Electric Reliability Update - February 29, 2016

February 29, 2016

FERC

FERC Grants Extension of Time for Revised CIP Reliability Standards - February 25 - FERC issued a letter order granting an extension of time to defer the implementation of the critical infrastructure protection (CIP) version 5 Reliability Standards.  The extension from April 1, 2016 to July 1, 2016 aligns the CIP version 5 Reliability Standards with the effective date for the revised CIP Reliability Standards approved in Order No. 822.

FERC Approves Demand and Energy Data Reliability Standard - February 18 - FERC submitted a letter order approving Reliability Standard MOD-031-2 (Demand and Energy Data) and the associated implementation plan.  Reliability Standard MOD-031-2 clarifies the compliance obligations related to providing data to Regional Entities and responding to requests for data along with retiring the previous standard.  FERC's letter order also retires the previous standard, MOD-031-2. 

FERC Seeks Comment on Primary Frequency Response Rules - February 18 - FERC issued a Notice of Inquiry (NOI) soliciting comment on the need for reforms regarding its primary frequency response rules.  Specifically, FERC is seeking comment on whether new primary frequency response requirements are necessary, given that fewer energy sources are providing primary frequency response due to the transforming energy supply mix.  Comments are due on April 25, 2016 and can be submitted through the Federal Register.

Shortened Answer Period in the Revised CIP Standards Proceeding - February 5 - FERC issued a notice shortening the date for filing answers to a motion by electric utility trade associations in the revised Critical Infrastructure Protection standards proceeding to and including February 12, 2016. 

NERC

NERC Submits Annual Compliance Monitoring and Enforcement Program Filing- February 18 - NERC submitted its annual Compliance Monitoring and Enforcement Program (CMEP) filing, which details the following: risk-based CMEP progress and trends; interplay between risk-based CMEP and other programs; internal controls evaluation; use of learning tools; oversight; and metrics for 2015.  According to the filing, NERC and its Regional Entities made significant gains in the implementation of the risk-based CMEP, which allows for additional focus on reliability issues.  

NERC Submits Compliance Filing in Response to January 16 Order - February 16 - NERC submitted to FERC a compliance filing in accordance with FERC’s January 16, 2013 Order approving a Settlement Agreement between the Office of Enforcement and NERC.  The compliance filing included an unaudited report of NERC’s budget-to-actual variance information for the fourth quarter of 2015.

NERC Provides Supplemental Information for Approval of Balancing Authority Reliability Standard - February 12 - NERC provided supplemental information for its petition for approval of Reliability Standard BAL-002-2 (Balancing Authority), which will "help ensure that responsible entities balance resources and demand and recover from a system contingency that is within a responsible entity’s Most Severe Single Contingency."  The supplemental filing clarifies language in NERC’s original petition describing the interaction between the new Reliability Standard and Reliability Standard TOP-007-0, which is set to retire. 

NERC Board Adopts Two Standards Projects - February 11 - The NERC Board of Trustees adopted two standards projects, Project 2014.2.1- Phase 2 Balancing Authority Reliability-based Controls (BAL-005-1, FAC-001-3 and BAL-006-2) and Project 2010-07.1- Vegetation Management (FAC-003-4).  The Board also approved two regional reliability standards and elected a new member.

Congress

Senate Energy Bill Includes Amendment Requiring Reliability Impact Statement - An amendment proposed by the Chair of the Senate Energy and Natural Resources Committee, Senator Lisa Murkowski (R-AK), to the Energy Policy Modernization Act, which the Senator also introduced, will require FERC to coordinate with Regional Entities to develop a Reliability Impact Statement no later than 15 days after the proposal of a major rule by a Federal agency to determine the proposed rule's impact on the reliability of the bulk-power system.  The Senate may resume consideration of the Energy Policy Modernization Act this week, and the Murkowski amendment (#2963) is one of several designated for consideration by voice vote. 

Regional Developments

Peak Reliability 2015 Performance Metrics Report - February 11 - Peak Reliability (Peak) released its 2015 Performance Metrics Report tracking the four strategic pillars that were developed for its 2015-2019 Strategic Plan.  The four pillars include:  1) Interconnection-Wide Operational Excellence, 2) Stakeholder Value, 3) Employee Engagement, and 4) Financial Stability.  To track the performance, Peak developed 24 Performance Metrics within each pillar.

MRO Releases 2015 Annual Report - February 5 - Midwest Reliability Organization (MRO) released its 2015 Annual Report highlighting accomplishments of the past year.  The report also details the strategic direction for 2016, including implementation of new Critical Infrastructure Protection Standards and challenges to meet the Clean Power Plan standards. 

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The Van Ness Feldman Electric Reliability Update is published by Malcolm McLellanIlan GutherzVan SmithGabe TabakDarsh SinghTyler Elliott, and Michael Weiner.  Van Ness Feldman counsels, advises and trains a wide range of clients on reliability matters.  Please email us or call us at 206.829.1814 or 202.298.1800 for additional information.  Click here to sign up for the Reliability Update.