NERC is seeking comments through 8 p.m. Nov. 20 on proposed changes to SERC Reliability Corporation’s Regional Reliability Standards Development Procedure (RSDP), stemming from recent changes to the regional entity’s executive structure.

Each RE files an RSDP with NERC to “define the steps in that region’s process for developing, reaffirming and withdrawing its regional reliability standards” and to ensure that regional standards align with continent-wide standards approved by FERC and its Canadian and Mexican counterparts. RSDPs must be reviewed and submitted to NERC every five years — or earlier if the RE’s board feels revisions might be needed.

SERC’s current RSDP was approved by the RE’s Board of Directors in October 2017 during its five-year review and accepted by NERC the following year. This revision, which comes about two years before the regularly scheduled review, is a relatively minor update intended to bring the RSDP in line with SERC’s updated executive structure as described in the RE’s revised bylaws approved by FERC in July. (See FERC Approves SERC’s Bylaw Changes.)

Changes to be implemented under the new bylaws include changing the Board Compliance Committee into a Board Risk Committee, transforming SERC’s Board of Directors into a hybrid board comprising both sector representatives and independent directors and eliminating the use of alternates and proxies for directors and independent directors. The updated RSDP reflects these changes by removing references to Board representatives and alternates and replacing references to the SERC Executive Committee with SERC Board of Directors.

In addition, the new document replaces references to the former executive committees of SERC’s technical committees to reflect their unification into a single Operations Planning and Security Executive Committee, and revises abbreviations throughout the RSDP to ensure internal consistency. The updates are planned to take effect Jan. 1, 2021, along with the new bylaws.

Openness, Balance Among Commenting Criteria

Industry stakeholders are being asked to comment on whether SERC’s updates meet NERC’s requirements for all regional RSDPs. Those requirements include the following:

• Openness — The RSDP must allow any person or entity that is “directly and materially affected by the reliability of the bulk power system within the regional entity” to participate in the reliability standard approval process.
• Inclusivity — Any person or entity with a direct and material interest must be permitted to express and justify an opinion, have that position considered and appeal through an established process in the case of an adverse decision.
• Balance — Regional RSDPs must have a balance of interest and not be dominated by any two interest categories. No single interest category can be allowed to defeat a matter.
• Due process — Standards development processes must provide reasonable notice and opportunity for public comment, including, at minimum, public notice of the intent to develop a standard, a comment period on the proposed standard, due consideration of comments and the opportunity for stakeholder ballots.
• Transparency — All actions and materials relating to standards development must be transparent, and members of the public must be notified and allowed to attend all standards development meetings.

Following the comment period, SERC will submit the revised RSDP for approval by NERC’s Board of Trustees, most likely at its meeting in February 2021. Earlier this year, the Board accepted the Northeast Power Coordinating Council’s revisions to its own regional standard processes manual, aimed at clarifying outdated language and establishing closer alignment with NERC’s standard development process. (See “Budget, ROP, Standards Actions,” NERC Board of Trustees/MRC Briefs: Aug. 20, 2020.)