Call it the grid version of answering a question with more questions.
The Federal Energy Regulatory Commission (FERC) earlier this year asked regional transmission organizations and independent system operators (RTO/ISO) to report their observations and concerns about many challenges facing the North American power grid. FERC preceded this request by rejecting the U.S. Department of Energy’s (DOE’s) proposed rule to financial incentivize power generation with on-site storage–i.e. coal and nuclear–but starting the conversation on the primary dangers facing the bulk energy system (BES).
The RTO/ISOs responded beginning last week, and their answers are myriad and unique to their own needs. In fact, they have more questions than answers for FERC.
ISO-New England sent an in-depth 180-page-plus warning about the weather and fuel supply issues particular to that region. New England doesn’t produce a lot of fuel on its own and is increasingly dependent on natural gas supply from pipelines which can prove inadequate to the capacity needs in times of weather duress such as the recent nor’easters. ISO-NE is worried about the future impact of coal and nuclear plant retirements.
PJM Interconnection, meanwhile, has plenty of natural gas supply in the belly of the Marcellus Shale. So, instead, it reflected FERC’s questions right back at the regulators, challenging current definitions of grid resiliency and questioning whether federal agencies are doing enough to inform the bulk electric system about potential cyber dangers out there.
And please don’t hold the grid operators to impossible-to-predict standards, PJM’s report read.
“Requiring the BES to “˜withstand’ a disruptive event is concerning because RTOs should not be required to plan and design the BES to be invulnerable to a broad spectrum of hazards and corresponding impacts–regardless of the cost to do so or the incremental value that may be achieved in making such improvements for a contingency that will rarely, if ever, occur,” the PJM filing added.
High-impact, low-frequency events are harder to analyze in advance, because, well, who knows when, where and how often they will happen, the RTO pointed out. Grid planners are identify certain threats and vulnerabilities, PJM noted, but FERC also could finalize a clarified working definition of grid resilience that helps RTO/ISOs to better understand how to establish “just and reasonable” rates and other preparations for grid hardening.
FERC and other federal agencies could open the communication process on cyber security threats coming from nation-state actors. From the Black Energy attacks onward, power grid operators know their systems, both online and physical, are attractive targets to those who would disrupt a way of life.
PJR asked for a filing process “that would allow an RTO to receive verification as to the reasonableness of its assessments of vulnerabilities and threats, including commission utilization of information that may be available to (FERC) but not available to the RTO because of natural security issues,” the report reads. “Simply put, in coordination with other federal agencies such as the United States Department of Defense, DOE, United States Department Homeland Security, as well as NERC (North American Electric Reliability Corp.), the commission needs to provide intelligence and metrics to apply to resilience, vulnerability and threat analyses that can then guide and anchor subsequent RTO planning, market design and/or operations directives.”