Academic journal article Energy Law Journal

Report of the System Reliability, Planning, and Security Committee

Academic journal article Energy Law Journal

Report of the System Reliability, Planning, and Security Committee

Article excerpt

This report summarizes developments at the Federal Energy Regulatory Commission related to system reliability, planning, and security of the bulk power system that occurred between July 1, 2018 and June 30, 2019.·

I. Reliability Governance, Structure, and Rules of Procedure

A. Rules of Procedure Filings and Approvals

1. Revisions to Appendix 4E (October 2018)

On October 16, 2018, the North American Electric Reliability Corporation (NERC) filed a petition with the Federal Energy Regulatory Commission (FERC) in Docket No. RR19-1-000 seeking approval of proposed revisions to the hearing procedures (CCCPP-004) and mediation procedures (CCCPP-006) of the Compliance and Certification Committee with Appendix 4E of NERC Rules of Procedure.1 On March 1, 2019, FERC issued a letter order accepting NERC's petition.2

2. Revisions to Compliance Filing (November 2018)

On November 16, 2018, in Docket No. RR17-6-000, NERC submitted a "compliance filing in accordance with the [FERC's] July 19, 2018 Order," which had approved in part and denied in part amendments to NERC Rules of Procedure.3 The compliance filing sought to restore sections 603, 604, and 605, as well as to correct typographical errors in sections 600 and 900, which address personnel certification as well as training and education, respectively.4 On January 25, 2019, FERC issued a letter order accepting NERC's uncontested compliance filing.5

3. Revisions to Appendix 3A (November 2018)

On November 19, 2018, NERC submitted a petition with FERC in Docket No. RR19-2-000 for "approval of proposed revisions to the Standards Processes Manual, Appendix 3A to [] NERC Rules of Procedure."6 The proposed revisions are intended to: (1) "enhance[] processes for field tests to support standards development and for the posting of supporting technical documents"; (2) improve "processes for appeals and interpretations"; (3) provide "language to clarify [existing] standard processes"; and (4) streamline language or punctuation, "and make other necessary updates."7 On March 1, 2019, FERC issued a letter order approving NERC's proposed amendment.8

B. Governance and Structure-Related Filings and Approvals

1. Amendments to NERC Bylaws (September 2018)

On September 25, 2018, in Docket No. RR18-7-000, FERC issued a letter order approving amendments to NERC bylaws.9 NERC proposed the amendments on June 4, 2018.10 The uncontested proposal reduces the day "prior notice requirement for Board of Trustees meetings [to be] held in closed session" from five days to twenty-four hours, which would permit the board "to address matters that may be considered during a closed session" in a timelier manner when necessary.11

2. Registration Transfer of WPSC and UMERC (September 2018)

On September 26, 2018, in Docket No. RR18-11-00, a joint petition was filed by NERC, the Midwest Reliability Organization (MRO) and ReliabilityFirst Corporation (RF) for the approval of the proposed registration transfer of Wisconsin Public Services Corporation (WPSC) and Upper Michigan Energy Resources Corporation (UMERC) from MRO to RF.12 fERC approved the uncontested request through a letter order issued on December 11, 2018.13

3. Dissolution of FRCC Regional Entity (February 2019)

On February 27, 2019, NERC, the Florida Reliability Coordinating Council, Inc. (FRCC) and the SERC Reliability Corporation (SERC) submitted a joint petition for approval in connection with the dissolution of the Florida Reliability Coordinating Council Regional Entity (FRCC RE).14 Later, on May 16, 2019, NERC requested advance funds from its operating contingency reserves to support the dissolution of the FRCC's Regional Entity Division.15 On June 14, 2019, FERC issued a letter order approving NERC's request, as well as obligating NERC to submit an informational report on or before June 1, 2020, documenting whether an advance from NERC's operating contingency reserves was provided to FRCC and in what amount, with supporting information showing how the specific amount advanced was determined and from what sources NERC replenished its operating contingency reserves. …

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