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Draft 2020-2021 Reliability Standards Development Plan

Description:

Start Date: 08/14/2019
End Date: 09/05/2019

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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James Grimshaw, On Behalf of: James Grimshaw, , Segments 1, 3, 5

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The following NERC projects are or will be coordinated with North American Energy Standards Board (NAESB) annual plan items/efforts:

• Project 2016-02 Modifications to CIP Standards (virtualization) (drafting estimated to be completed by November 2020 requiring approximately 11 industry subject matter experts for approximately 120 work hours each for the remaining part of this project)

• Related: Potential annual plan item related to Distributed Ledger Technology and the NAESB Public Key Infrastructure (PKI) Certification Program 

• Status: NAESB will continue to monitor this project.

• Project 2017-04 Periodic Review of Interchange Scheduling and Coordination Standards

• Related: Currently on hold at NERC pending outcome of Project 2018-03.  May impact NAESB WEQ-004 Standards.

• Status: NAESB will continue to monitor this project.

• Project 2017-07 Standards Alignment with Registration

• Related: May impact NAESB WEQ-004 Standards.

• Status: NAESB will continue to monitor the project.

• Project 2018-03 Periodic Review of Interchange Scheduling and Coordination Standards

• Related:  Standards Requests R19007 and R19008 were submitted to NAESB from NERC.

• Status: NAESB will continue coordination between the organizations.

 Project 2019-03 Cyber Security Supply Chain Risks-(drafting estimated to be completed by December 2020 requiring approximately nine subject matter experts for approximately 90 work hours each for this project)

• Related: Potential annual plan item related to cybersecurity related to the OASIS, eTag, and other industry software. 

• Status: NAESB will continue to monitor this project. 

Jonathan Booe, On Behalf of: North American Energy Standards Board, NA - Not Applicable, Segments NA - Not Applicable

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Other Answers

The following active projects are not included in the report:

  • ​2018-03
  • 2018-04 
  • 2019-01
  • 2019-02
  • 2019-03
  • 2019-04
  • 2019-05
  • 2016-EPR-01

Bette White, On Behalf of: Bette White, , Segments 3

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1 - Correct the bookmark for Executive Summary in the Table of Contents: "Error! Bookmark not defined."

​2 - The “2019” in the Background section on page iii should be changed to 2018: SER effort began in 2018, not 2019.

​3 - Suggest changing “next phases of the SER project” shown on page iv under Executive Summary to “next steps of Phase 2 of the SER Project”: The SER Project is in the final stages of Phase 2.

​4 - Suggest changing “BPS” to “BES” on page 3 to be consistent with language in the Executive Summary on page iv.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

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

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Bruce Reimer, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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CAISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, On Behalf of: California ISO, , Segments 2

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Southwest Power Pool Standards Review Group (SSRG), Segment(s) 2, 9/4/2019

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, 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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Anton Vu, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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There is no information in the plan for 2021-2022.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

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RSC, Segment(s) 10, 2, 4, 5, 7, 3, 1, 0, 6, 9/5/2019

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James Mearns, On Behalf of: James Mearns, , Segments 1, 3, 5

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We appreciate NERC providing the 2020-2022 Reliability Standards Development Plan (RSDP) and the opportunity to provide input.

 

The IRC Standards Review Committee (SRC) provides the following comments for consideration:

 

  • The 2019-2021 Reliability Standards Development Plan (RSDP) included “Attachment 1:  Final Grades for Standards Considered in 2018.” The 2020-2022 Executive Summary indicates that Standards Grading was paused due to the Standards Efficiency Review (SER) project in 2019.  Should clarification be added about the Attachment, such as a footnote, that Attachment 1 was not included in the  2020-2022 RDSP due to the suspension of Standards Grading in 2019 because of the SER project? 

     

  • The section on FERC Directives indicates the number of outstanding directives, but since all of the standard projects (completed and planned to be completed) are listed out, would it be beneficial to list the FERC directives as well even though it is noted that the status of the Directives are reported on quarterly at NERC Board meetings?

 

  • Project 2019-02 BES Cyber System Information Access Management is not listed

     

  • In an effort to improve the plan and make it more usable for the industry, we suggest adding more details and thoughts around “Other Projects Continuing into 2020.” Where that section mentions “[a]t least two Periodic Review should commence in 2020,” please specify which two are expected. Additionally, for all of the projects continuing into 2020, can we expect the work to culminate in one standard or multiple ones?

     

  • As the work plan is intended to be a 3-year work plan for 2020-2022, we recommend the plan be expanded to describe the work envisioned for 2021-2022 or modify the title of the plan to indicate it is a plan for 2020 only. At a minimum, the plan should provide a look ahead for routine work, such as planned periodic reviews, for the 3-year period. Flexibility would be retained, as the outlook for future years could be modified in subsequent plans as the RSDP is issued on an annual basis.  

     

  • An update on the Technical Rationale Transition Plan listed in the 2019-2021 Reliability Standards Development Plan is not given

 

ISO RTO Standards Review Committee, Segment(s) 2, 1, 9/5/2019

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Project 2019-02 BES Cyber System Information Access Management is not listed.

Tamara Evey, On Behalf of: Ameren - Ameren Services, SERC, Segments 1, 3, 5, 6

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Hot Answers

James Grimshaw, On Behalf of: James Grimshaw, , Segments 1, 3, 5

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Jonathan Booe, On Behalf of: North American Energy Standards Board, NA - Not Applicable, Segments NA - Not Applicable

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Other Answers

The report includes 2018-02 despite being completed in January 2019.

Bette White, On Behalf of: Bette White, , Segments 3

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None.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

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

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No comments.

Bruce Reimer, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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CAISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, On Behalf of: California ISO, , Segments 2

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Project 2017-07 Standards Alignment with Registration:

 The SPP Standards Review Group (SSRG) recommends moving Project 2017-07 Standards Alignment with Registration from the Projects Completed in 2019 section, to the Projects Continuing into 2020 section, based on the drafting teams modified timelines.

Project 2019-04 Modifications to PRC-005-6:

The SSRG recommends Project 2019-04 Modifications to PRC-005-6 move to a Medium Priority based on the proposed alignment of the definition for UFLS only Distribution Provider (DP).

Southwest Power Pool Standards Review Group (SSRG), Segment(s) 2, 9/4/2019

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

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BPA believes the forecasted SMEs hours (120) for Project 2016-02, Modifications to CIP Standards (virtualization), 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 2020, BPA recommends NERC reassess the SME workload.

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

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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General comment:  The title leads one to believe this is a 3-year plan for standards development.  The draft seems to be more of a year-to-year report (what was completed this year, what is planned for next year).  Based on section 310 of the NERC Rules of Procedure, an annual plan that includes a progress report for the current year results is the expectation.  It is recommended to change the title from RSDP 2020-2022, to RSDP 2020.  Alternatively, add a section that addresses plans for 2021-2022.  The 2020 plan could also be a “living document”, with revisions issued during the year if new standards development triggers occur that modify the 2020 plan/priorities.

Page iii, Background section: Should “CIP” be inserted before “Standards Efficiency Review (SER)”?  SER efforts on the O&P standards began in 2018.

Page 1, 2019 Progress Report: The first sentence under the header ends with “2018”.  Should this be “2019”?

Page 1, “FERC Directives” section:  A sentence states that the status of “Standards directives are reported quarterly to the NERC Board of Trustees”.  Based on a review of the NERC Board’s 2019 quarterly meeting materials posted on the NERC website (February, May and August 2019 meetings), there did not appear to be a collective status report on all standards activities associated with open FERC directives at any of these quarterly meetings.  The draft RSDP indicates that six outstanding FERC directives are now being addressed through the standards development process.  The February 2019 Board meeting package reflects that Project 2018-02 (CIP-008-6) was associated with a FERC directive.  The May 2019 Board meeting package reflects that Project 2016-02 (CIP-003-8) was associated with a FERC directive.  None of the items included under agenda item #6 of the August 2019 meeting appear to be associated with a FERC directive.  It would be an improvement if the RSDP, and the Reliability Standards Under Development web page, clearly distinguished the active standards development activities associated with FERC directives.

Page 1, “Projects Completed in 2019” section:  Consider incorporating a tabular format into this section.  Identify whether the project was considered a high, medium, or low priority in the 2019-2021 plan.  Identify the initiating triggers for the project (FERC directive, periodic review, SAR, etc).  Identify the standard(s) that was produced by the project and its status (NERC Board adopted with date, pending NERC Board adoption, drafted, carryover to 2020).  Provide an explanation for any high priority projects that were not completed in 2019 (e.g., Project 2015-09).  Address any new projects that were launched in 2019 that were not envisioned when the 2019-2021 plan was developed (e.g., Project 2019-01, Project 2019-04).

Page 2, “Projects Continuing into 2020” section:  Consider incorporating a tabular format into this section.  In addition to identifying the priority level, identify the initiating triggers for the project (FERC directive, periodic review, SAR, etc).  Identify the standard(s) that are expected to be produced by the project to the extent known.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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Taking into consideration our comments that were submitted on the scope of the SAR, we believe that the priority designation for Project 2019-04 Modifications to PRC-005-6 should be medium instead of low.  Rendering the standard "technology neutral" would adress what we perceive as a potential reliability gap when it comes to new techologies that are not addressed in the standard. 

Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

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Please consider listing the six FERC Directives that are being resolved through the standards development process and reference the project associated with each FERC Directive.

RSC, Segment(s) 10, 2, 4, 5, 7, 3, 1, 0, 6, 9/5/2019

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The "Momentary Cessation" phenominon described in Robert Cummings iPCGrid presentation (attached) would appear to represent a priority for updated modeling within the TPL guidance.

James Mearns, On Behalf of: James Mearns, , Segments 1, 3, 5

Robert Cummings - From Here to There - Grid Reliability in the Grid of the Future - iPCGRID 2019.pdf

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The SRC provides the following comments for consideration:

 

  • Recommend correcting the Table of Contents bookmark error

  • Recommend correcting the page numbers in the footers

  • Under Background, the SER efforts started prior to 2019, recommend date modification

  • Under Executive Summary, recommend adding the acronym CMEP, in the last paragraph

  • Under Executive Summary, recommend adding the acronym EA, in the last paragraph

  • Under Executive Summary, recommend adding the acronym NAESB, in the last paragraph

  • Under 2019 Progress Report, should the report date be 2019 instead of 2018, if so, recommend date modification

  • Under FERC Directives, in the first line, recommend the “12” be written out as “twelve”

  • Under Projects Completed in 2019, recommend the projects have active links for document consistency

  • Under Projects Continuing into 2020, recommend the High, Medium and Low projects have active links for document consistency

  • Under NERC Reliability Standards Efficiency Review Continuation, recommend adding Electric Reliability Organization before the use of the acronym ERO

  • Under NERC Reliability Standards Efficiency Review Continuation, recommend adding  Critical Infrastructure Protection before the use of the acronym CIP

 

The SRC appreciates the opportunity to submit comments.

ISO RTO Standards Review Committee, Segment(s) 2, 1, 9/5/2019

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Tamara Evey, On Behalf of: Ameren - Ameren Services, SERC, Segments 1, 3, 5, 6

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