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Draft 2019-2021 Reliability Standards Development Plan

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Start Date: 08/08/2018
End Date: 08/31/2018

Associated Ballots:

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RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 7/13/2018

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Please verify whether Project 2017-07 Standards Alignment with Registration should be included in the 2018 Progress Report on e-page 1, as the fifth project from 2017 or 2018 that will not have been completed in 2017 or 2018.

Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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Other Answers

Dan Roethemeyer, On Behalf of: Dan Roethemeyer, , Segments 5

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MEAG Power, Segment(s) 3, 1, 5, 6/15/2017

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Although the RSDP is designated as a 2019-2021 plan by its title, no information is provided beyond 2019. If the planning horizon is to be one year, recommend changing the title to 2019 only or expand the scope of the RSDP to describe projects planned for 2020-2021.

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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SPP Standards Review Group, Segment(s) 2, 8/30/2018

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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IRC-SRC, Segment(s) 2, 8/31/2018

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Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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William Sanders, On Behalf of: William Sanders, , Segments 1, 5

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David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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Hot Answers

Similar to the scores obtained in the past 3 to 4 years, the final grades for standards graded in the RSDP once again indicate a rather narrow range in the Content Average scores (2.50 to 3.0) and the Quality Average scores (12.25 to 13.0). This narrow range does not seem to provide any insights or clear indication of which standard is of much inferior content or quality compared to the others. We suggest the criteria used in the grading categories be reviewed and modified, where appropriate, to provide more meaningful results that can really help provide clearer indication for prioritization.

RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 7/13/2018

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Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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Other Answers

Dan Roethemeyer, On Behalf of: Dan Roethemeyer, , Segments 5

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A few of the descriptions are brief and it would be useful to include a reference to additonal information, such as include the location of the list and description of outstanding FERC Directives. Where can they be found? The NERC webiste is difficult to navigate.

Is it worth mentioning that Reliability Standard Developments can be monitored by reviewing the Weekley Standards, Compliance, and Enforcement Bulletin and the quarterly Standards Committee meetings?

Is there going to be a next Efficiency Review phase?

 

MEAG Power, Segment(s) 3, 1, 5, 6/15/2017

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Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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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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Similar to the scores obtained in the past 3 to 4 years, the final grades for standards graded in the RSDP once again indicate a rather narrow range in the Content Average scores (2.50 to 3.0) and the Quality Average scores (12.25 to 13.0). These average scores do not seem to provide any insights or clear indication of which standard is of much inferior content or quality compared to the others. These scores do not seem to be of great value to help the Standards Committee and the industry to prioritizing or developing schedule for standard development projects.

 

We suggest that the grading exercise either be discontinued to conserve industry resource, or the criteria used in the grading categories be thoroughly reviewed and modified, where appropriate, to provide more meaningful results that can really help the prioritization and scheduling needs.

 

 

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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NA

SPP Standards Review Group, Segment(s) 2, 8/30/2018

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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BPA supports the plan with the following comments:

  • BPA believes the forecasted SMEs hours (95) for Project 2016-02, Modifications to CIP Standards, to be a low projection. The Project 2016-02 Standard Drafting Team (SDT) meets in person on a monthly basis (20hrs +/month) and weekly via interactive media (4-6hrs /week), as well as personal assignments between meetings. As this project is scheduled to continue through Fall 2019, BPA recommends NERC to reassess the SME workload.

  • Executive Summary: pg. 4, paragraph three, line five. There is a reference to “Attachment 1” with regard to the Standards Grading tables on pg. 9 and 10. That section does not include “Attachment 1” in its title. The title shows as “Final Grades for Standards Graded in 2018”. BPA recommends including the “Attachment 1” language for consistency.

  • The cover page lists the date as October_,2018, while the footers lists the date as September 2018.

  • Pg. 7: first and last paragraph, no period to end the sentence.

  • Pg. 8: last paragraph, no period to end the sentence.

  • Pg. 9: last paragraph, no period to end the sentence.

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Thank you for the opportunity to comment on the 2017-2019 RSDP.  We appreciate NERC’s outreach to the Industry on ways to maintain an adequate level of reliability.  Our comments focus on things that should help NERC stabilize the standards and gain efficiencies while focusing on risk.

Addressing Risk

We agree that NERC should continue to seek input and recommendations from the Reliability Issues Steering Committee (RISC) with regard to emerging or potential risks to Bulk Electric System (BES) reliability that may require revisions to existing standards or new standards development.  We see value in the standing committees working with the RISC to outline a decision approach to determine which tool(s) best address a risk as a starting point.  The purpose of RISC is to prioritize the work of NERC. Any SARs that arise from and are endorsed from the standing committee and subcommittees should be consistent with the RISC Report and assessment.

Periodic Reviews

While we support NERC’s efforts to continually improve the standards, the downstream impact of minor changes can cause Registered Entities more work than any benefits they experience from the change (discussed later). 

Unless there is a major issue with a standard, there should not be a review of a standard before it’s gone through at least 2 audit cycles (before 7 years) so that the industry has had experience with the standard and the review teams can make meaningful decisions on whether changes are really needed or if the standard is OK as-is. 

Standards Grading

There seems to be significant overlap between the objectives of the Standards Grading project, the Standards Efficiency Review, and the Enhanced Periodic Reviews.  NERC can continue the grading effort if the technical committees have the bandwidth; however, because of the lack of distinction in the grading results (see explanation in following paragraph), the grading results alone should not determine which standards to retire and should only provide background to a periodic review team when the 7 year review point is met.

Notwithstanding the above comment, we are not certain that the grading exercise serves any particular value to the annual development of the RSDP. Similar to the scores obtained in the past 3 to 4 years, the final grades for standards graded in the RSDP once again indicate a rather narrow range in the Content Average scores (2.50 to 3.0) and the Quality Average scores (12.25 to 13.0). These average scores do not seem to provide any insights or clear indication of which standard is of superior or inferior content or quality compared to the others. These scores do not seem to be of great value to help the Standards Committee and the industry in prioritizing or developing a schedule for standards development projects.

We suggest that the grading exercise either be discontinued to conserve industry resources, or the criteria used in the grading categories be thoroughly reviewed and modified, where appropriate, to provide more meaningful results that can really help the prioritization and scheduling needs for standards qualitative review.

Standards Efficiency Review

With regard to the Standards Efficiency Review, NERC personnel are aware of several similar standards efficiency efforts attempted throughout the years[1].  It is important for NERC to continue to drive resources to not only retire requirements providing little value to reliability but also to retire, or otherwise address, requirements to gain greater efficiencies.  This Phase 2 effort can help registered entities and Regional Entities reap the benefits of risk-based compliance monitoring and benefit and improve reliability and security by allowing entities to better allocate resources towards core reliability requirements.   

The real efficiencies aren’t in retiring a small fraction of the requirements and then polishing and reorganizing the remainder.  In general, low-value requirements aren’t actively monitored by the Regions and infractions are handled as Compliance Exceptions or end up as zero dollar penalty FFTs.  Reformatting and retiring these low impact requirements may necessitate Registered Entities to conduct comprehensive reviews to ensure all RSAWs, internal procedures, training, and evidence collection reflect the minor SER changes.  All such review projects should continue to focus on high-risk requirements.

NERC could enable more efficiency if the next phase of the SER were to support the Regional Entities’ risk-based compliance monitoring programs by categorizing requirements as:

  • High priority (or core or focus area) requirements.

  • Supporting (provide some value but not likely to cause a problem) requirements.

  • Exception candidates, such that if an issue was self-identified, not repeat, and had no impact, it could be handled as a logged item. 

  • Redundant, such that if multiple requirements are asking for basically the same thing, NERC could select which requirement would be directly monitored and which would be handled as exception candidates.

 

[1] Similar efficiency review projects have included:  (a) “results-based” review in the 2009 timeframe that separated requirements into administrative, supporting, and risk-focused requirements; (b) Standards Independent Expert Review Project evaluated the quality and value of the requirements; (c) Paragraph 81 project reviewed which requirements were meaningful and which weren’t; (d) Standards Grading; and (e) Periodic Reviews.

IRC-SRC, Segment(s) 2, 8/31/2018

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None.

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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None.

William Sanders, On Behalf of: William Sanders, , Segments 1, 5

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N/A

David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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