n/a...2019/08/29 · [email protected]; [email protected] proposal for...

Proposal

Name of Individual or Organization(s) (list multiple if

submitted by a group):

Industry Segment (if applicable):

Region (if applicable)

Contact Telephone:

Contact Email:

Organization(s) Page # Comment Proposed Change (if applicable) SET Response

Christine F. Ericson, Federal Energy Regulatory Counsel,

and Special Assistant Attorney General, Illinois

Commerce Commission, Office of General Counsel; and

State Government Sector Representative, NERC

Planning Committee; and Cezar Panait, Regulatory

Engineer, Energy Facilities Permitting, Minnesota Public

Utilities Commission, and State Government

Representative, NERC Planning Committee 2

The draft indicates: "the technical committees must play a vital role in order

for the ERO Enterprise to be successful in its mission of reducing risk to the

BPS." Please explain how dissolving those technical committees would

advance that mission.

The proposal does not seek to eliminate the technical committees. The proposal seeks

to create a technical council to enhance oversight and coordination amongst the

subcommittees, working groups and task forces that fall under the existing technical

committees.

2

The draft suggests the importance of "enhancing stakeholder engagement

through the three technical committees" and "achieve a higher level of

industry participation". Please explain how eliminating the three technical

committees and replacing those with a much smaller ( by over 66%) new

oversight entity would improve stakeholder engagement.

Please see response above.

4

Please elaborate on what is meant by "[w]e bring multi-disciplined teams

together to develop 'complete' solutions." How would that differ under the

smaller model, and how would NERC be able to draw upon more multi-

disciplined teams with fewer participants in the process?

Please see response above.

4

Regarding eliminating redundancies, it seems the purpose of the Joint

Committee meetings was one measure that addressed overlapping issues in

order to increase efficiencies. In addition, the PC voted to give the PC

Executive Committee increased power last year to vote between meetings

and better coordinate with the other standing committees in order to address

any redundancy issues. Please explain whether or why such measures may

have been insufficient in the eyes of the SET. If the NERC Board in particular

was still seeing overlap on issues, was there any attempt to further delineate

which issues should be covered by which standing committee? Was there an

option to combine any overlapping subcommittees into Joint PC/OC/CIPC

subcommittees?

The SET did not discuss this issue. We are certain that the there will be an executive

committee and it will perform agenda setting activities as moe ExecComs perform. If

additional decision powers are needeed, this can be taken up with the rest of the

Council.

6

In footnote 2, the SET recommends Alternative 1a, create a new oversight

committee for NERC technical committees. This seems to contradict page 11

where it says the SET is recommending a participation model for option 2.

Please clarify. Fotnote 2 refers only to Option 1 and an alternative for its implementation. The SET

recommends Option 2 over Option 1.

Ericson: (312) 814-3706; Penait: (651) 201-2207

[email protected]; [email protected]

Proposal for Restructuring NERC Technical Committees - Reliability and Security Council Proposal

Christine F. Ericson, Federal Energy Regulatory Counsel, and Special Assistant Attorney General, Illinois Commerce Commission, Office of General Counsel, and State Government Sector Representative, NERC Planning Committee; and Cezar Panait,

Regulatory Engineer, Energy Facilities Permitting, Minnesota Public Utilities Commission, and State Government Sector Representative, NERC Planning Committee (comments provided are our own and not necessarily those of our respective commissions)

NOTE: Bill Chamblis (OC member) also signed onto these comments.

State Government

N/A

announcement

In the NERC announcement, NERC says it will seek country diversity. Can

you elaborate what is meant by country diversity? Will Canada, United States

of American and Mexico all have equal representation in the new oversight

committee? Will representation be based on other technical factors? How will

country diversity be measured? The RSC should also seek to achieve gender

and other forms of diversity. Please explain whether and how these and

other such diversity and inclusion goals would be taken into account in the

RSC formation.

According to federal statute and federal regulations, NERC is certified as the ERO by

FERC to establish and enforce Reliability Standards for the bulk power system in the

United States. The ERO is obligated to receive recognition by applicable governmental

authorities in Canada and Mexico to establish and enforce reliability standards for the

bulk power systems of the respective countries. Recognition of the ERO grants Canadian

and Mexican representatives the right to participate in NERC's committees.

Canadian / Mexican representation is outlined in Appendix C of the whitepaper and will

be further elabored in the forthcoming charter.

Representation will also be based on sectors and subject matter expertise.

NERC is always committed to including all types of diversity in industry participation in

its operations.

8 and 9

In option 2, the proposal indicates the "RSC will oversee the output of the

subcommittees, working groups, and task forces, and report to the Board."

Will those be newly formed subcommittees, working groups and task forces?

The organizational chart on page 9 suggests that the RSC will oversee the

existing OC, PC and CIPC committees. However, when the OC, PC and CIPC

are dissolved, the underlying committees would no longer exist. How does

the SET anticipate having a PC subcommittee with no PC Charter, for

example? How will the subcommittees, work groups and task forces be filled

given the diminished stakeholder participation at the quarterly and other

meetings? Would the RSC hold quarterly meetings? Would those open

meetings have a dial-in option or would industry still have to expend

resources to attend those in person. Has NERC contemplated internally

staffing to better cover its statutory duties? That would eliminate the

industry burden of having to travel, and NERC would have all its experts in

one place.

No, the SET expects to largely retain most of the existing subcommittees, working

groups and task forces.

NERC staffing would need to significantly increase in order to fully populate the

subcommittees, working groups and task forces. NERC values stakeholder input and

benefits greatly from this input.

8

Since the goal seems to be to align the technical committees to the RISC, and

the RISC only reports to the NERC Board every second year, it would seem

that this approach would significantly diminish transparency and

communication from quarterly information to bi-annual or some equivalent.

Was this the intent? How is this consistent with NERC's obligation under the

Federal Power Act to report on its activities.

As indicated in Chapter 8, the frequency of meetings will be defined in the forthcoming

charter.

9

Given the elevated role of the Reliability Issues Steering Committee in the

new structure, it seems that the state government sector should be

represented on the RISC. There does not appear to be any state government

representation there. Is that something that can be added? Also, what is the

role of the MRC. The MRC is not represented in the chart on page 9.

The elevated role of the RISC is only for Alternative 1. Alternative 2 is the leading

proposal for restructuring.

The SET will evaluate the inclusion of state government representations.

The MRC Vice Chair will serve on the Nominating Committee for the RSC.

9

If the purpose of the RISC is to prioritize risks and set strategy, has NERC or

the SET assessed whether RISC could have taken steps to prevent any

overlap and/or whether any adjustments should be made to the RISC to

ensure that it is more efficient going forward. The RISC's evaluation of risks is an input to the work plans of the RSC subcommittees,

working groups and task forces. The RISC does not manage these work plans.

9

NERC notes that the RISC performs, among other things, the budgeting and

strategic planning processes. What is the budget for the standing committees

versus the subcommittees, work groups and task forces. What do you

anticipate the budget will be under the new RSC? Since NERC's committees

are populated largely by industry volunteers, how would this budget and/or

any resulting savings be measured?

There has been conversation on the “efficiency” with a desire for identifying the

savings. The numbers for NERC are not the big part of the savings. Rather for industry

(30-40 members instead of 90-120). However, the Council will be far more “effective” as

it will be one group providing leadership and management towards a fulsome solution

set, rather than fragmented between multiple committees and subcommittees. For

example, the OC and PC are both working on inverters and have multiple groups

working pieces of the problem. Rather, it should be seen as one project with multiple

perspectives needed to be resolved towards a total solution.

10

Regarding the RSC initiating and overseeing (in conjunction with NERC

management) the development of technical assessments and analysis that

support the analytical assessment function of the ERO, please explain how

this meets NERC's ERO requirement to report on reliability matters.

Section 215 of the Federal Power Act requires the ERO to conduct periodic assessments

of the reliability and adequacy of the BPS in North America. These technical

assessments support that requirement.

10

Since the purpose of the ERO is to establish and enforce reliability standards

for the bulk-power system, subject to Commission review, 16 U.S.C. §

824o(a)(2), and since NERC as the ERO is relying largely upon industry

volunteers to conduct much of the analytical work to develop those

standards, please explain (1) how less industry oversight in the form of a

smaller, more insular RSC, would advance that purpose, and (2) how a more

insular group of fewer stakeholders would not simply be leaving those to

whom the standards apply in charge of enforcement.

The RSC does not oversee the Reliability Standards development process. That is the

role of the Standards Committee. The SC consists of two representatives from each of

the 10 industry segments. Standards Committee members are elected by the segment

they represent. The Standards Committee reports to the NERC Board of Trustees and

oversees the development of NERC Reliability Standards as its members:

Review actions to ensure the standards development process is being followed;

Review and authorize Standard Authorization Request postings;

Manage progress of Standard Authorization Requests and standards development

efforts;

Review and authorize drafting of new or revised Reliability Standards;

Authorize the development of supporting documents;

Make appointments to drafting teams.

The Standard Processes Manual requires each industry segment to elect up to two

representatives to serve on the Standards Committee.

10

Please explain how NERC plans to conduct periodic assessments of the

reliability and adequacy of the bulk-power system in North America in order

to meet its mandatory reporting requirement under 16 U.S.C. § 824o (g),

under which it is required to conduct reliability assessments - not just initiate

and oversee, as anticipated in the RSC (on page 10).

NERC’s Reliability Assessment and Performance Analysis group identifies areas of

concern regarding assessment and trend efforts and makes recommendations for their

remedy. NERC cannot order construction of additional generation or transmission or

adopt enforceable standards that have that effect, as that authority is explicitly

withheld. In addition, NERC does not make any projections or draw any conclusions

regarding expected electricity prices or the efficiency of electricity markets.

NERC’s assessments provide a high-level assessment of resource adequacy, an overview

of projected electricity demand growth and generation and transmission additions.

NERC also identifies long-term emerging issues and trends that do not necessarily pose

an immediate threat to reliability but will influence future Bulk-Power System planning,

development and system analysis. Trends identified by NERC can also provide the basis

for advisories, recommendations and essential action notifications. For more on these,

visit the Event Analysis page.

8

Please explain how the existing NERC technical committee's structure remains

unchanged as indicated on page 8, if the technical committees are dissolved? The oversight bodies of the technical committees are dissolved. The subcommittees,

working groups and task forces for these committees who perform the actual work are

not dissolved.

10

Page 10 indicates that the Personnel Subcommittee reports to the NERC

Operating Committee and is the governing body of the NERC Continuing

Education Program that apparently facilitates System Operator Training.

Please explain why NERC would not hire any staff for such functions and

appears to rely almost solely on industry volunteers. Can you point to NERC

budget items that reflect the savings that NERC anticipates from the

restructuring?

There is no budgetary savings for this move. This move consolidates continuing

education and program certification under one group thereby inproving efficiencies.

NERC uses indsutry subject matter experts to support its mission. Thc council and

subcommittees are the way NERC leeverages this expertise rather than hiring 100s of

technical staff.

11

The proposal indicates that "[m]ore time at Board and MRC meetings is

envisaged to hear a report from the RSC and tee up specific items for

discussion." It seems the purpose of the restructuring is to have a smaller

group of oversight members whose time commitment would actually increase

as they add additional MRC and trustee meetings. Is that the intention?

What additional time commitment is anticipated? Is it anticipated that NERC

would be providing the funding for these RSC members to travel?

More time would be freed up for the Board who will not need to hear three report-outs,

but instead one from a singular council. It is not anticipated that NERC will provide

funding for RSC member travel.

11

The proposal indicates the new sector representation "may or may not

include all existing sectors," which sectors do you anticipate eliminating? Are

there new sectors the SET anticipates adding?

The SET is evaluating eliminating the Regional Entity sector.

12

One member per sector seems inadequate. Moreover, such an approach

would eliminate any consistency of leadership between terms, etc., which

currently exists under the two year term duration permitting at least one

member with experience to participate at a time. There should be at least

two members per sector for continuity and range of expertise. Each sector

should be able to choose its own representation.

Thank you for your input. The Stakeholder Engagement Team will be reviewing these

options.

12

The proposal notes that the NERC mission is to "assure effective and efficient

reduction of risks to the reliability and security of the bulk power system." As

noted above, the purpose of the ERO is to establish and enforce reliability

standards. The mission should be consistent with this statutory mandate.

Not clear from the proposal whether these are consistent.

They are related. Reliability Standards are one set of tools that NERC uses to reduce

risks to the reliability of the system.

12

Presumably the various sector member volunteers on the RSC may have

different opinions on some policy matters. Please explain what the proposal

means by "Members of the RSC are expected to . . .execute the policies,

directives, and assignments of the Board. . ." Would the members be

employees of NERC or would they remain industry volunteers? It is unclear

from the proposal.

They will remain industry volunteers.

13

The Energy Policy Act requires that an ERO assure its independence of the

users and owners and operators of the bulk-power system, while assuring fair

stakeholder representation in the selection of its directors and balanced

decisionmaking in any ERO committee or subordinate organizational

structure. 16 USC §824o(c)(2)(A). If members are appointed to the RSC by

the Board and serve on the RSC at the pleasure of the Board, then is it really

fair sector representation? Concerns could arise whereby the members may

feel pressured to vote a particular way or risk replacement. It may be more

representative of the industry for each sector to pick its own representatives

who make independent assessments accordingly, similar to the stakeholder

committees in most RTOs.

Ultimately, the members of the RSC will not be creating the outputs that they review.

These products are created by the underlying subcommittees, working groups and tasks

forces. These individuals do not serve at the pleasure of the Board.


options.

14

Empowering the RSC Executive Committee to vote and conduct unauthorized

business between meetings is problematic. That format did not seem to work

well for the PC. It created a limited insular subgroup making key decisions

without representation of all the sectors, and without public agendas or

minutes. The EC should do what it is intended to do, which is to chair the

committee, set the agenda, provide minutes, etc., rather than serve as an

independent decision-making subcommittee of the full committee.


options.

MRC presentation

There was much talk at the MRC presentation of finding the "right" people.

Please elaborate what is meant by "right" people in this context. How would

they differ from the experts who currently comprise the technical

committees?

What is meant here is twofold: leadership and management of the subgoups that report

to the Council, and the subgroups themsleves taking a multi-deminsioned appraoch

toward tackling risks.

21

RSC Membership definition chart indicates 20 At Large voting members,

almost twice the amount of the sector representation. Given that these At

Large members have no sector requirements, it is possible that these

additional votes may be largely coming from one or two sectors - thus

skewing the sector voting. Please explain how NERC will protect against this

possible negative impact or violation of the balance requirements of 16 USC

§824o(c)(2)(A).

NERC would not allow the at-large voters to be heavily representative of any one sector.

NERC will not deviate from the balance requirements under federal statute.

21

Since the At Large voting members are presumably those who would be filling

the new subcommittees and work groups, does the SET anticipate that it

would be largely those At Large members conducting most of the work

product in those subcommittees, perhaps also leading them, since most of

the former participants would no longer be on those technical committees?

Please clarify.

The at-large members refer to the composition of the oversight RSC.

overall

Since NERC is only authorized to address matters that affect the BPS, how

will the new RSC make sure that it does not overstep its statutory

authorization under the Energy Policy Act, particularly when NERC appears to

be getting increasingly involved with matters pushing into the distribution

grid.

NERC's activities are approved annually under the business plan and budget process

which is an open stakeholder process.

overall

In particular, since Congress created the ERO to establish and enforce

reliability standards for the bulk power system, and Congress defined the BPS

as (A) facilities and control systems necessary for operating an interconnected

electric energy transmission network (or any portion thereof); and

(B) electric energy from generation facilities needed

to maintain transmission system reliability , specifically stating that "[t]he

term does not include facilities used in the local distribution of electric

energy" (emphasis added), how will the RSC ensure that in implementing the

new fast-past more agile approach to oversight it does not go beyond what

NERC is authorized to do? NERC's activities are approved annually under the business plan and budget process

which is an open stakeholder process.

general

16 USC §824o(j) contemplates the establishment of regional advisory bodies

of states to provide advise to the ERO, regional entity or FERC regarding

governance, standards proposed, fees or other responsibilities. Please explain

how the proposed RSC would coordinate, report to, and/or respond to any

state advisory bodies, particularly regarding the issue of whether a standard

proposed is just, reasonable, not unduly discriminatory or preferential, and in

the public interest. Please explain whether the RSC would conduct cost-

benefit analyses in its assessments and reports and whether the proposed

structure would be sufficiently responsive.

The only Regional Entity that has such a body is WECC. Nothing in the proposal is

intended to change any existing interaction between these technical committees and

regional advisory bodies.

There has been conversation on the “efficiency” with a desire for identifying the

savings. The numbers for NERC are not the big part of the savings. Rather for industry

(30-40 members instead of 90-120). However, the Council will be far more “effective” as

it will be one group providing leadership and management towards a fulsome solution

set, rather than fragmented between multiple committees and subcommittees. For

example, the OC and PC are both working on inverters and have multiple groups

working pieces of the problem. Rather, it should be seen as one project with multiple

perspectives needed to be resolved towards a total solution.



Industry Segment (if applicable)


Contact Telephone

Contact Email


Tri-State G&T V

The overview section of the Reliability and Security Council Proposal paper

describes the activity of the SET committee and concludes that the

recommendation will be to implement a new committee structure replacing

the PC/OC and CIPC with one RSC Committee. The paper continues to

explain that this recommendation will be provided to the BOT prior to the

December Board for approval. If this the recommendation that "will" be

provided to the Board, I question why NERC is soliciting for industry comment

if the decision has been established. Seems to me that the expected and

normal due process is being shortcut.

Consider comments from industry and consider

those at a future well-advertised and open SET

meeting. Seems to me from the paper that the SET

has concluded their consideration and has already

concluded that the recommendation to the BOT will

be to create a RSC.

The SET took into consideration all industry comments and Policy Input that

was submitted. The final proposal include development of the RSC and the

final participation mode includes…NEED TO UPDATE THIS.

Tri-State G&T V

The meeting precedings at the SET meeting and how this conclusion was

reached is difficult to understand.

Publish the meeting minutes from the meeting where

this decision was arrived (trust those are indeed

available, if not there is a bigger problem). Conduct

additional open and well published meeting dates for

industry participation in continued SET discussion.

SUGGEST WE SET UP A WEB PAGE WITH AGENDAS AND MEETING NOTES

Tri-State G&T VI

The paper points out that the goal of the SET effort is to “achieve greater

enterprise-wide effectiveness and efficiency…..recognizing the value of

industry expertise…..”

There seems to be a disconnect between the

previous stated value of the Standing Committees

and this statement. This would lead one to conclude

that this effort is not an effort to increase the value

and participation, rather to squash it, which seems

counterproductive. Recommend that this subject

and idea be vetted with industry in open, well

documented meetings.

Tri-State G&T VI

The paper alludes to successful implementation of various RE’s

implementation of restructuring the committees at the RE level. The Paper is

misleading the reader as not all RE restructuring has been successful. In fact

WECC restructured the committees and reduced the number of committees

and the participation from Western entities has been significantly lower. This

is not a good positon for the RE, the cornerstone of NERC has been to be a

good facilitator for industry participation, this SET recommendation will (as

confirmed by the paper itself on page 11 reduction from 120 to 40) reduce

industry participation.

Reevaluate the SET proposal and open up the SET

meetings for industry participation before a

recommendation is made at the BOT. As everyone

knows this SET recommendation was

overwhelmingly rejected at the June 2019 Standing

Committee meetings. Why is NERC continuing to

push an idea with such a negative reception?

Tri-State G&T 1

The paper states that the current committee members were surveyed for

input on the existing committee structure. The SET used this survey as input

to the evaluation process. I find no evidence that the SET proposal supports

industry.

Publish the survey results and identify how the

survey supports the SET recommendation. Publish

the SET meeting minutes so that this can be better

understood.

SUGGUST WE SET UP A WEB PAGE WITH AGENDAS AND MEETING NOTES

Tri-State G&T 2

The Scope section of the paper discusses the examination of the use of

“scarce” industry resources to focus on maintaining and enhancing BES

Reliability. The paper on page 11 concludes that the industry participation

will be reduced from 120 to 40. These two statements contradict one

another. Seems to me that we would want to, as much as possible, increase

industry participation to arrive at even better conclusions, not decrease it as

implementation of the SET recommendation will have on industry.

Have the SET evaluate in an open meeting how this

recommendation will increase industry participation.

Have the SET committee look at the WECC OC

changes and evaluate the impact changes made on

that committee structure.

Tri-State G&T 2

The paper concludes that “Committee Silos are blurring” but no evidence is

provided to explain what the perceived problem is. What is meant by

blurring?

Please explain what is meant by blurring and provide

some examples of where this has occurred, so we

can better gauge if this is a wide spread problem or if

it is isolated.

Inverter-based Resources impact the planning and operating worlds. EMS models,

software and hardware impact both the operating and CIP worlds.

Tri-State G&T 3

The paper states that the SET “…recognizes the importance of the

collaboration, training and education that occurs between participants and

attendees of the technical committee meetings. Lessons learned,

information sharing by the U.S. Department of Energy (DOE), National Labs,

technical reports, security briefings, cyber reports, training, tec. Will

continue to be provided….” While this may be a true statement I’m

concerned the effort to provide these will be less impactful due to the

decreased industry participation.

Have the SET reevaluate the impact these efforts will

ultimately have with reduced industry participation.

WECC and MRO

303-254-3259

[email protected]

Keith Carman, Tri-State Generation and Transmission Association

Cooperative

mailto:[email protected]

Tri-State G&T 4

The paper indicates on page 4 that there are silos and redundancies but the

paper does not offer any evidence of where these are occurring.

Elaborate on the silos and identify the concerns with

each silo. Many times having a operational silo

within the Operations Committee is a good problem

since the focus on the solution has complete

operational expertise emphasis that leads to robust

conclusions and recommendations.

Tri-State G&T 5

Chapter 3 of the paper identifies options for restructuring and makes four

broad observations with statements that are not supported by evidence.

Specifically, the four statements allude to work being performed at the TF or

subcommittee level, lack of coordination between committee work plans,

problem solving occurring at the TF or subcommittee level and

uncoordinated results. These statements, while may have some truth in

some isolated areas, are not wide spread problems as the paper alludes.

Provide explanation and provide examples that show

this is a problem that is causing the committees to be

unproductive. The very focused committee structure

that is in place today is frankly a NERC strength.

Some overlap or redundancy is not in itself a bad

trait.

Tri-State G&T 5

The paper points out that the SCCG exists, and while not formally, it does

oversee the issue of redundancy and overlap. One of the recommendations

(1a2) was to formalize this group and continue the oversight process.

Recommend the SET group evaluate this option as

this option is the one option that does not

discourage industry participation.

Tri-State G&T 11

The paper concludes that “by replacing the three existing technical

committees with one RSC, enhanced contact will result between the new

RSC and the NERC Board. More time at Board and MRC meetings is

envisaged to hear a report from the RSC and tee up specific items for

discussion. As well, it is currently a challenge for Trustees to attend the OC,

PC, and CIPC meetings as they occur concurrently.” The truth is that the BOT

have not recently attended any OC meeting, so to assume they might have

time in the future at a RSC is presumptuous. Furthermore, stating that it will

result in more contact is not fact based.

Have the SET reevaluate the impact and attendance

that the restructuring effort at the WECC OC has had

on the WECC OC attendance and engagement.

Explain in detail how this proposal will 1) ensure

NERC Trustees participation, 2) preserve and

enhance BES reliability and 3) encourage and support

industry participation as I believe both of these are at

stake with the SET recommendation.

Tri-State G&T 11

The paper states that the first meeting of the RSC will be in early 2020 and

the existing technical committees will be dissolved. This feels like this is

being forced way too quickly and without key support from NERC industry

participants. In my humble opinion it is a mistake to disassemble the key

industry participants in the current standing committees.

Reevaluate the proposal and develop a

recommendation that has key industry support.

More specifically engage the standing committee

themselves in this discussion before making this

move.

Tri-State G&T 15

The paper has a timeline that does not allow for proper industry input. Why

is NERC and the SET pushing this recommendation that will decrease

industry participation? I simply do not understand.

Recommend the SET conduct open meetings to

gather additional input to guide a recommendation

that will better support BES Reliability through

industry support.

Tri-State G&T

This whole effort seems to have support by the SET, which in all fairness has

representation from the current committee leadership. However, listening

carefully to the comments by members from the Standing Committees, it

must be recognized that this effort is NOT supported by the technical

participants in the Standing Committees. Yet those comments and positions

are not identified nor reflected in this paper.

Start over and involve those that make NERC

successful in the technical areas today. Don't propose

a solution that Silo's NERC with NERC staff and a few

industry participants.

This effort was born out of stakeholder concerns expressed to the NERC Board of

Trustees. In coordination with the Board, the SET was formed to evaluate the

effectiveness and efficiency of the technical committees. The SET consists of a broad

range of stakeholders including technical committee chairs, MRC members, Regional

Entity staff and other industry participants.





Contact Telephone

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Avista 5

Most task forces, particularly the leadership of the task forces, are made up of

OC or PC members. Dissolving these committees will make it difficult to form

effective task forces.

Maintain the present structure.

Avista 5

Work plan coordination between the committees could be accomplished with

a joint leadership meeting on an annual basis. This could be a four hour

meeting coincidental with the quarterly committee meetings.


Avista 9

RSC oversight of tactical priortizations implies less technical involvement at

the RSC level. One of the risks identified at RISC was the loss of industry

expertise due to retirements. This structure appears to exacerbate that issue

by diluting the technical expertise at the RSC compared to the OC, PC, and

CIPC structure.


[email protected]

Segment 1, Segment 3, Segment 5

WECC

509-495-4005

Rich Hydzik, Avista

Avista 9

Task Forces make up a very small percentage of the ongoing work the OC,

PC, and CIPC conduct. Although the work plans may not be coordinated, they

are based on work that continues to be done, and is done for specific

purposes. The Task Forces make sense when a specific issue arises that

crosses committee/subcommittee scopes. However, most reliability issues

requiring some industry action are identified by the subcommittees and their

ongoing tasks and data analysis. Any ongoing work identified by a Task Force

is generally assigned to the appropriate subcommittee.


Avista 10

Functions of the RSC listed on Page 10 are functions that are currently being

carried out by the OC, PC, and CIPC. Those three committees provide the

specialized industry expertise to coordinate, review, and finalize the products

of the functions listed. A combined group of the three committees will have

less depth of expertise in each specialty, but be required to be highly

knowledgeable in all three committee specialties. This will result in the

technical expertise moving from the leadership role in the RSC to the

subcommittees. One could expect that the RSC meetings will become more

general and less specific than the independent OC/PC/CIPC. This is likely to

lead to a decline in the quality of the product of the subcommittees and task

forces, as the clear instructions and scope from the RSC will be more general

and less specific.


Avista 11

Enhanced contact between the NERC Board, MRC and OC/PC/CIPC could be

handled by staggering the OC/PC/CIPC meetings during the meeting week.

This would allow anyone to attend more than one meeting. It would also

allow for a smaller venue, as all three meetings would not be occurring at

once.

Maintain the present structure. Examine options

regarding OC/PC/CIPC meeting overlap to allow BOT

and RISC participation in meetings.

Avista

Membership of the RSC would no longer include a Regional Entity

Representative (Sector 11). This Regional Entity Representative may be an RE

employee or someone else from a registered entity in a particular RE. The RE

Representatitve provides a regional perspective for the RE that may not be

captured by the proposed structure. Footnote 5 indicates that Sector 11

would be non-voting participants at the RSC meetings.





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Richard Field - Hoosier Energy REC, Inc. 13

I worry that at-large membership selection will be skewed towards large

IOU's. The mechanism proposed does not set a minimum number for

representative groups - each sector and each area of expertise. Even within

the CIPC, which is the group I am associated with, there are a number of

areas of expertise represented - cyber security, physical security, operations,

policy. I would imagine the PC and OC are the same. How will the

consolidated group capture the varying interests currently represnted by the 3

committees?

Provide more details around representation and

ensure one industry segment does not monopolize the

RSC.

THE SET IS RE-EVALUATING THE PARTICIPATION MODEL. UPDATE WHEN

FINAL MODEL IS DEVELOPED.

Richard Field - Hoosier Energy REC, Inc. noneLike the last gentleman who provided comments on the audio call indicated, I

am skeptical that any real efficiencies will be gained.

If efficienes are to be gained, please outline them in

detail. I am not seeing how this is more

Richard Field - Hoosier Energy REC, Inc. none

The CIPC has been instrumental is making sure members of the committee

have been granted secret level security clearances through the Private Sector

Clearance Program. With the number of individuals serving on the new RSC

board, my fear is the new committee will not sponsor as many people in the

cybersecurity field for clearances. Access to secured briefings has been a

major benefit to many organizations, mine included.

Detail how clearances will be handled in the future.

The Electricity Subsector Coordinating Council, where NERC is represented on its

steering committee, is engaged and working very hard with DOE and DHS on

the topic of security clearances. Also, in August of 2017, a White House

advisory group, the President’s National Infrastructure Advisory Council (NIAC),

has released an 11-step report urging the Administration to take action to

protect against “a watershed, 9/11-level cyber attack.” This report, called

Securing Cyber Assets: Addressing Urgent Cyber Threats to Critical

Infrastructure, recommends, among other things, that government “streamline

and expedite security clearance process for owners of the nation’s most critical

cyber assets, and expedite the siting, availability, and access of Sensitive

Compartmented Information Facilities (SCIFs) to ensure cleared owners and

operators can access secure facilities within one hour of a major threat or

incident.

[email protected]

Richard Field - Hoosier Energy REC, Inc.

Cooperative Utility (sector 3)

Reliability First

812-876-0320

https://www.dhs.gov/sites/default/files/publications/niac-cyber-study-draft-report-08-15-17-508.pdf














Richard Field - Hoosier Energy REC, Inc.

The three groups together is too broad to have a lot of interests in common.

If this proposal does end up being implemented, I would suggest more

specific break-out sessions and training opportunities. As I mentioed earlier,

even within the CIPC the content is overly broad. If anything, more specific

meeting topics is desired, not less.

Breakout sessions for specific topics relevant to sub

groups.

Beyond this, I sign off on the comments submitted by the Reliability First

CIPC. NERC and the E-ISAC, while not capable of sponsoring security clearances, will continue to share these important stakeholder requirements with government partners in the US and Canada. Even if the clearance situation improves, a vast majority of industry personnel will not have security clearances, so cleared E-ISAC personnel will continue to work with government partners to get information declassified for rapid sharing across the sector via unclassified methods





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Thomas Foltz on behalf of American Electric Power Entire Document

A robust and systematic selection process must be developed and used to

ensure the Reliability and Security Council is staffed only by individuals

possessing a high level of the appropriate subject matter expertise. The

topical scope, as well as the reduced number of committee members, makes

this already-important need even more so.





Industry Segment (if applicable):

Region (if applicable):

Contact Telephone:

Contact Email:


Bonneville Power Administration (BPA) General summary &

requestBPA appreciates this opportunity to provide comments. The SET members

did a commendable job in digging into specific functions and role of the

Technical Committees and designed a proposal that that BPA generally

supports.

BPA would like for NERC to implement appropriate metrics in order to

measure over a period of time, duration to be determined, the efficiencies

and effectiveness gained that would ultimately results to cost savings. BPA

also encourages MRC and the Board to be open in modifying, as necessary, if

the new structure is deterring from the ultimate goals and objectives were set

to meet

The proposal is silent whether a member serving in RISC could also be a

nominee and get selected in RSC? And could we have a member of RISC and

a member of RSC be from the same company?. Further clarifications would

be needed as it will ease the nomination and selection processes for RSC.

There are no restrictions on participation in the RISC and the RSC other than

having more than one representative from company or its affiliates.

It is our recommendation that chair and vice chair of each technical

committees to be part of initial RSC membership. This will also allow for a

more speedy transition after Board approval of the RSC, and it will avoid

creation of a gap between the e existing committees disband and when the

new RSC is seated to ensure that review and approval of subcommittee,

working group, and task force work products continues without

interruption.



614-716-5849

[email protected]

Thomas Foltz on behalf of American Electric Power

N/A

N/A

Proposed

Participation Model

Jeff Cook, BPA

Government

WECC

360-418-8981

[email protected]



Transition from the

three technical

committees to the

RSC

It is our recommendation that chair and vice chair of each technical

committees to be part of initial RSC membership. This will also allow for a

more speedy transition after Board approval of the RSC, and it will avoid

creation of a gap between the e existing committees disband and when the

new RSC is seated to ensure that review and approval of subcommittee,

working group, and task force work products continues without interruption.

For transparency, the new committee should continue to post its meeting

agendas, materials, and presentations publically on the NERC website

consistent with current practice. And offer greater availability of webinar /

phone options for meetings.

Lastly, RSC members should continue to maintain and enhance the necessary

coordination and involvement with EPRI, North America Transmission Forum,

North America Generation Forum, National Labs, and all stakeholders in

setting the appropriate priorities of work for subcommittees, workgroups,

teams, and subject matter experts. This approach will further avoid the

duplications of work.

It is expected that RSC meeting will continue to be operated as the OC, PC and CIPC

meetings are conducted today. All meetings will be noticed and documents will be

posted to the NERC web site. The SET envisions that the educational and training

opportunities as well as interaction with others such as DOE, EPRI, IEEE, etc. will

contunie under the new structure.





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Ameren 3

Diluting the technical expertise of the NERC CIPC/OC/PC down to one

oversight committee would affect the ability to guide and staff the subgroups

and working groups with volunteers. The members of these subgroups are

often identified by the current Technical Committees based on their expertise

in particular areas. A request from one of the Technical Committees' Officers

or Members would usually compel those asked, to serve.

Ameren 11

One of the reasons for the proposal is to reduce costs. This could be

accomplished in other ways, such as reducing the number of meetings from 4

to 3. Another option would be to combine the OC/PC and leave the CIPC

intact. Over the past few years the OC/PC have been working together more

often, and there would be some benefit to be one committee for those topics.





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RF staff person(s) General

We applaud NERC’s efforts to gain effectiveness and efficiency in its activities,

and also not to perpetuate the status quo in order to strive to continuously

improve! The RF comments below are provided by various staff persons and

may not be in agreement by all.

-

RF staff person(s) 5-6

Regarding Option 1: Create an Oversight Committee, this decision would be

adding to the already burgeoning bureaucracy of the NERC group structure.

If an oversight group has no deliverables of its own and is only reviewing

other’s work, that framework does not bode very well for an efficient and

effective structure.

Do not implement this option.

The SET concurs.

RF staff person(s) 7

Regarding Option 2: Replace the OC, PC, and CIPC with a Reliability and

Security Council (RSC), this is a good first step in the right direction and is

easy to implement. However, NERC should consider the comments listed in

the rows below.

Consider the comments and suggestions below.

David Jendras, Ameren

Jeff Mitchell on behalf of various ReliabilityFirst staff persons

Regional Entity

ReliabilityFirst

IOU

SERC

314-554-4904

[email protected]

216-503-0686

[email protected]




We understand the reasons for combining the OC and PC, but feel including

the CIPC isn’t a good idea. The OC and PC are more related to be combined.

There will be many companies who will have a hard time finding an employee

who has the requisite knowledge to understand the issues involved in all

three aspects.

Combine the OC and PC but leave CIPC alone.


This comment reflects the overall structure of the committees. The current

structure allows the individual committees to perform a deeper dive into the

documents that are relevant to the appropriate committee (e.g., the Planning

Committee will only review documents relevant to the planners of the BES).

The proposed structure will dilute the knowledge of the committees (i.e.,

operating personnel would be expected to comment on a document that is

meant for planning personnel). The current structure provides dedicated

personnel to attend the meeting and provide comments to documents.

Leave the current structure as is.


See General Efficiencies on page 11. Will the attendance count be limited?

Folks who used to attend past OC, PC, and/or CIPC meetings may all want to

attend the RSC meetings. Hence, there could be a potential to have 120+

people in the room at the RSC meetings.

Attendance would have to be limited to a manageable

amount.

RF staff person(s) 5 & 10

Currently, the OC and PC do not have any products or deliverables of their

own, and the new RSC does not appear that it will have any of its own

products either. It will be just a review and oversight group. Therefore, is

this really needed and provide a meaningful function? On page 5 of the

report, item 3 states “Most problem solving is occurring at the subcommittee,

working group, and task force level”. If this statement is true (which really is

“all” of the work and report production), then does an “oversight” group,

such as the RSC, provide any value? On page 10 under the Functions, there

are a lot of words that describe the RSC work as “review, endorse”, etc.

There are also other activities such as “develop” and “produce” but this work

would be delegated to a working group or task force with the RSC

“endorsing” the final report.

Could the working groups and task forces be led by

NERC staff with the NERC BoT approving work

products and deliverables? These groups would

obviously have stakeholder experts to perform the

work with NERC staff facilitating the group. The final

deliverable would go to the NERC BoT for approval.

For example, if the RISC determines a certain risk,

NERC staff can assign it to a subcommittee or task

force to provide the deliverable.


Is the Membership structure proper? Are these the proper Sectors? Are

Sectors needed at all? Did the SET consider a better structure for

Membership? Granted, it is much easier to continue using the current

Sectors. But a possible better structure should be considered and explored.

Should the Membership be related to the planning,

operating, and critical infrastructure areas instead

(and possible other areas, such as plant operator,

protection, maintenance, etc.? Or to the various

functional entities, such as GO, GOP, TO, TOP, BA,

etc.?




Option one is adding another layer. So unless the new oversight group

makes assignments and somewhat controls and assesses the work of the

working groups and task forces, this is a step backwards from consolidation.

If this option is selected, the new group would need to assess each existing

group’s charter and work plan, move forward the items that make sense, and

stop the others. No work should be done without this new team’s

authorization and approval.

none


Option two is merging a few groups. It has merit, but I don’t think it went far

enough.

Recommend taking the OC, OC, CIPC, and include the

CCC, SC, PCGC, and the RISC and decide what roles

are needed and what could be combined. Suggest

they take the OC, PC and CIPC put them under one

group, maybe the RISC. Then take the CCC and SC

and merge them and form a TF of SC work under the

CCC. Maybe move Certification piece of the CCC to

the OLT or CMG. And place standards under the new

CSC (Compliance and Standard Committee). Expand

the RISC to some new name, such as ERO Reliability

and Risk Committee (ERRC) and have them do what

the council has as their role plus the risk piece. In my

mind the OC, PC and CIPC should be identifying issues

and bubbling them up to that group anyway. Why

not have the RISC oversee those groups and provide

direction to address the identified risks? The charge of the SET was to evaluate the effectiveness and efficiency of the technical

committee only.





Contact Telephone

Contact Email

Scott McGough, Georgia System Operations Corporation

N/A

SERC

770-270-7689

[email protected]



GSOC supports the SET's determination that Option 2 would be the better of

the 2 presented options. The SET concurs.

The assignment of appropriate, knowledgeable support personnel is essential

to the success of any advisory council and associated subcommittees, work

groups, and task forces. As NERC is considering its currently allocated

support personnel in light of the revisions proposed by the SET, GSOC

recommends that NERC evaluate its current resources and their associated

knowledge, experience, and skill sets to ensure that it re-allocates

appropriate, knowledgeable personnel to support and administer the RSC’s

activities, which may require higher-level and policy-focused support, as well

as the activities of its subcommittees, working groups, and task forces, which

may require more technical support.

NERC will take this comment under advisement.

11, 12 GSOC recommends that the SET clarify the proposal to reduce the potential

for confusion regarding the intended sector participation in the RSC.

Specifically, the Recommended Participation Model section presently states

that all sectors may not include all existing sectors (page 11) while the

Membership section (page 12) provides a sector member from each Sector

except the RE sector (Sector 11). GSOC supports the maturation of the

participation model and agrees that sectors 1 - 10 and 12 should have at

least one representative on the RSC. However, the current language in the

Recommended Participation Model section could provide for exclusion of

Sector membership beyond the RE, which GSOC could not support. To

ensure clarity, GSOC recommends revising the language on page 11 to state:

"Sector representation from Sectors 1 - 10 and 12 as discussed in Chapter 5."

GSOC proposes to change the 1st bullet under the

Recommended Participation Model section as follows:

"Sector representation from Sectors 1 - 10 and 12 as

discussed in Chapter 5."

The SET concurs and has made this edit.

Because the consolidated oversight responsibilities of the RSC will address

three major areas of expertise, GSOC recommends that NERC consider

expanding sector representation to 2 representatives per sector and reducing

the amount of At-Large representatives. As currently proposed, sectors will

have to choose a subject matter expert in 1 or possibly 2 of the main areas of

responsibility, e.g., operations, operations and planning, or security. The

expansion of sector representation to 2 representatives would alleviate this

and better ensure that adequate expertise is provided for each sector.



7, 10

Page 7 of the proposal provides that the RSC will retain oversight of existing

subcommittees, working groups, and task forces to the extent that they

remain relevant and necessary. Specifically, page 7 provides: Replace the OC,

PC, and CIPC with a single, new RSC, which reports to the Board, overseeing

the work of the

Sub-committees, working groups, and task forces. ... those sub-committees

and working groups with recurring deliverables will be retained, ....

Page 10 of the proposal lists anticipated RSC functions and, while none clearly

provide a delegation or oversight function, several are higher-level. However,

some appear to be geared toward functions already being performed by an

existing subcommittee, working group, or task force. For example, the

operational analysis and event analysis functions appear to be functions

currently performed by the Event Analysis Subcommittee and Reliability

Assessment Subcommittee. Additionally, existing subcommittee, working

group, or task force often perform tasks, activities, etc. that are not explicitly

provided for in their charter. Where existing subcommittees, working groups,

or task forces perform such tasks, activities, etc., it is important that they be

delineated as within the RSC’s overall governance and purview. The list of functions on page 10 is meant to be representative and include various topics

that the RSC will work on and/or delegate to subcommittees, working groups or task

forces.

For this reason, GSOC is concerned that the language of the proposal may

require clarification as to whether the RSC: (1) is intended to perform

functions where there is an explicit statement, (2) can then delegate such

functions (whether such function is stated or implied through transference of

the existing subcommittee, working group, or task force), and/or (3) has

responsibility to oversee/approve the performance of functions by its

subcommittees, working groups, and task forces. GSOC recommends that the

SET evaluate the proposed functions to determine if there is a need for

revision and the addition of an oversight/delegation function and/or

responsibility.

The list of functions on page 10 is meant to be representative and include various topics

that the RSC will work on and/or delegate to subcommittees, working groups or task

forces.

In the Membership section, the proposal makes reference to the need for

"balanced representation and expertise" relative to the proposed membership

of the RSC. While GSOC supports the overall membership approach and

concept provided, it recommends that criteria be developed to ensure that

"balanced representation and expertise" is achieved. Such criteria should be

developed relative to expertise representation in all potential membership

classes (sector, At-Large, etc.) and to attaining sector-balanced

representation in the At-Large class, e.g., limiting the overall representation

of sectors in the At-Large class.

Without defined criteria, sectors and entities interested in participation will be

unable to identify their most appropriate candidates and there is a potential

that sectors with access to greater resources could engage in sector blocks

through membership in the At-Large class by occupying a disproportionate

number of seats. As an example, GSOC provides the following example

criteria: Sector/At-Large representation shall be balanced through

membership of 3 or 4 representatives with operational experience, 3 or 4

representatives with security experience, and 3 or 4 representatives with

planning experience or No more than 40% of the Sector or At-Large

representation shall have the same experience-type, e.g., operating, planning,

or security. At-Large representation shall be balanced amongst the sectors by

ensuring that no more than 4 representatives from one (1) sector occupy

seats in concurrent or overlapping terms.

Add criteria to ensure "balanced representation and

expertise" within the RSC. Example criteria language

is provided below: ctor/At-Large representation shall

be balanced through membership of 3 or 4

representatives with operational experience, 3 or 4

representatives with security experience, and 3 or 4

representatives with planning experience

or

No more than 25% of the Sector or At-Large

representation shall have the same experience-type,

e.g., operating, planning, or security.

At-Large representation shall be balanced amongst

the sectors by ensuring that no more than 4

representatives from one (1) sector occupy seats in

concurrent or overlapping terms.

THE SET IS RE-EVALUATING THE PARTICIPATION MODEL. UPDATE WHEN FINAL MODEL

IS DEVELOPED.

14 GSOC recommends additional clarification regarding the membership of

sectors in the Executive Committee on page 14. Without additional

information and/or details, it is unable to evaluate whether there are

appropriate controls to ensure balanced sector representation. For example,

can the Chair and Vice-Chair be from the same sector? Must the 4

represented sectors differ from the sectors of the Chair and Vice-Chair?


IS DEVELOPED.

GSOC recommends that the selection of representatives for each class of

membership appropriately reflect the best GSOC recommends that the

selection of representatives for each class of membership appropriately reflect

the best practices that have been identified from the existing committees.

Accordingly, GSOC recommends that each sector be allowed to elect its

representatives for the sector class members and that At-Large and other

membership classes have representatives selected by a nominating or

oversight committee.

Finally, GSOC supports the Board level approval mechanisms for nominated

representatives.


IS DEVELOPED.

As substantial work efforts are to be performed in subcommittees, etc., which

will be topically focused, with approval or deliverables by the entirety of the

RSC. For this reason, GSOC recommends that clear and consistent voting

procedures be defined for the RSC and its associated subcommittees, working

groups, and task forces and to ensure that representation is appropriate and

balanced. Voting procedures will be clearly defined in the RSC Charter.





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PPL NERC Registered Affiliates generally support Option 2 for restructuring

with the following proposals for clarifications and changesSee below

RSC membership should have a term limit.THE SET IS RE-EVALUATING THE PARTICIPATION MODEL. UPDATE WHEN


The Membership Selection portion of the proposal

should require that the RSC consider inclusion of

owners/operators from each region.



The current OC/PC/CIPC quarterly meetings provide a great source of

information sharing.

It would be beneficial to clarify that the RSC meetings

will be open for Registered Entity attendance, and not

would not be limited to the proposed 30 members.It is envisioned that RSC meetings will be open similar to current OC, PC and CIPC

meeting conduct.

Consider allowing the OC, PC, and CIPC

subcommittees, working groups, and task forces to

meet in coordination with the RSC meeting.

Clarify how the RSC meetings will incorporate the

information sharing and awareness that current

occurs at CIPC (e.g. through readouts from associated

entities; National Labs; EISAC)

Meetings will include subcommittee reports, Lessons Learned, emeerging issues among

other topics as selected by the RSC Executive Committee with general stakeholder

input. This is similar to the current practice of the technical committees.





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Exelon All

Exelon agrees the current NERC committee structure would benefit from

changes that eliminate silos and improve coordination between technically

focused subcommittees. Exelon supports Option 2 of the Proposal for

Restructuring NERC Technical Committees. Thank you for your comment.





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The announcement indicates that the SET is seeking stakeholder input on the

following:

1. The proposal to replace the NERC CIPC, OC, and PC with the RSC.

A consequence of the proposed reduction is that the technical breadth and

capabilities of the new Committee will be substantially reduced, which appears to

conflict with key considerations for this review, suggesting that new and unfamiliar

technologies are being developed, risk profiles are changing and speed of change is

accelerating. Accordingly, an environment of this nature would suggest it is necessary

to ensure industry committees have the appropriate expertise and bandwidth

available to adequately assess and address these realities. There is also no indication

that the amount of work for each technical sector (planning, operations, CIP) will be

reduced to match the reduced committee capabilities. If it is not, then future

technical meetings with the RSC replacing the PC, OC, and CIPC must inevitably be

longer as well as being reduced in quality due to the limited representation in each

sector. RSC membership will respond poorly to agendas where 2/3 of the topics for

each meeting are relevant to only 1/3 of the participants.

RF, SERC

Devin Shines 502-408-6253

[email protected]

PPL NERC Registered Affiliates

1, 3, 5, 6

[email protected]

Tennessee Valley Authority (TVA)

Exelon (On behalf of all Exelon business units)

Segments: 1, 3, 5, and 6

MRO, NPCC, RF, SERC, TRE, WECC

(779) 231-1352

Segments: 1, 3, 5, 6 / Sector: 4

SERC

423-751-8721

[email protected]

It is strongly recommended that the proposal be revised

with formation of the Oversight Committee as the

recommended action. (Option 1)




The proposed RSC is described as providing a new formal oversight that combines the

experience of the present three committees, but there is no indication of how

experience from the present committees will be transferred to the RSC. More

correctly, the RSC combines the responsibilities of the three committees, while

simultaneously reducing its capabilities to meet those responsibilities.

The RSC is described as increasing effectiveness and efficiency by providing end to

end solutions, through direction of the existing subgroups of the present

Committees. It is not described how a much smaller committee with a substantially

narrower representation of technical skills would be able to offer improved guidance

to these subgroups.

The single RSC is described as providing enhanced contact with the NERC Board.

Since it will have a substantially narrower breadth of technical skills, this

enhancement will not to be in the technical area. The alternative is that the RSC will

spend less time with the Board than is required for the present Committees, and that

this is considered an improvement.

2. The proposed participation model of the RSC.

As proposed, only one representative from each sector (excluding sector 11) may be

a member of the RSC. If TVA were to fill the Federal/Provincial seat for example, or

alternatively one of the at-large seats, that individual would have to cover the full

range of subjects – planning, operations, and CIP – for the three physically separated

and very different Federal entities. Even with a substantial increase in work to

prepare in advance of meetings, which will be required both of the NERC meeting

organizers as well as the participants, this will ensure delays in responses and reduce

the efficiency and effectiveness of participants.

See recommendation under item #1 above. If the RSC is

pursued in lieu of Option 1, consider the use of two voting

members for each sector -- possibly reducing the number

of at-large members.


IS DEVELOPED.

It is noted that the requirement for membership qualifications emphasizes senior

management and project management capabilities, and does not include the in-

depth technical capabilities that many members now have. This will significantly limit

the ability of the Committee to provide the technical oversight and guidance that is

presently provided by the technical committees to their subgroups. There is no

indication of where this important contribution will come from in the future. The

definition of Membership Qualifications is well suited to the SCCG, also for the

postulated Oversight Committee, but for the RSC it lacks understanding of the

technical dimension that subgroups need to be overseen and guided.


pursued in lieu of Option 1, consider an emphasis on

technical capabilities of the membership that will

collectively address the wide array of issues to be vetted.


IS DEVELOPED.

3. The best way to implement the transition from three technical committees to

the RSC.

The proposal to implement Option 2 (RSC) by early 2020 seems "rushed".

Accomplishing Option 1 by early 2020 is more practical. Upgrading the SCCG to an

Oversight Committee as an interface between the Technical Committees and the

NERC Board, appears to offer many benefits with the potential to respond to

recommendations contained in the MRC's February 2018 policy input comments. If a

reduction of membership of any of the committees would be beneficial, this would

be an excellent structure to review the possibilities interactively with the committee

and its leadership, rather than the present proposal to impose a drastic cut of all

committees with virtually no membership discussion or consideration of how its work

scope will be affected.


pursued in lieu of Option 1, consider more time on the

front end to work on the details (charter, timeline) before

calling for nominees. Option 1 could be used as an interim

step in moving to the RSC. Engage the existing technical

committees membership for assistance in developing a

transition plan.

In January, 2020, the RSC would begin work on transitioning from the current

committee structure to the new one. It is expected that this will take several months to

develop and implement.





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Joe Sowell, VP System Planning for Georgia Transmission Corporation

Cooperative

It is strongly recommended that the proposal be revised

with formation of the Oversight Committee as the

recommended action. (Option 1)

SERC

770-270-7779

[email protected]


Input on the proposal to replace the NERC CIPC, OC, and PC

with the RSC

GTC does not support the SET's recommendation for Option 2 in the proposal. The

SET should consider that reducing the three technical committees to a single and

much smaller committee will certainly reduce the input of the electric industry at the

NERC committee level which will have a negative impact on future new and revised

reliability standards. Other Regional Entities' efforts to improve efficiency, at least in

SERC's case, resulted in keeping three technical committees. An alternate to Option

2 may be to only combine the PC and OC as many items in these committees overlap,

but cyber security rarely overlaps with planning and operations.

Input on the proposed participation model of the RSC

Should Option 2 be approved by the NERC BOT, GTC recommends to expand the

sector membership so that there are two representatives from each of the 11

Sectors, thereby reducing the At-Large members to 7 if the desire is to keep the total

membership at 33 to try and address the above comment on electric industry input.

Consideration should also be given to the workload of the RSC as well as to the

available knowledge base of potential candidates. RSC meetings will have to span

multiple days to review and provide direction to working groups. RSC members with

experience in all three committee levels may be difficult to find. An alternative to

Option 2 may be to only combine the PC and OC as many items in these committees

overlap, but cyber security rarely overlaps with planning and operations.


IS DEVELOPED.

Input on the best way to implement the transition from the

three technical committees to the RSC

GTC recommends to wait for NERC BOT approval prior to offering input on a

transition plan. Whatever plan is approved, NERC should focus on industry

engagement as there appears to be less and less actual engagement. People are

attending the technical committee meetings but are not actually engaged in the

discussions of issues related to the BPS. This lack of engagement seems to stem from

the prescriptive approach to revising standards rather than keeping with an intent

approach. People are less engaged when discussing modeling tasks versus the intent

of how a BPS should operate and respond.





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NPPD 7

I do not agree with implementing Option 2.

As the current chair of the Supply Chain Working Group (SCWG), the skill set

of individuals for each of the current committees is too diverse to expect one

individual to understand and stay current in the three major areas of the

current committees (OC, PC and CIPC). The cyber security topics discussed

by my working group are understood by the members of CIPC, but would be

difficult to follow and understand by members of the other committees; and

likewise for cyber security professionals to understand operations and

planning issues and be able to provide leadership to our industry.

Combining the three current committees into one council will reduce the

number of seats at the council meetings and severely limit opportunities for

entities to participate in NERC. Direction of NERC will be concentrated in a

few individuals with focused interest in what they are concerned without the

current broad representatation from diverse groups across North America.

Council meetings will, by necessity, be much more high level and not able to

understand the issues in enough detail to make good decisions. Groups, such

as the national laboratories and industry groups (NATF, EPRI, EEI, etc.) will

not have a voice in this smaller council approach.

Any cost savings realized by eliminating the three separate committee will be

lost because Council meetings will need to span multiple days and entities will

have to find alternative means to do the work that was being done in the

committees.

Implement Option 1




Tony Eddleman - Nebraska Public Power District (NPPD)

1, 3, 5

MRO

402-845-5253

1

[email protected]

ITC Holdings Corp.



Contact Telephone

Contact Email


ITC Holdings Corp 11

ITC supports the comments submitted by EEI. In addition, ITC would like to

have clarification on what is meant by "RSC meetings will continue to be

conducted as open meetings…" At a recent OC meeting, there was discussion

that the RSC meetings may be set up as members-only face to face and

WebEx for listen-only participation of observers. This would limit who is

allowed to speak at the meetings (i.e. only voting members would have the

ability to speak and all others would be muted). ITC is concerned that

industry involvement in the RSC will decrease drastically if the opportunity to

actively participate in the meetings is not open to all those who wish to

attend, not just the voting members.

ITC would like to ensure that the RSC meetings are

open to observers and they have the opportunity to

participate.

The RSC meetings will be open to observers as the current technical committee

meetings. Meeting registration will be sent to industry well in advance of the

meeting.





Contact Telephone

Contact Email


Great River Energy V

The published Reliability and Security Council (RSC) proposal, with the

statement, "The recommendation will be provided to the Board prior to

December 2019 for approval", suggests a forgone conclusion without wide

industry input. It also appears to lack transparency that industry would

expect for such a major change. Further, it appears that the SET, by

concluding that a drastic reorganization was warranted, is not meeting the

obligations specifically requested by the NERC BOT as mentioned on page V

of the proposal, which was to perform a "...comprehensive review of the

technical committee structure and actions that could be taken to improve the

effectiveness and efficiency of those committees". The board - and

stakeholders - should be presented with a more thorough investigation of the

issues and multiple options for addressing them.

Consider comments from industry and consider those

at a future well-advertised and open SET meeting.

Create a time-line for comment replies and proposal

revision.

Empower the SET to produce a set of proposals from

the simple (for example: combining OC/PC), to the

more profound (for example: RSC Option 2), with full

cost-benefit and stakeholder-impact analysis of each

option.

Publish a clear problem statement so stakeholders can

understand what each proposal attempts to address.

If it's cost, say so. At very least, the SET should

authoritatively state why the vision specified in

Chapter 2 is NOT being addressed by the current

committee structure.

NOTE: These comments are the same as Basin electric below.

Great River Energy 1

Information regarding the RSC proposal is difficult to find on the NERC

website.

Meeting notes/minutes were not provided to industry. Additionally, the

proposal states that the current technical committee members were surveyed

for input on the existing committee structure, but the survey results were not

made public. Being able to review the non-attributable survey results and

meeting notes/minutes would help stakeholders better understand the

decisions made by the SET and the views of the technical committee

members.

As follow-up to the August BOT meeting, create a

project page for the RSC proposal and supporting

documents. To address early comments, SET should

ramp up their outreach to industry, up to and

including engaging NERC's public relations staff.

Additionally, and in particular to CIPC, notably absent

from the discussion thus far has been any mention of

the impact to, or involvement with, the E-ISAC. Their

voice should be louder in the potential loss of

stakeholder engagement due to the proposed

retirement of the CIPC and their 500+ followers.

SUGGUST WE SET UP A WEB PAGE WITH AGENDAS AND MEETING NOTES.

Also, need to address E-ISAC comment.

MRRE (RF, MRO)

248-946-3189

[email protected]

763-445-5961

[email protected]

Michael Brytowski, Great River Energy

Cooperative

MRO




There seems to be a premise that because the industry is changing and

because the existing committee structure has been in place for over 10 years,

there must be profound changes to the committee structure in order to

adapt. We should question that conclusion.

The SET conclusions as stated on page 2 can be paraphrased as such: the

existing committee "silos" are blurring which indicates that the existing

structure is adapting and that committee use of task forces to address

unfamiliar technologies might bring the agility and multi-disciplinary

collaboration desired.

Perhaps the change needed is more simple: formalize

and leverage the cross-disciplinary role of the SCCG,

and further coordinate and leverage use of task forces

to achieve further stakeholder collaboration across all

disciplines.


The RSC proposal feels that the primary goal was to gain efficiencies in

management of OC and PC work products and that CIPC was simply roped in.

Great River Energy subscribes to the theory that “CIPC is different”, and that

group should be given the latitude to operate as they do today with the

discretion to self-regulate their work product to meet stakeholder and ERO

concerns regarding cyber and physical security.

The CIPC member/observer skill set and expertise is

quite a bit different from the members/observers of

the PC and the OC. They are more IT and security

focused. They have different educational

backgrounds, work experience, and are typically

focused on the information systems that support

planning and operations. They speak a different

language and are more narrowly focused. Suggest

combining OC/PC and keeping CIPC separate with

both reporting to the NERC BOT, with a one-year trial

and measures in place to identify performance against

the Chapter 2 vision statements.


There are no assurances that the 33-member RSC will include sufficient

security expertise, and certainly not in the three discrete areas of security

that the CIPC requires – namely cyber, physical, and operations. As stated in

the proposal the RSC will be looking for “senior management and technical…”

individuals across multiple sectors.

GRE is concerned that there will be a gap in expertise such that emerging

cyber/physical threats may not be recognized and addressed in a timely

manner by the 33-member RSC. GRE acknowledges that the At Large seats

were designed to address such gaps but have reservations about whether or

not this will be effective.

Although more aligned, there could also be a gap within planning and

operations depending on the final makeup of the committee. There may also

be an ability for sector and geographic domination depending on the response

from industry during the nomination process that will be used to fill the At-

Large seats.

If the RSC Option 2 proposal is accepted by the BOT,

GRE would support a proposal to codify mandatory

minimum numbers of operations, planning, and

security representatives within the Sector and At

Large membership groups.

If the sectors are allowed to self-nominate, as

proposed by some earlier commenters, this will put

additional pressure on the At Large seats to fill any

subject matter expertise gaps. The RSC charter must

address how these gaps will be identified and

addressed.




Combining all 3 committees would yield a large - and potentially inefficient -

committee with questionable levels of expertise compared to the existing

structure. Combining the OC and PC is reasonable as long as the sub-

committee structures are carefully identified. However, adding the CIPC into

this mix dilutes the focus of the workplan. If cost is an issue, NERC could

drop number of annual meetings from 4 to 3 to meet the target.

Suggest combining OC/PC and keeping CIPC separate

with both reporting to the NERC BOT.

Additionally: Each technical committee has a NERC

executive sponsor. Empower and charge that person

with the task of justifying the cost of their committee

versus the value of their deliverable. These annual

reports, with metrics, should be presented to the BOT

prior to annual ERO budget kickoffs.


By combining the OC/PC/CIPC technical committees, there will be a reduced

number of active industry participants in quarterly meetings. This creates a

risk of shrinking the volunteer pool of contributors within the subcommittee

structure.

The proposed model would be more reliant on the subcommittees with less

participation at the committee level which could present issues with industry

participation.

The number of casual observers would decrease substantially. This may lead

to less participation at the sub-committee level since many of these volunteer

assignments are drafted by these engaged observers, which may include

vendors, trade groups, and government partners. This is the opposite of what

is intended.

Prior to release of the final proposal and before

presentation to the NERC BOT in November, the SET

should prepare a discussion draft of a typical RSC

committee meeting agenda, annual calendar,

communications plan, and a full analysis and set of

recommendations for the non-workgroup/subgroup

activities, briefings, and other intangible benefits that

stakeholder enjoy when attending the quarterly

OC/PC/CIPC meetings that will be lost.

For CIPC in particular, stakeholders would like to see a

statement from the E-ISAC acknowledging their

intention to 'inherit' some of the responsibilities of

CIPC such as free security workshops and classified

briefings.

Great River Energy

GRE is concerned that the focus of the committees and more limited

engagement with industry which we believe is the antithesis of the intent.

This concern is heightened with the increase in change that is occurring

within the industry. NERC also needs to keep observer options open for in-

person rather than just webinar attendance. Hallway conversations are a big

part of it as well. Listen-only webinars do not allow for interactions.

GRE would like to specifically request that stakeholder

"forums" be included in the final proposal to replace

the concentrated dialog that is an intangible benefit to

observers of the quarterly technical committee

meetings. The proposed expanded meeting space at

the Atlanta offices would make for a cost-effective

option for hosting these events.

Great River Energy

What will the meeting structure look like? A lot of behind the scenes

discussions will have to take place before the meetings so that members are

adequately briefed on operating, planning and CIP issues.

This structure has the potential to reduce transparency.

SET should provide discussion drafts of RSC meeting

agendas and calendars to help stakeholders

understand the mechanics of Option 2.


If the RSC proposal is accepted and implemented, GRE would call on NERC to

provide a once or twice-per-year ‘CIP Forum’ to replace the portions of the

current CIPC that were not addressed in the proposal.

- Briefings by DOE, DHS, FERC, CEA, RCMP, Public Safety Canada on national

& continent wide security initiatives

- Callouts from stakeholder groups such as EPRI, NATF, NAGT, and EnergySec

on products that are available to asset owners that are under development by

these organizations

- Two-way discussions with the NERC CIP drafting team(s)

- Briefings from E-ISAC on notable recent cyber and physical security trends

and shares

- NERC staff updates on other security initiatives (Supply Chain, RSC, RISC)

- Emerging issues ‘roundtable’

- Space for workgroup and task-force face-to-face meetings that are open to

observers and those who wish to be more engaged with ERO security efforts

- Synchronized with GridSecCon to ensure no duplication of topics/speakers

GRE would like to specifically support the E-ISAC

“inheriting” residual CIPC products:

- Offering security training that go beyond the

once/year GridSecCon (webinars, face-to-face).

Compliance-related training that CIPC offers might be

challenging for them, but are valuable “freebies” that

CIPC offers today.

- Twice per year classified briefings

- Help with security clearances

- Maintain the physical security advisory group

- Charter a corresponding cybersecurity advisory

group

- Take full ownership of the GridEx working group (co-

managed by CIPC today)

- Take full ownership of the Security metrics working

group (managed by CIPC today)

The E-ISAC is in the second year of executing its five-year Long-term Strategic

Plan to build the capacity, expertise, and capabilities to support these programs

and topics. This comprehensive list provides solid stakeholder requirements that

will help guide the remaining years of the Plan and the products and services

the E-ISAC will offer to members and partners.





Contact Telephone

Contact Email


ACES N/A

Replacing the Technical Committees with the RSC seems to allow efficiency

gains on the surface. A concern with this approach is the level of expertise

residing on the RSC. Having segment representation does not in itself

provide the right level of expertise for the initiatives taken place at the

current sub-committee levels.

It is recommended that technical expertise be a

criteria in selection of the RSC members.

ACES N/AThere are Regional Entities that utilize the current technical committee

structure. In the design of the new structure please provide a section on the

relationship the RSC will have with the Regional Entity Committees.

ACES N/AIn terms of CIPC, there existed training offerings. It is requested that these

offerings are evaluated within the design of the new structure.

ACES N/AIt is recommended that in the design of the new structure that collaboration

opportunities with trade groups are maintained.





Contact Telephone

Contact Email


Stuart Brindley

N/A

ACES

Segment 6

N/A

919-218-9658

[email protected]

N/A

905 464-4211

[email protected]



Stuart Brindley 5

Re point #1, not just "most", but virtually all of the work has always been

performed at the subcommittee, working group, and task force levels. This is

not new.

Given the volume of work performed by the groups

subordinate to the Committees, opportunities for

increased efficienciencies rests much more with these

groups than at the Committee level. It is not clear

that the SET considered the work of these

subordinate groups, which might represent 95% of

the Committees' efforts. The SET should consider

including in their review, at least at a summary level,

the nature and volume of work performed by the

subordinate groups. Alternatively, the SET should

provide common criteria or guidance that would help

the RSC determine the relative value of this work

across the OC, PC, and CIPC subject matter areas.

Suggest we have OC, PC and CIPC evaluate existing subcommittees and provide

a report to RSC in March with recommendations for any structural/topic

changes.

Stuart Brindley 5

Re point #4, I could be wrong but my sense is there may be more gaps in the

work of the Committees, than there are uncooordinated overlaps.

Consider including some examples of "uncoordinated

results" along with an explanation for why it could not

be improved under the existing Committee structure.

This might help the RSC ensure they develop

appropriate mechanisms to prevent this from

happening in future.

Stuart Brindley 7

First paragraph under Option 2 says that recurring deliverables will be

retained. I suggest that just because a deliverable is recurring, doesn't mean

it is of sufficient value to keep doing it.

Consider revising this paragraph to propose that all

subcommittee, working group, and task force work

should be reviewed for synergies and streamlining.

Also, consider developing criteria or guidance that

would help identify and prioritize streamlining

opportunities.

Stuart Brindley 8I support the SET's proposal for better aligning Committee work with the

RISC. Thank you for your support.

Stuart Brindley 8

Under Option 2, "… the RSC has an opportunity to complete its analysis of all

ongoing activities…"

This would not be a trivial task for the RSC given the

large number of subcommittees, working groups, and

task forces. I suggest that the SET should provide

common criteria or guidance that would at least help

the RSC in its formative stage determine the relative

value of this work across the OC, PC, and CIPC

subject matter areas.

Suggest we have OC, PC and CIPC evaluate existing subcommittees and provide

a report to RSC in March with recommendations for any structural/topic

changes.

Stuart Brindley 10

The list of the RSC's 11 functions vividly illustrates the substantial scope and

technical depth of subject matter expertise required to perform its role. Faced

with this scope of work, unless guided otherwise, the RSC may decide it

needs to introduce an additional organizational layer to provide adequate

oversight. This would eliminate any expected efficiency improvements.

If the SET is recommending that the RSC should not

introduce additional organizational layers between it

and the working-level groups, the SET should indicate

so explicitly. Any limits to the RSC's ability to self-

organize should be specified.

The list of functions on page 10 is meant to be representative and include

various topics that the RSC will work on and/or delegate to subcommittees,

working groups or task forces.

Stuart Brindley 10

Under "Purpose" what is meant by "… in conjunction with NERC

management…" ?

The SET should define more explicitly the respective

roles of NERC/E-ISAC management with the RSC and

vice versa. While I understand broadly that both

should collaborate and coordinate, it would be helpful

for the RSC to understand any limitations. For

example, role relationships could be advisory,

supportive, directive, must consult, or authority to

approve. Similarly, the SET should propose what

support NERC can provide to the RSC. If it is similar to

the secretariat and meeting logistics support currently

in place for the 3 committees, it might be worth

stating that. Or identify how it will be different. From

my experience, deliverables are best achieved when

the group is supported by NERC staff/contractors who

facilitate discussions and take care of the heavy-lift

items. This minimizes the effort required of industry

members and allows them to focus their expertise

where it is most needed.

E-ISAC relationship will be more fully vetted.

Stuart Brindley 11

Under "General efficiences", the opportunity to increase efficiencies by

combining the Committees refers only to Committee members. However,

currently, many other individuals regularly attend Committee meetings. The

proposal suggests meetings will continue to be open, and interest should not

be expected to decrease. For example, CIPC has around 30 members and yet

over a hundred attend every meeting. Therefore the implied efficiences of

120 members down to 40 may be substantially less than expected.

The SET should explicitly consider non-members who

attend RSC meetings and how they could affect

expected efficiency improvements.

Stuart Brindley 12

Under "Expectations", "the RSC will be responsible for ensuring the work … is

completed in coordination with the CCC, SC, PCGC, RISC."

The SET should consider proposing how the RSC will

coordinate with these other committees. Alternatively,

provide background on how coordination has been

deficient under the current structure so the RSC can

develop mechanisms to enhance coordination in

future. Also, given that industry members also

participate on non-NERC stakeholder groups (e.g.,

NATF, GATF, trade associations), the SET should

propose that the RSC recognize these other groups

and explicitly consider and address potential overlaps.





Contact Telephone

Contact Email


Basin Electric Power Cooperative V

The published Reliability and Security Council (RSC) proposal, with the

statement, "The recommendation will be provided to the Board prior to

December 2019 for approval", suggests a forgone conclusion without wide

industry input. It also appears to lack transparency that industry would

expect for such a major change. Further, it appears that the SET, by

concluding that a drastic reorganization was warranted, is not meeting the

obligations specifically requested by the NERC BOT as mentioned on page V

of the proposal, which was to perform a "...comprehensive review of the

technical committee structure and actions that could be taken to improve the

effectiveness and efficiency of those committees". The board - and

stakeholders - should be presented with a more thorough investigation of the

issues and multiple options for addressing them.

Consider comments from industry and consider those

at a future well-advertised and open SET meeting.

Create a time-line for comment replies and proposal

revision.

Empower the SET to produce a set of proposals from

the simple (for example: combining OC/PC), to the

more profound (for example: RSC Option 2), with full

cost-benefit and stakeholder-impact analysis of each

option.

Publish a clear problem statement so stakeholders can

understand what each proposal attempts to address.

If it's cost, say so. At very least, the SET should

authoritatively state why the vision specified in

Chapter 2 is NOT being addressed by the current

committee structure.

Basin Electric Power Cooperative 1

Information regarding the RSC proposal is difficult to find on the NERC

website.

Meeting notes/minutes were not provided to industry. Additionally, the

proposal states that the current technical committee members were surveyed

for input on the existing committee structure, but the survey results were not

made public. Being able to review the non-attributable survey results and

meeting notes/minutes would help stakeholders better understand the

decisions made by the SET and the views of the technical committee

members.

As follow-up to the August BOT meeting, create a

project page for the RSC proposal and supporting

documents. To address early comments, SET should

ramp up their outreach to industry, up to and

including engaging NERC's public relations staff.

Additionally, and in particular to CIPC, notably absent

from the discussion thus far has been any mention of

the impact to, or involvement with, the E-ISAC. Their

voice should be louder in the potential loss of

stakeholder engagement due to the proposed

retirement of the CIPC and their 500+ followers.


There seems to be a premise that because the industry is changing and

because the exisitng committee structure has been in place for over 10 years,

there must be profound changes to the committee structure in order to

adapt. We should question that conclusion.

The SET conclusions as stated on page 2 can be paraphrased as such: the

exisiting committee "silos" are blurring which indicates that the existing

structure is adapting and that committee use of task forces to address

unfamiliar technologies might bring the agility and multi-disciplinary

collaboration desired.

Perhaps the change needed is more simple: formalize

and leverage the cross-disciplinary role of the SCCG,

and further coordinate and leverage use of task forces

to achieve further stakeholder collaboration across all

disciplines.

Mike Kraft, Basin Electric Power Cooperative

Cooperative

MRO and WECC

701-557-5522

[email protected]



The RSC proposal feels that the primary goal was to gain efficiencies in

management of OC and PC work products and that CIPC was simply roped in.

Basin Electric Power Cooperative subscribes to the theory that “CIPC is

different”, and that group should be given the latitude to operate as they do

today with the discretion to self-regulate their work product to meet

stakeholder and ERO concerns regarding cyber and physical security.

The CIPC member/observer skill set and expertise is

quite a bit different from the members/observers of

the PC and the OC. They are more IT and security

focused. They have different educational

backgrounds, work experience, and are typically

focused on the information systems that support

planning and operations. They speak a different

language and are more narrowly focused. Suggest

combining OC/PC and keeping CIPC separate with

both reporting to the NERC BOT, with a one-year trial

and measures in place to identify performance against

the Chapter 2 vision statements.


There are no assurances that the 33-member RSC will include sufficient

security expertise, and certainly not in the three discrete areas of security

that the CIPC requires – namely cyber, physical, and operations. As stated in

the proposal the RSC will be looking for “senior management and technical…”

individuals across multiple sectors.

BEPC is concerned that there will be a gap in expertise such that emerging

cyber/physical threats may not be recognized and addressed in a timely

manner by the 33-member RSC. BEPC acknowledges that the At Large seats

were designed to address such gaps but have reservations about whether or

not this will be effective.

Although more aligned, there could also be a gap within planning and

operations depending on the final makeup of the committee. There may also

be an ability for sector and geographic domination depending on the response

from industry during the nomination process that will be used to fill the At-

Large seats.

If the RSC Option 2 proposal is accepted by the BOT,

BEPC would support a proposal to codify mandatory

minimum numbers of operations, planning, and

security representatives within the Sector and At

Large membership groups.

If the sectors are allowed to self-nominate, as

proposed by some earlier commenters, this will put

additional pressure on the At Large seats to fill any

subject matter expertise gaps. The RSC charter must

address how these gaps will be identified and

addressed.

The SET is evaluating the participation model. Need to update this when we finalize it.


Combining all 3 committees would yield a large - and potentially inefficient -

committee with questionable levels of expertise compared to the existing

structure. Combining the OC and PC is reasonable as long as the sub-

committee structures are carefully identified. However, adding the CIPC into

this mix dilutes the focus of the workplan. If cost is an issue, NERC could

drop number of annual meetings from 4 to 3 to meet the target.

Suggest combining OC/PC and keeping CIPC separate

with both reporting to the NERC BOT.

Additionally: Each technical committee has a NERC

executive sponsor. Empower and charge that person

with the task of justifying the cost of their committee

versus the value of their deliverable. These annual

reports, with metrics, should be presented to the BOT

prior to annual ERO budget kickoffs.The participation model is being refined. Need to update this with final participation

model


By combining the OC/PC/CIPC technical committees, there will be a reduced

number of active industry participants in quarterly meetings. This creates a

risk of shrinking the volunteer pool of contributors within the subcommittee

structure.

The proposed model would be more reliant on the subcommittees with less

participation at the committee level which could present issues with industry

participation.

The number of casual observers would decrease substantially. This may lead

to less participation at the sub-committee level since many of these volunteer

assignments are drafted by these engaged observers, which may include

vendors, trade groups, and government partners. This is the opposite of what

is intended.

Prior to release of the final proposal and before

presentation to the NERC BOT in November, the SET

should prepare a discussion draft of a typical RSC

committee meeting agenda, annual calendar,

communications plan, and a full analysis and set of

recommendations for the non-workgroup/subgroup

activities, briefings, and other intangible benefits that

stakeholder enjoy when attending the quarterly

OC/PC/CIPC meetings that will be lost.

For CIPC in particular, stakeholders would like to see a

statement from the E-ISAC acknowledging their

intention to 'inherit' some of the responsibilities of

CIPC such as free security workshops and classified

briefings.

SUGGUST WE SET UP A WEB PAGE WITH AGENDAS AND MEETING NOTES.

Also, need to address E-ISAC comment.

Basin Electric Power Cooperative

BEPC is concerned that the focus of the committees and more limited

engagement with industry which we believe is the antithesis of the intent.

This concern is heightened with the increase in change that is occurring

within the industry. NERC also needs to keep observer options open for in-

person rather than just webinar attendance. Hallway conversations are a big

part of it as well. Listen-only webinars do not allow for interactions.

BEPC would like to specifically request that

stakeholder "forums" be included in the final proposal

to replace the concentrated dialog that is an

intangible benefit to observers of the quarterly

technical committee meetings. The proposed

expanded meeting space at the Atlanta offices would

make for a cost-effective option for hosting these

events.

Basin Electric Power Cooperative

What will the meeting structure look like? A lot of behind the scenes

discussions will have to take place before the meetings so that members are

adequately briefed on operating, planning and CIP issues.

This structure has the potential to reduce transparency.

SET should provide discussion drafts of RSC meeting

agendas and calendars to help stakeholders

understand the mechanics of Option 2.


If the RSC proposal is accepted and implemented, BEPC would call on NERC

to provide a once or twice-per-year ‘CIP Forum’ to replace the portions of the

current CIPC that were not addressed in the proposal.

- Briefings by DOE, DHS, FERC, CEA, RCMP, Public Safety Canada on national

& continent wide security initiatives

- Callouts from stakeholder groups such as EPRI, NATF, NAGT, and EnergySec

on products that are available to asset owners that are under development by

these organizations

- Two-way discussions with the NERC CIP drafting team(s)

- Briefings from E-ISAC on notable recent cyber and physical security trends

and shares

- NERC staff updates on other security initiatives (Supply Chain, RSC, RISC)

- Emerging issues ‘roundtable’

- Space for workgroup and task-force face-to-face meetings that are open to

observers and those who wish to be more engaged with ERO security efforts

- Synchronized with GridSecCon to ensure no duplication of topics/speakers

BEPC would like to specifically support the E-ISAC

“inheriting” residual CIPC products:

- Offering security training that go beyond the

once/year GridSecCon (webinars, face-to-face).

Compliance-related training that CIPC offers might be

challenging for them, but are valuable “freebies” that

CIPC offers today.

- Twice per year classified briefings

- Help with security clearances

- Maintain the physical security advisory group

- Charter a corresponding cybersecurity advisory

group

- Take full ownership of the GridEx working group (co-

managed by CIPC today)

- Take full ownership of the Security metrics working

group (managed by CIPC today)

The E-ISAC is in the second year of executing its five-year Long-term Strategic

Plan to build the capacity, expertise, and capabilities to support these programs

and topics. This comprehensive list provides solid stakeholder requirements that

will help guide the remaining years of the Plan and the products and services

the E-ISAC will offer to members and partners.





Contact Telephone

Contact Email


WAPA 3

It is important that this change doesn’t result in less stakeholder involvement

or reduces stakeholder benefits. In order to accomplish this it is important

that the benefits stakeholders receive from information sharing with national

labs, technical reports, security briefings, lessons learned, cyber reports,

training, etc. are important and need to continue.

The SET envisions that the RSC will continue to have open meetings and will provide

stakeholders the opportunity participate in a group that addresses reliability issues in a

single venue. It is also envisioned that the RSC will continue outreach and educatuional

activities that exist today, thus retaining an active stakeholder participation level.

WAPA 12 Table 5.1

The hybrid participation model and the number of members being suggested

allows for the sectors to still have input on RSC membership, while

establishing at-large positions to allow the nominating committee to ensure

geographical/international, sector, size, asset, and subject matter (planning,

operating and security) diversity. WAPA is concerned that the size of the

proposed RSC is inadequate to ensure the overal diversity of membership and

additional thought should be given as to whether it should be increased. The

current split between sector members and at-large members is appropriate,

given that the size of the at-large membership will be critical in being able to

maintain this diversity.The SET is evaluating the participation model. Need to update this when we finalize it.

WAPA

13 Membership

Selection

While the nomination process will require the selection of all the RSC

members, it is important to a successful implementation that an adequate

level of continuity is maintained from the current Technical Committees. We

strongly suggest that when the nominating committee selecting the initial

RSC members keeps this in mind and at least 50% if the RSC should be

comprised of exisiting members of the Technical Committees, as it will allow

for a more speedy transition after Board approval of the RSC.The SET is evaluating the participation model. Need to update this when we finalize it.

WAPA 12 Table 5.1

When looking at diversity WAPA believes it is important that representation

from the Federal Power Marketing Administrations is included in the RSC. The SET is evaluating the participation model. Need to update this when we finalize it.





Contact Telephone

Contact Email


Sector 4

WECC and MRO

605-882-7500

[email protected]

Western Area Power Administration (WAPA)

ReliabilityFirst CIPC Leadership

N/A

RF

N/A

N/A


As a regional CIPC organization we feel that the loss of representation at the

NERC CIPC meeting will diminish the responsiveness we have with NERC and

other regional entities to questions our organization has concerning security

measures implemented at other utilities. As part of our charter the RF CIPC

representatives to the NERC CIPC group are empowered to present any

concerns the group may have. These same representatives also bring

pertinent information back from the NERC CIPC meetings and disseminate it

to the group. With the restructuring of the NERC CIPC there is no guarantee

there will be representatives from the RF CIPC group at the NERC RSC

meetings and we will lose this very important communications channel.

The SET envisions that the RSC will continue to have open meetings and will

provide stakeholders the opportunity participate in a group that addresses

reliability issues in a single venue. It is also envisioned that the RSC will

continue outreach and educatuional activities that exist today, thus retaining an

active stakeholder participation level.

The restructuring of the current committees will also dilute the overall

proficiency of the resulting RSC; in the situations where Infrastructure

Protection subjects are being discussed members who are part of operations

may not have the same level of interest and vice versa. The current CIPC and

OC committees can delve deeper into their areas of expertise due to the

combined knowledge of their groups and experiences of their members. The

reduction of specificity for each of the groups is expected to water down the

valuable information being presented to the NERC Board of Trustees.






The RF CIPC is concerned the changes to the committee structure being

proposed may ultimately lead to a reduction in the overall participation from

stakeholders. With the elimination of the current committees and the specific

information they discuss, there may be a reduction of the perceived value of

the meetings thus reducing the individuals who can justify their budgets to

attend. This will especially affect the smaller entities who benefit most from

the subjects discussed at the meetings. The reduction to the number of

individuals attending the NERC meetings would also increase the potential for

the elimination of the face to face meetings and training classes which take

place prior to or following the primary committee meetings. These sessions

have been perceived as a significant value add to the community and their

loss would further alienate continued participation from the stakeholders.






In summary, it is the opinion of the RF CIPC that the restructuring of the

NERC committees would remove a very important conduit of information for

its members and weaken the overall effectiveness of any resulting group. For

these reasons we recommend the current groups remain as they are.










Contact Telephone

Contact Email


With the proposed structure of the RSC to include Subject Matter Experts

(SMEs) from differing sectors, regions, and twenty (20) at-large seats, there

is a potential for non-subject matter experts to vote on, and affect, RSC

issues outside of the SME’s area of expertise. SPP encourages the SET to

consider an assurance into their process, that the BOT be aware of dissenting

votes, and minority positions, on RSC endorsed initiatives.

The SET will include language in the RSC Charter to address this concern.

To obtain industry perspectives at the RSC meetings, SPP encourages the

RSC Chair to follow a process similar to that of the BOT with the MRC.

Specifically, the BOT requests the MRC segment representatives provide

written or verbal input on agenda items that require debate. This process has

proven effective for BOT policy decisions.

SET needs to evaluate this topic.





N/A

SERC

501-614-3200

N/A

Duke Energy

N/A

SERC

SPP, Inc.

Contact Telephone

Contact Email


Duke Energy supports the concepts and ideas presented in Option 2

(Reliability and Security Council) of the Proposal if the following

considerations are implemented:

1. Coordinate and collaborate workplans to prevent duplication of efforts and

remove silos

The RSC will evaluate all subcommittees, working groups and task forces for duplication

of effort and to ensure an effective and efficient structure.

2. Implement a smooth transition for subject matter experts and the

prioritization of reliability and security stakeholder roles

The SET is developing a transition plan to accomplish a smooth transition from the

current structure to the proposed structure.

3. Extend the proposed January 2020 implementation date to ensure details

in the implementation plan and charter are addressed in a methodical and

transparent manner that allows sufficient time for effective change

management

The January 2020 date is designed to begin the transition process. The existing

committees will have their March meetings before we tranistion to the new structure.

4. Modify the proposed RSC membership selection process to allow for the

consideration of a hybrid nomination process, whereby:

a. Sector representation should be elected by the sector they serve, with final

approval by the NERC Board of Trustees (BOT),

b. At-large seats are determined based on identified criteria through a

nominating committee,

c. At-large member nominating committee membership and processes are

similar to the Compliance and Certification Committee (CCC) nominating

subcommittee, and

d. Sector 11 (Regional Entities) are included. SET to consider sector / at large membership, election and selection.

5. Address how information sharing and sessions will continue unimpeded

and without the fracture of existing technical committee agendasThe SET recognizes the value of these activities and will include these as part of the

activities to be continued by the RSC.

6. Remove all unintended language and references to the requirements that

remain in the Proposal due to its multiple revisions, such as the requirement

that members of the RSC have executive leadership experienceThe SET wil refine the languagge in the participation model regarding expertise needed.

7. Clarify coordination requirements among the RSC, RISC, and other NERC

Committees to effectively address the priorities the RISC identifies

The RISC is a forward looking committee that evaluates potiential reliability risks to the

BES. The RSC would then formulate tasks/activities to address those risks, following

through to completion of the tasks.

8. Resolve apparent overlap between the roles and expectations of the RSC

and RISC by clarifying their differences

The RISC is a forward looking committee that evaluates potiential reliability risks to the

BES. The RSC would then formulate tasks/activities to address those risks, following

through to completion of the tasks.

Proposal

Instructions

Review Period

Name of Individual

or Organization(s)

(list multiple if

submitted by a

group):

Industry Segment

(if applicable)

Region (if

applicable)

Contact Telephone

Contact Email

Page # Comment Proposed Change (if applicable) SET Response

Proposal for Restructuring NERC Technical Committees - Reliability and Security Council Proposal

Please use this form to submit comments on the draft Proposal for Restructuring NERC Technical Committees. Comments must be submitted within the review period below to Stephen Crutchfield ([email protected]) with

the words “RSC Proposal Comments” in the subject line. Only comments submitted in this Microsoft Excel format will be accepted. Both general and specific comments should be provided within this form. Red-line document changes,

PDF versions of this document, or email comments will NOT be accepted.

Comments may be submitted by individuals or organizations. Please provide the requested information in Row 6. If comments are submitted on behalf of multiple organizations, list all organizations in Row 6. Please provide the Industry

Segment and Region (if applicable) in Rows 7 and 8 and provide the requested contact information in Rows 9 and 10.

If you have any questions regarding this process, please contact Stephen Crutchfield ([email protected])

July 12, 2019 - August 15, 2019

Comments must be submitted using this comment form by 5:00 p.m. ET on August 15, 2019

N/A

N/A

7 Reclamation supports the creation of the RSC.

11 Reclamation supports the RSC participation model.

5

Reclamation does not support creating a new (additional) committee for

oversight.

Reclamation recommends to charter the existing

Standing Committee Coordination Group to serve as

the oversight committee for the RSC, or to dissolve

the existing Standing Committee Coordination Group

and replace it with the new Oversight Committee.

Thank you for your comment. The SET has recviewed all comments and

believes the recommended approach provide inprovements in effeciency and

effectiveness.

Summary of Policy Input to the NERC Board of Trustees August 2019

1

Proposal for Restructuring NERC Technical Committees CEA

• If further developed, the Reliability and Security Council (“RSC”) model offers an opportunity to increase the efficiency, effectiveness, coordination and oversight of the ongoing technical committee work within NERC, and to enhance overall stakeholder engagement.

• The proposed structure has the potential to deliver a wider view on topics, as the impact of greater digitalization moves the industry towards a greater mixing of traditional planning, operating, and security roles. In order to fully realize the benefits of the RSC model, and to avoid unintended consequences, NERC should further develop and clarify the following issues: RSC membership and effective Canadian representation; agenda-setting and prioritization of issues; cyber security considerations; ensuring North American perspectives; and ensuring this proposal complements wider NERC effectiveness and efficiency efforts.

• Clarification is requested regarding expected budget savings, and the future of the Standing Committee Coordination Group resulting from a transition to an RSC model.

• NERC may wish to consider renaming the RSC to minimize confusion between the RSC and RISC. • CEA is supportive of the policy input letter comments from the Federal Utilities and Federal

Power Marketing Administrations - Sector 4, submitted by Lloyd Linke. EEI

• EEI supports the concepts and ideas presented in Option 2, which should result in a more streamlined approach for addressing risk to the BPS because it will support coordination among the committees, remove silos, and ensure the prioritization of reliability and security stakeholder roles.

• EEI recommends providing additional time to effectively transition to this new structure because of the significant transformation required for successful implementation of the proposal.

• EEI recommends that sector representatives be elected by the sector they serve, with NERC Board of Trustees (BOT) oversight.

• EEI recommends that the at-large member nomination process be similar to the Compliance and Certification Committee (CCC) nominating committee model, which includes BOT oversight.

• EEI recommends removing references to the requirement that members of the Reliability and Security Committee (RSC) have executive leadership experience.

• EEI recommends providing additional clarity in how the roles and expectations of the RSC and Reliability Issues Steering Committee (RISC) differ.

ELCON and Sector 8

• The proposal to replace the NERC CIPC, OC, and PC with the RSC — Large Consumers support the effort to improve the efficiency and effectiveness of stakeholder engagement by creating a central committee overseeing the three standing committees. Both Option 1 and Option 2 would serve this function and Option 2 to create the RSC was the unanimous preference of the stakeholder engagement team (SET). Large Consumers, as a resource-constrained sector, expect to participate more robustly under a central committee model than in disaggregated venues. Large Consumers support the creation of the RSC subject to modifications of the participation model. Large Consumers also suggest consideration of an RSC model limited to operations and planning, leaving security to a separate committee, if the RSC model appears strained to represent all three subject matter areas sufficiently.


2

• The proposed participation model of the RSC — The RSC model requires modification to be successful. Two changes are essential: 1) a minimum of two representatives per sector is critical to provide sector balance and 2) sectors should retain the right to elect their own representatives. Additional modifications, such as RSC members elected their own leadership, would benefit RSC performance.

• The best way to implement the transition from three technical committees to the RSC – The timeframe to present the final SET recommendation at the November 6, 2019 NERC Board meeting with implementation starting January 1, 2020, is a tight timeframe. Full implementation in Q1 2020 may prove challenging, and quality should not be sacrificed for expediency. An interim phase-in structure may be necessary to ensure existing work at the standing committees continues uninterrupted. Large Consumers emphasize that the process to disassemble standing committees and reorient subcommittees be mindful of intended and unintended consequences, such as the transfer of institutional knowledge.

Federal Utilities and Federal Power Marketing Administrations (Part of Sector 4) [NERC Summary]

• It is important that this change doesn’t result in less stakeholder involvement or reduces stakeholder benefits.

• The size of the proposed RSC is the minimum number of members that we believe would be needed to ensure adequate diversity of membership and additional thought should be given as to whether it should be increased.

• While the nomination process will require the selection of all the RSC members, it is important to a successful implementation that an adequate level of continuity is maintained from the current Technical Committees. We strongly suggest that the nominating committee selecting the initial RSC members keeps this in mind, as it will allow for a more speedy transition after Board approval of the RSC.

• Suggest the SET recommends an initial RSC Chair and Vice Chair to the Board at the November Board meeting, so they could participate in the proposed nominating committee that will be selecting the RSC members.

ISO/RTO Council

• The IRC supports the effort to review the existing committee structure to identify efficiencies that can be found after more than ten years of ERO operations. We do agree that there may be some efficiencies observed through combining the existing Operations and Planning groups. However, the IRC believes that including Security matters in the combined group does not improve efficiency. The IRC is also concerned with a different committee structure being proposed for the new committee. The IRC is not aware of any concerns with the existing structure of the standing committees or the Members Representative Committee (MRC), which may be a better model for the RSC.

NAGF

• The NAGF agrees the RSC would increase the effectiveness and improve the functional alignment with the RISC.

• The NAGF along with the NATF would be very interested in participating on the RSC as a means to continue the forums collaborative support of the ERO.

• The NAGF suggests the RSC meet with the OC, PC and CIPC leadership to discuss the current goals and activities of the various subcommittees, working groups and task forces prior to the transition.


3

NATF

• If the NERC Board of Trustees restructures the Technical Committees as proposed, the new Reliability and Security Council (RSC) should include a representative from both the North American Transmission Forum (NATF) and the North American Generator Forum (NAGF). This would help ensure line of sight between ERO managed activities and industry forum activities and initiatives, enhancing the opportunity to eliminate or avoid duplication of effort or potential gaps in solutions.

NPCC

• The NPCC Board supports the proposal to form a NERC Reliability and Security Council (RSC). • The NPCC Board recommends that particular attention be paid to the criteria for RSC

membership that addresses geographic diversity. • The NPCC Board supports the inclusion of Regional Entity representatives as non-voting

participants at the RSC meetings to support the effective operation of the ERO Enterprise. • The NPCC Board recommends that RSC meetings provide WebEx/Teleconferencing access in

order to support efficient industry access to the deliberations. • In the interest of a successful, seamless transition, the NPCC Board recommends that the first

meeting of the RSC could immediately follow the final meetings of the existing technical committees.

Sector 3 (Cooperative Utilities)

• The Cooperative Sector appreciates the opportunity to provide policy input on the important issues surrounding the future of the three technical committees and we support the effort to undertake this review as part of NERC Efficiency and Effectiveness initiative.

• If option 2 is selected by the BOT: o Roles for both the RSC and RISC will need to be more explicitly understood to ensure

there isn’t duplication of efforts; o There may be benefits to expand the Sector membership so that there are two

representatives from each of the 11 Sectors as more fully described below. • Cooperative Sector members are split on their preferred direction on restructuring the three

technical committees. • The Cooperative Sector does not currently have input related to a transition plan.

Sector 6 (Merchant Electricity Generators)

• Sector 6 supports Option 2 as the preferred model. • The processes under which the Reliability Issues Steering Committee (RISC) and Reliability and

Security Council (RSC) operate must be clearly defined. • Since the RSC is a technical committee requiring subject matter expertise, the criterion for

candidates needing executive experience should not be a factor for serving. • The number of at-large representatives may need to be adjusted to allow for adequate technical

stakeholder representation and expertise. State and Municipal and Transmission Dependent Utility Sectors (“SM-TDUs”) [supported by APPA/TAPS/LPPC]

• Both Option 1 and Option 2 provide the needed central oversight for the three standing committees. Importantly, Option 1 provides oversight by refocusing the OC, PC, and CIPC, while


4

retaining the benefits those committees bring to NERC and the industry. If it is not acceptable as a long-term solution, Option 1 should be adopted as the mechanism for achieving an effective and efficient transition.

• Should Option 2 be selected, then the following need to be employed: o The Sectors should have three (3) representatives on the RSC, or in the alternative, a

minimum of two (2) representatives. o The Sector representatives and leadership should be elected by stakeholder groups,

with BOT oversight. o The transition needs to be well thought out and structured, and then an appropriate

timetable determined. o Executive experience should not be a qualifying-criteria for RSC membership.

3353 Peachtree Road NE Suite 600, North Tower

Atlanta, GA 30326 404-446-2560 | www.nerc.com

July 11, 2019 Mr. Greg Ford, Chair NERC Member Representatives Committee Dear Greg: I invite the Member Representatives Committee (MRC) to provide policy input on an issue of particular interest to the NERC Board of Trustees (Board) as it prepares for its August 14-15, 2019, meetings in Quebec City, Canada. In addition, policy input is requested on items on the preliminary agendas for the quarterly Board, Board Committees, and MRC meetings. The preliminary agendas are included in the MRC Informational Session agenda package (see Item 1) and are attached hereto (Attachment A). As final agenda packages with background materials are posted after policy input is due, the MRC’s agenda includes an opportunity for MRC members to provide additional input to the Board on the final agenda and materials. As a reminder, please include a summary of your comments in your response (i.e., a bulleted list of key points) for NERC to compile into a single summary document to be provided to the Board for reference, together with the full set of comments. Proposal for Restructuring NERC Technical Committees NERC is reviewing the effectiveness and efficiency of ERO Enterprise operations in an ongoing effort to advance our mission. In the near term, NERC is focusing on three major initiatives:

• Standards Efficiency Review: Review of NERC Reliability Standards to ensure they are effective and efficient to implement; results from Phase 1 have been filed with FERC for approval and Phase 2 is underway.

• Align: Development and deployment of the Align tool, designed to improve security, enable better performance management and reporting, reduce cost, and support greater alignment in Compliance Monitoring and Enforcement processes across the ERO Enterprise.

• Stakeholder Engagement: An effort to improve the effectiveness and efficiency of how stakeholders engage with NERC to advance our critical reliability and security mission.

In August, the Board will consider a recommendation from a stakeholder engagement team (SET)1 which was formed to address the third area where costs are born by stakeholders directly as well as by NERC. Given the nature of our model and criticality of industry expertise to the ERO’s success, enhancing the effectiveness of stakeholder participation in the face of our rapidly changing industry is the primary

1 The SET is comprised of members of the Board, leadership and representatives from the MRC, the chairs of the technical committees, other

stakeholder volunteers, and representatives from NERC executive leadership, legal, and staff.

https://www.nerc.com/gov/bot/MRC/Agenda%20Highlights%20nad%20Minutes%202013/0_MRC-Informational-Session-Agenda-Package-07-19-19.pdf

https://www.nerc.com/gov/bot/MRC/Agenda%20Highlights%20nad%20Minutes%202013/0_MRC-Informational-Session-Agenda-Package-07-19-19.pdf

objective of the initiative, always keeping an eye on the need to be as efficient as reasonably possible given all of the other demands on participants and staff. To address the objective of this aspect of the overall effectiveness and efficiency initiative, the SET was created to review the existing NERC technical committee structure (Critical Infrastructure Protection, Operating, and Planning) and develop recommendations for improving their effectiveness and efficiency. Based on this detailed review and as outlined in the attached draft proposal (Attachment B), the team is recommending replacing the three committees with a Reliability and Security Council (RSC). The RSC would report to the Board and focus on managing the work of the various subcommittees, working groups, and task forces organized to address specific risks to reliability and security. The resulting model supports the Board with two leadership bodies, the Reliability Issues Steering Committee (RISC) and the RSC. The RISC advises on emerging risks, prioritizes them, and identifies impactful mitigation activities. The RSC would oversee the implementation of those tactical prioritizations through work plans, as well as advise on the reliability and security of the bulk power system to address any unexpected new and emerging risks. The SET also evaluated how to populate the proposed RSC and is recommending a participation model that is composed of a chair and vice chair, one representative per sector (Sectors 1-10 and 12), 20 at-large representatives, and five non-voting members, for a total of 38 members. Nominations for all sector and at-large representatives would be called for by NERC on an annual basis, with members selected by a Nominating Committee consisting of the Board vice chair, NERC CEO, MRC vice chair, and the RSC’s chair and vice chair. The nominations for sector members would be called for under a process that is open, inclusive, and fair, similar to the annual nomination process of the existing Operating Committee (OC) and Planning Committee (PC). Note that sector nominees would not be able to represent more than one RSC sector at any one time and that a particular organization, including its affiliates, would not be permitted to have more than one member on the RSC. At-large members would be selected by a nominating committee based on skills and knowledge criteria to fulfill a balanced representation. Regional Entity employees would not be eligible to be an at-large representative. Non-voting members would include a NERC secretary, two United States federal government representatives, one Canadian federal government representative,2 and one Canadian provincial government representative. Overall selection of members will consider Regional Entity area diversity, subject matter expertise (planning, operating, or security), organizational type (e.g., Cooperative, Investor-Owned Utility, Public Power, ISO/RTO, etc.), and country (Canada, Mexico, and United States). In addition to Sector balance, the at-large membership should broadly reflect NERC’s geographic and interconnection mix, as well as any other key elements of “balance”, such as size and resource diversity.

2 Mexican Government representation will be considered once they have joined NERC.

The Board requests MRC policy input on the following:

1. The proposal to replace the NERC Critical Infrastructure Protection Committee, OC, and PC with the RSC.

2. The proposed participation model of the RSC.

3. The best way to implement the transition from three technical committees to the RSC. Written comments in response to the input requested above, the preliminary agenda topics, and on other matters that you wish to bring to the Board’s attention are due by July 31, 2019, to Kristin Iwanechko, MRC Secretary ([email protected]). The formal agenda packages for the Board, Board Committees, and MRC meetings will be available on August 1, 2019, and the presentations will be available on August 8, 2019. The Board looks forward to your input and discussion of these matters during the August 2019 meetings. Thank You,

Roy Thilly, Chair NERC Board of Trustees cc: NERC Board of Trustees Member Representatives Committee


Member Representatives Committee (MRC)

Pre-Meeting and Informational WebinarJuly 19, 2019

RELIABILITY | ACCOUNTABILITY2

• Review preliminary agenda topics for: August 14 MRC meeting August 14-15 Board of Trustees and Board Committee meetings

• Review policy input letter topics• Receive updates on emerging and informational issues

Objectives – Pre-Meeting and Informational Session


Wednesday, August 14, 2019

7:30-9:00 a.m. Public Breakfast

9:15-10:00 a.m. Finance and Audit Committee Meeting—Open

10:15–11:00 a.m. Corporate Governance and Human Resources Committee Meeting—Open

11:15 a.m.–12:00 p.m. Technology and Security Committee — Open

12:00 p.m.–1:00 p.m. Lunch

1:00–5:00 p.m. Member Representatives Committee Meeting—Open

5:30 p.m. Reception

Thursday, May 9, 2019

7:30–8:30 a.m. Public Breakfast

8:30 a.m.–12:00 p.m. Board of Trustees Meeting—Open

*Times are tentative and subject to change

Schedule of Quarterly NERC Meetings and Conference Calls


• Second Quarter Unaudited Financial Statements• NERC and Regional Entity Proposed 2020 Business Plans and

Budgets and Associated Assessments

Finance and Audit Committee 9:15 a.m. - 10:00 a.m., August 14


• 2019 ERO Work Plan Priorities Update• Draft 2020 ERO Work Plan Priorities Review• Board Self-Assessment and MRC Assessment of Board of

Trustees Effectiveness Survey Review• 2019 Work Plan Board Self-Assessment and MRC Assessment of

Board of Trustees Effectiveness Update• Employee Reporting and Document Retention Policies and

Procedures Review• Human Resources and Staffing Update

Corporate Governance and Human ResourcesCommittee 10:15 a.m. – 11:00 a.m., August 14


• Align Update• ERO Enterprise IT Projects Update• E-ISAC Update

Technology and Security Committee11:15 a.m. – 12:00 p.m., August 14


• General Updates and Reports Board of Trustees Nominating Committee Update Business Plan and Budget Input Group Update Regulatory Update

• Policy and Discussion Items Responses to the Board’s Request for Policy Inputo Effectiveness and Efficiency: Proposal for Restructuring NERC Technical

Committees Effectiveness and Efficiency: Standards Efficiency Review Phase 2 Update Additional Policy Discussion of Key Items from Board Committee Meetings MRC Input and Advice on Board Agenda Items and Accompanying Materials

Member Representatives Committee1:00 p.m. – 5:00 p.m., August 14


2019 ERO Reliability Risk Priorities Report Preview ERO Enterprise Long-Term Strategy Supply Chain 1600 Data Request

• Technical Updates Update on FERC Reliability Matters Standing Committee Highlights: Compliance and Certification Committee

Member Representatives Committee1:00 p.m. – 5:00 p.m., August 14


• Committee Membership and Charter Amendments Compliance and Certification Committee Membership Operating Committee Membership Planning Committee Membership

• Appointment of Interim General Counsel, Corporate Secretary

Board of Trustees 8:30 a.m. - 12:00 p.m., August 15


• Board Committee Reports Accept Second Quarter Unaudited Financial Statements Approve NERC and Regional Entity Proposed 2020 Business Plans and

Budgets and Associated Assessments

• Standards Quarterly Report and Actions Approve Supply Chain 1600 Data Request Adopt CIP-002-6, PRC-006-NPCC-2, BAL-002-WECC-3, BAL-003-2



• Other Matters and Reports Approve ReliabilityFirst Bylaws Amendments Update on 2019 Industry Dashboard Update Update on Task Force to Address Resilience to Electromagnetic Pulses Update on SERC/FRCC Integration Update on Reliability Coordinator Function in the Western Interconnection

• Committee, Forum, and Group Reports



• Overview of Policy Input Letter Proposal for Restructuring NERC Technical Committees

July 19 – MRC Informational Session


• July 11: Policy input letter issued• July 31: Written comments due on policy input topics and

preliminary agenda topics• August 1: Board and MRC agenda packages and policy input

letter comments posted• August 8: Board and MRC presentations posted

Upcoming Dates

NERC | Report Title | Report Date I

Reliability and Security Council Proposal July 11, 2019

NERC | Reliability and Security Council Proposal | July 2019 ii

Table of Contents

Preface ........................................................................................................................................................................... iv

Overview ......................................................................................................................................................................... v

Background .................................................................................................................................................................... vi

Chapter 1: Stakeholder Engagement Team Recommendation Development Process .................................................. 1

Overview of Existing Committee Structures ............................................................................................................... 1

Scope of SET Review .................................................................................................................................................... 2

Stakeholder Engagement Team Review ...................................................................................................................... 2

Chapter 2: Vision for a Restructured Standing Committee Organization ....................................................................... 4

Chapter 3: Options for Standing Committee Restructuring............................................................................................ 5

Option 1: Create an Oversight Committee .................................................................................................................. 5

Alternative 1a: Create a new Oversight Committee for NERC Technical Committees, Charter the SCCG and assign responsibilities ......................................................................................................................................................... 6

Oversight Committee Participation Model .............................................................................................................. 6

Oversight Committee Implementation plan ............................................................................................................ 7

Option 2: Replace Technical Committees with a Reliability and Security Council, and retain existing subcommittee structure ...................................................................................................................................................................... 7

Reliability and Security Council Participation Model Options ................................................................................. 7

Chapter 4: Compare and Contrast Options 1 and 2 ........................................................................................................ 8

Option 1: Establish an Oversight Committee .............................................................................................................. 8

Option 2: Establish Reliability and Security Council .................................................................................................... 8

Potential Effectiveness and Efficiency Benefits ....................................................................................................... 8

Recommended Participation Model: ........................................................................................................................ 11

Reliability and Security Council Implementation Plan .............................................................................................. 11

Chapter 5: Membership ................................................................................................................................................ 12

Membership Qualifications ....................................................................................................................................... 12

Expectations .............................................................................................................................................................. 12

Membership Selection .............................................................................................................................................. 13

Board Appointment and Membership Terms ........................................................................................................... 13

Officers ...................................................................................................................................................................... 13

Chapter 6: Executive Committee .................................................................................................................................. 14

Authorization ............................................................................................................................................................. 14

Membership .............................................................................................................................................................. 14

Terms ......................................................................................................................................................................... 14

Chapter 7: Industry Review and Comment Timeline .................................................................................................... 15

Table of Contents

NERC | Reliability and Security Council Proposal | July 2019 iii

Chapter 8: Elements of a Charter for the Reliability and Security Council ................................................................... 16

Appendix A: Stakeholder Engagement Team Roster .................................................................................................... 17

Appendix B: Existing Participation Models ................................................................................................................... 18

Appendix C: Reliability and Security Council Member Definitions ............................................................................... 20

NERC | Reliability and Security Council Proposal | July 2019 iv

Preface The vision for the Electric Reliability Organization (ERO) Enterprise, which is comprised of the North American Electric Reliability Corporation (NERC) and the six Regional Entities (REs), is a highly reliable and secure North American bulk power system (BPS). Our mission is to assure the effective and efficient reduction of risks to the reliability and security of the grid. The North American BPS is divided into six RE boundaries as shown in the map and corresponding table below. The multicolored area denotes overlap as some load-serving entities participate in one Region while associated Transmission Owners/Operators participate in another.

MRO Midwest Reliability Organization

NPCC Northeast Power Coordinating Council

RF ReliabilityFirst

SERC SERC Reliability Corporation

Texas RE Texas Reliability Entity

WECC Western Electricity Coordinating Council

NERC | Reliability and Security Council Proposal | July 2019 v

Overview NERC is presently undertaking a comprehensive assessment of its activities that is intended to improve the operational effectiveness of the ERO Enterprise while optimizing the value of industry stakeholder participation. The issue of improving the effectiveness and efficiency of stakeholder engagement across the ERO Enterprise was specifically raised by NERC Chair Roy Thilly in a January 4, 2018 Policy Input Letter to the Member Representatives Committee (MRC). In response to industry feedback that was received, the NERC Board of Trustees (Board) called for a comprehensive review of the existing technical committee structure and actions that could be taken to improve the effectiveness and efficiency of those committees. As a result of that request, a stakeholder engagement team (SET) was formed to review the existing NERC technical committee structure and develop a recommendation. The SET was tasked by the Board and is comprised of members of the Board, leadership and representatives from the MRC, the chairs of the technical committees (Operating, Planning, and Critical Infrastructure Protection), other stakeholder volunteers and NERC senior leadership, legal, and staff. The SET considered multiple options for fulfilling the ERO Enterprise need for participatory technical input on matters of reliability and security of the North American BPS, including maintaining the existing committee structure. The SET determined that a new Reliability and Security Council (RSC) to replace the three existing technical committees would best meet the vision for effective and efficient technical input. The sections below discuss the background, process, and vision that guided the SET’s work and recommendation. The recommendation will be provided to the Board prior to December 2019 for approval.

NERC | Reliability and Security Council Proposal | July 2019 vi

Background The ERO Enterprise Long-Term Strategy and ERO Enterprise Operating Plan, approved by the Board on November 9, 2017, recognize the importance of achieving greater enterprise-wide effectiveness and efficiency. Over the course of 2018, NERC and the REs identified current and ongoing efforts related to effectiveness and efficiency and explored future initiatives. The following objectives guided NERC and the REs in this effort:

1. Enhance ERO effectiveness in executing its statutory functions, recognizing the value of industry expertise.

2. Improve the efficiency of ERO operations and the use of stakeholder resources. The SET was formed to carry out the objectives as related to stakeholder engagement through the technical committees. The SET was co-chaired by the vice chair of the MRC and NERC’s Chief Reliability Officer. A complete list of the SET membership and participants is in Appendix A.

http://www.nerc.com/AboutNERC/StrategicDocuments/ERO_Enterprise_Long-Term_Strategy_Approved_by_the_NERC_Board_on_Novmeber_9_2017.pdf

https://www.nerc.com/AboutNERC/StrategicDocuments/ERO_Enterprise_Operating_Plan_Approved_by_the_NERC_Board_on_November_9_2017.pdf

NERC | Reliability and Security Council Proposal | July 2019 1

Chapter 1: Stakeholder Engagement Team Recommendation Development Process The SET performed four steps in its review and leveraged NERC’s Strategic Plan, Operating Plan, and RISC Report to facilitate the evaluation process: 1) examined all RE experiences with committee restructuring; 2) the team verified the parameters surrounding governance of the identified standing committees, as outlined in the NERC Rules of Procedure and Bylaws, Federal Power Act, and federal regulations; 3) the team reviewed common responsibilities, work flow, and current levels of coordination across the identified standing committees based on their work plans and deliverables; 4) the SET surveyed current committee members for their input about the existing committee structure and potential replacement structures. The SET then reviewed potential options for organizational structure and developed recommendations for next steps. Overview of Existing Committee Structures The ERO Enterprise makes use of technical input, guidance, and reliability/security leadership provided by its standing committees: Planning (PC), Operating (OC), Compliance and Certification (CCC), Standards (SC), Critical Infrastructure Protection (CIPC), Reliability Issues Steering (RISC), and Personnel Certification Governance (PCGC) Committees. The diagram below shows the current structure of all the standing committees and their general area of focus:

Under the current NERC committee structure, the OC, PC, CIPC, CCC, SC, PCGC, and the RISC report to the Board. Except for the RISC, each has an executive committee that supports the committee between meetings, as well as guides and coordinates the subcommittee, working group, and task force workload and priorities. To further coordinate issues that may be cross-cutting, the chairs and vice-chairs (who sit on the executive committees) of all NERC standing committees meet on a quarterly basis, concurrent with the Board and MRC meetings. This group of chairs and vice chairs is called the Standing Committee Coordination Group (SCCG).1 The SCCG itself does not have a

1 The SCCG also includes leadership teams from the SC, CCC, RISC, and the PCGC. The SCCG members work to improve coordination between

the technical committees and help develop work plan items to address reliability issues

Chapter 1: Stakeholder Engagement Team Recommendation Development Process


charter or a mandate and, therefore, holds no authority to further direct the activities of the standing committees. NERC staff facilitate the meetings and discussions of the SCCG. Separately, the RISC provides advice to the Board, triages risks, and provides front-end, high-level leadership for issues of strategic importance to the reliability and security of the BPS. Scope of SET Review To examine enhancements that could improve the use of scarce industry resources, the SET was tasked with reviewing the OC, PC, and CIPC structures and activities given their technical focus on reliability and security of the BPS. These technical committees identify and assess risk to the operation, planning, and security of the BPS. Most of the technical work of the committees is performed at the subcommittee, working group, or task force level. The technical committees provide direction and oversight of these groups. Some activities of the technical committees are ongoing and provide annual/biennial deliverables while other activities appear to be less focused and fragmented. Recently, more task force creation has occurred to address emerging, fast impacting issues. The advisory committees (CCC, SC, and PCGC) are not part of this review as each advisory committee is quite distinct with no overlap of responsibilities as specifically noted in NERC’s Rules of Procedure. These committees have been self-regulating over time to improve effectiveness and efficiency. Further, the RISC was also not a part of this review as it has a unique charge and participation model. It produces a biennial report on key risk identification and mitigation. The RISC is chartered to triage risk mitigation approaches. Stakeholder Engagement Team Review Based on its review, the SET concluded the following regarding the existing OC/PC/CIPC structure:

• The current model has been in place with little change for over 10 years

Model requires significant expense and time commitment from NERC members and NERC staff

The ERO Enterprise has matured

Several REs have had success enhancing their committee models

• The industry model is changing

Advances in new and unfamiliar technologies (e.g., inverters, batteries)

Risk profiles changing (e.g., fuel assurance, essential reliability services preservation with resource mix changes)

Recent experience within the committees is to stand up task forces for end-to-end solutions, bypassing existing subgroups

• The committee “silos” are blurring

Speed of change is accelerating

Committee activities increasingly overlap

New technology requires cross-cutting rethinking of many utility paradigms (e.g. – inverter-based resources including wind, solar and storage)

The technical committees must play a vital role in order for the ERO Enterprise to be successful in its mission of reducing risk to the BPS. Based on current operations, the technical committees provide oversight, work plan coordination, and technical review of the results and work products developed by working groups of subject matter

Chapter 1: Stakeholder Engagement Team Recommendation Development Process


experts. The SET recognizes the importance of the collaboration, training and education that occurs between participants and attendees of the technical committee meetings. Lessons learned, information sharing by the U.S. Department of Energy (DOE) National Labs, technical reports, security briefings, cyber reports, training, etc. will continue to be provided. Enhancing stakeholder engagement through the three technical committees should:

• Strengthen alignment of stakeholder input with ERO Enterprise priorities

• Accommodate the changing industry model

• Focus on reliability and security risks from a strategic planning, operating and security perspective

• Effectively address the increasing overlap between the technical committees

• Achieve a higher level of industry participation (effectiveness) and more cost-effectively leverage subject matter expertise (efficiency)

• Effective use of NERC staff


Chapter 2: Vision for a Restructured Standing Committee Organization The SET agreed on a vision for enhancing stakeholder engagement through technical committees as outlined below:

• We pivot quickly and refocus resources rapidly

We are in an ever-changing world and the pace of change is accelerating

Agile teams need to be readily deployed to address emerging issues

• We bring multi-disciplined teams together to develop “complete” solutions

Complex issues facing the industry that don’t fit into one basket

Ensure appropriate mix of knowledge/skills/abilities (participation model): Planning, Operations, Security, Compliance/Policy, and Legal

• We work collaboratively and efficiently to solve problems

Eliminate silos and redundancies

Committees need the ability to support standards and compliance

o Ability to address projected and emerging risks that threaten the reliability of the bulk power system

o Standards or guidelines may be needed

o Additional tools (potentially new) may be needed

• We leverage scarce talent to solve problems and maximize our return


Chapter 3: Options for Standing Committee Restructuring The SET reviewed all activities of the three technical committees. A few conclusions became apparent in this review:

1. Technical committee participation is generally based on sectors (OC/PC) or Regional nomination (CIPC). As more focused technical expertise is usually required to develop detailed solutions, most of the work is now performed at the subcommittee, working group, and task force level – not at the committee level.

2. By-and-large, technical committee activities focused on work plan development, evaluation and execution by the subgroups that report to them.

a. Subgroup report-outs are occurring on a quarterly basis.

b. The technical committee work plans are not formally coordinated.

3. Most problem solving is occurring at the subcommittee, working group, and task force level. Some subcommittees have ongoing recurring deliverables while others are more ad hoc task oriented.

4. Some reliability and security risk issues are being addressed in several subcommittees, leading to uncoordinated results, and less end-to-end solutions.

The SET also recognizes the importance of the collaboration, training and education that occurs during the technical committee meetings. Examples of such activities include presentations by National Laboratories, Lessons Learned, Security briefings, etc. These activities must continue in the future in some format. Issue statement: The SET identified the need to ensure work plans are coordinated, and an opportunity for more end-to-end solution development to address reliability/security risks. Several options were reviewed. Option 1: Create an Oversight Committee Retain the current committee structure and create an Oversight Committee. The Oversight Committee could either be a newly created body or a redesign of the existing SCCG or RISC.

NERC Board of Trustees

Operating Committee

Oversight Committee

Planning Committee

Critical Infrastructure

Protection Committee

The following are the options considered for the formation of the Oversight Committee to address the issue statement above:


Alternative 1a2: Create a new Oversight Committee for NERC Technical Committees, Charter the SCCG and assign responsibilities Charter the SCCG to perform the assigned responsibilities with associated reporting and accountability for tasks. Institute SCCG reporting to the Board. Subcommittees can be attached (as in Option 2 of the Committee/Council Structure below) for those groups that provide periodic reliability/security reports. For example, a Project Management Oversight Committee focused on project development, end-to-end solutions, and reduction of duplication. If selected, this option would be implemented by assigning to the SCCG the responsibility for developing a charter and organizational structure for approval. Recommendation for Option 1: The SET believes that Alternative 1a provides the best baseline for comparison of alternatives considered in the effectiveness and efficiency review. The SCCG is currently an informal group that is designed to perform many of the tasks envisioned to be performed by the Oversight Committee and its membership contains the necessary technical and leadership skills to transition to a formal organization reporting to the Board. The SET also considered alternatives 1b and 1c (shown in footnote 2) but the SET does not believe them to be the best option at creating an Oversight Committee because of the desire to have the Oversight Committee report to the Board. The SET recommends including RISC representation/leadership on the Oversight Committee. Oversight Committee Participation Model An oversight structure is needed to ensure the output of NERC RISC (risk reliability reports, risk parameters, data analysis, reliability assessments, etc.) is addressed as well as direct and coordinate potential mitigations and actions required of the NERC technical standing committees. If Alternative 1a is the preferred proposed structure, the oversight committee should ensure that:

1. Risks are identified, prioritized and managed

2. Assignments are coordinated and not duplicated

3. The technical committees (OC, PC, and CIPC) are directed to successful execution of the duties

4. Tools (guidelines, guidance, standards, etc.) employed in response to risks are appropriate There are a number of options for creating the Oversight Committee. Regardless of the selected organizational structure, assumptions have been made regarding the oversight council:

• Decisions should consider the technical committee structure

• Coordinates all NERC technical committees

• Assumes participation by NERC technical committees (regardless of number)

• Eliminate or avoid duplication of effort or potential gaps in solutions

• RISC Reliability Report (priorities and profiles) used to easily identify and coordinate efforts in support of reliability and security

• Support moving quickly and refocusing resources rapidly

• Brings multi-disciplined teams together to develop “complete” solutions

• Leverage scarce talent to solve problems and maximize returns

• Work collaboratively to solve problems

2 The SET analyzed three options for the creation of an Oversight Committee and recommends Alternative 1a. The other options considered

were Alternative 1b: Charter the SCCG with organizational reporting to RISC and Alternative 1c: Delegate functions to RISC. Option 1a was selected because it provided the best baseline to compare alternative structures, and is in-line with the current structure providing the lowest potential impact on the existing organization.


Oversight Committee Implementation plan This option would be the simplest and quickest option to implement. It would require formalizing the SCCG charter and gaining Board approval. Participation models for the committees would not change. However, the option doesn’t address all of the elements of the envisaged end-point. It does however provide a base-line to which a comparison can be made to other recommended approaches. Option 23: Replace Technical Committees with a Reliability and Security Council, and retain existing subcommittee structure Replace the OC, PC, and CIPC with a single, new RSC, which reports to the Board, overseeing the work of the subcommittees, working groups, and task forces. The existing subcommittees, working groups, and task forces reporting to the CIPC, OC, and PC will be evaluated for work scope and recurring deliverables. It is envisioned that those subcommittees and working groups with recurring deliverables will be retained, while those without recurring deliverables will be further evaluated for synergies and streamlining of stakeholder activities. Task forces will be deployed with clear deliverables and a timeline for completing those deliverables.

NERC Board

Operating Committee

OC Subcommittees, Working Groups,

Task Forces

Planning Committee

Critical Infrastructure

Protection Committee

PC Subcommittees, Working Groups,

Task Forces

CIPC Subcommittees, Working Groups,

Task Forces

NERC Board


Task Forces

Reliability and Security Council


Task Forces


Task Forces Reliability and Security Council Participation Model Options The ERO has three general types of participation models in its committees, highlighted below (See Appendix B for more details):

• OC/PC – Sector-based model with 2 members from each of the 12 sectors plus a chair and vice chair. Also have provisions for Canadian representation.

• CIPC – Regional-based model with 3 representatives from each Region with expertise in physical security, cyber security, and operations with provisions for Canadian representation as well as certain industry groups.

• RISC – Pool of experts selected based on skills and knowledge criteria

Geographic and International diversity

Sector, size, and asset (transmission, distribution, load, generation, etc.) diversity;

High-level understanding and perspective on reliability risks;

Experience in a leadership role or background in an executive-level position is strongly preferred; and

Balanced consideration of these criteria, across the entire membership of the RISC.

3 The SET reviewed several options for restructuring the technical committees. The two most viable options include Alternative 1: creating a

Reliability Council with Operating and Planning expertise while CIPC remains as it exists; and Alternative 2 Transform CIPC, OC and PC into a Reliability and Security Council with subcommittees and a “roster” of technical experts that can be spun up into “problem specific” task forces. This second option was selected by the SET as it encourages the consideration of all aspects of risks to reliability when designing and operating the bulk power system, during normal and emergency conditions, either natural or man-made. This would result in coordinated management of resources for addressing the various aspects of threats to the reliable operation of the bulk power system.


Chapter 4: Compare and Contrast Options 1 and 2 Option 1: Establish an Oversight Committee The existing NERC technical committee’s structure remains unchanged with this option. Option 1 does create formal oversight of the activities of the OC, PC, and CIPC by the SCCG, chartered as the Oversight Committee. The Oversight Committee will be responsible for coordinating development and approving the work plans of the technical committees to assure that there is no redundancy in committee activities. The Oversight Committee, in consultation with NERC management team, will determine when there is a need to form task forces (project teams) to resolve a specific grid reliability issue. To implement Option 1, a charter must be developed for the Oversight Committee that will include membership, responsibilities, deliverables and reporting requirements to the Board. Option 2: Establish Reliability and Security Council This option creates a new formal oversight that combines the experience of all three committees into one. The newly created RSC will oversee the output of the subcommittees, working groups, and task forces, and report to the Board. Depending on the participation model chosen for the RSC, this model provides less “silo” impact for issues that overlap in the current model as well as increasing effectiveness by addressing duplication and/or gaps in the current subcommittee structure. During the transition to this new structure, the existing subcommittees, working groups, and task forces will remain until the RSC has an opportunity to complete its analysis of all ongoing activities and priorities. Potential Effectiveness and Efficiency Benefits There are several potential effectiveness and efficiency benefits from Option 2, compared to both the status quo and Option 1. For example, Option 2 provides: Better functional alignment w ith the RISC The RISC is made up of industry advisors that provide leadership/advice on strategic forward-looking risks, prioritize the risks and provide recommendations for risk mitigation. The RISC provides its assessment in a report to the NERC Board every second year. The RISC report is used, among other things, to inform the ERO strategic plan and the annual Business Plan and Budget. The main RISC-related function as it relates to the RSC will be, in conjunction with NERC management, to initiate and oversee the development of technical analyses and products to better understand and mitigate the priority risks identified in the RISC report, monitor the effectiveness of mitigation activities, and identify emerging risks from measuring system performance. The graphic below shows the relationship between the RISC, RSC, and the Board:


NERC Board


Task Forces

Reliability and Security Council


Task Forces


Task Forces

Reliability Issues Steering Committee

The resulting model supports the ERO and NERC Board with two leadership bodies:

1. RISC: Advising on emerging risks, prioritizing them and identifying impactful mitigation activities.

2. RSC: Overseeing the implementation of those tactical prioritizations through work plans, similar to a project management office, as well as advising on the reliability and security of the BPS through reliability assessments and performance analysis to identify and address any unexpected new and emerging risks.

Below provides further granularity on the roles of RISC and the proposed RSC. Reliability Issues Steering Committee Charter Purpose The Reliability Issues Steering Committee (RISC or Committee) is an advisory committee that triages and provides front-end, high-level leadership for issues of strategic importance to BPS reliability and security and offers high-level stakeholder leadership engagement and input on issues that impact BPS reliability. RISC advises the NERC Board, NERC standing committees, NERC staff, regulators, Regional Entities, and industry stakeholders to establish a common understanding of the scope, priority, and goals for the development of solutions to address these issues, including the use of solutions other than the development of new or revised reliability standards. In doing so, the RISC provides a framework for steering, developing, formalizing, and organizing recommendations to help NERC and the industry effectively focus their resources on the critical issues needed to best improve the reliability and security of the BPS. Reporting The RISC reports to the NERC Board. Functions The RISC performs two primary functions for the Board.

1. The first function of the RISC is to evaluate emerging BPS reliability issues and risks. The RISC provides strategic leadership and advice to the NERC Board and others to triage key reliability risks and propose solutions to manage those risks.

2. Second, the RISC provides a biennial analysis of risks to the BPS and produces a relative prioritization of the risks and mitigation activities. The prioritization is designed to advise:

a. Annual ERO action planning, resource allocation, budgeting and strategic planning processes; and

b. Standing committee planning, including the development of the Reliability Standards Development Plan.


In addition, the RISC performs such other functions that may, from time to time, be delegated or assigned by the NERC Board. Reliability and Security Council Purpose Similar to the RISC, RSC will be an advisory council that, in conjunction with NERC management, initiates and oversees the development of technical assessments and analysis that i) support the analytical assessment function of the ERO; and ii) develop and provide products that can be used by industry to mitigate risks to the BPS. Reporting The RSC will report to the NERC Board. Functions To provide technical advice, project management, and subject matter expertise support to each of the NERC program areas, and to serve as a forum to integrate the outputs of each ERO program area, including:

1. Reliability Assessments – Review reliability assessments, assure technical accuracy and completeness of results, and endorse approval of assessments to NERC’s Board.

2. Cyber and Physical Security – Review and assess the horizon for emerging cyber and physical risks. Develop mitigations, including guidelines, Alerts, webinars, whitepapers and standard enhancements.

3. Emerging Issues and Reliability Concerns – Identify emerging issues within the electric industry, address issues in reliability and security assessments, and address other issues as assigned by the Board.

4. Operational Analyses – Develop operational analyses, model validation, and key reliability areas, resulting in technically accurate and comprehensive reports addressing these areas (i.e., frequency response, intermittent generation, cyber and physical security, distributed energy resources (DER), etc.). Provide recommendations that facilitate addressing the reliability and security risks identified. Provide oversight, guidance, and direction to address key planning related issues.

5. Standards Input – Provide technical expertise and feedback to Standard Authorization Requests (SARs) that have reliability- or security-related impacts, provide foundational technical efforts that support the key reliability operational, planning and security related standards development, coordinate effectively with the Standards Committee to maintain alignment on priorities, develop and vet planning, operational and security guidelines that align with approved standards with industry stakeholders, and provide reliability risk information for prioritization of SARs and new or enhanced Reliability Standards.

6. Metrics – Provide direction, technical oversight, and feedback on the NERC Adequate Level of Reliability (ALR) metrics. Pioneer development of security metrics

7. Event Analysis – Review all event reports to determine lessons learned and good industry practices and promote the dissemination of information to the industry to enhance reliability.

8. NERC Alerts – Participate in the review and development of requests for industry actions and informational responses.

9. Reliability and Security Guidelines, Technical Reports, White Papers, Implementation Guidance, and other reference documents – Develop reliability guidelines, white papers, technical reports and reference documents to address emerging issues and industry concerns related to system operations.

10. System Operator Training – Provide necessary support and guidance to facilitate System Operator training.4

4 Currently the Personnel Subcommittee (PS), reports to the NERC Operating Committee and is the governing body of the NERC Continuing

Education Program that oversees development and implementation of the Continuing Education (CE) Program requirements. The PS develops and updates, as necessary, the CE Program Manual. It may be better for this subcommittee to report to the NERC Personnel Certification Governance Committee. This transition would require a changes in NERC’s Rules of Procedure.

https://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/NERC_ROP_Effective_20180719.pdf


11. Additional Activities and Outreach – Opportunities to share lessons learned, information haring by U.S. DOE National Labs, technical reports, security briefings, cyber reports and training, etc. will be broadened so more stakeholders can participate.

Increasing effectiveness and efficiency by providing end-to-end solutions It is envisaged that the RSC would provide direction to the existing subgroups of the current PC, OC and CIPC that produce recurring deliverables that support ERO analytical work. As well, when emerging risks are identified, the RSC would determine the best way to get a better understanding of the technical aspects of the issues and the potential mitigating strategies. It is envisaged that it would approach this task through the creation of issue-specific task forces that would have well-defined mandates and deliverables. A single issue-specific task force could be structured to examine and report on planning, operational and security aspects of a given issue. Examples of past issues that the RSC might address in a more holistic way include essential reliability services (ERS), distributed energy resources (DER) and inverter-based resources. Future issues may include, for example, storage. Enhanced contact between RSC, the MRC and the NERC Board By replacing the three existing technical committees with one RSC, enhanced contact will result between the new RSC and the NERC Board. More time at Board and MRC meetings is envisaged to hear a report from the RSC and tee up specific items for discussion. As well, it is currently a challenge for Trustees to attend the OC, PC and CIPC meetings as they occur concurrently. General efficiencies The integration of the existing OC, PC, and CIPC provides efficiencies in terms of both NERC and industry support, although these are difficult to quantify at this time. For example, rather than nearly 120 members participating in the three existing technical committees, approximately 40 members will participate in the RSC. RSC meetings will continue to be conducted as open meetings, similar to the existing technical committee meetings Recommended Participation Model: The SET is recommending a participation model for Option 2 which will be a hybrid of the existing models used in other committees. The number of RSC members and qualifications are based on:

• Sector representation which may or may not include all existing sectors

• Skills and knowledge criteria similar to the RISC

• Provisions for Canadian representation Reliability and Security Council Implementation Plan The first meeting of the RSC will be in early 2020 and the existing technical committees will be dissolved with the formation of the RSC. A detailed Implementation / Transition Plan will be developed after the SET receives Policy Input from the MRC and Board.


Chapter 5: Membership Membership will be a hybrid model composed of sector representatives, at-large representatives, and non-voting members. Sector representation will be one member each for Sectors 1 – 10 and 12.5 Overall selection of members will consider RE area and Interconnection diversity, subject matter expertise (Planning, Operating, or Security) organizational type (Cooperatives, Investor-Owned Utilities, Public Power, Power Marketing Agencies, etc.) and country (Canada, Mexico, and U.S.). At-large representation will be used to fulfill a complete overall balanced representation and expertise in the RSC.

Table 5.1: Summary of the SET’s Proposed Membership Model

Name Voting Members Sectors 1-10 and 12 11 At-Large 20 Chair and Vice Chair 2 Total 33

Table 5.2: Additional Non-Voting Members6

Non-Voting Member Number of Members NERC Secretary 1 United States Federal Government 2 Canadian Federal Government 1 Provincial Government 1 Total 5

Membership Qualifications The RSC Charter will set forth that individuals qualified to serve on the RSC will include senior management and technical level (e.g., Manager, Director, Vice President, Principal, Lead Engineer) industry experts who have familiarity, knowledge, and experience in Planning, Operating, and/or Security. In addition, the RSC members are expected to have an understanding of Project Management culture and methods for delivering work products within scope, schedule, cost, and quality. The RSC members will collaborate to provide oversight of multi-disciplinary and cross-organizational initiatives to ensure that the work products achieve the ERO’s and RISC’s strategic objectives, enhance NERC’s critical functions, and collectively address planning, operating and security objectives. The RSC will primarily oversee development and implementation of risk mitigating technical solutions through the work of the subcommittees, working groups, and task forces. Expectations Members of the RSC are expected to support NERC’s reliability mission;7 execute the policies, directives, and assignments of the Board; and advise the Board on the technical perspectives of risk mitigating solutions for: operating reliability matters; transmission planning matters; reliability and resource adequacy matters; physical and cyber security matters.8 Additionally, the RSC will be responsible for ensuring the work of its subcommittees, working groups and task forces is completed in coordination with the efforts of the CCC, SC, PCGC, and the RISC.

5 With the ERO model maturing and Regional Entities an integral part of the ERO, Regional Entities (Sector 11) will not be directly represented

on the stakeholder RSC. Sector 11 representatives will participate as RSC non-voting participants. 6 Mexican Government representation considered once they have joined NERC. 7 NERC’s mission is to “assure effective and efficient reduction of risks to the reliability and security of the bulk power system.” 8 Liaise with the Electricity Information Sharing and Analysis Center (E-ISAC).


Membership Selection Nominations for expiring terms (Sector and At-Large) will be called for by NERC and are selected (for approval by the NERC Board of Trustees) by a Nominating Committee consisting of the NERC Board Vice Chair, NERC Chief Executive Officer, MRC Vice Chair, and the RSC’s Chair and Vice Chair. Representatives are selected based on the qualifications established in Membership and Membership Qualifications sections above. In addition to sector seat diversity, membership on the RSC should consider the following criteria in the selection of sector and at-Large representatives:

• Geographic and International (Canadian/Mexican) diversity, including a goal of having representatives based in each RE’s area and each Interconnection.

• Sector, size, and asset (transmission, distribution, load, generation, etc.) diversity; and,

• Subject matter expertise in Operations, Planning, and/or Security including a reasonable balance of expertise among these three areas.

Nominations for sector members (Sectors 1-10 and 12) will be called for annually under a process that is open, inclusive, and fair, similar to the annual nomination process of the existing OC and PC. The nomination process will be completed in time for the secretary to send the list of nominees to the RSC Nominating Committee. Sector and at-large nominees may not represent more than one RSC sector at any one time and no single organization, including its affiliates, may have more than one member on the RSC. RE employees are not eligible to be at-large representatives. The SET did not include the existing Sector 11 (Regional Entity) representation in the proposed model. The exclusion of Sector 11 reflects the maturation of the ERO enterprise and coordination within and between REs. See Appendix C for sector and at-large definitions and descriptions. Board Appointment and Membership Terms Members are appointed to the RSC by the Board and serve on the RSC at the pleasure of the Board. Member terms are two years (with half of the terms ending in odd years and the remaining half ending in even years for both Sector and At Large representatives). Vacancies are filled using the same process as selection. Officers Officers will serve two-year terms and shall be selected as follows:

• Chair and vice chair selections are through nomination by the RSC with confirmation by the NERC Board.

• The chair and vice chair shall not be from the same sector.

• No individual may serve more than one sequential term as chair and one term as vice chair unless approved by the Board.


Chapter 6: Executive Committee Authorization The executive committee of the RSC is authorized by the RSC to act on its behalf between regular meetings on matters where urgent actions are crucial and full RSC discussions are not practical. Ultimate RSC responsibility resides with its full membership whose decisions cannot be overturned by the executive committee, and which retains the authority to ratify, modify, or annul executive committee actions. Membership The RSC will select an executive committee of six members, with consideration of sectors, Regions, Interconnections, and other representation factors, as follows:

1. Chair

2. Vice-chair

3. Four members from different sectors selected by the RSC Chair and Vice-Chair with subject matter expertise in Operations, Planning, and/or Security including a reasonable balance of expertise between the three areas. These members will be confirmed by the full RSC.

Terms The executive committee will be replaced every two years, with the chair and vice chair replaced at the June meeting and the remaining four replaced at the September meeting. Vacancies between cycles may be filled by RSC leadership and approved by the RSC at its next meeting.


Chapter 7: Industry Review and Comment Timeline The SET presented the two options described in Chapter 3 to the MRC at their May 2019 meeting and requested feedback on these options. In light of that feedback and further consideration, the SET decided unanimously that Option 2 was preferable to Option 1 and has worked over the May-July period to refine the details of the proposed RSC for stakeholder feedback and further MRC and Board consideration. The SET will conduct an industry comment period from July 12-August 15, 2019 and conduct an industry webinar on August 8, 2019. There will be an MRC Informational Session webinar on July 19, 2019 to inform industry of the SET’s recommendations and to define the Policy Input questions regarding the proposal. There will be a Policy Input period July 11-31, 2019. The proposed recommendation will be presented to the MRC for policy input at their August 14, 2019 meeting. The SET may make revisions to the proposal based on MRC feedback. The final recommendation will be presented to the Board at their November 6, 2019 meeting with implementation to begin January 1, 2020.


Chapter 8: Elements of a Charter for the Reliability and Security Council The SET reviewed existing charter and scope documents and recommends including the following in the Reliability and Security Council Charter:

1. Membership

a. Representation

b. Selection

c. Terms

d. Vacancies

e. Proxies

2. Meetings

a. Frequency

b. Quorum

c. Voting

d. Confidential sessions

3. Officers

a. Terms

b. Conditions

c. Selections

4. Voting

5. Subcommittees, Working Groups, Task Forces

a. Formation and Cessation

b. Work Plan Approval Process


Appendix A: Stakeholder Engagement Team Roster

Table A.1: Stakeholder Engagement Team Roster Name Company Leadership Jennifer Sterling (MRC Vice Chair) Exelon Mark Lauby NERC Team Members Ken DeFontes NERC Trustee Fred Gorbet NERC Trustee Greg Ford (MRC Chair) Georgia System Operations Corporation Lloyd Linke (OC Chair) Western Area Power Administration Dave Zwergel (OC Vice Chair) MISO Brian Evans-Mongeon (PC Chair) Utility Services, Inc. Marc Child (CIPC Chair) Great River Energy Jennifer Flandermeyer (CCC Chair) Kansas City Power & Light Jason Marshall Wabash Valley Power Alliance Patti Metro NRECA David Short IESO Martin Sidor NRG Energy, Inc. Scott Tomashefsky Northern California Power Agency Jeffrey Cook Bonneville Power Association Michael Desselle Southwest Power Pool Additional Participants Edison Elizeh Bonneville Power Association Gaurav Karandikar SERC Phil Fedora NPCC David Zwergel MISO Jim Albright TexasRE Dave Godfrey WECC Tim Ponsetti SERC Melinda Montgomery SERC Maggie Peacock SERC John Odom FRCC Eric Senkowicz FRCC Jeff Craigo RF Ray Palmieri RF NERC Staff James Merlo Tom Hofstetter Sam Chanoski Nina Jenkins-Johnston John Moura Trion King Stephen Crutchfield Sandy Shiflett Mark Olson


Appendix B: Existing Participation Models

Table B.1: Existing Participation Models RISC CIPC OC/PC Pool of Experts Regional Entity Representation Balanced Sectors Member Composition

6 – Stakeholder based • 4 – MRC • 2 – At-Large

5 – Committee based

• 1 – from each of the standing committees (OC/PC/CIPC/CCC/SC)

32 Voting Members • 24 – registered entities

(3 from each Regional Entity)

• 2 – Canada • 2 – Policy Experts • 2 – APPA • 2 – NRECA

29 Voting Members • 27 – Sectors 1-129 • 2 – Chair and Vice Chair

Selecting Body

Stakeholder Based Nominating Committee (chaired by the MRC Vice-Chair) presents a recommended slate of candidates to the Board. Committee Based Board appointed

Self-nomination from groups identified above Subject to removal by Executive Committee

Candidates are elected by the registered NERC Members in Sectors 1-10 and 12. Members in Sector 11 are appointed by the Regional Entity.

Criteria Geographic and International diversity, such that Eastern, Western, and Texas Interconnections, along with Canada are represented on the RISC; Sector, size, and asset (transmission, distribution, load, generation, etc.) diversity; High-level understanding and perspective on reliability risks; Experience in a leadership role or background in an executive-level position is strongly preferred; and Balanced consideration of these criteria, across the entire membership of the RISC.

Each RE’s voting members must collectively have expertise in physical security, cyber security and operations

Investor-Owned Utility State/Municipality Cooperative Utility Federal or Provincial Utility / Federal Power Marketing Administration Transmission Dependent Utility Merchant Electricity Generator Electricity Marketer Large End-User Electricity Customer Small End-User Electricity Customer Independent System Operator / Regional Transmission Organization

9 Sectors 1-3, 5-9, and 11-12 have two voting members each. Sector 4 has four voting members and Sector 10 has three voting members.

Appendix B: Existing Participation Models


Regional Entity State Government Officers

Non-Voting Members

Identified list of organizations Government representatives (including Canada) Secretary Chair and Vice Chair of the subcommittees


Appendix C: Reliability and Security Council Member Definitions

RSC Members Name Definition Members Voting Members 1. Investor-Owned Utility This sector includes any investor-owned entity with substantial

business interest in ownership and/or operation in any of the asset categories of generation, transmission, or distribution. This sector also includes organizations that represent the interests of such entities.

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2. State/Municipal Utility This sector includes any entity owned by or subject to the governmental authority of a state or municipality, that is engaged in the generation, delivery, and/or sale of electric power to end-use customers primarily within the political boundaries of the state or municipality; and any entity, whose members are municipalities, formed under state law for the purpose of generating, transmitting, or purchasing electricity for sale at wholesale to their members. This sector also includes organizations that represent the interests of such entities.

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3. Cooperative Utility This sector includes any non-governmental entity that is incorporated under the laws of the state in which it operates, is owned by and provides electric service to end- use customers at cost, and is governed by a board of directors that is elected by the membership of the entity; and any non-governmental entity owned by and which provides generation and/or transmission service to such entities. This sector also includes organizations that represent the interests of such entities.

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4. Federal or Provincial Utility/Federal Power Marketing Administration

This sector includes any U.S. federal, Canadian provincial, or Mexican entity that owns and/or operates electric facilities in any of the asset categories of generation, transmission, or distribution; or that functions as a power marketer or power marketing administrator. This sector also includes organizations that represent the interests of such entities.

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5. Transmission dependent Utility

This sector includes any entity with a regulatory, contractual, or other legal obligation to serve wholesale aggregators or customers or end-use customers and that depends primarily on the transmission systems of third parties to provide this service. This sector also includes organizations that represent the interests of such entities.

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6. Merchant Electricity Generator

This sector includes any entity that owns or operates an electricity generating facility that is not included in an investor-owned utility’s rate base and that does not otherwise fall within any of sectors (i) through (v). This sector includes but is not limited to cogenerators, small power producers, and all other non-utility electricity producers such as exempt wholesale generators who sell electricity at wholesale. This sector also includes organizations that represent the interests of such entities.

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7. Electricity Marketer This sector includes any entity that is engaged in the activity of buying and selling of wholesale electric power in North America on a physical or financial basis. This sector also includes organizations that represent the interests of such entities.

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Appendix C: Reliability and Security Council Member Definitions


RSC Members Name Definition Members 8. Large End-User Electricity Customer

This sector includes any entity in North America with at least one service delivery taken at 50 kV or higher (radial supply or facilities dedicated to serve customers) that is not purchased for resale; and any single end-use customer with an average aggregated service load (not purchased for resale) of at least 50,000 MWh annually, excluding cogeneration or other back feed to the serving utility. This sector also includes organizations that represent the interests of such entities.

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9. Small End User This sector includes any person or entity within North America that takes service below 50 kV; and any single end- use customer with an average aggregated service load (not purchased for resale) of less than 50,000 MWh annually, excluding cogeneration or other back feed to the serving utility. This sector also includes organizations (including state consumer advocates) that represent the interests of such entities

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10. Independent System O perator/Regional Transmission Organization

This sector includes any entity authorized by the Commission to function as an independent transmission system operator, a Regional transmission organization, or a similar organization; comparable entities in Canada and Mexico; and the Electric Reliability Council of Texas or its successor. This sector also includes organizations that represent the interests of such entities.

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12. State Government This sector includes any state government department or agency in the United States having a regulatory and/or policy interest in the Bulk Electric System (BES).

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Officers Chair and Vice Chair 2 At Large Entities that collectively meet the following general criteria for

balanced representation: (i) geographic diversity from all U.S. interconnections and ERO Enterprise Regional Entities, (ii) high-level understanding and perspective on reliability risks based on experience at an organization in the electricity sector, (iii) operations, planning and/or cybersecurity experience and expertise from an organization in the electricity sector, and, (iv) experience in an executive-level position at an organization in the electricity sector. Excludes Regional Entity staff.

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Non-Voting Members Government Representatives

This sector includes any federal, state, or provincial government department or agency in North America having a regulatory and/or policy interest in wholesale electricity. Entities with regulatory oversight over the Corporation or any Regional Entity, including U.S., Canadian, and Mexican federal agencies and any provincial entity in Canada having statutory oversight over the Corporation or a Regional Entity with respect to the approval and/or enforcement of Reliability Standards, may be non-voting members of this sector. United States Federal Government 2 Canadian Federal Government 1 Provincial Government 1

Secretary The committee secretary is a NERC staff member appointed by NERC management and will be seated at the committee table

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MEMORANDUM

TO: Roy Thilly, Chair NERC Board of Trustees

FROM: Jack Cashin, Director, Policy Analysis and Reliability Standards, American Public Power Association John Di Stasio, President, Large Public Power Council John Twitty, Executive Director, Transmission Access Policy Study Group

DATE: August 6, 2019

SUBJECT: Response to Request for Policy Input to NERC Board of Trustees

The American Public Power Association, Large Public Power Council, and Transmission Access Policy Study Group concur with the Policy Input submitted today by the State/Municipal and Transmission Dependent Utility Sectors of the Member Representatives Committee, in response to NERC Board Chair Roy Thilly’s July 11, 2019 letter requesting policy input in advance of the August 2019 NERC Board of Trustees meetings.

NERC Board of Trustees Policy Input – Canadian Electricity Association

Quebec City, Quebec; August 14-15, 2019 The Canadian Electricity Association (“CEA”) appreciates this opportunity to provide policy input for the NERC Member Representatives Committee (“MRC”) and Board of Trustees (“Board”). Summary of Key Points:


• The proposed structure has the potential to deliver a wider view on topics, as the impact of greater digitalization moves the industry towards a greater mixing of traditional planning, operating, and

security roles. In order to fully realize the benefits of the RSC model, and to avoid unintended consequences, NERC should further develop and clarify the following issues: RSC membership and effective Canadian representation; agenda-setting and prioritization of issues; cyber security considerations; ensuring North American perspectives; and ensuring this proposal complements wider NERC effectiveness and efficiency efforts.

• Clarification is requested regarding expected budget savings, and the future of the Standing Committee Coordination Group resulting from a transition to an RSC model.

• NERC may wish to consider renaming the RSC to minimize confusion between the RSC and RISC.

• CEA is supportive of the policy input letter comments from the Federal Utilities and Federal Power Marketing Administrations - Sector 4, submitted by Lloyd Linke.

Proposal for Restructuring NERC Technical Committees

• CEA thanks NERC and the Stakeholder Engagement Team for the ongoing effectiveness and efficiency efforts, including efforts to ensure NERC’s stakeholder engagement structure allows it to best realize its mission of effective and efficient reduction of risks to the reliability and security of the grid as the industry model and reliability considerations evolve. The proposed structure has the potential to deliver a wider view on topics, as the impact of greater digitalization moves us toward a greater mixing of traditional planning, operating, and security roles.


• In order to fully realize the potential benefits of the RSC model and to avoid unintended consequences, NERC should further develop and clarify the concept of the RSC model, particularly for the following elements:

o RSC membership & recruitment

▪ While evolving reliability issues faced by the industry may require solutions and expertise that expand across traditional operating frameworks, many companies are still internally structured through a planning/operations/security model. Technical expertise in many cases is still developed within this framework as well, with people developing knowledge within a certain industry area. This reality may make it challenging to identify RSC members who can bring the necessary breadth of knowledge and experience to work across these industry areas. Additionally, under the current construct subcommittee members could work their way up to leadership roles in the three technical committees over time, as expertise in a certain technical area was gained. NERC should also consider that working up to RSC membership may be more difficult under the RSC model, unless exposure is gained in all three areas.

o Agenda-setting and prioritization ▪ With the RSC model, streamlining could lead to less time and consideration for important

issues previously accorded their own committees. At the same time, it could also lead to the inability for the RSC adequately focus agendas and attention on the highest priority issues if there is an inability to prioritize or adequately manage subcommittee and task-group work. Care must be taken to ensure that issues addressed by the RSC are well-prioritized, while also guarding against dilution of attention due to a higher number of issues being overseen by one group rather than three.

o Cyber security ▪ Cyber security is an area of evolving and growing concern with unique challenges that

require highly tailored expertise to address. As such, it may be challenging for cyber-specific work to be undertaken under a merged committee structure. NERC should consider how to ensure that the right expertise, and sufficient attention, is focused on this issue.

o North American-wide representation ▪ As NERC is a North American regulator overseeing an integrated bulk power system, care

must be taken to ensure Canadian perspectives are equally considered alongside American ones.

▪ CEA appreciates that some consideration has been made to ensure Canadian representation on the RSC. That said, NERC should ensure that there is adequate Canadian representation from across the country, and that there is not a reduction of consideration to Canadian issues relevant to Bulk Power System reliability. Ongoing care must be taken to ensure adequate Canadian and North American wide representation on the RSC.

▪ In addition to RSC membership, NERC should consider how to ensure adequate Canadian

membership and mandates to include North American perspectives, when relevant, for the

subcommittees, working groups and taskforces the RSC would oversee. As these subcommittees and groups would conduct most of the technical detail work for the RSC, it would be beneficial to have this clarified at this stage of RSC development.

o Overall effectiveness and efficiency efforts ▪ This proposal is part of an initiative to improve the effectiveness and efficiency of how

stakeholders engage with NERC, with this stakeholder initiative being a part of a wider NERC endeavor to review the effectiveness and efficiency of ERO Enterprise operations. NERC must take care to ensure that proposals that stem from different parts of this wider endeavor are developed in a measured and coordinated fashion so that they serve to complement and reinforce each other. Additionally, changes that serve to increase the effectiveness and efficiency with one aspect of NERC should complement other areas of NERC that work well.

▪ NERC should consider that the restructuring of this aspect of stakeholder engagement may lead to steps to potentially restructure or streamline additional subcommittees and working groups, or other NERC committees, and what those next steps may look like should be considered with a holistic approach. A longer-term plan that can be shared with stakeholders may also be an output of this existing process. As such, NERC should consider what timeline or milestones may allow a sufficient window for the RSC to develop its working process and to work through any operating issues before developing further restructuring plans (if appropriate), and to strike the right balance of neither rushing nor delaying.

• Other aspects which CEA would encourage NERC to clarify include: o Identifying the expected budget savings as a result of the change to an RSC model. o Whether the Standing Committee Coordination Group (“SCCG”) will continue in a modified form

under the RSC model, or be phased out.

• CEA would also encourage NERC to consider: o Whether a different name for the RSC may minimize possible confusion with the Reliability Issues

Steering Committee (“RISC”), which also reports to the Board.

CEA thanks the Board for considering these comments. CEA and its members look forward to continuing the discussion in Quebec City. Dated: August 6, 2019. Contact: Francis Bradley President & CEO Canadian Electricity Association [email protected]

Policy Input for the NERC Board of Trustees Provided by the Edison Electric Institute August 6, 2019 On behalf of its member companies, the Edison Electric Institute (EEI) appreciates the opportunity to provide the following policy input for the NERC Board to review in advance of the meetings in Quebec. EEI perspectives on bulk power system (BPS) reliability are formed by the CEO Policy Committee on Reliability, Security, and Business Continuity and the Reliability Executive Advisory Committee with the support of the Reliability Committee. We look forward to an active discussion on the Stakeholder Engagement Team Proposal (SET Proposal) at the upcoming meetings. Summary of Comments

• EEI supports the concepts and ideas presented in Option 2, which should result in a more streamlined approach for addressing risk to the BPS because it will support coordination among the committees, remove silos, and ensure the prioritization of reliability and security stakeholder roles.

• EEI recommends providing additional time to effectively transition to this new structure because of the significant transformation required for successful implementation of the proposal.

• EEI recommends that sector representatives be elected by the sector they serve, with NERC Board of Trustees (BOT) oversight.

• EEI recommends that the at-large member nomination process be similar to the Compliance and Certification Committee (CCC) nominating committee model, which includes BOT oversight.

• EEI recommends removing references to the requirement that members of the Reliability and Security Committee (RSC) have executive leadership experience.

• EEI recommends providing additional clarity in how the roles and expectations of the RSC and Reliability Issues Steering Committee (RISC) differ.

Stakeholder Engagement In the July 12, 2019 policy input letter, NERC Board of Trustees Chair, Roy Thilly, asked for input on the stakeholder engagement initiative with the objective of improving it by restructuring the NERC Technical Committees. EEI supports efforts

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to re-examine the NERC standing committees to improve their effectiveness and efficiency. Specifically, EEI supports the coordination and collaboration of workplans to prevent duplication of efforts and remove silos. The proposal should also ensure a smooth transition for the subject matter experts and the prioritization of reliability and security stakeholder roles.

EEI joins NERC and the Stakeholder Engagement Team (SET) in support of the concepts and ideas presented in Option 2 of the proposal. Option 2, which combines the three committees into a new oversight committee, should result in a more streamlined approach for addressing risk to the BPS. To strengthen the final SET Proposal, EEI offers the following suggestions for the NERC BOT to consider.

A longer transition period is needed because Option 2 represents a substantive change from the current structure. The proposed January 2020 implementation date likely will not provide enough time to address the details in the implementation plan and charter to transition to this new structure in a methodical, transparent manner. To accommodate this transformation, additional time and details are necessary. EEI recommends a longer transition period, but no later than June 2020, to implement the new direction and allow time for effective change management to ensure the success of this path moving forward.

Additionally, EEI recommends modifications to the proposed RSC membership selection process, including consideration of a hybrid nomination process. Sector representation should be elected by each sector with final approval by the NERC BOT, prior to selection of at-large members. At-large seats can then be determined based on the identified criteria, through a nominating committee. Selecting at-large members after sector representatives are confirmed will ensure geographic diversity, size, and subject matter expertise is represented. EEI recommends that the nominating committee membership and process be similar to the CCC nominating subcommittee. Including representatives from each sector in all NERC standing committees is fundamental to maintain the integrity of the stakeholder driven process, which is crucial to the success of the ERO Enterprise model.

Additionally, EEI supports the exclusion of Sector 11 (Regional Entities) in the SET Proposal.

The NERC Board should address more clearly industry participation at the RSC meetings. Guidelines should ensure that meetings are open to industry and that sufficient space is available for industry to participate. This is essential to maintain critical peer-to-peer networking and discussions. Additionally, the SET Proposal should address clearly how information sharing and informational sessions will continue in the proposal. These sessions are a key component of existing technical committee agendas.

Understanding that the SET Proposal has undergone multiple iterations, references to requirements for executive leadership experience for the RSC members may be a

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holdover from previous drafts and, if so, should be removed from the final SET Proposal.

Finally, Option 2 should clarify coordination among the RSC, RISC, and other NERC Committees to address effectively the priorities the RISC identifies. This coordination is a key factor in Option 2. There also appears to be overlap between the roles of the RSC and RISC as currently described. The NERC Board should clarify how these roles and expectations differ in the final SET Proposal.

Thank you for the opportunity to provide policy input. As previously stated, EEI supports the concepts and ideas presented by the SET and looks forward to working with NERC to continue strengthening the proposal for this transformative effort.

Sector 8 Policy Input for the NERC Board of Trustees & Member Representatives Committee

August 14-15, 2019 Meetings in Quebec City, Canada

ELCON, on behalf of Large End-Use Consumers, submits the following policy input for the consideration of NERC’s Board of Trustees (BOT) and the Member Representatives Committee (MRC). It responds to BOT Chairman Roy Thilly’s July 11, 2019 letter to Greg Ford, Chair of the MRC.

SUMMARY

• The proposal to replace the NERC CIPC, OC, and PC with the RSC — Large Consumers support the effort to improve the efficiency and effectiveness of stakeholder engagement by creating a central committee overseeing the three standing committees. Both Option 1 and Option 2 would serve this function and Option 2 to create the RSC was the unanimous preference of the stakeholder engagement team (SET). Large Consumers, as a resource-constrained sector, expect to participate more robustly under a central committee model than in disaggregated venues. Large Consumers support the creation of the RSC subject to modifications of the participation model. Large Consumers also suggest consideration of an RSC model limited to operations and planning, leaving security to a separate committee, if the RSC model appears strained to represent all three subject matter areas sufficiently.

• The proposed participation model of the RSC — The RSC model requires modification to be successful. Two changes are essential: 1) a minimum of two representatives per sector is critical to provide sector balance and 2) sectors should retain the right to elect their own representatives. Additional modifications, such as RSC members elected their own leadership, would benefit RSC performance.

• The best way to implement the transition from three technical committees to the RSC – The timeframe to present the final SET recommendation at the November 6, 2019 NERC Board meeting with implementation starting January 1, 2020, is a tight timeframe. Full implementation in Q1 2020 may prove challenging, and quality should not be sacrificed for expediency. An interim phase-in structure may be necessary to ensure existing work at the standing committees continues

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uninterrupted. Large Consumers emphasize that the process to disassemble standing committees and reorient subcommittees be mindful of intended and unintended consequences, such as the transfer of institutional knowledge.

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Replacing the Three Standing Committees with the RSC

Large Consumers support the effort to improve the efficiency and effectiveness of stakeholder engagement by creating a central committee overseeing the three standing committees. The stakeholder engagement team (SET) considered two options: 1) create an oversight committee and retain the existing standing committees or 2) create the Reliability and Security Council (RSC) to replace the standing committees and retain only the subcommittees. Sector 8 comments are focused on Option 2, having recognized that the SET decided unanimously that Option 2 was preferable to Option 1. Sector 8 also raises the question of whether security expertise should be integrated with a consolidated approach to planning and operating expertise.

Sector 8 believes integrating planning and operating expertise is a more natural fit but including security may stretch the ability of the RSC to function effectively across all three subject matter areas. Sector 8 supports consideration of a third option: having the OC and PC replaced by the RSC but retain a separate security committee. Any security committee should be configured to achieve sector balance. For example, if one representative per sector is pursued, the number of at-large seats available to any sector should not outweigh the number of sector-designated seats.

Regardless, consolidating the standing committees will enhance the ability of resource-constrained sectors to participate, including Large Consumers. For example, each ELCON company with registered entities has one to three full-time equivalents assigned to NERC/RE activities. ELCON, as the Sector 8 trade association, has one position dedicated in part to NERC issues. As such, Sector 8 is incapable of populating dozens of committees, subcommittees, task forces, and working groups. Therefore, the limited participation of Sector 8 is a reflection of resource constraints, not a lack of interest. It is critical that RSC governance decisions protect the rights and standing of resource-constrained sectors and enhance avenues to ensure fair representation. Generally, Sector 8 expects to participate more actively in venues with broad oversight, like the RSC, whereas the benefits to participation are diffuse in more concentrated venues.

The process to disassemble standing committees and reorient subcommittees must be mindful of intended and unintended consequences. Standing committees have unique cultures, areas of expertise, and processes that reflect much fine-tuning over the years. These insights, along with transferring other forms of institutional knowledge, warrant careful consideration through a careful RSC implementation process. Integrating disparate forms of expertise has benefits in a matrix format but the challenges may vary unevenly across different subject matter combinations. For example, combining planning and operating committee functions may face fewer barriers than integrating them with security issues.

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Large Consumers are confident that SET can address these barriers with a sufficient implementation process and timeframe by the November 2019 BOT meeting. Sector 8 support for the creation of the RSC is predicated on several revisions to the proposed participation model, which are necessary to provide robust sector representation on the RSC.

Proposed Participation Model of the RSC

Sector 8 believes the proposed RSC participation model requires modification to be successful. The proposal consists of a chair and vice chair, one representative per sector (Sectors 1-10 and 12), 20 at-large representatives, and five non-voting members. Nominations for Sector and At-Large seats would be selected by a Nominating Committee consisting of the NERC Board Vice Chair, NERC Chief Executive Officer, MRC Vice Chair, and the RSC’s Chair and Vice Chair.1 Large Consumers are very concerned that this would result in sector imbalance in RSC composition, especially as the depth of subject matter expertise varies across sectors.

Two modifications are imperative for the RSC to be successful:

1. The minimum number of representatives per sector should be two. One representative for some sectors would not provide broad representation and diversity of stakeholder views. Increasing this to two representatives per sector, while holding total membership constant, would result in nine at-large positions. This is sufficient for the nominating committee to fill in any gaps in regional diversity or expertise. If a sector cannot fill its two seats, the position can default to the applicable term for an at-large position.

2. Sectors should retain the right to elect their own representatives. As proposed, a nominating committee selecting representatives on behalf of a sector may create representation flaws and stakeholder discontent. Sector stakeholders are better positioned to know which of their own are best suited to represent the sector’s perspectives on RSC issues, as well as which subject matter experts are best suited to contribute to an oversight committee. Peer sector voting has been successful in other committees to-date in achieving geographic diversity, while providing expertise. The BOT would still retain authority over final membership decisions, and the nominating committee would retain the ability to fill-in any criteria gaps with at-large selections.

Sector 8 also emphasizes other criteria points for RSC membership:

1 For approval by the NERC Board of Trustees.

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• RSC leadership should be elected by the RSC. RSC leadership, specifically the Chair and Vice Chair positions, should be elected by the full RSC, subject to BOT confirmation. This is important for a self-governing stakeholder body and will provide for balance in the nominating committee to select at-large members of the RSC.

• Sector balancing criteria. It is unclear how the various criteria discussed in the proposal will be weighed. If a formulaic approach is unworkable, minimum parameters for sector balance should be established at a minimum. This is critically important if the RSC retains one representative per sector.

• Sectors should retain autonomy over term limits. Resource-constrained sectors do not have the depth of personnel that other sectors possess. Restricting the ability of personnel to remain on consecutive terms would severely diminish the quality of representation and expertise on the RSC, while imposing a disproportionate burden on Large Consumers.

• Ensure minimum RSC membership qualifications do not accidentally preclude quality candidates. RSC membership should be comprised of individuals with direct experience in planning, operations, and security to maximize its objectives. Executive experience should not be a requirement and may conflict with the objectives of creating the RSC. Electric industry expertise is uncommon and typically not a requirement for executives of companies outside the utility industry, such as industrial consumers. The vast majority of electricity expertise in non-utility companies are not in executive positions (e.g., energy procurement directors) and should be eligible to participate in the RSC. Unnecessary RSC eligibility restrictions would restrict expertise available to the RSC, thus undermining the objective of having greater expertise at the RSC’s disposal.

Transition Implementation

Initiating implementation in Q1 2020 would be feasible but full implementation may prove challenging on this timeframe, presuming the revised SET proposal obtains NERC Board approval in November 2019. Several elements will be important to achieve effective and efficient RSC implementation, most importantly establishing a communications and change management plan that adheres to all stakeholders. This includes establishing an implementation team or committee if necessary and selecting participants, a timetable for milestones, regular progress updates communicated to stakeholders, clarifications of the nuanced roles and responsibilities that align the RSC charter and subcommittee determinants with NERC’s mission, and formulating performance metrics. Developing measures of success, creating an RSC performance feedback mechanism, and ensuring the RSC process permits room for revision to tweak the model are important elements to instill up-front in the implementation phase.

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RSC implementation should take the necessary time for effective implementation; change management at this scale often takes about six months to complete. An overly aggressive timeframe may risk work disruptions and stakeholder dissatisfaction. Existing standing committees should not be dissolved prematurely. An interim RSC phase-in structure may be necessary to ensure existing work at the standing committees continues uninterrupted. This may require the RSC and existing standing committees to co-exist until new work processes and human capital arrangements have been finalized for the RSC and new subcommittee governance.

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TO: Roy Thilly, Chair NERC Board of Trustees FROM: Lloyd A, Linke Federal Utility/Federal PMA Portion Sector 4 DATE: August 5, 2019 SUBJECT: Response to Request for Policy Input to NERC Board of Trustees The Portion of Sector 4 representing the Federal Utilities and Federal Power Marketing Administrations (Federal PMA), appreciate the opportunity to respond to your July 11, 2019 letter to Mr, Greg Ford, Chair NERC Member Representative Committee, requesting input on certain policy issues. It is clear that the SET delved deeply into the workings of the Technical Committees and developed a streamlined organization to oversee the technical work of the Technical Committees. The Board requested MRC provide policy input on the following: The proposal to replace the NERC Critical Infrastructure Protection Committee, OC and PC with the RSC. It is important that this change doesn’t result in less stakeholder involvement or reduces stakeholder benefits. In order to accomplish this it is important that the benefits stakeholders receive from information sharing with national labs, technical reports, security briefings, lessons learned, cyber reports, training, etc. are important and need to continue. The proposed participation model of the RSC. The hybrid participation model and the number of members being suggested allows for the sectors to still have input on RSC membership, while establishing at‐large positions to allow the nominating committee to ensure geographical/international, sector, size, asset, and subject matter (planning, operating and security) diversity. The size of the proposed RSC is the minimum number of members that we believe would be needed to ensure adequate diversity of membership and additional thought should be given as to whether it should be increased. The current split between sector members and at‐large members is appropriate, given that the size of the at‐large membership will be critical in being able to maintain this diversity. The best way to implement the transition from the three technical committees to the RSC. Successful implementation will be a key factor in determining whether it is a great proposal or not. While the nomination process will require the selection of all the RSC members, it is important to a successful implementation that an adequate level of continuity is maintained from the current Technical Committees. We strongly suggest that when the nominating committee selecting the initial RSC members keeps this in mind, as it will allow for a more speedy transition after Board approval of the RSC.

The initial Chair and Vice Chair of the RSC will also have a vital role in ensuring a successful transition. The SET consider this and recommend an initial RSC Chair and Vice Chair to the Board at the November Board meeting, so they could participate in the proposed nominating committee that will be selecting the RSC members. The Federal PMAs support the comments provided by Canadian Electricity Association. As the CEA points out that it is important to ensure adequate Canadian representation, the Federal PMA’s also believe that it is important to ensure that there is adequate Federal PMA representation.

ISO/RTO Council’s (IRC) Policy Input to Board of Trustees August 31, 2019

The ISO/RTO Council 1 (“IRC”) appreciates the opportunity to respond to the Board’s request for policy input. The IRC offers the following response to Mr. Roy Thilly’s letter dated July 11, 2019, to the Member Representatives Committee (MRC) The IRC has prepared responses to the proposal for restructuring NERC Technical Committees and the topics below:

1. The proposal to replace the NERC Critical Infrastructure Protection Committee, OC, and PC with the RSC.

2. The proposed participation model of the RSC. 3. The best way to implement the transition from three technical committees to the RSC.

Summary Comments

The IRC supports the effort to review the existing committee structure to identify efficiencies that can be found after more than ten years of ERO operations. We do agree that there may be some efficiencies observed through combining the existing Operations and Planning groups. However, the IRC believes that including Security matters in the combined group does not improve efficiency. The IRC is also concerned with a different committee structure being proposed for the new committee. The IRC is not aware of any concerns with the existing structure of the standing committees or the Members Representative Committee (MRC), which may be a better model for the RSC.

I. The proposal to replace the Operating Committee, Planning Committee, and NERC Critical Infrastructure Protection Committee with the RSC.

There is reasonable justification for a committee that is responsible for both Operations and Planning. Recent joint meetings between the NERC OC and PC have proven productive due to

1 The IRC is comprised of the Alberta Electric System Operator (AESO), the California Independent System Operator Corporation (California ISO), Electric Reliability Council of Texas (ERCOT), the Independent Electricity System Operator of Ontario, Inc., (IESO), ISO New England, Inc. (ISO-NE), Midcontinent Independent System Operator, Inc., (MISO), New York Independent System Operator, Inc. (NYISO), PJM Interconnection, L.L.C. (PJM), and Southwest Power Pool, Inc. (SPP).

various existing and emerging issues that impact both Operations and Planning. Timely and improved communications between Operations and Planning will be helpful going forward.

Unlike others, the IRC has not struggled to participate in each of the three committees. Each committee is comprised of individuals with a specific skill set for the core work involved, and the IRC has been able to provide resources for each.

In contrast, it would be a challenge to find a single expert to address IRC issues for a consolidated RSC focused on Operations, Planning and Security issues – particularly because of the typical separation of Security from Operations and Planning functions. We understand that a consolidation may reduce NERC’s resource commitment; however those efficiencies need to be balanced with the technical commitment needed from the industry and the overall NERC budget.

We do not disagree that from time to time there is a need to have all groups come together for a common issue. However Security issues—whether Cyber or Physical—are usually different enough from Operations and Planning matters to warrant retaining a CIPC type of group to address Physical and Cyber Security. Because of the relatively few crossover topics between Operations/Planning and Security, the efficiencies gained through combining Operations and Planning may be lost if Security issues are added to the scope of the RSC. The IRC believes that the limited coordination needed between the operations/planning and security groups can still be achieved by joint meetings, as needed, similar to the current process.

If NERC does decide to address Security issues in a single committee, the IRC recommends a phased approach, beginning with combining the Operations and Planning Committees. Industry experience with that consolidation would permit some immediate efficiency, while allowing the combined committee time to adapt to working together before fully incorporating Security matters.

II. The proposed participation model of the RSC.

The IRC would like to better understand how the proposed participation model of the RSC would be able to adequately represent the diverse interests of the industry that the current committee structure can. We ask why the RSC could not be structured similar to the MRC, with two reps from each sector, which has worked well in the past. In the case of our recommendation, sectors could be populated with both an Operations expert and a Planning expert. This would provide a more balanced committee with adequate expertise from each sector. Other than a smaller total group size, it is not clear what working efficiencies will be obtained with the proposed structure.

The RSC Proposal suggested that the balance of the expertise will be filled by the 20 at-large seats. The IRC is interested to understand how NERC will ensure that the skill sets will be balanced among Operations, Planning and Security as emerging issues arise, in coordination with the sector positions.

The proposal also suggests that the sector representatives will no longer be elected by each sector. Rather, they will be presented to the Board by a Nominating Committee and the Board will vote on them. We can support a final vote by the Board; however, the IRC believes it is better situated to find candidates from its membership than the Board, and asks for the right to provide its sector nominees on the RSC. The RSC would still utilize the Nominating Committee to populate the at-large member sector.

III. The best way to implement the transition from three technical committees to the RSC.

The IRC is hopeful the transition will carefully consider the open items each of the existing committees are currently working through. Considering that the existing committees meet four times a year, a reasonable transition may be to allow for one or two joint meetings to occur prior to disbanding the existing committees, to ensure a proper close and transition of work from the old committees to the new. Thus, we recommend a transition period of no less than six months.

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North American Generator Forum

Policy Input to the NERC Board of Trustees August 15, 2019, Quebec City, QC, Canada

Provided by the North American Generator Forum

---------------------------------------------------------------------------------------------------------- The North American Generator Forum appreciates the opportunity to provide the following policy input in advance of the NERC BOT meeting.

Summary

Item 1: The proposal to replace the NERC Critical Infrastructure Protection Committee, OC, and PC with the RSC.

The NAGF agrees the RSC would increase the effectiveness and

improve the functional alignment with the RISC. Item 2: The proposed participation model of the RSC. The NAGF along with the NATF would be very interested in

participating on the RSC as a means to continue the forums collaborative support of the ERO.

Item 3: The best way to implement the transition from three technical

committees to the RSC. The NAGF suggests the RSC meet with the OC, PC and CIPC

leadership to discuss the current goals and activities of the various subcommittees, working groups and task forces prior to the transition.

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Discussion Item 1: The proposal to replace the NERC Critical Infrastructure

Protection Committee, OC, and PC with the RSC. The NAGF agrees the RSC would increase the effectiveness and

improve the functional alignment with the RISC. The NAGF notes a concern regarding the transfer of knowledge. With the technical committees, knowledge transfer occurs at the meetings either during the formal presentations or during the informal discussions at break. The R & S Council may need to supplement document releases with more frequent workshops and WebEx’s.

Item 2: The proposed participation model of the RSC. The NAGF understands the functional model proposed and would be

very interested in participating along with the NATF as a means to continue the forums collaborative support of the ERO. The NAGF also notes the R & S Council Nominating Committee needs to ensure members have the technical expertise and familiarity with the emerging risks to be able to effectively evaluate and guide the various subcommittees, working groups and task forces. The NAGF would be very interested along with the NATF in being a member of Council as we currently work together to bring WebEx’s and workshops to the industry with the goals to identify emerging risks and develop strategies to mitigate those risks.

Item 3: The best way to implement the transition from three technical

committees to the RSC. With the subcommittees, working groups and task forces already in

place, NERC should establish the R & S Council then have the RSC meet with the OC, PC and CIPC leadership to discuss the current goals and activities of the different groups, develop a plan and then begin the evaluation of opportunities for consolidation.

Community

Confidentiality

Candor

Commitment

Open Distribution Copyright © 2019 North American Transmission Forum. Not for sale or commercial use. All rights reserved.

To: NERC Board of Trustees (BOT)

From: Thomas J. Galloway, NATF President and CEO

Date: July 31, 2019

Subject: NATF Policy Input to the NERC BOT (August 2019): Proposal for Restructuring NERC Technical Committees

The North American Transmission Forum (the “NATF”) appreciates the opportunity to provide policy input on the proposal to restructure the NERC technical committees (OC, PC, CIPC) for consideration by the NERC Board of Trustees.

Summary Input

• If the NERC Board of Trustees restructures the Technical Committees as proposed, the new Reliability and Security Council (RSC) should include a representative from both the North American Transmission Forum (NATF) and the North American Generator Forum (NAGF). This would help ensure line of sight between ERO managed activities and industry forum activities and initiatives, enhancing the opportunity to eliminate or avoid duplication of effort or potential gaps in solutions.

Full Input

NATF has reviewed the recommendation of the Stakeholder Engagement Team (SET) to establish a Reliability and Security Council (RSC) to replace the existing technical committees, as described in the draft Proposal for Restructuring NERC Technical Committees. If the NERC Board of Trustees decides to implement the SET’s proposal, the NATF recommends the RSC include a representative from both the North American Transmission Forum (NATF) and the North American Generator Forum (NAGF). This would help ensure line of sight between ERO managed activities and industry forum activities and initiatives, enhancing the opportunity to eliminate or avoid duplication of effort or potential gaps in solutions.

NERC and the NATF have entered into a memorandum of understanding in which NERC’s role is to identify existing and emerging risks to BPS reliability with support from industry stakeholders, including the NATF and its membership, and facilitate strategies and activities to appropriately address and effectively mitigate the identified risks. The NATF’s role is to support NERC in identifying and mitigating (where appropriate and practical) risks by providing input to characterize and validate the risks, identify other risk areas, and implement appropriate strategies and activities amongst its members to support mitigation of the identified BPS risks.

While the focus of the SET recommendation and the role of the RSC is on the activities of the NERC technical committees and their associated subcommittees, working groups, and task forces, solutions to industry risks and issues can also come from the industry forums (NATF and NAGF).

Including NATF and NAGF representatives to the RSC creates an approach to effectively address issues with scarce resources and reduce duplication, ensuring we have “the right people working on the right issues.”

cc: NATF Board: J. Jipping, E. Seidler NATF Staff: Keels, Carter, Aldred, Underwood

Policy Input From a Northeastern North American Reliability Perspective

By the NPCC Board of Directors

1. Proposal to Replace the NERC Planning, Operating and Critical Infrastructure ProtectionCommittees with a Reliability and Security Council

The NPCC Board supports the proposal to form a NERC Reliability and Security Council (RSC),

which will be similar in scope and nature to NPCC’s Reliability Coordinating Committee.

With the emergence of differing, asymmetric risks to reliability across North America, the NPCC

Board recommends that particular attention be paid to the criteria for RSC membership that

addresses geographic diversity.

The NPCC Board supports the inclusion of Regional Entity representatives as non-voting

participants at the RSC meetings to support the effective operation of the ERO Enterprise.

The NPCC Board recommends that RSC meetings provide WebEx/Teleconferencing access in

order to support efficient industry access to the deliberations.

In the interest of a successful, seamless transition, the NPCC Board recommends that the first

meeting of the RSC could immediately follow the final meetings of the existing technical

committees.

Submitted to the August 14, 2019 NERC MRC and August 15, 2019 NERC BOT Meetings

Affirmed by the NPCC Board of Directors July 30, 2019

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Cooperative Sector Policy Input to the NERC Board of Trustees August 6, 2019

The Cooperative Sector appreciates the opportunity to provide policy input to the NERC Board of Trustees (BOT) for policy issues that will be discussed at the August 14/15 NERC MRC, Board and Board Committee meetings. Summary of Policy Input

• The Cooperative Sector appreciates the opportunity to provide policy input on the important issues surrounding the future of the three technical committees and we support the effort to undertake this review as part of NERC Efficiency and Effectiveness initiative.

• If option 2 is selected by the BOT: o Roles for both the RSC and RISC will need to be more explicitly understood to ensure there isn’t

duplication of efforts; o There may be benefits to expand the Sector membership so that there are two representatives

from each of the 11 Sectors as more fully described below. • Cooperative Sector members are split on their preferred direction on restructuring the three technical

committees and further details are provided below. • The Cooperative Sector does not currently have input related to a transition plan.

Proposal for Restructuring NERC Technical Committees Item 1: The proposal to replace the NERC CIPC, OC and PC with the RSC

• The Cooperative Sector appreciates the opportunity to provide policy input on the important issues surrounding the future of the three technical committees. This is an important element of NERC’s efficiency and effectiveness initiative and we support the effort to undertake this review. At this time our input is based upon a split in opinions from our sector members.

• For those sector members who expressed a preference between the two options presented, option 2 was viewed as the best option to address the effectiveness and efficiency going forward for the three technical committees.

• An important consideration for option 2 is that tight coordination and communication will be necessary between the RSC and the RISC. Additionally, roles for both the RSC and RISC will need to be more explicitly understood to ensure there isn’t duplication of efforts.

• Not all sector members expressed a preference between the two options presented, and several themes were derived from those comments:

o There needs to be assurances provided that the most valuable aspects/services/forums provided by the three technical committees continue to be implemented in any new model. The technical committee members should be part of the decision-making process for making these determinations.

o Some found it challenging to understand the deliberations of the SET meetings and that meeting notes/minutes were not provided to industry. Additionally, the proposal states that the current technical committee members were surveyed for input on the existing committee structure, but the survey results were not made public. Being able to review the non-attributable survey results and meeting notes/minutes would help stakeholders better understand the decisions made by the SET and the views of the technical committee members.

o An increased understanding for the basis of the four conclusions in Chapter 3 would help stakeholders better understand the basis for the issues addressed in the proposal.

• Based on the Cooperative Sector’s split views on the proposal, we look forward to a good discussion during the MRC meeting on our issues and those of the other Sectors.

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Item 2: The proposed participation model of the RSC • The Cooperative Sector has the following issues with the participation model of the RSC:

o Regarding the option 2 Sector and At-large membership structure, there may be benefits to expand the Sector membership so that there are two representatives from each of the 11 Sectors, thereby reducing the At-Large members to 7 if the desire is to keep the total membership at 33. By increasing the Sector membership, each of the Sectors will have increased control over the skillsets to bring to the RSC. There is value in At-Large members, but having nearly double At-Large members compared to Sector members does not appear to provide the individual Sectors a large enough role for the focus on the work ahead.

o Additionally, there is concern that option 2 as proposed may not be optimal for ensuring the needed expertise will be represented across the membership. Giving the Sectors two members each is one potentially beneficial way to increase needed expertise, but in both the Sector and At-Large membership there needs to be more checks and balances to ensure that there are appropriate operations, planning and security experts represented in the membership.

Item 3: The best way to implement the transition from three technical committees to the RSC

• The Cooperative Sector does not currently have input on how to transition from three technical committees to the RSC primarily due to not knowing if the RSC option is in fact the direction the BOT will choose. After the BOT makes a final decision at a future meeting, that appears to be the best time to begin working on a transition plan from the current committee structure to the structure approved by the BOT.

Submitted on behalf of the Cooperative Sector by: Barry Lawson Senior Director, Regulatory Affairs National Rural Electric Cooperative Association (NRECA) 703.907.5781 [email protected]


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NERC Board of Trustees

Quebec, City, Canada August 14-15, 2019

Policy Input of the Merchant Electricity Generator Sector Sector 6, Merchant Electricity Generator Sector, takes this opportunity to provide policy input in advance of the upcoming North American Electric Reliability Corporation (NERC) Member Representatives Committee (MRC) and Board of Trustees (Board) meetings in Quebec City. In a letter to MRC Chair Greg Ford dated July 11, 2019, Board Chair Roy Thilly requested MRC input on the Reliability and Security Council Proposal. Sector 6 makes the following comments in response. Key Points

• Sector 6 supports Option 2 as the preferred model. • The processes under which the Reliability Issues Steering Committee (RISC) and

Reliability and Security Council (RSC) operate must be clearly defined. • Since the RSC is a technical committee requiring subject matter expertise, the criterion

for candidates needing executive experience should not be a factor for serving. • The number of at-large representatives may need to be adjusted to allow for adequate

technical stakeholder representation and expertise. Sector 6 Comments for Policy Input

The Merchant Electricity Generator Sector supports the work of the stakeholder engagement team and the proposed Option 2. We recognize the need for the technical committees to operate more effectively with fewer available experts, and this option encourages this to happen.

The RISC and RSC would be more closely aligned and must work in a well-defined process in order to be successful. The RISC has evolved in what it considers, the way it operates and what it delivers. We would like to see a process that more clearly addresses what the RISC will deliver to the RSC and how the RSC will interact with the RISC and NERC staff.

Since the RSC would be a technical committee, the criteria for representation should focus on the technical expertise within the sector. Overemphasizing executive experience for those serving on the RSC would reduce the number of qualified candidates available, especially in sectors where qualified representation is difficult to recruit. The RISC itself is a policy-focused committee that identifies the issues for the experts in the RSC to address and already uses executive experience as a selection criterion. The RSC should be fine seeking experts with management experience.

The Merchant Generators agree with the number of representatives on the RSC. It is about as large as it can be for effective oversight and discussion. The Merchant Generators understand

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that it can be difficult to balance the needed expertise in operations, engineering, and the numerous CIP functions to have effective representative expertise. We feel this is one area where further stakeholder input would be valuable. We understand the hesitancy from others regarding only one elected sector representative. We would support a change in how RSC members are selected or appointed if a simple satisfactory process can be identified that meets the overall technical needs of the RSC while satisfying stakeholder desires.

The Merchant Generators feel the March 2020 implementation date is aggressive, especially with the need to develop new charters and alter existing charters. As noted earlier, processes will need to be created, hopefully with stakeholder input, and this too will take time. Combined with the effort to fill the RSC we would be comforted to see another 6 months added to the timetable to fully address concerns.

Sincerely, /s/ Sector 6 Merchant Electricity Generator Representatives: Martin Sidor NRG Energy, Inc. Sean Cavote PSEG

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MEMORANDUM

TO: Roy Thilly, Chair NERC Board of Trustees FROM: Carol Chinn William J. Gallagher Roy Jones John Twitty DATE: August 6, 2019 SUBJECT: Response to Request for Policy Input to NERC Board of Trustees

The Sector 2 and 5 members of the NERC Member Representatives Committee (MRC), representing State/Municipal and Transmission Dependent Utilities (SM-TDUs), appreciate the opportunity to respond to the July 11, 2019 letter to Mr. Greg Ford, Chair of the MRC.

We appreciate the invitation for MRC member sectors to provide input on an important

policy and governance matter that is intended to improve the efficiency and effectiveness of NERC and the stakeholder process: the proposal to replace the NERC Critical Infrastructure Protection Committee (CIPC), Operating Committee (OC) and Planning Committee (PC) with the Reliability Security Council (RSC). Herein, the SM-TDUs provide policy input on the proposal.

We also provide additional input to thank NERC for launching the CIP Standards

Efficiency Review project. We look forward to discussing the proposal, along with other agenda package items at the

upcoming meetings of the Board of Trustees (BOT), Board committees, and the MRC on August 14-15, 2019 in Quebec City. Summary of Comments on Proposal to Restructure NERC Technical Committees

Both Option 1 and Option 2 provide the needed central oversight for the three standing committees. Importantly, Option 1 provides oversight by refocusing the OC, PC, and CIPC, while retaining the benefits those committees bring to NERC and the industry. If it is not acceptable as a long-term solution, Option 1 should be adopted as the mechanism for achieving an effective and efficient transition.

Should Option 2 be selected, then the following need to be employed:

o The Sectors should have three (3) representatives on the RSC, or in the alternative, a minimum of two (2) representatives.

o The Sector representatives and leadership should be elected by stakeholder groups, with BOT oversight.

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o The transition needs to be well thought out and structured, and then an appropriate timetable determined.

o Executive experience should not be a qualifying-criteria for RSC membership.

SM-TDU Comments on the NERC Board of Trustee’s Request for Policy Input

The SM-TDUs support NERC’s objective to improve effectiveness and efficiency and encourage NERC not to lose the value that the three stakeholder committees have brought to NERC for decades. Otherwise, the commitments made by individual stakeholders and their organizations to these committees would be lost. Consistent with that encouragement, SM-TDUs believe Option 1 would be a better approach to retaining the many benefits of the existing structure, while also ensuring committee coordination is focused on reliability and security priorities.

Option 1

The focus of Option 1 is to oversee the important work of the existing OC, PC, and CIPC committees, including the best aspects of both options by providing a central oversight committee. By directing priorities, the oversight committee will reorient the work of the existing three technical committees, without dissolving the existing OC, PC and CIPC committees. While we understand that the intent of the SET proposal is for the task forces and subcommittees to continue their efforts under the RSC, once it is established, the elimination of the three committees puts at risk the investment by current members and their sponsoring organizations, as well as the institutional knowledge and processes that have long contributed to the success of NERC’s mission.

While the SM-TDUs believe that the true efficiency promise lies with Option 1, we recognize that Option 2 appears to be the preferred approach. Thus, if Option 1 is not acceptable as a long-term solution, then, at a minimum, Option 1 should serve as the foundation for the transitional plan for Option 2 (as improved by implementing our suggestions below). Option 1 would allow for the needed oversight as the three committees can prioritize work as they are phased out in an orderly fashion.

Option 2 –Reliability Security Council -with Modifications

If the Electric Reliability Organization (ERO) is committed to selecting Option 2, then the SM-TDUs believe that it needs to be modified to be successful. The following explains the recommended modifications to ensure success for the RSC oversight entity.

• Role of the Reliability Issues Steering Committee

The success of Option 2 depends on the Reliability Issues Steering Committee (RISC) and assumes the RISC is a mature committee that has reached peak effectiveness. In the context of the proposal, that assumption needs to recognize that, although RISC was established to do triage, it does not perform that task as originally envisioned. Moreover, the RISC needs an established, repeatable process for setting priorities so that stakeholder members of the RISC can have an

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effective role in focusing on key priorities, with NERC staff support. The SM-TDUs recognize that the RISC members, along with NERC staff, are working on resolving these matters.

• RSC Members Should be Elected by Stakeholder Peers

The SM-TDU Sectors believe that to function effectively as a stakeholder committee, RSC members that are sector representatives should be elected rather than nominated as suggested in the Option 2 proposal. Sectors are best suited to self-select the Subject Matter Experts (SMEs) to represent them on the RSC; SMEs that are well-suited to understand and contribute to an oversight committee. There is no evidence that the existing system has led to uneven geographic representation or SME imbalance. On the contrary, diversity has been achieved through election. Additionally, the proposal does not adequately justify the nomination committee selecting the sector representatives as well as the significant number of at-large members. While the NERC BOT will still have final say on RSC membership, the election model would provide the needed transparency if the BOT does not accept an elected representative.

• The Composition of the RSC Should be Modified to Better Ensure Effective Sector Representation

As currently proposed, the RSC would have 11 sector representatives and 20 at large members, plus the RSC Chair and Vice Chair. Consistent with support for electing RSC members with adequate stakeholder expertise, the SM-TDUs strongly prefer that each of the 11 sectors elect three (3) representatives to the RSC to secure the technical expertise from each of the three substantive areas (OC, PC, and CIPC). At a minimum, to be effective, the RSC should have two (2) elected representatives from each sector. Allowing for only 1 representative per sector (11 sectors representative out of 33 proposed members – see page 12 of the SET proposal) is not sufficient to assure the broad representation and diversity of stakeholder views. The remaining 9 spots would be at-large positions, providing the nominating committee an opportunity to fill in any gaps in regional diversity or expertise. To the extent a sector cannot fill its two spots, that spot can default to the applicable term for an at-large position.

• RSC Leadership Should be Elected by the RSC

RSC leadership, similar to sector representatives, should be elected, rather than selected, through a nominating committee process. The Chair and Vice Chair of the RSC should be elected by the full RSC, subject to confirmation by the BOT. Adopting this approach, along with the other proposed changes to the composition and selection process for RSC members, will better ensure a balanced nominating committee for selecting the at-large members of the RSC. Allowing RSC members to elect the Chair and Vice Chair would also reduce the size of the RSC by two, enhancing its efficiency.

• RSC Membership Should Not be Limited to Executives

The qualifications for RSC membership should be modified. While executives with technical expertise may seem a good fit, the SM-TDUs believe requiring executive experience could lead to a less effective RSC. Requiring executive experience for at-large members (as provided on page 21 of the proposal) would be inappropriate, potentially excluding candidates with valuable technical knowledge and experience. A requirement of managerial/leadership experience

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coupled with the necessary technical knowledge would enable the members to provide the effective policy oversight that the RSC is intended to provide. Basing committee membership on titles rather than experience could serve to deny able contributors that would otherwise benefit the ERO. This could be especially true for small entities, where titles often do not tell the true story of leadership or experience.

• Transition Timetable

The SM-TDUs believe that the successful movement to an oversight committee, such as the RSC, is dependent on an adequate transition plan and timetable. As mentioned earlier, if not selected as a longer-term approach, Option 1 should be used as the foundation for a transition plan to Option 2. In any case, the process for planning and structuring the transition needs to be elongated to ensure that the existing work of the OC, PC, and CIPC effectively continues. The proposed March 2020 implementation date is unreasonable. This is especially true given the need to more fully develop the implementation plan and charter.

Additional Input Item – SER Phase 2

We appreciate NERC’s efforts to launch and support the CIP Standards Efficiency Review (SER). The SER has been an important effort and we commend NERC for completing Phase I. We look forward to engaging with NERC and the industry to advance the CIP SER.

Thank you for the opportunity to provide this policy input. We look forward to the

discussion at the meetings.

Stakeholder Engagement Team General Themes Note: Breakfast and lunch to be served at the meeting The following are the main general themes from the industry comment period July 12-August 15, 2019

1. The draft suggests the importance of "enhancing stakeholder engagement through the three technical committees" and "achieve a higher level of industry participation". Please explain how eliminating the three technical committees and replacing those with a much smaller (by over 66%) new oversight entity would improve stakeholder engagement.

2. In the NERC announcement, NERC says it will seek country diversity. Can you elaborate what is meant by country diversity? Will Canada, United States of American and Mexico all have equal representation in the new oversight committee? Will representation be based on other technical factors? How will country diversity be measured? The RSC should also seek to achieve gender and other forms of diversity. Please explain whether and how these and other such diversity and inclusion goals would be taken into account in the RSC formation.

3. One member per sector seems inadequate. Moreover, such an approach would eliminate any consistency of leadership between terms, etc., which currently exists under the two year term duration permitting at least one member with experience to participate at a time. There should be at least two members per sector for continuity and range of expertise. Each sector should be able to choose its own representation.

4. Empowering the RSC Executive Committee to vote and conduct unauthorized business between meetings is problematic. That format did not seem to work well for the PC.

5. RSC Membership definition chart indicates 20 At Large voting members, almost twice the amount of the sector representation. Given that these At Large members have no sector requirements, it is possible that these additional votes may be largely coming from one or two sector

6. Publish the meeting minutes from the meeting where this decision was arrived (trust those are indeed available, if not there is a bigger problem). Conduct additional open and well published meeting dates for industry participation in continued SET discussion.

7. Please explain what is meant by blurring and provide some examples of where this has occurred, so we can better gauge if this is a wide spread problem or if it is isolated.

8. Membership of the RSC would no longer include a Regional Entity Representative (Sector 11). This Regional Entity Representative may be an RE employee or someone else from a registered entity in a particular RE. The RE Representative provides a regional perspective for the RE that may not

Industry Comments – Stakeholder Engagement – August 29, 2019 2

be captured by the proposed structure. Footnote 5 indicates that Sector 11 would be non-voting participants at the RSC meetings.

9. I worry that at-large membership selection will be skewed towards large IOU's. The mechanism proposed does not set a minimum number for representative groups - each sector and each area of expertise.

10. A robust and systematic selection process must be developed and used to ensure the Reliability and Security Council is staffed only by individuals possessing a high level of the appropriate subject matter expertise.

11. BPA would like for NERC to implement appropriate metrics in order to measure over a period of time, duration to be determined, the efficiencies and effectiveness gained that would ultimately results to cost savings.

12. It is our recommendation that chair and vice chair of each technical committees to be part of initial RSC membership. This will also allow for a more speedy transition after Board approval of the RSC, and it will avoid creation of a gap between the e existing committees disband and when the new RSC is seated to ensure that review and approval of subcommittee, working group, and task force work products continues without interruption.

13. One of the reasons for the proposal is to reduce costs. This could be accomplished in other ways, such as reducing the number of meetings from 4 to 3. Another option would be to combine the OC/PC and leave the CIPC intact. Over the past few years the OC/PC have been working together more often, and there would be some benefit to be one committee for those topics.

14. Will the attendance count be limited? Folks who used to attend past OC, PC, and/or CIPC meetings may all want to attend the RSC meetings. Hence, there could be a potential to have 120+ people in the room at the RSC meetings.

15. The assignment of appropriate, knowledgeable support personnel is essential to the success of any advisory council and associated subcommittees, work groups, and task forces.

16. Because the consolidated oversight responsibilities of the RSC will address three major areas of expertise, GSOC recommends that NERC consider expanding sector representation to 2 representatives per sector and reducing the amount of At-Large representatives

17. Add criteria to ensure "balanced representation and expertise" within the RSC. Example criteria language is provided below: sector/At-Large representation shall be balanced through membership of 3 or 4 representatives with operational experience, 3 or 4 representatives with security experience, and 3 or 4 representatives with planning experience; or No more than 25% of the Sector or At-Large representation shall have the same experience-type, e.g., operating, planning, or security. At-Large representation shall be balanced amongst the sectors by ensuring that no more than 4 representatives from one (1) sector occupy seats in concurrent or overlapping terms.

18. GSOC recommends additional clarification regarding the membership of sectors in the Executive Committee on page 14. Without additional information and/or details, it is unable to evaluate whether there are appropriate controls to ensure balanced sector representation. For example,


can the Chair and Vice-Chair be from the same sector? Must the 4 represented sectors differ from the sectors of the Chair and Vice-Chair?

19. GSOC recommends that clear and consistent voting procedures be defined for the RSC and its associated subcommittees, working groups, and task forces and to ensure that representation is appropriate and balanced.

20. RSC membership should have a term limit.

21. The Membership Selection portion of the proposal should require that the RSC consider inclusion of owners/operators from each region.

22. It would be beneficial to clarify that the RSC meetings will be open for Registered Entity attendance, and not would not be limited to the proposed 30 members.

23. Clarify how the RSC meetings will incorporate the information sharing and awareness that current occurs at CIPC (e.g. through readouts from associated entities; National Labs; EISAC)

24. If the RSC is pursued in lieu of Option 1, consider an emphasis on technical capabilities of the membership that will collectively address the wide array of issues to be vetted.

25. GTC does not support the SET's recommendation for Option 2 in the proposal. The SET should consider that reducing the three technical committees to a single and much smaller committee will certainly reduce the input of the electric industry at the NERC committee level which will have a negative impact on future new and revised reliability standards. Other Regional Entities' efforts to improve efficiency, at least in SERC's case, resulted in keeping three technical committees. An alternate to Option 2 may be to only combine the PC and OC as many items in these committees overlap, but cyber security rarely overlaps with planning and operations.

26. GTC recommends to wait for NERC BOT approval prior to offering input on a transition plan. Whatever plan is approved, NERC should focus on industry engagement as there appears to be less and less actual engagement.

27. As the current chair of the Supply Chain Working Group (SCWG), the skill set of individuals for each of the current committees is too diverse to expect one individual to understand and stay current in the three major areas of the current committees (OC, PC and CIPC).

28. Additionally, and in particular to CIPC, notably absent from the discussion thus far has been any mention of the impact to, or involvement with, the E-ISAC. Their voice should be louder in the potential loss of stakeholder engagement due to the proposed retirement of the CIPC and their 500+ followers.

29. If the RSC Option 2 proposal is accepted by the BOT, GRE would support a proposal to codify mandatory minimum numbers of operations, planning, and security representatives within the Sector and At Large membership groups. If the sectors are allowed to self-nominate, as proposed by some earlier commenters, this will put additional pressure on the At Large seats to fill any subject matter expertise gaps. The RSC charter must address how these gaps will be identified and addressed.


30. GRE would like to specifically request that stakeholder "forums" be included in the final proposal to replace the concentrated dialog that is an intangible benefit to observers of the quarterly technical committee meetings. The proposed expanded meeting space at the Atlanta offices would make for a cost-effective option for hosting these events.

31. Suggest we have OC, PC and CIPC evaluate existing subcommittees and provide a report to RSC in March with recommendations for any structural/topic changes.

32. The SET should consider proposing how the RSC will coordinate with these other committees. Alternatively, provide background on how coordination has been deficient under the current structure so the RSC can develop mechanisms to enhance coordination in future. Also, given that industry members also participate on non-NERC stakeholder groups (e.g., NATF, GATF, trade associations), the SET should propose that the RSC recognize these other groups and explicitly consider and address potential overlaps.

33. It is important that this change doesn’t result in less stakeholder involvement or reduces stakeholder benefits. In order to accomplish this it is important that the benefits stakeholders receive from information sharing with national labs, technical reports, security briefings, lessons learned, cyber reports, training, etc. are important and need to continue.

34. With the proposed structure of the RSC to include Subject Matter Experts (SMEs) from differing sectors, regions, and twenty (20) at-large seats, there is a potential for non-subject matter experts to vote on, and affect, RSC issues outside of the SME’s area of expertise. SPP encourages the SET to consider an assurance into their process, that the BOT be aware of dissenting votes, and minority positions, on RSC endorsed initiatives.

35. Extend the proposed January 2020 implementation date to ensure details in the implementation plan and charter are addressed in a methodical and transparent manner that allows sufficient time for effective change management.