NERC, NPCC & New England

Compliance

Kathleen Goodman

Operations Compliance Coordinator

January 19, 2005 RC Meeting

ComplianceGeneral Information

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Reporting Structure

T ra n sm iss ionC o m pa n ies

G e ne ra tionC o m pa n ies

A re as(N e w E ng la n d , N e w Y ork , e tc .)

R e g io ns(N P C C )

N E R C

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2005 ISO-NE Compliance Responsibilities

Matrix Organization Layout

Jo h n N ord enC o n su lta n t

O p e ra tio n s A d m in is tra tive = N o rd e n (G o o dm a n)O p e ra tio ns T ech n ica l = G o od m an

P la n n in g A d m in is tra tive = B u rkeP la n n in g Te ch n ica l = H e n de rson

IT D ep a rtm e ntT B D

O ve ra ll C o m p lia n ce Re sp o ns ib ilit iesS te ve R ou rke

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Compliance Survey Timelines

Send out data request to appropriate Participants (i.e. generation, transmission) at least 2 months before due to NPCC

Give Participants at least 45 days to respond to ISO-NE

ISO-NE requires a minimum of 15 days to assimilate data for reporting Area Compliance to NPCC

NPCC reports Regional Compliance, based on Area submittals to NERC, if a NERC measure

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2005 Program Schedule

Will be published as soon as we have it NPCC dependent on NERC to set their

schedule ISO-NE dependent on NPCC to set schedule

based on NERC requirements, as well as NPCC requirements Once NPCC sets schedule, ISO-NE modifies to

include Participant-reporting requirement deadline to ISO-NE

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Participant Reporting Structure

Compliance Contacts Maintained Transmission Generation (by Lead Participant)

These are the Individuals who are held responsible for providing the data May request data from another individual

(i.e. station operator, protection engineer), but you are still accountable

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Compliance Contacts Maintained

One per Company - ONLY Will CC another individual, if requested

Will not maintain multiple contacts at same company

Need to have one person to call and notify of lateness

Very burdensome due to lack of administrative staffing levels Investigating the use of CAMS

Participants are responsible for notifying us of changes

NERC Version 0 Update

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“Plan for Accelerating the Adoption of NERC Reliability Standards” – June 15, 2004

Translation from existing requirements Existing Planning Standards, including post-

blackout Compliance Template revisions Existing Operating Policies, including post-

blackout Policy 5, 6 & 9 revisions This Committee was updated by John Norden at

their August 31st meeting

“Version 0” NERC Standards

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“Version 0” First Ballot Initial ballot conducted from December 3 through

December 13, 2004 87.4% of the ballot pool voted, achieving a quorum a weighted average of 94.4% affirmative vote by the

ballot pool indicating approval

Several negative votes with comments were cast, requiring a recirculation ballot in accordance with NERC's ANSI-accredited standards process. The recirculation ballot provides an opportunity for the

ballot pool to view the dissenting comments and reconsider their votes

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“Version 0” Final Ballot Results The recirculation ballot was held from December 20,

2004 through January 7, 2005 The Version 0 Reliability Standards Drafting Team

reviewed comments submitted with the ballots and prepared their consideration of the comments

Stakeholders voted to approve the Version 0 Reliability Standards by a 95.5% weighted average

The standards will now be forwarded to the NERC Board of Trustees for adoption on February 8, 2005. If adopted by the Board, the standards will become

effective on April 1, 2005

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“Version 0” Implementation If adopted by the Board, the standards will become

effective on April 1, 2005 Because Version 0 is based on existing Policy, NERC

expects industry to be fully compliant on April 1st

The first compliance reporting period will be April 1st through June 30th

Compliance based on Registered Entities (i.e. the Functional Model) and existing Compliance Templates – if their was existing compliance measures, if not, there are no measures

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“Version 0” ISO-NE Next Steps Project is aimed at preparing the ISO for the

conversion to Version 0 of the NERC Standards Perform Gap Analysis for the NERC Version 0

Templates with existing ISO-NE documentation Based upon the Gap Analysis finding, re-write and or

develop new Operating Procedures, M/L Procedures, SOPs, Planning Procedures etc. to fill gaps identified

Revise Compliance Procedure to ensure compliance and reporting responsibilities under Version 0, the NPCC RCEP, NRAP and ISO New England Standards

Re-write the Compliance SOP to include all compliance activities with “detailed” instructions

NERC Version 1 Update

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Standards Authorization Requests (SARs) – Proposition that a Standard be written for a specific Reliability need Industry determines whether or not it is

needed, based on vote

Six were posted for comment until January 7th

“Related” to Blackout Recommendations, requested to be expedited

“Version 1” NERC SARs

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Phase III/IV planning standards not included in Version 0; grouped into 4 SARs Blackstart Capability Disturbance Monitoring and Reporting Modeling Protection and Control

System Personnel Training Nuclear Offsite Supply Reliability

Posted “Version 1” NERC SARs

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Phase III/IV Planning Standards

“Certain planning standards that were part of the Phase III and IV NERC compliance program were not included in the Version 0 reliability standards.  The Version 0 drafting team, supported by industry comments, realized it could not achieve industry consensus on these specific standards in the timeframe or within the scope of the Version 0 standards project.  These standards are important, nonetheless, as they contain critical reliability requirements in support of recommendations from the NERC and U.S./Canada Power System Outage Task Force reports on the August 14, 2003 blackout.  Recognizing the importance of these standards, the NERC board resolved on October 15, 2004, that: "A satisfactory resolution of the issues regarding Phases III and IV of the planning standards would be to: (1) develop reliability standards covering the Phase III and Phase IV issues separate from the Version 0 effort, using the NERC standards development process; (2) have the Planning Committee expeditiously complete the drafting of the proposed standards needed to address the Phase III and Phase IV issues, and move those standards through the NERC standards development process as promptly as possible, but not later than the May 2005 board meeting."  This SAR proposes the development of reliability standards that address the disturbance monitoring and reporting requirements of those Phase III and IV planning standards.”

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Phase III/IV planning standards II.B Standards - System Modeling Data

Requirements – Generation Equipment

Field Verification• Verification of gross and net reactive power capability of

generators

• Test results of generator voltage regulator controls and limit functions

• Test results of speed/load governor controls

• Verification of excitation system dynamic modeling data

Contentious “Version 1” NERC SARs

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III.C Standards – Generation Control and Protection Prime mover control (governors) shall operate with

appropriate speed/load characteristics to regulate frequency…

Generator owners/operators shall analyze protection system operations…

Generator owners/operators shall have a generator protection system maintenance and testing program in place…

Generation representatives should be providing input!

More Generations “Version 1”NERC SARs

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“Version 1” NERC Standards

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“Version 1” Implementations?

Implementing some of these requirements could cost you money!

How will these costs be recovered? Are all these requirements necessary for BES

Reliability? Are the necessary requirements included in what will

ultimately come to pass? New England will have to be compliant with the NERC

requirements – if you have not been involved, you will be held to Standards that other people have drafted

NERC StandardsRecommendations

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Provide comments Process is designed to build greater stakeholder

participation and consensus as proposed standards proceed from the initial proposal to the final ballot

The NPCC builds consensus comments, for Member consideration; but we all provide individual company comments as well

The more “similar” comments are received the louder the voice becomes and the more influence it has

Shaping the Standards

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We comment directly to NERC, through the Registered Ballot Body mechanism

We actively participate in the NPCC group which has been charged with tracking, commenting, recommending voting, etc. during the NERC Standards development initiative

We actively participate in the ISO/RTO/Council SRC, a review group of ISO’s and RTO’s across the country designed to participate in NERC Standards development

How is ISO-NE Involved

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GET INVOLVED – these will impact you directly NPCC Group (CP-9) charged with reviewing and

providing consensus comments to SARs, Standards, and – additionally – recommending a vote to NPCC Membership

The Registered Ballot Body (RBB) comprises all entities that qualify and register for one of the nine industry segments as defined in the Reliability Standards Process Manual. Members of the RBB are eligible to vote on proposed reliability standards• You can participate individually!

Recommendations

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Segment 1 – Transmission Owners Segment 2 – RTOs, ISOs, RRCs Segment 3 – Load Serving Entities (LSEs) Segment 4 – Transmission Dependent Utilities Segment 5 – Electric Generators Segment 6 – Electricity Brokers, Aggregators, and

Marketers Segment 7 – Large Electricity End Users Segment 8 – Small Electricity Users Segment 9 – Federal, State, and Provincial Regulatory

or Other Government Entities

RBB Industry Segments

2005 Compliance Proposal

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It is certainly time to keep a close watch on compliance requirements, therefore, ISO-NE proposes: Retirement of the NEPOOL Compliance

Working Group (NCWG) with thanks for their hard work and dedication

Hold quarterly update meetings with the RC, similar to today’s and

Have annual Workshops in the Spring

2005 Compliance Proposal

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Quarterly meetings with the RC Same format as today Piggyback on existing meetings; no

additional meetings February, May, August & October timeframes

Workshop on annual compliance requirements in the Spring of each year RC members and Compliance Contacts

invited to attend – central location

2005 Compliance Proposal Schedule

Questions?