Welcome! NERC State of Standards Webinar Lacey Ourso, NERC Standards Developer July 24, 2014
NERC Antitrust Compliance Guidelines It is NERC s policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition. This policy requires the avoidance of any conduct that violates, or that might appear to violate, the antitrust laws. Among other things, the antitrust laws forbid any agreement between or among competitors regarding prices, availability of service, product design, terms of sale, division of markets, allocation of customers or any other activity that unreasonably restrains competition. 2
Opening Remarks Mark Lauby, Senior Vice President and Chief Reliability Officer State of Standards Webinar
Topics Progress made in 2014 Partnerships with Industry and the Standards Committee Vision for the Future 4
Updates on the Standards Program Valerie Agnew, Director of Standards State of Standards Webinar
Topics Progress made in 2014 Outlook for standards development projects Getting to steady state and what that means Preview of draft 2015-2017 Reliability Standards Development Plan 6
2014-2016 Reliability Standards Development Plan Identified 24 projects to be completed in 2014 4 projects were added after plan was developed Project 2014-01: Standards Applicability for Dispersed Generation Resources (high-priority standards) Project 2014-02: Critical Infrastructure Protection Standards Version 5 Revisions Project 2014-03: Revisions to TOP and IRO Standards Project 2014-04: Physical Security 23 projects are anticipated to be completed in 2014 5 projects may be extended into 2015 7
November 2014 2014-2016 Reliability Standards Development Plan Project 2007-06: System Protection Coordination (PRC-027-1, PRC- 001-1) Project 2007-11: Disturbance Monitoring (PRC-002-2) Project 2007-17.3: Phase 3 Protection Systems: Sudden Pressure Relays (PRC-005-X) Project 2010-05.2: Phase 2 Protection Systems: Special Protection Systems (Definition) Project 2010-13.3: Phase 3 of Relay Loadability: Stable Power Swings (PRC-026-1) 8
November 2014 Cont d 2014-2016 Reliability Standards Development Plan Project 2010-14.1: Phase 1 of Balancing Authority Reliability-based Controls: Reserves (BAL-002) Project 2013-03: Geomagnetic Disturbance Mitigation (TPL-007-1) Project 2014-01: Standards Applicability for Dispersed Generation Resources (high-priority standards) Project 2014-02: Critical Infrastructure Protection Standards Version 5 Revisions Project 2014-03: Revisions to TOP and IRO Standards (TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-002-4, IRO-008-2, IRO-010-2, IRO-014-3, and IRO-017-1) 9
2014-2016 Reliability Standards Development Plan February 2015 Project 2008-02: Undervoltage Load Shedding (UVLS) & Underfrequency Load Shedding (UFLS)(PRC-10-1 and PRC-006-1) Project 2009-03: Emergency Operations (EOP-011-1) Project 2010-14.2: Periodic Review of BAL Standards (BAL-005, BAL-006) Project 2012-09: Implementation of IRO Five-year Review Recommendations Project 2014-01: Standards Applicability for Dispersed Generation Resources (medium priority standards) Project 2010-05.2: Phase 2 Protection Systems: Special Protection Systems (Standard(s)) 10
Progress Against Work Plan 31 19 27 12 17 5 7 5 Q1-2014 Q2-2014 Q3-2014 Q4-2014 Planned Standards to Board (All Projects) Actual/Projected Standards 11
Projects with Regulatory Deadlines 12
Progress on FERC Directives *Does not include non-standards related directives 13
Progress on Paragraph 81 and Independent Experts Review Panel (IERP) *Represents unique candidates 14
Progress on Paragraph 81 and Independent Experts Review Panel (IERP) Of the 202 requirements that have been addressed: 47 percent (95) have been retired 44 percent (88) have been modified 9 percent (19) have been retained 15
Medium Priority Project 2015-01 TPL Directives (prioritized by SC in 2014) Project 2015-02 Periodic Review of EOP-004, EOP-005, EOP-006 and EOP-008 Project 2015-03 Periodic Review of FAC-010, FAC-011, FAC-014 Low Priority 2015-2017 Reliability Standards Development Plan Project 2015-04 Alignment of Glossary of Terms used in NERC Reliability Standards and the Definitions used in the Rules of Procedure (Rules of Procedure Appendix 2) 16
Trend in Number of Requirements 17
Enhanced Periodic Reviews Laura Hussey, Director of Standards Development State of Standards Webinar
Periodic Reviews to Date Originally five year reviews Standard Process Manual revised in 2013 (Section 13) First periodic reviews completed in 2013: EOP family (EOP-001, -002, -003) FAC family (FAC-001, -002, -003, -008, and -013) IRO family (IRO-003, -004, -006, -006-EAST, -008, -009 and -010) NUC-001 Additional progress in 2014: BAL-005, -006 o BAL-004 ongoing 19
Periodic Review Process Standards Committee (SC) developed template to guide reviews Provides consistent approach to each review Provides documentation of review recommendations SC appoints periodic review team (PRT) PRT reviews independently; meets to develop draft recommendation Draft recommendation posted for 45-day comment period PRT meets to review comments If comments indicate general support: finalize and submit to SC If comments indicate the need for significant revisions: revise draft recommendation and post for additional comment period 20
Enhanced Periodic Reviews What is enhanced? Template revised to include quality, content, and cost considerations Composition of periodic review team Enhancements posted for stakeholder comment through July 21, 2014 Comments will be reviewed, and template finalized for SC endorsement prior to delivering to NERC Board in November 2014 Time frame for conducting enhanced periodic reviews : 2015 and beyond 21
Update from the Standards Committee Scott Miller, Vice-Chair of Standards Committee State of Standards Webinar
Standards Committee: 2014 Work Plan Updates Paragraph 81 Independent Expert Review Panel recommendations Consensus building Cost Effectiveness Analysis Process (CEAP) Steady state Quality review 23
SC subcommittee updates SC subcommittee scope updates: Syncing language in common areas Officer election and member solicitation Functional Model Advisory Group Project Management Oversight Subcommittee Standards Committee Process Subcommittee 24
Looking to 2015 Enhanced periodic review Steady state 25
Question & Answer
Question & Answer Session Please submit your questions using the chat feature 27
Implementation Support and Training for New Reliability Standards Laura Hussey, Director of Standards Development Steven Noess, Associate Director of Standards Development Jerry Hedrick, Director of Regional Entity Assurance and Oversight
Topics BAL-003-1 (Frequency Response and Frequency Bias Setting) PRC-005-2 (Protection System Maintenance) EOP-010-1 (Geomagnetic Disturbance Operations) CIP Version 5 transition plan 29
What Happens When a brand new Reliability Standard becomes enforceable? Potential surge in self-reported violations Potential surge in requests for interpretation or other forms of clarification a significantly revised standard becomes enforceable? Same as above 30
ERO Support Standards Implementation Tools to support entity and auditor implementation of new or significantly revised standards In-depth, standard-specific auditor training Workshop and webinars for Registered Entities Enforceable (or partially enforceable) April 1, 2015: BAL-003-1 Frequency Response and Bias Setting o Requirements R2, R3 and R4 EOP-010-1 Geomagnetic Disturbance Operations PRC-005-2 Protection System Maintenance Enforceable April 1, 2016 Version 5 CIP Standards BAL-003-1 Frequency Response and Bias Setting o Requirement R1 31
ERO Implementation Support Plans for 2014-2015 BAL-003-1 Frequency Response and Bias Setting Industry webinar and workshop September 2014 PRC-005-2 Protection System Maintenance Full-day auditor training September 2014 Industry workshops o WECC PRC-005-2 workshop July 29-30, 2014 o NERC Standards and Compliance Workshop September 23-25, 2014 EOP-010-1 Geomagnetic Disturbance Operations Implementation support planning in progress Exploring options such as web-based training module for system operators Feedback and suggestions welcome 32
Regional Entity Oversight New Standard Support Standard Development Collaboration with Industry and Standards on Development Posting of Reliability Standard Audit Worksheet (RSAW) Implementation and Transition Develop training and informational material Demonstrate testing methodology Consistency of compliance On-Going Maintenance Re-post all changes to RSAWs Provide continuous feedback to Standards 33
Purpose of CIP Version 5 transition program Transitioning entities confident in implementation Vision 2016: smooth transition to CIP Version 5 Support all entities in the timely, effective, and efficient transition to CIP Version 5 34
Focused Collaboration NERC, Regions, and stakeholder group to meet monthly Address pressing topics to support transitioning entities confidence in implementing Version 5 Partner with the regions and stakeholders through continued communication and engagement First Meeting August 4-5, 2014 Team composition: o Implementation Study participants (Industry and Regional Entity) o Transition Guidance participants o RSAW work group (Industry and Regional Entity) o Standard Drafting Team representation 35
Transition Factors Continuous Outreach Training Compliance and Enforcement Periodic Guidance 36
Transition Factors Continuous outreach Conferences, workshops, and training Deliberate feedback loop with focused transition group Training Auditors and enforcement: consistent application CIP Auditor Workshop (September 2014) Industry o Address areas of concern o Input to enhance guidance and other tools Reliability Assurance Initiative (RAI) Coordination with CIP V5 revisions 37
Transition Factors Pre-enforcement audit assistance Monitor/preview implementation in non-audit context Promote engagement on implementation progress Ensure meaningful dialogue on challenges and hurdles Provide input to monthly transition group Incorporate key questions and topics across regions 38
Recent and Near-term Activities Transition Guidance Draft posted for comment (June 2014) August 2014 completion Implementation Study Draft Implementation Study report (Q3) Field work complete June 2014 Drafting study report (Q3) Related activities: Project 2014-02: CIP Version 5 Revisions Reliability Standard Audit Worksheet development 39
Regional Entity Assurance and Oversight - Updates Jerry Hedrick, Director of Regional Entity Assurance and Oversight
Oversight and Assurance Updates - RSAW Review and Revision Process Effective Date Process Overview Concurrent Development Collaboration with Industry and Standards Integrated process from approval through implementation Other RSAW Activities Training Development 41
Oversight and Assurance Updates - AML 2014 List of standards based on risk One-size fits all list of standards 2015 Risks to the Bulk Electric System Understanding risks related to functional tasks Standards applicable to organizational risk 42
Risk-Based Registration (RBR) Initiative Terry Brinker, Manager of Registration Services Soo Jin Kim, Manager of Reliability
RBR Background and Current Registration Challenges Follow all standards according to Function, regardless of impact Some Functions may have minimal impact on reliability Conservative criteria and thresholds used to register entities Flexibility to use entity risk, but limited application to date 44
RBR Vision Differentiate entities exhibiting different levels of risk: Clear thresholds Registration using consistent risk assessment methods Focused Reliability Standard requirements Align with: Bulk Electric System definition Reliability Assurance Initiative Reliability Standard reform 45
RBR Benefits Align registration and compliance with reliability impacts Reduce registration burden while sustaining BES reliability Increase consistency in registration across the ERO Provide feedback to Reliability Standards development Improve use of NERC, Regional Entity and industry resources 46
Highlights of Proposed RBR Design Eliminate functions that are commercial in nature PSE, LSE, IA Raise the Distribution Provider (DP) threshold to 75 MW (directly connected to the BES) Specific characteristics for DP inclusion is below 75 MW threshold Create a new UFLS Only DP registration Threshold synchronization with the new BES definition Centralized review process for threshold determinations Consistent risk-based methods to assess entity s impact Improve the attestation process with a one-time attestation 47
Feedback and Comments Draft Design, Implementation Plan, and redlines to Rules of Procedure (ROP) Appendix 5B posted for industry comment from June 2, 2014 to June 23, 2014 Approximately 50 comments submitted Most commenters supportive of the RBR project Initial technical analysis and comments from Regional Entities and Reliability Coordinators submitted on June 27, 2014 Additional technical studies being conducted 48
Highlights of Key Comments Suggestions to provide more detail and provide areas for expansion for the Implementation Plan including: JRO/CFR impacts Certification Standards/glossary projects Suggested language to address concerns over applicable governmental authority (Canada and US) Several comments focused on the proposed tiering for Transmission Operators (TOP) and whether Transmission Owners (TO) could be tiered further Joint ownership/control over BES elements and facilities were raised by several entities One entity questioned removing entities from the INT standards 49
Phase 1 RBR Implementation Timeline 50
Next Steps Incorporate MRC policy input Solidify technical validations Post Design, Implementation Plan, and ROP changes for 45 days Recommend NERC Board of Trustees approval in November Move forward with Implementation Plan 51
Update On Web-Based Tools Barb Nutter, Manager of Standards Information State of Standards Webinar
Topics Standards Balloting and Commenting System (SBS) update Registered Ballot Body Single Portal (new) 53
SBS SBS URL - https://sbs.nerc.net/ Balloting and Commenting Page 54
SBS 55
Registered Ballot Body Voting in the new SBS: All current NERC Registered Ballot Body (RBB) members must go through a new registration process. If you have not registered or are a new member requesting membership in the RBB, please click here. Appendix 3D Registered Ballot Body Criteria 56
Single Portal 57
Standards Information Standards Program News o Weekly Standards Bulletin Standards Processes Manual Resources SBS questions/feedback - ballotadmin@nerc.net 58
Fall Standards & Compliance Workshop Ryan Stewart, Standards Developer State of Standards Webinar
Standards & Compliance Workshop Fall Workshop: September 23 25, 2014 Atlanta, GA Agenda topics to include: Reliability Assurance Initiative (RAI) Update Risk-Based Registration Physical Security CIP Version 5 Transition and Revisions 60
Question & Answer
Closing Remarks Valerie Agnew, Director of Standards State of Standards Webinar