In a special teleconference on Thursday, NERC’s Standards Committee unanimously agreed to submit for industry comment a proposal to update the organization’s Rules of Procedure intended to streamline the reliability standard development process and allow a faster response to emerging issues.

The changes apply to section 300 of the ROP, covering standards development, and to Appendix 3A, NERC’s Standard Processes Manual (SPM). With the committee’s approval, the planned updates to the SPM will be posted for a 45-day formal comment period, with ballot pools to be formed in the first 30 days and an initial ballot conducted during the last 10 days of the comment period. Comments on these revisions will be submitted through NERC’s Standards Balloting System.

The proposed ROP changes will be posted for their own 45-day comment period, to run concurrently with those to the SPM. Because these revisions are not subject to ballot body approval, stakeholders are requested to comment on them via email. In response to a question from Marty Hostler of the Northern California Power Agency, NERC Senior Counsel Lauren Perotti confirmed that these emailed responses will be organized into a “matrix consideration of comments” and posted to NERC’s ROP page.

The biggest change to the ROP is the addition of a new section 322, which would give NERC’s Board of Trustees “the authority to direct the development of a reliability standard in extraordinary circumstances where the board finds that issuing a directive is essential to address an urgent reliability issue.” Currently only FERC has the authority to direct standards development unilaterally, under section 321; the proposed section 322 is modeled on the existing rule.

NERC Trustee Sue Kelly | NERC

NERC’s board ordered the Standards Committee to pursue the ROP updates at its November meeting, following a proposal by the Standards Process Stakeholder Engagement Group in October. Trustee Sue Kelly, the committee’s liaison to the board, told members last month that the board was trying to address concerns that NERC’s “deliberative” standards development process was not keeping up with the increasingly rapid pace of industry change. (See NERC Board Member Argues for Increased Authority.)

Other revisions to the ROP include adding a provision in section 316 requiring that the standards development process be accredited by the American National Standards Institute (ANSI). This proposal drew another question from Hostler, who asked why, if “you have an accredited system already for standards … would you not want to follow that?”

In response, Latrice Harkness, NERC’s manager of standards development, explained that “in order to move forward with … the streamlining of the standards development process, there were certain things that we had to move away from,” including maintaining ANSI accreditation. However, she assured listeners that the development process is still modeled on ANSI procedures.

Perotti added that “while we may not be following some of the more granular ANSI procedural requirements, we still will be adhering to the general framework of due process, public comment, balanced stakeholder voting and so forth.”

The SPM changes include creating a tiered system of comment periods, under which the initial 45-day comment and balloting periods would be followed by shorter comment periods “when the issues are likely to have narrowed.” A revised Section 4.13 would remove the requirement for a final ballot to confirm the results of the most recent successful ballot, if the standards development team “has made a good faith effort at resolving objections [and] is not making any substantive changes” to the finished standard.