area 2 As defined in the ReliabilityFirst By-laws ReliabilityFirst Board Approval December 15th 2010 Page 2 of 31 Regional Reliability Standard Definition Characteristics and Elements Definition of a Reliability Standard As contained in the ReliabilityFirst By-laws ReliabilityFirst ldquoRegional Reliability Standardrdquo shall mean a type of Reliability Standard that is applicable only within a particular Regional Entity or group of Regional Entities A Regional Reliability Standard may augment add detail to or implement another Reliability Standard or cover matters not addressed by other Reliability Standards Regional Reliability Standards upon adoption by NERC and approval by the Commission enforced within the applicable Regional Entity or Regional Entities pursuant to delegated authorities Inherent in this definition a ReliabilityFirst Standard will define certain obligations or requirements of entities that own operate plan and use the BPS within the ReliabilityFirst geographical footprint These obligations or requirements as contained in the ReliabilityFirst Standards are to be measurable and consistent with Good Utility Practice Standards are not to include processes or procedures that implement a Standard In addition obligations requirements or procedures imposed upon ReliabilityFirst by NERC reliability standards are not to be ReliabilityFirst Standards unless those obligations requirements or procedures require the establishment of a ldquopolicy or standardrdquo as defined by the ReliabilityFirst By-laws Characteristics of a Regional Reliability Standard A Standard is policy including adequacy criteria to provide for the reliable regional and sub-regional planning and operation of the BPS consistent with Good Utility Practice A Standard shall generally have the following characteristics bull Measurable - A Standard shall establish technical or performance requirements that can be practically measured bull Relative to NERC Reliability Standards - A Standard generally must go beyond add detail to or implement NERC Reliability Standards or cover matters not addressed in NERC Reliability Standards Format Requirements of a Regional Reliability Standard A Standard shall consist of the requirements shown in the Regional Reliability Standard Template These requirements apply to the development and revision of Standards These requirements are necessary to achieve Standards that are measurable enforceable and consistent Supporting documents to aid in the implementation of a Standard may be referenced by the Standard but are not part of the Standard itself The most current version of the approved NERC Reliability Standard template and its associated elements ReliabilityFirst Board Approval December 15th 2010 Page 3 of 31 posted on the NERC website will be used at the time of the development of a ReliabilityFirst Regional Reliability Standard if different from the elements listed below Regional Reliability Standard Format Requirement Template Example Identification Number A unique identification number assigned in accordance with an administrative classification system to facilitate tracking and reference ReliabilityFirst documentation Title A brief descriptive phrase identifying the topic of the Standard Applicability Clear identification of the functional classes of entities responsible for complying with the Standard noting any specific additions or exceptions If not applicable to the entire ReliabilityFirst area then a clear identification of the portion of the BPS to which the Standard applies Any limitation on the applicability of the Standard based on electric facility requirements should be described Effective Date and Status The effective date of the Standard or prior to approval of the Standard the proposed effective date Purpose The purpose of the Standard The purpose shall explicitly state what outcome will be achieved or is expected by this Standard Requirement(s) Explicitly stated technical performance and preparedness requirements Each requirement identifies what entity is responsible and what action is to be performed or what outcome is to be achieved Compliance is mandatory for each statement in the requirements section ReliabilityFirst Board Approval December 15th 2010 Page 4 of 31 Risk Factor(s) The potential reliability significance of each requirement designated as a High Medium or Lower Risk Factor in accordance with the criteria listed below A High Risk Factor requirement (a) is one that if violated could directly cause or contribute to BPS instability separation or a cascading sequence of failures or could place the BPS at an unacceptable risk of instability separation or cascading failures or (b) is a requirement in a planning timeframe that if violated could under emergency abnormal or restorative conditions anticipated by the preparations directly cause or contribute to BPS instability separation or a cascading sequence of failures or could place the BPS at an unacceptable risk of instability separation or cascading failures or could hinder restoration to abnormal condition A Medium Risk Factor requirement (a) is a requirement that if violated could directly affect the electrical state or the capability of the BPS or the ability to effectively monitor and control the BPS but is unlikely to lead to BPS instability separation or cascading failures or (b) is a requirement in a planning timeframe that if violated could under emergency abnormal or restorative conditions anticipated by the preparations directly affect the electrical state or capability of the BPS or the ability to effectively monitor control or restore the BPS but is unlikely under emergency abnormal or restoration conditions anticipated by the preparations to lead to BPS instability separation or cascading failures nor to hinder restoration to a normal condition A Lower Risk Factor requirement is administrative in nature and (a) is a requirement that if violated would not be expected to affect the electrical state or capability of the BPS or the ability to effectively monitor and control the BPS or (b) is a requirement in a planning time frame that if violated would not under the emergency abnormal or restorative conditions anticipated by the preparations be expected to affect the electrical state or capability of the BPS or the ability to effectively monitor control or restore the BPS Measure(s) Each requirement shall be addressed by one or more measurements that will be used to assess performance and outcomes for the purpose of determining compliance with the requirements stated above Each measurement identifies to whom the measurement applies Each measurement shall be tangible and as objective as is practical Achieving the full compliance level of each measurement is a necessary and sufficient indicator that the requirement was met Compliance Administration Elements ReliabilityFirst Board Approval December 15th 2010 Page 5 of 31 Compliance Monitoring Process Defines for each measure bull The specific data or information that is required to measure performance or outcomes bull The entity that is responsible to provide the data or information for measuring performance or outcomes bull The process that will be used to evaluate information for the purpose of assessing performance or outcomes bull The entity that is responsible for evaluating information to assess performance or outcomes bull The time period in which performance or outcomes is measured evaluated and then reset bull Data retention requirements and assignment of responsibility for data archiving bull Violation severity levels ReliabilityFirst Board Approval December 15th 2010 Page 6 of 31 Supporting Information Elements Interpretations Any ReliabilityFirst interpretations of the Standards that were developed and approved in accordance with the ldquoInterpretation of Standardsrdquo section of this Procedure to expound on the application of the Standard for unusual or unique situations or provide clarifications Implementation Plan Each ReliabilityFirst Standard shall have an associated implementation plan describing the effective date of the Standard or effective dates if there is a phased implementation The implementation plan may also describe the implementation of the Standard in the compliance program and other considerations in the initial use of the Standard such as necessary tools training etc The implementation plan must be posted for at least one public comment period and be approved as part of the ballot of the standard Supporting References This section references related documents that support reasons for or provide additional information related to the Standard Examples include but are not limited to bull Glossary of Terms bull Developmental history of the Standard and prior versions bull Subcommittee(s) responsible for Standard bull Notes pertaining to implementation or compliance bull Standard references bull ProceduresPractices bull Training andor Technical Reference Roles in the Regional Reliability Standards Development Process Process Roles Originator - Any entity (person organization company government agency individual etc) that is directly and materially affected by the reliability of the ReliabilityFirst BPS is allowed to request a Standard be developed or an existing Standard is modified or deleted by creating a Standards Authorization Request (SAR) See Appendix B Board ndash The ReliabilityFirst Board shall act on any proposed Standard that has gone through the process contained in this Procedure Once the ReliabilityFirst Board approves a Standard compliance with the Standard will be enforced consistent with the By-laws and the terms of the Standard Standards Committee (SC) - The ReliabilityFirst SC will consider which requests for new or revised Standards shall be assigned for development (or existing Standards considered for deletion) The SC manages the Standards development process The SC ReliabilityFirst Board Approval December 15th 2010 Page 7 of 31 will advise the ReliabilityFirst Board on Standards presented for adoption by the ReliabilityFirst Board Standards Process Manager (SPM) ndash A person or persons on the ReliabilityFirst staff assigned the task of ensuring that the development revision or deletion of Standards is in accordance with this Procedure The SPM works to ensure the integrity of the process and consistency of quality and completeness of the Standards The SPM facilitates the administration of all actions contained in all steps in the process Standards Process Staff ndash Employees of the ReliabilityFirst that work with or for the SPM Standard Drafting Team (SDT) ndash A team of technical experts and typically including a member of the ReliabilityFirst Standards staff and the Originator assigned the task of developing a proposed Standard based upon an approved SAR using the Standard development process contained in this Procedure Ballot Body (BB) ndash The Ballot Body comprises all entities that qualify for one or more of the categories and are registered with ReliabilityFirst as potential ballot participants in the voting on standards The categories of registration within the Ballot Body and the registration process are described in Appendix D Ballot Pool ndash The Ballot Pool is comprised of those members of the Ballot Body that register to vote for each particular standard A separate Ballot Pool is established for each standard up for vote Only individuals who have joined the Ballot Pool for that particular standard are eligible to vote on a standard Reliability Committee (RC) ndash The ReliabilityFirst RC serves as a technical advisory body to address the reliability related activities required by the Reliability Standards via review and discussion of the regional activities as requested by the SC Regional Reliability Standard Development Process (Flow chart of Process shown in Appendix C) Assumptions and Prerequisites The ReliabilityFirst Regional Reliability Standards Development Process has the following characteristics bull Fair due process - The ReliabilityFirst standards development process shall provide for reasonable notice and opportunity for public comment At a minimum the procedure shall include public notice of the intent to develop a standard a public comment period on the proposed standard due consideration of those public comments and a ballot of interested stakeholders ReliabilityFirst Board Approval December 15th 2010 Page 8 of 31 bull Openness - Participation is open to all Organizations who are directly and materially affected by the ReliabilityFirst region BPS reliability There shall be no undue financial barriers to participation Participation shall not be conditioned upon membership in the ReliabilityFirst and shall not be unreasonably restricted on the basis of technical qualifications or other such requirements Meetings of SDTs are open to the ReliabilityFirst membership and to others bull Balanced - The ReliabilityFirst standards development process strives to have an appropriate balance of interests and shall not be dominated by any two interest categories and no single interest category shall be able to defeat a matter bull Inclusive - Any entity (person organization company government agency individual etc) with a direct and material interest in the BPS in the ReliabilityFirst area shall have a right to participate by a) expressing a position and its basis b) having that position considered and c) having the right to appeal bull Transparent - All actions material to the development of ReliabilityFirst Standards shall be transparent All standards development meetings shall be open and publicly noticed on ReliabilityFirstrsquos Web site bull Does not unnecessarily delay development of the proposed Standard Note The term ldquodaysrdquo refers to calendar days Each standard shall enable or support one or more of the reliability principles thereby ensuring that each standard serves a purpose in support of the reliability of the regional BPS Each standard shall also be consistent with all of the reliability principles thereby ensuring that no standard undermines reliability through an unintended consequence While ReliabilityFirst Standards are intended to promote reliability they must at the same time accommodate competitive electricity markets Reliability is a necessity for electricity markets and robust electricity markets can support reliability Recognizing that BPS reliability and electricity markets are inseparable and mutually interdependent all ReliabilityFirst Standards shall be consistent with NERCrsquos market interface principles Consideration of the market interface principles is intended to ensure that standards are written such that they achieve their reliability objective without causing undue restrictions or adverse impacts on competitive electricity markets ReliabilityFirst will coordinate with NERC such that the acknowledgement of receipt of a standard request identified in step 1 notice of comment posting period identified in step 4 and notice for vote identified in step 5 below are concurrently posted on both the ReliabilityFirst and NERC websites ReliabilityFirst Board Approval December 15th 2010 Page 9 of 31 Step 1 - Development of a Standards Authorization Request (SAR) to Develop Revise or Delete a Regional Reliability Standard Any individual representing an organization (Originator) which is directly or materially impacted by the operation of the BPS within the geographical footprint of the ReliabilityFirst may request via a submittal of a Standard Authorization Request (SAR) form the development modification or deletion of a ReliabilityFirst Standard Any such request shall be submitted to the ReliabilityFirst SPM or hisher designee or by another process as otherwise posted on the ReliabilityFirst website The SAR form may be downloaded from the ReliabilityFirst website The SAR contains a description of the proposed Standard subject matter containing sufficiently descriptive detail to clearly define the purpose scope impacted parties and other relevant information of the proposed Standard The SPM will verify that the submitted SAR form has been adequately completed The SPM may offer the Originator suggestions regarding changes andor improvements to improve clarity and assist the ReliabilityFirst community to understand the Originatorrsquos intent and objectives The Originator is free to accept or reject these suggestions Within 15 days the SPM will electronically acknowledge receipt of the SAR The SPM will forward the adequately complete SAR to the ReliabilityFirst SC at which time the SC will post the SAR for comments within 15 days SARs will be posted and publicly noticed Comments on the SARs will be accepted for a 30-day period from the notice of posting Comments will be accepted online using an internet-based application The SPM will provide a copy of the comments to the Originator and the SC Based on the comments the SC shall make available a consideration of comments report and determine the disposition of the SAR (within 60 calendar days following the SAR commenting period) The disposition decision and decision process shall use the normal ldquobusiness rules and proceduresrdquo of the SC then in effect The SC may take one of the following actions3 in accordance with the ReliabilityFirst Standards Committee Governance document bull Accept the SAR as a candidate for development of a new Standard revision of an existing Standard or deletion of an existing Standard The SC may in its sole discretion expand or narrow the scope of the SAR under consideration The SC shall prioritize the development of SARs as may be required based on the number of SARs under development at any time bull Reject the SAR If the SC rejects a SAR a written explanation for rejection will be delivered to the Originator within 30 days of the decision 3Actions by the Standards Committee may be appealed per the Appeals process in Appendix A ReliabilityFirst Board Approval December 15th 2010 Page 10 of 31 bull Remand the SAR back to the Originator for redirection to the NERC process In cases where there is a Reliability need identified in the SAR but it does not meet the criteria for Regional standards (more stringent reliability requirements than the NERC reliability standard or cover matters not covered by an existing NERC reliability standard) the Standards Committee will assist the Originator in submitting the SAR to NERC bull Remand the SAR back to the Originator for additional work The SPM will make reasonable efforts to assist the Originator in addressing the deficiencies identified by the SC The Originator may then resubmit the modified SAR using the process above The Originator may choose to withdraw the SAR from further consideration prior to re-submittal to the SC Any SAR that is accepted by the SC for development of a Standard (or modification or deletion of an existing Standard) shall be posted for public viewing on the ReliabilityFirst website within 30 days of acceptance by the SC The status of posted SARs will be publicly posted Any documentation of the deliberations of the SC concerning SARs shall be made available according to the ldquoReliabilityFirst Standards Committee Governancerdquo document then in effect The SC shall submit a written report to the ReliabilityFirst Board on a periodic basis (at least at every regularly scheduled ReliabilityFirst Board meeting) showing the status of all SARs that have been brought to the SC for consideration Step 2 ndash Formation of the Standard Drafting Team and Declaration of Milestone Date Upon acceptance by the SC of a SAR for development of a new Standard (or modification or deletion of an existing Standard) the SC shall direct the SPM to develop a qualified balance slate for the SDT using the specific directions and preferences of the SC The SPM will send out self-nomination forms to solicit SDT nominees The SDT will consist of a group of people (members of ReliabilityFirst and as appropriate non-members) who collectively have the necessary technical expertise and work process skills The SPM will recommend a slate of ad-hoc individuals or a preexisting task force work group or similar for the SDT based upon the SCrsquos desired SDT capabilities The SC may also direct the SPM to designate an existing ReliabilityFirst committee (or subset thereof) as the SDT augmented by other persons as may be appropriate for the subject matter The SC will insure that SDT membership includes all necessary administrative support This support typically includes a ReliabilityFirst staff member and the Originator if heshe chooses to participate The SC appoints the interim chair (should not be a staff person) of the SDT The SDT will elect the permanent Chair and Vice-chair at its first meeting ReliabilityFirst Board Approval December 15th 2010 Page 11 of 31 The SPM submits the proposed list of names of the SDT to the SC The SC will either accept the recommendations of the SPM or modify the SDT slate as it deems appropriate within 60 days of accepting a SAR for development Upon approval of the SDT slate the SC will declare a preliminary date on which the SDT is expected to have ready a completed draft Standard and associated supporting documentation available for consideration by the ReliabilityFirst membership Step 3 ndash Work and Work Product of the Standard Drafting Team The SDT will then develop a work plan for completing the Standard development work including the establishment of milestones for completing critical elements of the work in sufficient detail to ensure that the SDT will meet the deadline established by the SC or the SDT shall propose an alternative date This plan is then delivered to the SC for its concurrence The SDT is to meet either in person or via electronic means as necessary establish sub-work teams (made up of members of the SDT) as necessary and performs other activities to address the parameters of the SAR and the milestone date(s) established by the SC The work product of the SDT will consist of the following bull A draft Standard consistent with the SAR on which it was based bull An assessment of the impact of the SAR on neighboring regions and appropriate input from the neighboring regions if the SAR is determined to impact any neighboring region bull An implementation plan including the nature extent and duration of field-testing if any bull Identification of any existing Standard that will be deleted in part or whole or otherwise impacted by the implementation of the draft Standard bull Technical reports white papers andor work papers that provide technical support for the draft Standard under consideration bull Document the perceived reliability impact should the Standard be approved Upon completion of these tasks the SDT submits these documents to the SC which will verify that the proposed Standard is consistent with the SAR on which it was developed The SDT regularly (at least once each month) informs the SC of its progress in meeting a timely completion of the draft Standard The SDT may request of the SC scope changes of the SAR at any point in the Standard development process The SC may at any time exercise its authority over the Standards development process by directing the SDT to move to Step 4 and post for comment the current work product If there are competing drafts the SC may at its sole discretion post the version(s) of the ReliabilityFirst Board Approval December 15th 2010 Page 12 of 31 draft Standard for comment on the ReliabilityFirst website The SC may take this step at any time after a SDT has been commissioned to develop the Standard Step 4 ndash Comment Posting Period At the direction from the SC the SPM then facilitates the posting of the draft Standard on the ReliabilityFirst website along with a draft implementation plan and supporting documents for a 30-day comment period The SPM shall also inform ReliabilityFirst Members and other potentially interested entities inside or outside of ReliabilityFirst of the posting using typical membership communication procedures then currently in effect or by other means as deemed appropriate As early as the start of the first posting for comment entities may join the Ballot Pool established for the eventual voting on the proposed standard The Ballot Pool category description and associated requirements are in Appendix D Within 30 days of the conclusion of 30-day comment posting period the SDT shall convene and consider changes to the draft Standard the implementation plan andor supporting technical documents based upon comments received Based upon these comments the SDT may elect to return to step 3 to revise the draft Standard implementation plan andor supporting technical documentation The SDT shall prepare a ldquomodification reportrdquo summarizing the comments received and the changes made as a result of these comments The modification report also summarizes comments that were rejected by the SDT and the reason(s) that these comments were rejected in part or whole Responses to all comments will be posted on the ReliabilityFirst website no later than the next posting of the proposed Standard Step 5 ndash Posting for Voting by ReliabilityFirst Registered Ballot Body Upon recommendation of the SDT and if the SC concurs that all of the requirements for development of the Standard have been met the SPM will post the revised draft Standard implementation plan supporting technical documentation and the ldquomodification reportrdquo Once the notice for a vote has been issued no substantive modifications may be made to the proposed standard unless the revisions are posted and a new notice of the vote is issued Entities may register in the BB at any time during the Standards process The BB category description and associated rules are in Appendix D By 1159 PM Central Prevailing Time (CPT) of the seventh day of the 15 day pre-ballot posting period registered BB members intending to vote on the proposed standard must have joined the Ballot Pool established for the eventual voting on the proposed standard being posted The SPM will schedule a Vote by the Ballot Pool which is to be scheduled to commence no sooner than 15 days and no later than 30 days following this posting The Vote by the Ballot Pool is an advisory to the ReliabilityFirst Board ReliabilityFirst Board Approval December 15th 2010 Page 13 of 31 The Ballot Pool shall be allowed to vote over a period of 15 days Votes will be submitted electronically but may be submitted through other means as approved by the SC All BB members are eligible to participate in voting on proposed new Standards Standard revisions or Standard deletions There is a requirement to join a Ballot Pool to participate in voting for each standard The voting results will be composed of only the votes from BB entities that have joined the Ballot Pool for the standard being voted on and responding within the voting period Votes may be accompanied by comments explaining the vote but are not required All comments shall be responded to and posted to the ReliabilityFirst website prior to going to the SC or Board Step 6A ndash Voting Receives Two-Thirds or Greater Majority of Affirmative Category Votes A two-thirds or greater majority4 of votes within a category determines the vote for that category The Initial ballot has passed if there is a two-thirds or greater affirmative majority of category votes (only those categories with votes cast will be considered) during the 15-day voting period and a quorum5 is met If there is at least one (1) Negative vote with comment during the initial ballot then the standard will be posted for a 10-day Recirculation ballot If there are no Negative votes with comments the SC will forward the Standard to the ReliabilityFirst Board for action (Step 7) In the recirculation ballot members of the Ballot Pool shall again be presented the proposed standard (that has not been significantly changed from the previous ballot) along with the reasons for negative votes the responses and any resolution of the differences An insignificant 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 ldquosubstantiverdquo the Standards Committee shall make the final determination 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 recirculation ballot In the recirculation ballot Ballot Pool members may indicate a revision to their original vote otherwise their vote shall remain the same as in their prior ballot Upon successful completion of the initial and recirculation voting periods the SC will forward the Standard to the ReliabilityFirst Board for action (Step 7) 4 For the purposes of determining majority within a category an abstention is not considered a vote 5 A quorum is achieved when three-fourths (75) or greater of the ballot pool casts a vote ReliabilityFirst Board Approval December 15th 2010 Page 14 of 31 Step 6B ndash Voting Does Not Receive Two-Thirds or Greater Majority of Affirmative Category Votes or a Quorum5 is Not Met If a draft Standard does not receive a two-thirds or greater affirmative majority of votes determined for each category (only those categories with votes cast will be considered) or does not reach quorum during the 15-day Initial voting period the SC may Direct the SDT to respond to ballot comments and post the standard for a 10-day Recirculation ballot (as discussed in Step 6A) to determine if the response to comments alleviates reasons for the Negative initial ballots Direct the existing SDT to reconsider or modify certain aspects of the draft Standard andor implementation plan The resulting draft Standard andor implementation plan will be posted for a second initial voting period The SC may require a second comment period prior to the second voting period The second posting of the draft Standard implementation plan and supporting documentation shall be within 60 days of the SC action o If there is a two-thirds or greater affirmative majority of categories with votes cast and a quorum is met during the second initial ballot and second recirculation ballot the SC will forward it to the ReliabilityFirst Board for action (Step 7) o If a draft Standard does not receive a two-thirds or greater majority of affirmative category votes cast during the second initial ballot or a quorum is not met the SC will refer the draft Standard and implementation plan to the ReliabilityFirst Board The SC may also submit an assessment opinion and recommendations to the ReliabilityFirst Board (Step 7) bull Revise the SAR on which the draft Standard was based and remand the development work back to the original SDT or a newly appointed SDT The resulting draft Standard andor implementation plan will be posted for a second voting period The SC may require a second comment period prior to a second voting period The second posting of the draft Standard implementation plan and supporting documentation shall be within 60 days of the SC action o If there is a two-thirds or greater affirmative majority of categories with votes cast and a quorum is met during the second initial ballot and second recirculation ballot the SC will forward it to the ReliabilityFirst Board for action (Step 7) o If a draft Standard does not receive a two-thirds or greater majority of affirmative category votes cast during the second voting period or a quorum is not met the SC will refer the draft Standard and implementation plan to the ReliabilityFirst Board The SC may also ReliabilityFirst Board Approval December 15th 2010 Page 15 of 31 submit an assessment opinion and recommendations to the ReliabilityFirst Board (Step 7) bull Recommend termination of all work on the development of the Standard action under consideration and so notify the ReliabilityFirst Board Step 7 ndash Action by the ReliabilityFirst Board A draft Standard submitted to the ReliabilityFirst Board for action must be publicly posted at least 30 days prior to action by the Board At a regular or special meeting the ReliabilityFirst Board shall consider adoption of the draft Standard The Board will consider the results of the voting and dissenting opinions The Board will consider any advice offered by the SC Draft Standards that received a two-thirds or greater of categories with votes cast shall be delivered to the ReliabilityFirst Board for their action The ReliabilityFirst Board shall be provided with an ldquoinformational packagerdquo which includes bull The draft Standard and any modification or deletion of other related existing Standard(s) bull Implementation Plan (including recommending field testing and effective dates) bull Technical Documentation supporting the draft Standard bull A summary of the vote and summary of the comments and responses that accompanied the votes The ReliabilityFirst Board is expected to either bull Approve the draft Standard action with only minor or no modification Under no circumstances may the Board substantively modify the proposed regional reliability standard bull Remand to the SC with comments and instructions or bull Disapprove the draft Standard action without recourse Draft Standards that did not receive a two-thirds or greater of categories with votes cast in the second voting period shall be delivered to the ReliabilityFirst Board for their action The ReliabilityFirst Board shall be provided with an ldquoinformational packagerdquo The ReliabilityFirst Board is expected to either bull Approve the draft Standard action with only minor or no modification Under no circumstances may the Board substantively modify the proposed regional reliability standard bull Remand to the SC with comments and instructions or bull Disapprove the draft Standard action without recourse ReliabilityFirst Board Approval December 15th 2010 Page 16 of 31 Once a regional ReliabilityFirst Standard is approved by the Board the standard will be submitted to NERC for approval and filing with FERC Step 8 - Implementation of a Regional Reliability Standard The SPM will notify the membership upon ReliabilityFirst Board approval of the standard through the normal and customary membership communication procedures and processes then in effect The SPM will also notify the ReliabilityFirst Compliance Staff for integration into the ReliabilityFirst Compliance Program The approval date of each ReliabilityFirst standard is upon Board approval The effective date will depend on the implementation plan that is provided with each new or revised standard The ReliabilityFirst standard is mandatory and enforceable (without monetary penalties for non-compliance) upon the effective date after ReliabilityFirst Board approval for applicable entities that are members of ReliabilityFirst3 ReliabilityFirst standards shall be subject to approval by NERC as the electric reliability organization and by the Federal Energy Regulatory Commission (FERC) before becoming mandatory and enforceable under Section 215 of the FPA Upon approval of a ReliabilityFirst standard action by FERC it is mandatory and enforceable (with monetary penalties for non-compliance) to all applicable entities within the ReliabilityFirst footprint The effective date for non-members upon the FERC approval will be determined by the implementation plan that is provided with each new or revised standard 3 By applying for and becoming a Regular or Associate Member of the Corporation each Member agrees to comply with all Reliability Standards all NERC standards and requirements and the other obligations of Members of the Corporation set forth in the ReliabilityFirst Bylaws or duly adopted by the Board in order to achieve the purposes of the Corporation ReliabilityFirst Board Approval December 15th 2010 Page 17 of 31 Appendix A Maintenance of Regional Reliability Standards Development Process Significant changes to this Procedure shall begin with the preparation of a SAR and be handled using the same procedure as a request to add modify or delete a Standard The ReliabilityFirst SC has the authority to make lsquominorrsquo changes to this Procedure as deemed appropriate by the SC and subject to the SC voting practices and procedures according to the ldquoReliabilityFirst Standards Committee Governancerdquo document The SC shall promptly notify the ReliabilityFirst Board of such lsquominorrsquo changes to this Procedure for their review and concurrence at the next ReliabilityFirst Board meeting Maintenance of Regional Reliability Standards The SC shall ensure that each Standard shall be reviewed at least once every five years from the effective date of the Standard or the latest revision to the Standard whichever is the later The review process shall be conducted by soliciting comments from the stakeholders If no changes are warranted the SC shall recommend to the ReliabilityFirst Board that the Standard be reaffirmed If the review indicates a need to revise or delete a Standard a SAR shall be prepared and submitted in accordance with the standards development process contained in this Procedure Urgent Action Under certain conditions the SC may designate a proposed Standard or revision to a Standard as requiring urgent action Urgent action may be appropriate when a delay in implementing a proposed Standard or revision could materially impact reliability of the BPS The SC must use its judgment carefully to ensure an urgent action is truly necessary and not simply an expedient way to change or implement a Standard A requester prepares a SAR and a draft of the proposed Standard and submits both to the SPM The SAR must include a justification for urgent action The SPM submits the request to the SC for its consideration If the SC designates the requested Standard or revision as an urgent action item then the SPM shall immediately post the draft for pre-ballot review This posting requires a minimum 30-day posting period before the ballot and applies the same voting procedure as detailed in Step 5 Processing will continue as outlined in the subsequent steps In the event additional drafting is required a SDT will be assembled as outlined in the Procedure Any Standard approved as an urgent action shall have a termination date specified that shall not exceed one year from the approval date Should there be a need to make the Standard permanent then the Standard would be required to go through the full Standard development process All urgent action Standards require ReliabilityFirst Board NERC and FERC approval as outlined for Standards in the regular process ReliabilityFirst Board Approval December 15th 2010 Page 18 of 31 Urgent actions that expire may be renewed using the urgent action process again in the event a permanent Standard is not adopted In determining whether to authorize an urgent action Standard for a renewal ballot the SC shall consider the impact of the Standard on the reliability of the BPS and whether expeditious progress is being made toward a permanent replacement Standard The SC shall not authorize a renewal ballot if there is insufficient progress toward adopting a permanent replacement Standard or if the SC lacks confidence that a reasonable completion date is achievable The intent is to ensure that an urgent action Standard does not in effect take on a degree of permanence due to the lack of an expeditious effort to develop a permanent replacement Standard With these principles there is no predetermined limit on the number of times an urgent action may be renewed However each urgent action Standard renewal shall be effective only upon approval by the ReliabilityFirst Board NERC and FERC Any person or entity including the SDT working on a permanent replacement Standard may at any time submit a SAR proposing that an urgent action Standard become a permanent Standard by following the full Standards process Interpretations of Standards All persons who are directly and materially affected by the reliability of ReliabilityFirst BPS shall be permitted to request an interpretation of the standard The person requesting an interpretation will send a request to the SPM explaining the specific circumstances surrounding the request and what clarifications are required as applied to those circumstances The request should indicate the material impact to the requesting party or others caused by the lack of clarity or a possibly incorrect interpretation of the standard The SPM along with guidance from the SC will assemble a team with the relevant expertise to address the request The Interpretation Drafting Team (IDT) typically consists of members from the original SDT The SPM submits the proposed list of names of the IDT to the SC The SC will either accept the recommendations of the SPM or modify the IDT slate As soon as practical (not more than 45 days) the team will prepare an initial draft interpretation of the standard addressing the issues raised Once the IDT has completed the initial draft interpretation the team will post the draft for a 30-day informal6 stakeholder comment period The IDT will review the stakeholder feedback and may make changes before preparing a final draft of the interpretation The IDT will then forward the draft interpretation to the SPM The SPM will forward the interpretation to the Reliability Committee (RC) Barring receipt of an opinion from the RC within 21 calendar days that the interpretation is not technically appropriate for the Standard 6 An informal comment period does not require the IDT to respond to every stakeholder comment and is only used to make potential changes for the final draft of the interpretation ReliabilityFirst Board Approval December 15th 2010 Page 19 of 31 respectively the SPM will forward the interpretation to the SC The SC will determine if the interpretation is consistent with the Standard and does not add additional requirements to the standard The SC will forward the interpretation to the ReliabilityFirst Board for informational purposes as being appended to the approved Standard Note In the event that the RC determines that the interpretation makes the standard technically inappropriate the RC shall provide an explanation of its reasoning to the SPM and IDT for inclusion in a subsequent revision In either case the IDT and SPM will continue to re-circulate the interpretation as stated above The interpretation will stand until such time as the standard is revised through the normal process at which time the standard will be modified to incorporate the clarifications provided by the interpretation Appeals Persons who have directly and materially affected interests and who have been or will be adversely affected by any substantive or procedural action or inaction related to the development approval revision reaffirmation or withdrawal of a Standard shall have the right to appeal This appeals process applies only to the Standards process as defined in this Procedure The burden of proof to show adverse effect shall be on the appellant Appeals shall be made 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 In all cases the request for appeal must be made prior to the next step in the process The final decisions of any appeal shall be documented in writing and made public The appeals process has two levels with the goal of expeditiously resolving the issue to the satisfaction of the participants Level 1 Appeal Level 1 is the required first step in the appeals process The appellant submits a complaint in writing to the SPM that describes the substantive or procedural action or inaction associated with a Standard or the standards process The appellant describes in the complaint the actual or potential adverse impact to the appellant Assisted by any necessary staff and committee resources the SPM 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 will be made a part of the public record associated with the standard Level 2 Appeal ReliabilityFirst Board Approval December 15th 2010 Page 20 of 31 If after the Level 1 Appeal the appellant remains unsatisfied with the resolution as indicated by the appellant in writing to the SPM the SPM shall convene a Level 2 Appeals Panel This panel shall consist of five members total appointed by the ReliabilityFirst Board In all cases Level 2 Appeals Panel members shall have no direct affiliation with the participants in the appeal The SPM 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 person that is directly and materially affected by the substantive or 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 SC 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 appellantrsquos objections The panel may not however revise approve disapprove or adopt a reliability standard 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 ReliabilityFirst Board for consideration at the time the Board decides whether to adopt a particular reliability standard The objection must 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 must be filed no later than 30-days after the announcement of the vote on the Standard in question ReliabilityFirst Board Approval December 15th 2010 Page 21 of 31 Appendix B Standard Authorization Request The SC shall be responsible for implementing and maintaining this form as needed to support the information requirements of the standards development process in this Procedure Changes to this form are considered minor and therefore subject to only the approval of the SC ReliabilityFirst Standard Authorization Request Form ReliabilityFirst will complete ID Authorized for Posting Authorized for Development Title of Proposed Standard Request Date SAR Originator Information Name SAR Type (Check box for one of these selections) Company New Standard Telephone Revision to Existing Standard Fax Withdrawal of Existing Standard E-mail Urgent Action Purpose (Provide one or two sentences) Industry Need (Provide one or two sentences) ReliabilityFirst Board Approval December 15th 2010 Page 22 of 31 Brief Description (A few sentences or a paragraph) Reliability Functions The Standard will Apply to the Following Functions (Check box for each one that applies) Reliability Authority Ensures the reliability of the bulk transmission system within its Reliability Authority area This is the highest reliability authority Balancing Authority Integrates resource plans ahead of time and maintains load-interchange-resource balance within its metered boundary and supports system frequency in real time Generator Owner Owns and maintains generating units Interchange Authority Authorizes valid and balanced Interchange Schedules Planning Authority Plans the BPS Resource Planner Develops a long-term (generally one year and beyond) plan for the resource adequacy of specific loads (customer demand and energy requirements) within a Planning Authority Area Transmission Planner Develops a long-term (generally one year and beyond) plan for the reliability (adequacy) of the interconnected bulk electric transmission systems within its portion of the Planning Authority Area Transmission Service Provider Provides transmission services to qualified market participants under applicable transmission service agreements Transmission Owner Owns transmission facilities Transmission Operator Operates and maintains the transmission facilities and executes switching orders Distribution Provider Provides and operates the ldquowiresrdquo between the transmission system and the customer ReliabilityFirst Board Approval December 15th 2010 Page 23 of 31 Generator Operator Operates generating unit(s) and performs the functions of supplying energy and Interconnected Operations Services Purchasing-Selling Entity The function of purchasing or selling energy capacity and all necessary Interconnected Operations Services as required Load-Serving Entity Secures energy and transmission (and related generation services) to serve the end user Market Operator Integrates energy capacity balancing and transmission resources to achieve an economic reliability-constrained dispatch of resources The dispatch may be either cost-based or bid-based Regional Reliability Organizations An entity that ensures that a defined area of the BPS is reliable adequate and secure A member of the North American Electric Reliability Council The Regional Reliability Organization can serve as the Compliance Monitor NOTE The SDT may find it necessary to modify the initial reliability function responsibility assignment as a result of the standards development and comments received Reliability Principles Applicable Reliability Principles (Check box for all that apply) 1 Interconnected BPS 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 BPS 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 BPS 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 BPS 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 BPS 6 Personnel responsible for planning and operating interconnected BPS shall be trained qualified and have the responsibility and authority to implement actions 7 The security of the interconnected BPS shall be assessed monitored and maintained on a wide-area basis ReliabilityFirst Board Approval December 15th 2010 Page 24 of 31 Market Interface Principles Does the proposed Standard comply with all of the following Market Interface Principles Recognizing that reliability is an essential requirement of a robust North American economy yes or no 1 A reliability standard shall not give any market participant an unfair competitive advantage yes or no 2 A reliability standard shall neither mandate nor prohibit any specific market structure yes or no 3 A reliability standard shall not preclude market solutions to achieving compliance with that standard yes or no 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 ReliabilityFirst Board Approval December 15th 2010 Page 25 of 31 Detailed Description (Provide enough detail so that an independent entity familiar with the industry could draft a Standard based on this description) ReliabilityFirst Board Approval December 15th 2010 Page 26 of 31 Related Standards (NERC and Regional) Standard No Explanation Related SARs SAR ID Explanation ReliabilityFirst Board Approval December 15th 2010 Page 27 of 31 Implementation Plan Description (Provide plans for the implementation of the proposed standard including any known systems or training requirements Include the reliability risk(s) associated with the violation that the standard will mitigate and the costs associated with implementation) Proposed Implementation days after Board adoption or on (date) Assignments Assignment Team Members ReliabilityFirst Staff ReliabilityFirst Board Approval December 15th 2010 Page 28 of 31 Appendix C Flowchart for Standards Process Step 1 SC Action Remand SAR Accept SAR Reject SAR Post Request for SDT Step 2 Appoint SDT Draft Standard Step 3 Edit Format Grammar Spelling SC Authorizes 30-Day Posting for Comments Step 4 Posting of Draft Standard for Comments SDT Convenes to Respond to CommentsModify Standard SAR Comment Period Originator Submits SAR to SPM Remand SAR amp Redirect to NERC ReliabilityFirst Board Approval December 15th 2010 Page 29 of 31 Initial Category Vote SC Action Revise SAR Terminate Standard Direct SDT to Revise Standard SC Assessment File for NERCFERC approval and implement standard throughout RFC footprint 2nd Category Vote Two-Thirds or Greater Affirmative Two-Thirds or Greater Affirmative Yes No Yes No SC Forwards to Board Step 5 Step 6B Step 6A Step 7 Negative vote with comments No Recirculation Vote Yes Two-Thirds or Greater Affirmative Yes A Implement standard for RFC member companies No B Yes Board Approval No A B A Step 8 ReliabilityFirst Board Approval December 15th 2010 Page 30 of 31 Appendix D Ballot Pool Categories For the purposes of category Ballot Pool registration and voting a person or entity may join the registered Ballot Pool to vote on standards whether or not such person or entity is a member of ReliabilityFirst A corporation or other organization with integrated operations or with affiliates that qualifies to belong to more than one category (eg Transmission Owners and Load Serving Entities) may join and vote once in each category for which it qualifies provided that each category constitutes a separate membership in the Ballot Body and the organization is represented in each category by a different representative Affiliated entities are collectively limited to one membership in each category in the Ballot Pool for which they are qualified Category 1 ndash Transmission Owner Transmission Operator Transmission Service Provider Category 2 ndash Generator Owner Generator Operator Category 3 ndash Load Serving Entity Purchasing and Selling Entity End User Category 4 ndash Reliability Coordinator Planning Coordinator Transmission Planner Resource Planner Regional Transmission Organization Balancing Authority regulatory or governmental agency Category 5 ndash Distribution Provider Ballot Body Registration Entities may register in the BB at any time during the Standards process The SPM shall review all applications for joining the BB and make a determination of whether they qualify for the self-selection category In order to comment or vote you must have an active membership in the BB When you submit your registration request to join the BB you are placed in a ldquopending stagerdquo until your account is activated Activation of your account may take up to 24 hours You will be unable to submit comments or join a Ballot Pool until your account is activated The contact designated as primary representative to ReliabilityFirst is the voting member with the secondary contact as the backup Note Registration for a BB is not the same as registration for the compliance registry Although the terminology used to describe the BB categories in most cases has the same meaning as the terms used in the NERC Functional Model registration in a BB goes beyond the compliance registry in that entities smaller than those stated in the compliance ReliabilityFirst Board Approval December 15th 2010 Page 31 of 31 ReliabilityFirst Board Approval December 15th 2010 Page 32 of 31 registry guidelines are allowed to register in a BB Entities shall have evidence that they qualify for the BB category they register in Such evidence shall be available for the SPM review to verify BB registration and may include compliance registration Ballot Pool Formation In order to participate in voting on a particular standard an entity must join the Ballot Pool being established for the standard as follows 1 ndash As early as the start of the first posting for comment entities may join the Ballot Pool established for the eventual voting on the proposed standard being posted 2 - By close of business of the seventh day of the 15 day pre ballot posting period entities wishing to vote must have joined the Ballot Pool established for the eventual voting on the proposed standard being posted Attachment B ReliabilityFirst Standards Development Procedure Revised December 15 2010 (Redline) ReliabilityFirst Reliability Standards Development Procedure Board Approval December 6th 2007 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 ReliabilityFirst Corporation Reliability Standards Development Procedure ReliabilityFirst Reliability Standards Development Procedure Board Approval December 6th 2007 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 ReliabilityFirst Reliability Standards Development Procedure Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Formatted Font 10 pt Formatted Font 10 pt Formatted Font 10 pt Version 3 ReliabilityFirst Corporation Reliability Standards Development Procedure Table of Contents Introduction 1 Background 2 Regional Reliability Standard Definition Characteristics and Elements 3 Roles in the Regional Reliability Standards Development Process 7 Regional Reliability Standards Development Process 8 Appendix A Maintenance of Regional Reliability Standards Development Processhelliphelliphellip17 ReliabilityFirst Reliability Standards Development Procedure Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Formatted Font 10 pt Formatted Font 10 pt Formatted Font 10 pt Appendix B Standard Authorization Request 21 Appendix C Flowchart for Standards Process 28 Appendix D Ballot Pool Categories and Registration 30 ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 1 of 31 Formatted Font 10 pt Formatted Font 10 pt ReliabilityFirst Corporation Reliability Standards Development Procedure Introduction This procedure establishes the process for adoption of a Regional Reliability Standard1 (hereinafter referred to as ldquoStandardrdquo) of the ReliabilityFirst Corporation (ReliabilityFirst) and the development of consensus for adoption approval revision reaffirmation and deletion of such Standards1 ReliabilityFirst Standards provide for the reliable regional and sub-regional planning and operation of the Bulk Power System2 (BPS) consistent with Good Utility Practice2 within the ReliabilityFirst geographical footprint This procedure was developed under the direction of the ReliabilityFirst Board of Directors (Board) who may request changes to this ReliabilityFirst Reliability Standards Development Procedure (hereinafter referred to as ldquothis Procedurerdquo) as deemed appropriate A procedure for revising this Procedure is contained in Appendix A This Procedure is consistent with the North American Electric Reliability CouncilCorporation (NERC) Reliability Standards Development Procedure Proposed StandardsReliabilityFirst standards shall be subject to approval by NERC as the electric reliability organization and by the Federal Energy Regulatory Commission (FERC) before becoming mandatory and enforceable under Section 215 of the FPA No Standard shall be effective within the ReliabilityFirst area unless filed by NERC with FERC and approved by FERC The approval date of each ReliabilityFirst standard is upon ReliabilityFirst Board approval The effective date will depend on the implementation plan that is provided with each new or revised standard The ReliabilityFirst standard is mandatory and enforceable (without monetary penalties for non-compliance) upon the effective date after ReliabilityFirst Board approval for applicable entities that are members of ReliabilityFirst3 The ReliabilityFirst standard is mandatory and enforceable (with monetary penalties for non-compliance) to all applicable entities within the ReliabilityFirst footprint upon approval by FERC The effective date for non-members upon the FERC approval will be determined by the implementation plan that is provided with each new or revised standard 1 Legacy standards such as ECAR Documents MAIN Guides and MAAC Procedures shall be considered ReliabilityFirst Regional Reliability Standards for the purposes of this document until otherwise acted upon by the ReliabilityFirst Board 2 As defined in the ReliabilityFirst By-laws 3 By applying for and becoming a Regular or Associate Member of the Corporation each Member agrees to comply with all Reliability Standards all NERC standards and requirements and the other obligations of Members of the Corporation set forth in the ReliabilityFirst Bylaws or duly adopted by the Board in order to achieve the purposes of the Corporation Formatted Adjust space between Latin andAsian text Adjust space between Asian textand numbers ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 2 of 31 Formatted Font 10 pt Formatted Font 10 pt ReliabilityFirst Standards shall provide for as much uniformity as possible with NERC reliability standards across the interconnected BPS A ReliabilityFirst Standard shall be more stringent than a NERC reliability standard including a regional difference that addresses matters that the NERC reliability standard does not or shall be a regional difference necessitated by a physical difference in the BPS A ReliabilityFirst Standard that satisfies the statutory and regulatory criteria for approval of proposed NERC reliability standards and that is more stringent than a NERC reliability standard would generally be acceptable ReliabilityFirst Standards when approved by FERC shall be made part of the body of NERC reliability standards and shall be enforced upon all applicable BPS owners operators and users within the ReliabilityFirst area regardless of membership in the region Background Regions may develop through their own processes separate ldquoRegional Standardsrdquo (ReliabilityFirst Standards) that go beyond add detail to or implementaid implementation of NERC reliability standards or otherwise address issues that are not addressed in NERC reliability standards As a condition of ReliabilityFirst membership all ReliabilityFirst Members2 agree to adhere to the NERC reliability standards As such the ReliabilityFirst and its Members will adhere to the NERC reliability standards in addition to the ReliabilityFirst Standards NERC reliability standards and the ReliabilityFirst Standards are both to be included within the ReliabilityFirst Compliance Program ReliabilityFirst Standards are intended to apply only to that part of the Eastern Interconnection within the ReliabilityFirst geographical footprint The development of these ReliabilityFirst Standards is developed according to the following principles via the process contained within this Procedure bull Developed in a fair and open process that provided an opportunity for all interested parties to participate bull Does not have an adverse impact on commerce that is not necessary for reliability bull Provides a level of BPS reliability that is adequate to protect public health safety welfare and national security and would not have a significant adverse impact on reliability and bull Based on a justifiable difference between Regions or between sub-Regions within the Regional geographic area 2 As defined in the ReliabilityFirst By-laws Formatted Outline numbered + Level 1 +Numbering Style Bullet + Aligned at 025 +Tab after 05 + Indent at 05 ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 3 of 31 Formatted Font 10 pt Formatted Font 10 pt Regional Reliability Standard Definition Characteristics and Elements Definition of a Reliability Standard As contained in the ReliabilityFirst By-laws ReliabilityFirst ldquoRegional Reliability Standardrdquo shall mean a type of Reliability Standard that is applicable only within a particular Regional Entity or group of Regional Entities A Regional Reliability Standard may augment add detail to or implement another Reliability Standard or cover matters not addressed by other Reliability Standards Regional Reliability Standards upon adoption by NERC and approval by the Commission shall be Reliability Standards and shall be enforced within the applicable Regional Entity or Regional Entities pursuant to delegated authorities Inherent in this definition a ReliabilityFirst Standard will define certain obligations or requirements of entities that own operate plan and use the BPS within the ReliabilityFirst geographical footprint These obligations or requirements as contained in the ReliabilityFirst Standards are to be measurable and consistent with Good Utility Practice Standards are not to include processes or procedures that implement a Standard In addition obligations requirements or procedures imposed upon ReliabilityFirst by NERC reliability standards are not to be ReliabilityFirst Standards unless those obligations requirements or procedures require the establishment of a ldquopolicy or standardrdquo as defined by the ReliabilityFirst By-laws Characteristics of a Regional Reliability Standard A Standard is policy or standard including adequacy criteria to provide for the reliable regional and sub-regional planning and operation of the BPS consistent with Good Utility Practice A Standard shall generally have the following characteristics bull Measurable - A Standard shall establish technical or performance requirements that can be practically measured bull Relative to NERC Reliability Standards - A Standard generally must go beyond add detail to or implement NERC Reliability Standards or cover matters not addressed in NERC Reliability Standards Format Requirements of a Regional Reliability Standard A Standard shall consist of the format requirements shown in the Regional Reliability Standard Template These requirements apply to the development and revision of Standards These requirements are necessary to achieve Standards that are measurable Formatted Outline numbered + Level 1 +Numbering Style Bullet + Aligned at 025 +Tab after 05 + Indent at 05 Formatted Outline numbered + Level 1 +Numbering Style Bullet + Aligned at 025 +Tab after 05 + Indent at 05 ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 4 of 31 Formatted Font 10 pt Formatted Font 10 pt enforceable and consistent Supporting documents to aid in the implementation of a Standard may be referenced by the Standard but are not part of the Standard itself The most current version of the approved NERC Reliability Standard template and its associated elements posted on the NERC website will be used at the time of the development of a ReliabilityFirst Regional Reliability Standard if different from the elements listed below Regional Reliability Standard Format Requirement Template Example Identification Number A unique identification number assigned in accordance with an administrative classification system to facilitate tracking and reference ReliabilityFirst documentation Title A brief descriptive phrase identifying the topic of the Standard Applicability Clear identification of the functional classes of entities responsible for complying with the Standard noting any specific additions or exceptions If not applicable to the entire ReliabilityFirst area then a clear identification of the portion of the BPS to which the Standard applies Any limitation on the applicability of the Standard based on electric facility requirements should be described Effective Date and Status The effective date of the Standard or prior to approval of the Standard the proposed effective date Purpose The purpose of the Standard The purpose shall explicitly state what outcome will be achieved or is expected by this Standard Requirement(s) Explicitly stated technical performance and preparedness requirements Each requirement identifies what entity is responsible and what action is to be performed or what outcome is to be achieved EachCompliance is mandatory for each statement in the requirements section shall be a statement for which compliance is mandatory Formatted Table ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 5 of 31 Formatted Font 10 pt Formatted Font 10 pt Risk Factor(s) The potential reliability significance of each requirement designated as a High Medium or Lower Risk Factor in accordance with the criteria listed below A High Risk Factor requirement (a) is one that if violated could directly cause or contribute to BPS instability separation or a cascading sequence of failures or could place the BPS at an unacceptable risk of instability separation or cascading failures or (b) is a requirement in a planning timeframe that if violated could under emergency abnormal or restorative conditions anticipated by the preparations directly cause or contribute to BPS instability separation or a cascading sequence of failures or could place the BPS at an unacceptable risk of instability separation or cascading failures or could hinder restoration to abnormal condition A Medium Risk Factor requirement (a) is a requirement that if violated could directly affect the electrical state or the capability of the BPS or the ability to effectively monitor and control the BPS but is unlikely to lead to BPS instability separation or cascading failures or (b) is a requirement in a planning timeframe that if violated could under emergency abnormal or restorative conditions anticipated by the preparations directly affect the electrical state or capability of the BPS or the ability to effectively monitor control or restore the BPS but is unlikely under emergency abnormal or restoration conditions anticipated by the preparations to lead to BPS instability separation or cascading failures nor to hinder restoration to a normal condition A Lower Risk Factor requirement is administrative in nature and (a) is a requirement that if violated would not be expected to affect the electrical state or capability of the BPS or the ability to effectively monitor and control the BPS or (b) is a requirement in a planning time frame that if violated would not under the emergency abnormal or restorative conditions anticipated by the preparations be expected to affect the electrical state or capability of the BPS or the ability to effectively monitor control or restore the BPS Measure(s) Each requirement shall be addressed by one or more measurements Measurements that will be used to assess performance and outcomes for the purpose of determining compliance with the requirements stated above Each measurement identifies to whom the measurement applies Each measurement shall be tangible practical and as objective as is practical Achieving the full compliance level of each measurement should beis a necessary and sufficient indicator that the requirement was met Compliance Administration Elements ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 6 of 31 Formatted Font 10 pt Formatted Font 10 pt Compliance Monitoring Process Defines for each measure bull The specific data or information that is required to measure performance or outcomes bull The entity that is responsible to provide the data or information for measuring performance or outcomes bull The process that will be used to evaluate data or information for the purpose of assessing performance or outcomes bull The entity that is responsible for evaluating data or information to assess performance or outcomes bull The time period in which performance or outcomes is measured evaluated and then reset bull Measurement dataData retention requirements and assignment of responsibility for data archiving bull Violation severity levels Formatted Indent Left 018 Hanging 013 Outline numbered + Level 1 +Numbering Style Bullet + Aligned at 025 +Tab after 05 + Indent at 05 ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 7 of 31 Formatted Font 10 pt Formatted Font 10 pt Supporting Information Elements Interpretations Any ReliabilityFirst interpretations of the Standards that were developed and approved in accordance with the ldquoInterpretation of Standardsrdquo section of this Procedure to expound on the application of the Standard for unusual or unique situations or provide clarifications Implementation Plan Each ReliabilityFirst Standard shall have an associated implementation plan describing the effective date of the Standard or effective dates if there is a phased implementation The implementation plan may also describe the implementation of the Standard in the compliance program and other considerations in the initial use of the Standard such as necessary tools training etc The implementation plan must be posted for at least one public comment period and isbe approved as part of the ballot of the standard Supporting References This section references related documents that support reasons for or otherwise provide additional information related to the Standard Examples include but are not limited to bull Glossary of Terms bull Developmental history of the Standard and prior versions bull Subcommittee(s) responsible for Standard bull Notes pertaining to implementation or compliance bull Standard references bull ProceduresPractices bull Training andor Technical Reference Roles in the Regional Reliability Standards Development Process Process Roles Originator - Any entity (person organization company government agency individual etc) that is directly and materially affected by the reliability of the ReliabilityFirst BPS is allowed to request a Standard be developed or an existing Standard is modified or deleted by creating a Standards Authorization Request (SAR) See Appendix B Board ndash The ReliabilityFirst Board shall act on any proposed Standard that has gone through the process contained in this Procedure Once the ReliabilityFirst Board approves a Standard compliance with the Standard will be enforced consistent with the By-laws and the terms of the Standard Standards Committee (SC) - The ReliabilityFirst SC will consider which requests for new or revised Standards shall be assigned for development (or existing Standards considered for deletion) The SC manages the Standards development process The SC Formatted Table Formatted Indent Left 015 Hanging 013 Outline numbered + Level 1 +Numbering Style Bullet + Aligned at 025 +Tab after 05 + Indent at 05 Tab stops 028 List tab ReliabilityFirst Board Approval December 6th 200715th 2010 Standards Committee Modified April 1st 2008 - Board Concurrence May 22nd 2008 Page 8 of 31 Formatted Font 10 pt Formatted Font 10 pt will advise the ReliabilityFirst Board on Standards presented for adoption by the ReliabilityFirst Board Standards Process Manager (SPM) ndash A person or persons on the ReliabilityFirst staff assigned the task of ensuring that the development revision or deletion of Standards is in accordance with this Procedure The SPM works to ensure the integrity of the process and consistency of quality and completeness of the Standards The SPM facilitates the administration of all actions contained in all steps in the process Standards Process Staff ndash Employees of the ReliabilityFirst that work with or for the SPM Interim Compliance Committee (ICC) ndash The ReliabilityFirst committee responsible for the administration of the ReliabilityFirst Compliance Program The duties of this committee includes but not limited to providing inputs and comments during the standards development process to ensure the measures will be effective and other aspects of the Compliance Program can be practically implemented Standard Drafting Team (SDT) ndash Normally aA team of technical experts and typically includesincluding a member of the ReliabilityFirst Standards staff and the Originator assigned the task of developing a proposed Standard based upon an approved SAR using the Standard development process contained in this Procedure Ballot Body (BB) ndash The Ballot Body comprises all entities that qualify for one or more of the categories and are registered with ReliabilityFirst as potential ballot participants in the voting on standards The categories of registration within the Ballot Body and the registration process are described in Appendix D Ballot Pool ndash The Ballot Pool is comprised of those members of the Ballot Body that register to vote for each particular standard that is up for vote A separate Ballot Pool is established for each standard up for vote Only individuals who have joined the Ballot Pool for that particular standard are eligible to vote on a standard Reliability Committee (RC) ndash The ReliabilityFirst RC serves as a technical advisory body to address the reliability related activities required by the Reliability Standards via review and discussion of the regional activities as requested by the SC Regional Reliability Standard Development Process (Flow chart of Process shown in Appendix C) Assumptions and Prerequisites The ReliabilityFirst Regional Reliability Standards Development Process has the following characteristicsimage1png