Project 2013-02 Paragraph 81 - NERC...Aug 21, 2012 · Phase 1 Spreadsheet with Proposed Retirements Comment Form (Word) Next Steps • September 12-13, 2012: SDT meeting to complete

Project 2013-02

Paragraph 81Paragraph 81

Industry Webinar

August 21, 2012 | 2:00-3:00 p.m. ET

Administrative

• NERC Antitrust Guidelines

• Notice of open meeting

• Introduction of presenters

• Submit questions through chat feature on ReadyTalk

2 RELIABILITY | ACCOUNTABILITY

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


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.

Agenda

• Background

• Draft Standard Authorization Request (SAR)

• Submitting comments

• Benefits of the Paragraph 81 (P81) project

• Project status


• Project status

• Next steps

• Questions

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.”


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.”

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,


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

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


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

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


• 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

Relevant Criteria

• The Reliability Standard requirement must satisfy

both Criteria A and B, with consideration of Criteria C


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


Criteria B

• Requirement fits any of the following:

� Administrative

� Data Collection/Data Retention

� Purely Documentation

� Purely Reporting


� 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

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


• 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?

Submitting Comments

• Question #1

� Do you agree with the criteria listed in the SAR to identify

Reliability Standard requirements for retirement?


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


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.


• 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


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.


• 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.


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


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

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


• Will increase efficiency of the ERO compliance

programs

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


02_Paragraph_81.html

• Posted Materials:

� Complete Set of Standards with Proposed Retirements for

Phase 1

� Spreadsheet with Proposed Retirements

� Comment Form (Word)

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


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

Questions?

• Please submit questions through the

ReadyTalk chat window

21 RELIABILITY | ACCOUNTABILITYRELIABILITY | ACCOUNTABILITY

Contact Information

Brian Murphy

P81 Chair

305-442-5132

[email protected]

Kristin Iwanechko

P81 NERC Coordinator

404-446-9736

[email protected]

22 RELIABILITY | ACCOUNTABILITYRELIABILITY | ACCOUNTABILITY

Guy Zito

P81 Vice-Chair

212-840-1070

[email protected]

Documents

Project 2013-02 Paragraph 81 - NERC...Aug 21, 2012 · Phase 1 Spreadsheet with Proposed Retirements Comment Form (Word) Next Steps • September 12-13, 2012: SDT meeting to complete