NERC Reliability Standards Project Updates (August 23, Updated)

Transcription

1 NERC Reliability Standards Project Updates (August 23, Updated) Concurrent Postings Project Protection System Maintenance and Testing The proposed PRC Protection System Maintenance standard addresses FERC directives from FERC Order 693, as well as issues identified by stakeholders. In accordance with the FERC directives, this draft standard establishes requirements for a time-based maintenance program, where all relevant devices are maintained according to prescribed maximum intervals. It further establishes requirements for a condition-based maintenance program, where the hands-on maintenance intervals are adjusted to reflect the known and reported condition of the relevant devices. For a performance based maintenance program, it ascertains where the hands-on maintenance intervals are adjusted to reflect the historical performance of the relevant devices. Note that PRC reflects the merging of the following standards into a single standard, making it impractical to post a redline of proposed PRC that shows the changes to the last approved version of the standard. o PRC b Transmission and Generation Protection System Maintenance and Testing o PRC Underfrequency Load Shedding Equipment Maintenance Program o PRC UVLS System Maintenance and Testing o PRC Special Protection System Maintenance and Testing Successive Ballot Results (06/18/12 06/27/12): PRC Non-binding Poll Results Quorum: 79.46% Quorum: 75.00% Approval: 79.00% Supportive Opinions: 70.21% The drafting team has made minor changes to the tables in the Standard along with changes to the Implementation Plan, Mapping Document and Supplemental Reference and FAQ documents. No changes have made to the Technical Justification, Table of Issues and Directives or the VRF and VSL Justification. Comment Period/Successive Ballot: A formal comment period for PRC Protection System Maintenance is open through 8 p.m. Eastern on Monday, August 27, A successive ballot for PRC Protection System Maintenance is open through 8 p.m. Eastern on Monday, August 27, Next Steps: The drafting team will consider all comments received during the formal comment period and successive ballot and, if needed, make revisions to the standard. If the comments do not show the need for significant revisions, the standard will proceed to a recirculation ballot.

2 Project Protection Systems: Phase 1 (Misoperations) PRC Protection System Misoperations is a revision of PRC-004-2a Analysis and Mitigation of Transmission and Generation Protection System Misoperations with the stated purpose: Ensure all transmission and generation Protection System Misoperations affecting the reliability of the Bulk Electric System (BES) are analyzed and mitigated. PRC Regional Procedure for Analysis of Misoperations of Transmission and Generation Protection Systems required the Regions to establish procedures for analysis of Misoperations. In the NOPR, the Commission identified PRC as a fill-in-the-blank standard. The NOPR stated that because the regional procedures had not been submitted, the Commission proposed not to approve or remand PRC Because PRC (now PRC-003-1) is not enforceable, there is not a mandatory requirement for Regional procedures to support the requirements of PRC-004-2a. This is a potential reliability gap; consequently, PRC combines the reliability intent of the two legacy standards PRC and PRC-004-2a. Project is an important part of the ERO s strategic goal to develop technically sufficient standards with requirements that provide clear and unambiguous performance expectations and reliability benefits. Comment Period: A formal comment period for PRC Protection System Misoperation Identification and Correction is open through 8 p.m. Eastern on Friday, September 7, Ballot Pool Formation: Two ballot pools, one for the standard and one for the associated VRFs and VSLs, are open through 8 a.m. Eastern on Monday, August 27, Registered Ballot Body members may join each of these ballot pools at the following page: Join Ballot Pool. Note that there is no requirement to join both of these ballot pools; Registered Ballot Body members who are only interested in voting during the ballot of the standard are not required to join the ballot pool for the nonbinding poll, and vice versa. Next Steps: During the pre-ballot windows, members of the ballot pools may communicate with one another by using their ballot pool list servers. (Once the balloting begins, ballot pool members are prohibited from using the ballot pool list servers.) The ballot pool list servers for these ballot pools are: o Initial ballot: bp _prc-004-3_in@nerc.com o Non-binding poll: bp _prc-004_nb_in@nerc.com An initial ballot of the standard and non-binding poll of the associated VRF/VSLs will be conducted beginning on Wednesday, August 29, 2012 through Friday, September 7, 2012.

3 Project Interpretation of BAL for NWPP Reserve Sharing Group Northwest Power Pool Reserve Sharing Group (NWPP) submitted a request for interpretation asking for clarification between reportable disturbances and disturbances that excluded from compliance evaluation. The specific areas NWPP is requesting clarification on are; 1) although a Disturbance that exceeds the most severe single Contingency must be reported by the Balancing Authority or Reserve Sharing Group (as applicable), is the Disturbance excluded from compliance evaluation for the applicable Balancing Authority or Reserve Sharing Group; 2) with respect to either simultaneous Contingencies or non-simultaneous multiple Contingencies affecting a Reserve Sharing Group, the exclusion from compliance evaluation for Disturbances exceeding the most severe single Contingency applies both when a.) all Contingencies occur within a single Balancing Authority member of the Reserve Sharing Group and b.) different Balancing Authorities within the Reserve Sharing Group experience separate Contingencies that occur simultaneously, or non-simultaneously but before the end of the Disturbance Recovery Period following the first Reportable Disturbance; and 3) the meaning of the phrase excluded from compliance evaluation as used in Section 1.4 ( Additional Compliance Information ) of Part D of BAL and for purposes of the preceding statements is that, with respect to Disturbances that exceed the most severe single Contingency for a Balancing Authority or Reserve Sharing Group (as applicable), a violation of BAL does not occur even if ACE is not recovered within the Disturbance Recovery Period (15 minutes unless adjusted pursuant to BAL-002-0, R4.2). Initial Ballot Results (02/15/10 02/26/10): Appeal: Quorum: 89.83% Approval: 48.60% On January 17, 2012 NERC received a Level 1 Appeal for inaction from the ISO/RTO Council's Standards Review Committee on Project Northwest Power Pool s Reserve Sharing Group s request for an interpretation of BAL-002-0, Requirement R4. The appellants asked for clarity on the following issues: o Did NERC, or the Standards Committee, convene the IDT, after comments were received. What industry and/or NERC personnel made up the IDT? o What accounted for the Standards Committee placing the RFI on hold (in October 2010) and the delay in processing the RFI prior to the Standards Committee 2011 action to place on hold pending Interpretations? o Do the Standards Committee Agendas correctly indicate that NERC considered the RFI an invalid request, and if so, why? IRC (ISO/RTO Council) Appeal NERC Response

4 Comment Period/Successive Ballot: Next Steps: A formal comment period for the Interpretation of BAL Disturbance Control Performance Requirements R4 and R5 by NWPP Reserve Sharing Group is open through 8 p.m. Eastern on Tuesday, September 4, A successive ballot of Interpretation of BAL Disturbance Control Performance Requirements R4 and R5 by NWPP Reserve Sharing Group will be conducted beginning Thursday, August 23, 2012 through Tuesday, September 4, The drafting team will consider all comments received during the formal comment period and successive ballot and, if needed, make revisions to the interpretation. If the comments do not show the need for significant revisions, the interpretation will proceed to a recirculation ballot. Project Operating Personnel Communications Protocols The purpose of this project is to require that real-time system operators use standardized communication protocols during normal and emergency operations to enhance the clarity of communications, improve situational awareness, shorten response time and ultimately serve reliability. As requested in the SAR, in the development of this proposed standard, the drafting team reviewed communication protocols in other NERC standards and considered the use of alert level guidelines and three-part communications to achieve consistency across regions. The proposed standard is designed to ensure that reliability-related information is conveyed effectively, accurately, consistently and in a timely manner to ensure mutual understanding by all key parties, both during alerts and emergencies and during the communication of routine operating instructions. Since Project Operating Personnel Communications Protocols addresses communication protocols for normal and emergency operations, the drafting team has proposed a new term, Operating Instruction, to define the scope of communications to which the COM protocols would apply. The proposed definition of Operating Instruction is Command from a System Operator to change or preserve the state, status, output, or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System. Initial Ballot Results (6/11/2012-6/20/2012): Quorum: % Weighted Segment Vote: % Comment Period: In response to comments received during the last comment period and other input, the drafting team has taken a new approach to COM This version requires entities to establish communication protocols and then implement a process for identifying, assessing and correcting deficiencies with adherence to those communication protocols. The entity is to ensure that its process is working, rather than requiring the demonstration of absolute compliance with communication protocols at all times and identifying each deficiency as a possible violation. A formal comment period for COM Operating Personnel Communication Protocols is open through 8 p.m. Eastern on Thursday, September 20, 2012.

5 Next Steps: Additionally, this version was drafted in conjunction with the development of the Reliability Standard Audit Worksheet (RSAW). The parallel development of these documents provided the opportunity for the drafting team to consider the compliance implications of the language in the standard and to offer input into the language of the RSAW. The RSAW is posted for informal comments along with COM A comment period on the draft RSAW is open through 8 p.m. Eastern on Thursday, September 20, The draft RSAW is posted on the NERC Compliance Reliability Standard Audit Worksheet (RSAW) page. Please submit comments on the draft RSAW using the RSAW comment form (located under Tools ) to RSAWfeedback@nerc.net. A webinar on COM is planned for the week of September 17, A separate announcement will be sent when the date and time are finalized. A successive ballot of COM and a non-binding poll of the associated VRFs and VSLs will be conducted beginning on Tuesday, September 11, 2012 through 8 p.m. Eastern on Thursday, September 20, 2012.

6 Current Ballots None Posted for Comment Project TPL Table 1 Order: TPL-002-1b, footnote b and TPL-001-3, footnote 12 FERC Order No. 762, issued April 19, 2012, remanded TPL-002-0b to NERC as vague, unenforceable, and not responsive to the previous Commission directives on this matter. The Standards Committee directed the Standards Drafting Team (SDT) to revise footnote b in accordance with the directives of Orders No. 693 and 762. The SDT was also charged with revising the corresponding footnote 12 of TPL in order to prevent the remand of TPL In revising the footnotes, the SDT adopted a philosophy of minimal changes to the actual footnote itself. This was done to minimize confusion as to what was changed, for ease of reading and following the footnote, and for formatting within the actual standards documents. Instead, the SDT revised the footnote by developing an attachment to the footnote containing changes in response to the Commission orders. It should be noted that attachments to standards are an extension of the Requirements and thus are binding to applicable entities. Project is an important part of the ERO s strategic goal to be responsive to regulatory authority directives in an expeditious manner in order to reduce the amount standards-related directives and to provide an adequate level of reliability. Comment Period: Next Steps: A formal comment period for TPL-002-1b Single Performance Following Loss of a Single BES Element for footnote b and TPL-001-3a Transmission System Planning Performance Requirements for footnote 12 is open through 8 p.m. Eastern on Wednesday, August 29, The drafting team will consider all comments and determine whether to make changes. If the drafting team does not make significant changes, the standards will be posted for a 45-day comment period and initial ballot. Project Assess Transmission Future Needs and Develop Transmission Plans Data Request The purpose of this data request is to solicit data and information from each registered Transmission Planner in the United States and Canada in order to provide information identifying the specific instances of any planned interruptions of Firm Demand under footnote b and how frequently the provision has been used. NERC is issuing this data request in accordance with FERC s directive in Transmission Planning Reliability Standards which directed NERC to identify specific instances of any planned interruptions of Firm Demand under footnote b and gather this data under Section 1600 of its Rules of Procedure. Due to the need for the data request to align with the tight schedule to be followed for revisions to TPL b Table 1 footnote b, the NERC Board of Trustees approved a request from NERC staff to shorten the time period to seek comments on this proposed data request to twenty-one (21) days.

7 Accordingly, NERC posted this proposed data request in accordance with the requirements of Section 1606 of the NERC Rules of Procedure for public comment. The twenty-one (21) day comment period was held June 19 through July 9, The NERC Board of Trustees approved this data request by an ballot on July 26, Data Request: Next Steps: Registered Transmission Planners are requested to respond to this request no later than 8 p.m. Eastern on Thursday, August 30, The timing of the formal request for data or information will allow for the data and information to be evaluated by the drafting team in the same timeframe as the responses to comment period for TPL and TPL that is open through 8 p.m. Eastern on Thursday, August 30, Project Paragraph 81 On March 15, 2012, the Federal Energy Regulatory Commission (FERC) issued an order on NERC s Find, Fix and Track process that stated the following in Paragraph 81: The Commission notes that NERC s FFT initiative is predicated on the view that many violations of requirements currently included in Reliability Standards pose lesser risk to the Bulk-Power System. If so, some current requirements likely provide little protection for Bulk-Power System reliability or may be redundant. The Commission is interested in obtaining views on whether such requirements could be removed from the Reliability Standards with little effect on reliability and an increase in efficiency of the ERO compliance program. If NERC believes that specific Reliability Standards or specific requirements within certain Standards should be revised or removed, we invite NERC to make specific proposals to the Commission identifying the Standards or requirements and setting forth in detail the technical basis for its belief. In addition, or in the alternative, we invite NERC, the Regional Entities and other interested entities to propose appropriate mechanisms to identify and remove from the Commissionapproved Reliability Standards unnecessary or redundant requirements. We will not impose a deadline on when these comments should be submitted, but ask that to the extent such comments are submitted NERC, the Regional Entities, and interested entities coordinate to submit their respective comments concurrently. The purpose of the project is to retire or modify FERC-approved Reliability Standard requirements that as FERC noted, provide little protection to the reliable operations of the BES, are redundant or unnecessary, or to retire or modify a FERC-approved Reliability Standard requirement to increase the efficiency of the ERO s compliance programs. The draft SAR identifies criteria for retiring or modifying requirements, defines phases for the project, and includes a suggested list of requirements put together by NERC, the regions, and the trades and their member companies for consideration in Phase 1. The suggested list includes requirements in 28 Reliability Standards. Phase 1 identifies Reliability Standard requirements that clearly meet the criteria set forth in the SAR and are believed to not require extensive technical research.

8 Subsequent phases of the project will address Reliability Standard requirements that need additional technical research before retirement or modification. Comment Period: Next Steps: The Standards Committee has authorized posting of the draft Standards Authorization Request (SAR) for stakeholder input for 30 day informal comment period through 8 p.m. Eastern on Monday, September 4, The drafting team will review the comments and determine whether to revise the SAR before proceeding with Phase 1 of the project. The drafting team will post a summary of its responses to comments received during this informal comment period. Adequate Level of Reliability Revised Definition and Associated Documents The Adequate Level of Reliability Task Force (ALRTF) was formed in May 2011 under the NERC Standing Committees Coordinating Group (SCCG), which comprises the chairs and vice chairs of NERC s standing committees, to address concerns expressed by the NERC Board of Trustees (BOT), the Member Representatives Committee (MRC), and stakeholders that NERC s current definition of Adequate Level of Reliability (ALR) needs reassessment to ensure that the definition supports and helps to define NERC s mission to ensure reliable operation of the bulk power system. The ALRTF s draft scope document describes the Task Force s purpose as follows: Deliver, for use by the ERO enterprise, a document which includes a definition of ALR and associated characteristics with demonstrated ability to measure the relative state of ALR on an ongoing basis. The definition and associated characteristics may be identical to those previously approved or may be enhanced if necessary. Further, these measurable objectives and characteristics should focus on support for the ERO s key activities, including Reliability Standards and Compliance and Certification functions. The ALRTF s goal has been to develop a definition of ALR that encompasses NERC s responsibility to ensure reliable planning and operation of the bulk power system and to identify and define reliability objectives and performance characteristics that drive what system planners and operators do on a day-today basis to ensure that the bulk power system is reliable. The ALRTF appreciates all comments submitted by stakeholders during its last posting from April 24 through June 25, The Task Force reviewed and considered all feedback and proposed language changes, and has updated both the ALR definition and its accompanying technical report to address the most common and compelling concerns. The ALRTF, NERC staff, and most commenters agree that the detailed proposed definition, which now includes performance and assessment objectives, time frames, and associated outcomes, is both useful and superior to the current definition of ALR. Once it is finalized, the ALR definition will be filed with FERC for information, as the current definition was. The definition will then be used by the NERC Performance Analysis Subcommittee and NERC reliability assessment staff to assess BES reliability, to identify gaps in data, and to begin developing the framework within which the Reliability Issues Steering Committee (RISC) will be able to work.

9 Comment Period: Next Steps: The Adequate Level of Reliability Task Force (ALRTF) has posted a revised definition of Adequate Level of Reliability and associated documents for a 30-day stakeholder comment period through September 13, Posted documents include the following: o Definition: Adequate Level of Reliability for the Bulk Electric System o Technical Report Supporting Definition of Adequate Level of Reliability o Mapping of Adequate Level of Reliability for the Bulk Electric System to Standards Development Reliability Principles The ALRTF will meet in September to review all comments received and determine what revisions are necessary to finalize its proposed revision to the definition of Adequate Level of Reliability. The definition and technical report will be submitted to the Standing Committees Coordination Group for approval in October, and then to NERC s Member Representatives Committee and Board of Trustees for adoption in November Reliability Standards Development Plan Project Prioritization NERC is in the process of developing the Reliability Standards Development Plan, which will address how NERC prioritizes the projects that will be put into development as current projects are completed. This Plan was developed using a methodology designed to provide an objective method for prioritizing projects. NERC solicited the industry for projects in April 2012 of this year. The submitted suggestions are included in the draft prioritization spreadsheets. The draft spreadsheets containing project prioritizations were endorsed for industry comment by the Standards Committee (SC) at their August 2012 meeting. Comment Period: The prioritization is currently posted for 30 days, closing at 8:00 p.m. ET on Tuesday, September 18, At this stage of developing the Plan, comments should be focused on the ranking of each of the criteria provided in the downloadable excel spreadsheet rather than the final result. In formulating comments, use the excel versions of the prioritization spreadsheets (one includes all projects; one eliminates the currently active projects). The PDF spreadsheets are provided for information only to show how, using the currently identified rankings, the projects would be prioritized. Information obtained from the comments received will be utilized to develop the final version of the Plan. The final version of the Plan will be developed to incorporate the top eight projects from the Reliability sort, the top three projects from the Time Sensitive sort, and the top two projects from the Practicality sort, as possible. The number of projects from each category may be adjusted based on the degree of complexity in the top projects, the completion of technical research, and the availability of resources required for a specific project or other considerations.

10 Next Steps: Following consideration of the comments received, the Plan will be submitted to the SC for approval at the October 2012 meeting and subsequently presented to the NERC Board of Trustees at their meeting in November Southwest Power Pool Regional Reliability Standard PRC-006-SPP-01 Automatic Underfrequency Load Shedding The SPP Automatic Underfrequency Load Shedding (UFLS) standard, PRC-006-SPP-01, was developed to provide regional UFLS requirements to entities in the SPP region. PRC-006-SPP-01 adds specificity not contained in the NERC standard (PRC-006-1) for development and implementation of a UFLS scheme in the SPP Region that effectively mitigates the consequences of an underfrequency event. Comment Period: SPP has requested NERC to post regional reliability standard PRC-006-SPP-01 SPP Automatic Underfrequency Load Shedding for a 45-day industry review as permitted by the NERC Rules of Procedure. The comment period is open through 8 p.m. Eastern on Friday, September 28, Comments shall be permitted only on the following criteria (technical aspects of the standard are vetted through the regional standards development process): o Unfair or Closed Process The regional reliability standard was not developed in a fair and open process that provided an opportunity for all interested parties to participate. Although a NERC-approved regional reliability standards development procedure shall be presumed to be fair and open, objections could be raised regarding the implementation of the procedure. o Adverse Reliability or Commercial Impact on Other Interconnections The regional reliability standard would have a significant adverse impact on reliability or commerce in other interconnections. o Deficient Standard The regional reliability standard fails to provide a level of reliability of the bulk power system such that the regional reliability standard would be likely to cause a serious and substantial threat to public health, safety, welfare, or national security. o Adverse Impact on Competitive Markets within the Interconnection The regional reliability standard would create a serious and substantial burden on competitive markets within the interconnection that is not necessary for reliability.

11 To be posted during the week of August 20: NERC Standards Committee Postings Projects Under Active Development Project Operating Personnel Communications Protocols COM-003 (30-day comment period and successive ballot) Standard Processes Manual (SPM) Revisions (comment period and possibly initial ballot - TBD) To be posted during the week of August 27: Project Disturbance and Sabotage Reporting CIP-001 and EOP-004 (30-day comment period and successive ballot) Project Reliability Coordination COM-001 (recirculation ballot) To be posted during the week of September 3: VRF/VSL Revisions (45-day comment period and non-binding poll) Cost Effective Analysis Process (CEAP) (30-day comment period and successive ballot) To be posted during the week of September 10: Project Cyber Security Order 706 (10 standards, implementation plan, and set of definitions - CIP Version 5) (successive comment period and ballot) Project 2010-INT-01 Rapid Revision of TOP-006 (recirculation ballot) To be posted during the week of September 17: No new postings To be posted during the week of September 24: Project TPL Table 1, Footnote b (45-day comment period and initial ballot) Project Paragraph 81 (P. 81) (45-day comment period and initial ballot) Project Frequency Response (30-day comment period and successive ballot) Project DBES Guidance Doc (30-day comment period) To be posted during the week of October 1: Project Generator Verification (five standards, 30-day comment period and successive ballot)

12 Project Project PRC-005 ALR Definition Project PRC-004 Project BAL-002 Interpretation Project TPL FN b Project P. 81 Project COM-003 SPM Revisions Project Frequency Resp. VRF/VSL Revisions Project DBES Guidance Doc Project CIP-001 and EOP-004 Project 2010-INT-01 TOP-006 CEAP Project Generator Verification Project Generator Verification Project Generator Verification Project Generator Verification Project Generator Verification Project COM-001 8/20 8/26 8/27 9/2 9/3 9/9 9/10 9/16 9/17 9/23 9/24 9/30 10/1 10/7 10/8 10/14 10/15 10/21 10/22 10/ /29 11/4 11/5 11/11 Projected for November NERC Board of Trustees meeting Draft SAR Initial comment period and ballot Successive comment period and ballot Recirculation ballot or possible recirculation ballot depending on previous ballot results

13 Webinars Addressing Zero Defect Concerns in CIP Standards Tuesday, September 11, :00 p.m. - 4:00 p.m. ET Registration NERC Board of Trustee Meetings NERC Standard Drafting Team Vacancies None Notice of NERC Postings for Comment None NERC Board of Trustee Actions The NERC Board of Trustees met on August 16, 2012 (Quebec City, QC) Reliability Standard Actions: o VAR-002-2b Generator Operation for Maintaining Network Voltage Schedules In January this year an interpretation request was submitted by Constellation Power Generation that sought clarification regarding whether a communication must be conducted between a GOP and a TOP during start up or shut down of a generator. The Standards Committee considered the request and decided (with Constellation s consent) to move forward using a rapid revision process. Requirement R1 was revised to add two bullets to clarify that a communication between a GOP and a TOP is not necessary during start up or shut down of a generator. The approved VRFs and VSLs were also incorporated into the standard. There was a 90.97% quorum and a 69.81% affirmative vote. BOT unanimously approved. o IRO Reliability Coordination Responsibilities and Authorities As part of Project Reliability Coordination, IRO clarifies the authority of the RC and also clarifies the TOP, BA, GOP and DPs obligation to comply with RC direction and to notify the RC of its inability to perform. The standard was approved by stakeholders with an 85% quorum and an approval of 81%. BOT unanimously approved. o Section 1600 Data Request in Response to Order No. 754 In September 2011, FERC issued Order No 754 approving an interpretation of TPL-002-1, in which FERC directed NERC and FERC staff to initiate a process to identify and reliability issues (i.e. a single point of failure on protection systems) associated with the interpretation. NERC staff determined that the best method of addressing this issue is to first discover the extent of and risk through a Data Request. BOT unanimously approved.

14 o Retirement of the BAL Time Error Correction In July 2007 the NERC OC submitted a Standards Authorization Request requesting urgent action to revise BAL A revised standard was developed to address concerns about inappropriate compliance requirements on RC s who voluntarily serve as Interconnection Time Monitors, to remove inappropriate compliance requirements on the RC which is not a user, owner, or operator, and to remove requirements to follow NAESB business practices. The resulting standard was approved by the RBB and the BOT and filing was made with FERC on March 11, FERC issued a NOPR in March 2010 proposing to remand BAL with specific instruction to address deficiencies FERC identified in the standard. In April 2010 NERC responded to the NOPR advising FERC that NERC was exploring the possible elimination of Manual Time Error Corrections entirely which would eliminate the need for the standard altogether. In August 2010 NERC submitted a Motion to Defer Action on BAL citing the ongoing efforts to evaluate whether elimination of the practice was feasible. After much outreach and debate, the NERC OC decided at their March 2012 meeting that NERC should discontinue its pursuit of the elimination of Manual Time Error Corrections. Because NERC is no longer proposing to eliminate Manual Time Error Corrections, there is no longer any reason for FERC to continue to defer action on the standard. A remand of BAL and the associated FERC directives, based on March 2010 NOPR, would distract the ERO from more pressing reliability needs. The reliability concerns associated with Time Error corrections have been and continue to be addressed by the existing standard. BOT rescinded approval of BAL and withdrew it from further regulatory action.

15 FRCC Reliability Standards Project Updates FRCC Documents, Procedures, and Process Under Development FRCC Regional Reliability Standard Development Process PRC Automatic Underfrequency Load Shedding Program The FRCC System Protection and Controls Subcommittee (SPCS) and FRCC Standards Staff is currently performing a comparison between the NERC Board approved continent-wide standard and the FRCC Underfrequency Program to determine if further action is required in support of a Regional Reliability Standard or a regional variance to the continent-wide standard. To complete this task and to accurately compare the performance characteristics between the two programs a graphical depiction of the FRCC Automatic Underfrequency Load Shedding Program Design Performance and Modeling Curves is required. In response to the FRCC SPCS and FRCC Standards Department request through the FRCC PC RE to the FRCC SWG, the chair of the SWG has indicated that additional data is necessary to complete the performance assessment in support of the project. The preliminary assessment has indicated that based on the FRCC generation coordination requirements, the Region could potentially have generating units and/or facilities that trip within the boundaries established by the Generator Underfrequency Trip Modeling curve in PRC-006-1and therefore are required to be included in the model utilized for the UFLS design assessment. Data Request: FRCC Standards staff is verifying participation of Register Entities and compiling the data for the Stability Working Group. FRCC Regional Criteria: FRCC Generation Coordination Requirements (PRC Generator Performance During Frequency and Voltage Excursions) The FRCC System Protection and Controls Subcommittee (SPCS) and FRCC Standards Staff is currently revising and updating the FRCC Generation Coordination Requirements and is requesting that the FRCC Regional Entity Planning Committee direct the FRCC Stability Working Group to develop a graphical depiction of the FRCC program characteristics utilizing the format established in Attachments1 and 2 of NERC Reliability Standard PRC Generator Performance During Frequency and Voltage Excursions: o Off Nominal Frequency Capability Curve o Voltage Ride-Through Time Duration Curves In response to the FRCC SPCS and FRCC Standards Department request through the FRCC PC RE to the FRCC SWG, the chair of the SWG has indicated that additional data is necessary to complete the performance assessment in support of the projects. The preliminary assessment has indicated that based on the FRCC generation coordination requirements, the Region could potentially have generating units and/or facilities that trip within the boundaries established by the Generator Underfrequency Trip Modeling curve in PRC-006-1and therefore are required to be included in the model utilized for the UFLS design assessment.

16 Data Request: FRCC Standards staff is verifying participation of Register Entities and compiling the data for the Stability Working Group.

17 Reliability Standards Links NERC Governance: Rules of Procedure NERC Reliability Standards Under Development NERC Standards Committee Meeting Agendas and Minutes NERC Standards Committee Postings