NERC submits the 2022 NERC Standards Report, Status and Timetable for Addressing Regulatory Directives

Summary:

Since NERC’s 2021 annual directives report filed on March 29, 2021, the Commission has issued one new directive related to Reliability Standards. In that time, NERC filed petitions with the Commission addressing four Reliability Standards-related directives. Currently, there are seven outstanding directives related to Reliability Standards or issued in orders approving Reliability Standards. NERC is addressing one of these directives through standards development projects. NERC is addressing a second directive through quarterly reporting of development project status. The other outstanding directives relate to data gathering, registration, or the performance of research or studies and are being addressed through other mechanisms. The 2022-2024 Reliability Standards Development Plan (“RSDP”) provides a plan to address the remaining Reliability Standards-related directives. NERC’s annual RSDP establishes priorities related to Reliability Standards to help ensure that those issues that most directly impact Bulk-Power System reliability are addressed first. Directives to create new or modify existing Reliability Standards are assigned to existing or future development projects that are prioritized by the NERC Standards Committee and are reflected in the RSDP.

Additional Discussion:

Outstanding FERC Directives (FERC's take)
Order No. 706 (S-Ref 10820)
(122 FERC 61,040)
51: “[The Commission] believe[s] that NERC should register demand side aggregators if the loss of their load shedding capability, for reasons such as a cyber incident, would affect the reliability or operability of the Bulk-Power System.” | “NERC should consider whether there is a current need to register demand side aggregators and, if so, to address any related issues and develop criteria for their registration.”

Order No. 830 (S-Ref 10957)
(156 FERC 61,215)
89: “[T]he Commission directs NERC, pursuant to Section 1600 of the NERC Rules of Procedure, to collect GIC monitoring and magnetometer data from registered entities for the period beginning May 2013, including both data existing as of the date of this order and new data going forward, and to make that information available.”

Order No. 851
(165 FERC 61,124)
30: “[W]e direct NERC to prepare and submit a report addressing how often and why applicable entities are exceeding corrective action plan deadlines as well as the disposition of time extension requests. The report is due within 12 months from the date on which applicable entities must comply with the last requirement of Reliability Standard TPL-007-2.”

Order No. 866
(170 FERC 61,031)
36: “[W]e direct that NERC develop modifications to the CIP Reliability Standards to require protections regarding the availability of communication links and data communicated between bulk electric system Control Centers.”

Order Directing Informational Filings Regarding NERC Standard Drafting Projects
(170 FERC 61,109)
“NERC is directed to file quarterly status updates on Project 2016-02 and Project 2019-02, on an informational basis, starting 120 days from the date of issuance of this order.”

Order Directing Informational Filing
(173 FERC 61,243)
17: “[W]e direct NERC to begin a formal process to assess the feasibility of voluntarily conducting BES operations in the cloud in a secure manner.”

Order No. 876
175 FERC 61,037
27 (req data in ¶ 21): “[W]e…direct NERC and WECC to submit an informational filing 30 months following implementation of regional Reliability Standard BAL-002-WECC-3 containing a report that addresses the adequacy of contingency reserves in the Western Interconnection.”

Order No. 817
153 FERC 61,178
27: While it appears that regional discrepancies exist regarding the manner for calculating IROLs, we accept NERC’s explanation that this issue is more appropriately addressed in NERC’s Facilities Design, Connections and Maintenance or “FAC”

Reliability Standards. NERC indicates that an ongoing FAC-related standards development project - NERC Project 2015-09 (Establish and Communicate System Operating Limits) - will address the development and identification of SOLs and IROLs.

We conclude that NERC’s explanation, that the Project 2015-09 standard drafting team will address the clarity and consistency of the requirements for establishing both SOLs and IROLs, is reasonable. Therefore, we will not direct further action on IROLs in the immediate TOP and IRO standard-related rulemaking. However, when this issue is considered in Project 2015-19, the specific regional difference of WECC’s 1,000 MW threshold in IROLs should be evaluated in light of the Commission’s directive in Order No. 802 (approving Reliability Standard CIP-014) to eliminate or clarify the “widespread” qualifier on “instability” as well as our statement in the Remand NOPR that “operators do not always foresee the consequences of exceeding such SOLs and thus cannot be sure of preventing harm to reliability.”