NERC’s Standards Committee approved the posting of proposed changes to its geomagnetic disturbances (GMDs) standard and authorized new initiatives on cyber system information access management and operator certifications during a brief meeting Wednesday.
Revised GMD Standard Set for Posting
The committee authorized the initial posting of proposed reliability standard TPL-007-4 and its implementation plan for a 45-day formal comment period. The ballot pool will be formed in the first 30 days, and initial ballots and nonbinding polls on the violation risk factors and violation severity levels will be held during the last 10 days.
The proposed revisions to TPL-007-3 (Project 2019-01) were made in response to FERC Order 851, which broadened the definition of GMDs, required grid operators to collect certain data and imposed deadlines for corrective actions (RM18-8, RM15-11-003). (See Revised NERC GMD Standard Approved.)
FERC’s November order directed NERC to revise the standard to require the implementation of corrective action plans for responding to vulnerabilities to “supplemental” GMD events and to authorize case-by-case extensions of deadlines on corrective action plans.
SAR Authorized on BES Cyber System Information Access Management
The committee accepted a standard authorization request (SAR) and appointed a standard drafting team for potential revisions regarding access to bulk electric system cyber system information (Project 2019-02).
The team will work to clarify the critical infrastructure protection (CIP) requirements on managing access and securing BES cyber system information (BCSI).
This project will consider revisions to CIP-004 and CIP-011 and will review BCSI definitions in the NERC Glossary of Terms. The SAR said the changes would increase “choice, greater flexibility, higher availability and reduced-cost options for entities to manage their BCSI.”
The project also will seek to clarify the protections expected when utilizing third-party solutions such as cloud services. (See Panelists Seek FERC OK to Move to Cloud.)
Move to a Single Operator Credential
The committee approved a SAR by the Personnel Certification and Governance Committee to implement its “One System Operator Certification credential” white paper to require all system operators hold the same certification (PER-003-2). The committee said the change from the current four credentials (Reliability Coordinator; Balancing and Interchange Operator; Transmission Operator; and Balancing, Interchange and Transmission Operator) will support reliability by ensuring all system operators have the same base knowledge. It would require 140 hours of continuing education hours and 30 hours each of standards and simulation training.
Request for Interpretation Rejected
The committee rejected Powerex’s request for interpretation (RFI) of INT-006-4 (Evaluation of Interchange Transactions). Powerex requested clarification on whether the time allotted in Attachment 1, Column B for the “Timing Requirements for all Interconnections except WECC” and “Timing Requirements for WECC” tables are mutually independent of other columns.
It also sought clarification on whether a balancing authority that is not the sink BA can be allocated additional time from other table columns and exceed the assessment time listed in Column B. Powerex also asked whether a transmission service provider can be allocated additional time from other columns and exceed the assessment time listed in Column B in either table.
NERC staff recommended rejecting the RFI, saying, “The meaning of the reliability standard is clear and evident by … the plain words that are written.
“The amount of the time specified in each column of the timing tables pertains to only the specific column. Each of the requirements referencing Column B of the tables (Requirements R1, R2, R3) provide that the required action shall take place ‘prior to the expiration of the time period defined in Attachment 1, Column B’ and makes no reference to additional time that may be allocated from other table columns.”
Standards Documents Retired
The committee approved the retirement of three reliability standards resource documents, as recommended by the Standards Committee Process Subcommittee:
- SC Procedure – Approving a Field Test Associated with a Reliability Standard (dated March 10, 2008);
- Guidelines for Interpretation Drafting Teams (Sept. 19, 2013); and
- SC Procedure – Processing Requests for an Interpretation (Dec. 9, 2012).
Revisions to the Standard Processes Manual (Appendix 3A to the NERC Rules of Procedure) clarified the processes for approving field tests, processing requests for interpretations and activities for interpretation drafting teams. The changes were approved by FERC effective March 1.
— Rich Heidorn Jr.