FERC, in a final rule issued on Nov. 19, approved revisions to the Transmission Operations and Interconnection Reliability Operations and Coordination Reliability Standards developed by NERC, and directed NERC to make three modifications to the standards within 18 months of the effective date of the final rule.
As TransmissionHub reported, FERC on June 18 issued a notice of proposed rulemaking that would approve NERC‘s proposal to replace the existing suite of TOP reliability standards with three TOP reliability standards.
According to the NOPR, NERC’s proposed TOP reliability standards generally address real-time operations and planning for next-day operations, and apply primarily to the responsibilities and authorities of transmission operators.
FERC said that the proposed revisions are designed to ensure that transmission operators plan and operate within all system operating limits.
In the NOPR, FERC said it believes that the proposed standards improve on the currently effective standards by providing a more precise set of reliability standards addressing operating responsibilities and improving the delineation of responsibilities between applicable entities.
In its Nov. 19 final rule, FERC said that under section 215(d) of the Federal Power Act (FPA), it adopts the “NOPR proposal and approve NERC’s revisions to the TOP and IRO reliability standards, including the associated definitions, violation risk factors, violation severity levels, and implementation plans, as just, reasonable, not unduly discriminatory or preferential and in the public interest.”
FERC said that all of the commenters that address the matter support, or do not oppose, approval of the revised suite of TOP and IRO reliability standards.
“We determine that NERC’s approach of consolidating requirements and removing redundancies generally has merit and is consistent with commission policy promoting increased efficiencies in reliability standards and reducing requirements that are either redundant with other currently-effective requirements or have little reliability benefit,” FERC said.
In a Nov. 19 statement, NERC said it “appreciates FERC’s continued recognition of the reliability benefit of these standards.”
In its Nov. 19 final rule, FERC noted that it approved the initial TOP and IRO reliability standards in Order No. 693. NERC in April 2013 submitted for FERC approval three revised TOP reliability standards to replace the eight currently effective TOP standards.
Also in April 2013, NERC submitted for FERC approval four revised IRO reliability standards to replace six currently effective IRO reliability standards. FERC added that in November 2013, it issued the remand NOPR in which it expressed concern that NERC had “removed critical reliability aspects that are included in the currently-effective standards without adequately addressing these aspects in the proposed standards.”
FERC also said it expressed concern that the proposed TOP reliability standards did not require transmission operators to plan and operate within all SOLs, which is a requirement in the currently effective standards. FERC also expressed concern that the proposed IRO reliability standards did not require outage coordination.
NERC last March filed a petition with FERC for approval of the proposed TOP and IRO reliability standards, which consolidate many of the currently effective TOP and IRO reliability standards and replace the TOP and IRO reliability standards that were the subject of the remand NOPR.
FERC added that according to NERC, the proposed reliability standards include improvements over the currently effective TOP and IRO reliability standards in operating within SOLs and interconnection reliability operating limits (IROLs); outage coordination; situational awareness; improved clarity and content in foundational definitions; and requirements for operational reliability data.
NERC said that the proposed reliability standards provide a comprehensive framework for reliable operations, with important improvements to ensure the bulk electric system is operated within pre-established limits while enhancing situational awareness and strengthening operations planning, FERC said.
Also, NERC said that the proposed reliability standards establish or revise requirements for operations planning, system monitoring, real-time actions, coordination between applicable entities, and operational reliability data.
FERC further noted that NERC contended that the proposed reliability standards help to ensure that reliability coordinators and transmission operators work together, and with other functional entities, to operate the bulk electric system within SOLs and IROLs.
Among other things, FERC noted that in the NOPR, it proposed to find that the proposed reliability standards adequately address the 2011 Southwest Outage Blackout Report recommendation regarding monitoring sub-100 kV facilities, primarily because of the responsibility of the reliability coordinator under proposed reliability standard IRO-002-4, Requirement R3 to monitor non-BES facilities to the extent necessary.
FERC said it noted, however, that “the transmission operator may have a more granular perspective than the reliability coordinator of its necessary non-bulk electric system facilities to monitor,” and it is not clear whether or how the transmission operator would provide information to the reliability coordinator regarding which non-BES facilities should be monitored.
FERC said it sought comment on how NERC will ensure that the reliability coordinator will receive such information.
FERC also said that including such non-BES facilities in the definition of bulk electric system through the NERC Rules of Procedure exception process could be an option to address any potential gaps for monitoring facilities but noted that there may be potential efficiencies gained by using a more expedited method to include non-bulk electric system facilities that requires monitoring. FERC added that it sought comment on whether the BES exception process should be used exclusively in all cases.
FERC said it agrees with NERC, TAPS and EEI that the bulk electric system exception process can be a mechanism for identifying non- bulk electric system facilities to be included in the BES definition. However, FERC said it is concerned that in some instances the absence of real-time monitoring of non-BES facilities by the transmission operator within and outside its TOP area as necessary for determining SOL exceedances in proposed TOP-001-3, Requirement R10 creates a reliability gap.
Under section 215(d)(5) of the FPA, FERC directed NERC to revise reliability standard TOP-001-3, Requirement R10 to require real-time monitoring of non-BES facilities.
“To be clear, we are not directing that all current non-bulk electric system facilities that a transmission operator considers worthy of monitoring also be included in the bulk electric system,” FERC said. “We believe that such monitoring may result in some facilities becoming part of the bulk electric system through the exception process; however it is conceivable that others may remain non- bulk electric system because they are occasional system operating limit exceedance performers that may not qualify as a candidate for inclusion in the BES definition.”
Regarding data exchange capabilities, FERC noted that it approved reliability standards COM-001-2 (communications) and COM-002-4 (operating personnel communications protocols) in Order No. 808, and noted that in the NOPR underlying that order (COM NOPR), it raised concerns as to whether reliability standard COM-001-2 addresses facilities that directly exchange or transfer data. NERC clarified that reliability standard COM-001-2 did not need to include requirements regarding data exchange capability because such capability is covered under other existing and proposed standards.
FERC added that in the NOPR, it stated that facilities for data exchange capabilities appear to be addressed in NERC’s TOP/IRO petition. However, FERC said it sought additional explanation from NERC regarding how it addresses data exchange capabilities in the TOP and IRO Standards in such areas as redundancy and diverse routing.
FERC said that it agrees with NERC and other commenters that there is a reliability need for the reliability coordinator, transmission operator and balancing authority to have data exchange capabilities that are redundant and diversely routed.
However, FERC said it is concerned that the TOP and IRO standards do not clearly address redundancy and diverse routing so that registered entities will unambiguously recognize that they have an obligation to address redundancy and diverse routing as part of their TOP and IRO compliance obligations.
FERC said that under section 215(d)(5) of the FPA, it directs NERC to modify reliability standards TOP-001- 3, Requirements R19 and R20 to include the requirement that the data exchange capabilities of the transmission operators and balancing authorities require redundancy and diverse routing. FERC further noted that it directs NERC to clarify that “redundant infrastructure” for system monitoring in reliability standards IRO-002-4, Requirement R4 is equivalent to redundant and diversely routed data exchange capabilities.