FERC asks NERC to approve new transmission reliability standards

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FERC on June 18 issued a notice of proposed rulemaking that would approve NERC’s proposal to replace the existing suite of transmission operations (TOP) reliability standards with three TOP reliability standards.

According to the notice, NERC’s proposed TOP reliability standards generally address real-time operations and planning for next-day operations, and apply primarily to the responsibilities and authorities of transmission operators. FERC said that the proposed revisions are designed to ensure that transmission operators plan and operate within all system operating limits (SOL).

In the notice, FERC said it believes that the proposed standards improve on the currently effective standards by providing a more precise set of reliability standards addressing operating responsibilities and improving the delineation of responsibilities between applicable entities.

In relation to the notice, FERC requested stakeholder comments on four issues:

·      possible inconsistencies in identifying interconnection reliability operating limits (IROL)

·      monitoring of non-bulk electric system facilities

·      removal of the load-serving entity as an applicable entity for proposed reliability standard TOP-001-3

·      data exchange capabilities

Comments are due to FERC within 60 days of the pending publication of the notice in the Federal Register.

The proposed TOP reliability standards are TOP-001-3, TOP-002-4 and TOP-003-3.

TOP-001-3 contains 20 requirements designed to prevent instability, uncontrolled separation or cascading outages that adversely affect the reliability of the interconnection, by ensuring prompt action to prevent or mitigate such occurrences, according to the notice. FERC said that the proposed standard achieves the reliability goal by providing appropriate entities with the authority to take actions, or direct the actions of others, to maintain reliability during real-time operations. The standard includes real-time monitoring and real-time assessment requirements to preserve reliability and ensure that applicable entities identify and address all SOL exceedances.

According to the notice, TOP-002-4 contains seven requirements relating to operations planning for transmission operators and balancing authorities. FERC said that the proposed standard addresses next-day planning and provides for the necessary notifications and coordination between various functional entities. The proposed standard also improves coordination of next-day operations by requiring transmission operators and balancing authorities to provide operating plans to their reliability coordinators.

TOP-003-3 contains five requirements pertaining to the provision of information and data needed by the transmission operator and balancing authority for reliable operations, according to the notice. FERC said that the purpose of the standard is to ensure that transmission operators and balancing authorities have the data needed to fulfill their operational and planning responsibilities. The proposed standard also requires entities receiving data specifications to respond according to mutually agreed upon parameters, including format and security protocols.

The notice also would approve NERC’s proposed interconnection reliability operations and coordination (IRO) reliability standards to complement the proposed TOP standards.

FERC said that the IRO reliability standards would ensure that the bulk electric system is planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions. The proposed IRO reliability standards establish the responsibility and authority of reliability coordinators to provide for reliable operations.

FERC said in the notice that, under the proposed IRO reliability standards, reliability coordinators must continue to monitor SOLs in addition to their obligation in the current reliability standards to monitor and analyze IROLs. FERC added that those obligations require reliability coordinators to have the wide-area view necessary for situational awareness and provide them with the ability to respond to system conditions that have the potential to negatively affect reliable operations.

According to the notice, IRO-001-4 contains three requirements relating to the reliability coordinator’s overall responsibility for reliable operation within the reliability coordinator area. The requirements, for example, direct each reliability coordinator to act to address the reliability of its reliability coordinator area through direct actions or by issuing operating instructions.

IRO-002-4 contains four requirements relating to capabilities for monitoring and analysis of real-time operating data, according to the notice. FERC said that the purpose of the proposed reliability standard is to provide system operators with the capabilities necessary to monitor and analyze data needed to perform reliability functions. The requirements, for example, direct reliability coordinators to have data exchange capabilities with their balancing authorities, transmission operators, and other entities as they deem necessary, for them to perform operational planning analyses, real-time monitoring and real-time assessments.

According to the notice, IRO-008-2 contains six requirements for reliability coordinators to conduct next-day analyses and assessments of operating conditions in real-time to help prevent instability, uncontrolled separation or cascading. FERC said that the proposed standard enhances next-day operations planning by specifying requirements for coordination of the reliability coordinator’s operating plan to address potential SOL and IROL exceedances. The requirements, for example, direct each reliability coordinator to perform an operational planning analysis that will allow it to assess whether the planned operations for the next day will exceed SOLs and IROLs.

IRO-010-2 provides a mechanism for a reliability coordinator to obtain the information and data it needs for reliable operations and to help prevent instability, uncontrolled separation or cascading outages, according to the notice. FERC said that the proposed reliability standard reflects recommendations from the 2011 Southwest Outage Blackout Report, including more clearly identifying necessary data and information to be included in a reliability coordinator’s data specification. The requirements, for example, direct reliability coordinators to maintain a documented specification for the data, including non-bulk electric system and external network data, necessary for them to perform operational planning analyses, real-time monitoring and real-time assessments.

According to the notice, IRO-014-3 contains requirements for coordination for interconnected operations at the reliability coordinator level. FERC said that the purpose of the proposed reliability standard is to ensure that each reliability coordinator’s operations are coordinated in such a way that they will not adversely affect other reliability coordinator areas and to preserve the reliability benefits of interconnected operations. The requirements, for example, direct reliability coordinators to have and implement operating procedures, processes or plans for activities that require notification or coordination of actions that may affect adjacent reliability coordinator areas.

IRO-017-1 is designed to ensure that outages are properly coordinated in the operations planning time horizon and near-term transmission planning horizon, according to the notice. FERC said that the requirements in the proposed reliability standard, which span both time horizons, provide the necessary guidelines for effective coordination of planned outages to support reliable operations.

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