Require generator owners, transmission owners, and distribution providers to share validated modeling, planning, operations, and disturbance monitoring data for IBRs with system operators and planners.
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. FERC’s actions call for the North American Electric Reliability Corporation (NERC) to develop a plan to register IBR technology-based equipment.
Additionally, FERC proposes to accelerate the development of standards-related to IBR facilities data sharing, modeling, studies and performance requirements. TRC clients are advised to follow these developments closely, as FERC’s actions will substantially increase registration and compliance requirements.
Background
IBR technology projects are not directly synchronized to the electric power system and must be programmed to “ride through” disturbances to avoid tripping offline during routine system disturbances. The current power system was designed with the generation fleet consisting predominately of synchronous generation that through inertia would ride through disturbance events such as tripping and reclosing of transmission lines. However, based on numerous system disturbances reported by NERC linked to IBR technology, FERC has become concerned that the existing Reliability Standards inadequately address the aggregate impact risk to reliability created by IBR deployment. For example on December 9, 2022 NERC and Texas Regional Entity issued their Events Analysis Report on the second Odessa, Texas area disturbance which outlines in great detail the failure modes and reliability risks resulting from failure to coordinate Inverter based resources control systems. The report outlines numerous immediate actions required to assure the preservation of reliability through the industry transition to renewable resources.
To address these concerns, FERC recently took the actions summarized below.
Related Services
NERC Registration of Inverter-Based Resources
In its Registration of Inverter-Based Resources Order, FERC addresses the aggregate reliability impact of the subset of renewable projects currently exempt from NERC’s Reliability Standards. Many IBRs are exempt because they do not meet the “bright line” test requiring them to register with NERC (i.e., if the generating facility’s aggregate capacity exceeds 75 MVA sharing a point of interconnection to the transmission system at a voltage at or above 100 kV). NERC has found in several instances that the aggregate impact of such IBRs tripping offline can make recovery from the disturbance more difficult.
To address this demonstrated gap in the reliability regulations, FERC directed NERC to submit a “work plan” to identify and register unregistered IBRs that, “in the aggregate, have a material impact on the reliable operation of the Bulk-Power System.” NERC must submit its work plan by February 15, 2023. The order provides that all such IBR owners and operators will be identified and registered within three years of FERC approving NERC’s work plan.
Many IBRs connecting to the Bulk-Power System do not individually meet the current Bulk Electric System (BES) definition, and thus, are not registered with NERC. This means that those IBRs below the BES threshold currently are not required to comply with mandatory Reliability Standards or respond to NERC alerts. TRC clients are advised to stay informed regarding NERC’s plans to bring these IBR projects into the regulatory framework.
Proposal to Require Reliability Standards to Address Inverter-Based Resources
The industry is preparing comments on FERC’s proposal to require NERC to create new IBR related Reliability Standards. FERC also proposes that once FERC issues a final rule, NERC must submit the new or modified Reliability Standards for FERC approval.
In its proposal to address Reliability Standards for IBRs, FERC directed NERC to submit new or modified standards to tackle four issues:
Ensure that IBR models are comprehensive, validated, and timely, so that they can adequately predict the behavior of all IBRs and their impacts on reliability.
Ensure that validated IBR models are included in planning and operational studies to assess IBRs’ reliability impacts, both individually and taken together.
Ensure that registered IBRs provide frequency and voltage support during frequency and voltage excursions adequate to contribute toward the overall system needs
Resources
FERC Order on Registration of Inverter-Based Resources
FERC Order on Registration of Inverter-Based Resources Published November 17, 2022
FERC NOPR on Reliability Standards to Address Inverter-Based Resources
Published November 17, 2022
TRC Services – NERC Compliance
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NERC Compliance News From TRC
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Regulatory Updates
NERC Approves IBR Related Standards Impacting Renewable Generation
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The standards will soon be filed and pending final approval from FERC. NERC also voted to improve the definition of ride through to include the “ability to withstand voltage or frequency disturbances inside defined limits and to continue operating as specified.”
Regulatory Updates
NERC Proposes Changes to Registration Criteria for Inverter Based Resources (IBRs)
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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.
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Regulatory Updates
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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.
Regulatory Updates
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June 21, 2023
FERC issued an order approving NERC’s compliance filings.
Regulatory Updates
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Regulatory Updates
New FERC Orders Will Change Regulatory Process for Inverter Based Resources
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Regulatory Updates
NERC Releases Inverter-Based Resource Strategy Plan
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NERC Seeks to Improve GADS Reliability Performance Reporting
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April 22, 2021
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January 20, 2021
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February 20, 2019
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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.
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September 30, 2024
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September 19, 2024
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August 30, 2024
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August 8, 2024
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June 27, 2024
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May 23, 2024
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May 6, 2024
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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.
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.
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
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
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.
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.
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.
Regulatory Updates
NERC Releases Inverter Based Resources Webinar Series
October 19, 2023
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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
Regulatory Updates
CFATS Program Expires but Reauthorization Anticipated this Fall
September 6, 2023
Regulated organizations should continue to follow DHS cybersecurity requirements.
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
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.
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.
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.
Regulatory Updates
NERC Files Report on Effectiveness on CIP-014 Physical Security Standard
May 25, 2023
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Regulatory Updates
FERC Issues Order on Cold Weather Reliability Standards
April 27, 2023
FERC has approved two NERC proposed cold weather-related reliability standards.
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.
Regulatory Updates
Insights from the Odessa II Power System Disturbance
February 22, 2023
NERC and TRE release the Odessa II Power System Disturbance Report
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.
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.
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.
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.
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:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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…
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.
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.
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.
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.
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.
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.
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.
