The NERC Standards Committee last week approved posting for industry comment the Evidence Retention Report produced by the Standard Efficiency Review (SER) Phase 2 team, which recommends reducing the number of evidence retention schemes to eight from the current more than 50.

Unless otherwise specified, the default retention period would be a rolling 48 months, which the report says “is useful for high [violation risk factor] requirements where an entity is audited every six years. It is not useful for medium and low VRF requirements.”

“High volume data” would be retained for 30 days except for a small set of requirements that would be kept for six months.

Voice and audio recordings, which take up a lot of space on computer systems, would be retained for only 90 days.

Michael Puscas of ISO-NE said evidence retention was one of the higher priority issues identified by the Phase 2 team.

A 2014 white paper had also recommended reducing the requirements, but the changes were not enacted. As a result, the report says, “data and evidence retention schemes remain overly complicated and burdensome.”

Comments are due by Sept. 23.

BAL SAR Rejected

The committee voted to reject Arizona Public Service’s April 2018 standard authorization request (SAR) for BAL-002-3 (Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event).

APS said the proposed change — allowing compliance with the standard to have been reached once interconnection frequency has recovered — would prevent the recovery of one event from contributing to the creation of another event. The company said it was attempting to draw attention to a situation in which a balancing authority’s area control error (ACE) is low while the interconnection frequency is high.

APS said intentionally increasing frequency when it is already high is not permissible in normal operations and should be discouraged during emergency operations.

The Standards Committee said modifying requirement Part R1.1 of the standard to include interconnection frequency assessment “would modify the original intent of standard, which is the demonstration of the deployment of reserves to recover from reportable balancing contingency events.”

It said that APS’ concerns “can be addressed by other means.”

“Compliance guidance, reliability guidelines and/or reference documents can be developed to instruct BAs/[reserve sharing groups] on how this should be addressed, including modifications to the Operating Process and Operating Plan (see R2) to better prepare for such situations and manage reserves so that injection of power or firm load shed is not the default response. An effort to develop any of these documents, in concert with the appropriate NERC technical committees, could be completed more quickly than the entire standard revision process. Such an effort will provide different solution(s) than proposed but will align with and not circumvent the requirements in the standard.”

In May, the committee delayed a vote rejecting the SAR after several members said they wanted to add the technical justification for its rejection to the record. (See NERC Panel Delays Action on BAL Standard Request.)

Committee Ponders less In-person Meetings

Director of Engineering and Standards Howard Gugel proposed reducing the committee’s face-to-face meetings, citing internal staff discussions and those with the SC’s Executive Committee.

Gugel proposed “as a conversation starter” reducing the in-person meetings from four to two or three annually, all to be held at NERC’s Atlanta headquarters. NERC is converting its entire sixth floor into conference space to reduce outside meeting costs.

Gugel said the in-person meetings could be supplemented by conference calls every four to six weeks when needed.

“Some of our face-to-face meetings have been rather brief,” Gugel said. “It requires a lot more work for us before the face-to-face meetings than the calls. It can be very taxing on the staff.”

He suggested the Atlanta meetings be scheduled in the spring and fall, when the weather is most temperate and hotels are less busy.

The proposal was quickly endorsed by ISO-NE’s Puscas.

But Venona Greaff of Occidental Chemical said new committee members would benefit from meeting the other members immediately after joining, which is typically in January. Evergy’s Jennifer Flandermeyer and Amy Casuscelli of Xcel Energy agreed.

“I’m pretty reluctant to agree to just two meetings a year. I think that there is real value in face-to-face interactions. We talk about things. It really contributes to the cohesiveness of the committee as a whole. I think that there are some softer, more intangible benefits that often get overlooked when we think about efficiencies and people’s schedules and their travel calendars,” she said. “I would hate to see us lose any effectiveness for the sake of trying to make things better.”

Casuscelli also expressed concern that limiting the meetings to Atlanta might hurt participation by West Coast stakeholders.

California-based consultant Barry Jones seconded Casuscelli’s concern, suggesting consideration of a “NERC West” office.

“I’ve primarily been in the California, Nevada [and] Arizona regions, and when we fly to Atlanta, we lose three hours and it’s really exhausting,” said Jones. “When we fly West to East it eats up an entire week just to go for two days [of meetings].”

Chairman Andrew Gallo said, “There is a good benefit to face-to-face meetings, even when they’re brief,” noting committee members seem to comment more freely in person.

“I do think it sparks more enthusiastic participation,” he said. “There’s just not a whole lot of commenting [on calls]. I don’t know if people are distracted.”

Barry Lawson, of the National Rural Electric Cooperative Association, opposed cutting in-person meetings in half immediately but said he would support an initial switch from four to three meetings “and see how it goes.”

Gugel said the next step will be further discussions with the Executive Committee. “We’ll have more conversations, and at some point, this will be a decision the committee as a whole will be making,” he said.

Other Actions

The committee also:

• Approved the procedure for electing its chair and vice chair for two‐year terms beginning Jan. 1. The election will be held at the Sept. 18 committee meeting in Kansas City.
• Authorized the solicitation of additional nominees for the Project 2019-02 (BES Cyber System Information Access Management) standard drafting team (SDT), which recently lost several members, including its chair.
• Appointed members, the chair and vice chair to the SDT for Project 2019-03 (Cyber Security Supply Chain Risks), as recommended by NERC staff.

– Rich Heidorn Jr.