On September 20, 2017, FERC issued two final rules and a notice of proposed rulemaking (“NOPR”) on reliability standards for the bulk power system. The final rules—Order Nos. 836 and 837—will become effective sixty days after their publication in the Federal Register. Parties interested in filing comments on matters discussed in the NOPR must do so within sixty days of when that notice is published in the Federal Register.
In Order Nos. 836 and 837, FERC approved various proposals raised by the nation’s Electric Reliability Organization, the North American Electric Reliability Corporation (“NERC”). In the case of Order No. 836, FERC approved NERC’s proposed Reliability Standards BAL-005-1 (Balancing Authority Control) and FAC-001-3 (Facility Interconnection Requirements), as well as NERC’s proposal to retire Reliability Standards BAL-005-0.2b (Automatic Generation Control), FAC-001-2 (Facility Interconnection Requirements), and BAL-006-2 (Inadvertent Interchange). As FERC stated in its order, these standards are intended to enhance reliability by clarifying and consolidating existing requirements related to frequency control, including requiring timely reporting of Area Control Errors.
In Order No. 837, FERC approved Reliability Standard PRC-012-2 (Remedial Action Schemes) and associated violation risk factors and severity levels, implementation plan, and effective date proposed by NERC. As FERC stated in its Order, the goal of new Reliability Standard PRC-012-2 is to ensure that remedial action schemes do not introduce unintentional or unacceptable reliability risks to the bulk electric system.
Issued concurrently with Order Nos. 836 and 837 was the NOPR in which FERC has proposed to approve four Emergency Preparedness and Operations (“EOP”) Reliability Standards: EOP-004-4 (Event Reporting), EOP-005-3 (System Restoration from Blackstart Resources), EOP-006-3 (System Restoration Coordination), and EOP-008-2 (Loss of Control Center Functionality). The first proposed standard, EOP-004-4, is intended to enhance reliability by assigning reporting to appropriate entities and clarifying the threshold reporting for a given event. Meanwhile, proposed Reliability Standards EOP-005-3, EOP-006-3, and EOP-008-2 are intended to enhance reliability by: delineating the roles and responsibilities of entities that support system restoration from blackstart resources; clarifying the procedures and coordination requirements for reliability coordinator personnel to execute system restoration processes; and refining operating plan elements if primary control functionality is lost. Along with these new standards, FERC also proposes to retire their currently-effective counterparts, EOP-004-3, EOP-005-2, EOP-006-2, and EOP-008-1, immediately prior to the effective dates of the proposed EOP Reliability Standards.