FERC Open Meeting Highlights for Reliability Compliance Staff

FERC Open Meeting Highlights

Today the FERC held a virtual open meeting and issued a variety of orders, rules, and inquiries. Below are highlights of items that will be of interest to your NERC Reliability Standards compliance staff.

Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Under the NERC Standards Efficiency Review

Today’s ruling by the Commission falls short of the originally proposed 74 Reliability Requirements that NERC and the Standard Efficiency Review Team proposed back in 2019. The Commission only approved 18 requirements for retirement. They also approved the associated violation risk factors, violation severity levels, implementation plan, and effective dates proposed by NERC. The final rule will be effective on December 14, 2020.

The following four Reliability Standards will be eliminated in their entirety:

FAC-013-2: Assessment of Transfer Capability for the Near-Term Transmission Planning Horizon

INT-004-3.1: Dynamic Transfers

INT-010-2.1: Interchange Initiation and Modification for Reliability

MOD-020-0: Providing Interruptible Demands and Direct Control Load Management Data to System Operators and Reliability Coordinators

Individual Reliability Requirements will be retired as follows:

TOP-001-4 Requirements R19 and R22 requiring TOPs and BAs, respectively, to fulfil specific operational responsibilities by having data exchange capabilities with other entities.

IRO-002-6 Requirement R1 requiring RCs to fulfill specific operational responsibilities by having data exchange capabilities with other entities.

PRC-004-5(i) Requirement R4 requiring TOs, GOs, and DPs to continue investigating the cause(s) of an identified Misoperation at least once every two full calendar quarters after the date the Misoperation was first identified until the investigation is concluded or no cause of the Misoperation could be determined.

FERC postponed the retirement of the remaining 56 Reliability Requirements, which constitute the so-called “MOD A” Reliability Standards, for further coordination and eventual incorporating into the existing North American Energy Standards Board (NAESB) business practice standards.

Lastly, the Commission agrees that Requirement R7 (“Provision of Facility Ratings to External Entities”) of FAC-008-3 can be retired, but is still concerned that Requirement R8 (“Response to External Entity Info Requests”) needs further work. The Commission remanded the proposed Standard Revision to NERC for further development.

Equipment and Services Produced or Provided by Certain Entities Identified as Risks to National Security

FERC issued a Notice of Inquiry for comments on the potential BES risks posed by using equipment and services produced or provided by entities identified as risks to national security. This is following recent Executive Orders, legislation, and federal agency decisions identifying such risks in other Sectors. Additional comments are also requested on whether existing NERC CIP Reliability Standard are adequate to address these risks. The Notice of Inquiry identifies five specific questions asked by the Commission for respondents to answer within 90 days following publication in the Federal Register.

If you have questions regarding today’s ruling or other NERC compliance needs, PCS can help. Please contact Dale Zahn at dzahn@provencompliance.com or (262) 436-4116 for further information. To learn more about Proven Compliance Solutions Inc., visit our website at www.provencompliance.com.

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