NERC’s Standards Committee expects to bring five standards development projects to a final ballot by the end of the year despite work schedule challenges created by the COVID-19 pandemic, according to Project Management and Oversight Subcommittee Chair Charles Yeung.

During the committee’s monthly conference call on Wednesday, Yeung said the following projects — including NERC’s oldest standard drafting project still in progress — are on track for FERC approval within the next six months:

• Project 2015-09 — Establish and communicate system operating limits. A final ballot is planned by August, with the standard submitted to FERC for approval in September.
• Project 2019-02 — Bulk electric system cyber system information access management. Final ballot and FERC filing both scheduled for September.
• Project 2016-02 — Modifications to Critical Infrastructure Protection standards. Final ballot in December, FERC filing in January 2021.
• Project 2017-01b — Modifications to BAL-003-1.1. Final ballot in October, FERC filing in December.
• Project 2019-03 — Cybersecurity supply chain risks. A final ballot is tentatively planned for August. The FERC filing has not been scheduled yet.

While committee members had no questions about the projects, Linn Oelker, market compliance manager for LG&E and KU, raised a concern about the transparency of the development process. Oelker said he could find “very few, if any, meeting agendas and meeting notes” on NERC’s website, noting he had raised a similar concern at the committee’s March meeting. (See “Coronavirus Adaptations Spark Transparency Debate,” NERC Standards Committee Briefs: March 18, 2020.)

Soo Jin Kim, NERC’s manager of standards development, acknowledged the concern but asked committee members to have patience, as different standard development teams might approach recordkeeping in different ways, and that technical or other misunderstandings in an SDT meeting might need to be worked out before a team is comfortable posting their minutes. Oelker replied that he understood the challenges; however, he continued to urge SDT leaders to ensure they are handling issues consistently for the sake of industry.

Hostler Raises Cost-benefit Complaint

An additional question about NERC’s Project Tracking Spreadsheet was raised by Marty Hostler, reliability compliance manager for the Northern California Power Agency (NCPA). Hostler, who joined the committee prior to its March meeting, asked why no effort appeared to have been made to estimate financial costs and benefits of the 11 projects currently in progress, given that all would likely require utilities to expend money and other resources to ensure compliance.

“I’ve never worked in an industry where we have projects that don’t have any estimates. We have lots of people that have to pay the bills for all these proposals, and there’s no cost-benefit analysis for any of them?” Hostler said. “I personally would like to see some cost estimates; I don’t know if anyone else would, but I’m a customer myself, and I’d like to know what it’s going to cost.”

Standards Committee Chair Amy Casuscelli, of Xcel Energy, reminded Hostler that comment forms do typically ask respondents to share their estimated compliance costs, though she admitted being unsure whether that information is collected or analyzed by NERC. Hostler replied that the lack of any other cost-benefit actions seems to confirm that utilities’ burdens are a low priority for SDTs.

Kim added to Casuscelli’s remark about the cost question on comment forms, assuring Hostler that drafting teams do take the responses into consideration and actively weigh costs against benefits, even though these debates are not reflected in the project spreadsheet. She also reminded participants that NERC and the committee had a mandate from FERC to address specific issues, which do not include entities’ financial challenges.

“I understand from a utility perspective you do have a concern for cost to ratepayers, but because of our statutory authority, we’re obligated to address reliability concerns,” Kim said. “We do take cost into consideration for formal ballots. … However, we don’t, before we address a reliability concern, start [a] cost-benefit analysis before every” standard authorization request.

Cold Weather Team Grows by 3

The Standards Committee voted to add three new members to the SAR drafting team for Project 2019-06 (Cold weather), having approved the expansion of the team at last month’s meeting. (See “Debate over Cold Weather Team Expansion,” NERC Standards Committee Briefs: June 17, 2020.)

The addition of three team members came as a surprise to some participants. Sean Bodkin, NERC compliance policy manager for Dominion Energy — who, along with Oelker, cast the only votes against the proposal in June — reminded the committee that that motion referred only to adding one or two members to represent small entities.

NERC had received four nominations for the drafting team and recommended two candidates for approval by the committee. Steven Rueckert, director of standards at WECC, moved to add another candidate from the four on the grounds that the existing SAR drafting team had no representatives from the Western Interconnection.

But Bodkin said the motion seemed to overlook better ways of achieving this result. He warned that having three out of 13 members (post expansion) from small entities could actually lead to overrepresentation of the sector.

“I really can’t support adding three additional candidates from a very limited pool,” he said. “If we’re looking for Western Interconnection representation, then we should solicit that from all entities in the Western Interconnection, not just from small entities.”

Bodkin’s argument failed to sway other members, and his ended up being the only “no” vote. Abstaining were Michael Puscas, compliance manager for reliability and operations compliance at ISO-NE; Venona Greaff, senior energy analyst for Occidental Chemical; and independent member David Kiguel.

SDT Candidate Restored After Application Oversight

Another debate was sparked by a motion to appoint the chair, vice chair and members to the SAR drafting team for Project 2020-03 (Supply chain low impact revisions).

The motion presented to the committee requested that members approve nine of the original 10 candidates solicited by NERC for the team. A 10th member was left off the slate because he did not list any references on his application form. Several participants on the call questioned whether this omission really constituted sufficient grounds for rejecting a candidate that otherwise seemed highly qualified.

“If it’s just an oversight, there are compensating aspects [such as] the fact that he’s got such long experience compared to many other members,” said Robert Blohm, managing director of Keen Resources.

NCPA’s Hostler agreed and also asked whether NERC had made it clear to the candidate that the missing references would disqualify him from serving on the team. Kim and Casuscelli did not respond directly to this question but noted that reference checks form a crucial part of the nomination process and that completing the application form didn’t seem like “an unreasonable request.”

“I’ve heard this candidate several times on calls and seen their comments, and I’m surprised they weren’t nominated for the committee, because they’re very adept with the cybersecurity and critical infrastructure protection standards,” Hostler said. “I want to know if that’s the policy to exclude candidates [for lacking references]; if so, candidates need to know that.”

Blohm called for an amendment that would add the excluded candidate back to the slate, which was approved unanimously; the amended slate subsequently passed without objection. The committee also approved a solicitation for additional members to represent entities that only have low-impact cyber systems, as the current slate lacks any such entities.