NERC Seeks to Balance Oversight, Collaboration

By Robert Mullin

SEATTLE — NERC CEO Jim Robb said last week his organization is sidestepping Washington’s fuel war politics and striving to maintain its independence from industry while still collaborating to identify best practices and emerging threats.

Robb has had no shortage of issues to address in the four months since he joined NERC from Western Electricity Coordinating Council (WECC). In his keynote address at last week’s third biennial NAES-NERC conference, Robb said the organization is focused on making sure its reliability standards evolve in response to the changing generation mix and the growth of electric vehicles and distributed generation. (See related story, Overheard at the NAES-NERC Conference.)

“Do [the standards] need to be evolved in particular ways to be compatible with the industry as it’s evolving?” Robb asked. “Are we keeping our eyes far enough down the road on reliability issues to make sure that we have a good sense of how this new restructured industry is going to work — and going to work reliably? If we don’t have a sense of what we need to have in the ground 10, 15 years from now, we may have lost the battle, and that’s becoming particularly clear on issues like gas infrastructure.”

Relationship with Industry

Robb, who replaced longtime CEO Gerry Cauley, said the organization is seeking to balance its role as enforcer of reliability standards with the need to work closely with industry to respond to new threats, such as cyberattacks.

“We are an independent authority; however, we are very tightly linked with industry in terms of being able to leverage technical expertise and capability in order to do our work,” Robb said. “Our work is much better because of the relationship we have with industry, but we can never be viewed as not being independent from industry.”

Robb said NERC and its Regional Entities face the challenge of “how to manage the yin and yang of independence and partnership in a way that gets us to the right answer from an oversight perspective.”

Other speakers at the three-day conference also discussed that balance.

Midwest Reliability Organization CEO Sara Patrick emphasized that “authority should defer to expertise” with respect to reliability issues. NERC and the REs must be sensitive to actual operations, “understanding how things work, not just how they’re supposed to work.”

Patrick said her organization has changed from its early focus on enforcement of standards. “Enforcement is only one of the tools in our toolkit and it may not be the most effective,” she said, encouraging companies to self-report violations and devise strategies for avoiding them in the future.

Jeff Craigo, vice president of reliability assurance and monitoring at ReliabilityFirst, cautioned against companies adopting practices that superficially achieve compliance without actually improving grid security, often the product of organizational silos and inadequate communication among different departments.

“The key is that you’re coordinating your compliance program across your organization,” Craigo said.

“You can be minimally compliant, but that won’t get you security,” said David Godfrey, WECC vice president of entity oversight.

Curtis Crews, director of compliance assessments for Texas Reliability Entity, talked about the “circle of competence” between oversight agencies and plant operators.

“I audit; you do maintenance. We need each other,” Crews said.

James Merlo, NERC vice president of reliability management, warned against the tendency for companies to drift from reliability standards.

“You can’t see drift in your own organization” in the same way that “you can’t smell your own room,” Merlo said, referring to the phenomenon of “sensory adaptation.”

“I believe NERC standards are the floor, not the ceiling, so the work of [NERC] is critical,” FERC Commissioner Neil Chatterjee said.

The Politics of Resilience

Robb also acknowledged the highly charged debate over resilience and the Trump administration’s push to protect coal and nuclear generation.

“There’s a tremendous amount of political influence in place right now, whether it’s ‘Can we survive without coal plants?’ or ‘What are we going to do if we don’t have our nuclear fleet?’ ‘How much renewable can we really put on the system?’

“Many of these issues are important technical issues for the industry and NERC and the REs to deal with, but they’re also highly politicized, and our job is to stay out of the political fray and be ideologically independent,” Robb said.

Mark Lauby, NERC’s chief reliability officer, told the conference that resilience has always been part of his agency’s mission.

“It’s our definition of reliability,” he said. “Resilience is something we have to keep our eye on, particularly as the risks change.”

EVs, Behind-the-Meter Generation

Robb also pointed to uncertainties stemming from the increased adoption of EVs and how they will interplay with solar generation.

“We used to always operate the system on a very simple, straightforward baseload, mid-merit peaking array, with a fairly well-known load curve,” he said. “We have to kind of ’fess up. We don’t even know what the load curve looks like. So much [generation] is masked by behind-the-meter generation.

“We’ve learned a tremendous amount over the course of the last two years around how inverter-based resources respond to disruptions on the system, and it’s been a little bit like following a ball of yarn through a house,” Robb told conference participants. “One issue you think you’ve corrected, and then another one appears, and so forth.”

The NERC chief pointed out that inverters are not just a problem for solar-heavy California. (See Solar Inverter Problem Leads CAISO to Boost Reserves.)

“It’s an industry issue because inverters will be highly central to the deployment of batteries, which we’ll see in multiple jurisdictions,” Robb said, adding that solar will also continue to be “one of the resources of choice” over the next 10 to 15 years. He also noted that inverters have “pretty extraordinary capabilities” to promote reliable operations. “We need to be ahead of that.”

Robb also said the industry needs to shift its operating model to one that is “just more stochastic in nature.”

“Policies in general need to be rethought,” Robb said. “Most of our frameworks and rules of thumb around things like resource adequacy were based on largely coal and liquid fuel resource mix and a metal-bending [heavy manufacturing] economy, and that’s not what we have anymore.”