2004NERC, NPCC & New

EnglandCompliance Programs

John Norden

Manager, Operations Training, Documentation & Compliance

August 31, 2003 RC Meeting

NERC 2004 Program Changespost-blackout

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Request from NERC on 10/15/2003 to Reliability Coordinators and Control Areas to review reliability practices to ensure compliance with NERC and regional reliability council standards and established good utility practices Surveyed Participant practices for two issues

Ensure all interconnected generators that have automatic voltage regulation (AVR) and are operating under AVR; and

Ensure high voltage transmission line rights of way are free of vegetation and other obstructions that could contact an energized conductor within the normal and emergency ratings of each line

Near-Term Actions to Assure Reliable Operations

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Recommendation 2 of NERC Final Blackout Report: “Strengthen the NERC Compliance Enforcement Program”

NERC Formed the CTTF in order to make more clear the existing requirements and develop any additional measures as were identified as contributing factors to the Blackout 12 additional measures and more clear requirements

replace what was in the existing 2004 Compliance Enforcement Program

Compliance Template Task Force (CTTF)

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On April 2, 2004 the NERC BOT approved a set of 38 revised compliance templates that strengthen and clarify existing standards 18 Planning Measures 20 Operating Measures

Reporting required as of June 1, 2004 Many requirements are “upon occurrence”

as opposed to scheduled reporting

38 “New” Compliance Templates

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Protection System Maintenance and Testing NPCC Document A-4, Bulk Power System Protection

Minimum Maintenance already in the Enforceable Program

Inter-Area Coordination (outages & Interchange) NPCC does a very good job

Operator Training Vegetation Management

New England Transmission Maintenance and Construction Task Group will be revising OP #3 Appendix C and D and asking the RC for approval as a separate Operating Procedure

Loss of Primary Control Facility

Major Additions

NERC Version 0 Update

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“Plan for Accelerating the Adoption of NERC Reliability Standards” – June 15, 2004

How does this effect the Version 1 process

Translation from existing requirements

Existing Planning Standards, including post-blackout Compliance Template revisions

Existing Operating Policies, including post-blackout Policy 5,6, and 9 revisions

“Version 0” NERC Standards

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Why “Version 0”? The August 14 blackout has challenged NERC and the

industry to demonstrate that its reliability standards are unambiguous and measurable – now.

Recommendation 25 of the U.S./Canada Power System Outage Task Force final report: “NERC should reevaluate its existing reliability standards development process and accelerate the adoption of enforceable standards.”

An April 14, 2004 order of FERC states a policy objective addressing “the need to expeditiously modify [NERC] reliability standards in order to make these standards clear and enforceable.”

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Why “Version 0”? (cont’d.)

The continued use of multiple formats, processes and forums for developing and maintaining reliability rules is an inefficient dilution of industry and staff resources.

The transition to new standards and retiring of existing operating policies and planning standards will be too complex for industry implementation if taken one standard at a time over several years.

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“Version 0” Status Posted for Industry Comment on July 11th

Over 400 pages of documentation to review Only 30 days to review, compile & submit comments

Comment period closed on August 9th

Approximately 100 entities submitted written comments

ISO-NE, NPCC and ISO/RTO Council reviewed all material and issued comments including issues with Phase III and IV Planning standards regarding generation testing.

ISO-NE also has issues with implementation plans

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“Version 0” Next Steps Drafting Team met again August 18-20

Comments considered Standards revised, as appropriate

Second draft to be posted by August 30th

45 days review period During September and October, several regional

workshops will be held to hear comments and answer questions about the Version 0 reliability standards and the registration of reliability functions

Committee action during November 9-11 meetings Present to NERC BOT in February 2005 and

implementation upon approval

2004 Program Status Report

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Reporting Participants report on all Participant

Compliance requirements to the ISO The ISO reports both Participant and Area

Compliance for NPCC and NERC Measures through NPCC

Regions (NPCC) report on Regional Compliance (a compilation of all Areas’ and all Area’s Participant compliance) to NERC for the NERC Measures

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2004 NERC Requirements 41 Requirements in the Final 2004 Program

22 “Planning” (4 of which are operational) 19 Operations 12 Covered by NPCC Compliance

requirements; no double-reporting 6 Regional (NPCC) reporting requirements 15 Area/Reliability Coordinator reporting

requirements 8 Participant reporting requirements

All surveyed and reported on for the 2004 Program

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2004 NPCC NRAP(non-enforceable)

Five Requirements One Planning – Participant reporting on

Generator Underfrequency Tripping Four Operations

One Participant Reporting - Testing Requirements for critical components associated with key facilities (Document A-03, Section 4.10) To be Reported in Early 2005

Three Area reporting requirements

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2004 NPCC RCEP(enforceable)

Eight Requirements Three Planning – Two are Participant

reporting requirements Minimum BPS Maintenance Area Automatic UFLS requirements

Five Operations One Participant Reporting – Annual

blackstart testing requirement (Document A-03)

Reported from previous year

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2004 NPCC & NERC Reporting Status

Partial non-compliance reported NPCC-wide on the NRAP non-enforceable measure for Testing Requirements for critical components associated with key facilities May be due to required clarification to uniformly

address some of the specific testing requirements contained in Section 4.10.1 of Document A-03

Critical requirements following August 14th Blackout Several testing requirements will be enforceable in

next year’s program Need to stress importance to Industry Participants that

compliance with NPCC Criteria, whether enforceable or not, is required by the Restated NEPOOL Agreement!

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2004 New England Two Requirements identified to-date

NEPOOL Operating Procedure No. 17, ‘Load Power Factor Correction’

NEPOOL Operating Procedure No. 13, ‘Standards For Voltage Reduction and Load Shedding Capability’ – 5% Voltage Reduction

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2005 NPCC RCEP(Document A-08)

Report on the “Restoration of the NPCC Areas Following the Power System Collapse of August 14, 2003” recommends additional requirements of this Program NPCC Document A-03, ‘Emergency

Operation Criteria,’ Section 4.10 Make several tests enforceable with

penalties Blackstart Generating Station Testing (“BS-1”); and Control Center and Telecommunication Center

Facility Testing (“CC-1” through “CC-7”)

Questions