Authors: 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
GettyImages-827487222

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.

Contact Us

Resources

e7df91e7-in-the-grass-there-are-light-bulbs-1345611854

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.

Contact Us

Adapt to
Change

Partner With TRC’s Tested Practitioners

Contact Us

Sharing Our Perspectives

Our practitioners share their insights and perspectives on the trends and challenges shaping the market.

gettyimages-1777966022-2048x2048-1-min
Regulatory Updates

FERC Issues Guidance to Improve Power System Security and CIP Compliance

September 30, 2024

This update provides details from FERC 2024 staff report from CIP audits, so utilities can improve compliance and reduce security risks.

Powerlines-and-solar_326915924-min
Regulatory Updates

NERC Releases 2024 State of Reliability Report

September 19, 2024

The North American Electric Reliability Corporation (NERC) recently released its 2024 State of Reliability report, examining power system performance in calendar year 2023.

Electricity-workers-and-pylon-silhouette-1148713243
Regulatory Updates

Facility Ratings Compliance Through a Corporate Community Approach

August 30, 2024

Facility Ratings play a critical role in the reliable planning and operation of the Bulk Electric System (BES) and yet maintaining compliance with relevant NERC standards remains an industry challenge.

image-41-1
Regulatory Updates

Extreme Geomagnetic Disturbances Impact NERC Planning

August 8, 2024

Learn about the recent geomagnetic disturbance which caused stakeholders within the bulk power system to react swiftly to protect grid reliability. Find out the impacts and what NERC and the industry are doing about it.

Senior Engineer looking and checking electric power station.
Regulatory Updates

Consistent NERC Compliance Evidence for Successful Audit Outcomes

June 27, 2024

While utilities often work in technical silos, NERC auditors are trained to cross check compliance evidence and data between interrelated standards.

GettyImages-1352600335.jpg_Resize-1-649x502-1
Regulatory Updates

New NERC Standards Help Protect Against Cyber Attacks

May 23, 2024

As part of NERC’s ongoing effort to bolster Critical Infrastructure Protection (CIP) requirements and enable the implementation of a security improvement concept known as virtualization.

GettyImages-1207439061-scaled-1
Regulatory Updates

NERC Compliance Success Through a Corporate Community Approach

May 6, 2024

While utilities often work in technical silos, NERC auditors are trained to cross check compliance evidence and data between interrelated standards. Working in silos often leads to inadvertent situations where the compliance evidence from one standard is used but inconsistent with information produced or used by other standards. To assure compliance evidence reporting objectives are achieved in each applicable standard and requirement, it is important to identify interrelationships and create a framework where subject matter experts (SMEs) in all technical disciplines consider the evidence data consistency requirements. NERC compliance auditors are also trained to examine process flows and identify whether they are comprehensive or incomplete. Auditors determine the appropriateness of information by examining the quality and completeness of compliance evidence. They examine the relevance, validity, consistency and reliability of evidence used for addressing the audit reliability objectives and supporting their findings and conclusions. If conflicting evidence is found, they will identify this in their formal Regional Entity (RE) audit report findings which could further lead to a compliance violation and related fines. To improve the likelihood of favorable NERC audit compliance outcomes and avoid the need for implementing mitigation plans, individual contributors and SMEs should look at certain cross linked compliance evidence to assure consistency between approaches used to record compliance evidence. Doing so will allow a company to spend more time on executing core reliability duties and enhance company regulatory obligations. Avoid waiting until the RE compliance audits are underway to identify conflicting evidence situations.

e2fdef7d-photovoltaic-panels-of-solar-power-station-at-sunset-662095604
Regulatory Updates

NERC Proposes Changes to Registration Criteria for Inverter Based Resources (IBRs)

April 19, 2024

NERC has submitted for FERC approval new compliance criteria for the registration of IBRs as part of continuing efforts to address reliability risks. It is critical for renewable energy developers, generation owners and transmission owners to understand the potential implications for interconnection studies and interconnection queues.

elliott
Regulatory Updates

NERC Proposes Clarifications to EOP Cold Weather Standards

March 26, 2024

NERC has submitted proposed revisions to the EOP-012-2 – Extreme Cold Weather Preparedness and Operations standard, for FERC approval on an expedited basis. The proposed revisions address the remaining key recommendations from the FERC–NERC Joint Inquiry Report into Winter Storm Uri and directives arising from a 2023 FERC Order regarding the previously submitted cold weather standards.

Aerial-view-of-electrical-wires-large-scale-power-energy-tower-497627242-1-scaled-1
Regulatory Updates

Update to FAC-003-5 Brings Sweeping Changes to Transmission Classifications Starting April 1

March 19, 2024

Update to FAC-003-5 Brings Sweeping Changes to Transmission Classifications Starting April 1

Corporate-team-working-colleagues-working-in-office
Regulatory Updates

Prevent NERC Compliance Failures with Readiness Reviews

February 20, 2024

Every NERC-registered utility must strive for continuous compliance with their portfolio of applicable NERC Reliability Standards

high-voltage-substation-under-the-sunset
Regulatory Updates

NERC Releases 2024-2026 Standards Development Plan

January 26, 2024

NERC has submitted its 2024-2026 Reliability Standards Development Plan to the Federal Energy Regulatory Commission (FERC), outlining its current priorities and future standard development plans to protect the reliability of the Bulk Power System over the next three years.

elliott
Regulatory Updates

NERC & FERC Release Winter Storm Elliott Report

January 2, 2024

NERC and FERC have released their final report on Winter Storm Elliott which provides reinforcement for recommendations in prior cold weather-related disturbance event reports. The Report identifies critical reliability performance shortcomings and the reliability related near misses. NERC states that a crisis was “narrowly dodged.” The Report outlines the steps the industry must take to avoid a repeat in the future.

Solar-Panels
Regulatory Updates

FERC Order 901 Calls for Standards to Address IBR Reliability Gaps

November 27, 2023

Inverter Based Resources are playing central role when it comes to adding new electric generation capacity into the bulk power system.

nerc-releases-inverter-based-resources-webinar
Regulatory Updates

NERC Releases Inverter Based Resources Webinar Series

October 19, 2023

As the power delivery system continues to rapidly evolve due to decarbonization policy initiatives, inverter-based resources (IBRs) are playing an ever-more significant role in generation additions to the bulk power system. NERC and other technical organizations have taken numerous actions to support the reliable integration of these resources.

windmills
Regulatory Updates

FERC Issues Order 2023 to Resolve Interconnection Process Issues

September 25, 2023

The Federal Energy Regulatory Commission has approved Order 2023 to facilitate and improve the speed and reliability of adding new energy resources to the power system

cfats-program-expires-but-reauthorization-anticipated-this-fall
Regulatory Updates

CFATS Program Expires but Reauthorization Anticipated this Fall

September 6, 2023

Regulated organizations should continue to follow DHS cybersecurity requirements.

b78b71a2-ferc
Regulatory Updates

FERC Hosts Technical Conference on the Effectiveness and Improvements to CIP-014-3

August 30, 2023

Expert Discussions and Key Takeaways Focus on Physical Security

power-lines
Insights

Intro to NERC Regulatory Guidance on Inverter-Based Resources

August 29, 2023

As renewable energy proliferates across the US power system, the North American Electric Reliability Corporation (NERC) continues to actively address reliability risks resulting from the implementation of inverter-based resources (solar and wind generation technology) connected at both transmission and Distributed Energy Resources (DER) levels.

extreme-weather-initiative-changes-transmission-planning-
Regulatory Updates

FERC Extreme Weather Initiative Will Change the Transmission Planning Process

July 26, 2023

FERC issued a Final Rule directing NERC to develop a new or modified reliability standard addressing transmission system planning performance requirements for extreme heat or cold weather events.

inverter-bas
Regulatory Updates

FERC Approves Plan to Register Certain Inverter-Based Resources as part of NERC Mandatory Standards Compliance Program

June 21, 2023

FERC issued an order approving NERC’s compliance filings.

3364aa84-nerc-files-report-on-effectiveness-on-cip-014-physical-security-standard
Regulatory Updates

NERC Files Report on Effectiveness on CIP-014 Physical Security Standard

May 25, 2023

On behalf of the North American Electric Reliability Corporation (NERC), its President and CEO Jim Robb, recently presented to the Federal Energy Regulatory Commission (FERC) a summary of NERC’s report on the effectiveness of NERC’s CIP-014 Physical Security Standard. There were almost 1,700 physical security incidents reported to the Electricity-Information Security Analysis Center (E-ISAC) in 2022, an increase of 10.5% from 2021.

41dcd979-gettyimages-1190354242-1
Regulatory Updates

FERC Issues Order on Cold Weather Reliability Standards

April 27, 2023

FERC has approved two NERC proposed cold weather-related reliability standards.

72e2e911-substation-in-the-evening-1163113257
Regulatory Updates

FERC Orders Internal Network Security Monitoring Rule to be Finalized

March 14, 2023

FERC directed NERC to develop Reliability Standards to implement INSM within trusted CIP environments.

solar-photovoltaic-panels-and-substations
Regulatory Updates

Insights from the Odessa II Power System Disturbance

February 22, 2023

NERC and TRE release the Odessa II Power System Disturbance Report

solar20panel20transmission20lines20substations
Regulatory Updates

New FERC Orders Will Change Regulatory Process for Inverter Based Resources

January 9, 2023

The Federal Energy Regulatory Commission (FERC) recently proposed actions to keep the regulatory process and requirements ahead of reliability risks resulting from the accelerated deployment of Inverter Based Resources (IBR) based solar, wind and battery storage projects.

transmission-towers-and-substation-at-dusk
Regulatory Updates

NERC Releases Facilities Ratings Best Practices Report

December 19, 2022

NERC report on best practices for utilities that have encountered facility ratings program challenges.

Electric Reliability Corporation
Regulatory Updates

NERC Files Comments in the FERC Generator Interconnection Notice of Proposed Rulemaking

November 21, 2022

The rulemaking addresses improvements needed to reliably facilitate the power industry’s transition to renewable and distributed generating resources utilizing inverter-based technologies.

GettyImages-1718569266-sm
Regulatory Updates

NERC Releases Inverter-Based Resource Strategy Plan

October 25, 2022

The North American Electric Reliability Corporation (NERC) recently released an Inverter-Based Resource (IBR) Strategy, which details the steps needed to successfully integrate IBR facilities into the planning and operation of the power system. The strategy was put in place due to the rapid interconnection of IBR systems, which are extensively used for solar and wind generating facilities, including new battery-based energy storage systems and are one of the most significant drivers of power grid transformation. Because of control system inconsistencies, IBR facilities pose well-documented risks to power system reliability when this strategy’s practices are not adhered to. NERC’s plan calls attention to the need for thoughtful integration of IBRs and identifies current and future work required to mitigate reliability risks resulting from the deployment of this technology.

power-lines
Regulatory Updates

NERC Releases 2022 State of Reliability Report

September 16, 2022

The North American Electric Reliability Corporation (NERC) recently released its 2022 State of Reliability report, which examines power system performance in calendar year 2021 and evaluates reliability performance trends. The 2022 report identified six key findings regarding power system performance that are summarized as follows:

GettyImages-534863741
Regulatory Updates

NERC Proposes Implementation Guidance for PRC-019-2

August 22, 2022

NERC has proposed implementation guidance for PRC-019-2, the standard that verifies coordination of generating unit facility or synchronous condenser voltage regulating controls, limit functions, equipment capabilities and protection system settings.

transmission20lines20substations
Regulatory Updates

Revisions to FAC-001 and FAC-002 Submitted for FERC Approval

July 12, 2022

Reliability Standards FAC-001-4 and FAC-002-will resolve uncertainty regarding the meaning of “materially modify” under the currently effective standards.

silhouette-of-two-engineers-discussing-together
Regulatory Updates

FERC Order No. 881-A Has Implications for NERC Compliance Programs

June 23, 2022

Updated Order will have significant impact on NERC compliance programs related to both PRC standards and facilities ratings. Utilities should review the Order’s requirements and prepare for changes needed to remain compliant.

electric-industrial-power-station-windmill-and-sola
Regulatory Updates

NERC’s Revised PRC-024-3 Standard for Inverter-Based Generation Effective in October 2022

May 11, 2022

Changes to PRC-024-3 in support of inverter-based generation performance are going into effect in October of this year. Interconnection programs and documentation procedures may need to be updated in order to maintain compliance.

GettyImages-989229564
Regulatory Updates

FERC Issues Notice of Inquiry Regarding Dynamic Line Ratings

April 25, 2022

There are significant technical challenges involved in implementing Dynamic Line Ratings in the planning and operation of utility systems. Utilities should be prepared to modify their NERC compliance programs as necessary to address the potential introduction of DLR in their businesses.

pylon-and-photovoltaic-panels
Regulatory Updates

New NERC Guidance Supports the Implementation of Grid Forming Inverters

March 8, 2022

NERC has issued a new report highlighting the key attributes of various inverter controls to support proper implementation and to protect reliability.

GettyImages-1070427216
Regulatory Updates

NERC Recommends Approaches for Underfrequency Load Shedding Programs

February 24, 2022

In a recently released reliability guideline, NERC recommends additional approaches for Underfrequency Load Shedding (UFLS) program design to help utilities effectively consider the effects of Distributed Energy Resources (DERs). The guidance was developed to address the accelerated transition of the power system to locally installed, decarbonized resources that depend on inverters. These new technologies introduce operational controls issues into the electric grid. UFLS data gathering and analysis methodologies may require modification to address reliability risks.

c9d7cd17-regs
Insights

FERC Order No. 2222, DERs & Energy Technology

February 1, 2022

FERC issued O. 2222 to enable distributed energy resources (DERs) to better participate alongside traditional resources in regional, organized wholesale markets.

protection-and-controls_2
Regulatory Updates

NERC and FERC Recommend Protection System Commissioning Improvements

January 18, 2022

Between 18 and 36 percent of reported utility misoperations were attributed to issues that could have been detected through a properly implemented PSC.

d4eb5574-microsoftteams-image-33
Regulatory Updates

FERC & NERC Issue Joint Report on Freeze Reliability Failures

December 15, 2021

The in-depth report outlines twenty-eight recommendations to address freeze reliability failures, including operating practices and recommendations for NERC standards modifications surrounding generator winterization and gas-electric coordination.

cold-weather
Regulatory Updates

NERC Accelerates Additional Cold Weather Standards Changes

November 22, 2021

At its November 2021 meeting, NERC’s Board of Trustees took aggressive action to advance critical cold weather Reliability Standards. Most notably, the group approved the 2022-2024 Reliability Standards Development Plan, which prioritizes standards projects for the coming years including a resolution to include new cold weather operations, preparedness and coordination standards as high priority development projects.

GettyImages-665252122

PRC-002-2 Disturbance Monitoring and Reporting Standard: Initial Mandatory Implementation Plan Dates Approach

November 18, 2021

The Federal Energy Regulatory Commission approved PRC-002-2 in September, 2015. The initial due date for system studies necessary to identify locations for the collection of disturbance related data under Requirement R1 is January 1, 2017.

0ec0f37f-chess
Insights

Substation Hardening: Don’t Be a Pawn to Security

October 28, 2021

Protecting our critical energy infrastructure from physical security threats is certainly not a game, but the process can take some important lessons from the game of chess.

New-Potential-Compliance-Standards-Identified-at-FERC-Technical-Conference-on-Reliability-1
Regulatory Updates

New Potential Compliance Standards Identified at FERC Technical Conference on Reliability

October 18, 2021

With a focus on the reliability impact of extreme weather and the shortcomings of current system planning approaches, both NERC and FERC conference participants opened the door to potential forthcoming compliance standard enhancements or changes.

NERC-Issues-Odessa-Texas-Disturbance-Report-1
Regulatory Updates

NERC Issues Odessa Texas Disturbance Report

September 29, 2021

While NERC has analyzed multiple similar events in California, this is the first disturbance involving a widespread reduction of PV resource power output observed in the Texas Interconnection.

snowy-powerline-in-winter
Regulatory Updates

FERC Approves Modifications to NERC’s Cold Weather-Related Standards

September 7, 2021

The Federal Energy Regulatory Commission has approved changes to three mandatory NERC Reliability Standards that aim to better prepare the North American power system to withstand extreme cold weather events.

Salton-Sea-scaled-4
Regulatory Updates

NERC’s Generator Relay Loadability Standard is Now in Effect

August 30, 2021

The Federal Energy Regulatory Commission (FERC) has approved changes to three mandatory NERC Reliability Standards that aim to better prepare the North American power system to withstand extreme cold weather events. All utilities, even those not impacted by recent events, will be required to comply. The modified standards include: EOP-011-2 (Emergency Preparedness and Operations) IRO-010-4 (Reliability Coordinator Data Specification and Collection) TOP-003-5 (Operational Reliability Data) NERC proposed the standards modifications in response to the findings of the NERC FERC Joint Report on the 2018 South Central Cold Weather Event. The changes address the need to winterize facilities; ensure the accurate reporting of design specifications to reliability coordinators for generating units; and the need for balancing authorities and reliability coordinators to be aware of, and plan for, generating units’ limitations during extreme cold weather.

clean-energy
Regulatory Updates

NERC Seeks to Improve GADS Reliability Performance Reporting

August 26, 2021

Under the enabling legislation that created the Electric Reliability Organization, NERC is responsible for assessing the reliable performance of the power system. One way NERC does so is via an industry reporting system for generation and transmission. The Generator Availability Data System (GADS) has been used by NERC and the industry for over 40 years to obtain data on the generation component of the power system[1]. Due to the rapidly changing generating resource mix, it is essential that NERC have comprehensive plant, event, outage and performance data for photovoltaic and wind generation to ensure reliability. As renewable technologies are increasingly deployed, a complete set of generation asset performance statistics is necessary to allow NERC to evaluate the system’s ability to serve load, the performance of the power system and to forecast any potential reliability issues due to resource inadequacy. Therefore, NERC is proposing to make the following enhancements to the GADS data collection process for renewable generation: Add Generator Owners that operate solar photovoltaic facilities of 20 MW or greater to the Generating Availability Data System (referred to as “GADS-PV”); and Expand GADS Wind (“GADS-W”) reporting to include connected energy storage and event reporting.

1907f223-ercot-transmission
Regulatory Updates

Electric Reliability Council of Texas Releases 60-Point Plan for Change

August 23, 2021

ERCOT’s recently released “Roadmap to Improving Grid Reliability” presents a plan for change in Texas that includes increasing electric power generation and purchasing significantly more power reserves.

f4a996d8-nerc-compliance
Regulatory Updates

Prepare for Upcoming NERC Compliance Deadlines

August 20, 2021

With 2020 right around the corner, there are many new NERC standards and standards requirements set to go into effect in the areas of Critical Infrastructure Protection and Transmission Operations and Planning.

777c8e0e-microsoftteams-image-19
Regulatory Updates

Developments in Texas and Nationally Mandate Extreme Weather Responses to Protect Reliability

July 23, 2021

Two recent actions will change the current system planning, investment needs and operating procedures for electric utilities. New infrastructure investments and more robust compliance programs will be needed.

GettyImages-471943873-1
Regulatory Updates

Electric System Planning for Extreme Weather Events: NERC Recommends Actions to Protect Reliability this Summer

June 23, 2021

Due to recent extreme weather-related power systems failures, stakeholders are examining the planning and operations practices for all electric utilities.

9325eb27-substation-and-power-transmission-lines-1226921578
Regulatory Updates

NERC’s FAC-008 Guidance on Facility Ratings

May 24, 2021

FAC-008 is one of the most data-intensive standards in the NERC regulatory framework. Compliance has been difficult for many utilities. Recently, FERC made public it’s intent to address serious allegations of facility ratings violations, including a lack of rigor by one utility.

NERC-Issues-Battery-Energy-Storage-Systems-Reliability-Guidance
Regulatory Updates

NERC Issues Battery Energy Storage Systems Reliability Guidance

April 22, 2021

While NERC has recently published a reliability guideline addressing inverter-based resources generally, they are now giving more attention to the various potential uses of BESS to support effective implementation with newly released guidance.

NERC-Proposes-Revisions-to-CIP-008
Regulatory Updates

NERC Proposes Revisions to CIP-008

March 27, 2021

NERC’s CIP-008 standard aims to mitigate reliability risks resulting from a Cyber Security Incident by specifying incident response requirements. Newly proposed revisions would augment mandatory reporting to include incidents that compromise, or attempt to compromise, a utility’s Electronic Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMS).

powerline-snow-winter
Regulatory Updates

Cold Weather Reliability Preparedness and Hardening

March 22, 2021

The latest weather impacts to power reliability have accelerated the need for mandatory regulatory compliance changes.

10f61d9f-compliance-theme-with-aerial-view-of-city-skylines-1211589828
Regulatory Updates

NERC Releases 2021 Compliance Monitoring and Enforcement Findings

February 8, 2021

NERC’s 2021 Compliance Monitoring and Enforcement Program reframes the previous year’s risks and their associated areas of focus. Utilities should review their compliance programs and internal controls to determine if enhancement or changes are need to maintain compliance.

NERC-Proposes-Revision-of-Pending
Regulatory Updates

NERC Proposes Revision of Pending TPL-001-5.1 Standard

January 20, 2021

NERC has recently undertaken important standards and guidance development activities related to the proliferation of inverter-based technologies such as solar and wind generation, as well as battery energy storage which is growing as an industry solution to ensure the reliability of renewable power for end-use customers.

NERC-and-FERC-Take-Action-on-Facilities-Ratings
Regulatory Updates

NERC and FERC Take Action on Facilities Ratings

December 4, 2020

There has been significant work across the electric industry to improve facility ratings related processes, programs, frameworks, internal controls and best practices. Yet this continues to be a challenging area for utilities, particularly from an asset management and regulatory compliance perspective.

FERC-Issues-Annual-Report-on-Critical-Infrastructure-Protection-CIP-Reliability-Audits
Regulatory Updates

FERC Issues Annual Report on Critical Infrastructure Protection (CIP) Reliability Audits

November 17, 2020

In its 2020 Report on CIP Reliability Audits, the Federal Energy Regulatory Commission found that most of the cybersecurity protection processes and procedures adopted by utilities met the mandatory CIP requirements for protecting the Bulk Electric System. However, there are areas for improvement.

NERC-Prioritizes-Inverter-Based-Resources-for-Future-Standards-Development
Regulatory Updates

NERC Prioritizes Inverter-Based Resources for Future Standards Development

October 19, 2020

As inverter-based resources found in wind and solar generation technologies continue to rapidly penetrate the U.S. power delivery system, NERC remains focused on managing the potential reliability consequences.

NERC-Issues-2020-State-of-Reliability-Report-1
Regulatory Updates

NERC Issues 2020 State of Reliability Report

September 22, 2020

The Report identifies areas of ongoing concern including generation reserve margins and the reliability risk from shifting the resource mix toward renewables.

technologies
Regulatory Updates

NERC Issues Lessons Learned on Misoperations Due to Mixing Relay Technologies

August 13, 2020

On July 10, 2020 NERC released new Lessons Learned guidance to address situations where multiple composite protection systems have misoperated as a result of mixing protective relay technologies at the remote terminals of directional comparison blocking (DCB) schemes. This technical information will help utilities improve the reliability of the Bulk Power System.

Voltage-Protection-Settings-for-Generating-Resources-1
Regulatory Updates

NERC Reliability Standard PRC-024-3 Approved: Frequency and Voltage Protection Settings for Generating Resources

July 28, 2020

On July 9, 2020 NERC standard PRC-024-3 was approved, paving the way for improved protection systems in support of keeping generating resources connected during defined frequency and voltage excursions.

Summary-of-NERC-CIP-Standards-Updates-1
Regulatory Updates

Summary of NERC CIP Standards Updates

June 29, 2020

FERC has released a notice of inquiry seeking comments on potential enhancements to NERC’s Critical Infrastructure Protection (CIP) Reliability Standards.

NERC-Protection-System-Compliance-Studies-Due-This-Year-1
Regulatory Updates

NERC Protection System Compliance Studies Due This Year

February 24, 2020

NERC’s PRC-027-1 standard was approved by FERC in 2018 and is set to go into effect on October 1, 2020. Utilities should begin preparing now to meet compliance requirements which include significant system studies.

1389c41c-power-tower
White Papers / Reports

NERC Compliance Assurance: Maintaining Cross Functional Data Integrity

January 21, 2020

Assuring continued power system reliability is a complex undertaking for utilities. Balancing the demands of system changes and regulatory compliance is an essential strategy for optimizing ongoing operations. Given the wide range of NERC standard families that require simultaneous data management for compliance, data integrity, data flow and data verification are critical for avoiding violations that can impact electric service to customers and communities.

b65d7094-physical-and-cyber-security

NERC Reliability Report Prioritizes Power System Security Risks for Action

January 2, 2020

NERC’s 2019 ERO Reliability Risk Priorities Report identified and prioritized the major risks facing the utility industry with a particular focus on security issues.

GettyImages-1402147678
Regulatory Updates

NERC Reliability Report Prioritizes Power System Risks

November 21, 2019

Looking ahead to the many changes coming to North America’s Bulk Power System (BPS), NERC’s 2019 ERO Reliability Risk Priorities Report highlights the top issues requiring industry and regulatory attention and recommends actions for the ongoing protection of BPS reliability.

NERC-Pursues-Changes-to-Protection-Relay-and-Control-PRC-Standards-1
Regulatory Updates

NERC Pursues Changes to Protection Relay and Control (PRC) Standards

September 24, 2019

Two Standards Authorization Requests currently being debated in the NERC stakeholder engagement process could help clarify PRC standards obligations for generator owners and operators.

GettyImages-636068142
Regulatory Updates

NERC to Modify Standard and Develop Compliance Guidance to Accommodate Inverter-Based Generation Technologies

February 20, 2019

Renewable energy systems have dramatically changed the power generation resource mix. These new generation technologies no longer involve directly coupled rotating generators which were once standard in the industry. Now, inverters that change Direct Current (DC) electricity to the Alternating Current (AC) electricity suitable for delivery via AC transmission systems are becoming more prevalent, raising reliability…

NERC-Addresses-Single-Points-of-Failure-in-Protection-Systems-Among-Other-FERC-Concerns-1
Regulatory Updates

NERC Addresses Single Points of Failure in Protection Systems Among Other FERC Concerns

October 25, 2018

Under the proposed NERC TPL-001-5 standard, utilities with transmission planning responsibilities will be required to identify reliability risks related to protection system failures and take mandatory corrective action. It will be critical to have an in depth understanding of your company’s protection system settings and to perform the system studies necessary to identify where single points of failure may result in cascading tripping of transmission elements. Mitigation actions may require the installation of redundant protection systems which in turn may lead to significant substation redesign. Transmission planners and planning coordinators should begin preparing for any necessary protection system changes. TPL-001-5 Overview NERC began studying the reliability risk associated with single points of protection system failure starting in 2011 as directed in FERC Order 754. TPL-001-5 will bring significant changes for Planning Coordinators and Transmission Planners as they perform annual Planning Assessments. There is a new obligation to adequately account for the reliability risk posed by single point of protection system failure via risk-based Assessment. This reliability risk management approach will be implemented through modifications to the Category P5 Planning Event which is described in Table 1 of the TPL-001-5 standard. NERC believes that the most cost-effective Corrective Action Plans to address unacceptable system performance for the P5 Planning Events will likely be to add protection system component redundancy in certain cases. Protection system redundancy changes to address Category P5 Event system performance violations should reduce or even negate non-redundant component related risks that need to be considered in assessing transmission system performance. These risks will be identified during simulations of certain extreme events as required under the standard. TPL-001-5 also addresses reliability risks related to outage management as directed in FERC Order 786. The standard requires utility planners to consider maintenance outages of significant facilities as well as outages for critical long lead time to repair or replace equipment. Specifically, it addresses stability analysis to assess system performance for conditions expected during possible unavailability of long lead time equipment. Although it is not a NERC defined term, it is believed that a “spare equipment strategy will be sufficient to allow flexibility for utilities to conduct both steady state and stability analysis required by TPL-001-5. For example, a utility’s spare equipment strategy may include the warehousing of a replacement transformer to be installed given the failure of an in service transformer. When a utility’s spare equipment strategy may prevent major transmission equipment from being out-of-service for one year or more, this possible equipment unavailability need not be assessed as part of TPL-001-5.

GettyImages-1344124162-scaled

NERC Proposes Compliance Monitoring and Enforcement Plan for 2019

September 26, 2018

This month, NERC released the first draft of its 2019 Compliance Monitoring and Enforcement Plan (CMEP) which identifies power delivery system risks and outlines compliance audit requirements for next year. The risk elements outlined in the plan include significant differences from previous years, as shown in the table below. Each NERC region must consider these risks as they develop their monitoring and audit scopes for utilities. Utilities should be prepared to be audited and implement any necessary compliance initiatives in these areas.

GettyImages-483313074
Regulatory Updates

NERC Calls for New Approach to Reliability Planning Due to Gas Supply Disruption Risks

December 14, 2017

A recently published NERC report concludes that as reliance on natural gas to meet electric generation requirements increases, additional planning and operational measures must be considered to mitigate power system reliability risks.

5d21a930-trc-cfats-cyber-security
Insights

Hardening Cyber Defenses at Chemical Facilities a Key Part of Federal CFATS Regulations

October 24, 2017

Federal CFATS regulations cover more than just the handling, transport and storage of dangerous chemicals. They also deal with tools and methods terrorists could use to acquire the deadly agents – such as a cyber attack.

GettyImages-496264156
Regulatory Updates

NERC CIP-013-1 Standard for Supply Chain Risk Management

September 29, 2017

NERC has filed mandatory standard CIP-013-1 for supply chain risk management, requiring controls to mitigate cyber threats and their impact to the reliable operation of the Bulk Electric System.

GettyImages-1493729544
Regulatory Updates

NERC Identifies New Reliability Risk due to Utility Scale Solar Generation Inverter Design

June 13, 2017

NERC has released a report documenting its findings and recommendations related to reliability risks from utility scale solar generation projects with implications for PRC-024 compliance, as well as generation, interconnection and protection system technologies.

GettyImages-172424949
Regulatory Updates

NERC Standard Extends Maintenance Program Obligations to Generators

February 3, 2014

The approval of NERC Standard PRC-005-2 extends protection system maintenance obligations to Generators and crates one comprehensive standard establishing minimum maintenance activities and maximum time intervals for protection systems and load shedding equipment affecting the bulk electric system.

gettyimages-1777966022-2048x2048-1-min
Regulatory Updates

FERC Issues Guidance to Improve Power System Security and CIP Compliance

September 30, 2024

This update provides details from FERC 2024 staff report from CIP audits, so utilities can improve compliance and reduce security risks.

Corporate-team-working-colleagues-working-in-office
Regulatory Updates

Prevent NERC Compliance Failures with Readiness Reviews

February 20, 2024

Every NERC-registered utility must strive for continuous compliance with their portfolio of applicable NERC Reliability Standards

elliott
Regulatory Updates

NERC & FERC Release Winter Storm Elliott Report

January 2, 2024

NERC and FERC have released their final report on Winter Storm Elliott which provides reinforcement for recommendations in prior cold weather-related disturbance event reports. The Report identifies critical reliability performance shortcomings and the reliability related near misses. NERC states that a crisis was “narrowly dodged.” The Report outlines the steps the industry must take to avoid a repeat in the future.

Solar-Panels
Regulatory Updates

FERC Order 901 Calls for Standards to Address IBR Reliability Gaps

November 27, 2023

Inverter Based Resources are playing central role when it comes to adding new electric generation capacity into the bulk power system.

windmills
Regulatory Updates

FERC Issues Order 2023 to Resolve Interconnection Process Issues

September 25, 2023

The Federal Energy Regulatory Commission has approved Order 2023 to facilitate and improve the speed and reliability of adding new energy resources to the power system

b78b71a2-ferc
Regulatory Updates

FERC Hosts Technical Conference on the Effectiveness and Improvements to CIP-014-3

August 30, 2023

Expert Discussions and Key Takeaways Focus on Physical Security

extreme-weather-initiative-changes-transmission-planning-
Regulatory Updates

FERC Extreme Weather Initiative Will Change the Transmission Planning Process

July 26, 2023

FERC issued a Final Rule directing NERC to develop a new or modified reliability standard addressing transmission system planning performance requirements for extreme heat or cold weather events.

inverter-bas
Regulatory Updates

FERC Approves Plan to Register Certain Inverter-Based Resources as part of NERC Mandatory Standards Compliance Program

June 21, 2023

FERC issued an order approving NERC’s compliance filings.

3364aa84-nerc-files-report-on-effectiveness-on-cip-014-physical-security-standard
Regulatory Updates

NERC Files Report on Effectiveness on CIP-014 Physical Security Standard

May 25, 2023

On behalf of the North American Electric Reliability Corporation (NERC), its President and CEO Jim Robb, recently presented to the Federal Energy Regulatory Commission (FERC) a summary of NERC’s report on the effectiveness of NERC’s CIP-014 Physical Security Standard. There were almost 1,700 physical security incidents reported to the Electricity-Information Security Analysis Center (E-ISAC) in 2022, an increase of 10.5% from 2021.

41dcd979-gettyimages-1190354242-1
Regulatory Updates

FERC Issues Order on Cold Weather Reliability Standards

April 27, 2023

FERC has approved two NERC proposed cold weather-related reliability standards.

72e2e911-substation-in-the-evening-1163113257
Regulatory Updates

FERC Orders Internal Network Security Monitoring Rule to be Finalized

March 14, 2023

FERC directed NERC to develop Reliability Standards to implement INSM within trusted CIP environments.

Electric Reliability Corporation
Regulatory Updates

NERC Files Comments in the FERC Generator Interconnection Notice of Proposed Rulemaking

November 21, 2022

The rulemaking addresses improvements needed to reliably facilitate the power industry’s transition to renewable and distributed generating resources utilizing inverter-based technologies.

c7e32b54-business-strategy-consulting-1186614184
Insights

Using Economic Impact Assessments to Share the Story of a Project or Facility

August 24, 2022

Economic Impact Assessments can demonstrate the positive effects a project has on the local economy.

transmission20lines20substations
Regulatory Updates

Revisions to FAC-001 and FAC-002 Submitted for FERC Approval

July 12, 2022

Reliability Standards FAC-001-4 and FAC-002-will resolve uncertainty regarding the meaning of “materially modify” under the currently effective standards.

silhouette-of-two-engineers-discussing-together
Regulatory Updates

FERC Order No. 881-A Has Implications for NERC Compliance Programs

June 23, 2022

Updated Order will have significant impact on NERC compliance programs related to both PRC standards and facilities ratings. Utilities should review the Order’s requirements and prepare for changes needed to remain compliant.

electric-industrial-power-station-windmill-and-sola
Regulatory Updates

NERC’s Revised PRC-024-3 Standard for Inverter-Based Generation Effective in October 2022

May 11, 2022

Changes to PRC-024-3 in support of inverter-based generation performance are going into effect in October of this year. Interconnection programs and documentation procedures may need to be updated in order to maintain compliance.

GettyImages-989229564
Regulatory Updates

FERC Issues Notice of Inquiry Regarding Dynamic Line Ratings

April 25, 2022

There are significant technical challenges involved in implementing Dynamic Line Ratings in the planning and operation of utility systems. Utilities should be prepared to modify their NERC compliance programs as necessary to address the potential introduction of DLR in their businesses.

GettyImages-1070427216
Regulatory Updates

NERC Recommends Approaches for Underfrequency Load Shedding Programs

February 24, 2022

In a recently released reliability guideline, NERC recommends additional approaches for Underfrequency Load Shedding (UFLS) program design to help utilities effectively consider the effects of Distributed Energy Resources (DERs). The guidance was developed to address the accelerated transition of the power system to locally installed, decarbonized resources that depend on inverters. These new technologies introduce operational controls issues into the electric grid. UFLS data gathering and analysis methodologies may require modification to address reliability risks.

c9d7cd17-regs
Insights

FERC Order No. 2222, DERs & Energy Technology

February 1, 2022

FERC issued O. 2222 to enable distributed energy resources (DERs) to better participate alongside traditional resources in regional, organized wholesale markets.

protection-and-controls_2
Regulatory Updates

NERC and FERC Recommend Protection System Commissioning Improvements

January 18, 2022

Between 18 and 36 percent of reported utility misoperations were attributed to issues that could have been detected through a properly implemented PSC.

d4eb5574-microsoftteams-image-33
Regulatory Updates

FERC & NERC Issue Joint Report on Freeze Reliability Failures

December 15, 2021

The in-depth report outlines twenty-eight recommendations to address freeze reliability failures, including operating practices and recommendations for NERC standards modifications surrounding generator winterization and gas-electric coordination.

cold-weather
Regulatory Updates

NERC Accelerates Additional Cold Weather Standards Changes

November 22, 2021

At its November 2021 meeting, NERC’s Board of Trustees took aggressive action to advance critical cold weather Reliability Standards. Most notably, the group approved the 2022-2024 Reliability Standards Development Plan, which prioritizes standards projects for the coming years including a resolution to include new cold weather operations, preparedness and coordination standards as high priority development projects.

GettyImages-665252122

PRC-002-2 Disturbance Monitoring and Reporting Standard: Initial Mandatory Implementation Plan Dates Approach

November 18, 2021

The Federal Energy Regulatory Commission approved PRC-002-2 in September, 2015. The initial due date for system studies necessary to identify locations for the collection of disturbance related data under Requirement R1 is January 1, 2017.

0ec0f37f-chess
Insights

Substation Hardening: Don’t Be a Pawn to Security

October 28, 2021

Protecting our critical energy infrastructure from physical security threats is certainly not a game, but the process can take some important lessons from the game of chess.

New-Potential-Compliance-Standards-Identified-at-FERC-Technical-Conference-on-Reliability-1
Regulatory Updates

New Potential Compliance Standards Identified at FERC Technical Conference on Reliability

October 18, 2021

With a focus on the reliability impact of extreme weather and the shortcomings of current system planning approaches, both NERC and FERC conference participants opened the door to potential forthcoming compliance standard enhancements or changes.

snowy-powerline-in-winter
Regulatory Updates

FERC Approves Modifications to NERC’s Cold Weather-Related Standards

September 7, 2021

The Federal Energy Regulatory Commission has approved changes to three mandatory NERC Reliability Standards that aim to better prepare the North American power system to withstand extreme cold weather events.

9325eb27-substation-and-power-transmission-lines-1226921578
Regulatory Updates

NERC’s FAC-008 Guidance on Facility Ratings

May 24, 2021

FAC-008 is one of the most data-intensive standards in the NERC regulatory framework. Compliance has been difficult for many utilities. Recently, FERC made public it’s intent to address serious allegations of facility ratings violations, including a lack of rigor by one utility.

NERC-and-FERC-Take-Action-on-Facilities-Ratings
Regulatory Updates

NERC and FERC Take Action on Facilities Ratings

December 4, 2020

There has been significant work across the electric industry to improve facility ratings related processes, programs, frameworks, internal controls and best practices. Yet this continues to be a challenging area for utilities, particularly from an asset management and regulatory compliance perspective.

FERC-Issues-Annual-Report-on-Critical-Infrastructure-Protection-CIP-Reliability-Audits
Regulatory Updates

FERC Issues Annual Report on Critical Infrastructure Protection (CIP) Reliability Audits

November 17, 2020

In its 2020 Report on CIP Reliability Audits, the Federal Energy Regulatory Commission found that most of the cybersecurity protection processes and procedures adopted by utilities met the mandatory CIP requirements for protecting the Bulk Electric System. However, there are areas for improvement.

GettyImages-1472176132
Videos

INGAA Foundation Interview with Lauren O’Donnell

June 22, 2020

TRC’s own Lauren O’Donnell is currently the elected Chair of the INGAA Foundation. The Foundation’s primary activity is to sponsor research aimed at promoting natural gas use and safe, efficient pipeline construction and operation.

GettyImages-1582693186
News

INGAA Foundation Elects TRC’s Lauren O’Donnell as Chair

February 5, 2020

The board of directors of the INGAA Foundation elected Lauren O’Donnell as its chair for a one-year term.

NERC-Addresses-Single-Points-of-Failure-in-Protection-Systems-Among-Other-FERC-Concerns-1
Regulatory Updates

NERC Addresses Single Points of Failure in Protection Systems Among Other FERC Concerns

October 25, 2018

Under the proposed NERC TPL-001-5 standard, utilities with transmission planning responsibilities will be required to identify reliability risks related to protection system failures and take mandatory corrective action. It will be critical to have an in depth understanding of your company’s protection system settings and to perform the system studies necessary to identify where single points of failure may result in cascading tripping of transmission elements. Mitigation actions may require the installation of redundant protection systems which in turn may lead to significant substation redesign. Transmission planners and planning coordinators should begin preparing for any necessary protection system changes. TPL-001-5 Overview NERC began studying the reliability risk associated with single points of protection system failure starting in 2011 as directed in FERC Order 754. TPL-001-5 will bring significant changes for Planning Coordinators and Transmission Planners as they perform annual Planning Assessments. There is a new obligation to adequately account for the reliability risk posed by single point of protection system failure via risk-based Assessment. This reliability risk management approach will be implemented through modifications to the Category P5 Planning Event which is described in Table 1 of the TPL-001-5 standard. NERC believes that the most cost-effective Corrective Action Plans to address unacceptable system performance for the P5 Planning Events will likely be to add protection system component redundancy in certain cases. Protection system redundancy changes to address Category P5 Event system performance violations should reduce or even negate non-redundant component related risks that need to be considered in assessing transmission system performance. These risks will be identified during simulations of certain extreme events as required under the standard. TPL-001-5 also addresses reliability risks related to outage management as directed in FERC Order 786. The standard requires utility planners to consider maintenance outages of significant facilities as well as outages for critical long lead time to repair or replace equipment. Specifically, it addresses stability analysis to assess system performance for conditions expected during possible unavailability of long lead time equipment. Although it is not a NERC defined term, it is believed that a “spare equipment strategy will be sufficient to allow flexibility for utilities to conduct both steady state and stability analysis required by TPL-001-5. For example, a utility’s spare equipment strategy may include the warehousing of a replacement transformer to be installed given the failure of an in service transformer. When a utility’s spare equipment strategy may prevent major transmission equipment from being out-of-service for one year or more, this possible equipment unavailability need not be assessed as part of TPL-001-5.

d00b3517-robert_moses_niagara_power_plant_01_170320_131114
Insights

Seeking a new FERC license for your hydroelectric project? Here are the 2 key questions to ask.

March 22, 2017

Across the U.S., Department of Energy data show that some 2,200 hydroelectric projects produce more than 6 percent of all the electricity we consume, which amounts to more than one-third of all power generated in 2015 from renewable sources. Operations of many existing hydroelectric projects are governed by 30- to 50-year licenses issued by the…

b57bad8c-trc-dylan-achey
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 mailto:dachey@trccompanies.com.

fb5c8db4-t-farrar-headshot
Tim Farrar

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 tfarrar@trccompanies.com