Reliability Standards Development Plan

Transcription

1 Reliability Standards Develpment Plan Nvember 5, 2015 I

2 Table f Cntents Backgrund... iii Executive Summary... iv Steady State...1 Directives...1 Trend in Number f Requirements Prgress Reprt Prjects...4 Prjects Cntinuing frm 2015 int High Pririty...4 Medium Pririty...4 Prjects t be Initiated in Enhanced Peridic Reviews...5 Interpretatins...6 Enhanced Peridic Review Guidelines...7 Standards Eligibility...7 Criteria fr What Makes a Standard Eligible:...7 Criteria fr What Makes a Standard Nt Eligible:...8 Priritizatin...8 Feedback Lps (Factrs fr Cnsideratin f Risk)...8 Emerging Risks and Changing Technlgies...8 Event Analysis and Cmpliance Vilatin Statistics...8 Lessns Learned and Frequently Asked Questins...9 Ratinale and Guidelines...9 Measures...9 Request fr Interpretatins...9 RSAW Develpment and Cmpliance Input...9 Audit Feedback...9 Reginal Variances...9 Cnstruct f Standards Surveys and Plls Crdinatin with the Nrth American Energy Standards Bard (NAESB) ii

3 Backgrund The Reliability Standards Develpment Plan (RSDP) utlined a methd fr NERC Reliability Standards t reach steady state, 1 addressing the remaining FERC directives and recmmendatins t retire requirements. The number f active prjects in the plan was less than in prir RSDPs, and it was prjected that the number f prjects wuld remain at the 2015 level in future years. The RSDP indicated that, after Reliability Standards reach steady state in 2016, prjects in future years wuld cnsist f standards being assessed fr quality, cntent, r alignment with ther standards thrugh enhanced peridic reviews (EPRs), prjects addressing FERC directives, r newly identified risks t the Bulk Pwer System (BPS). Fllwing the cmpletin f the wrk t achieve Steady State, the Reliability Standards will cntinue t be assessed fr quality, cntent r alignment with ther standards thrugh EPRs. The Members Representative Cmmittee (MRC) and the NERC Bard f Trustees (Bard) sught industry input prir t the May 2015 meetings regarding the future f standards develpment. In light f the appraching milestne f steady state standards maturity, the Bard asked whether the NERC Reliability Standards shuld be cnsidered stabilized r if there is value in making additinal significant enhancements. If cnsidered stabilized at steady state, nly incremental refinements wuld be made t the standards t address FERC directives r newly identified risks t the BPS. Pursuant t the NERC Rules f Prcedure, Sectin 310, NERC shall develp and prvide an annual Reliability Standards Develpment Plan fr develpment f Reliability Standards t the applicable gvernmental authrities. NERC shall cnsider the cmments and pririties f the applicable gvernmental authrities in develping and updating the annual Reliability Standards Develpment Plan. Each annual Reliability Standards Develpment Plan shall include a prgress reprt cmparing results achieved t the prir year s Reliability Standards Develpment Plan. NERC als includes the Standards Cmmittee review during develpment f the RSDP and psts the RSDP fr industry cmment. 1 Fr the purpses f that plan, steady state means a stable set f clear, cncise, high quality, and technically sund Reliability Standards that are results based, including the retirement f requirements that d little t prmte reliability. iii

4 Executive Summary This RSDP sets frth a plan that invlves cnducting the EPRs as well as accmplishing ther envisined tasks by addressing: 1) emerging risks, 2) FERC directives, and 3) standards authrizatin requests (SARs). This plan specifically includes the Integratin f Variable Generatin Task Frce (IVGTF) recmmendatins, the Essential Reliability Services Task Frce (ERSTF) recmmendatins, cmmunicatin with the Reliability Issues Steering Cmmittee (RISC) n ther emerging risks, ptential FERC directives, and input frm industry n the feedback lps explained in detail later in this plan. Based n the plicy input and the discussin at the Bard, it appeared there was general supprt t cnduct the EPRs at a measured pace. 2 It als appeared there was general supprt fr a set gal f cmpleting a certain number f reviews each year with the understanding that the reviews shuld be aligned with strategic cnsideratins f reviewing standard families 3 that are interrelated. There was als supprt fr the EPRs t start with a perid f study and data evaluatin f three t six mnths t infrm the reviews. Accmpanying the measured apprach t review the quality and cntent f standards thrugh the EPR prcess, the Bard requested that the Standards Cmmittee and NERC staff develp a standards metric. Althugh the standards metric is nt explicitly included in the RSDP, it will be referenced after it is apprved by the Bard in the filing t the applicable gvernmental authrities by the end f the year. It is imprtant t nte that while mst f the wrk in the next three years will fcus n EPRs, there may be new r emerging risks identified that wuld generate full standards develpment wrk. NERC and the Standards Cmmittee will cntinue t seek input and recmmendatins frm the RISC with regard t ptential risks t reliability that may be addressed thrugh the revisin f existing standards r the develpment f new standards. This plan is meant t prvide a perspective f the standards develpment wrk t be undertaken at time f publicatin t apprpriate the necessary resurces t accmplish the standards develpment bjectives. 2 The Standards Cmmittee apprved an enhanced peridic review template n September 30, This was presented t the Bard n Nvember 12, 2014, as part f the Standard Cmmittee s update. The template includes backgrund infrmatin and questins t guide a cmprehensive review f the standard(s) by the review team and it serves as dcumentatin f the review team s cnsideratins and recmmendatins. 3 In sme cases, the ne-ff review f a standard will likely be apprpriate. Fr example, there are nt necessarily ther interrelated standards with FAC-003. iv

5 Steady State This sectin prvides infrmatin n the status f FERC directives, Paragraph 81 candidates, and the Independent Experts Review Panel s (IERP) recmmendatins fr retirement. Cmpletin f prjects is discussed in the next sectin, 2015 Prgress Reprt. Directives In 2013, NERC set ut t address the 191 FERC directives that were issued r unaddressed prir t December All f the utstanding standards-related directives are being addressed in current 2015 prjects. As f June 30, 2015, there were 35 standards-related directives, including FERC guidances, t be reslved. Table 1 illustrates the prgress t address FERC directives issued and nly includes directives that are standards related. Table 1: Summary f Ttal Directives Pre-2013 Directives* Pst-2012 Directives* Ttal Issued prir t year-end Issued since year-end Reslved as f March 31, Remaining Prjected t be reslved in Prjected remaining at year-end *Des nt include directives fr ther NERC departments While this is ne benchmark, it is als an imperative t address the FERC directives issued pst December 2012 in a timely fashin. As nted in the ftnte t Table 1, FERC issued sme directives that require wrk frm grups utside f Standards, such as the NERC technical cmmittees, r anther internal NERC department, such as Reliability Assessment and Perfrmance Analysis (RAPA). These directives, as they cannt be reslved thrugh a Standards prcess, are nt included in the abve numbers. Depending upn prject cmpletin, 186 will be addressed at year end Trend in Number f Requirements As the NERC Reliability Standards becme steady state, there is an expectatin that the ttal number f requirements subject t enfrcement will be reduced. T measure the accuracy f NERC s expectatin, NERC staff used the US Enfrcement Status/Functinal Applicability Spreadsheet 4 t analyze the trend in the ttal number f Bard-apprved requirements at the end f each year since standards became enfrceable in the U.S. in Figure 1 n the next page was created 5 fr the Nvember 2014 SOTC meeting and was based n each requirement s U.S. enfrcement date in the US Enfrcement Status/Functinal Applicability Spreadsheet. Fr cmparisn, this figure has been updated with infrmatin cntained in the spreadsheet as f June 30, This figure updates the prjectin fr 1) pending cntinent-wide retirements and 2) the number f reginal Reliability 4 Available frm the Standards sectin f the NERC website: 5 This figure was develped using Q data. NERC DRAFT Reliability Standards Develpment Plan Nvember 5,

6 Steady State Standards. The variances within cntinent-wide standards were remved frm the reginal Reliability Standards line. Using the Nvember 2014 data, the line indicating the number f retirements shws a dwnward slpe in This dwnward trend was anticipated as pending prjects were filed. Using the June 2015 data, the line indicating the number f requirements shws the dwnward trend in t mre accurately reflect the anticipated enfrcement dates. The prjects pending that have significant reductins in the number f requirements include Prject TOP/IRO Revisins with a net reductin f 57 requirements, Prject Available Transmissin System Capability (MOD A) with a net reductin f 50 requirements, and Prject Emergency Operatins with a net reductin f 17 requirements. Table 2 prvides the list f prjects pending apprval. Overall, the ttal pending prjects reflect a ptential reductin f 108 requirements. Figure 1 als includes the prjected number f requirements at the end f each f the data lines. In Nvember 2014, it was anticipated that the number f enfrceable standards, nce all prjects were implemented, wuld be 422. At this time, the prjectin is 405 requirements. Trend fr Number f Requirements Number f Requirements Years Cntinent-wide Requirements by Enfrcement Date Nvember 2014 Cntinent-wide Requirements by Enfrcement Date April 2015 Reginal Reliability Requirements by Bard Adptin Nvember 2014 Reginal Reliability Requirements by Enfrcement Date April 2015 Figure 1: Trend fr Number f Requirements NERC Reliability Standards Develpment Plan Nvember 5,

7 2015 Prgress Reprt The RSDP identified 16 prjects that initiate in 2015 r cntinue frm All f the prjects listed in this sectin are expected t have been cmpleted in 2015 r are planned t be cmpleted, except Prject : Real-time Reliability Mnitring and Analysis Capabilities, and Prject : Phase 3 f Prtectin Systems: Remedial Actin Schemes (RAS), which are bth listed under Prjects cntinuing frm 2015 int At the time f presentatin t the NERC Bard f Trustees, the fllwing prjects were expected t be cmpleted in 2015: Prjects frm the RSDP 1. Prject : System Prtectin Crdinatin (PRC-027-1) 2. Prject : System Prtectin Crdinatin (PRC-001) 3. Prject : Phase 2 Undervltage Lad Shedding (UVLS): Misperatins (PRC-004 and PRC- 010) 4. Prject : Phase 1 Balancing Authrity Reliability-based Cntrls: Reserves (BAL-002) 5. Prject : Phase 2 Balancing Authrity Reliability-based Cntrls (BAL-005, BAL-006) 6. Prject : Phase 2 Balancing Authrity Reliability-based Cntrls (BAL-004) 7. Prject : Critical Infrastructure Prtectin (CIP-003-6, CIP-004-6, CIP-007-6, CIP-010-2, CIP ) 8. Prject : Transmissin Operatins (TOP-001-3) 9. Prject : Peridic Review f EOP Standards (EOP-004, EOP-005, EOP-006, and EOP-008) 10. Prject : Standards Applicability fr Dispersed Generatin Resurces (medium-pririty standards) 11. Prject : Physical Security Directives Prject : Peridic Review f System Operating Limit Standards (FAC-010, FAC-011, and FAC- 014) 13. Prject : Alignment f NERC Glssary f Terms used in NERC Reliability Standards and the Definitins Used in the Rules f Prcedure 14. Prject : Intercnnectin Reliability Operatins and Crdinatin 7 Additinal Prjects cnducted t address a FERC directive 1. Prject : PRC-005 FERC Order N. 803 Directive 8 2. Prject : MOD-031 FERC Order N. 804 Directive 9 6 This prject was cntinued t address a directive frm a FERC Order. Because the timing was relatively shrt between filing and apprval f the standard, the same standard drafting team was kept in place and the riginal SAR was revised. 7 This prject was put n hld until Prject (TOP/IRO Revisins) was filed with the applicable gvernmental authrities. This prject began in Q2 f ,9 This prject was cntinued t address a directive that came ut frm a FERC rder. Because the timing was relatively shrt between filing and apprval f the standard, the same standard drafting team was kept in place and the riginal SAR was revised. NERC DRAFT Reliability Standards Develpment Plan Nvember 5,

8 2016 Prjects Prjects Cntinuing frm 2015 int 2016 The fllwing prjects are planned t cntinue frm 2015 alng with any 2015 prjects that are planned t be cmpleted in that year but need additinal time. As in the RSDP, the apprach t priritizing Reliability Standards prjects in this RSDP addressed hw Reliability Standard family pririties are applied t individual prjects and utstanding wrk. Specific elements included: (1) RISC Categry Rankings; (2) regulatry directives; (3) regulatry deadlines; (4) Reliability Standard requirement candidates fr retirement; (5) the IERP cntent and quality assessments; and (6) additinal cnsideratins (fill-in-the-blank status and five-year assessment cmmitments). The priritizatin gave primary cnsideratin t RISC categry rankings, regulatry directives, and regulatry deadlines. Based n the applicatin f these elements, this sectin priritizes each Reliability Standard prject as high, medium, lw, r pending technical cmmittee input. High Pririty Prject : Real-time Reliability Mnitring and Analysis Capabilities (Target: February 2016 Bard)* Tw FERC directives RISC: high-pririty area (Mnitring and Situatinal Awareness) IERP cnsideratins: risks nt adequately mitigated fr situatinal awareness tls, such as realtime cntingency analysis (RTCA) in energy management systems (EMS) (recmmendatin 22 f the 2003 Blackut) Prject : Internal Cmmunicatins Capabilities FERC Order N. 808 Directive Tw FERC directives RISC: high-pririty area (wrkfrce capability and human errr) IERP cnsideratins: minr quality and cntent Prject : FAC-003: Vegetatin Management One FERC directive RISC: lw-pririty area (transmissin right f way) IERP cnsideratins: minr quality and cntent Prject : Single Pints f Failure TPL-001 This prject will address tw directives and cnsider ther imprvements t TPL Transmissin System Planning Perfrmance Requirements. There are n remaining timesensitive directives. Medium Pririty Frm FERC Order N. 786 Paragraph 40 directs NERC t mdify Reliability Standard TPL t address the cncern that the six-mnth threshld culd exclude planned maintenance utages f significant facilities frm future planning assessments. Paragraph 89 directs NERC t cnsider a similar spare equipment strategy fr stability analysis upn the next review cycle f Reliability Standard TPL RISC: high-pririty area (prtectin systems) IERP cnsideratins: minr quality and cntent n pssible P81 candidates NERC DRAFT Reliability Standards Develpment Plan Nvember 5,

9 2016 Prjects Prject : Phase 3 f Prtectin Systems remedial actin schemes (RASs) (Target: February 2016 Bard) N FERC directives RISC: high-pririty area (prtectin systems) IERP cnsideratins: minr quality and cntent Prject : Critical Infrastructure Prtectin 10 N FERC directives RISC: high pririty area (cyber attack) IERP cnsideratins: N/A Prject : Emergency Operatins N FERC directives RISC: medium-pririty area (crdinated attack n multiple facilities), lw-pririty areas (extreme weather/acts f nature and electr magnetic pulse (EMP)) IERP cnsideratins: minr quality and cntent n pssible P81 candidates Prject : System Operating Limits N FERC directives RISC: high-pririty area (Situatinal Awareness) IERP cnsideratins: minr quality and cntent n pssible P81 candidates Prjects t be Initiated in 2016 The fllwing prjects are expected t be initiated in Nt all prjects have SARs. The missing SARs will be develped and presented t the Standards Cmmittee prir t beginning them. EPRs that recmmend revisins t standards Emerging risks, if any (with input frm the RISC n whether a standard is needed) Ptential mdificatins t existing standards if FERC directives are issued Enhanced Peridic Reviews The fllwing EPRs are planned t begin in based n NERC and the Standards Cmmittee priritizatin and the develpment f prject plans t ensure prjects are develped at a measurable and sustainable pace. Their scheduling and timing depends n the cmpletin f the standard prjects discussed earlier. The EPR teams will use the EPR template apprved by the Standards Cmmittee n September 30, 2014, r as subsequently revised and apprved by the Standards Cmmittee. The EPR teams shall als take int accunt the wrk f the Risk-Based Registratin initiative and mdify the standard r standards accrdingly. 10 The existing Prject Standard Drafting Team is tasked with addressing Versin 5 transitin issues and therefre there may be a standards develpment prject in

10 2016 Prjects An initial set f pssible EPR candidates is listed here. This initial set was develped by Standards Cmmittee leadership and NERC staff based n effective dates f the NERC Reliability Standards, breadth and depth f mdificatins made by recent revisins, and standards nt under current develpment BAL and INT families (BAL-001 and INT-004, INT-006, INT-009, and INT-010) EOP-001, EOP-002, and EOP-003 EOP-010 (as a ne-ff) 11 FAC (as a ne-ff) NUC (as a ne-ff) PER-001, PER-003, and PER-004 PRC families VAR-001 and VAR-002 Interpretatins Pursuant t Sectin 7 f the Standard Prcesses Manual (SPM), there may be requests fr interpretatins that are accepted by the Standards Cmmittee tward the end f 2015 and beynd. Thse requests wuld begin based n NERC and the Standards Cmmittee priritizatin and the develpment f prject plans t ensure prjects are develped at a measurable and sustainable pace, cnsistent with the criteria t priritize standard prjects that are included in this list. 11 One-ff refers t an enhanced peridic review which fcused n ne standard. 6

11 Enhanced Peridic Review Guidelines 12 Many factrs must be cnsidered in develping the plan t cnduct EPRs. As the reviews prvide a wider view f the standards t determine whether a particular grup f standards is effective, the first task is hw t grup standards fr review. Fr example, it may be reasnable t review standards by lking at the entire standards family, but it may als make sense t lk at reliability actins that cut acrss standards r by sectins f standards that relate t each ther. 13 The next task is whether the grup f standards is eligible fr an update. Eligibility may be affected by additinal prjects that may be cnducted. Once the eligibility tasks have been made fr grups f standards, a priritizatin must be determined. Standards Eligibility The criteria belw are used t assist in the determinatin f eligibility t cnduct the EPRs fr standards fr 2016, 2017, and Criteria fr What Makes a Standard Eligible: All requirements f a Reliability Standard have been in effect, based n the implementatin/cmpliance dates apprved by the applicable gvernmental authrity, fr at least a year. In sme instances, a standard may be eligible if it has been a year since the effective date f the rder 14 apprving that standard if entities are early adpting the requirements as they implement their prgrams t prepare fr the effective date. Examples f standards that meet this criterin fr the 2016 EPRs are: NUC and NUC : NUC was effective 4/1/2013 and NUC will be effective 1/1/2016. The changes t NUC were nt significant (e.g., they were related t capitalizatin f terms, deleting unneeded terms). Cmpliance expectatins are nt clear r the standard is nt being cnsistently mnitred. Feedback lps indicate risk (e.g., Event Analysis lessns learned). 12 Per Sectin 13 f the SPM, all Reliability Standards shall be reviewed at least nce every ten years frm the effective date f the Reliability Standard r the date f the latest Bard f Trustees adptin t a revisin f the Reliability Standard, whichever is later. If a Reliability Standard is apprved by the American Natinal Standards Institute (ANSI) as an American natinal standard, it shall be reviewed at least nce every five years frm the effective date f the Reliability Standard r the date f the latest Bard f Trustees adptin t a revisin f the Reliability Standard, whichever is later. The RSDP shall include prjects that address this five- r ten-year review f Reliability Standards. If a Reliability Standard is nearing its five- r ten-year review and has issues that need reslutin, then the Reliability Standards Develpment Plan shall include a prject fr the cmplete review and assciated revisin f that Reliability Standard that includes addressing all utstanding gvernmental directives, all apprved interpretatins, and all unreslved issues identified by stakehlders. If a Reliability Standard is nearing its five- r ten-year review and there are n utstanding gvernmental directives, interpretatins, r unreslved stakehlder issues assciated with that Reliability Standard, then the RSDP shall include a prject slely fr the five-year review f that Reliability Standard. While the main wrk in the next three years will be the cntinuatin f research and cnducting f the enhanced peridic reviews with cnsideratin f the tpics discussed belw, there may be risks identified fr which prjects may need t be initiated. 13 The IERP develped ne apprach t gruping standards. 14 Effective date and issue date are different, s this must be cnsidered. NERC DRAFT Reliability Standards Develpment Plan Nvember 5,

12 Enhanced Peridic Review Guidelines11F Outstanding Paragraph 81 requirements that may nt have been addressed. The implementatin f the Standards Independent Experts Review Prject - Final Reprt recmmendatins. 15 Per the SPM, standards will g thrugh a review at least nce every 10 years fr nn-ansi 16 -apprved standards and every five years fr ANSI-apprved standards. Criteria fr What Makes a Standard Nt Eligible: A standard that is currently in standards develpment r is scheduled t underg standards develpment that will likely result in significant revisins f the standard currently in effect. Standards develpment here includes the standard: being in a standards develpment prject; being adpted by the NERC Bard f Trustees; pending regulatry filing; being filed with regulatry agencies; r being apprved by regulatry agencies but nt yet in effect. Priritizatin Specific elements cnsidered in the priritizatin f the EPRs include: 1. RISC categry rankings 2. Feedback n risk 3. Outstanding regulatry directives with deadlines 4. Outstanding regulatry directives 5. Outstanding requirements that are candidates fr retirement 6. Standards Independent Experts Review Panel - Final Reprt cntent and quality assessments Feedback Lps (Factrs fr Cnsideratin f Risk) The fllwing feedback lps, r factrs fr cnsideratin, will assist in keeping the wrklad steady by priritizing (a) the prjects nt having a ne-year deadline, and (b) cmpliance input built earlier int the prject s timeline. Prjects that will have a deadline will be dictated by any FERC directives that have a filing due date specific in a Final Rule. Emerging Risks and Changing Technlgies The RISC, IVGTF, and ERSTF are three imprtant cmmittees r task frces fcusing n emerging risks and changing technlgies. They will need t be invlved during the beginning f 2016 t assist in the EPR fr priritizatin and technical expertise. Event Analysis and Cmpliance Vilatin Statistics Event analysis and cmpliance vilatin statistics shuld be reviewed as the EPRs get underway. Lessns learned and statistics frm analyzing events will allw teams t review existing requirements t see if there is any crrelatin between the events and requirements. Vilatins statistics allw teams t investigate requirements 15 The Standards IERP final reprt recmmendatins can be fund here: rt.pdf 16 American Natinal Standards Institute 8

13 Enhanced Peridic Review Guidelines11F that are highly vilated t identify areas where language may have been misinterpreted and prvide training t the industry n the intent f the requirements. Lessns Learned and Frequently Asked Questins Lessns learned dcuments are designed t cnvey infrmatin frm NERC s varius implementatin activities. They are nt intended t establish new requirements under NERC s Reliability Standards, t mdify the requirements in any existing Reliability Standards, r t prvide an interpretatin under Sectin 7 f the SPM. Additinally, there may be ther legitimate ways t fulfill the bligatins f the requirements that are nt expressed in these supprting dcuments. Cmpliance will cntinue t be determined based n language in the NERC Reliability Standards as they may be amended frm time t time. Implementatin f a lessn learned is nt a substitute fr cmpliance with requirements in NERC s Reliability Standards. Frequently asked questins (FAQs) prvide transparency in prviding answers t questins asked by entities. The infrmatin presented in FAQ dcuments is intended t prvide guidance and is nt intended t establish new requirements under NERC s Reliability Standards r t mdify the requirements in any existing Reliability Standards. A standard being the subject f numerus lessns learned r FAQs is an indicatin that the language in the standard may be ambiguus, interpreted in multiple ways, r des nt apprpriately capture the risk t reliability. Ratinale and Guidelines Industry feedback will be encuraged n hw these sectins relate t the wrk f the Member Representative Cmmittee s cmpliance guidance wrk. Measures There have been mre requests fr guidance t industry n what is expected fr measuring perfrmance n standard requirements. This shws that the measures within sme standards are nt infrmative enugh. The EPRs shuld include cnsideratin f requests fr guidance frm industry, and the effrts shuld have an emphasis n imprving measures such that guidance dcuments r detailed reliability standard audit wrksheets (RSAWs) are nt needed and the measures are sufficient guidance t industry. Request fr Interpretatins Similar t lessns learned and FAQs, a standard receiving a valid interpretatin request may indicate prblems with the language f a requirement. RSAW Develpment and Cmpliance Input In the beginning f 2013, NERC endeavred t develp RSAWs cncurrently with standards. The purpse was t pst RSAWs within 15 days f a standard being psted t allw industry t cnsider the cmpliance apprach frm auditrs as they vte n the standard(s) being ballted. Audit Feedback A pssible mechanism fr auditrs r registered entities being audited t prvide feedback n a standard culd be beneficial t ntice issues with standards. During a mnitring prcess r risk assessment, that feedback culd be valuable fr standards develpment wrk. Reginal Variances If a reginal standard is in effect, r is under cnsideratin fr a develpment prject, it shuld be wrapped int cntinent-wide Reliability Standards as a reginal variance, prvided that there is a cntinent-wide standard that addresses the same subject. 9

14 Enhanced Peridic Review Guidelines11F Cnstruct f Standards The IERP recmmendatins n a new cnstruct f standards will need t be researched with industry t establish the benefit f realigning the standards. Fr example, the ttal transfer capability standards (prpsed MOD-001-2) and sme f the FAC standards have sme verlap. If there is cnsensus in the industry, a discussin abut the standards alignment and where requirements culd best reside can take place as part f the EPR discussin. Surveys and Plls Surveys and plls culd be gd utreach tls as the feedback lps are implemented in the beginning f Questins fr the industry, r thughts n cnducting the EPRs, culd be an efficient way t cllect stakehlders pinins. Since standards develpment is n a mre measurable apprach and nt n a track t accmplish X amunt f prjects a year, this will be imprtant feedback t ensure industry resurces are nt strained and the priritizatin f prjects and EPRs addresses prjects/peple invlved in high-risk areas. Crdinatin with the Nrth American Energy Standards Bard (NAESB) NERC rutinely crdinates with NAESB n NERC Reliability Standard develpment and hw it may affect sme f the NAESB business practices. NAESB mnitrs varius NERC prjects and the crdinatin between NERC and NAESB will cntinue. 10