the reliable wirenerc focused on serious risk issues with its notices of penalty (nop), filing 12...
TRANSCRIPT
2018 CMEP Annual Report
The Reliable Wire provides the industry with updates on recent developments at NERC, FERC, and the regions that may impact your
operations and reliability compliance program.
RECENT NERC NEWS
On February 6, 2019, NERC released its 2018 Compliance Monitoring and Enforcement Program (CMEP) Annual Report, providing an extensive summary of NERC’s 2018 CMEP activities and 2019 priorities. A few key metrics related to the ERO Enterprise oversight activities:
• NERC focused on serious risk issues with its Notices of Penalty (NOP), filing 12 full NOPs with a combined penalty amount of $4.3M.
• NERC continued to see an increase in the use of streamlined disposition, with 90 percent of minimal risk instances of non-compliance treated as Compliance Exceptions.
NERC’s 2019 CMEP priorities include: continuing its focus on program alignment; successfully completing activities to support the dissolution of Peak Reliability; and integrating internal control reviews in all scheduled compliance audits and spot checks.
Takeaways from Inverter-Based Resource Workshop
On February 22, 2019, NERC released “Key Takeaways” from its recent Inverter-Based Resource Performance and Analysis Technical Workshop. Some highlights include:
• The NERC Inverter-Based Resource Performance Task Force (IRPTF) is developing a Reliability Guideline: Improvements to Interconnection Requirements for BPS-Connected Inverter-Based Resources that can be used by TOs to improve the clarity and technical strength of their interconnection requirements for newly interconnecting inverter-based resources.
• GOs are encouraged to work with their inverter manufacturers to eliminate the use of momentary cessation for existing solar PV facilities, to the extent possible.
• The majority of models in the interconnection-wide planning cases used to represent solar PV resources do not accurately represent the resource installed in the field.
Formation of Electric-Gas Working GroupOn February 21, 2019, NERC announced the formation of the Electric-Gas Working Group (EGWG). The EGWG will develop a Reliability Guideline on effectively assessing fuel disruption risks in planning studies, among other activities. NERC is seeking technical experts on generator ownership and operation, transmission planning, and generation planning to join the EGWG roster.
DEVELOPMENTS AT NERC
Proposed Consolidation of SO CertificationOn February 11, 2019, NERC’s Personnel Certification Governance Committee (PCGC) issued a whitepaper to communicate proposed changes to NERC’s System Operator Certification program. The proposal would consolidate the current four credentials of the System Operator Certification to one credential, “NERC Certified System Operator.” The PCGC believes that one credential will ensure all System Operators are tested to the same level of minimum knowledge and skills to better serve reliability. This whitepaper will be posted for industry comment until March 27, 2019, with any feedback sent to [email protected]. The PCGC will review all responses received during the comment period and determine the next steps of the project.
Phase 2 of Standards Efficiency ReviewNERC conducted a webinar on February 22, 2019 to solicit industry feedback on Phase Two of the Standards Efficiency Review (SER), in which it will continue to seek solutions to reduce inefficiencies and unnecessary regulatory burdens in the NERC Standards while supporting continued reliability.
The SER team presented its approaches to concepts such as moving requirements to guidance and consolidating categories of requirements (e.g., training and data exchange). The SER Phase 2 Team is seeking industry input on each concept via a questionnaire, with responses due by March 22, 2019.
Expansion of SERC
On February 7, 2019, the NERC Board of Trustees authorized NERC to terminate the delegation agreement with the Florida Reliability Coordinating Council (FRCC) and approved the transfer of the FRCC registered entities to SERC. On February 27, 2019, SERC filed a joint petition with NERC and FRCC for FERC approvals in connection with FRCC’s dissolution. Pending approval from FERC, this transition is expected to occur by 7/1/19.
KEY REGION AND MARKET NEWS
CAISO
• On February 20, 2019, CAISO announced the new name of its Reliability Coordinator (RC) service, RC West, and completion of 39 RC service agreements with BAs and TOPs. The CAISO expects to begin providing RC services for California in July 2019.
Texas RE
• Texas RE posted an updated 2019 Annual Audit Plan, listing all registered entities scheduled for a compliance audit in 2019.
WECC• On February 7, 2019, WECC launched its new brand, including
use of “WECC” and a change in its domain name to www.wecc.org.
• WECC renamed the Entity Oversight department to the “Reliability and Security Oversight” department.
STANDARDS IN MOTION
Adoption of CIP-008-6On February 7, 2019, the NERC Board of Trustees approved proposed modifications to CIP-008-6 (Cyber Security Incident Reporting), which had received the requisite two-thirds approval via industry ballot. The revised Standard expands the scope of mandatory reporting of Cyber Security Incidents to include attempts to compromise applicable systems; and adds a Requirement R4 for reporting and notification timelines for Reportable Cyber Security Incidents and applicable attempts. NERC is expected to file the proposed Standard for regulatory approval soon in order to satisfy FERC’s directive.
Assembly of PRC-024-2 Drafting TeamThe comment period on the Standard Authorization Request (SAR) proposing to revise PRC-024-2 (Generator Frequency and Voltage Protective Relay Settings) closed on January 18, 2019. 35 sets of responses were received, representing over 90 companies. The SAR proposes to address and clarify issues identified in a whitepaper prepared by the Inverter-Based Resource Performance Task Force (IRPTF), detailing potential gaps and necessary clarifications in PRC-024-2 to reflect the performance of inverter-based resources. On February 20, 2019, the NERC Standards Committee appointed the Standard Drafting Team, with the first in-person drafting team meeting held February 26-27, 2019 in Austin, TX.
Comment and Ballot on Proposed Retirements
On February 27, 2019, NERC announced the opening of a formal comment period and initial ballots as part of Phase One of its Standards Efficiency Review (SER) initiative designed to reduce current inefficiencies in the NERC Reliability Standards. The comment period is open through April 12, 2019 and initial ballots will be conducted April 3-12, 2019. NERC is proposing the partial or complete retirement of specific Reliability Standards, including: FAC-008-4 (Facility Ratings), with proposed retirement of R4-R5 & R7-R8; and PRC-004-6 (Protection System Misoperation Identification and Correction), with proposed retirement of R4. There is a single form seeking comments from registered entities on the proposed retirements and there will be a separate ballot for each standard.
NERC GUIDANCE
• On February 13, 2019, NERC posted new proposed implementation guidance addressing CIP-004-6 (Access Control for BES Cyber System Information (BCSI) Repositories Managed by Service Providers). If endorsed, the ERO Enterprise would give examples in this guidance deference during compliance monitoring activities.
• On February 28, 2019, NERC issued two Lessons Learned: (1) Substation Fires: Working With First Responders (applicable to TO/GO/DP); and (2) Current Drone Usage (applicable to TO/TOP/GO/GOP).
UPCOMING EVENTS AND WEBINARS
March 14, 2019
2019 Reliability Leadership Summit
(Washington, DC)
March 26-28, 2019
NERC 8th Annual Human Performance Conference
(Atlanta, GA)
CYBERSECURITY AWARENESS MOMENT
One Step to Reduce Data Breaches
According to a recent Verizon Data Breach Report, 81% of data breaches have one thing in common: stolen or compromised credentials. Even though we know better, too many of us reuse credentials across sites and applications (personal and professional). Multi-factor authentication is a solution to significantly reduce the risk of poor password security. This works by relying on something you know + something you have.
In the typical use-case, the “something you know” is your standard username and password combination; the “something you have” is either a hardware token or, more commonly, a mobile device enrolled as an authorized second factor. This means that if your username and password are compromised, an attacker still cannot login as you without approving the second factor veri-fication on your phone. Multi-factor authentication is especially important for VPN connections to critical infrastructure.
UPCOMING EFFECTIVE DATES
Reliability Standard Title Effective DateEOP-004-4 Event Reporting April 1, 2019
EOP-005-3 System Restoration from Blackstart Resources April 1, 2019
EOP-006-3 System Restoration Coordination April 1, 2019
EOP-008-2 Loss of Control Center Functionality April 1, 2019
PER-003-2 Operating Personnel Credentials July 1, 2019
TPL-007-3 (R1 & R2) Transmission System Planned Performance for Geomagnetic Disturbance Events
July 1, 2019
March 2019
ABOUT GRIDSME GridSME is a results-focused consulting firm, representing a diverse group of talented electric industry experts ready to help guide our clients through the fast-changing landscape of the industry.
Our clients make up a very diverse group, ranging from small renewable energy companies to large regional utilities and everything in-between—our subject matter experts (SME) provide pragmatic solutions on a wide range of operational, technical, and business challenges, leveraging industry best-practice knowledge gleaned over the many decades of collective experience amassed by our team. While GridSME’s core competencies lie in NERC compliance, cybersecurity, and electrical engineering, we provide a number of additional grid support services to our clients, such as electricity market expertise, operations training, and IT services.
April 9-11, 2019
WECC Spring Reliability & Security Workshop
(Anaheim, CA)
April 25, 2019
Texas RE Spring Standards & Compliance Workshop
(Austin, TX)
May 1, 2019
2019 Western Reliability Summit
(Scottsdale, AZ)
May 1-3, 2019
ReliabilityFirst Spring Reliability and CIP Workshops
(Baltimore, MD)
March
April
May
Please let us know if you want more information on anything contained in this issue and we appreciate your feedback on The Reliable Wire.
WireThe Reliable