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Regulatory Updates

NERC and FERC Recommend Protection System Commissioning Improvements

Dylan Achey | Tim Farrar, PE | January 18, 2022

Changes Needed to Prevent Misoperations

In a recently released joint report, FERC and NERC identify several changes needed to prevent misoperations in utility protection system commissioning (PSC) programs. The organizations originally undertook a review of these programs and procedures after a sample of the Misoperation Information Data Analysis System (MIDAS) indicated that between 18 and 36 percent of reported utility misoperations were attributed to issues that could have been detected through a properly implemented PSC.

Generator and Transmission Owners responsible for protection systems maintenance and commissioning should take note of the report’s detailed findings which focus on relatively high misoperation rates reported by the industry. Key PSC program shortcomings observed include:

  • Lack of independent review of protection system designs by the commissioning group prior to construction;
  • Lack of centralized overarching PSC programs that serve as a tool for the execution of PSC procedures; and/or
  • Lack of feedback controls to prevent repeated problems in future projects.

Key PSC Recommendations

NERC and FERC’s recommendations are based on PSC information from eight representative utility participants with diverse geographical locations and one contractor entity with experience aiding registered entities with their PSC programs. The review team assessed the completeness of each utility participant’s PSC program and focused on the following critical elements of a reliable utility PSC program:

  • Stated goals and objectives
  • Well-defined plans to perform commissioning
  • Clearly identified lines of responsibility
  • Authority given to responsible parties
  • Feedback methods to improve the PCS plan

Next Steps

Regulated utilities are advised to review the report’s findings and recommendations and should be prepared to modify their PSC programs as necessary.

With expertise in all power generation and power delivery protection system engineering and commissioning subject areas. TRC can provide independent project management services to review your company’s PCS program and can offer an independent review of your program as called for in the Joint FERC-NERC Report. TRC is well positioned to assess your protection system’s ability to perform as required in compliance with NERC mandatory standards and guidance.


Your Trusted Regulatory Advisor

TRC closely follows the national and state regulatory trends in all regions of North America. Our approach to power system engineering, planning, design,  construction and commissioning testing balances solutions that incorporate appropriate industry trends, mandatory standard requirements, regulatory guidance, compliance obligations, best practices, operational goals, and budgets. With expertise in both power system planning and operations, we support public utilities and private energy providers in their effort to stay ahead of the curve to meet regulatory requirements as they evolve.

This regulatory update is a service to TRC’s utility clients, helping keep you informed of issues that impact your company’s electric system reliability risks along with related topics regarding regulatory developments to help you achieve your company’s business goals.

Dylan Achey

Dylan Achey is TRC’s Manager of Generation Engineering Services. He has been leading the effort with TRC generation clients on evaluating and providing updates/information so that clients can meet applicable NERC standards. His highly technical staff perform NERC compliance standard evaluations as well as studies for both generation and transmission clients that need assistance on technical issues concerning NERC compliance. Contact Dylan at

Tim Farrar, PE

Tim Farrar is a licensed professional engineer and works as the Protection & Controls Chief Engineer in TRC’s Augusta, Maine office. He is also a Certified Control System Technician (CCST) and Licensed Electrician with an Associate Degree from Eastern Maine Technical in Electrical Power Technology. Tim has 28 years of experience in protection and controls systems engineering for electric utilities and power generation industries including 10 years at Central Maine Power Company and 18 Years in the consulting engineering business. He has held several positions at TRC as an Engineer, Supervisor of Automation and Controls and Electrical Engineering Manager prior to his current position as Chief Engineer.

Contact Tim at

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