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Draft 2022-2024 Reliability Standards Development Plan

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Start Date: 07/30/2021
End Date: 08/30/2021

Associated Ballots:

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

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Hot Answers

EEI appreciates the opportunity to provide comments on the NERC 2022-2024 NERC Reliability Standards Development Plan and recommends the following comments:

  1. Section 3.8 of the Standards Processes Manual states that, “[t]he technical committees, subcommittees, working groups, and task forces share their observations regarding the need for new or modified Reliability Standards or Requirements with the NERC Reliability Standards Staff for use in identifying the need for new Reliability Standards projects for the three-year Reliability Standards Development Plan.”  It is unclear in 2022-2024 Reliability Standards Development Plan where this information resides. 
  2. In Section 4.0 (of the Standards Processes Manual), Figure 1 contains a flow chart which details the process for developing or modifying a Reliability Standard.  Key among the steps is the Reliability Standards Development Plan.  Although no narrative was included in the report to describe any efforts to consider or otherwise identify new projects through this process, EEI suggests that a narrative describing any efforts to identify a need to develop, withdraw or retire any NERC Reliability Standards as part of this process would be informative and provide stakeholder insights into those efforts.
  3. The Executive Summary states that, “[t]his 2022-2024 RSDP provides insight into standards development activities anticipated at the time of publication, so that stakeholders may make available resources needed to accomplish the standards development objectives.”  However, no information or insights are provided beyond what is already known through 2022.  Moreover, it is reasonable to assume that NERC will initiate new projects throughout 2022 through 2024, yet no details or forecasts were made or provided (e.g., additional cold weather requirements).
  4. The Executive Summary also identifies the transformation of NERC Reliability Standards into a mature state through efforts such as the Periodic Review, however, EEI cannot identify any projects that have come out of those efforts.  While issues are periodically identified in those reviews, no action seems to be taken as a result.  Nor are their any post Review Reports that might describe the finding and any actions the reviewers believe might be appropriate.
  5. The Executive Summary also states that “NERC will use a variety of feedback mechanisms, including but not limited to, the Compliance Monitoring and Enforcement Program, RISC profiles, Events Analysis, and Compliance violation statistics, as well as any published “Lessons Learned.”  The report would benefit from examples of when this might have occurred.
  6. Project 2021-06 (Modifications to IRO-010 and TOP-003) is missing from the projects listed on page 1 and 2.
  7. On page 3 & 4, listing prioritization of projects that are expected to continue into 2022, Project 2021-06 should be included and Project 2020-04 and should be removed because it is expected to be completed in 2021.
  8. On page 5, the Projects Commenting section states that, “no Reliability Standards are due for periodic review in 2022.”   This section should also cover the projects due for periodic review in 2023 and 2024. 
  9. In Attachment 1 and 2 of this report, Final Grades for the Reliability Standards reviewed for the 2020 and 2021 Periodic Reviews are included, however, in Section 13 of the Standards Processes Manual, it states that NERC will conduct a 45-day comment period for Stakeholders and upon completion of their review submit to the NERC Board of Trustees (BOT) recommendations for either Reaffirming, Modifying or Retiring the Reliability Standards review.  The report and both appendices would be enhanced by including a narrative on the process, what stakeholders said about the posted ratings and what recommendations will be made to the NERC BOT for each of the reviewed Reliability Standards.

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

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We suggest adding project 2021-06 Modifications to IRO-010 and TOP-003 to the RSDP.

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 8/6/2021

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Other Answers

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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I recommend adding Project 2021-06 Modifications to IRO-010 and TOP-003‚Äč.

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

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

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Project 2021-06 appears to be missing from 2022 RSDP..

Paul Mehlhaff, On Behalf of: Sunflower Electric Power Corporation, , Segments 1

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Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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ATC supports the comments of EEI

LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

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The NSRF would like to point out that Project 2021-06, SAR to Modifications to IRO-010 and TOP-003 is not listed in the Draft RSDP.  Since the SAR is still being reviewed currently, this Project should be listed on page 1, under “Continuing Projects”.

MRO NSRF, Segment(s) 2, 4, 1, 6, 3, 5, 7/1/2021

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None.

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

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The Standards Efficiency Review project for IRO-010 and TOP-03 (2021-06) has been added to the list of ongoing projects tracked by the Project Tracking Spreadsheet.   This should be added to the list of ongoing projects in the Plan and ranked for priority.

There are anticipated standards work coming in 2022 which do not have Standards Authorization Requests.  Although the RSDP does not include anticipated projects in the Plan, it would be helpful for industry to know how new projects will be integrated into the Plan.  For example, if resources are constrained, will some of the Low priority projects be deferred to 2023?  A good work plan takes into account the resources needed to complete it.  If additional projects are added to 2022 work schedule, will additional resources be needed?   Resources include staffing, meeting budgets and volunteer resources.

 

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

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Eversource recommends adding Project 2021-06 Modifications to IRO-010 and TOP-003 in the "Continuing Projects" section.  

Christopher McKinnon, On Behalf of: Eversource Energy, , Segments 1, 3

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No comment

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

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1. Project 2021-06 Modifications to IRO-010 and TOP-003 missing from the list.

 

Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Hot Answers

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

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We suggest removing project 2020-04 Modifications to CIP-012 from the 2022 High Priority Project List since this project is planned to be completed in 2021.

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 8/6/2021

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Other Answers

 

1.     With the additional information that has been proposed in each project description on pages 3 – 4, it is suggested that readability would be improved if the information was presented in a tabular format.  An example is provided below.

 

Project Number

Title

Resource Commitment

Estimated Completion Date

 

 

 

 

 

2.     GSOC appreciates the evolution and maturation of SER activities proposed on page 5.  However, it suggests clarifying the activities described on page 5 to ensure that they are clear and easily distinguishable.  For example, there appear to be at least two different activities proposed, one that is focused on SER activities associated with the CIP reliability standards and one that is focused on documenting efficiency principles to be utilized in future SER activities. However, as written, it could be interpreted that the second activity is also intended to be CIP-focused as opposed to an overall change to future SER activities.  Additionally, it is unclear if the final paragraph is proposing activities that are distinct from the previously described activities.  For these reasons, GSOC recommends that NERC clarify the activities to be performed as part of the NERC Reliability Standards SER Transition described on page 5.

 

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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

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

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Paul Mehlhaff, On Behalf of: Sunflower Electric Power Corporation, , Segments 1

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Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

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Within the NERC Standards Develop Plan, all Drafting Teams need to follow the NERC outline Results-Based Standards process, as highlighted in the Results-Based Standards webinar on 20 October 2010.  The three types of Results-Based Standards (Performance-Based, Risk-Based and Competency-Based) will allow for a Standard to be developed once and be able to fit fulfill the Reliability concepts, regardless of new technologies, processes, etc.  There was a lot of work put into the Results-Based Standard’s concepts.  We should continue to build on this foundation.  By employing the Results-Based Standard’s concept, our industry would not be required to continually update our Reliability Standards.  Every time there is an update to a Reliability Standard it takes time away from our limited resources, where they should be concentrating their efforts on the Reliability and Security of the BPS.   

MRO NSRF, Segment(s) 2, 4, 1, 6, 3, 5, 7/1/2021

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No additional comments at this time.

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

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Given the perspective provided in #1, NERC should prioritize the 8 lower priority projects in matter of reliability impact. Industry expertise resources have been strained as evidenced by the low number of nominations for recent SAR teams. 2022 may add new high priority projects like those which may be needed in response to the Winter 2021 events which will add more demands on industry resources.

Please consider:

In addition to prioritizing these projects H M L, should also denote the type of expertise required for each project. E.g. –transmission planning, CIP, transmission operations, etc.

Add a #7 in prioritizing the projects under the “Projects Continuing into 2022”.  Propose that NERC revise its priorities to space apart the nomination periods so that not all of the same expertise is requested concurrently.  This will help not only getting more numbers for volunteers on drafting teams, but achieve the best possible diversity and expertise per subject matter.

7.  Minimize the overlap of projects with similar technical subject matter to allow for the most experts needed to nominate for a drafting team.

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

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Eversource recommends that the following language be added, "Project 2021-06 Modifications to IRO-010 and TOP-003 was initiated by phase two of the SER" in the "NERC Reliability Standards Efficiency Review Transition" section.  Eversource recommends adding the different SER phases and concepts in the “NERC Reliability Standards Efficience Review Transition” section.

Christopher McKinnon, On Behalf of: Eversource Energy, , Segments 1, 3

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

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1. It wold be nice to links to the project pages for all projects referenced in the document (i.e. Projects that have been or are planned to be completed in 2021) 

2. Page 6, second bullet; Two representatives from the Reliability and Security Technical (RSTC), should instead by "Reliability and Security Technical Committee"

Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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