FERC Approves Reliability Standard Retirements, Replacements
NERC's headquarters in Atlanta.
NERC's headquarters in Atlanta. | © RTO Insider LLC
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FERC approved two new reliability standards developed through NERC’s Standards Efficiency Review (SER) process while agreeing to the retirement of six others. 

FERC has approved two new reliability standards developed through NERC’s Standards Efficiency Review (SER) process while agreeing to the retirement of six others. 

The two new standards, TOP-003-6.1 (Transmission operator and balancing authority data and information specification and collection) and IRO-010-5 (Reliability coordinator data and information specification and collection), were adopted by NERC’s Board of Trustees at its meeting in August. (See “Standards Process Changes Accepted,” NERC Board of Trustees/MRC Meeting Briefs: Aug. 16-17, 2023.) FERC gave its approval in a filing Thursday, noting that no motions to intervene, comments or protests had occurred during the 30-day comment period (RD23-6). 

Phase 2 of the SER produced four efficiency concepts for NERC to pursue in future standards development activities; the second of these concepts concerns consolidation of information and data-exchange requirements, which the new standards are intended to address. This recommendation was based on the concern that requirements in the current reliability standards might create “unnecessary administrative burdens” for entities trying to demonstrate compliance, as the ERO said when submitting the standards to the commission. 

The goal of Project 2021-06, which developed IRO-010-5 and TOP-003-6.1, was to simplify the burdens associated with the standards they will replace while limiting data retention requirements that are not necessary to grid reliability and clarifying expectations regarding data specifications. The changes to the final standards mainly apply to the data retention requirements, which NERC said in its submission are “substantively similar, if not functionally identical” between the two standards. 

IRO-010-5 contains new language requiring reliability coordinators to maintain specifications for “the data and information necessary … to perform [their] operational planning analyses, real-time monitoring and real-time assessments.” It replaces language requiring “a periodicity for providing data” with more detailed requirements detailing time periods and criteria for respondents to provide data, and for identifying a process to resolve conflicts with respondents. 

TOP-003-6.1 received similar changes, in keeping with NERC’s proposal to bring the two standards closer in line with each other. The main difference between the two is that TOP-003-6.1 targets transmission operators and includes language relating to their relationships with their balancing authorities. 

The commission also approved the implementation plan submitted by NERC, according to which both standards will become effective on the first day of the first calendar quarter 18 months after FERC approval. According to that timeline, the standards will take effect July 1, 2025. 

NAESB Rules to Replace MOD A Standards

FERC also agreed Oct. 26 to the retirement in their entirety of six standards identified in the SER as “no longer necessary” (RM19-17): 

    • MOD-001-1a (Available transmission system capability); 
    • MOD-004-1 (Capacity benefit margin); 
    • MOD-008-1 (Transmission reliability margin calculation methodology); 
    • MOD-028-2 (Area interchange methodology); 
    • MOD-029-2a (Rated system path methodology); and 
    • MOD-030-3 (Flowgate methodology). 

NERC submitted the proposed retirements to the commission in 2020 while also proposing to retire four other standards and modify five more; the latter retirements were accepted at the time. (See FERC Accepts Removal of 18 NERC Requirements.) 

However, while FERC gave its preliminary approval to retire the so-called MOD A standards, the decision was complicated by the fact that the commission’s intended replacement for these standards — the North American Energy Standards Board’s (NAESB) Standards for Business Practices and Communications Protocols for Public Utilities — had recently been updated. At the time, FERC was still accepting industry comments on its proposal to adopt the updated NAESB standards. 

The commission decided to defer its decision on the MOD A standards until “a later time.” In its filing last month, FERC noted that the NAESB standards have been fully implemented and that it was now satisfied that removing the MOD A standards “will not result in a reliability gap.” 

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