NERC Regional Entities

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“Our members know all too well that this industry is constantly changing and NERC compliance standards are no exception,” said Art Iler, AMP’s director of reliability standards compliance.

The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to assure the reliability of the bulk power system in North America. NERC develops and enforces Reliability Standards – there are currently 88 standards with numerous numbered requirements within each standard.

The standards impact AMP members who are operating or controlling facilities connected to the transmission system at 100 kV or higher, referred to by NERC as the Bulk Electric System (BES), as they must register with NERC and be subject to the NERC standards and requirements.

AMP is registered with NERC as a Generation Owner, Generation Operator and Resource Planner. AMP’s six NERC-registered generators are: AMP Fremont Energy Center; OMEGA JV2 in Hamilton; and hydro plants Belleville, Cannelton, Smithland and Willow Island.

There are eight Regional Entities (RE) who monitor NERC compliance, but the majority of AMP members and AMP’s BES generation facilities are located within the ReliabilityFirst Corporation’s (RF) region.

About 20 members are registered with NERC, and AMP helps these members stay up-to-date on NERC issues through monthly webinars, an annual onsite day-long NERC program, and monthly presentations to the AMP Board of Trustees.

The webinars and onsite program are both hosted by AMP with the assistance of Utility Services, a consulting firm that serves almost exclusively municipal power entities. The informational webinars are offered at no cost to AMP members and Utility Services offers a fee-based service for compliance assistance.

“Utility Services has a relationship with AMP and they work together to monitor all of the new standards that are coming, all of the existing standards that get changed, and then AMP and Utility Services together as a team try to educate the membership as to what is happening,” said Bill Lyren Jr., general manager of electric and communications for the City of Wadsworth.

Wadsworth is no stranger to the RE audit process.

“We’re on a regular audit schedule with the ReliabilityFirst Corp. and we are eligible to be audited on our applicable NERC standards every three years,” said Lyren. “This was our second time in five years. Our last audit was completed in late 2011, nearly five years between audits.”

Wadsworth began providing the RF auditor information in December 2016.

“When we were notified by our auditor in December, he sent us a huge spreadsheet that we needed to fill in all the blanks, and his requirement was that he wanted it completed and returned to him in just a couple weeks,” said Lyren.

The city didn’t have any indication the request was coming, and with the holiday season and regular work, Wadsworth immediately asked for an extension.

“We’re just a little guy here,” said Lyren. “We don’t have an entire compliance department or have staff dedicated to this. They did grant the extension and we used every bit of it.”

Lyren estimated over the audit process, between December and March, his staff spent hundreds of hours preparing its responses to the audit. The city also utilized Utility Services as a team member to assist with the audit compliance.

“We really enjoyed using them as a resource,” said Lyren. “They are the experts and were able to approve everything before we sent it to the auditor.”

NERC’s ultimate goal is to ensure better grid reliability, and although the process had its headaches, Lyren is looking at the positives of the situation and using it as a learning experience.

“At the conclusion of the audit, there were no findings, which was great, and it tells us that we are doing exactly what we need to be doing,” he said. “One of the biggest positives is we learned how we need to be maintaining our records. When the auditor made requests for evidence in a large package, we had to scramble to look for everything. While we knew it was in the database it wasn’t organized in the way they wanted it. We learned we need to do better at filing, labeling and dating so that we can just click and drag information into a package that was in the way the auditor wanted it received.”

Wadsworth’s experience with RF is not unique. REs monitor NERC compliance through quarterly, annual and other certifications; spot audits; and regular audits that cover critical infrastructure protection (CIP) and applicable standards compliance. AMP is currently scheduled for a non-CIP audit in 2018.

The Federal Energy Regulatory Commission (FERC) chose NERC as the national Electric Reliability Organization (ERO) in 2006, following the adoption of the Energy Policy Act in 2005.

“NERC is not a governmental or regulatory body, its actions are sanctioned by a regulatory body – FERC,” said Iler. “All standards proposed by NERC must be approved by FERC. Once approved, they are enforceable like a FERC regulation would be.”

Many NERC standards have undergone significant modification since they went into place about 10 years ago. The majority of the standards have reached almost a steady state, but the CIP standards have been evolving and are continuing to evolve.

“The CIP standards are up to version 6, which is currently enforceable, and versions 7 and 8 are being developed,” Iler said. “Cybersecurity is likely the area most susceptible to revision next.”

Most of the standards changes stem from issues recognized by FERC when the standards were first approved.

“NERC is catching up and its goal is to reach a point where there are limited changes to the standards,” explained Iler. “Although its own rules require a periodic review of the relevance and effectiveness of each standard.”

NERC annually assesses seasonal and long-term reliability, monitors the bulk power system through system awareness, and educates, trains and certifies industry personnel.

“Currently there is a lot of attention being paid to NERC’s modelling requirements,” said Iler. “There are significant concerns that currently acceptable models do not reflect actual performance of what is being modelled.”

Iler anticipates there will be new requirements to compare expected and actual performance in the near future.

“Behind the meter non-BES generation may need to be modelled in some instances, especially for larger units,” he said. “Self-logging of minor violations of the standards is gaining momentum and this will significantly reduce the number of self-reported violations to the regions.”

NERC’s area of responsibility currently spans the continental United States, Canada, the northern portion of Baja California, Mexico. However, NERC has reached a tentative agreement with the Mexican equivalent of FERC to cover the remainder of Mexico. NERC is the ERO for North America, and is subject to oversight by FERC and governmental authorities in Canada and Mexico. NERC’s jurisdiction includes users, owners and operators of the bulk power system, which serves more than 334 million people.

In addition to being a part of a number of mailing lists maintained by NERC, RF and others, AMP participates in several groups focused on NERC and other regulatory issues:

• AMP’s director of reliability standards compliance sits on the NERC Planning Committee
• Regular attendance at the meetings of the NERC Board of Trustees and NERC Members Representative Committee (NERC’s primary governing and stakeholder bodies)
• Monthly Transmission Access Policy Study Group (TAPS) NERC/North American Electric Standards Board update calls
• RF semiannual stakeholder meetings
• PJM’s Reliability Standards and Compliance Subcommittee

Additionally, AMP’s government relations team tracks new congressional proposals that would impact NERC standards and requirements.

“It’s important for AMP to continue the work they do on the regulatory and legislative fronts,” said Lyren. “I know they are at the table with NERC, and are educating federal agencies on the importance of municipals and their obligations.”

AMP members with questions regarding NERC are encouraged to contact Amy Ritts at 614.540.0899 or [email protected].

Compliance

There are 14 types of entities that if connected to, or operating or controlling facilities connected to the transmission system at 100 kV or higher (in NERC terms the Bulk Electric System or BES), must register with NERC and be subject to the NERC standards and the requirements.

As applicable to AMP and its members, NERC registration is required for entities with BES facilities.

These include:

• Generation owners (GO) and/or generation operators (GOP) with generation facilities larger than 20 MVA (distributed generation including wind farms and solar facilities must be greater than 75 MVA)
• Resource Planners (RP)
• Distribution Providers (DP) with facilities serving greater than 75 MW of load
• Smaller DPs larger than 25 MW that are part of certain vital reliability-related programs such as Under-Frequency Load Shedding and Under-Voltage Load Shedding are also required to register
• Transmission Owners (TO)
• Under NERC’s recently revised definition of BES, this may include entities that were either previously registered only as a DP, or even not previously registered, that own facilities such as a ring bus operated at 100 kV or above or which have 100 kV or above lines that loop through their distribution system