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Draft 2018-2020 Reliability Standards Development Plan

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Start Date: 06/26/2017
End Date: 07/25/2017

Associated Ballots:

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Hot Answers

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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On page 3 of the plan, under “Projects Commencing in 2018” it indicates PER-001-1.1(ii) as one of the standards eligible for periodic review in 2018. The PER-001-0.2 standard retired 3/31/2017. We believe that is a typo & should reference the PRC-001-1.1(ii) standard, which is in effect.

Tara Lightner, On Behalf of: Sunflower Electric Power Corporation - SPP RE - Segments 1

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Other Answers

Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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For future RSDP’s, please consider adding standards related to RFI’s and SAR’s that were rejected by the SC if they failed to meet the criteria for acceptance.

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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We agree there should be feedback into the standards process.  That said, feedback to create new or revised standard should focus on risk, reliability or security data, and enforcement information.  If there is not data (e.g., multiple cases of an issue causing a reliability problem), a standard is likely not the best tool to initially address the issue. 

While the CMEP can provide useful feedback for potential changes to a standard (e.g. unreasonable performance expectation regarding most violated standards), we suggest that these should not be handled directly and initially in the standards process.  Flaws in performance expectations or low value requirements that don’t contribute to reliability could be flagged as Compliance Exception candidates and handled as such for a period of time in a transparent manner.  The exception candidates could be evaluated over time and those that don’t contribute to reliability retired periodically in groups.  We agree that compliance history associated with a standard be presented as part of the review process.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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We agree there should be feedback into the standards process.  The primary feedback to create new or revised standard should focus on risk and data.  If there is not data (multiple cases of an issue causing a reliability problem), a standard is likely not the best tool to initially address the issue. 

While the CMEP can provide useful feedback for potential changes to a standard (e.g. unreasonable performance expectation regarding most violated standards or low risk administrative requirements), we suggest that these flaws should not be handled directly and initially in the standards process.  Flaws in performance expectations or low value requirements that don’t contribute to reliability could be flagged as Compliance Exception candidates and handled as such for a period of time.  The exception candidates could be evaluated over time and those that don’t contribute to reliability retired periodically in groups.  

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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Elizabeth Mallett, On Behalf of: North American Energy Standards Board, NA - Not Applicable, Segments NA - Not Applicable

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APPA supports the Reliability Issues Steering Committee (RISC) and standing committees being important parts of the standards development feedback loop.  The RSDP lists feedback coming from various entities that can provide appropriate input for consideration of risks that can potentially lead to new standards.  Significantly, public power entities depend on the RISC to provide the key input on reliability risks and the need for new standards.  Because the RISC is comprised of members of the standing committees and gains feedback from these industry experts, public power entities respect the RISC’s findings and standards input. 

 

Regarding the review of existing standards, the RSDP lays out the Standards Grading Metric that will be employed by the Periodic Review Standing Review Team (PRSRT).  Similar to the RISC, the PRSRT will get feedback from the standing committees and industry will be able to comment on the PRSRT grading.

 

While public power recognizes that the timing is not optimal for the RSDP, the standards review or Paragraph 81 process that came out of the June 22 FERC Reliability Technical Conference likely will contain parallel or overlapping work with the PRSRT work, that will require a coordinated process.  Specifically, the coordinated process will need a feedback loop that considers input from the industry entities that have significant experience with the existing standards.  The RSDP needs to include the evolving second Paragraph 81 effort and describe how it will coordinate with the PRSRT and include a feedback loop with industry.  

Jack Cashin, On Behalf of: American Public Power Association, , Segments 3, 4

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FMPA supports the comments of the American Public Power Association. Additionally, FMPA believes clarity and transparency are needed regarding how feedback received through the mechanisms described in the RSDP will be applied in the standards development process.

FMPA, Segment(s) , 12/5/2016

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Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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Hot Answers

Regarding Periodic Reviews, Tri-State would like to see standards be in effect and fully implemented for a longer period of time, such as 5 or more years, before having them reviewed again. Some of the standards listed have just become effective as of late 2016 (FAC-003-4, MOD-025-2, PRC-002-2, and PRC-019-2) or even as recent as early 2017 (IRO-001-4, IRO-010-2, IRO-017-1, MOD-029-2a, MOD-030-3, MOD-033-1, PRC-015-1, PRC-016-1, TOP-002-4, and TOP-003-3). One of those standards listed, PRC-002-2, has a phased implementation plan and hasn't completely gone into effect so we don't understand why it should be reviewed. Unless there is a SAR that points out a specific issue, we would like to see standards remain in steady-state for longer periods of time to better understand the effectiveness of the standard.

We think there also might be an error in the list of standards eligble for Periodic Review. PER-001-1.1(ii) is listed but think that is meant to be PRC-001-1.1(ii) since there is no active PER-001 standard.

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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Tara Lightner, On Behalf of: Sunflower Electric Power Corporation - SPP RE - Segments 1

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Other Answers

Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Page iii: We agree with the “goal to develop a stable set of clear, concise, technically sound, and results-based NERC Reliability Standards and to retire requirements that do little to promote reliability”.  However, the plan does not appear to stabilize the standards or focus revised or new standards on risk.  We are on a pace of well over 30 new or revised standards or portions of standards becoming enforceable annually.

Page iv: We believe there needs to be a reassessment of the direction and approach to Periodic Reviews and Enhanced Periodic Reviews.  While most would agree NERC and the industry have created a sound body of standards, we continue to revise standards without a defined focus, need, or risk.  There is significant overhead even with apparent minor changes to standards.   Registered Entities need to revise procedures, training, controls, RSAWs and validate all these are in line with the new wording of the standards.  The current approach churns well-understood standards, often making them more complex and less focused. 

The current approach deviates from the 10 year review obligation and opens the standard for revision before laying out the case for change and polling the industry on whether the suggested changes merit the addition cost of revising the standard.  Most of the standards listed in the RSDP as needing review have been effective for less than two years, which means most have not even been through a single audit cycle.

When there are FERC directives, the industry should be brought into the discussion to offer insight on equally effective alternatives and cost effective ways to address the directive.  This should be done prior to forming a drafting team and could be done by the Standing Committees. 

NERC should affirm whether all past open directives are still necessary given the length of time that has passed.  Additionally, there may be value in reaching out to the new FERC Commissioners to determine if the outstanding priorities are better addressed through alternative means.

Page 3: The plan lists over 30 standards “eligible for review” that will be considered for drafting work.  It appears most of these standards are nowhere near their 10 year review point and several have other revisions in queue.  Some may result in wasted effort.  For example,  MOD-001 and the proposal to retire MOD-004, -008, -028 through -030 are under an open  NOPR from July 2014.  Until FERC issues an order on the MOD standards and the associated NAESB WEQ-023, these revised standards are in a state of limbo and do not need to be reviewed.

We believe NERC should publish a listing that denotes when a standard is due for its 10 year review and not initiate work until perhaps year 7 or 8.  Additionally, the periodic review team should lay out the issues with a given standard or set of standards and the industry should be given the opportunity to vote whether the standard is acceptable as is or whether the suggested changes merit revision.  The industry should also provide input via a straw poll on which suggested changes should be addressed.

Page 4: We have concerns with the direction of the Standards Grading effort as it appears that it will lead to continued cases of taking standards out of their 10 year review cycle, and therefore will lead to continued churn.  As discussed in the SRC comments on the Standard Grading Effort submitted previously, the SRC continues to have concerns with the overall grading methodology.  If continued, we believe the grading approach should be used as a data input for two situations (prior to balloting a standard and as an input as a standard approaches its 10 year review cycle).  We also propose that it should not be assumed that requirements that receive a low content score be revised to raise their score.  If the requirement does not add value and if there is no evidence of violations of the requirement leading to reliability issues, the requirement should be placed in a Compliance Exception candidate category.  If over time data shows there is no reliability value provided by the requirement, it should be considered for retirement.  Ultimately, if industry continues to revise standards that have been only effective two years, it means that NERC and the applicable entities should be focusing on the quality of new standards.

We have one final suggestion regarding retirement of requirements.  If this is the only change to a standard, we suggest that the requirement numbering with the standard remain the same and the existing wording for said requirement be replaced with “Retired”.  Renumbering requirements causes a ripple effect in Registered Entities’ procedures, data bases, and compliance documentation.

 

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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The approximations given for hours spent by subject matter experts (drafting team members, most likely) on standards development projects appear to unrealistically low. Have these estimations been provided by the drafting team members themselves? If not, NERC may wish to consider having each project team provide their own estimations, for inclusion in the annual Reliability Standards Development Plan. A more accurate assessment of the time spent allows industry to see, and more fully appreciate, the time and effort spent by these individuals on this valuable work. In addition, and in further support of the above, NERC may wish to obtain and share estimates of time spent by active/contributing observers (and all participants, really) who provide support in these efforts as well. Once again, a more accurate estimation of time spent by all these individuals would give industry a better appreciation of the time and effort spent.

 

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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The draft plan does not provide the final grades for Standards graded in 2017 (i.e., Attachment 1 is blank).  Will industry get a chance to review the results of the PRSRT’s grading efforts prior to finalizing the 2018 – 2020 plan?

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Page iii: We agree with the “goal to develop a stable set of clear, concise, technically sound, and results-based NERC Reliability Standards and to retire requirements that do little to promote reliability”.  Our challenge is that the plan does not appear to stabilize the standards or focus changed and new standards on risk.  We are on a pace of well over 30 new or revised standards or portions of standards becoming enforceable annually.

Page iv: We believe there needs to be a reassessment of the direction and approach to Periodic Reviews and Enhanced Periodic Reviews.  While most would agree NERC and the Industry have created a sound body of standards, we continue to revise standards without a defined focus, need, or risk.  There is significant overhead even with apparent minor changes to standards.   Registered Entities need to revise procedures, training, controls, RSAWs and validate all these are in line with the new wording of the standards.  The current approach churns well-understood standards, often making them more complex and less focused. 

The current approach deviates from the 10 year review obligation and opens the standard for revision before laying out the case for change and polling the industry whether the suggested changes merit the addition cost of revising the standard. 

Page 1.  FERC Directives.  Given the incoming new Commissioners and new Administration’s expectations on regulations, we suggest that NERC hold discussions with FERC to determine if all outstanding directives are still priorities and whether some of these might be effectively addressed through alternate tools.

Page 3: The plan lists over 30 standards “eligible for review” that will be considered for drafting work.  It appears most of these standards are nowhere near their 10 year review point and several have other revisions in queue. The vast majority of the standards listed as eligible for review have been effective for less than two years, which means they have not even gone through one full audit cycle.  There are other projects that appear will end up in wasted effort.  For example,  MOD-001 and proposal to retire MOD-004, -008, -028 through -030 are under an open NOPR from July 2014.  Until FERC issues an Order on the MOD standards and the associated NAESB WEQ-023, these revised standards are in a state of limbo. 

We believe NERC should publish a listing that denotes when a standard is due for its 10 year review and not initiate work until perhaps year 7 unless there is data and grading that points to significant flaws.  Additionally, the periodic review team should lay out the issues and the industry given the opportunity to vote whether the standard is acceptable as is or whether the suggested changes merit revision.  The industry should also provide input via a straw poll on which suggested changes should be addressed.

Page 4: We have concerns with direction of the Standards Grading effort as it appears that it will lead to continued cases of taking standards out of their 10 year review cycle and lead to continued churn.  We believe the grading approach should be used as a data input for two situations (prior to balloting a standard and as an input as a standard approaches its 10 year review cycle).  We also propose that should not be assumed that requirements that receive a low content score be revised to raise their score.  If the requirement does not add value and if there is no evidence of violations of the requirement leading to reliability issues, they should be placed in a Compliance Exception candidate category.  If over time data shows there is no reliability value provided by the requirement, it should be considered for retirement. 

Projects Commencing in Future Years – The list of selected standards is missing in each of the out years. The Plan should list standards that make sense based on those closes to their mandatory 10 year review and the associated grades assigned. 

Enhanced Periodic Review Guidelines – The inclusion of these guidelines as  Attachment 1, for convenient reference, is missing. They were included in the 2017-2019 RSDP.  Additionally, the industry should have the opportunity to comment on these guidelines now that the process has been tested.  Ultimately if we are having to revise standards shortly after their effective date, it implies we are not capturing quality characteristics in the initial drafting process.

We have one final suggestion regarding retirement of requirements.  If this is the only change to a standard, we suggest that the requirement numbering with the standard remain the same and the existing wording for said requirement be replaced with “Retired”.  Renumbering requirements caused a ripple effect in Registered Entities’ procedures, data bases, and compliance documentation.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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The North American Energy Standards Board (NAESB) appreciates the commitment of NERC and the NERC staff to ensure that the interrelated standards development activities of the two organizations continue to be coordinated.  NERC and NAESB share a strong working relationship, and we look forward to the continuing this relationship while meeting the goals of our individual organizations and the industry at large.  

As you know, the following NERC projects are currently coordinated with the NAESB 2017 Wholesale Electric Quadrant (WEQ) Annual Plan, and NAESB will continue to monitor the associated NERC standards as they move to completion

• Project 2016-02 Modification to CIP Standards 

Related NAESB WEQ Annual Plan Item: 2017 WEQ Annual Plan Item 4.b 

Status: NAESB is currently monitoring this project through the WEQ Cybersecurity Subcommittee. 

• Project 2016-03 Cyber Security Supply Chain Risk Management

Related NAESB WEQ Annual Plan Item: 2017 WEQ Annual Plan Item 4.b

Status: NAESB is currently monitoring this project through the WEQ Cybersecurity Subcommittee.

• Project 2017-04 INT-004, INT-006, INT-009, and INT-010 Periodic Review of Interchange Scheduling and Coordination Standards

Related NAESB WEQ Standard:  WEQ-004 Coordinate Interchange

Status: NAESB will continue to monitor this project, through the WEQ Standards Review Subcmmittee.  At NERC’s request, to accommodate INT-004-3.1, Requirement 3, the NAESB Electric Industry Registry (EIR) was modified to allow for the registration of pseudo-ties.

Additionally, NAESB plans to coordinate on the following standards under Periodic Review when the NERC Standard Review Team initiates efforts, as there may be impacts on the NAESB WEQ Business Practice Standards:

• BAL-005-02b: WEQ-005- Area Control Error (ACE) Equation Special Cases

• BAL-006-2: WEQ-007 - Inadvertent Interchange Payback

• IRO-006-5:  WEQ-008 - Transmission Loading Relief (TLR) - Eastern Interconnection related to NAESB WEQ Electronic Tagging (eTagging) Functional Specification

• NERC MOD Standards related to WEQ-23 – Modeling and WEQ-004 Coordinated Interchange.  NAESB and NERC will continue to coordinate on this effort.

 

 

Elizabeth Mallett, On Behalf of: North American Energy Standards Board, NA - Not Applicable, Segments NA - Not Applicable

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APPA supports that the draft 2018-2020 RSDP shows that the pace of standards development -- outside of CIP -- is shifting to a more measured pace while seeking to include standards grading and possible improvements focused on reliability.  Additionally, public power supports adding the second Paragraph 81 process to the 2018-2020 RSDP (see answer to question 1).  Further, APPA believes that the inclusion of the Paragraph 81 process beginning as part of the 2018-2020 RSDP should include a cost effectiveness analysis for standards.  As part of the Paragraph 81 process, such an analysis would help identify standards and requirements that need adjustment or retirement, as well as broadly establish a cost effectiveness program for standards.  In addition, such an inclusion would be consistent with the draft RDSP’s goal of adding the “objective of enhanced cost effectiveness in standards development.”

 

The draft 2018-2020 RSDP indicates that the 2017-19 RSDP goals carry over, but does not specifically state how the 2017-19 RSDP objective to "retire requirements that do little to promote reliability” will be pursued.  While one could infer that this could be part of the Periodic Reviews, the draft does not specifically state this, or explain how this work will carry over in the 2018-2020 RSDP.  Public power believes such an explanation should be included in the RSDP to make the periodic reviews more understandable to stakeholders. 

 

Beyond discussion of the Paragraph 81 process and cost effectiveness, the current way that cost-effectiveness is addressed in the draft RSDP lacks specifics.  Consequently, it becomes difficult to see the cost-effectiveness goals for 2018-2020 that will be used to measure the effectiveness of the plan as it moves forward.   

Jack Cashin, On Behalf of: American Public Power Association, , Segments 3, 4

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FMPA supports the comments of the American Public Power Association.

FMPA, Segment(s) , 12/5/2016

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Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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