NERC Standards Committee Chair Andrew Gallo urged committee members Wednesday to file comments on Phase 2 of NERC’s Standards Efficiency Review before Friday’s deadline.
Gallo made his comments after Howard Gugel, NERC senior director of engineering and standards, presented an update on the review, which is considering retiring or consolidating administrative or duplicative standards.
The inquiry is considering changes in six areas of NERC’s Operations & Planning and Critical Infrastructure Protection standards, including evidence retention time frames, moving requirements to guidance, simplifying training requirements and consolidating data exchange requirements.
NERC held a webinar on the initiative Feb. 22 and accepted additional comments until Friday.
“I would really encourage all of the members of the Standards Committee … to please engage your folks in the process,” said Gallo, director of corporate compliance for Austin Energy. “It’s very rare that we [have] had opportunities to do a hard look at the standards.
“Everybody is so quick to [complain] about the standards … ‘[It’s] administrative. It’s burdensome. It doesn’t really help reliability,’” he added. “Those kinds of things you hear … all the time. Here’s our chance — let’s use it. This is a real good opportunity for us to try and do away with some of the things that are more administrative.”
Standards Grading Process on ‘Pause’
In a related matter, the committee agreed to “pause” work on the Standards Grading Process until May 2020 to avoid conflicts with other current initiatives with overlapping resources and scope.
In 2016 the SC created the Periodic Review Standing Review Team, composed of the chairs of the SC, Operating Committee, Planning Committee, a regional representative and NERC staff, to annually grade a selected set of standards.
Gugel said the initiative resulted from a charge by the Board of Trustees to develop metrics to signal whether revised standards have resulted in improvements. The 2017 review graded 47 requirements of eight standards.
“Given all the changes that we’ll be making with the Standards Efficiency Review, and potentially changes that would [be made] in Phase 2, we thought it would be a good idea this year to put a pause on that so we can concentrate our efforts, our focus, on the efficiency review,” Gugel said.
Cyber System SAR Approved for Posting
The committee accepted a Standards Authorization Request (SAR) and authorized a 30-day comment period and 30-day drafting team nomination period to consider standard changes to accommodate use of third-party “cloud” data storage providers.
The SAR was proposed March 1 by Tri-State Generation and Transmission Association on behalf of a sub-group of the Critical Infrastructure Protection Committee (CIPC) to consider use of encryption as a security measure under NERC BES Cyber System Information (BCSI) access management rules.
The project, which was endorsed by the CIPC on March 5, would consider changes to CIP-004-6 and CIP-011-2.
“The standard should allow multiple methods for controlling access to BES Cyber System Information, rather than just electronic and physical access to the [BCSI] storage location,” the SAR says. “As currently drafted, the requirement is focused on access to the ‘storage location,’ and therefore does not permit methods such as encryption and key management to be utilized in lieu of physical/electronic access controls.”
Functional Model Advisory Group Work Frozen
The committee agreed to direct the Functional Model Advisory Group (FMAG) to cease work pending deliberations on whether the group should continue or be eliminated to avoid confusion over registration requirements and related standards.
Created in 2014, the FMAG was tasked last year with aligning the terms and definitions in the Functional Model guideline with those used in NERC’s Rules of Procedure. It also was asked to solicit industry input on whether it should continue its work and make “more substantive” revisions to the FM to align with industry practices, NERC said.
At its December 2018 meeting, the SC endorsed the FMAG’s work on the first task but delayed publication of its report. At the same time, several SC members called for creating a small group of members from the NERC standing committees to consider next steps.
In February, the Standing Committee Coordinating Group (SCCG) agreed to form an ad hoc group of NERC staff, Compliance and Certification Committee leadership and SC leadership to map out plans for the FM. SC Chair Gallo instructed the FMAG to refrain from additional work until the ad hoc group makes its recommendations.
“What’s happened historically is, any time a change is made to the Functional Model, there are those who think it automatically changes registration, how standards are written. So, it’s caused a lot of angst,” explained Charles Yeung, SPP’s executive director for interregional policy. “It’s only changes to the registration criteria that can change entity registration.”
Gallo, a member of the ad hoc group, said he’d like the issue resolved quickly. “We don’t want this to languish very long. The Functional Model work has been going on now for a couple of years. It’s been stopping and starting and [moving in] fits and starts,” he said. “That’s not good for anybody.”
Revised Charter OK’d
Members approved a new committee charter, replacing the version last amended in December 2014 and reviewed and reaffirmed in December 2016. The revisions, which are mostly cosmetic or updates, were drafted by the SC Executive Committee and will be submitted to the board at its next meeting.
“I thought there were a lot of changes in here that didn’t really change anything,” commented Barry Lawson, associate director of power delivery and reliability for National Rural Electric Cooperative Association. “A few of the changes are substantive.”
Section 5.1 amends the timing for selecting the committee chair and vice chair, requiring nominations about 150 calendar days before the end of the expiring terms.
Another member expressed concern about the elimination of a section mandating at least two Canadian representatives. But NERC’s Gugel said the section was removed as duplicative because Canadian representation is protected in Rules of Procedure Appendix 3B.
Modifications Within SAR Scope
The committee agreed that making modifications to IRO-008-2 and TOP-001-4 are within the scope of the Project 2015-09 system operating limits SAR.
The Standards Drafting Team (SDT) requested the committee’s approval to make clarifying modifications to the two standards to ensure their consistency with proposed FAC-011-4 Requirement R6 regarding logging and reporting of system operating limits (SOL) exceedances.
The SDT is modifying FAC standards that address SOLs and interconnection reliability operating limits (IROLs).
SDT member Stephen Solis, of ERCOT, said several entities have market mechanisms for addressing projected post-contingency exceedances identified in real-time assessments and generally can mitigate them within minutes.
Solis said the revised rules would give entities up to 30 minutes to address the issue before having to report an exceedance to its reliability coordinator or transmission operator (TOP).
Under proposed FAC-011-4 R6, if a TOP’s real-time assessment indicates that a contingency would cause a facility to exceed its emergency rating, it would constitute an SOL exceedance, triggering logging and other documentation requirements.
Several entities have complained that the requirement creates an undue burden for logging, communicating with the RC and creating audit-ready compliance documentation, Solis said. They said the unnecessary logging and communications would divert system operators’ attention from operating the system, creating an increased reliability risk.
“We can’t lower what the requirements are, but we can clarify what the requirements are,” Solis said. “Solidify for everybody what is and is not an SOL exceedance.
“If you’re a TOP and you see a voltage limit exceedance, you can [perform switching] in 30 seconds to a minute,” Solis said. “Why [should] you then [have] to call your RC right after these normal-type operating actions that happen throughout every day?”
Participant Conduct Policy
NERC Senior Counsel Lauren Perotti briefed the committee on NERC’s new Participant Conduct Policy, which spells out acceptable (e.g., discussing issues) and unacceptable (e.g., engaging in price fixing, using NERC for commercial purposes) conduct at stakeholder meetings.
The policy will replace individual policies previously adopted by the SC and Operating Committee. It applies to all NERC standing committees.
“The whole point of us putting this together was to promote an efficient and effective use of our participants’ time. NERC relies on its stakeholders to achieve its mission,” Perotti said.
The rules bar members using NERC’s listserv to express personal views unless they are directly related to the scope of work. “‘I really hate XYZ politician’ is not appropriate,” Perotti said.
Perotti said that when stakeholders speak to news reporters, they should specify that they are speaking for themselves or their company and not for NERC.
— Rich Heidorn Jr.
