project 2013-02 paragraph 81 - nerc...aug 21, 2012 · phase 1 spreadsheet with proposed...
TRANSCRIPT
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Project 2013-02
Paragraph 81Paragraph 81
Industry Webinar
August 21, 2012 | 2:00-3:00 p.m. ET
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Administrative
• NERC Antitrust Guidelines
• Notice of open meeting
• Introduction of presenters
• Submit questions through chat feature on ReadyTalk
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Antitrust Guidelines
• It is NERC’s policy and practice to obey the antitrust
laws and to avoid all conduct that unreasonably
restrains competition. This policy requires the
avoidance of any conduct that violates, or that might
appear to violate, the antitrust laws. Among other
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appear to violate, the antitrust laws. Among other
things, the antitrust laws forbid any agreement
between or among competitors regarding prices,
availability of service, product design, terms of sale,
division of markets, allocation of customers or any
other activity that unreasonably restrains
competition.
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Agenda
• Background
• Draft Standard Authorization Request (SAR)
• Submitting comments
• Benefits of the Paragraph 81 (P81) project
• Project status
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• Project status
• Next steps
• Questions
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Background
• FERC March 15, 2012 Order regarding the Find, Fix,
Track and Report (FFT) process
� P81
� Opportunity to “…remove from the Commission-approved
Reliability Standards unnecessary or redundant
requirements.”
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requirements.”
• NERC Standard Process Input Group (SPIG)
Recommendation No. 4
� “Standards Product Issues: The NERC board is encouraged
to require that the standards development process address:
. . . The retirement of standards no longer needed to meet
an adequate level of reliability.”
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Background
• Collaborative effort
� The North American Electric Reliability Corporation (NERC)
� The Regional Entity Management Group (Regions)
� The Trades and their member companies (Industry)
o Edison Electric Institute, American Public Power Association,
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o Edison Electric Institute, American Public Power Association,
National Rural Electric Cooperative Association, Large Public Power
Council, Electricity Consumers Resource Council, The Electric Power
Supply Association and the Transmission Access Policy Study Group
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Standard Authorization Request (SAR)
• Standards Committee approved the draft SAR for
posting during its July 2012 meeting
• The draft SAR:
� Identifies criteria for retiring or modifying requirements
o The criteria is broad enough to be used in all phases and to capture
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o The criteria is broad enough to be used in all phases and to capture
all Reliability Standard requirements that are unnecessary,
redundant or provide little protection to the Bulk Electric System
(BES)
� Defines phases
� Includes a suggested list of requirements put together by
NERC, the Regions, and Industry for potential inclusion in
the initial phase
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Phased Approach
• Initial Phase
� Shall identify for retirement all FERC-approved Reliability
Standard requirements that easily satisfy the criteria set
forth in the SAR
• Future Phases
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• Future Phases
� Shall identify FERC-approved Reliability Standard
requirements that satisfy the criteria set forth in the SAR,
but could not be included in the Initial Phase due to the
need for additional analysis or an editing of language
� The composition of the Standard Drafting Team (SDT) may
need to change in future phases based on the expertise
required
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Relevant Criteria
• The Reliability Standard requirement must satisfy
both Criteria A and B, with consideration of Criteria C
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Criteria A
• In the event no responsible entity performed the
FERC-approved Reliability Standard requirement,
there would be little or no impact to the protection or
reliable operation of the BES
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Criteria B
• Requirement fits any of the following:
� Administrative
� Data Collection/Data Retention
� Purely Documentation
� Purely Reporting
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� Purely Reporting
� Periodic Updates
� Commercial or Business Practice
� Redundant
� Hinders the protection or reliable operation of the BES
� Little, if any, value as a reliability requirement
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Criteria C
• Was the Reliability Standard requirement part of a FFT filing?
• Is the Reliability Standard requirement being reviewed in an ongoing standards development project?
• What is the Violation Risk Factor of the Reliability Standard requirement?
• In which tier of the Actively Monitored Standards does the
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• In which tier of the Actively Monitored Standards does the Reliability Standard requirement fall?
• Would retiring the requirement have any negative impact on NERC’s published and posted Reliability Principles?
• Would retiring the requirement have any negative impact on the defense-in-depth protection of the BES?
• Does the retirement or modification promote results- or performance-based Reliability Standards?
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Submitting Comments
• Question #1
� Do you agree with the criteria listed in the SAR to identify
Reliability Standard requirements for retirement?
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Submitting CommentsContinued
• Question #2
� The Initial Phase of the P81 project is designed to identify all
FERC-approved Reliability Standard requirements that easily
satisfy the criteria. Do you agree that the suggested list of
Reliability Standard requirements included in the draft SAR
easily satisfy the criteria listed in the draft SAR? If you
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easily satisfy the criteria listed in the draft SAR? If you
disagree, please provide a statement supporting what
Reliability Standard requirements you would add or subtract
from the Initial Phase, including a citation to at least one
element of Criterion B, as applicable.
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Submitting CommentsContinued
• Question #3
� The subsequent phases of the P81 project are designed to
identify all FERC-approved Reliability Standard requirements
that could not be included in the Initial Phase due to the
need for additional analysis or an editing of language.
Please list any Reliability Standard requirements that you
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Please list any Reliability Standard requirements that you
believe should be revised or retired in a subsequent phase,
and include a brief supporting statement and citation to at
least one element of Criterion B for each requirement listed.
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Submitting CommentsContinued
• Question #4
� If you have any other comments or suggestions on the draft
SAR that you have not already provided in response to the
previous questions, please provide them here.
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Benefits of the P81 Project
• Responsive to P81 of FERC’s March 15, 2012 order
and SPIG Recommendation No. 4
• Requirements submitted for the initial phase appear
to be clear candidates and should not require
extensive technical research
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extensive technical research
• The collaborative nature of the project is an example
for future work because it advances the project while
reducing the impact on stakeholders and NERC staff
� The project is proposed to be under a tight schedule so it
will not impact resources for an expanded period of time
� The pace of the project sets an example for future work
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Benefits of the P81 ProjectContinued
• Furthers the focus on results- and performance-based
Reliability Standards
� May provide a roadmap of what should or should not be a
requirement in future Reliability Standards
• Will increase efficiency of the ERO compliance
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• Will increase efficiency of the ERO compliance
programs
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Project Status
• August 3-September 4, 2012: Draft SAR posted for
informal comment period
• Project page:
http://www.nerc.com/filez/standards/Project2013-
02_Paragraph_81.html
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02_Paragraph_81.html
• Posted Materials:
� Complete Set of Standards with Proposed Retirements for
Phase 1
� Spreadsheet with Proposed Retirements
� Comment Form (Word)
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Next Steps
• September 12-13, 2012: SDT meeting to complete
summary responses to the comments received and
finalize the SAR
• Final project schedule will be determined based on
comments received during the draft SAR posting
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comments received during the draft SAR posting
• Finalized SAR to go before Standards Committee
� Standards Committee also to finalize P81 SDT, possibly seek
additional Subject Matter Experts via nomination process
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Questions?
• Please submit questions through the
ReadyTalk chat window
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Contact Information
Brian Murphy
P81 Chair
305-442-5132
Kristin Iwanechko
P81 NERC Coordinator
404-446-9736
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Guy Zito
P81 Vice-Chair
212-840-1070