By John Funk and Rich Heidorn Jr.

NERC’s plan to streamline its top technical committees appears to face limited opposition, although officials indicated Thursday they are considering proposals to increase sector representation and lengthen the transition.

The new structure, to be discussed in detail at NERC’s quarterly meeting in Québec beginning Tuesday, would merge the Planning, Operating and Critical Infrastructure Protection committees into a new Reliability and Security Council (RSC). While the three technical committees have almost 120 voting members, the proposal would limit the RSC to 33.

Only two stakeholders made comments during a webinar Thursday on the proposal, both questioning why NERC hasn’t quantified the proposal’s supposed benefits. But NERC also has received written comments from a dozen stakeholder groups, who were nearly unanimous in calling for a longer transition and an increase in the number of sector representatives in the new organization. Some also questioned whether security issues should be combined with operations and planning.

The collapse of the existing committee structures aims to save time and money and reduce the “silos” and inefficiencies that some NERC members believe the three existing committees have created over time.

Exelon’s Jennifer Sterling, vice chair of the Member Representatives Committee (MRC) and co-chair of the Stakeholder Engagement Team (SET) that made the proposal, led the webinar.

“The idea is that we pivot quickly and focus resources rapidly,” she explained in her opening remarks. “You are all aware that our world and our industry are changing quickly and that the pace only continues to accelerate. We need to be agile. We need to be readily deployed to address these emerging issues.”

Existing subcommittees and task forces would remain intact for the time being and report to the RSC. Subcommittees that do not have recurring tasks would be eliminated or combined with others. “The whole idea is that every subcommittee should understand what their task is,” Sterling said.

Reassurances

Sterling acknowledged some stakeholders have expressed fears that the overhaul could unintentionally eliminate networking, workshops, lessons-learned sessions and similar interactions that have developed over the years.

“That was never our intention,” she said. “We would expect that the [RSC] would continue those activities going forward.”

Sterling also addressed concerns that reducing the number of committee members would diminish transparency and stakeholder involvement. “We are committed to making sure the meetings are held in spaces that are open and that provide enough space for everyone who wishes to attend,” she said.

Potential Changes

Sterling also indicated NERC is considering potential changes to the plan based on stakeholder feedback.

The SET proposed a “hybrid” of the regional representation used by the CIPC, the sector-based membership of the PC and OC, and the at-large membership of the MRC and Reliability Issues Steering Committee (RISC).

The RSC would include one voting member from each sector (except for the regional entities), 20 at-large members, a chair and a vice chair. Members would be selected by a nominating committee of NERC officers and approved by the Board of Trustees, with selections based on interconnection diversity, subject matter expertise, and a mix of small and large entities.

“Let me emphasize the word ‘proposed’ here,” Sterling said in prefacing her description of the proposed RSC makeup.

“We have gotten a number of comments that perhaps people would like to see more sector representatives. Right now, we have one per sector, but people have asked for two. And also, there have been a number of comments that they would like to see the sectors elect their own representatives. … These will all be discussed at the upcoming [SET] meeting, and I’m sure it will be discussed next week at the MRC.”

Sterling said her team also has heard stakeholder concerns that the proposed timeline — which calls for nominating RSC members in the fourth quarter and completing the transition in the first quarter of 2020 — may be too aggressive.

Stakeholders also have expressed concern that the RSC’s name could cause confusion with the RISC. “Essentially, the RISC will be developing the lists of risks on a strategic basis,” Sterling explained. “That RISC report, along with other reports, would then be used by the RSC to develop their tactical work plans.

“There were some people who thought that name, the RSC, might be confusing,” she acknowledged. “So, we’ll talk about that as a group at our August meeting.”

Cost-benefit Analysis

Only two stakeholders had comments during the workshop. Barry Jones, of the Western Area Power Administration, asked why the plan did not include an “impact analysis.” Keen Resources’ Robert Blohm, a member of the OC, said the proposal might not produce the promised efficiencies.

“What we have now are three groups simultaneously dealing with three parts of the overall issue, saving a lot of time,” he said. “I would have been more comfortable seeing this [proposal presented in] a more objective or less presumptive fashion, where cost-benefit arguments, pro and con, are listed quite clearly.”

Sterling said the SET’s goal was achieving efficiency, “and hopefully cost savings will result.”

Mark Lauby, NERC chief reliability officer, said the revamping would increase NERC’s effectiveness at addressing issues in a holistic manner. “Going from 120, 130 people to whatever the size of this group ends up being, that will certainly be less of a burden and cost to industry,” he added.

Written Comments

The Policy Input Package for the August quarterly meetings includes written comments from 12 sets of stakeholders, including industrial consumers, cooperatives, generation owners, transmission owners, utilities and RTOs.

In addition to calling for an increase in sector representation, many of the commenters also recommended eliminating the requirement that RSC members have “executive leadership experience,” saying that subject matter expertise is more important.

The Canadian Electricity Association was among the most skeptical of the proposal. “While evolving reliability issues faced by the industry may require solutions and expertise that expand across traditional operating frameworks, many companies are still internally structured through a planning/operations/security model,” said CEA, which represents generators, transmission and distribution companies. “This reality may make it challenging to identify RSC members who can bring the necessary breadth of knowledge and experience to work across these industry areas.”

It also said issues addressed by the RSC must be “well-prioritized, while also guarding against dilution of attention due to a higher number of issues being overseen by one group rather than three.”

Several commenters said that while they agree with combining the OC and PC, they saw less synergy in combining them with the CIPC, which focuses on security.

The Electricity Consumers Resource Council (ELCON), which represents large energy consumers, recommended replacing the OC and PC while retaining a separate security committee. The ISO/RTO Council said that while “there is reasonable justification” for combining operations and planning, “including security matters in the combined group does not improve efficiency.”

The Cooperative Sector said its members were split on the restructuring. It was also critical of NERC’s transparency, saying some of its members “found it challenging to understand the deliberations of the SET meetings and that meeting notes/minutes were not provided to industry. Additionally, the proposal states that the current technical committee members were surveyed for input on the existing committee structure, but the survey results were not made public.”

Only one set of comments, from stakeholders representing state, municipal and transmission-dependent utilities, opposed the RSC proposal (Option 2) outright, saying they preferred Option 1: keeping the three committees and adding a steering committee above them.

“Option 1 provides oversight by refocusing the OC, PC and CIPC, while retaining the benefits those committees bring to NERC and the industry,” it said. “If it is not acceptable as a long-term solution, Option 1 should be adopted as the mechanism for achieving an effective and efficient transition.”

Most of the commenters called for a slower transition. Said ELCON: “Change management at this scale often takes about six months to complete.”