FERC

FERC Conditionally Accepts NERC Compliance Filing - November 4 - FERC issued an order conditionally accepting NERC’s compliance filing on its Reliability Assurance Initiative in Dockets RR15-2-001 and RR15-2-002.  In the Order, FERC directed NERC to codify the Self-Log Review period and submit a compliance filing within 120 days of the date of the Order.  Furthermore, NERC is directed to include additional information in future reports on the risk-based compliance monitoring and enforcement program.

FERC Order Conditionally Approving Revised Delegation Agreements - November 2 - FERC conditionally approved NERC’s proposed Pro Forma Delegation Agreement and revised Regional Entity delegation agreements .  The revised versions are intended to replace the current Regional Delegation Agreements, which expire on December 31, 2015.  FERC is directing NERC to submit a compliance filing within 120 days to implement several additional modifications to the Delegation Agreements.

FERC Approves NERC 2016 Business Plans and Budgets - November 2 - FERC accepted the 2016 business plans and budgets for NERC, the Regional Entities, and the Western Interconnection Regional Advisory Board (WIRAB).  NERC’s 2016 Business Plan and Budget proposal, originally filed on August 24, totals $150,501,295, including $51,785,828 for NERC funding, $97,666,649 for Regional Entity funding, and $1,048,819 for WIRAB funding.

FERC to Hold Technical Conference on Critical Infrastructure Protection - October 28 - FERC will hold a technical conference on Critical Infrastructure Protection Supply Chain Risk Management.  The conference, led by FERC staff, will facilitate discussion on features, requirements, and a timetable for NERC to develop Reliability Standards for supply chain risk management.

NERC

NERC Assessment of Protection System Single Points of Failure - October 30 - NERC submitted to FERC a report title Order No. 754 Assessment of Protection System Single Points of Failure Based on the Section 1600 Data Request (Assessment).  The Assessment, prepared by NERC System Protection and Control Subcommittee (SPCS) and the System Analysis and Modeling Subcommittee (SAMS), analyzed transmission owner and operator data that assessed locations where a three-phase fault accompanied by a protection system failure could result in a reliability risk.  The Assessment concluded that there are fewer instances of a single point of failure on higher voltage systems, but there is a potential reliability risk associated with protection systems that the SPCS and SAMS need to address.  NERC requested that FERC accept this filing for informational purposes only.

NERC Submits Supplemental Information Clarifying VRF Implementation Plan - October 23 - NERC submitted a supplemental filing to clarify its July 7 proposed revisions to the Violation Risk Factors (VRFs) for Requirement R1 through R6 of Reliability Standards PRC-004-3, PRC-004-4, and PRC-004-5.   

NERC Comments on GMD Benchmark Event TPL-007-1 - October 22 - NERC submitted comments regarding the technical paper prepared by Los Alamos National Laboratory (LANL) titled Review of the GMD Benchmark Event in TPL-007-1 (LANL Report).  The LANL Report provided results and analysis for the proposed Reliability Standard TPL-007-1 – Transmission System Planned Performance for Geomagnetic Disturbance Events (GMD Event).  Specifically, the LANL Report analyzed geoelectric field magnitude, the scaling of the GMD Event based on geomagnetic latitude, and the effect of earth conductivity data on scaling the GMD Event.  NERCs comments support the LANL Report saying that the GMD Event was developed using a technically-justified approach and that proposed Reliability Standard TPL-007-1 should be approved.

FERC Requests FFT Information from MRO - October 20 - NERC issued a data request to the Midwest Reliability Organization (MRO) to allow for evaluation of NERC’s Find, Fix, Track and Report (FFT) and Compliance Exception programs.   

Cybersecurity and Grid Security

NRC Adopts New Cyber Security Regulations - November 2 - The U.S. Nuclear Regulatory Commission adopted new rules to guide nuclear power plants following the commission’s analysis on the reliability and effectiveness of nuclear power reactor licensees. The rules, which go into effect December 2^nd, establish new cyber security event notification requirements, codify certain reporting activities, and will, according to the NRC, help to provide “high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks.”

Congress

Grid Security Amendment Added to Transportation Bill - November 5 - A grid security amendment introduced by House Energy and Commerce Committee Chairman Fred Upton (R-MI) was attached to the House transportation bill.  The amendment would grant the government new emergency powers over the electric grid in the event the President declares a “grid security emergency.”  The transportation bill, as amended, passed the House by a vote of 363-64. 

Cybersecurity Information Sharing Act Passes Senate - October 27 - The Cybersecurity Information Sharing Act of 2015 (S. 754), introduced by Senator Richard Burr (R-NC) passed the Senate by a vote of 74-21.  If enacted, the bill would create additional incentives to increase sharing of cybersecurity threat information and facilitate voluntary cooperation between private companies and the government in sharing cyber threat indicators.  The bill would also protect companies that monitor or share cybersecurity information with the federal government from lawsuits related to those activities.

The Van Ness Feldman Electric Reliability Update is published by Andrew Art, Malcolm McLellan with assistance from Ilan Gutherz, Van Smith, Gabe Tabak, Tyler Elliott, and Michael Weiner.  Van Ness Feldmancounsels, advises and trains a wide range of clients on reliability matters.  Please email us or call us at 202.298.1817 or 206.829.1814 for additional information.  Click here to sign up for the Reliability Update.  

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