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Draft 2023-2025 Reliability Standards Development Plan

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Start Date: 07/26/2022
End Date: 08/24/2022

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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SPP RTO, Segment(s) 2, 8/24/2022

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Other Answers

Ellese Murphy, On Behalf of: Duke Energy - MRO, WECC, Texas RE, SERC, RF - Segments 1, 3, 5, 6

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Dwanique Spiller, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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The Plan provides a comprehensive summary of the projects that will be worked on in 2023 which we support.  But it does not add any more information to what can already be found in the Project Tracking Spreadsheet. Over the years the types of standards projects  in development has grown due to an ever increasing need to address new reliability risks.   Historically, when there were numerous tasks in front of NERC like completing  Order 693 directives, developing CIP Version 5 and more recently the Standards Efficiency Reviews, the RSDP provided industry with a “road map” of how and when NERC would achieve those objectives.  Such objectives are absent in the Plan for 2023 and it lacks an overall sense of direction.  The report mentions a piecemeal approach to how new projectsare identified and standards requests are received:

“While most of the work in the next three years will focus on new SARs, Periodic Reviews, SER implementation, and Standards Grading, there may be new or emerging risks identified that could generate new standards development projects. NERC will 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.”

In the 2023 RSDP, all of the listed projects are important, and many urgent, to meet reliability challenges but industry does not get a sense of an overall strategy as forementioned. The majority of today’s standards projects are being introduced in a piecemeal fashion as reliability issues are identified or regulatory drivers come about.

“To help determine the impact of potential risk to BES reliability, 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.’”

 This feedback mechanism to assessing risk and identifying what is the most appropriate mitigation tool is one way to keep pace with the changing grid.  However, the 2023 Plan should contain an overarching strategic objective or set of objectives that ties the projects with the RISC priorities.  The SRC believes the RSDP can be a guide for the work of the NERC committees and provide insight for regulators to how NERC is meeting the reliability challenges facing the industry. By tying an objective(s) to the RSDP, the committees can identify any gaps or tangential issues that may need to be addressed with other NERC tools.  This can also help regulators with further details of how the RISC priorities are being addressed and where regulatory gaps limit the capability of NERC standards.  The bright line for the BES definition, the authority over resource capacity, and the jurisdictional issues of distribution networks require parties outside of the traditional NERC regulatorty authority,  are some key regulatory issues that should be included in the RDSP.

As an example, the projects for PRC-002, PRC-023 and TPL-001/MOD-032 address the effects of Inverter Based Resources on the synchronous network.  In the Progress Report, FAC-001 and FAC-003 changes already adopted are also tied to IBRs since that was a driver for those changes.  Together these standards projects improve the modeling and response of IBRs to synchronize with the AC performance of the grid. Any future work being investigated by the RSTC related to IBRs, like at SPIDERWG, should be laid out so stakeholders can visualize a strategic “road map” of how standards can play a part in addressing specific risks. Regulators can also use the RSDP to understand how the reliability risks the projects are addressing may have compliance limitations over assets outside of BES jurisdiction.

 

SRC 2022, Segment(s) 2, 1, 7/14/2022

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EEI notes that Project 2020-04 is identified as both to be completed in 2022 (page 2) and continuing on into 2023 (page 1).  Please clarify what the intent is for this project.

Additionally, EEI notes that Project 2022-04 (EMT Modeling) is not identified in either the list of projects to be completed in 2022 or 2023 (or beyond).  This omission should be corrected before finalizing the report.

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

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Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI) for question #1.

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

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The current Draft 2023 – 2025 Reliability Standards Development Plan (RSDP) is a snapshot in time (dated July, 2022).  We acknowledge and agree with the draft plan as written.  However, we have a future recommendation as documented in the response to question number 2.

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

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NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/6/2022

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Hot Answers

BPA appreciates the opportunity to comment on the Draft 2023-2025 Reliability Standards Development Plan.

BPA supports the forecasted slowdown in CIP standards development, to allow entities to catch up on imminent changes and changes currently under development that are slated to close out in 2022.

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

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SPP recommends that NERC staff  change the priority status of Project 2022-02 Modification to TPL-001-5.1 and MOD-032-1 from “low” to “high”.

There is a compliance gap associated with the MOD-032 Standard which was an unintended consequence created via the NERC Risk Based Registration (RBR) initiative. Basically, the RBR initiative retired a Load Serving Entity’s (LSE) long held accountabity for compliance associated with providing load data via Attachment 1 in the standard. As a result, there are no designated entity or entities obligated to provide that specific load data via attachment 1. For example, the curret attatchment 1 reflects that the LSE would be responsible for providing Aggregated Demand data in the Steady State study. Due to the implementation of the RBR Initiative, the LSE doesn’t have to provide that data anymore to the TP and PC. With that barrier in place, the TP and PC doesn’t have access to the data to run their studies which could lead to suspect results.

Moreover, there are technical documents (created by the ERSWG and DERTF) recommending that the Distribution Provider (DP) be the entity to replace the LSE as well as provide the load data. However, the DP has not be officially included in the applicability section of the standard. At this point, it will be very difficult for the TP and PC to obtain the modeling data to produce quality results, as well as proving the appropriate compliance data to support their actions taken.

Furthermore, the Odessa Report recommends that the MOD-032 standard is the appropriate avenue for entities like the TP and PC to obtain EMT modeling data; and there is an expectation that the TP and PC will conduct SCR screenings to determine if an EMT study is needed. As stated above, there are currently no requirements in the standard that allows the TP and PC to obtain the EMT modeling data and the EMT models created by the GO. Without specific requirements to disclose such information, GOs are in a position to reject data requests, and the TP and PC cannot go to entities outside the jurisdiction of NERC, like Original Equipment Manufacturers (OEMs) who will not share the data due to proprietary legalities.

 For these reasons, SPP recommends that the priority status of this project be changed to “High” so that all of these issues can be addressed in a timely manner and help maintain the reliability of the grid.

SPP RTO, Segment(s) 2, 8/24/2022

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Other Answers

Project 2020-04 (Modifications to CIP-012) is identified as a project that will continue into 2023 under Continuing Projects, but is then listed as a planned completion for 2022 with an anticipated Board adoption date of November 2022. We would like clarification. Given the number of Standard Developers , and priority projects such as Project 2021-07 (Cold Weather), we are anticipating that Project 2020-04 would likely wrap up in 2023.

Ellese Murphy, On Behalf of: Duke Energy - MRO, WECC, Texas RE, SERC, RF - Segments 1, 3, 5, 6

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None at this time.

Dwanique Spiller, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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Projects are categorized by a priority ranking – High, Medium and Low.  But how are the project priorities used – if at all?  Standards requests come to the Standards Committee throughout the year in succession and very rarely as a comprehensive package the Committee can use to prioritize work.  There should be an explanation of whether work plans and resources are allocated or more importantly – reallocated – if higher priority projects are added.  There are currently almost 20 standards projects in progress and many stakeholders are already saturated or reaching saturation to provide volunteers for drafting teams.  NERC’s Standards Committee should begin consideration of delaying lower priority work in favor of higher ones.

The RSTC has many initiatives underway  to address many of the RISC recommendations from the 2021 Reliability Risk Priorities Report. The RSDP should note what  work of the numerous RSTC subcommittees and working groupsare are relevant and complement the risks associated with exisiting standards projects.. By referencing ongoing work before they become standards requests, the RSDP can provide a broader and longer term perspective to be proactive and convey to an audience how the RSDP plays a part in addressing the RISC issues.. Other solutions to address risks, such as Guidelines, Technical Papers and the like should also be noted.

We recommend NERC upgrade the priority of Project 2022-02 to High.  The MOD-032 Standard has a compliance gap created by the NERC Risk Based Reliability initiative. One outcome of that effort was removing the Load Serving Entity (LSE)  from compliance pertaining to providing load data via Attachment 1 in the standard.  Additionally, the Distribution Provider (DP) is not currently applicable in the standard. However, the ERSWG and DERTF have developed technical documents recommending the DP provide that load data.  Furthermore, the Odessa Report recommends the MOD-032 standard for entities like the TP and PC to obtain EMT modeling data. Requirements are critical to ensure the TP and PC obtain the EMT modeling data as well as the EMT models created by the GO and there are currently no requirements in place to provide the EMT data in MOD-032.

The Standards Grading Metrics need to be updated to take into account actual reliability impact and become a template for evaluating “pilot standards” which can help expedite the development and earlier adoption of new or revised standards.   Currently, the grading metrics focus on content and quality of the standards, unchanged since 2016.  Then, the purpose of grading was to ensure standards requirements were clearly understood and implemented properly to meet compliance. Today, the industry is moving quickly to try to address rapid changes to the grid by influences such as penetration of renewable resources, IBR-based energy storage and DER expansion, and extreme weather grid resilience. Because of these effects, many existing standards have been or will be impacted by revision requests. We recommend a new standard grading process be developed to assess whether a standard addressses these risks and, if not, be given a lower priority.  We believe this would better complement the purpose and objectives of the RSDP.

We also recommend that NERC consider including a targeted completion date for the projects included in the 2023 RSDP.  The recent Cold Weather projects have shown that standard drafting teams can work more expeditiously than we’ve seen in the past to successfully develop standards given a targeted completion date.

 

SRC 2022, Segment(s) 2, 1, 7/14/2022

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EEI suggests that NERC reconsider the current low priority prioritization of Project 2020-06 (Verification of Models and Data for Generators).  This rating does not appear to align with the NERC 2021 RISC Report that identified Grid Transformation as the No. 1 Risk.  The report goes on to state among the top mitigations is “update data, modeling and assessment requirements to ensure valid and accurate results.”  For this reason, we suggest elevating Project 2020-06 to medium priority.  Such a change would more closely align with the RISC recommendation.

EEI appreciates that estimates for work hours for supporting subject matter experts (SMEs). Given the numerous projects currently planned, it is important to have dependable work hour estimates for planning purposes for both NERC and supporting industry partners, who commit critical human resources (i.e., SMEs) to these projects. That said, we ask that NERC ensure these estimates are supported based on past project experience and feedback from the SMEs. 

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

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Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI) for question #2.

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

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The electric power industry, including the Tennessee Valley Authority (TVA), Federal Energy Regulatory Commission (FERC), the North American Electric Reliability Corporation (NERC), and the NERC regional entities, are concerned about the extreme heat that is impacting the Bulk Electric System (BES).  The impact of the extreme hot weather is a serious challenge to the integrity of and to the reliability of the BES.  To address this concern we recommend a NERC project that addresses extreme hot weather grid operations, preparedness, and coordination, similar to the Project 2021-07, Extreme Cold Weather Grid Operations, Preparedness, and Coordination.  With the impact and duration of extreme heating weather during the summer of 2022 and recent years, such a project will meet the priority designation of “High Priority.”  It may also receive a regulatory directive in the form of a NOPR from FERC, based on the concerns expressed by the FERC Chairman and the FERC Commissioners.

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

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On page 2 of the RSDP (page 6 of PDF) under the number “5” 2021-07 Extreme Cold Weather, it states the project was “adopted by the Board October 2022)”. This should be “anticipated Board Adoption October 2022),” as October has not happened yet.

 

Project 2020-04 is listed both as a continuing project on Page 1 of the RSDP (page 5 of the PDF) as well as a project planned to be completed this year (November) on the next page, page 2 (page 6 of the pdf). The project should be removed from the continuing projects list if it is expected to be completed this year.

 

Please consider removing Project 2020-04 Modifications to CIP-012 from the list of projects that will continue into 2023, since the project is also listed as a project that is planned to be completed in 2022. Please consider listing Project 2021-07 Extreme Cold Weather Grid Operations, Preparedness, and Coordination (Phase 1) as a project that is (anticipated Board adoption October 2022) instead of (adopted by the Board October 2022.) Please consider increasing the priority of Project 2020-06 Verification of Models and Data for Generators from a low priority project to a medium priority project in regard to events involving inverter-based resource performance

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/6/2022

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