When the NERC standards were originally approved, they were derived from NERC Policies. Over the years, a great deal of effort was put into making the standards based on performance. However, in some instances, it appears that more recent standards are moving towards documentation requirements and away from performance-based requirements. Another way of saying this is that some new and/or proposed standards appear to prescribe specific details as opposed to setting the end goal.
As an example, compare TOP-003-5 to its predecessor, TOP-003-4. In response to cold weather events, the revision added language to both Requirements R1 and R2 , requiring that the TOP and BA acquire very specific information from the generators related to cold weather capability.
The question is not whether the BA and TOP need this information. The question is why do we need to specifically list this information in the requirement? If the industry agrees that the data is needed, why are these entities not being found in violation of the existing requirements, which allow the entities to request any data they need to properly plan and operate the grid? If these data points are needed to be listed in the requirement, what about maximum capability, ramp rate, start-up time? These data points are important in everyday planning and operation of the grid, not just during a cold weather event. In an audit, is it okay if these data points are not being collected by the BAs and TOPs since they are not listed in the requirements?
Is the problem that auditors are not doing an adequate review of the data points that TOPs and BAs need for an effective planning analysis to be performed? Are the auditors empowered to analyze the entities data specifications and determine if the requested data is sufficient to properly plan? If the entity does not have sufficient data points in their Data Specification, is it a potential violation? It was identified in the 2011 cold weather event report that the BAs needed cold weather capability information, and repeated in the 2018 cold weather event report. Have these Data Specifications been reviewed for sufficiency over the past 10 plus years? Were the Data Specifications found to be sufficient or lacking or are the auditors not allowed to look at the specific points requested?
If the auditors do not have the authority to address this type of issue, should the auditing process be improved or do we need to restructure the requirements in many standards to state specifically what is required? Do we need to list every step required to perform day-ahead planning analysis by the BA, TOP and RC?
Note that the current proposal for MOD-026 is significantly expanding the items required to meet compliance. Is that because the Transmission Planners are not making it clear to the Generator Owners the data required to be usable? If that is the case, where is the failure, at the Generator Owner for failing to know the Transmission Providers needs or the Transmission Planner for not communicating clearly what is needed in their models to provide good output? What happens when the next forecasts are off due to some data point not being included in the revised standard? Will we have to create another Standard Drafting Team (SDT) to add more required data points to the standard or is there a better way to do business, so the results are not dependent on every minute detail being included in a requirement? If the industry is looking to be able to react to evolving needs, the SDT method is too slow and cumbersome to meet the speed of change. To NERC’s credit, their leadership has identified this as an issue. However, based on some of the recommendations that have come from NERC, it appears that their suggestions look to be prescriptive on how to achieve a goal rather than stating what the goal is and allowing industry to meet it as each entity feels is reasonable.
Ultimately, the electric industry needs to do the right thing without requiring the auditors to check every little item during an audit. Unfortunately, something appears broken in the process at this time. Industry needs to pause these efforts and develop a plan to move forward intelligently.
Cover Photo Credit: Allison McCallister via Patch.com
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