By Rich Heidorn Jr.

A NERC standards drafting team (SDT) has opened a final ballot on the elimination of all or parts of 18 reliability standards as Phase 1 of the organization’s standards efficiency review (SER) nears its conclusion.

Ballot pool members will have until May 2 to vote on the changes: the withdrawal of one proposed reliability standard, the complete retirement of 10 standards and the elimination of certain requirements for seven standards. (See chart.)

All the proposed retirements received 88 to 99% support in segment-weighted voting in the initial ballot that closed April 12. “They all passed at pretty high percentages,” observed NERC’s Laura Anderson, standards developer for the SDT at a team meeting April 17.

NERC’s ballot body, representing its 10 industry segments, currently has 525 members.

Proposed retirements that clear a two-thirds segment-weighted threshold on the final ballot will proceed to final approval by NERC’s Board of Trustees, likely at the board’s May meeting. Votes from the initial ballot are automatically included in the final ballot, although voters can change their positions.

Pruning the Rules

The Standards Efficiency Review Retirements effort (Project 2018-03) was created to take a second look at the rules that have been created since FERC certified NERC as the electric reliability organization (ERO) in 2006.

Three teams — representing real-time operations, long-term planning, and operations planning — identified for elimination requirements that were duplicative, obsolete or that were administrative and did not provide reliability benefits. Many of the standards to be retired relate to commercial business practices governed by the North American Energy Standards Board (NAESB) Wholesale Electric Quadrant (WEQ).

NERC last month closed the comment period on Phase 2 of the SER project. The phase involves considering changes in six areas of the organization’s operations and planning (O&P) and critical infrastructure protection (CIP) standards, including evidence retention time frames, moving requirements to guidance, simplifying training requirements and consolidating data exchange requirements. (See “Chair Urges Comments on Standards Efficiency Review,” NERC Standards Committee Briefs: March 20, 2019.)

The comments on the Phase 1 recommendations indicated how much the industry has changed since NERC became the ERO and gained enforcement authority.

For example, Black Hills Corp. said requirements 16 and 17 of standard TOP-001-4 provide no reliability benefit. The rule is intended to ensure prompt action to prevent or mitigate instability, uncontrolled separation or cascading outages.

The requirements direct transmission operators and balancing authorities to provide their system operators with authority to approve planned outages of its telemetering and control equipment, monitoring and assessment capabilities, and associated communication channels.

The requirements “don’t even align with most, if not all, standard business processes,” Black Hills’ Maryanne Darling-Reich said. “The outage coordinator, [supervisory control and data acquisition emergency management system], IT networking and communications departments determine the impacts of all ‘planned’ outages of telemetry equipment. Most system operators do not even have the technical knowledge to make a substantiated decision to delay or postpone this work.”

MOD Standards

Eight of the 18 standards proposed for retirement were from NERC’s modeling (MOD) family of rules. The SDT proposed the elimination of seven of the MOD standards, including those on calculations of capacity benefit margins, transmission reliability margins and transfer capability — requirements incorporated in NAESB standards.

The standard authorization request (SAR) that initiated the SER project said that available transfer capability (ATC) and available flowgate capability (AFC) are “commercially based values used to facilitate a market for unused transmission capacity in an open access environment and that the values do not directly control the operation of the [bulk power system]. … [Transmission operators] are ultimately responsible for operating the grid in a reliable manner consistent with system operating limits, not ATC/AFC values.”

The team also proposed not implementing MOD-001-2, which has been awaiting FERC approval since February 2014 (RM14-7). It was intended to ensure calculations of available transmission system capability support reliability and that the methodology and data behind the calculations are disclosed to applicable registered entities.

The SAR said MOD-001-2 was not needed because although ATC and AFC values can influence real-time conditions, other standards, including subsequent improvements to TOP rules, ensure that real-time operations observe system operation limits. The “commercially based values and market related issues [regarding ATC/AFC] should not be addressed through NERC reliability standards,” it said.

Despite the high level of support for the retirements, there were some forceful dissents.

Duke Energy, for example, said it could not support the elimination of the seven existing MOD standards if MOD-001-2 is withdrawn.

“We disagree with the commercial-based focus that the drafting team took in the technical rationale document,” Duke’s Kim Thomas wrote. “While these MOD standards (and ATC calculation) may have some commercial-based elements to them, they also put in place valuable boundaries that help promote consistency in how the industry calculates these values. Removing these boundaries does not promote reliability for the bulk electric system and introduces additional burden to the real-time system operator.”

Southern Co. took a similar position, saying that transferring the seven MOD standards to NAESB without enacting MOD-001-2 would upset the “appropriate balance of addressing reliability-related concerns, while incorporating any market related issues.

“Simply stating that ATC/AFC calculations are primarily commercially focused elements and that there are mechanisms in place to address reliability in real time is an oversimplification of the ATC/AFC concept,” Southern’s Marsha Morgan wrote. “Inaccurately modeling and assessing transfer capability which considers real physical transmission limits on both the host and neighboring systems can create extremely complicated situations in real time that can unduly burden system operators.”

PJM, which was neutral on the elimination of MOD-001-2, supported the proposal to transfer the other MOD standards to NAESB, saying “reliability components of congestion management are handled amongst Eastern Interconnect parties through various established coordination processes.”

It warned against additional revisions to the NAESB WEQ rules, “especially those driven by issues unique to particular seams or between specific entities, as those issues may not be realized by other parties.”

“Therefore, blanket revisions may unnecessarily impact reliability and/or market aspects for other entities,” PJM’s Preston Walker said.

INT Standards

Also proposed for retirement are four interchange scheduling and coordination (INT) standards relating to interchange coordination, dynamic schedules, pseudo-ties and transmission loading relief procedures.

The SAR said the standards are duplicative of NAESB rules and that two of them are unenforceable because the “purchasing selling entity” is no longer a NERC registered function.

Duke also opposed the retirement of requirements 3.1, 4 and 5 of INT-006-4.

“We are not confident that this issue is adequately covered in the NAESB standards. Unlike the NERC standards which aim to promote reliability, the NAESB standards are commercially focused, and are not viewed as essential to maintaining a reliable system,” Thomas said. “We believe that not having these conditions outlined could negatively impact reliability.”

Morgan disagreed, saying requirements 4 and 5 are duplicative of the NAESB e-Tagging specifications “and are not a reliability-related task performed by a NERC registered entity.”