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Draft 2017-2019 Reliability Standards Development Plan

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Start Date: 06/20/2016
End Date: 07/19/2016

Associated Ballots:

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Hot Answers

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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ERO Enforcement staff has started to collect “impact” data, in other words, did a violation cause or contribute to some observed impact on reliability?  We believe ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements.  Data would also be useful in affirming whether or not that a “paragraph 81” can be retired.

IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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Other Answers

Weighted consideration should be afforded to standards identified through Regional Risk Assessments and included in the ERO CMEP.

Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Basin Electric Power Cooperative recommends that NERC also consider SARs in their feedback loop that are submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment (IRA) since this activity may identify those requirements that are little to no risk to the BES and should be considered for retirement.

ERO Enforcements staff has started to collect “impact” data.  In other words, did a violation cause or contribute to some observed impact on reliability.  The NSRF believes ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements.  Data would also be useful in affirming whether or not a “paragraph 81” related requirement can be retired.

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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The NSRF recommends that NERC also consider SARs in their feedback loop that are submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment (IRA) since this activity may identify those requirements that are little to no risk to the BES and should be considered for retirement.

ERO Enforcements staff has started to collect “impact” data.  In other words, did a violation cause or contribute to some observed impact on reliability.  The NSRF believes ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements.  Data would also be useful in affirming whether or not a “paragraph 81” related requirement can be retired.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 7/14/2016

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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In the RSDP it is not evident where information from approved Implementation Guidance fits in with this process. It is mentioned under the Feedback Loops Section, but the text has not been updated from last year’s plan. Does it impact the priority of a project, IERP considerations, etc. For example if there are quality and content issues for a standard, but the approved Implementation Guidance addresses the issues is the priority lowered? Do the projects consider the approved Implementation Guidance and/or the CMEP Practice guides when ranking or deciding to undertake projects. If the approved Implementation Guidance can’t address the main issues associated with standard is the priority raised. The EPR Guidelines don’t appear to consider information produced that is related to the NERC Approved Compliance Guidance Policy. The RSDP should be updated/revised to better reflect the guidance and language provided in the NERC Approved Compliance Guidance Policy.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Since many compliance difficulties associated with a new Standard aren’t identified until the Standard is audited, consider implementing a voluntary pilot for new Standards whereby a participating entity is granted immunity for any violations identified by a targeted, multi-regional audit team.  The results of this targeted audit would provide invaluable input to refining the requirements, measures, etc.

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

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Texas RE recommends changing “Audit Feedback” to “Compliance Monitoring and Enforcement Feedback”.   Monitoring processes should include issues that arise in the Enforcement process.  For instance, many issues with Standard requirements, as well as measures and other supporting materials arise through the processing of self-reports and self-logs.  These experiences should be incorporated into a complete Standards feedback loop.

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

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ATC recommends that NERC also consider SARs in their feedback loop that are submitted either by a Registered Entity or Regional Entity after conducting an Inherent Risk Assessment (IRA) since this activity may identify Standards which include requirements that provide little to no risk to the BES and should be considered for retirement.

Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Tara Lightner, On Behalf of: Sunflower Electric Power Corporation - SPP RE - Segments 1

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 Dominion suggests adding the words “may be” to the following sentence: “This shows that the measures within some standards are may not be informative enough.”within the Feedback Loops section, Measures.  We believe that often requests for quidance within the Measures are based upon a  request to identifying  elements required to meet compliance rather than ambigious wording of a standard.

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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ERO Enforcements staff has started to collect “impact” data to identify when a violation caused or contributed to some observed impact on reliability.  We believe ongoing collection of this information will allow the ERO and the Industry to identify the most consequential requirements.  Data would also be useful in affirming whether or not that a “paragraph 81” can be retired or treated as compliance exceptions.

There’s one feedback loop that should be reconsidered.  NERC’s strategic plan notes it intends to use reviews of large system events to address reliability gaps via standards.  The occurrence of a single event does not mean there is a reliability gap.  W. Edwards Deming noted that that making changes to processes based on reaction to a single event often creates more waste, cost, and inefficiency than doing nothing at all.  There is variation in the physical universe and the single data point could be a one-time convergence of multiple factors that would never likely occur again.  While it is a worthwhile exercise to learn from events, changes to processes, particularly by implementing new standards, should be based on patterns of data.

While not directly part of the RSDP, we believe Standards are one tool in NERC’s kit that can be used to address risks.  We believe NERC and the standing committees (including the Standards Committee) should work with the NERC RISC to outline the process to select the appropriate tool based on facts/data, immediacy, estimated risk, cost,  and similar factors.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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NPCC Participating Members believe that the Standards Issues Database should be re-established to allow known issues to be “parked” and not lost.  These issues can be effectively stored until such time as the standard is re-opened again during an EPR.

RSC no National Grid, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/19/2016

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Hot Answers

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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Other Answers

Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 7/14/2016

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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The Measures section under the Feedback Loops Section looks outdated and not in alignment with CMEP Practice guides or approved Implementation Guidance which are detailed in the NERC Approved Compliance Guidance Policy. Where or how do these requests for guidance on measuring fit in with the guidance policy which details a move to the use of approved Implementation Guidance and CMEP Practice guides? As I understand the policy these two items should provide the guidance the industry is requesting. The former coming from the industry would provide methods to implement with internal controls that measure and validate performance. The latter coming from the ERO/RRO provides information about the methods and what the auditors will be looking for to validate compliance. The CMEP practice guide represents the meaures used by the ERO/RRO to check the effectiveness of internal controls and validate compliance. Because of this both items need to be considered and factored into the RSDP and right now they do not appear to be addressed in the draft. Putting an effort into get these items reviewed, approved and published could provide what is needed to avoid numerous revisions to the same standard.

The effort and cost associated with revising a standard can be enourmous for all involved, so reducing the number of revisions to a standard thru use of approved Implementation Guidance and CMEP Practice guides benefits everyone and supports the ultimate goal of improved reliability to the BES. In addition when there is a change to a Relaibility Standard new risks to the reliability of the BES can be introduced that will diminish over time. Frequent changes to the same Reliability Standard impacts the time needed to allow any new risks to diminish.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Southern Company, Segment(s) 3, 5, 6, 4/21/2016

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

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Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Tara Lightner, On Behalf of: Sunflower Electric Power Corporation - SPP RE - Segments 1

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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NPCC Participating Members believe that the RSDP should be a workplan of what is going to be done for standards development. The RSDP need not be a status report of what has been done, looking back. We suggest that the plan focus strictly on resources and projects that are going to be continued or started in the coming years covered by the plan. We don’t believe there is much value discussing and tracking issues such as outstanding FERC Directives. These other issues such as P-81 remaining issues, IERP recommendations and outstanding Directives should instead be status reports appearing in the weekly bulletin or as status items to the NERC Board of Trustees from the SC Chair.

RSC no National Grid, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/19/2016

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Hot Answers

There  are no requests for interpretation (RFI) under the "Interpretations" section of the current draft. However, it is our understanding that there are at least a few RFIs that have been discussed by the NERC Standards Committee and are in the queue to be worked on. For example, we have heard in several NERC forums that the "Project 2016-02 Modifications to CIP Standards" drafting team has been tasked with reviewing an outstanding RFI regarding "shared BES Cyber Systems". Yet, we do not see this reflected anywhere in the RSDP. Tri-State would like to see more transparency regarding RFIs. If there are some requests pending, then they should be included in the RSDP since that could have an impact on standards development. Industry should be able to see what RFIs are in the queue, their status and estimated timeline for when those interpretations will be addressed.

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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There are many activities outlined in the RSDP and NERC staff, drafting teams, and the Standards Committee should be commended for bringing us to a point where we have a sound body of standards.  That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together.  In other words, how do all the outcomes of these reliability based activities get introduced into a standards project?  It also looks like these activities, combined with ongoing directives and directives that occur when filing an “improved” standard will preclude achieving steady state.

We offer the following recommendations:

  • The front of the RSDP should have long term (e.g. 10 year) objectives or principles in order to guide what we want the standards to be in the future.  Examples might include:

    • Maintain a set of clear, workable (not perfect) standards that provide an adequate level of reliability.

    • Create a standards project when:

      • Directed by FERC.

      • Data affirms a reliability risk or gap

      • A cost effectiveness study affirms the project is worth pursuing

  • Create a table that gives the next mandatory 10 year review date.

  • Outline in the plan what specifically causes a standard to get escalated into an active standards project and introduced into the RSDP.  In general, we believe the activities in the RSDP should be used as input to decide whether or not to open an approved standard for changes, not to move it earlier in the queue in order to always have something in the pipeline. 

IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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Other Answers

Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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There are many activities outlined in the RSDP and NERC staff, drafting teams, and the Standards Committee should be commended in bringing us to a point where we have a sound body of standards.  That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together.  It also looks like these activities, combined with ongoing FERC directives and directives that occur when filing an “improved” standard will preclude achieving steady state.

Basin Electric Power Cooperative offers the following recommendations:

  • The front of the RSDP should have long term (e.g. 10 year) objectives or principles in order to guide what we want the standards to be in the future.  Examples might include:

    • Maintain a set of clear, “workably effective” (not perfect) standards that provide an “adequate level of reliability.

    • Develop new standards when

      • Directed by FERC.

      • Data affirms a reliability risk

      • When the industry affirms prior to starting the project that the investment is worth pursuing the project. 

  • Create a table or spreadsheet that tracks the next mandatory 10 year review date.

  • Outline in the plan what specifically causes a standard to get escalated due to reliability risks.  In general, Basin Electric Power Cooperative believes the activities in the RSDP should be used as input to decide whether or not to open a standard, not to move it earlier in the queue in order to always have something in the pipeline. 

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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There are many activities outlined in the RSDP and NERC staff, drafting teams, and the Standards Committee should be commended in bringing us to a point where we have a sound body of standards.  That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together.  It also looks like these activities, combined with ongoing FERC directives and directives that occur when filing an “improved” standard will preclude achieving steady state.

The NSRF offers the following recommendations:

  • The front of the RSDP should have long term (e.g. 10 year) objectives or principles in order to guide what we want the standards to be in the future.  Examples might include:
  • Maintain a set of clear, “workably effective” (not perfect) standards that provide an “adequate level of reliability.
  • Develop new standards when
  • Directed by FERC.
  • Data affirms a reliability risk
  • When the industry affirms prior to starting the project that the investment is worth pursuing the project. 
  • Create a table or spreadsheet that tracks the next mandatory 10 year review date.
  • Outline in the plan what specifically causes a standard to get escalated due to reliability risks.  In general, the  NSRF believes the activities in the RSDP should be used as input to decide whether or not to open a standard, not to move it earlier in the queue in order to always have something in the pipeline.  

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 7/14/2016

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Southern Company, Segment(s) 3, 5, 6, 4/21/2016

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

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Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Tara Lightner, On Behalf of: Sunflower Electric Power Corporation - SPP RE - Segments 1

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 Dominion believes that the inclusion of the presentation or a link to the NERC Standards Grading Backgroup and Process presentation dated June7, 2016 would be beneficial in understanding the Grading flowchart and process.

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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There are many activities outlined in the RSDP.  NERC staff, drafting teams, and the Standards Committee should be commended bring us to a point where we have a sound body of standards.  That said, it’s not clear how all these activities (periodic review, EPRs, Independent Expert activities, RSAW efforts, feedback, prioritization, grading, categorization/reorganization, etc.) all fit together.  It also appears that these activities, combined with ongoing directives and directives that occur when filing a revised standard, will prevent the ERO from achieving steady state.   With this regard, we offer the following recommendations:

  • The front of the RSDP should have long term (e.g. 10 year) objectives or principles in order to guide what we want the standards to be in the future.  Examples might include:

    • Maintain a set of clear, workable (not perfect) standards that provide an adequate level of reliability.

    • Develop new standards when

      • Directed by FERC.

      • Data affirms a reliability risk.

      • When the industry affirms prior to starting the project that the investment is worth pursuing the project. 

  • Create and post a table that gives the next mandatory 10 year review date.

  • Outline in the plan what specifically causes a standard to get escalated.  In general, we believe the activities in the RSDP should be used as input to decide whether or not to open a standard, not to move it earlier in the queue in order to always have something in the pipeline. 

 

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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RSC no National Grid, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/19/2016

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Hot Answers

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat.  FERC noted the need for a more adaptable approach at the recent Reliability Conference.  One activity in the RSDP should be to take a step back and via technical conferences or other outreach try to develop an improved approach.  NERC should develop a stable set of core CIP standards based on a review of the current set of CIP standards.

 

IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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Other Answers

Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Editorial Changes Only:

  1. The RSDP Table of Contents should list the two new attachments:

    1. Attachment 1 – Enhanced Periodic Review Guidelines

    2. Attachment 2 – Final Standards Grading for Standards Graded in 2016

  2. The draft RSDP should have a placeholder for Attachment 2 as not to overlook adding at a later date.

The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat.  FERC noted the need for a more adaptable approach at the recent Reliability Conference.  One activity in the RSDP should be to take a step back and via technical conferences or other outreach try to develop an improved approach.  Things to be considered include:

•    A stable set of core CIP standards.

•    Unless there is a national emergency threat, have a measured burn-in period for CIP changes, where for a period after a new requirement is approved and implement, it goes through a period (e.g. 2-3 years) where missteps (not programmatic failures) are handled as Compliance Exceptions.

•    Move away from using standards for emerging and less defined issues.  Basin Electric Power Cooperative believes that Readiness Reviews (aka Peer Reviews, Assistance Visits) would be a more nimble approach to evolving issues and move us from a least common denominator approach to one that pursues excellence.

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Editorial Changes Only:

  1. The RSDP Table of Contents should list the two new attachments:
  • Attachment 1 –Enhanced Periodic Review Guidelines
  • Attachment 2 – Final Standards Grading for Standards Graded in 2016

2. The draft RSDP should have a placeholder for Attachment 2 as not to overlook adding at a later date.

The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat.  FERC noted the need for a more adaptable approach at the recent Reliability Conference.  One activity in the RSDP should be to take a step back and via technical conferences or other outreach try to develop an improved approach.  Things to be considered include:

•    A stable set of core CIP standards.

•    Unless there is a national emergency threat, have a measured burn-in period for CIP changes, where for a period after a new requirement is approved and implement, it goes through a period (e.g. 2-3 years) where missteps (not programmatic failures) are handled as Compliance Exceptions.

•    Move away from using standards for emerging and less defined issues.  The NSRF believes that Readiness Reviews (aka Peer Reviews, Assistance Visits) would be a more nimble approach to evolving issues and move us from a least common denominator approach to one that pursues excellence.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 7/14/2016

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On page 5, first line, the reference to the « PRC family of standards » should be broken out so that specific standards are identified as eligible.

Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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The process is missing a feedback loop from FERC once an Order is posted to the Federal Register.  The SDP teams need to then clarify the implementation dates in the implementation plans for the Standard, instead of just leaving it in the circular references they do today.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Southern Company, Segment(s) 3, 5, 6, 4/21/2016

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

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Editorial Changes recommended by ATC:

The RSDP Table of Contents should list the two new attachments:

The draft RSDP should have a placeholder for Attachment 2 as not to overlook adding the attachment at a later date when the 2016 final Standards Grading is completed.

  1. Attachment 1 –Enhanced Periodic Review Guidelines

  2. Attachment 2 – Final Standards Grading for Standards Graded in 2016

  • The draft RSDP should have a placeholder(Blank pg.) at the end for Attachment 2 as not to overlook adding the attachment when the 2016 final Standards Grading is completed.

Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Tara Lightner, On Behalf of: Sunflower Electric Power Corporation - SPP RE - Segments 1

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Additionanally, Dominion believes that Footnote 2, Page iv, “2 The Standards Committee approved an EPR template on September 30, 2014 and presented it to the NERC Board of Trustees on November 12, 2014 as part of the Standard Committee’s update. The template includes background information and questions to guide a comprehensive review of the standard(s) by the EPR team, and serves as documentation of the EPR team’s considerations and recommendations  “ as it related to the statement in the  Executive Summary, Page iv, first sentence in the second paragraph, “As with the 2016-2018 RSDP, EPRs will occur at a measured pace2 …”  does not clarify the term measured pace but seems to be related to the template being used.  Please consider updating the reference to clarify what is meant by a measured pace.

Also, Dominionsuggests that throughout the document:  since this is a NERC document, should the defined terms for the various functional entities (i.e. Reliability Coordinator, Balancing Authority, Transmission Operator, etc…) be used when describing the FERC directives even though the FERC order does not use these defined terms?  The FERC orders are not being directly quoted so this would appear to be appropriate.  This would be consistent with other defined terms being used throughout the document.

Project 2015-08:  Dominion believes adding a footnote to the FERC guidance reference would be helpful.                                                     Project commencing in 2017:  Some additional information on potential emerging risks (i.e. GMD, CPP, etc…) would be helpful.

Dominion also notes that the RSDP has no mention or discussion of upcoming NERC assessments and coordination with standards/stakeholders on the impact these assessments could have on standards development and planning.  Therefore,  Dominion suggests that including some discussion on this interaction could be beneficial.  This topic could also influence the criteria for EPRs.

Dominion recommends that in general, the entire document could use a refresh as it reads the same as it has for the last 4-5 years.

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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The challenges in rolling out CIP V5 and the continuous CIP development activity point to the need for a different model to address this emerging threat.  FERC noted the need for a more adaptable approach at the recent Reliability Conference.  One activity in the RSDP should be to take a step back and via technical conferences or other outreach develop an improved approach to address CIP risk.  Things to be considered include:

  • A stable set of core CIP standards.

  • Unless there is a national emergency threat, have a measured burn-in period for CIP changes, where for a period after a new requirement is approved and implemented, it goes through a period (e.g. 2-3 years) where missteps (not programmatic failures) are handled as Compliance Exceptions.

  • Move away from using standards for emerging and less defined issues.  We believe that Readiness Reviews (aka Peer Reviews, Assistance Visits) would be a more nimble approach to evolving issues and move us from a least common denominator approach to one that pursues excellence.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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NPCC supports the pace of standards development and the EPR process as well as feedback loops noted in the RSDP and encourages the use of the Standards Grading activity to help prioritize Standards requiring revision. NPCC also supports Cost Effectiveness analysis activities and the NERC pilot to develop and refine any such analysis. We also suggest promoting the concept of cost effectiveness to the Reliability Issues Steering Committee (RISC). NPCC believes that cost considerations should enter into the emerging risk decision making process that the RISC is engaged in.

RSC no National Grid, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/19/2016

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