agenda standards committee conference call

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RELIABILITY | RESILIENCE | SECURITY Agenda Standards Committee Conference Call May 19, 2021 | 1:00―3:00 p.m. Eastern Dial-in: 1-415-655-0002 | Access Code: 180 955 2703 | Meeting Password: 051921 Click here for: WebEx Access Introduction and Chair’s Remarks NERC Antitrust Compliance Guidelines and Public Announcement* NERC Participant Conduct Policy Agenda Items 1. Review May 19 Agenda - Approve - Amy Casuscelli (1 minute) 2. Consent Agenda - Approve - Amy Casuscelli (5 minutes) a. March 17, 2021 Standards Committee Meeting Minutes* - Approve b. April 21, 2021 Standards Committee Meeting Minutes* - Approve 3. Projects Under Development - Review a. Project Tracking Spreadsheet - Charles Yeung (5 minutes) b. Projected Posting Schedule - Howard Gugel (5 minutes) 4. Standard Authorization Request for PRC-002-2 - Accept/Authorize/Authorize - Latrice Harkness (10 minutes) a. Standard Authorization Request for PRC-002* 5. Project 2020-05 Modifications to FAC-001-3 and FAC-002-2 - Accept/Authorize/Appoint - Latrice Harkness (10 minutes) a. Standard Authorization Request for Modifications to FAC-001-3 and FAC-002-2* 6. Project 2021-03 CIP-002 Transmission Owner Control Centers Standard Drafting Team Recommendation* - Appoint - Latrice Harkness (10 minutes) 7. Legal Update and Upcoming Standards Filings* - Review - Marisa Hecht (5 minutes) 8. Informational Items - Enclosed a. Standards Committee Expectations* b. 2021 SC Meeting Schedule c. 2021 Standards Committee Roster

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Page 1: Agenda Standards Committee Conference Call

RELIABILITY | RESILIENCE | SECURITY

Agenda Standards Committee Conference Call May 19, 2021 | 1:00―3:00 p.m. Eastern Dial-in: 1-415-655-0002 | Access Code: 180 955 2703 | Meeting Password: 051921 Click here for: WebEx Access Introduction and Chair’s Remarks NERC Antitrust Compliance Guidelines and Public Announcement* NERC Participant Conduct Policy Agenda Items

1. Review May 19 Agenda - Approve - Amy Casuscelli (1 minute)

2. Consent Agenda - Approve - Amy Casuscelli (5 minutes)

a. March 17, 2021 Standards Committee Meeting Minutes* - Approve

b. April 21, 2021 Standards Committee Meeting Minutes* - Approve

3. Projects Under Development - Review

a. Project Tracking Spreadsheet - Charles Yeung (5 minutes)

b. Projected Posting Schedule - Howard Gugel (5 minutes)

4. Standard Authorization Request for PRC-002-2 - Accept/Authorize/Authorize - Latrice Harkness (10 minutes)

a. Standard Authorization Request for PRC-002*

5. Project 2020-05 Modifications to FAC-001-3 and FAC-002-2 - Accept/Authorize/Appoint - Latrice Harkness (10 minutes)

a. Standard Authorization Request for Modifications to FAC-001-3 and FAC-002-2*

6. Project 2021-03 CIP-002 Transmission Owner Control Centers Standard Drafting Team Recommendation* - Appoint - Latrice Harkness (10 minutes)

7. Legal Update and Upcoming Standards Filings* - Review - Marisa Hecht (5 minutes)

8. Informational Items - Enclosed

a. Standards Committee Expectations*

b. 2021 SC Meeting Schedule

c. 2021 Standards Committee Roster

Page 2: Agenda Standards Committee Conference Call

Agenda – Standards Committee Meeting – May 19, 2021 2

d. Highlights of Parliamentary Procedure*

9. Adjournment

*Background materials included.

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RELIABILITY | RESILIENCE | SECURITY

Public Meeting Notice REMINDER FOR USE AT BEGINNING OF MEETINGS AND CONFERENCE CALLS THAT HAVE BEEN PUBLICLY NOTICED AND ARE OPEN TO THE PUBLIC Conference call/webinar version: As a reminder to all participants, this webinar is public. The registration information was posted on the NERC website and widely distributed. Speakers on the call should keep in mind that the listening audience may include members of the press and representatives of various governmental authorities, in addition to the expected participation by industry stakeholders. Face-to-face meeting version: As a reminder to all participants, this meeting is public. Notice of the meeting was posted on the NERC website and widely distributed. Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities, in addition to the expected participation by industry stakeholders. For face-to-face meeting, with dial-in capability: As a reminder to all participants, this meeting is public. Notice of the meeting was posted on the NERC website and widely distributed. The notice included the number for dial-in participation. Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities, in addition to the expected participation by industry stakeholders.

Page 4: Agenda Standards Committee Conference Call

RELIABILITY | RESILIENCE | SECURITY

Minutes Standards Committee Conference Call March 17, 2021 | 1:00―3:00 p.m. Eastern

A. Casuscelli, chair, called to order the meeting of the Standards Committee (SC or the Committee) onFebruary 17, at 1:00 p.m. Eastern. A. Oswald, secretary, called roll and determined the meeting had aquorum. The SC member attendance and proxy sheets are attached as Attachment 1.

NERC Antitrust Compliance Guidelines and Public Announcement The Committee secretary called attention to the NERC Antitrust Compliance Guidelines and the public meeting notice and directed questions to NERC’s General Counsel, Sonia C. Mendonça.

Introduction and Chair’s Remarks A. Casuscelli welcomed the Committee and guests.

Review March 17, 2021 Agenda (agenda item 1) The Committee approved the March 17, 2021 meeting agenda.

Consent Agenda (agenda item 2) The Committee approved the February 17, 2021 SC meeting minutes by unanimous consent. A. Casuscelli informed the committee that the Standards Committee Process Subcommittee leadership has changed. A. Casuscelli appointed Kent Feliks to the position of chair and Matt Harward for the position of vice chair for a two-year term, ending December 2022.

Projects Under Development (agenda item 3) C. Yeung reviewed the Project Tracking Spreadsheet. H. Gugel reviewed the three-month outlook and theProjected Posting Schedule.

Project 2020-06 Verification of Models and Data for Generators SAR Drafting Team (agenda item 4)

L. Harkness provided an overview of Standard Authorization Request (SAR) drafting team (DT)recommendation.

J. Howell suggested swapping the chair and vice chair candidates to have more generator experience asthe chair of the SAR DT. S. Ruekert stated the individuals in leadership rolls do not always need thetechnical expertise, they need to be able to run meetings effectively. He stated he would like to hear theopinion of NERC staff before amending the current motion. NERC staff reported that the individualschosen for chair and vice chair were picked for their ability to lead the team effectively and that thecombination of the whole team had good generation representation. M. Puscas stated that candidatenumber 1 would be very familiar with the generator world and should remain as chair.

Agenda Item 2a Standards Committee

May 19, 2021

Page 5: Agenda Standards Committee Conference Call

Minutes – Standards Committee Meeting – March 17, 2021 2

S. Ruekert moved to appoint chair, vice chair and members to the Project 2020-06 Standard AuthorizationSAR DT.

The committee approved the motion with no objections or abstentions.

Project 2016-02 CIP-002 Field Test (agenda item 5)

L. Harkness provided an overview of the CIP-002 field test. M. Hostler asked if a new SAR is needed totake this action and inquired as to why this update was not given to the SC during the January meetingbefore CIP-002 was pulled at the February Board Meeting. L. Harkness responded that a portion of the2016-02 SAR will be assigned to the new team, the current 2016-02 team does not have the bandwidth tocomplete this project on top of their current workload. Kal (FERC) inquired how the test will work. L.Harkness stated that the elements of the field test have yet to be determined, that is what the field testteam will be tasked with, and the deliverable will be a recommendation from the team. N. Shockey statedthe justification for the field test is not complete and expressed concern that the Standards ProcessManual (SPM) has not been followed. He requested NERC Staff draft a new SAR with explicit scope statedand objective of the field test. H. Gugel reminded the committee that this action is asking for the ability tosolicit for a team to scope the field test only. Not authorize a test at this time. The team would be go tothe RSTC for technical input and support before returning to the SC to ask for authorization to conductthe field test. M. Hostler asked why FERC held CIP-002 for 6 months and what concerns they hadregarding CIP-002 to cause it to be pulled by the board at the February meeting. H. Gugel stated that hecannot speak on behalf of FERC but it is not unusual for FERC to do analysis before approving standardswhich take significant time, in addition, the NERC board can choose to make moves on what they feel isnecessary at the time. L. Oelker stated he would like a new SAR to show what portions of the 2016-02 SARwould be assigned to the new team. H. Gugel stated it would be the section focusing on low impactcontrol centers. L. Oelker stated the action as written sounds like it is authorizing a field test and H. Gugelresponded that this would not be authorizing a field test, just a team to determine what the test shouldbe. B. Lawson agreed with L. Oelker that the language in the one pager is confusing on this point. The onepager was brought up to modify to make the language clearer and remove the words “to conduct” toavoid the presumption that a field test is occurring. H. Gugel reminded the committee that the action isonly to solicit a team at this time.

N. Shockey moved to authorize soliciting nominations for a SDT to determine appropriate criteria fordefining low impact Transmission Owner Control Centers (TOCC) in the CIP-002 Standard and assign thatportion of the Project 2016-02 SAR that related to TOCC to the SDT.

The committee approved the motion with no objections. M. Hostler abstained.

Standing Committee Coordination Group Scope Document (agenda item 6)

Amy Casuscelli provided an overview of the Standing Committee Coordination Group (SCCG) scope document. L. Oelker inquired if the SCCG was a standalone committee. A. Casuscelli stated the SCCG is composed of the chair and vice chairs of the committees and is only a coordinating committee. C. Yeung moved to endorse to SCCG document.

The committee approved the motion with no objections. L. Oelker absented.

Page 6: Agenda Standards Committee Conference Call

Minutes – Standards Committee Meeting – March 17, 2021 3

Functional Model Task Force (agenda item 7)

T. Bennett provided an overview of the actions of the Functional Model Task Force. It was asked if thedocumentation would be used to update the Rules of Procedure (ROP) and T. Bennett responded that thescope was the organization and registration criteria. In addition, the Functional Model is currentlyarchived on the NERC website.

Project 2019-06 Cold Weather (agenda item 8)

L. Harkness notified the committee that the NERC Board is considering actions for the Cold WeatherDrafting Team to complete their work by June 2021. If the board passes this action, the Project 2019-06team will be asking the SC to conduct an action without a meeting to shorted future comment periodsfrom 45 days to 25 days to meet the deadline.

Subcommittee Reports (agenda item 9)

C. Yeung provided an update on the Project Management Oversite Subcommittee. Two new membershave been added to the PMOS and are being assigned projects are they arise. A. Casuscelli provided anupdate on behalf of the SCPS leadership. The group is working on the Standard Drafting Team (SDT) scopeand reference manual. A sub team is also working on drafting a roles and responsibilities document. TheStandards Efficiency Review (SER) team is reviewing the standards template and team training modules.Any SC members that have interest in participating in that effort are welcome to join.

Legal Update and Upcoming Standards Filings (agenda item 10)

M. Hecht provided the legal update regarding recent and upcoming filings.

Adjournment

A. Casuscelli thanked committee members and observers and adjourned the meeting at 2:54 p.m.Eastern.

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RELIABILITY | RESILIENCE | SECURITY

Attachment 1 Segment and Terms

Representative Organization Proxy Present (Member or Proxy)

Chair 2020‐21 Amy Casuscelli Sr. Reliability Standards Analyst Xcel Energy

x

Vice Chair 2020‐21

Todd Bennett Managing Director, Reliability Compliance & Audit Services

Associated Electric Cooperative, Inc.

x

Segment 1‐2020‐21 John Babik Director of Electric Compliance JEA

x

Segment 1‐2021‐22 Troy Brumfield Regulatory Compliance Manager

American Transmission Company

x

Segment 2‐2020‐21 Michael Puscas Compliance Manager, Reliability and Operations Compliance

ISO New England, Inc. x

Segment 2‐2021‐22 Charles Yeung Executive Director Interregional Affairs Southwest Power Pool

x

Segment 3‐2020‐21 Kent Feliks Manager NERC Reliability Assurance – Strategic Initiatives

American Electric Power Company, Inc.

Bev Laios

x

Segment 3‐2021‐22 Linn Oelker Manager – Market Compliance LG&E and KU Services Company

x

Segment 4‐2020‐21 Marty Hostler Reliability Compliance Manager

Northern California Power Agency

x

Segment 4‐2021‐22 Barry Lawson* Senior Director, Regulatory Affairs

National Rural Electric Cooperative Association

x

Segment 5‐2020‐21 Neil Shockey Principal Manager Southern California Edison

x

Segment 5‐2021‐22 Jim Howell Markets Compliance Manager Southern Company Generation

x

Segment 6‐2020‐21 Sarah Snow Manager of Reliability Compliance Cooperative Energy

x

Page 8: Agenda Standards Committee Conference Call

2021 Standards Committee Attendance – March 17, 2021 2

Segment and Terms

Representative Organization Proxy Present (Member or Proxy)

Segment 6‐2021‐22 Justin Welty Senior Manager, NERC Reliability Standards

NextEra Energy x

Segment 7‐2020‐21 Vacant N/A

Segment 7‐2021‐22 Venona Greaff* Senior Energy Analyst

Occidental Chemical Corporation

x

Segment 8‐2020‐21 Robert Blohm1 Managing Director Keen Resources Ltd.

x

Segment 8‐2021‐22 Philip Winston Retired (Southern Company)

Independent x

Segment 9‐2020‐21 Ajinkya Rohankar Advanced Engineer, Division of Energy Regulation and Analysis

Public Service Commission of Wisconsin

x

Segment 9‐2021‐22 Kimberly Jones Director NC Utilities Commission

x

Segment 10‐2020‐21 Tony Purgar Manager, Operational Analysis & Awareness

ReliabilityFirst x

Segment 10‐2021‐22 Steven Rueckert Director of Standards WECC

x

1 Serving as Canadian Representative *Denotes SC Executive Committee Member

Page 9: Agenda Standards Committee Conference Call

RELIABILITY | RESILIENCE | SECURITY

Minutes Standards Committee Conference Call April 21, 2021 | 1:00―3:00 p.m. Eastern A. Casuscelli, chair, called to order the meeting of the Standards Committee (SC or the Committee) on April 21, at 1:00 p.m. Eastern. A. Oswald, secretary, called roll and determined the meeting had quorum. The SC member attendance and proxy sheets are attached as Attachment 1. NERC Antitrust Compliance Guidelines and Public Announcement The Committee secretary called attention to the NERC Antitrust Compliance Guidelines and the public meeting notice and directed questions to NERC’s General Counsel, Sonia C. Mendonça. Introduction and Chair’s Remarks A. Casuscelli welcomed the Committee and guests. A. Casuscelli notified the committee that N. Shockey will be retiring and this meeting will be his last as a SC member. The Committee was also notified that the agenda package posted to the public webpage did not include the March SC Meeting Minutes so the consent agenda was not discussed during this call; the March SC Meeting Minutes will be included in the May package. The Committee was reminded that there were two open ballots for standards development projects at the time and that the Committee members should refrain from discussion on these items. In addition, the Committee was reminded of the confidential treatment associated with agenda item 5 and the committee members should refrain from using any identifying information during that discussion. Review April 21, 2021 Agenda (agenda item 1) The Committee approved the April 21, 2021 meeting agenda. Consent Agenda (agenda item 2) This agenda item was removed for this meeting. Projects Under Development (agenda item 3) C. Yeung reviewed the Project Tracking Spreadsheet. H. Gugel reviewed the Projected Posting Schedule. Project 2020-04 Modifications to CIP-012 (agenda item 4) L. Harkness provided an overview of the documents for initial posting. S. Rueckert moved to authorize initial posting of proposed Reliability Standard CIP-012-2 and the associated Implementation Plan for a 45-day formal comment period, with ballot pool formed in the first 30 days, and parallel initial ballots and non-binding polls on the Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs), conducted during the last 10 days of the comment period.

The committee approved the motion with no objections or abstentions.

Project 2019-06 Cold Weather (agenda item 5)

Agenda Item 2b Standards Committee

May 19, 2021

Page 10: Agenda Standards Committee Conference Call

Minutes – Standards Committee Meeting – April 21, 2021 2

L. Harkness provided an overview of the confidential nominee for addition to the Cold Weather drafting team. N. Shockey inquired if due to the condensed project timeline if the addition of this team member would add value or disrupt the team. NERC staff responded that this would be a seamless transition. M. Hostler noted that there is only one candidate being proposed and that no nomination period was open for additional candidates. H. Gugel reminded the Committee that the Standard Processes Manual (SPM) does not require the Committee to solicit nominations, and NERC staff can recommend individuals to augment a drafting team. L. Oelker agreed that this could be disruptive to the team and he is inclined to let the team move forward without a replacement. C Yeung stated he would prefer the team member be replaced in case the project goes on longer than anticipated and the additional team member might be necessary. L. Oelker stated that if the project is going to take longer than expected he would like a nomination period to be opened. S. Rueckert moved to appoint a supplemental standard drafting team (SDT) member to the Project 2019-06 Cold Weather SDT, as recommended by NERC staff. H. Gugel stated it is not likely for the project go past the June 2021 Board deadline and NERC believes industry does not need to be burdened with another solicitation period given the recommended candidate has been observing the project so far. K. Feliks stated this recommendation feels out of the ordinary and L. Oelker agreed. H. Gugel reminded the Committee that candidates have been recommended like this in the past and this is not precedent setting. A. Casuscelli reminded the Committee of the motion and a vote was called. The Committee approved the motion. K Feliks, L. Oelker, N. Shockey, J. Howell and J. Welty opposed. V. Greaff absented. Reliability Standards Process Enhancements (agenda item 6)

L. Harkness provided an overview of the team recommendations. M. Hostler moved to endorse the recommendation for the Standards Committee Process Subcommittee in coordination with NERC staff to conduct a comprehensive review of existing standards development processes and propose revisions to engrain the efficiency principles into all aspects of the standards development process.

The Committee approved the motion with no objections.

Legal Update and Upcoming Standards Filings (agenda item 7)

M. Hecht provided the legal update regarding recent and upcoming filings.

Adjournment

A. Casuscelli thanked committee members and observers and adjourned the meeting at 1:37 p.m. Eastern.

Page 11: Agenda Standards Committee Conference Call

RELIABILITY | RESILIENCE | SECURITY

Attachment 1

Segment and Terms

Representative Organization Proxy Present (Member or Proxy)

Chair 2020‐21 Amy Casuscelli Sr. Reliability Standards Analyst Xcel Energy

x

Vice Chair 2020‐21

Todd Bennett Managing Director, Reliability Compliance & Audit Services

Associated Electric Cooperative, Inc.

x

Segment 1‐2020‐21 John Babik Director of Electric Compliance JEA

x

Segment 1‐2021‐22 Troy Brumfield Regulatory Compliance Manager

American Transmission Company

x

Segment 2‐2020‐21 Michael Puscas Compliance Manager, Reliability and Operations Compliance

ISO New England, Inc. x

Segment 2‐2021‐22 Charles Yeung Executive Director Interregional Affairs Southwest Power Pool

x

Segment 3‐2020‐21 Kent Feliks Manager NERC Reliability Assurance – Strategic Initiatives

American Electric Power Company, Inc.

x

Segment 3‐2021‐22 Linn Oelker Manager – Market Compliance LG&E and KU Services Company

x

Segment 4‐2020‐21 Marty Hostler Reliability Compliance Manager

Northern California Power Agency

x

Segment 4‐2021‐22 Vacant N/A

Segment 5‐2020‐21 Neil Shockey Principal Manager Southern California Edison

x

Segment 5‐2021‐22 Jim Howell Markets Compliance Manager Southern Company Generation

x

Segment 6‐2020‐21 Sarah Snow Manager of Reliability Compliance Cooperative Energy

x

Page 12: Agenda Standards Committee Conference Call

2021 Standards Committee Attendance – April 21, 2021 2

Segment and Terms

Representative Organization Proxy Present (Member or Proxy)

Segment 6‐2021‐22 Justin Welty Senior Manager, NERC Reliability Standards

NextEra Energy x

Segment 7‐2020‐21 Vacant N/A

Segment 7‐2021‐22 Venona Greaff* Senior Energy Analyst

Occidental Chemical Corporation

x

Segment 8‐2020‐21 Robert Blohm1 Managing Director Keen Resources Ltd.

Segment 8‐2021‐22 Philip Winston Retired (Southern Company)

Independent x

Segment 9‐2020‐21 Ajinkya Rohankar Advanced Engineer, Division of Energy Regulation and Analysis

Public Service Commission of Wisconsin

x

Segment 9‐2021‐22 Kimberly Jones Director NC Utilities Commission

x

Segment 10‐2020‐21 Tony Purgar Manager, Operational Analysis & Awareness

ReliabilityFirst x

Segment 10‐2021‐22 Steven Rueckert Director of Standards WECC

x

1 Serving as Canadian Representative

*Denotes SC Executive Committee Member

Page 13: Agenda Standards Committee Conference Call

Agenda Item 4 Standards Committee

May 19, 2021

Standards Authorization Request Disturbance Monitoring and Reporting Requirements

Action

• Accept the Standard Authorization Request (SAR) submitted by Glencoe Light and Power to revise Reliability Standard PRC-002-21, Requirements R1, Part 1.2 and R3;

• Authorize posting of the SAR for a 30-day formal comment period2; and

• Authorize for solicitation of SAR Drafting Team (DT) members. Background The purpose of PRC-002-2 is to have adequate data available to facilitate analysis of Bulk Electric System (BES) disturbances. The standard has a methodology which determines locations for capturing Sequence of Events Recording (SER), fault recording (FR) data, and dynamic disturbance recording data on BES elements. Summary The SAR proposes modifying Requirement R1, Part 1.2 to clarify notification of other BES Element owners. Additionally, the SAR proposes to modify Requirement R3 to clarify when the applicable BES Element owner (i.e., Transmission Owner and Generator Owner) must have FR data associated with an applicable transformer or transmission line connected to an identified BES bus. On January 20, 2021, the Standards Committee accepted and authorized for posting a PRC-002-2 SAR that was submitted by the NERC Inverter-based Resource Performance Task Force (IRPTF). The IRPTF PRC-002 SAR proposes to address gaps to ensure adequate data is available and periodically assessed to facilitate the analysis of BES disturbances, including in areas of the Bulk Power System (BPS) that may not be covered by the existing requirements. The IRPTF PRC-002 SAR has not yet been posted for comment. NERC Standards Staff recommends that both the IRPTF PRC-002 SAR and the Glencoe PRC-002 SAR be posted for comment simultaneously, and that NERC solicit nominees to serve on a single SAR drafting team that would consider both SARs as part of the same standard development project.

1 PRC-002-2 — Disturbance Monitoring and Reporting Requirements (https://www.nerc.com/_layouts/15/PrintStandard.aspx?standardnumber=PRC-002-2&title=Disturbance%20Monitoring%20and%20Reporting%20Requirements&Jurisdiction=United%20States) 2 The Standards Committee authorized the solicitation of a PRC-002-2 SAR DT on January 20, 2021. That team will be sufficient to address the proposed issues in this SAR.

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RELIABILITY | RESILIENCE | SECURITY

Standard Authorization Request (SAR)

The North American Electric Reliability Corporation (NERC) welcomes suggestions to improve the reliability of the bulk power system through improved Reliability Standards.

Requested information SAR Title: PRC-002-2 Disturbance Monitoring and Reporting Requirements

Date Submitted: April 8, 2021

SAR Requester

Name: Terry Volkmann

Organization: Glencoe Light and Power NCR11444

Telephone: 612-419-0672 Email: [email protected]

SAR Type (Check as many as apply)

New Standard Revision to Existing Standard Add, Modify or Retire a Glossary Term Withdraw/retire an Existing Standard

Imminent Action/ Confidential Issue (SPM Section 10)

Variance development or revision Other (Please specify)

Justification for this proposed standard development project (Check all that apply to help NERC prioritize development)

Regulatory Initiation Emerging Risk (Reliability Issues Steering

Committee) Identified Reliability Standard Development Plan

NERC Standing Committee Identified Enhanced Periodic Review Initiated Industry Stakeholder Identified

Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?):

The purpose of PRC-002-21 is to have adequate sequence of events recording (SER) and fault recording (FR) data available to facilitate analysis of Bulk Electric System2 (BES) disturbances.

1 NERC Reliability Standard PRC-002-2 Disturbance Monitoring and Reporting Requirements (https://www.nerc.com/_layouts/15/PrintStandard.aspx?standardnumber=PRC-002-2&title=Disturbance%20Monitoring%20and%20Reporting%20Requirements&Jurisdiction=United%20States) 2 See Glossary of Terms Used in NERC Reliability Standards (https://www.nerc.com/pa/Stand/Glossary%20of%20Terms/Glossary_of_ Terms.pdf)

Complete and submit this form, with attachment(s) to the NERC Help Desk. Upon entering the Captcha, please type in your contact information, and attach the SAR to your ticket. Once submitted, you will receive a confirmation number which you can use to track your request.

Agenda Item 4a Standards Committee

May 19, 2021

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Standard Authorization Request (SAR) 2

Requested information Requirement R1, Part 1.2 infers that the notified BES Element owner is required to have FR data without regard to the identified BES bus owner having a connected BES Element for which FR data would be required for an applicable transformer or transmission line. By virtue of this notification, the transformer or transmission line BES Element owner is burdened with an obligation to have FR data and implicitly obligates these transformer or transmission line BES Element owners to either:

1. work with other BES Element (i.e., circuit breaker) owners to provide the data and data recording specification for which the transformer or transmission line owners must rely on for compliance, or

2. the transformer or transmission line BES Element owner must install its own equipment that is duplicative to the identified BES Bus recording equipment.

Below is Requirement R1 for reference:

R1. Each Transmission Owner shall: [Violation Risk Factor: Lower ] [Time Horizon: Long-term Planning]

1.1. Identify BES buses for which sequence of events recording (SER) and fault recording (FR) data is required by using the methodology in PRC-002-2, Attachment 1. 1.2. Notify other owners of BES Elements connected to those BES buses, if any, within 90-calendar days of completion of Part 1.1, that those BES Elements require SER data and/or FR data. 1.3. Re-evaluate all BES buses at least once every five calendar years in accordance with Part 1.1 and notify other owners, if any, in accordance with Part 1.2, and implement the re-evaluated list of BES buses as per the Implementation Plan.

Notifications for FR data are being sent to BES Element owners that extend well beyond the BES bus boundary described in PRC-002-2 Attachment 1 as “a single BES bus includes physical buses with breakers connected at the same voltage level within the same physical location sharing a common ground grid.” Notifying BES Element owners beyond this boundary unnecessarily obligates the BES Element (i.e., transformer or transmission line) owner to Requirement R3, including joint owners.

Purpose or Goal (How does this proposed project provide the reliability-related benefit described above?):

The goal of the proposed project is to clarify the necessary notifications in Requirement R1, Part 1.2 relative to FR data, and clearly identify the BES Element owners that need to have FR data for transformers and transmission lines with the associated identified bus.

Project Scope (Define the parameters of the proposed project):

The scope should include modifying Requirement R1, Part 1.2 to clarify notifications, which may include but is not limited to separating the SER data and/or FR data regarding notification. Additionally, Requirement R3 should be modified so that it is abundantly clear to the applicable Transmission Owner

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Standard Authorization Request (SAR) 3

Requested information and Generator Owner when their BES Element must have FR data for an applicable transformer or transmission line.

Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to execute the project. If you propose a new or substantially revised Reliability Standard or definition, provide: (1) a technical justification3 which includes a discussion of the reliability-related benefits of developing a new or revised Reliability Standard or definition, and (2) a technical foundation document (e.g., research paper) to guide development of the Standard or definition):

The Transmission Owner (TO) applying the method in Attachment 1 who identifies a BES bus is in the ideal position to know which BES Elements (i.e., circuit breakers, transformer and transmission line) are connected to a single BES bus that includes physical buses with breakers connected at the same voltage level within the same physical location sharing a common ground grid. Additionally, the identified BES bus owner should know who owns the particular BES Element (i.e., circuit breaker) that need FR data to capture disturbances on generators, transformers and transmission lines as identified in Requirement R3. Owners of BES Elements beyond the physical buses with breakers connected at the same voltage level within the same physical location sharing a common ground grid should not be notified, unless their FR data is needed to complete the identified BES bus FR data. Requirement R1, Part 1.1 uses a method and BES bus definition4 outlined in Attachment 1 to identify BES buses that require SER data and/or FR data. Part 1.2 requires the notification of other BES Element owners connected to the identified BES bus under Requirement R1, Part 1.1. As currently written, a notification is required regardless of whether the identified BES bus owner has FR data for the intended BES Element (i.e., transformer or transmission line) or owns the BES Elements directly connected to the identified BES bus. Requirement R1, Part 1.2 should be modified such that only the directly connected BES Element owner to the identified BES bus at the same voltage level within the same physical location sharing a common ground grid of the identified BES bus shall have FR data. This will eliminate unnecessary notifications and obligations transformer and transmission line owners to compel other entities to have FR data when there is no authority to do so. In these cases, the other BES Element owner(s) have to rely on FR data from another entity that does not have the obligation under the standard Additionally, clarifying the BES Element for which FR data is required will reduce auditing needs resulting from notifying BES Element owner who should not be responsible to have FR data as well as reducing the cost burden of meeting the reliability need for FR data.

3 The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent information to this form before submittal to NERC. 4 Attachment 1, Step 1: Determine a complete list of BES buses that it owns. For the purposes of this standard, a single BES bus includes physical buses with breakers connected at the same voltage level within the same physical location sharing a common ground grid. These buses may be modeled or represented by a single node in fault studies. For example, ring bus or breaker-and-a-half bus configurations are considered to be a single bus.

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Standard Authorization Request (SAR) 4

Requested information

Identified Bus

Straight Bus

The above figure of a straight bus is the simplest BES bus configuration contained within a common ground grid. Only the BES circuit breakers are connected to the identified BES bus. In this case it is clear concerning SER data in Requirement R2 because the circuit breaker is “directly connected.” However, to achieve the need for FR data in Requirement R3, the identified BES bus owner notifies the transformer and transmission line owners under Requirement R, Part 1.2 thus obligating them to have FR data where the circuit breaker is directly connected and the logical BES Element to record FR data. Under the current Requirement R3, the notified GO or TO transformer or line owner will need to contact the circuit breaker owner in hope of obtaining FR Data or install their own equipment. The GO or TO cannot compel the circuit breaker owner to have FR data. Additionally, relying on another entity that has no reliability responsibility for complying with PRC-002-2 places the transformer or transmission line owner at risk if the other entity fails to have the necessary and adequate FR data. The intent of the standard in Requirement R3 is to have FR data associated with all applicable BES Elements at a single BES bus that includes physical buses with breakers connected at the same voltage level within the same physical location sharing a common ground grid of the identified BES bus. Requirement R1, Part 1.2 should only require notification to the BES Element (i.e., circuit breaker) owner directly connected with the identified BES bus. Having the appropriate BES Elements identified at the same voltage level within the same physical location sharing a common ground grid that require SER and/or FR data will help facilitate obtaining data by only having to seek the data from those entities directly connected to the identified BES bus. However, the current standard could be interpreted that generation, transformer and transmission line owners could have FR data that is recorded at a location remote to the identified BES bus. As such, any modifications should consider alternative approaches that will achieve the intent of the standard while reducing associated cost and compliance burdens.

Page 18: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 5

Requested information Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated with the proposed project):

None, the proposed modification above eliminates the unnecessary cost of being required to have FR data due to expanded notifications and the administrative burden to transformer and transmission line owners when these entities generally do not own the BES Elements that actually record the FR data.

Please describe any unique characteristics of the BES facilities that may be impacted by this proposed standard development project (e.g., Dispersed Generation Resources):

None.

To assist the NERC Standards Committee in appointing a drafting team with the appropriate members, please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for definitions):

Transmission Owner and Generation Owner

Do you know of any consensus building activities5 in connection with this SAR? If so, please provide any recommendations or findings resulting from the consensus building activity.

None.

Are there any related standards or SARs that should be assessed for impact as a result of this proposed project? If so, which standard(s) or project number(s)?

A SAR was submitted by the NERC Inverter-based Resource Performance Task Force (IRPTF) to address potential gaps and improvements based on the work and findings of the IRPTF was authorized for posting by the NERC Standards Committee on January 20, 2021.

Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could meet the objectives? If so, please list the alternatives.

Standard Implementation Guide or Practice Guide could provide the necessary clarity; however, these documents cannot change the strict language of the PRC-002-2 Reliability Standard. Nothing is being considered at the present time.

Reliability Principles Does this proposed standard development project support at least one of the following Reliability Principles (Reliability Interface Principles)? Please check all those that apply.

1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions as defined in the NERC Standards.

5 Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Page 19: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 6

Reliability Principles 2. The frequency and voltage of interconnected bulk power systems shall be controlled within

defined limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected bulk power systems

shall be made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected bulk power systems shall be developed, coordinated, maintained and implemented.

5. Facilities for communication, monitoring and control shall be provided, used and maintained for the reliability of interconnected bulk power systems.

6. Personnel responsible for planning and operating interconnected bulk power systems shall be trained, qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected bulk power systems shall be assessed, monitored and maintained on a wide area basis.

8. Bulk power systems shall be protected from malicious physical or cyber attacks.

Market Interface Principles Does the proposed standard development project comply with all of the following Market Interface Principles?

Enter (yes/no)

1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes

2. A reliability standard shall neither mandate nor prohibit any specific market structure. Yes

3. A reliability standard shall not preclude market solutions to achieving compliance with that standard. Yes

4. A reliability standard shall not require the public disclosure of commercially sensitive information. All market participants shall have equal opportunity to access commercially non-sensitive information that is required for compliance with reliability standards.

Yes

Identified Existing or Potential Regional or Interconnection Variances

Region(s)/ Interconnection

Explanation

None

For Use by NERC Only

SAR Status Tracking (Check off as appropriate). Draft SAR reviewed by NERC Staff Draft SAR presented to SC for acceptance DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC SAR assigned a Standards Project by NERC

Page 20: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 7

SAR denied or proposed as Guidance document

Version History

Version Date Owner Change Tracking 1 June 3, 2013 Revised

1 August 29, 2014 Standards Information Staff Updated template

2 January 18, 2017 Standards Information Staff Revised

2 June 28, 2017 Standards Information Staff Updated template

3 February 22, 2019 Standards Information Staff Added instructions to submit via Help Desk

4 February 25, 2020 Standards Information Staff Updated template footer

Page 21: Agenda Standards Committee Conference Call

Agenda Item 5 Standards Committee

May 19, 2021

Project 2020-05 Modifications to FAC-001 and FAC-002 Action

• Accept the revised Project 2020-05 Modifications to FAC-001 and FAC-002 Standard Authorization Request (SAR);

• Authorize drafting revisions to the Reliability Standards identified in the SAR; and

• Appoint the Project 2020-05 Modifications to FAC-001 and FAC-002 SAR Drafting Team (DT) as the Project 2020-05 Standard Drafting Team (SDT).

Background The NERC Inverter-based Resource Performance Task Force (IRPTF) performed a comprehensive review of NERC Reliability Standards to determine if there were any potential gaps or improvements based on the work and findings of the IRPTF. The IRPTF identified several issues as part of this effort and documented its findings and recommendations in a white paper. The “IRPTF Review of NERC Reliability Standards White Paper" was approved by the Operating Committee and the Planning Committee in March 2020. Among the findings noted in the white paper, the IRPTF identified issues with FAC-001-3 and FAC-002-2 that should be addressed. On June 10, 2020 the IRPTF submitted a SAR to revise FAC-001-3 and FAC-002-2 to clarify the use of “materially modified” as it relates to compliance with the standards. On September 24, 2020 the Standards Committee (SC) accepted the SAR, authorized a 30-day informal comment period, and authorized solicitation of nominees for a SAR DT. On February 17, 2021 the SC appointed the SAR DT. The SAR DT met in March and April 2021 to review and make revisions to the SAR. The team considered the stakeholder comments submitted during the informal comment period and solicited additional feedback through informal means. As of April 1, 2021, FAC-002-3 became the enforceable standard and will be the one modified by the team going forward. This change is reflected in the redline SAR.

Page 22: Agenda Standards Committee Conference Call

RELIABILITY | RESILIENCE | SECURITY

Standard Authorization Request (SAR)

The North American Electric Reliability Corporation (NERC) welcomes suggestions to improve the reliability of the bulk power system through improved Reliability Standards.

Requested information SAR Title: FAC-001-3 Facility Interconnection Requirements; FAC-002-3, Facility

Interconnection Studies Date Submitted: June 10, 2020 SAR Requester

Name: Allen Shriver, Chair Jeffery Billo, Vice Chair

Organization: Inverter-Based Resource Performance Task Force (IRPTF)

Telephone: Allen: 561-904-3234 Jeffery: 512-248-6334 Email: [email protected]

[email protected] SAR Type (Check as many as apply)

New Standard Revision to Existing Standard Add, Modify or Retire a Glossary Term Withdraw/retire an Existing Standard

Imminent Action/ Confidential Issue (SPM Section 10)

Variance development or revision Other (Please specify)

Justification for this proposed standard development project (Check all that apply to help NERC prioritize development)

Regulatory Initiation Emerging Risk (Reliability Issues Steering

Committee) Identified Reliability Standard Development Plan

NERC Standing Committee Identified Enhanced Periodic Review Initiated Industry Stakeholder Identified

Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?): The NERC Inverter-based Resource Performance Task Force (IRPTF) undertook an effort to perform a comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or improvements based on the work and findings of the IRPTF. The IRPTF identified several issues as part of this effort and documented its findings and recommendations in a white paper. The “IRPTF Review of NERC Reliability Standards White Paper” was approved by the Operating Committee and the Planning Committee in March 2020. Among the findings noted in the white paper, the IRPTF identified issues with FAC-001-3 and FAC-002-3 that should be addressed. The purpose of FAC-001-3 is to ensure that Facility interconnection requirements exist for Transmission Owners and Generator Owners when connecting new or “materially modified” facilities. The purpose of FAC-002-3 is to ensure studies are performed to analyze the impact of interconnecting new or “materially

Complete and submit this form, with attachment(s) to the NERC Help Desk. Upon entering the Captcha, please type in your contact information, and attach the SAR to your ticket. Once submitted, you will receive a confirmation number which you can use to track your request.

Agenda Item 5a Standards Committee

May 19, 2021

Page 23: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 2

Requested information modified” facilities on the Bulk Electric System (BES). An ambiguity exists in these standards in regards to the term “materially modified” and which entity is responsible for making such a determination. Hence, these standards need to be modified to address this issue. Purpose or Goal (How does this proposed project provide the reliability-related benefit described above?): This SAR proposes to revise FAC-001-3 and FAC-002-3 to clarify requirements related to “material modifications” of Facilities. Project Scope (Define the parameters of the proposed project): The proposed scope of this project is as follows:

a. Consider ways to clarify which entity (entities) are responsible for making the determination of what is considered to be a “material modification” to a Facility, including but not limited to a planned or existing Facility.

b. Consider requiring Facility owners to notify affected entities when making a “material modification” to a Facility, including but not limited to a planned or existing Facility.

c. Consider changing or defining the “materially modifying” term or consider a new defined glossary term, to avoid confusion with similar terminology that is used for a different purpose in the FERC Open Access Transmission Tariff.

d. Consider other manners in which to clarify existing requirements to ensure new or “materially modified” Facilities on the Bulk Electric System (BES) are adequately accounted for to ensure reliability.

Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to execute the project. If you propose a new or substantially revised Reliability Standard or definition, provide: (1) a technical justification1 which includes a discussion of the reliability-related benefits of developing a new or revised Reliability Standard or definition, and (2) a technical foundation document (e.g., research paper) to guide development of the Standard or definition): Both FAC-001-3 and FAC-002-3 imply that the term “materially modified” should be used to distinguish between facility changes that are required to be studied and those that need not be studied. However, there is not a requirement for any entity to determine what changes are to be considered “materially modifying” and Facility owners are not required to notify potentially affected entities of these changes. This has led to confusion and potential reliability issues within industry. For example, a Transmission Planner may consider an inverter-based resource (IBR) control system software change to be “materially modifying”, but if the Generator Owner does not consider such a change to be “materially modifying” they will not notify the Transmission Planner of the change. While the existing standards do require coordination and cooperation between a Facility owner and the Transmission Planner or Planning Coordinator when a new or “materially modified” interconnection Facility is being studied, it should be made clear what entity is responsible for making the determination of what is considered “materially modified”. For example FAC-002-3 Requirement R5, does not specify what entity is responsible for determining what is considered to be a “material modification”. Further,

1 The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent information to this form before submittal to NERC.

Page 24: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 3

Requested information the existing language is unclear about whether these requirements only apply when a different entity is proposing to interconnect, or has already interconnected to a Facility owner’s Facility, or if they also apply to the Facility owner’s new or modified Facility. Additionally, the FERC-defined term Material Modification refers to a new generation project’s impact on other generators in the interconnection queue. This has led to widespread confusion across the industry regarding the correct application of these terms related to the FERC Open Access Transmission Tariff (OATT) implementation and the NERC Reliability Standards requirements. The application of these terms is different between the FERC process and the NERC Reliability Standards (specifically FAC-001-3 and FAC-002-3). For example, if a Generator Owner changes out the inverters on an existing solar PV resource, the change may have no impact on other generators in the interconnection queue, and thus would not be considered a Material Modification under the FERC OATT rules. But such a change could have reliability impacts on the system that should be studied in accordance with FAC-002-3. The Standards Drafting Team should consider changing the term, defining the term, or consider a new defined glossary term, to avoid this confusion. FAC-001-3 and FAC-002-3 should be modified to clarify the use of “materially modifying”, particularly as it relates to compliance with the standards. Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated with the proposed project): The SAR proposes to clarify and address gaps in the requirements in FAC-001-3 and FAC-002-3. The cost impact is unknown. Please describe any unique characteristics of the BES facilities that may be impacted by this proposed standard development project (e.g., Dispersed Generation Resources): The frequency of change of components could be higher for IBRs and the magnitude of such changes could vary. For example, due to a rapid change in wind turbine generator (WTG) technology, it is a common practice to re-power an existing wind power plant with bigger blades while keeping the same electrical generator and converter systems (for both Type 3 and Type 4 WTGs). This may be considered a “material modification” since a new set of bigger blades can produce more power at a lower wind speed. However, the nameplate rating of the plant will remain unchanged. From an interconnection requirements’ perspective, it is the electrical generator and converter system that impacts the majority of the steady-state, short-circuit, and dynamic characteristics and therefore will be mostly unchanged. Therefore, the question remains if these sort of repowering projects should be studied under FAC-002-3 R1 and which entity should make that determination. To assist the NERC Standards Committee in appointing a drafting team with the appropriate members, please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for definitions): Planning Coordinator, Transmission Planner, Generator Owner, Transmission Owner, Distribution Provider

Page 25: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 4

Requested information Do you know of any consensus building activities2 in connection with this SAR? If so, please provide any recommendations or findings resulting from the consensus building activity. This issue was captured in the “IRPTF Review of NERC Reliability Standards White Paper” which was approved by the Operating Committee and the Planning Committee. Are there any related standards or SARs that should be assessed for impact as a result of this proposed project? If so, which standard(s) or project number(s)? N/A Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could meet the objectives? If so, please list the alternatives. The IRPTF did not identify any alternatives since there are ambiguities in the existing language for FAC-001-3 and FAC-002-3 that need to be clarified.

Reliability Principles

Does this proposed standard development project support at least one of the following Reliability Principles (Reliability Interface Principles)? Please check all those that apply.

1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions as defined in the NERC Standards.

2. The frequency and voltage of interconnected bulk power systems shall be controlled within defined limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected bulk power systems

shall be made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected bulk power systems shall be developed, coordinated, maintained and implemented.

5. Facilities for communication, monitoring and control shall be provided, used and maintained for the reliability of interconnected bulk power systems.

6. Personnel responsible for planning and operating interconnected bulk power systems shall be trained, qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected bulk power systems shall be assessed, monitored and maintained on a wide area basis.

8. Bulk power systems shall be protected from malicious physical or cyber attacks.

Market Interface Principles Does the proposed standard development project comply with all of the following Market Interface Principles?

Enter (yes/no)

1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes

2 Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Page 26: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 5

Market Interface Principles 2. A reliability standard shall neither mandate nor prohibit any specific market

structure. Yes

3. A reliability standard shall not preclude market solutions to achieving compliance with that standard. Yes

4. A reliability standard shall not require the public disclosure of commercially sensitive information. All market participants shall have equal opportunity to access commercially non-sensitive information that is required for compliance with reliability standards.

Yes

Identified Existing or Potential Regional or Interconnection Variances

Region(s)/ Interconnection

Explanation

None N/A

For Use by NERC Only

SAR Status Tracking (Check off as appropriate).

Draft SAR reviewed by NERC Staff Draft SAR presented to SC for acceptance DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC SAR assigned a Standards Project by NERC SAR denied or proposed as Guidance

document Version History

Version Date Owner Change Tracking 1 June 3, 2013 Revised

1 August 29, 2014 Standards Information Staff Updated template

2 January 18, 2017 Standards Information Staff Revised

2 June 28, 2017 Standards Information Staff Updated template

3 February 22, 2019 Standards Information Staff Added instructions to submit via Help Desk

4 February 25, 2020 Standards Information Staff Updated template footer

Page 27: Agenda Standards Committee Conference Call

RELIABILITY | RESILIENCE | SECURITY

Standard Authorization Request (SAR)

The North American Electric Reliability Corporation (NERC) welcomes suggestions to improve the reliability of the bulk power system through improved Reliability Standards.

Requested information SAR Title: FAC-001-3 Facility Interconnection Requirements; FAC-002-32, Facility

Interconnection Studies Date Submitted: June 10, 2020 SAR Requester

Name: Allen Shriver, Chair Jeffery Billo, Vice Chair

Organization: Inverter-Based Resource Performance Task Force (IRPTF)

Telephone: Allen: 561-904-3234 Jeffery: 512-248-6334 Email: [email protected]

[email protected] SAR Type (Check as many as apply)

New Standard Revision to Existing Standard Add, Modify or Retire a Glossary Term Withdraw/retire an Existing Standard

Imminent Action/ Confidential Issue (SPM Section 10)

Variance development or revision Other (Please specify)

Justification for this proposed standard development project (Check all that apply to help NERC prioritize development)

Regulatory Initiation Emerging Risk (Reliability Issues Steering

Committee) Identified Reliability Standard Development Plan

NERC Standing Committee Identified Enhanced Periodic Review Initiated Industry Stakeholder Identified

Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?): The NERC Inverter-based Resource Performance Task Force (IRPTF) undertook an effort to perform a comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or improvements based on the work and findings of the IRPTF. The IRPTF identified several issues as part of this effort and documented its findings and recommendations in a white paper. The “IRPTF Review of NERC Reliability Standards White Paper” was approved by the Operating Committee and the Planning Committee in March 2020. Among the findings noted in the white paper, the IRPTF identified issues with FAC-001-3 and FAC-002-32 that should be addressed. The purpose of FAC-001-3 is to ensure that Facility interconnection requirements exist for Transmission Owners and Generator Owners when connecting new or “materially modified” facilities. The purpose of FAC-002-32 is to ensure studies are performed to analyze the impact of interconnecting new or

Complete and submit this form, with attachment(s) to the NERC Help Desk. Upon entering the Captcha, please type in your contact information, and attach the SAR to your ticket. Once submitted, you will receive a confirmation number which you can use to track your request.

Agenda item 5a Standards Committee

May 19, 2021

Page 28: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 2

Requested information “materially modified” facilities on the Bulk Electric System (BES). An ambiguity exists in these standards in regards to the term “materially modified” and which entity is responsible for making such a determination. Hence, these standards need to be modified to address this issue. Purpose or Goal (How does this proposed project provide the reliability-related benefit described above?): This SAR proposes to revise FAC-001-3 and FAC-002-32 to clarify requirements related to “material modifications” of Facilities. Project Scope (Define the parameters of the proposed project): The proposed scope of this project is as follows:

a. Consider ways to clarify which entity (entities) isare responsible for making the determination of what is considered to be a “material modification” to a Facility, includinge but not limited to a planned or existinga Facility.

b. Consider requiring Facility owners to notify affected entities when making a “material modification” to a Facility, includinge but not limited to a planned or existing a Facility.

c. Consider changing or defining the “materially modifying” term “materially modifying”, or consider a new defined glossary term, to avoid confusion with similar terminology that is used for a different purpose in the FERC Open Access Transmission Tariff.

d. Consider other manners in which to clarify existing requirements to ensure new or “materially modified” Facilities on the Bulk Electric System (BES) are adequately accounted for to ensure reliability.

Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to execute the project. If you propose a new or substantially revised Reliability Standard or definition, provide: (1) a technical justification1 which includes a discussion of the reliability-related benefits of developing a new or revised Reliability Standard or definition, and (2) a technical foundation document (e.g., research paper) to guide development of the Standard or definition): Both FAC-001-3 and FAC-002-32 imply that the term “materially modified” should be used to distinguish between facility changes that are required to be studied and those that need not be studied. However, there is not a requirement for any entity to determine what changes are to be considered “materially modifying” and Facility owners are not required to notify potentially affected entities of these changes. This has led to confusion and potential reliability issues within industry. For example, a Transmission Planner may consider an inverter-based resource (IBR) control system software change to be “materially modifying”, but if the Generator Owner does not consider such a change to be “materially modifying” they will not notify the Transmission Planner of the change. While the existing standards do require coordination and cooperation between a Facility owner and the Transmission Planner or Planning Coordinator when a new or “materially modified” interconnection Facility is being studied, it should be made clear what entity is responsible for making the determination of what is considered “materially modified”. connected to their system, fFor example FAC-002-32 Requirement R5, does not neither standard specifies specify what entity is responsible for determining

1 The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent information to this form before submittal to NERC.

Page 29: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 3

Requested information what is considered to be a “material modification”. Further, the existing language is unclear about whether these requirements only apply when a different entity is proposing to interconnect, or has already interconnected to a Facility owner’s Facility, or if they also apply to the Facility owner’s new or modified Facility. Additionally, the FERC-defined in FERC-jurisdictional areas, the term “Materially Modification” refers to a new generation project’s impact on other generators in the interconnection queue. This has led to widespread confusion across the industry regarding the correct application of these terms related to the FERC Open Access Transmission Tariff (OATT) implementation and the NERC Reliability Standards requirements. The application of these terms is different between the FERC process and the NERC Reliability Standards (specifically FAC-001-3 and FAC-002-32). For example, if a Generator Owner changes out the inverters on an existing solar PV resource, the change may have no impact on other generators in the interconnection queue, and thus would not be considered a Material Modification under the FERC OATT rules. But such a change could have reliability impacts on the system that should be studied in accordance with FAC-002-32. The Standards Drafting Team should consider changing the term, defining the term, or consider a new defined glossary term, to avoid this confusion. FAC-001-3 and FAC-002-32 should be modified to clarify the use of “materially modifying”, particularly as it relates to compliance with the standards. Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated with the proposed project): The SAR proposes to clarify and address gaps in the requirements in FAC-001-3 and FAC-002-32. The cost impact is unknown. Please describe any unique characteristics of the BES facilities that may be impacted by this proposed standard development project (e.g., Dispersed Generation Resources): The frequency of change of components could be higher for IBRs and the magnitude of such changes could vary. For example, due to a rapid change in wind turbine generator (WTG) technology, it is a common practice to re-power an existing wind power plant with bigger blades while keeping the same electrical generator and converter systems (for both Type 3 and Type 4 WTGs). This may be considered a “material modification” since a new set of bigger blades (e.g., 93 m to 208 m) can produce more power at a lower wind speed. However, the nameplate rating of the plant will remain unchanged. From an interconnection requirements’ perspective, it is the electrical generator and converter system that impacts the majority of the steady-state, short-circuit, and dynamic characteristics and therefore will be mostly unchanged. Therefore, the question remains if these sort of repowering projects should be studied under FAC-002-32 R1 and which entity should make that determination. To assist the NERC Standards Committee in appointing a drafting team with the appropriate members, please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for definitions): Planning Coordinator, Transmission Planner, Generator Owner, Transmission Owner, Distribution Provider

Page 30: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 4

Requested information Do you know of any consensus building activities2 in connection with this SAR? If so, please provide any recommendations or findings resulting from the consensus building activity. This issue was captured in the “IRPTF Review of NERC Reliability Standards White Paper” which was approved by the Operating Committee and the Planning Committee. Are there any related standards or SARs that should be assessed for impact as a result of this proposed project? If so, which standard(s) or project number(s)? N/A Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could meet the objectives? If so, please list the alternatives. The IRPTF did not identify any alternatives since there are ambiguities in the existing language for FAC-001-3 and FAC-002-32 that need to be clarified.

Reliability Principles

Does this proposed standard development project support at least one of the following Reliability Principles (Reliability Interface Principles)? Please check all those that apply.

1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions as defined in the NERC Standards.

2. The frequency and voltage of interconnected bulk power systems shall be controlled within defined limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected bulk power systems

shall be made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected bulk power systems shall be developed, coordinated, maintained and implemented.

5. Facilities for communication, monitoring and control shall be provided, used and maintained for the reliability of interconnected bulk power systems.

6. Personnel responsible for planning and operating interconnected bulk power systems shall be trained, qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected bulk power systems shall be assessed, monitored and maintained on a wide area basis.

8. Bulk power systems shall be protected from malicious physical or cyber attacks.

Market Interface Principles Does the proposed standard development project comply with all of the following Market Interface Principles?

Enter (yes/no)

1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes

2 Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Page 31: Agenda Standards Committee Conference Call

Standard Authorization Request (SAR) 5

Market Interface Principles 2. A reliability standard shall neither mandate nor prohibit any specific market

structure. Yes

3. A reliability standard shall not preclude market solutions to achieving compliance with that standard. Yes

4. A reliability standard shall not require the public disclosure of commercially sensitive information. All market participants shall have equal opportunity to access commercially non-sensitive information that is required for compliance with reliability standards.

Yes

Identified Existing or Potential Regional or Interconnection Variances

Region(s)/ Interconnection

Explanation

None N/A

For Use by NERC Only

SAR Status Tracking (Check off as appropriate).

Draft SAR reviewed by NERC Staff Draft SAR presented to SC for acceptance DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC SAR assigned a Standards Project by NERC SAR denied or proposed as Guidance

document Version History

Version Date Owner Change Tracking 1 June 3, 2013 Revised

1 August 29, 2014 Standards Information Staff Updated template

2 January 18, 2017 Standards Information Staff Revised

2 June 28, 2017 Standards Information Staff Updated template

3 February 22, 2019 Standards Information Staff Added instructions to submit via Help Desk

4 February 25, 2020 Standards Information Staff Updated template footer

Page 32: Agenda Standards Committee Conference Call

Agenda Item 6 Standards Committee

May 19, 2021

Project 2021-03 CIP-002 Transmission Owner Control Centers Standard Drafting Team Recommendation

Action Appoint members, chair, and vice chair to the Standard Drafting Team (SDT) for Project 2021-03, as recommended by NERC staff. Background The purpose of this project is to review CIP-002 and evaluate the categorization of Transmission Owner Control Centers (TOCCs) performing the functional obligations of a Transmission Operator (TOP), specifically those that meet medium impact criteria. In addition, this SDT will assist NERC staff in meeting the directive from the NERC Board of Trustees to conduct further study of the need to readdress the applicability of the Critical Infrastructure Protection (CIP) Reliability Standards to these Control Centers to support reliability. The Standards Committee authorized solicitation for a SDT on March 17, 2021 and assigned a portion of the Project 2016-02 Standard Authorization Request (SAR) that relates to TOCCs to the SDT. From March 22 – April 27, 2021, NERC solicited nominations for volunteers to serve on a SDT for CIP-002. NERC staff received nine (9) nominations from industry professionals and recommends eight (8) of the nine (9) as they have the requisite background, experience, and skills necessary for membership on the SDT.

Page 33: Agenda Standards Committee Conference Call

Agenda Item 7 Standards Committee

May 19, 2021

NERC Legal and Regulatory Update April 7, 2021–May 4, 2021

NERC FILINGS TO FERC SUBMITTED SINCE LAST SC UPDATE

FERC Docket No. Filing Description FERC Submittal

Date

AD21-13-000

Comments of NERC on Climate Change, Extreme Weather, and Electric System Reliability NERC submitted comments in response to the Supplemental Notice of Technical Conference Inviting Comments issued on March 15, 2021 in the Climate Change, Extreme Weather, and Electric System Reliability technical conference proceeding.

4/15/2021

RR20-5-000

Compliance Filing on the Revised Delegation Agreements With Regional Entities NERC submitted a compliance filing in accordance with FERC’s December 30, 2020 Order directing NERC to modify certain terms in the Revised RDAs.

4/29/2021

RM15-11-003

GMD Research Work Plan Final Report Informational Filing NERC submitted an informational filing regarding research done under the Geomagnetic Disturbance (GMD) Research Work Plan.

4/30/2021

FERC ISSUANCES SINCE LAST SC UPDATE

FERC Docket No. Issuance Description FERC Issuance

Date

RR21-1-000

Letter Order approving amended NERC Bylaws FERC issued a letter order approving amendments to NERC Bylaws.

4/5/2021

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RD21-4-000

Letter Order approving Reliability Standard FAC-008-5 FERC issued a letter order approving Reliability Standard FAC-008-5.

4/7/2021

RM19-20-000

Order approving Reliability Standard BAL-002-WECC-3 FERC issued an order approving Reliability Standard BAL-002-WECC-3 (Contingency Reserve).

4/15/2021

ANTICIPATED UPCOMING FILINGS

FERC Docket No. Issuance Description Anticipated Filing

Date

Petition for Approval of Revised WECC RSDP 5/27/2021

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RELIABILITY | RESILIENCE | SECURITY

Standards Committee Expectations Approved by Standards Committee January 12, 2012

Background Standards Committee (SC) members are elected by members of their segment of the Registered Ballot Body, to help the SC fulfill its purpose. According to the Standards Committee Charter, the SC’s purpose is:

In compliance with the NERC Reliability Standards Development Procedure, the Standards Committee manages the NERC standards development process for the North American-wide reliability standards with the support of the NERC staff to achieve broad bulk power system reliability goals for the industry. The Standards Committee protects the integrity and credibility of the standards development process.

The purpose of this document is to outline the key considerations that each member of the SC must make in fulfilling his or her duties. Each member is accountable to the members of the Segment that elected them, other members of the SC, and the NERC Board of Trustees for carrying out their responsibilities in accordance with this document.

Expectations of Standards Committee Members

1. SC members represent their segment, not their organization or personal views. Each member isexpected to identify and use mechanisms for being in contact with members of the segment inorder to maintain a current perspective of the views, concerns, and input from that segment. NERCcan provide mechanisms to support communications if an SC member requests such assistance.

2. SC members base their decisions on what is best for reliability and must consider not only what isbest for their segment, but also what is in the best interest of the broader industry and reliability.

3. SC members should make every effort to attend scheduled meetings, and when not available arerequired to identify and brief a proxy from the same segment. SC business cannot be conducted inthe absence of a quorum, and it is essential that each SC member make a commitment to beingpresent.

4. SC members should not leverage or attempt to leverage their position on the SC to influence theoutcome of standards projects.

5. The role of the SC is to manage the standards process and the quality of the output, not thetechnical content of standards.

Agenda Item 8a Standards Committee

April 21, 2021

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Parliamentary Procedures

Agenda Item 8d Standards Committee

April 21, 2021

Based on Robert’s Rules of Order, Newly Revised, 11th Edition, plus “Organization and Procedures Manual for the NERC Standing Committees”

Motions Unless noted otherwise, all procedures require a “second” to enable discussion.

When you want to… Procedure Debatable Comments Raise an issue for discussion

Move Yes The main action that begins a debate.

Revise a Motion currently under discussion

Amend Yes Takes precedence over discussion of main motion. Motions to amend an amendment are allowed, but not any further. The amendment must be germane to the main motion, and cannot reverse the intent of the main motion.

Reconsider a Motion already approved

Reconsider Yes Allowed only by member who voted on the prevailing side of the original motion.

End debate Call for the Question or End Debate

No If the Chair senses that the committee is ready to vote, he may say “if there are no objections, we will now vote on the Motion.” The vote is subject to a 2/3 majority approval. Also, any member may call the question. This motion is not debatable. The vote is subject to a 2/3 vote.

Record each member’s vote on a Motion

Request a Roll Call Vote

No Takes precedence over main motion. No debate allowed, but the members must approve by 2/3 majority.

Postpone discussion until later in the meeting

Lay on the Table Yes Takes precedence over main motion. Used only to postpone discussion until later in the meeting.

Postpone discussion until a future date

Postpone until Yes Takes precedence over main motion. Debatable only regarding the date (and time) at which to bring the Motion back for further discussion.

Remove the motion for any further consideration

Postpone indefinitely

Yes Takes precedence over main motion. Debate can extend to the discussion of the main motion. If approved, it effectively “kills” the motion. Useful for disposing of a badly chosen motion that can not be adopted or rejected without undesirable consequences.

Request a review of procedure

Point of order No Second not required. The Chair or secretary shall review the parliamentary procedure used during the discussion of the Motion.

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Notes on Motions Seconds. A Motion must have a second to ensure that at least two members wish to discuss the issue. The “seconder” is not recorded in the minutes. Neither are motions that do not receive a second.

Announcement by the Chair. The Chair should announce the Motion before debate begins. This ensures that the wording is understood by the membership. Once the Motion is announced and seconded, the Committee “owns” the motion, and must deal with it according to parliamentary procedure.

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Voting Voting Method When Used How Recorded in Minutes Unanimous Consent The standard practice.

When the Chair senses that the Committee is substantially in agreement, and the Motion needed little or no debate. No actual vote is taken.

The minutes show “by unanimous consent.”

Vote by Voice The standard practice. The minutes show Approved or Not Approved (or Failed).

Vote by Show of Hands (tally)

To record the number of votes on each side when an issue has engendered substantial debate or appears to be divisive. Also used when a Voice Vote is inconclusive. (The Chair should ask for a Vote by Show of Hands when requested by a member).

The minutes show both vote totals, and then Approved or Not Approved (or Failed).

Vote by Roll Call To record each member’s vote. Each member is called upon by the Secretary, and the member indicates either “Yes,” “No,” or “Present” if abstaining.

The minutes will include the list of members, how each voted or abstained, and the vote totals. Those members for which a “Yes,” “No,” or “Present” is not shown are considered absent for the vote.

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