Members of NERC’s Standards Committee are working to balance workload changes forced by the COVID-19 pandemic with the obligation to maintain transparency.
A particular focus at the committee’s conference call this week — replacing its scheduled in-person meeting in accordance with NERC’s Business Continuity Plan — was the work of the organization’s standard drafting teams (SDTs). Charles Yeung, chair of the Standards Committee Project Management and Oversight Subcommittee, told members the teams have seen little impact so far from ending face-to-face meetings. However, he warned that conference calls and online meetings could make discussing technical issues very difficult.
Linda Lynch, a member of the drafting team for Project 2017-01, involving frequency response and frequency bias shedding, presented her team’s approach to the problem in hopes that others might find it useful. Rather than try to address complicated technical subjects during full conference calls, team members have found it more useful to schedule smaller meetings of two or three people on an ad hoc basis. These small groups allow difficult issues to be worked out and presented to the larger group for a decision.
Committee members agreed that this approach could help work progress more quickly, but some expressed concern that they had not known about these small group meetings until this week’s call. They worried that these informal meetings could unintentionally shut entities out of an essential step in the standard drafting process.
“If, because of the pandemic, industry starts not having as much visibility [into] these standard projects, then it could be problematic, just from a perception standpoint,” said Sean Bodkin, NERC compliance policy manager for Dominion Energy.
In response, Lynch emphasized that the small group meetings were intended only to facilitate work on highly technical matters that are hard to resolve at the SDTs’ official meetings. Soo Jin Kim, NERC’s manager of standards development, insisted that the organization intends to ensure that industry operators do not see any significant loss of input into the standards development process.
“I will assure you, and I’ll reaffirm with all the developers, [that] there are no votes taking place, there’s nothing necessarily put forward to ballot … If there [are] any concerns, the small groups are also presenting their information to the larger team to discuss,” Kim said.
Approvals
The committee approved action on the following projects:
- Modifications to reliability standard MOD-032-1: Accept the standard authorization request (SAR) as developed by the System Planning Impacts from Distributed Energy Resources (SPIDER) Working Group; authorize posting of the SAR for a 30-day informal comment period; and authorize solicitation for nominees for a SAR drafting team.
- Transmission-connected resources: Accept the SAR proposing modifications to reliability standards MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-2 and PRC-024-3 to apply to nonsynchronous energy sources; authorize posting of the SAR for a 30-day informal comment period; and authorize solicitation for nominees for a SAR drafting team.
- Modifications to CIP-012 requiring entities to protect cyber communication links between control centers: Accept the SAR developed in response to FERC Order 866; authorize posting of the SAR for a 30-day informal comment period; and solicit nominees for a drafting team.
- Data request on cybersecurity supply chain risks: Accept the SAR developed in response to a resolution adopted by NERC’s board of trustees at its February meeting; authorize posting of the SAR for a 30-day informal comment period; and solicit nominees for a drafting team.
The last two items were passed in modified form. While the original proposals would have assigned each SAR to an existing standard drafting team — Project 2019-02 for the CIP-012 SAR and Project 2019-03 for the cybersecurity data request — the committee voted to create new teams for both projects.
In the case of CIP-012, Bodkin said he feels the team for Project 2019-02 — working on expanding options for entities to manage bulk electric system cyber information — already has enough on its plate with addressing industry feedback on its proposals. (See CIP Teams Compromise on Cloud Risk Assessment.) Regarding the cybersecurity data request, Venona Greaff of Occidental Chemical Corporation said industry feedback indicated that “this is not a supply chain issue, but a remote connectivity issue,” and that the SAR would therefore be better addressed by a new team rather than the supply chain-focused 2019-03.
Nominating Criteria Debate Remains Unsettled
The committee also approved a proposal to change its criteria for drafting team membership, despite objections that the planned revision did not do enough to provide needed clarity in the nominating process.
The review of the team membership criteria was ordered at the committee’s December meeting, following an unsuccessful motion by Bodkin to remove a regional entity official from the SAR drafting team responsible for cold weather standards (Project 2019-06) on the basis that only industry members should serve on drafting teams. (See NERC Worries Standards Committee ‘Close to a Line’.) Bodkin had led a push the previous month to remove two members from a different team because they were consultants. (See “Consultants Removed from SDT Nominee List,” NERC Standards Committee Briefs: Nov. 20, 2019.)
These actions led to concern on the part of committee members that criteria for drafting team membership were unclear. At the time, Howard Gugel, NERC vice president of engineering and standards, warned that if the nominating process was not considered transparent, the Electric Reliability Organization could have trouble winning recertification by the American National Standards Institute.
In response, the Standards Committee Process Subcommittee — chaired by Bodkin — was assigned to review the nominating criteria. The resulting document, presented at this week’s conference call, contained no changes to the criteria themselves. However, the subcommittee did change the “Purpose” section of the document to indicate more clearly that it related to eligibility for appointment to an SDT and replaced a reference to the Standards Development Process Participant Conduct Policy with the NERC Participant Conduct Policy.
Kent Feliks of American Electric Power Company, who chaired the group that revised the document, explained to the committee that their goal was to give the Standards Committee the greatest possible latitude to select drafting team members, which was why their changes were relatively limited. However, Gugel warned that the underlying issues had yet to be resolved.
“While I think these changes are fine, I still think there’s an elephant in the room that needs to be addressed. And whether you assign it to this team or create some other team, there still needs to be some way for drafting team selection to occur without bias, or without the appearance of bias,” Gugel said.
— By Holden Mann