NERC
Reliability Regime Needs Focus
The system for developing and enforcing mandatory electric reliability standards “is working as well as can be expected, given the relative enormity and complexity of the undertaking,” an NRECA official told regulators. But improvements are needed, he added.
NRECA’s Dave Mohre, seen here in this file photo, said there’s room for improvement in the system for developing and enforcing mandatory electric reliability standards. (Photo By: Luis Gomez)
The model involves “a delicate balance,” noted Dave Mohre, executive director of the association’s energy and power division, at a Federal Energy Regulatory Commission technical conference on reliability monitoring, enforcement and compliance [Docket AD11-1].
At the Nov. 18 session, Mohre joined representatives of investor-owned and municipal utilities, a regional entity and the North American Electric Reliability Corp. on a panel discussing violation processing and penalties.
He said that today’s standards regime balances three elements: standards development by industry stakeholders; standards processing and compliance monitoring, by NERC, the FERC-certified reliability organization; and standards approval by the commission.
The success of the enterprise is demonstrated in part by the FERC-approved mandatory standards already in place, and by an industry that continues to demonstrate its commitment to reliability, Mohre indicated.
However, “This does not mean that we believe the process is perfect or can’t be improved,” and several areas must be addressed, the NRECA official emphasized.
First, he said, violation processing must be streamlined to reduce or eliminate backlogs and ensure sufficient resources are focused on priority issues. Today’s challenges include audits insufficiently focused on priorities, but too much on minor compliance violations and documentation issues, he asserted.
Instead, the focus must be on auditing matters directly tied to preventing cascading failures and long-term equipment damage with enormous economic consequences, Mohre emphasized.
Second, while NERC’s sanction guidelines are appropriate for the current compliance process, they are not the real issue, he said. Rather, “the real issue in compliance enforcement” is the need to simplify the standards requirements and to minimize the number of standards documentation requirements.
Finally, Mohre told the commission, NRECA believes that NERC is doing “a far better job today than in the recent past on the timeliness and usefulness of lessons learned analyses sent to industry.” Critical infrastructure protection-related violations are a possible exception, he added.
If significant reliability improvements are expected, Mohre said, continuing timely transmission of such analyses by NERC is a key.
Tags: Federal Energy Regulatory Commission, North American Electric Reliability Corporation