A proposal at the monthly meeting of NERC’s Standards Committee to reject a standard authorization request (SAR), despite its support from industry stakeholders in a 2024 comment round, prompted a debate among the group’s members over the appropriateness of the action.

At issue was an SAR that the SC accepted in July 2024, proposing to update NERC’s Glossary of Terms to add owners and operators of inverter-based resources (including those not currently subject to NERC’s standards) to the glossary definitions of generator owner and generator operator. The SC assigned the SAR to the standard drafting team for Project 2024-01 (Rules of Procedure definitions alignment — generator owner and generator operator).

Presenting the proposal, NERC Manager of Standards Development Alison Oswald explained the SDT reviewed the comments on the SAR from a comment round in August and September 2024. The review was delayed by the need to focus on an SAR assigned to the project earlier.

SDT members concluded they already achieved the SAR’s objective through other revisions to the GO and GOP definitions. The team also considered it best to avoid IBR-related definitions because they are being addressed by Project 2022-02 (Uniform Modeling Framework for IBR). The SDT therefore recommended the committee vote to reject the SAR, with a letter of explanation to the submitters, which include the American Public Power Association, the Electric Power Supply Association, the Large Public Power Council and the Transmission Access Policy Study Group.

But Marty Hostler of the Northern California Power Agency objected, pointing out the SAR received 68 positive comments from industry stakeholders against 22 negative ones and professing himself “not clear exactly why the consensus is being ignored.” He added that the SDT members “haven’t even asked the commenters if they feel that [the team] has addressed the issues.”

“It also says in the Standards Processes Manual [SPM] that NERC staff and the drafting team should be giving ‘prompt consideration to written views and objections.’ Well, this wasn’t prompt at all,” Hostler continued. “The comments were requested and closed in September of last year, and the comments weren’t even addressed till March.” He also pointed out the SAR for Project 2022-02 does not permit the SDT to create definitions.

Responding to Hostler, NERC Director of Standards Development Jamie Calderon described the support from industry in more nuanced terms, saying “there were industry participants who approved of one or more … definitions and some who disapproved of one or more … definitions.” In addition, Calderon clarified that SDTs do have the ability to consider definitions … within the realms of” their work.

SC Chair Todd Bennett, of Associated Electric Cooperative Inc., reminded attendees “the SPM only gives us two options on this … either [to] authorize drafting or … reject the SAR.” But, he continued, NERC’s standards development process provides “other ways to influence that path and provide feedback and input.”

The proposal to reject the SAR ultimately passed, with Hostler and four others voting against it. Nine members voted in favor and six abstained.

Additional Actions

Several other standards items passed the SC with comparatively little discussion and no objections.

First, members voted to approve the posting of proposed reliability standard MOD-026-2 (Verification and validation of dynamic models and data), developed under Project 2020-06 (Verifications of models and data for generators).

The standard, found on Page 11 of the agenda, is meant to address FERC’s Order 901, issued in 2023, which required NERC to develop standards to improve the reliability of IBRs. (See FERC Orders Reliability Rules for Inverter-Based Resources.) It will be posted for a 26-day formal comment period, with ballots conducted during the last 10 calendar days.

The SC next approved the appointing of three new members to the SDT for Project 2020-06, which Calderon explained was intended to “round out the drafting team” after several recent departures.

Finally, the committee voted to accept an SAR aiming to modify NERC’s Critical Infrastructure Protection (CIP) standards by grouping protected cyber assets (PCAs), electronic access control or monitoring systems (EACMS), and physical access control systems (PACS) together in a single standard as “CIP applicable” systems. Oswald told attendees this move will bring clarity to NERC’s enforcement process.

Currently, a failure to appropriately identify PCAs, EACMS and PACS is addressed under CIP-010-4 (Cybersecurity — configuration change management and vulnerability assessments). But Oswald said this approach is only a “temporary solution” that poses an administrative burden on both the industry and the ERO.

The SAR will be posted for a 30-day formal comment period and assigned to Project 2021-03 (CIP-002).