By Rich Heidorn Jr.

FERC last week told the North American Electric Reliability Corp. to provide additional detail on its new risk-based approach to reliability compliance monitoring and enforcement.

The commission had approved NERC’s Reliability Assurance Initiative in February, saying it would allow regulators to focus resources on the most serious issues. FERC told NERC to revise its rules of procedure to define the RAI concepts and programs and provide details on NERC’s planned oversight of the program. (See New NERC Enforcement Methods Allow Self-Logging Minor Risk Issues.)

In its Nov. 4 order (RR15-2), the commission told NERC to provide additional information on the program in its annual reports, including:

• performance assessments of Regional Entities under the program;
• an analysis of self-logging data provided by REs “to measure the quality and consistency of self-logging across regions”; and
• the types of “data driven” metrics it will track.

FERC also ordered NERC to eliminate “regulator trust” as a “success factor” in its analyses. “The notion of ‘regulator trust’ is a subjective concept that is not conducive to quantitative measurement,” the commission said. The commission also ordered revisions to the rules of procedures to set data retention requirements for self-logging data.

Commissioner Cheryl LaFleur issued a concurring statement cautioning FERC against micromanaging NERC.

“The RAI program grew out of a well-documented concern … that NERC and the Regional Entities’ reliability work was unsustainably bogged down in paperwork on relatively minor issues, which detracted from our collective ability to focus on more significant reliability matters. Going forward, I believe we must be careful not to require, as part of our ongoing oversight, the type of overly prescriptive and time-consuming analysis that the RAI program was designed to avoid,” she said.

“FERC and NERC should focus our attention on significant issues before us like cybersecurity, geomagnetic disturbances and adapting the electric grid to changes in the resource mix. We should also stay focused on the risk-based prioritization that led us to approve RAI, and not require NERC to repeatedly justify that program.”