Recent FERC Activity Highlights nad Minutes … · Recent FERC Activity Andy Dodge Director, Office of Electric Reliability. Federal Energy Regulatory Commission. May 14, 2020. The

Recent FERC ActivityAndy DodgeDirector, Office of Electric ReliabilityFederal Energy Regulatory CommissionMay 14, 2020

The views expressed in this presentation are my own and do not represent those of the Commission or any individual Commissioner

Commission Actions on COVID-19 Pandemic

• Pandemic Liaison Team created to coordinate answers to industry questions• Caroline Wozniak named as the Pandemic Liaison

• Contact: [email protected]• OER contacts: Mark Hegerle and Kal Ayoub

• Notice Granting Extension of Time, AD20-11-000 issued 3/19/20• Extends deadline for filing forms, non-statutory filings (e.g.,

compliance filings, responses to data requests, rulemakings) until 5/1/20

• OER team proposed numerous other actions, including delay of effective date of certain Reliability Standards

• Joint Commission-NERC Notice on regulatory discretion issued 3/18/20 2

mailto:[email protected]

FERC, NERC Guidance to Ensure Reliability Amid Potential Coronavirus Impacts

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• On 3/18, FERC and NERC announced that they will use their regulatory discretion to ensure all registered entities can balance healthy workforce and reliability

• Effects of coronavirus will be considered an acceptable basis for non-compliance with: • Obtaining and maintaining personnel certification to comply

with PER-003-2 for the period 3/1/20 to 12/31/20• Reliability Standard requirements involving periodic actions

that would have been taken between 3/1/20 and 7/31/20• Registered entities should notify their Regional Entities of

any periodic actions that will be missed during this period • Regional Entities will postpone on-site audits, certifications

and other on-site activities at least until 7/31/20 • FERC and NERC may extend these dates as needed

Further Commission Action to Prioritize Reliability and Provide Regulatory Relief

• Policy Statement on Business Continuity of Energy Infrastructure issued 4/2/20• Commission will give highest priority to processing filings made to assure the

reliable operation of energy infrastructure during COVID-19 emergency• Facilitates social distancing by approving blanket waiver of tariff requirements on

holding in-person meetings and requiring notarized documents through 9/1/20• Prioritizes efficient processing of requests for waiver and other requests for relief:

• Delegates authority to OEMR to act on uncontested requests for prospective waivers of certain regulatory obligations through 6/1/20

• Delegates authority to OEPI to act on motions for extension of time to file, or requests or petitions for waiver of the requirements of FERC Form No. 552 and FERC-730

• Extends time period for RTOs/ISOs to post Uplift Reports and Operator Initiated Commitment Reports

• Grants extensions of time for certain non-statutory deadlines, waiving regulations and shortening answer periods for extensions of time due to COVID-19

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Order Granting Deferred Implementation of Certain NERC Reliability Standards • Order RM15-4, RM16-22, RM17-13 and RD18-4 issued 4/17/20• Grants three-month deferral of the implementation of Reliability Standards:

• CIP-005-6 (Cyber Security – Electronic Security Perimeter(s))• CIP-010-3 (Cyber Security – Configuration Change Management and

Vulnerability Assessments) • CIP-013-1 (Cyber Security – Supply Chain Risk Management)

• Grants six-month deferral of the implementation of Reliability Standards: • PRC-002-2 (Disturbance Monitoring and Reporting Requirements) • PRC-025-2 (Generator Relay Loadability) • PRC-027-1 (Coordination of Protection Systems for Performance During

Faults) • PER-006-1 (Specific Training for Personnel)

• Commission recognizes that registered entities have already taken steps to ensure effective and timely implementation of these standards

• Deferred implementation is a proportionate and reasonable response to deal with COVID-19 that will allow registered entities to focus immediate efforts and resources on maintaining safety and ensuring reliability of the grid 5

Virtualization, Cloud Services for Power Grid Operations • NOI in RM20-8, RD20-2 issued 2/20/20• Seeks comments on potential benefits and risks of virtualization and

cloud computing services in the bulk electric system operations and barriers to FERC-approved Critical Infrastructure Protection (CIP) Reliability Standards

• Poses questions on four general topics: • Scope of potential use of virtualization or cloud computing• Associated benefits and risks• Possible impediments to their implementation• Potential new and emerging technologies beyond virtualization• Cloud computing that responsible entities may be interested in

adopting• The Commission will use the NOI to decide whether to direct NERC to

develop modifications to the CIP reliability standards to facilitate the use of virtualization and cloud computing by grid users and operators

• Comments were due 4/27/20; reply comments due 5/27/20• Initial and reply comments in the Virtualization and Cloud NOI

extended to 7/1/20 and 7/31/20, respectively6

Delays on Reliability & Security Related Actions

• OER has postponed all on-site audit activities in coordination with NERC and the Regional Entities

• Reliability Technical Conference postponed from 6/25/20 to a future date to be determined

• Compliance filings related to the NERC Five-Year Performance Assessment extended to 6/1/20 and 9/28/20

• Initial and reply comments in the Virtualization and Cloud NOI extended to 7/1/20 and 7/31/20, respectively

• Time extended for NERC/WECC filing related to BAL-002-WECC to 6/3/20

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Transmission Incentives NOPR

• NOPR in RM20-10 issued 3/20/20• Proposes to revise existing regulations implementing section 219 of

the FPA to align Commission policy with statutory mandate of ensuring reliability and reducing transmission congestion

• Proposes to depart from the risks and challenges approach and instead focus on granting incentives based on economic and reliability benefits

• NOPR proposes to provide incentives for:• Joining/remaining in an RTO/ISO (increased from 50 to 100 basis points)• Projects that meet a pre-construction benefit-to-cost ratio (50 pts) and

projects that meet a post-construction benefit-to-cost ratio (50 pts)• Projects that demonstrate reliability benefits (up to 50 pts)• Technologies that enhance existing transmission facilities (100 pts)

• Comments due 7/1/208

Technical Conference on Storage as a Transmission Only Resource• Staff-led workshop in ER20-588 held 5/4 via WebEx• MISO has proposed to allow for the selection of a storage facility as a

transmission-only asset (SATOA) in the MISO Transmission Expansion Plan (MTEP)

• On 3/10, the Commission issued an order accepting and suspending the proposed revisions for five months and establishing a technical conference

• Technical conference addressed:• Evaluation and selection criteria for SATOAs• SATOA market activities and market impacts• Cost recovery for SATOA• Impact on the generator interconnection queue• Operating guides for SATOAs

• Commission will consider post conference comments submitted on or before 5/25/20

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Upcoming Conferences

• Technical Conference on Increasing Market and Planning Efficiency and Enhancing Resilience through Improved Software • To be held 6/23/20 – 6/25/20 in AD10-12-011 via WebEx• Will explore research and operational advances with respect to

market modeling with potential for efficiency or resilience improvements

• Topics will include representation of physical constraints, managing uncertainty, grid enhancing technologies, system flexibility, et al.

• Technical Conference on Hybrid Resources• To be held 7/23/20 in AD20-9-000 (location TBD)• Will discuss technical and market issues prompted by growing

interest in projects comprised of more than one resource type at same plant location (hybrid resources)

• Commission will focus on a generation resource and an electric storage resource paired together as a hybrid resource

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Commission Meetings

• Commission meetings will be held in virtual format during COVID-19 pandemic

• April Open Meeting was held in virtual format with virtual press conference

• Next Commission meeting: 5/21/20• Commission meetings will be held using virtual format for the

foreseeable future

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Stay Home, Stay Safe!

• Thank you!

• Questions?

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RELIABILITY | RESILIENCE | SECURITY

Update on Cloud Computing

Lonnie J Ratliff, Senior Manager, Cyber and Physical Security AssuranceMember Representatives Committee MeetingMay 14, 2020

RELIABILITY | RESILIENCE | SECURITY2

Seeking benefits and risks with virtualization and cloud services

• ERO Enterprise Collaboration Potential Risks Identified Current Standard considerations and impacts

• Standard Drafting Team (SDT) focus Project 2016-02 - Virtualization Project 2019-02 - BES Cyber Security Information (BCSI)

FERC Notice of Inquiry


• ERO Enterprise Practice Guide providing clarification Focus on the ability “obtain and use” Physical access compared to controls deployed to secure data (e.g., cloud

storage)

• Input to and collaboration with SDT

Storage of BCSI


• Cloud-based solutions increasing and more common Office 365 ServiceNow

• Demonstrating Compliance Managing encryption keys (Entity versus third-party) Third-party managing encryption keys

• Consideration of third-party certifications FedRAMP/SOC GAGAS Independence and Using the Work of Others

• Moving Forward…

Cloud-based Service Models


RELIABILITY | RESILIENCE | SECURITY

2020 Summer Reliability AssessmentPreview

John Moura, Director, Reliability AssessmentsMember Representatives Committee MeetingMay 14, 2020


• NERC published Pandemic Preparedness and Operational Assessment – Spring 2020 to advise about elevated risk profile potential workforce disruptions potential supply chain interruptions increased cybersecurity threats

• NERC Summer Reliability Assessment (SRA) will continue to assess risks to the reliability and security of the BPS and report on industry actions and preparedness in the SRA

Pandemic Special Report


• Pandemic risk differs from many of the other threats facing the BPS because it is a “people event.”

• The fundamental risk is the loss of critical staff needed to operate and maintain the BPS.

• Managing abnormal system conditions, preventive and corrective maintenance, prolonged outages, system operations and control room continuity.

• Pandemic-driven workforce constraints could affect the ability of organizations to provide mutual assistance

Pandemic and Mitigation Strategy Risks


NERC Response

• February 5, 2020 all-points bulletin issued• Heighted awareness surrounding pandemic related issues• Coordination with the Electricity Subsector Coordinating Council (ESCC)

E-ISAC

• March 10, 2020 NERC alert issued with six recommendations for industry to pursue related to the pandemicNERC Alerts

• Initiate special assessment on Spring operations• Focus on Summer 2020 preparations• Event analysis and lessons learned

Reliability Assessment

• Operating Reliability Subcommittee, weekly status from North American BPS Reliability Coordinators

Industry Coordination

• FERC and NERC using regulatory discretion on compliance with certain Reliability Standards.

Compliance and FERC Coordination


• Difficulties with transmission outage coordination and canceled maintenance

• Corrective measures implemented by transmission operators (e.g., manual actions, tap changes)

• Electricity demand down 5–10% compared to typical demand for this time of year and 10–25% down in areas where restrictions are highest

International Experiences Shed Light on Reliability Considerations


• Sufficient resources, but need to monitor outages due to potential for workforce or supply chain disruptions

• Demand Uncertainty Decreased demand during pandemic has been observed but timing,

duration, and effect on seasonal peak is uncertain Extreme demand scenarios based 90/10 weather scenarios can cause

demand increase that potentially offsets pandemic impacts

Preliminary SRA Key Findings


• Prospective resources may be at risk of delays due to supply chain or personnel disruption

2020 Summer Reserve Margins

Summer 2020 Anticipated and Prospective Reserve Margins

4,400 MW of Prospective Resources


• Nearly 2 GW of new on-peak resource additions in Texas contribute to increased reserve margin and less risk of Energy Emergency Alerts in Texas compared to 2019 Demand reductions from pandemic could

further reduce shortfall risk on peak

2020 Summer Reserve Margins

Preliminary Reserve Margins – Texas

RE/ERCOT


• Potential reliability and security risks require continued vigilance as industry maintains pandemic posture: Heightened cyber risk due to increased use of remote work arrangements Potential for increased forced outages due to deferred maintenance, staff

unavailability, or limited supplies or fuel Day-ahead forecast uncertainty due to changing pandemic conditions Fuel assurance risk due to pandemic impact on interdependent

infrastructure Potential for increased Distributed Energy Resource (DER) impacts as a

result of low demand

Operating Challenges in Pandemic


• North American fire agencies project normal to above-normal risk for wildfires for U.S. West Coast and western Canada

• Wildfire conditions can result in localized risk to BPS reliability Utility pre-season planning includes public safety power shut programs in

addition to maintenance and operational preparations

Wildfire Risk


2020 SRA Schedule

Date MilestoneMay 18 Report sent to Planning Committee for EndorsementMay 20 Report sent to NERC Executive Management for approvalMay 27 Final Report sent to NERC Board of Trustees and MRCJune 2 Report Release


2020 State of Reliability ReportPreview

John Moura, Director, Reliability AssessmentsMember Representatives Committee MeetingMay 14, 2020

DO NOT CITE OR USE THE DATA IN THIS PRESENTATION – Preliminary Data and Results

RELIABILITY | ACCOUNTABILITY2 Preliminary Data and Results-DO NOT CITE OR USE THE DATA IN THIS PRESENTATION

• Provide objective, credible, and concise information to policy makers, industry leaders, and the NERC Board of Trustees on issues affecting the reliability and resilience of the North American bulk power system (BPS) Identify system performance trends and emerging reliability risks Determine the relative health of the interconnected system Measure the success of mitigation activities deployed

The State of Reliability: Objective


• Improved reliability in 2019• No category 3, 4, or 5 events• Frequency Response stable or improving• Conventional generation forced outage rate is down• Slight uptick in number of Energy Emergencies• Improved protection system misoperation rate• Extreme events caused by winter weather and fire are most

severe to BPS Fire-related transmission forced outages in October one of largest

simultaneous outage of transmission on record

Key Findings (PRELIMINARY)


Report Framework

By the Numbers: The North American BPS

Detailed statistics on peak demand, energy, generation capacity, fuel mix, transmission miles, and functional organizations

Events Analysis Review A detailed review of qualified Events analyzed by the ERO over the year. Highlights of published lessons learned are also included.

Reliability Indicators A set of reliability metrics that evaluate four core aspects of system performance: 1) resource adequacy, 2) transmission performance and availability, 3) generation performance and availability, and 4) system protection and disturbance performance.

Severity Risk Index and Component Analysis

A performance measure of the BPS on a daily basis compared to prior years built from components of generation, transmission and load loss data.

Trends in Priority Reliability Issues

Data and analysis from various NERC data sources are compiled to provide clear insights on a variety of priority reliability issues.


The North American BPS – By the Numbers


2019 Events and Trends


The reliability indicators below represent four core aspects to system performance that are measurable and quantifiable:• Resource Adequacy - Does the system have enough capacity,

energy, and ancillary services?• Transmission Performance and Availability - Is the transmission

system adequate?• Generation Performance and Availability - What are the energy

limitations and outage performance of the generation fleet?• System Protection and Distribution Performance - Can the

system remain stable and withstand disturbances?

Reliability Indicator Categories

Red – Actionable, key findingYellow – Declining, heightened monitoring

White – Stable or no change

Green – Improving


Reliability Indicators:Energy Emergencies (Level 3)

Eastern Interconnection Western Interconnection

Texas Interconnection Quebec Interconnection


Reliability Indicators:Loss of Load Transmission-Related Events

Transmission greater than 100kV


Reliability Indicators:Transmission Outages

Protection System

Human Error

AC Substation Equipment


Reliability Indicators:Protection System Misoperations

BES Protection Systems


Severity Risk Index


Severity Risk IndexTop 10 Days in 2019


Priority Reliability Issues Example: Resilience and Extreme Natural Events

Transmission


Priority Reliability Issues Example: Resilience and Extreme Natural Events

Generation


Date Milestone

May 27 – June 3 Electronic Voting Deadline for Report Acceptance by Technical Committees

July 9 Report Sent to NERC Board of Trustees and MRC for Review

July 23 Report Sent to NERC Board of Trustees for Acceptance

July 30 Target Release

Draft 2020 SOR ScheduleRevision date: May 4, 2020


Documents

Recent FERC Activity Highlights nad Minutes … · Recent FERC Activity Andy Dodge Director, Office of Electric Reliability. Federal Energy Regulatory Commission. May 14, 2020. The