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Draft 2021-2023 Reliability Standards Development Plan

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Start Date: 08/11/2020
End Date: 09/09/2020

Associated Ballots:

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

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

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Other Answers

The NSRF requests that Project 2019-05, Modifications to PER-003-2, be a High Priority, since we are all experiencing the Covid-19 restrictions.  Currently, many NERC Certified System Operators maintain their certifications via mostly face to face training sessions.  These face to face training sessions have been halted for an unknown period of time.  If, PER-003 was rewritten to a single NERC Certification and maintaining that certification with 140 CEHs (per the PCGC’s White Paper), this would benefit all NERC Certified System Operators.    

Currently, there is a a FERC/NERC waiver for expired NERC Certifications for System Operators which expires 31 December 2020.  There has been no guidance on what happens to those System Operators on 1 January 2021.  By giving Project 2019-05 a High Prioroty, it will assist and many System Operators (who certified at the RC level which is 72% of all System Operators) how will just need to move to the single System Operator certificate.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

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OMPA supports the comments submitted by City Utilities of Springfield.

Ashley Stringer, On Behalf of: Oklahoma Municipal Power Authority, , Segments 1, 4

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

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We are pleased to see that NERC plans to support continued efforts with the Standards Efficiency Review project.  This project created by the Board of Trustees’ effectiveness and efficiency initiative must be allowed to complete its work with adequate support from NERC.  While we appreciate the efforts to retire “low hanging fruit” associated with Phase 1, our customers will realize negligible benefit.  Most of the retirements are for commercial activities not applicable to us.  The others are removing redundant requirements, so the administrative burden still exists in another requirement.  We are also doubtful any benefit will be realized from the current CIP SER project.  Instead, NERC should elevate the priority of Phase 2 and dedicate more resources to taking a strategic approach to transition more standards (especially CIP) from administrivia to results-based with clear and measurable reliability/security outcomes.  Most of the priority projects are revisions to existing standards to address specific implementation issues, which apparently highlight enforceability issues and/or the absence of results-based objectives, or they would not need to be continually revised.  This approach is not effective, efficient, or sustainable as the industry deals with the rapid transformation of the grid.  Therefore, NERC should pause any new projects not associated with a FERC order and focus on this effort.

John Allen, On Behalf of: City Utilities of Springfield, Missouri, , Segments 1, 3, 4

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Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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

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See response to item No. 2

Marty Hostler, On Behalf of: Northern California Power Agency, , Segments 3, 4, 5, 6

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TAPS supports the comments submitted by City Utilities of Springfield.

Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments NA - Not Applicable

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The IRC SRC supports the efforts of the Standards Efficiency Review Phase 2 and notes that the team had prepared a Standards Authorization Request (SAR) in March 2020 for Operational Data Exchange Simplification.  This SAR was submitted by City Utilities of Springfield. However, we are not aware of any action taken by the Standards Committee and do not see it in the Plan.  Please include this in the Plan or provide an update on the status of the SAR.

 

 

SRC 2020, Segment(s) 2, 1, 3, 9/9/2020

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APPA supports the ongoing efforts to complete the next phase with Standards Efficiency Review (SER) of the Critical Infrastructure Protection (CIP) family of standards.  It will be a valuable and efficient next step to review the CIP standards and eliminate or revise standard requirements that do not further reliability in the important area of cyber security. NERC's Board of Trustees’ initiated this effort as part of the effectiveness and efficiency initiative.  Therefore, completing the next step to ensure review of the entire body of NERC standards is needed.  APPA public power utility members value the SER effort, but see significant benefit to customers by reducing administrative costs associated with the current body of CIP standards.  APPA supports the Transmission Policy Access Study (TAPS) Group recommendation that NERC should elevate the priority of Phase 2 and dedicate more resources to taking a strategic approach to transition more standards (especially CIP) from administrivia to results-based with clear and measurable reliability/security outcomes. This approach is needed because many of the RSDP priority projects are revisions to existing standards to address specific implementation issues, that center on enforceability issues and/or the absence of results-based objectives.  Moreover, many of the standards in the plan are being revised due to such implementation issues or the need to move to results based objectives.  Therefore, a new approach would be more effective to maintain reliability during a time of grid transformation.  To that end, APPA recommends any new projects not associated with a FERC order be paused so that the CIP and data retention SER efforts be able to move forward with out delay.  

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

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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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NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 9/9/2020

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

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Other Answers

In many Project Comment Forms, there is a question on if there we be a realized cost savings per the Project scope.  Project 2019-05 would provide a hugh cost savings to every Entity who is required to have NERC Certified System Operators.   NERC would be able to truly show a cost savings (benefit) with this Project for every Entity that must have NERC Certified System Operators to maintain system reliability and security.

For an estamited dollar savings please note the below numbers of Certified System Operators.

This equals a difference of 370820 of required CEHs between today’s Certifications and what is being prposed in the update of PER-003.

If you take an average cost of $40 per CEH (this does not include travel time, lodging, meals and employee time) there is a savings of $14,832,800 that Entities will save.  This is why Project 2019-05 needs to be a High Priority and actively being developed.

 

In general, the NSRF is pleased to see that NERC plans to support continued efforts with the Standards Efficiency Review project.  This project created by the Board of Trustees’ effectiveness and efficiency initiative must be allowed to complete its work with adequate support from NERC.  While we appreciate the efforts to retire “low hanging fruit” associated with Phase 1, our customers will realize negligible benefit.  Most of the retirements are for commercial activities not applicable to to many.  The others are removing redundant requirements, so the administrative burden still exists in another requirement.  We are also doubtful any benefit will be realized from the current CIP SER project.  Instead, NERC should elevate the priority of Phase 2 and dedicate more resources to taking a strategic approach to transition more standards (especially CIP) from administrivia to results-based with clear and measurable reliability/security objectives.  Most of the priority projects are revisions to existing standards to address specific implementation issues, which apparently highlight enforceability issues and/or the absence of results-based objectives, or they would not need to be continually revised.  This approach is not effective, efficient, or sustainable as the industry deals with the rapid transformation of the grid.  Therefore, NERC should apply the Risk Based Standard process and have clear objectives with any new or updated Standard and remove prescripted Requirements..

Please see attached for charts that will not copy over.

 

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

2021-2023 RSDP NSRF Draft Comment_Form Final.docx

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Ashley Stringer, On Behalf of: Oklahoma Municipal Power Authority, , Segments 1, 4

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

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John Allen, On Behalf of: City Utilities of Springfield, Missouri, , Segments 1, 3, 4

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To minimize churn among standard versions, Reclamation recommends the SDT take additional time to define the scope and coordinate the modifications with other existing drafting teams for related standards. This will help minimize the costs associated with the planning and adjustments required to achieve compliance with frequently changing requirements. NERC should foster a standards development environment that will allow entities to fully implement technical compliance with current standards before moving to subsequent versions. This will provide entities economic relief by better aligning the standards for overall improved reliability and by reducing the chances that standards will conflict with one another.

Executive Order 13920 pushes for the Department of Energy to develop and publish rules and regulations prohibiting certain acquisitions, import, transfer, or installation of bulk-power system components where there is a credible threat that could compromise the BPS within the next year. Is it currently anticipated that this publishing of the rules and regulations developed by DOE will reopen Project 2019-03 when complete?

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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None.

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

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Project 2019-06 Cold Weather and Project 2020-03 Supply Chain Low Impact Revisions are not High Priority; new or revised Reliability Standards are not needed.  Neither is a regulatory directive and neither has a high probability of occurrence.  Regardless both can be easily mitigated with ongoing reliability guidance and outreach.  It is really not necessary for Industry to spend Millions of dollars and thousands of laborious hours on these projects that offer little or no reability benefit. Why hasn't anyone provided a cost benefit analysis for either project? The Standards Committee should not approve any more project SARs without cost estimates, they are needed for benefit vs. cost justifications?

The FERC report mentions numerous other less expensive local/regional operational and Market rule recommendations; we have not heard of any being employed, just the push for the most expensive option, this unnecessary Continent-Wide Standard.   Simply proactive operational modifications such as increasing reserves and BAs warming generation facilities prior to expected load pocket temperature decreases, are all that is needed.  Entities can work with the BAs/RCs in their area to make operational changes or Market rule modification without forcing a Continent-Wide Standard that are not needed.  Use local/regional knowledge and skillsets to solve local/regional issues.

Project 2020-04 CIP-012 modifications is a regulatory item but still not high priority.  Entities already have back up control centers, and now NERC/FERC is pushing for more backup communications when we already have backups.  Also, why isn't there a benefit/cost justification in the SAR? Why did the SC approve this without a benefit/cost analysis?

 

Marty Hostler, On Behalf of: Northern California Power Agency, , Segments 3, 4, 5, 6

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Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments NA - Not Applicable

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SRC 2020, Segment(s) 2, 1, 3, 9/9/2020

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

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The following NERC projects are or will be coordinated with NAESB annual plan items/efforts:

Project 2016-02 Modifications to CIP Standards (virtualization)

Related: May impact WEQ-012 Public Key Infrastructure Standards.

Status: NAESB will continue to monitor this project.

Project 2019-02 BES Cyber System Information Access Management

Related: May impact WEQ-012 Public Key Infrastructure Standards.

Status: NAESB will continue to monitor this project.

Project 2019-03 Cyber Security Supply Chain Risks

Related: May impact WEQ-012 Public Key Infrastructure Standards.

Status: NAESB will continue to monitor this project.

       Project 2020-03 Supply Chain Low Impact Revisions

              Related: May impact NAESB WEQ-012 Public Key Infrastructure Standards.

              Status: NAESB will continue to monitor this project.

       Project 2020-04 Modifications to CIP-012

               Related: May impact NAESB WEQ-012 Public Key Infrastructure Standards.

               Status: NAESB will continue to monitor the project.

The following NAESB annual plan items or standards requests are or will be coordinated with NERC reference documents:

Annual Plan Item 8.a – Consistent with FERC Order No. 676-I, reconsider the reservation of WEQ-006 Manual Time Error Correction and determine if the standards should be retained or revised (see ¶46 – 47)

Related NERC Reference Document: Time Monitoring Reference Document V5.

Standards Request R20008 – Request to update WEQ-005 Area Control Error (ACE) Equation Special Cases to account for modifications at NERC Dynamic Transfer Reference Document V 4.

Related NERC Reference Document: NERC Dynamic Transfer Reference Document V4.

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

2021-2023 NERC RSDP Unofficial Comment Form (NAESB).docx

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Since technological solutions are often the answer to the various challenges of the electrical industry, there is a tendency to resort to cloud computing solutions to accelerate deployment and reduce costs. It therefore appears important to us, in order to reduce cybersecurity risks to a minimum while ensuring the flexibility required by maintaining the reliability of the Bulk Electric System that NERC focus on adapting the CIP Reliability Standards to cloud computing environments. Exploring ways to integrate certifications (i.e. FedRamp, or Soc II Type 2) will be essential to permit compliance certification with the CIP requirements by various cloud providers. This support would prevent entities from needing to carry out isolated proceedings with suppliers, which may be inconsistent across industry.

 

There is no mention of ongoing work in the area of Electromagnetic Pulse (EMP) hardening which will also result in a new standard and also the likely revision of the TPL-007 GMD standard.  Efforts are underway to produce enhanced ground resistivity data, earth transfer models and increase our understanding of how EMPs could affect the grid and cost effect methods to protect it.

 

The cover page of the report contains “RELIABILITY | RESILIENCE | SECURITY” as part of the template however there is no specific reference in the Plan to any of the projects being related to Resilience (i.e. the Cold Weather project contributes to increased resilience).  NERC has some activities underway in the area of Resilience however there is opportunity to identify what these are and how they will affect the development of standards.

 

The last paragraph of the Plan is very vague as to future projects.  The sentence: “Several projects are anticipated based on SARs being developed at the RSTC.” , could lead into a list of the SARs/projects the RSTC did approve to move to the Standards Committee.  These will certainly be projects.

 

The Plan also states “The first phase of Standards retirements for SER have been completed, and any future development will continue into 2021.”  The SER paragraph near the end has little in the way of details of what will be done and is incomplete.  There are efforts that have been underway to also review the O&P standards for retirement or revision.  More detail is needed here regarding what was done, what will be done and specifics.  There needs to be more transparency with the SER project.  Many in the industry are interested in this moving forward but there seems to be no timeline or milestones for completion of project stages.

 

The SPIDERWG is also reviewing all the O&P Standards to determine if they have been, will, or may in the future be impacted and need revision as a result of increasing amounts of DER.  There will likely be standards projects initiated as a result of this review and the SPIDERWG will be publishing a whitepaper and eventually SARs to initiate these projects.  This is not reflected in the Plan and will result in additional projects in the timeframe of the Plan and should be mentioned.

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 9/9/2020

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