Members of NERC’s Standards Committee moved forward a slate of standards development projects at their monthly conference call Wednesday after moving to address concerns about stakeholders’ ability to provide feedback.

The biggest debate revolved around the first standards action, which proposed to accept a draft standard authorization request (SAR) to revise reliability standard EOP-004-4 (Event reporting) to ensure that events involving inverter-based resources (IBR) are reported to regional entities or other responsible authorities.

The SAR was developed in response to NERC and WECC’s joint white paper on the widespread reduction of solar output in Southern California on July 7, 2020. NERC’s Reliability and Security Technical Committee (RSTC) endorsed the draft SAR at its meeting on Dec. 6. (See “Members Approve IRPS SARs,” NERC RSTC Briefs: Dec. 6-7, 2022.)

The action before the committee on Wednesday was to accept the draft SAR and authorize NERC to solicit SAR drafting team members and post the proposal for a 30-day informal comment period. However, Southern Co.’s Jim Howell, noting “some feedback from my segment [over] concerns with what this might involve,” suggested modifying the proposal to post the SAR for a formal, rather than informal, comment period.

Latrice Harkness, NERC’s manager of standards development, responded that a formal comment period was unnecessary because industry already had a chance to influence the draft SAR when it was before the RSTC. She added that a formal comment period would require the SAR drafting team to provide a response to stakeholders when it returns to the committee with the final SAR. This would not be required for an informal comment period.

In either case, the team would not be required to revise the SAR in response to comments.

Howell insisted that the committee should err toward giving as many opportunities for industry input as possible.

“There’s still quite a bit of folks not necessarily plugged in to those committees that may have some valid comments about the SAR itself,” Howell said. “I do think [we] would be better served to have a formal comment period where there’s more interaction between the drafting team and the comments up front.”

Marty Hostler, reliability compliance manager for Northern California Power Agency, supported Howell’s proposal, saying that “there are just a host of initiatives out there by FERC [and] NERC on IBRs,” and that it would be inappropriate to move forward with yet another standards project “until we get all these other comments in … from the other IBR initiatives.”

Hostler said a formal comment period would provide a chance “to have industry vet what their opinions are.” Kent Feliks of American Electric Power and William Chambliss of the Virginia State Corporation Commission also voiced support for the idea, with Chambliss seconding Howell’s formal motion to switch from an informal to a formal comment period. The motion passed the committee unanimously.

Other Standards Actions

The committee’s next item also concerned IBRs, with a proposal to accept a draft SAR to “address IBR performance issues” either by creating a new standard or by modifying PRC-004-6 (Protection system misoperation identification and correction).

Like the earlier draft SAR, this proposal was also endorsed by the RSTC at its December meeting. Hostler again expressed misgivings about the SAR, asking why the committee needed to consider two separate projects both intended to address IBRs. Vice Chair Todd Bennett, of Associated Electric Cooperative Inc., responded that the two SARs had very different goals, with the former intended to address reporting of IBR-related incidents and the latter intended to mitigate performance issues within IBRs once they have been detected.

Aside from Hostler’s questions, few misgivings were expressed for this item. Howell explained that he was “not so concerned” about requiring a formal comment period because there is already “a lot of … good information out there from the industry on what this would entail.” The committee voted unanimously to accept the SAR, appoint the drafting team and authorize posting for an informal comment period.

Next up was a proposal to accept two SARs requiring registered entities to perform energy reliability assessments to ensure energy assurance. The SARs were proposed by NERC’s Energy Reliability Assessment Task Force (ERATF) last year and assigned to Project 2022-3 (Energy assurance with energy-constrained resources) at the Standards Committee’s September meeting. Harkness explained that the ERATF and SAR drafting team proposed two SARs to cover risks associated with the operational and planning time horizons separately.

Chambliss abstained from the vote, explaining that “all this work occurred before I got on the committee, and I hadn’t really had a chance to familiarize myself with it.” The proposal — which included appointing the 15 members of the SAR drafting team as the standard drafting team as well as accepting the SAR — otherwise passed without objection.

Also approved without objection was a proposal to appoint the SAR drafting team, including chair and vice chair for Project 2022-05 (Modifications to CIP-008 reporting threshold). The project was also approved at the committee’s September meeting; NERC solicited industry for nominations to the team from Nov. 2 through Dec. 5, receiving 10 nominations whose names were not disclosed at Wednesday’s meeting in accordance with the organization’s confidentiality policy.

Finally, the committee approved a motion to update NERC’s definition of reporting area control error (ACE) as proposed by Project 2022-01 (Reporting ACE definition and related terms). The new definition expands the list of relevant entities and changes certain language to reflect updated NERC terminology.

While no committee members voted against the measure, Robert Blohm of Keen Resources abstained from the vote. He said he was concerned about the committee’s inability to review the final comment form before it is posted, mentioning that he had already expressed misgivings about the lack of questions regarding the definition of ACE Diversity Interchange. Describing this absence as “a serious technical error … that could affect the acceptability” of the ballot outcome, Blohm said he could not “in good conscience” support the motion.

Members Approve Executive Committee Slate

In addition to their standards actions, attendees approved the membership of the Standards Committee’s Executive Committee (EC) for 2023, to serve one-year terms.

According to the Standards Committee’s charter, the EC is to comprise five members including the chair and vice chair — currently Amy Casuscelli of Xcel Energy and Bennett, respectively. At its last meeting, the committee invited those interested in one of the three remaining seats to submit their nominations by Jan. 9. (See “2023 Executive Committee Nominations,” NERC Standards Committee Briefs: Dec. 13, 2022.)

Three committee members nominated themselves prior to the meeting: Venona Greaff of Occidental Chemical, Sarah Snow of Cooperative Energy and Charles Yeung of SPP. Troy Brumfield, regulatory compliance manager at American Transmission, also threw his hat in during the meeting. Members chose Brumfield, Greaff and Snow in the final vote. Bennett thanked the new EC members and encouraged others “to get involved with this committee as much or as little as they like.”