NERC Petition (without Exhibits) in RD16-2

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation

)
)

Docket No. _________

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
PRC-005-6
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595– facsimile

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Lauren A. Perotti
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099– facsimile
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

November 13, 2015

I.

TABLE OF CONTENTS
EXECUTIVE SUMMARY .................................................................................................... 3

II.

NOTICES AND COMMUNICATIONS ................................................................................ 6

III.

BACKGROUND ................................................................................................................. 6

A.

Regulatory Framework ..................................................................................................... 6

B.

NERC Reliability Standards Development Procedure ..................................................... 7

C.

History of the PRC-005 Reliability Standard ................................................................... 8
1.

PRC-005-1 .................................................................................................................... 8

2.

PRC-005-2 .................................................................................................................... 9

3.

PRC-005-3 .................................................................................................................... 9

4.

PRC-005-2(i), PRC-005-3(i) ...................................................................................... 10

5.

PRC-005-2(ii) and PRC-005-3(ii) .............................................................................. 10

6.

PRC-005-4 .................................................................................................................. 11

7.

PRC-005-5 .................................................................................................................. 12

D.

Project 2007-17.4 PRC-005 FERC Order No. 803 Directive (PRC-005-6) .................. 14

IV.

JUSTIFICATION FOR APPROVAL ............................................................................... 16

A.

Revisions to Address the Inclusion of Supervisory Devices.......................................... 17
1.

Revised Definitions for Use in the Proposed Standard .............................................. 18

2.

Revisions to Tables..................................................................................................... 19

3.

Use of Abbreviation “PSMP” ..................................................................................... 20

B.

Dispersed Generation Resources Applicability Revisions (Section 4.2) ....................... 21

C.

Proposed Implementation Plan....................................................................................... 23

D.
V.
VI.

1.

Proposed PRC-005-6 Implementation Plan................................................................ 23

2.

Retirement of Previous PRC-005 Standards .............................................................. 26
Alternate Proposal to Approve PRC-005-5 .................................................................... 27

ENFORCEABILITY OF THE PROPOSED RELIABILITY STANDARD ....................... 27
CONCLUSION .................................................................................................................. 29

i

Exhibit A

Proposed Reliability Standard PRC-005-6 and Alternative Proposed Standard
PRC-005-5

Exhibit A-1

Proposed Reliability Standard PRC-005-6 (Clean and Redline [PRC-005-6

to PRC-005-4] & [PRC-005-6 to PRC-005-5])
Exhibit A-2

Alternative Proposed Reliability Standard PRC-005-5 (Clean and Redline

[PRC-005-5 to PRC-005-4])
Exhibit B

Implementation Plans

Exhibit B-1a Implementation Plan PRC-005-6
Exhibit B-1b Implementation Plan PRC-005-6 Rationale
Exhibit B-2

Implementation Plan PRC-005-5 (alternative)

Exhibit C

Order No. 672 Criteria

Exhibit D

Draft White Paper, Proposed Revisions to the Applicability of NERC Reliability
Standards to Dispersed Generation Resources

Exhibit E

Supplementary Reference and FAQ

Exhibit F

Consideration of Directives

Exhibit G

Analysis of Violation Risk Factors and Violation Severity Levels

Exhibit H

NERC Planning Committee System Analysis and Modeling Subcommittee
(“SAMS”) and System Protection and Control Subcommittee (“SPCS”),
Considerations for Maintenance and Testing of Autoreclosing Schemes (Nov.
2012)

Exhibit I

Summary of Development and Complete Record of Development

Exhibit J

Standard Drafting Team Rosters

ii

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation

)
)

Docket No. ________

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
PRC-005-6
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”)3 hereby submits for Commission approval
proposed Reliability Standard PRC-005-6 (Protection System, Automatic Reclosing, and Sudden
Pressure Relaying Maintenance). Proposed Reliability Standard PRC-005-6 incorporates the
modification in PRC-005-5, which was approved by the NERC Board of Trustees to carry
forward a clarification made to the applicability of PRC-005 to dispersed power producing
resources (also called dispersed generation resources). Proposed Reliability Standard PRC-005-6
further revises the PRC-005 standard, including the standard-only definition of Automatic
Reclosing used therein, to address the Commission’s directive in Order No. 803 to “develop
modifications to Reliability Standard PRC-005-3 to include supervisory devices associated with
autoreclosing relay schemes to which the Reliability Standard applies.”4

1

16 U.S.C. § 824o (2012).
18 C.F.R. § 39.5 (2014).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Amer. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
4
Protection System Maintenance Reliability Standard, Order No. 803, 150 FERC 61,039 at P 31 (2015)
(“Order No. 803”).
2

1

NERC requests that the Commission approve proposed Reliability Standard PRC-005-6
(Exhibit A-1) and find that it is just, reasonable, not unduly discriminatory or preferential, and in
the public interest.5 NERC also requests approval of the retirement of previous Reliability
Standard PRC-005 standard versions as detailed in the implementation plan associated with
proposed PRC-005-6 (Exhibit B-1a). As discussed below, the proposed PRC-005-6
implementation plan is intended to facilitate an orderly and efficient transition from currentlyeffective PRC-005-2(i) to proposed PRC-005-6 and represents a significant improvement over
the previous implementation approach for these standards. To allow for this orderly transition,
NERC has filed, simultaneously with this petition, a Motion to Delay Implementation of the
approved, but not yet effective versions of the PRC-005 Reliability Standards in Docket Nos.
RM14-8-000 (PRC-005-3), RD15-3-000 (PRC-005-3(i)), and RM15-9-000 (PRC-005-4) until
after the Commission issues an order or rule regarding proposed PRC-005-6 and the proposed
implementation plan.
As proposed Reliability Standard PRC-005-6 reflects the dispersed generation
applicability resources revisions approved by the NERC Board of Trustees in PRC-005-5 and is
intended to supersede PRC-005-5, the Commission need not independently approve proposed
PRC-005-5. Should the Commission decline to approve proposed PRC-005-6 or its associated
implementation plan, however, NERC respectfully requests that the Commission approve PRC005-5 (Exhibit A-2) and its associated implementation plan (Exhibit B-2). This approval will
ensure that the PRC-005 standard continues to be applied appropriately to dispersed generation

5
Unless otherwise designated, capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards (“NERC Glossary of Terms”), available at
http://www.nerc.com/files/Glossary_of_Terms.pdf.

2

resources while NERC addresses any of the Commission’s concerns regarding proposed PRC005-6.
As required by Section 39.5(a)6 of the Commission’s regulations, this petition presents
the technical basis and purpose of the proposed Reliability Standard, a demonstration that the
proposed Reliability Standard meets the criteria identified by the Commission in Order No. 6727
(Exhibit C), and a summary of the standard development history (Exhibit I).
I.

EXECUTIVE SUMMARY
The PRC-005 Reliability Standard helps ensure that entities have a program for the

maintenance of their applicable Protection Systems, Automatic Reclosing, and Sudden Pressure
Relaying so that they are kept in working order. The standard has been revised several times
since its initial approval in Order No. 6938 to incorporate interpretations, clarify applicability,
and respond to Commission directives. Following a restructuring of the standard in PRC-005-2, a
number of versions have been developed, including currently-effective PRC-005-2(i),
Commission-approved but not yet effective versions PRC-005-3, PRC-005-3(i), and PRC-005-4,
and pending versions PRC-005-2(ii) and PRC-005-3(ii).
In this petition, NERC proposes additional modifications that improve upon the most
recent Commission-approved version, PRC-005-4, in two respects.9 First, proposed Reliability
Standard PRC-005-6 revises the standard to include supervisory devices and functions associated
6

18 C.F.R. § 39.5(a) (2012).
The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, at P 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).
8
Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, FERC Stats. & Regs. ¶ 31,242
(“Order No. 693”), order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).
9
Reliability Standard PRC-005-4 was approved by the Commission in Docket No. RM15-9-000. See
Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance Reliability Standard, Order
No. 813, 152 FERC ¶ 61,199 (2015) (“Order No. 813”).
7

3

with applicable autoreclosing relay schemes. Reliability is improved by extending the protections
of a strong Protection System Maintenance Program to these devices consistent with Order No.
803.10
Second, proposed Reliability Standard PRC-005-6 includes a revision to the PRC-005
standard that was included in prior versions of the standard but, as explained further below, was
not carried forward to PRC-005-4 due to the timing of the development of that version.
Specifically, proposed Reliability Standard PRC-005-6 includes Commission-approved revisions
addressing the applicability of PRC-005 to owners of dispersed generation resources.11 As
explained in greater detail below, these revisions reflect the determination of the standard
drafting team for Project 2014-01 Standards Applicability for Dispersed Generation Resources
that while the components of dispersed power generation, such as individual wind or solar units,
often do not pose a significant risk to the reliability of the Bulk-Power System when evaluated
individually, reliability could be improved by ensuring the equipment utilized to aggregate these
individual units to a common point of interconnection with the Bulk-Power System is operated
and maintained as required by the PRC-005 Reliability Standard.12
Additionally, as there are now multiple versions of the PRC-005 Reliability Standard
pending enforcement or Commission approval, the implementation plan for proposed PRC-005-6

10

Order No. 803 at P 31.
See Letter Order, N. Am. Elec. Reliability Corp., 151 FERC ¶ 61,186 (2015) (approving Reliability
Standards PRC-005-2(i), PRC-005-3(i), and certain other Reliability Standards containing revisions to address
applicability to owners of dispersed generation resources.). As discussed more fully herein, at the same time the
Project 2014-01 Standards Applicability for Dispersed Generation Resources standard drafting team was developing
PRC-005-2(i) and PRC-005-3(i) to clarify the applicability of the PRC-005 standard to dispersed generation
resources, a separate standard drafting team was developing PRC-005-4 to address the inclusion of Sudden Pressure
Relaying. After both sets of revisions were approved by their respective ballot pools and the NERC Board of
Trustees, the Project 2014-01 standard drafting team initiated revisions to PRC-005-4 to ensure that the PRC-005
standard would be applied consistently to dispersed generation resources going forward.
12
As described below, these revisions to PRC-005-4 were approved by the NERC Board of Trustees as PRC005-5. Proposed Reliability Standard PRC-005-6 incorporates these revisions without further modification.
11

4

is designed to assist registered entities and the ERO Enterprise in their transition efforts by
simplifying and streamlining the implementation approach for all of the newly-applicable
systems introduced in the versions of PRC-005 not yet in effect. As discussed below, the
proposed implementation plan retains the reasonable, phased-in implementation approach of past
plans, which require registered entities to gradually ensure compliance of a percentage of their
devices until they reach 100% compliance. However, NERC proposes to replace the patchwork
implementation of requirements for the systems introduced by each successive PRC-005 version
with an implementation plan that aligns compliance dates for all newly applicable systems.
Aligning the dates by which registered entities must be compliant for all newly applicable
systems necessitates a slight delay from the staggered timeframe contemplated by previous PRC005 implementation plans. However, the proposed approach advances reliability by: (1) allowing
entities sufficient time to develop comprehensive Protection System Maintenance Programs to
address all new applicable systems, thereby decreasing the number of opportunities for
misidentified and missed devices across successive program revisions and across multiple
compliance schedules; (2) promoting the efficient use of entity and ERO Enterprise resources by
eliminating the need to create and audit multiple, successive revisions to entity Protection
System Maintenance Programs; and (3) providing NERC additional time to provide additional
education and outreach to industry regarding the implementation of this important Reliability
Standard.

5

II.

NOTICES AND COMMUNICATIONS

Notices and communications with respect to this filing may be addressed to the following:13
Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Associate General Counsel
Lauren A. Perotti*
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099– facsimile
[email protected]
[email protected]
[email protected]

III.

Howard Gugel
Director of Standards
North American Electric Reliability Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
[email protected]

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005,14 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Bulk-Power System,
and with the duties of certifying an ERO that would be charged with developing and enforcing
mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)15 of the
FPA states that all users, owners, and operators of the Bulk-Power System in the United States
will be subject to Commission-approved Reliability Standards. Section 215(d)(5)16 of the FPA
authorizes the Commission to order the ERO to submit a new or modified Reliability Standard.

13

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2012), to allow the inclusion
of more than two persons on the service list in this proceeding.
14
16 U.S.C. § 824o (2012).
15
Id. § 824o(b)(1).
16
Id. § 824o(d)(5).

6

Section 39.5(a)17 of the Commission’s regulations requires the ERO to file with the Commission
for its approval each Reliability Standard that the ERO proposes should become mandatory and
enforceable in the United States, and each modification to a Reliability Standard that the ERO
proposes should be made effective.
The Commission is vested with the regulatory responsibility to approve Reliability
Standards that protect the reliability of the Bulk-Power System and to ensure that Reliability
Standards are just, reasonable, not unduly discriminatory or preferential, and in the public
interest. Pursuant to Section 215(d)(2) of the FPA18 and Section 39.5(c)19 of the Commission’s
regulations, the Commission will give due weight to the technical expertise of the ERO with
respect to the content of a Reliability Standard.
B.

NERC Reliability Standards Development Procedure

The proposed Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process.20 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual.21
In its order certifying NERC as the Commission’s ERO, the Commission found that
NERC’s proposed rules provide for reasonable notice and opportunity for public comment, due
process, openness, and a balance of interests in developing Reliability Standards and thus satisfy

17

18 C.F.R. § 39.5(a) (2015).
16 U.S.C. § 824o(d)(2).
19
18 C.F.R. § 39.5(c)(1).
20
Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
21
The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.
18

7

the criteria for approving Reliability Standards.22 The development process is open to any person
or entity with a legitimate interest in the reliability of the Bulk-Power System. NERC considers
the comments of all stakeholders, and a vote of stakeholders and the NERC Board of Trustees is
required to approve a Reliability Standard before the Reliability Standard is submitted to the
Commission for approval.
C.

History of the PRC-005 Reliability Standard

The PRC-005 Reliability Standard has been revised several times since its initial approval
in Order No. 69323 to incorporate interpretations, clarify applicability, and respond to
Commission directives. NERC provides a brief history of the PRC-005 standard below.
1.

PRC-005-1

In Order No. 693, the Commission approved initial versions of four protection system
maintenance and load-shedding-related maintenance standards: Reliability Standards PRC-0051, PRC-008-0, PRC-011-0, and PRC-017-0.24 The Commission approved interpretations PRC005-1a on September 26, 201125 and PRC-005-1b on February 3, 2012.26 On September 19,
2013, the Commission approved PRC-005-1.1b, which clarified the standard’s applicability to
protection systems associated with generator interconnection facilities.27

22

116 FERC ¶ 61,062 at P 250 (2006).
Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, FERC Stats. & Regs. ¶ 31,242
(“Order No. 693”), order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).
24
Order No. 693 at P 1474, 1492, 1514, and 1546.
25
North American Electric Reliability Corp., 136 FERC ¶ 61,208 (2011).
26
Interpretation of Protection System Reliability Standard, Order No. 758, 138 FERC ¶ 61,094 (2012)
(“Order No. 758”).
27
Generator Requirements at the Transmission Interface, Order No. 785, 144 FERC ¶ 61,221 (2013).
23

8

2.

PRC-005-2

The Commission approved PRC-005-2 on December 19, 2013.28 PRC-005-2 combined
four standards that addressed maintenance and testing of protection and control systems (PRC005-1b, PRC-008-0, PRC-011-0, and PRC-017-0) into one comprehensive Reliability Standard.
Consistent with certain directives from Order No. 693, PRC-005-2 included specific minimum
maintenance activities and maximum time intervals for testing Protection System components.
PRC-005-2 also established criteria for developing and maintaining a performance-based
maintenance program.
The PRC-005-2 implementation plan required entities to develop a PRC-005-2-compliant
Protection System Maintenance Program for its applicable Protection Systems by April 1, 2015.
However, the PRC-005-2 implementation plan established a phased compliance schedule for
allowing entities to transition their maintenance activities for Protection System components to
PRC-005-2 over time.
3.

PRC-005-3

The Commission approved PRC-005-3 on January 22, 2015 in Order No. 803.29 PRC005-3 revised PRC-005-2 to require applicable entities to test and maintain certain autoreclosing
relays as part of their Protection System Maintenance Programs.30 In Order No. 803, the
Commission also directed further revisions to the PRC-005 Reliability Standard which are, in
part, the subject of this petition.

28

Protection System Maintenance Reliability Standard, Order No. 793, 145 FERC ¶ 61,253 (2013) (“Order
No. 793”).
29
Order No. 803 at P 17.
30
In Order No. 758, the Commission directed NERC to “include maintenance and testing of reclosing relays
that can affect the reliable operation of the Bulk-Power System” within its PRC-005 standard revision efforts. Order
No. 758 at P 27.

9

NERC carried forward the phased implementation approach of PRC-005-2 in the PRC005-3 implementation plan, adding new provisions to address the addition of Automatic
Reclosing Components. Under this plan, applicable entities continue to calculate their
compliance dates for Protection System Components based on the regulatory approval date of
PRC-005-2, but calculate their compliance dates for Automatic Reclosing Components based on
the regulatory approval date of PRC-005-3.
4.

PRC-005-2(i), PRC-005-3(i)

On May 29, 2015, the Commission approved PRC-005-2(i) and PRC-005-3(i), which
revised PRC-005-2 and PRC-005-3 to address applicability to dispersed power producing
resources.31 Under the PRC-005-2(i) implementation plan, PRC-005-2(i) immediately became
mandatory and enforceable and is the currently-effective version of the PRC-005 standard.
Under its implementation plan, PRC-005-3(i) is to become effective the first day following the
effective date of PRC-005-3.
The implementation plans for PRC-005-2(i) and PRC-005-3(i) incorporated by reference
the phased implementation plans of PRC-005-2 and PRC-005-3 respectively, which are
described above.
5.

PRC-005-2(ii) and PRC-005-3(ii)

On February 3, 2015, NERC submitted a petition seeking approval of proposed PRC005-2(ii) and PRC-005-3(ii). The proposed standards, which were developed as part of a broader
effort to develop a clearer, more detailed definition of “Remedial Action Scheme,” replace the

31

Letter Order, N. Am. Elec. Reliability Corp., 151 FERC ¶ 61,186 (2015).

10

term “Special Protection System” with “Remedial Action Scheme” where it appears in PRC005.32 This petition is pending.
The implementation of these proposed versions is addressed in the proposed Remedial
Action Scheme implementation plan. Under this plan, the proposed versions would become
effective the first day of the first calendar quarter that is 12 months after regulatory approval, if
not already retired by an implementation plan for a successor version.
6.

PRC-005-4

The Commission approved PRC-005-4 in Order No. 813 issued September 17, 2015.33
PRC-005-4 revised PRC-005-3 to require applicable entities to maintain certain sudden pressure
relays that can affect the reliable operation of the Bulk-Power System as part of their Protection
System Maintenance Programs.34
While PRC-005-4 was in development, a separate standard drafting team was developing
revisions to versions 2 and 3 of the standard to address applicability to dispersed power
producing resources (PRC-005-2(i) and PRC-005-3(i)). However, due to the timing of the
various ballot and comment periods and approvals, PRC-005-4 did not reflect the applicability
revisions that were ultimately reflected in PRC-005-2(i) and PRC-005-3(i).35 Both PRC-005-4
and PRC-005-2(i)/-3(i) were adopted by the NERC Board of Trustees on November 13, 2014
and filed with Commission for approval soon after. Development then began on PRC-005-5,

32

Petition of the North American Electric Reliability Corporation for Approval of Revisions to the Definition
of “Remedial Action Scheme” and Proposed Reliability Standards, Docket No. RM15-13-000 (Feb. 3, 2015).
33
See supra n. 9.
34
PRC-005-4 addressed certain concerns set out by the Commission in Order No. 758 regarding a lack of
maintenance requirements for non-electrical sensing relays (such as sudden pressure relays) that could affect the
reliable operation of the Bulk-Power System. See id. at PP 5 and 22.
35
PRC-005-4 was first posted for comment and ballot from April 17, 2014 – June 3, 2014, and again from
July 30, 2014 – September 12, 2014, with the final ballot in October 2014. PRC-005-2(i) and PRC-005-3(i) were
first posted for comment and ballot from June 12, 2014 through July 29, 2014, with the final ballot from August 27,
2014 – September 5, 2014.

11

discussed below, to revise PRC-005-4 to incorporate the dispersed generation resources
applicability revisions.
In the PRC-005-4 implementation plan, NERC carried forward the phased
implementation approach of previous PRC-005 plans. Pursuant to the PRC-005-4
implementation plan, PRC-005-4 will become effective on January 1, 2016. Entities continue to
calculate their compliance dates for Protection System Components and Automatic Reclosing
Components based on the regulatory approval dates of PRC-005-2 and PRC-005-3 respectively,
while compliance dates for Sudden Pressure Relaying Components are based on the regulatory
approval date of PRC-005-4.
7.

PRC-005-5

As discussed above, PRC-005-5 was developed to carry forward the dispersed generation
resources applicability revisions reflected in PRC-005-2(i) and PRC-005-3(i), but not reflected in
PRC-005-4. All three versions were developed through Project 2014-01 Standards Applicability
for Dispersed Generation Resources. A brief history of this project and a brief summary of the
design and operational characteristics of dispersed generation resources are provided below for
reference. For additional information regarding this project and revisions developed to other
Reliability Standards as part of this project, please refer to Docket No. RD15-3-000.
a)

History of Project 2014-01

Project 2014-01 Standards Applicability for Dispersed Generation Resources was
initiated in response to industry request and designed to ensure that the Generator Owners and
Generator Operators of dispersed generation resources are appropriately assigned responsibility
for performance in NERC Reliability Standard requirements that impact the reliability of the
Bulk-Power System, given the unique operating characteristics of these resources. The goal of
Project 2014-01 was to review and revise the applicability of all of the Generator Owner- and
12

Generator Operator-related Reliability Standards and ensure that only those dispersed generation
resources that could affect the reliability of the Bulk-Power System are subject to applicable
Reliability Standards.
To ensure continuity, Project 2014-01 initiated applicability revisions in three versions of
the PRC-005 Reliability Standard. The Commission approved PRC-005-2(i) and PRC-005-3(i),
which revised the applicability of PRC-005-2 and PRC-005-3 respectively, in Docket No. RD153-000.36 The Project 2014-01 standard drafting team also developed PRC-005-5 to ensure that
the PRC-005 standard would continue to be applied appropriately to dispersed generation
resources. PRC-005-5 revised the applicability of PRC-005-4, which was developed concurrently
with PRC-005-2(i) and PRC-005-3(i) in a separate project. The applicability revisions made in
PRC-005-5 were carried through without modification in proposed Reliability Standard PRC005-6.
b)
Design and Operational Characteristics of Dispersed Power
Producing Resources
As discussed further in Docket No. RD15-3-000 and the DGR White Paper,37 the Project
2014-01 standard drafting team concluded that the design and operational characteristics of
dispersed power producing resources are different than traditional generation. Dispersed power
producing resources are typically comprised of many individual generating units and in most
cases, the units are similar in design and produced by the same manufacturer. The equipment is
often geographically dispersed and the generating capacity of individual generating modules can
be as small as a few hundred watts to as large as several megawatts. Dispersed generation
resources interconnected to the transmission system typically have a control system that controls

36

See supra n. 11 and Section III.C.4.
Draft White Paper, Proposed Revisions to the Applicability of NERC Reliability Standards to Dispersed
Generation Resources (“DGR White Paper”), appended hereto as Exhibit D.

37

13

voltage and power output of the aggregate facility. The control system is capable of recognizing
the capability of each individual unit or inverter included in the facility, to appropriately
distribute the volume of generation contribution required of the facility across the available units
or inverters and to recognize and account for the variation of uncontrollable factors that affect
the individual units, such as wind speed and solar irradiance levels. For efficiency, the facilities
are designed to provide the system requirements at the point of interconnection to the
transmission system and not at the individual unit level.38
Based on a consideration of the design and operating characteristics of dispersed
generation resources, the Project 2014-01 standard drafting team determined that the
unavailability or failure of any one individual generating resource may have a negligible impact
on the aggregated capability of the facility, and individual resources have limited effect on the
reliability of the Bulk-Power System. However, as the aggregated capability of the facility may
in some cases contribute to the reliability of the Bulk-Power System, there can be a reliability
benefit from ensuring that the equipment utilized to aggregate the individual units to a common
point of interconnection with the transmission system is operated and maintained as required by
the PRC-005 Reliability Standard.39
D.

Project 2007-17.4 PRC-005 FERC Order No. 803 Directive (PRC-005-6)

As noted above, in Order No. 803, the Commission approved Reliability Standard PRC005-3, which brought certain automatic reclosing devices within the scope of the PRC-005
standard. Automatic reclosing equipment is equipment that provides for automatic reclosing of a
switching device as desired after it has opened under abnormal conditions. In the PRC-005-3

38
39

For this discussion, see id. at Section 3.2.
Id. at Sections 3.2.1, 3.2.3 and 4.10.7.

14

standard, Automatic Reclosing is defined as having the following two Components: reclosing
relay and control circuitry associated with the reclosing relay. In Order No. 803, the Commission
directed NERC to develop modifications to the PRC-005-3 Reliability Standard “to include
supervisory devices associated with autoreclosing relay schemes to which the Reliability
Standard applies.”40 Project 2007-17.4 PRC-005 FERC Order No. 803 Directive was initiated in
response to this directive.
As explained by the Commission in its Notice of Proposed Rulemaking proposing to
approve PRC-005-3, supervisory devices, such as synchronism check or voltage relays,
“essentially ‘supervise’ the actions of an autoreclosing scheme. That is, they allow reclosing for
desirable conditions or block autoreclosing for undesirable conditions.”41 The Commission
expressed concern that the PRC-005-3 standard did not include supervisory devices that may be
critical to the operation of a reclosing scheme.42 Therefore, the Commission proposed to direct
that NERC develop modifications to PRC-005-3 to address the appropriateness of including
supervisory relays under the maintenance and testing provisions of the PRC-005 Reliability
Standard.
In its comments on the PRC-005-3 NOPR, NERC acknowledged the issues cited by the
Commission and suggested modifying PRC-005-3 to include maintenance of supervision
functions for which a failure can result in autoreclosing into a fault and potentially cause

40

Order No. 803 at P 31.
Protection System Maintenance Reliability Standard, Notice of Proposed Rulemaking, 148 FERC ¶ 61,041
at P 28 (2014) (“PRC-005-3 NOPR”) at 30.
42
Id. at P 30 (citing Order No. 758 at P 24). In Order No. 758, the Commission stated, “a misoperating or
miscoordinated reclosing relay may result in the reclosure of a Bulk-Power System element back onto a fault or that
a misoperating or miscoordinated reclosing relay may fail to operate after a fault has been cleared, thus failing to
restore the element to service.” Misoperated or miscoordinated relays, the Commission explained, may result in
damage to the Bulk-Power System, such as excessive shaft torques and winding stresses and exposure of circuit
breakers to systems conditions less than optimal for correct operation.
41

15

generating unit or plant instability. NERC stated that it would support the addition of voltage
supervision, supervisory inputs associated with selective autoreclosing (where used), and
synchronism check supervision in the PRC-005 Reliability Standard.43
In Order No. 803, the Commission adopted its NOPR proposal and directed NERC to
“develop modifications to PRC-005-3 to include supervisory devices associated with
autoreclosing relay schemes to which the Reliability Standard applies.”44 The Commission stated
that it found “acceptable” NERC’s proposal to limit the scope of supervisory devices to those
providing voltage supervision, supervisory inputs associated with selective autoreclosing, and
sync-check relays that are part of a reclosing scheme covered by PRC-005-3.45
The revisions developed in response to this Order No 803 directive are discussed in the
following section.
IV.

JUSTIFICATION FOR APPROVAL
As discussed in Exhibit C and below, proposed Reliability Standard PRC-005-6 satisfies

the Commission’s criteria in Order No. 672, and is just, reasonable, not unduly discriminatory or
preferential, and in the public interest. The purpose of the proposed Reliability Standard is to
document and implement programs for the maintenance of all Protection Systems, Automatic
Reclosing, and Sudden Pressure Relaying affecting the reliability of the Bulk Electric System (or

43

Comments of the North American Electric Reliability Corporation in Response to Notice of Proposed
Rulemaking, Dkt. No. RM14-8-000 (Sep. 29, 2014) at 4. In its comments, NERC explained that it reviewed the
report of the NERC Planning Committee System Analysis and Modeling Subcommittee (“SAMS”) and System
Protection and Control Subcommittee (“SPCS”) titled Considerations for Maintenance and Testing of Autoreclosing
Schemes (“SAMS/SPCS Report”) and consulted with its internal subject matter experts “on which supervisory
devices should be included within NERC’s PRC-005 standard to meet the Commission’s concerns raised in the
NOPR and ensure entities properly maintain the devices in order to minimize the risk of failure.” See id. at n. 4. The
SAMS and SPCS jointly performed a technical study to determine which reclosing relays should be addressed
within PRC-005 and provided advice to the PRC-005-3 standard drafting team regarding appropriate maintenance
intervals and activities for those relays. This report, which was also included as Exhibit D to NERC’s February 14,
2014 petition for approval of PRC-005-3, is appended hereto as Exhibit H for ease of reference.
44
Order No. 803 at P 31.
45
Id.

16

“BES”) so that they are kept in working order. The proposed Reliability Standard enhances
reliability and improves upon prior versions of the standard by: (i) extending the coverage of an
entity’s Protection System Maintenance Program to include supervisory devices and functions
associated with applicable Automatic Reclosing, consistent with Order No. 803; and (ii) ensuring
that owners and operators of dispersed generation resources are appropriately subject to the
requirements of the PRC-005 standard, consistent with prior Commission-approved revisions to
the PRC-005 standard. Proposed Reliability Standard PRC-005-6 adds detailed information
regarding minimum maintenance activities and maximum maintenance intervals for supervisory
devices or functions associated with Automatic Reclosing, extending the benefits of a strong
maintenance program to those Components.
To assist responsible entities in understanding the addition of supervisory devices and
functions to the scope of the standard, the Project 2007-17.4 standard drafting team revised the
Supplementary Reference and FAQ document (Exhibit E) developed concurrently with
proposed PRC-005-6. This revised document will be posted with the proposed PRC-005-6
Reliability Standard following approval.
Provided below is a summary of the proposed revisions, including their technical basis
and a discussion of prior proceedings, and a discussion of the proposed implementation plan.
A.

Revisions to Address the Inclusion of Supervisory Devices

To address the Commission’s Order No. 803 directive, the definition of Automatic
Reclosing in Section 6, Definitions Used in this Standard, has been revised to add supervisory
relays or functions, the associated voltage sensing devices, and the associated control circuitry.
In addition, tables have been revised, and one new table added, to address maintenance activities

17

and testing for Automatic Reclosing with supervisory relays. Other than reflecting the addition of
this new table, no substantive revisions are proposed to the Reliability Standard Requirements.
1.

Revised Definitions for Use in the Proposed Standard

The definition of Automatic Reclosing, which is used only within the PRC-005
Reliability Standard and is not proposed for addition to the Glossary of Terms Used in NERC
Reliability Standards, is revised as follows to address the Commission’s Order No. 803 directive:
6. Definitions Used in this Standard:
Automatic Reclosing – Includes the following Components[46]
•

Reclosing relay

•

Supervisory relay(s) or function(s) – relay(s) or function(s) that perform
voltage and/or sync check functions that enable or disable operation of the
reclosing relay

•

Voltage sensing devices associated with the supervisory relay(s) or
function(s)

•

Control circuitry associated with the reclosing relay or supervisory relay(s)
or function(s)
***

As there are now four specific elements of Automatic Reclosing instead of the previous
two, the standard-only definition of Component Type is revised accordingly. In addition, the
standard-only definition of Countable Event has been updated to refer to a newly-added table.
The analysis in the SAMS/SPCS Report identified that the failure mode of concern is
associated with premature autoreclosing into a fault, which creates the potential for generating
unit or plant instability. This may occur due to a timing failure in the autoreclosing relay or when

46

The definition of Component as used in the proposed PRC-005-5 and PRC-005-6 standards remains
unchanged from the PRC-005-4 Reliability Standard. Component is defined in the PRC-005 standard as follows:
“Any individual discrete piece of equipment included in a Protection System, Automatic Reclosing, or Sudden
Pressure Relaying.”

18

a supervision failure results in autoreclosing into a dead-line with a fault when this closing is not
intended. Autoreclosing into a fault when dead-line closing is not intended could result from
failure of voltage supervision or, when used, failure of a selective autoreclosing input, such as a
protective relay output that blocks autoreclosing following a three-phase fault.47 Therefore, to
address this concern, NERC proposes to add voltage supervision and where used, supervisory
inputs associated with selective reclosing, to the list of Automatic Reclosing Components. This
will bring these devices within the scope of the PRC-005 Reliability Standard in response to the
Commission’s directive.
NERC also proposes to add synchronism check supervision to the list of Automatic
Reclosing Components. A synchronizing or synchronism (“sync”) check relay is a synchronizing
device that produces an output that supervises closure of a circuit breaker between two circuits
whose voltages are within prescribed limits of magnitude and within the prescribed phase angle
for the prescribed time. It may or may not include voltage or speed control. A sync‐check relay
permits the paralleling of two circuits that are within prescribed (usually wider) limits of voltage
magnitude and phase angle for the prescribed time.48 Including such devices within the PRC-005
standard provides a reliability benefit. For example, a sync-check device may prevent reclosing
of a line into a fault that could cause damage to generator equipment. Maintenance of these
devices helps to ensure that they operate correctly in the autoreclosing scheme.
2.

Revisions to Tables

The following PRC-005 Tables are revised to include maintenance activities and intervals
for supervisory relays:

47
48

See SAMS/SPCS Report (Exhibit H) at 5-7.
See Ex. E (Supplementary Reference and FAQ – October 2015) at 8.

19

•

Table 4-1, Maintenance Activities and Intervals for Automatic Reclosing Components
Component Type – Reclosing and Supervisory Relay;

•

Table 4-2(a), Maintenance Activities and Intervals for Automatic Reclosing Components
Component Type – Control Circuitry Associated with Reclosing and Supervisory Relays
that are NOT an Integral Part of an RAS; and

•

Table 4-2(b), Maintenance Activities and Intervals for Automatic Reclosing Components,
Component Type – Control Circuitry Associated with Reclosing and Supervisory Relays
that ARE an Integral Part of an RAS.
In addition, proposed PRC-005-6 adds a new Table 4-3, Maintenance Activities and

Intervals for Automatic Reclosing Components, Component Type – Voltage Sensing Devices
Associated with Supervisory Relays. Table references have been updated throughout the
standard to reflect the addition of Table 4-3.
The Project 2007-17.4 standard drafting team determined that it was appropriate to assign
the same maintenance intervals for the supervisory relays or functions as their associated
automatic reclosing relay. The maintenance activity provisions in these tables for supervisory
relays or functions are similar in nature to those for other protective functions already existing in
the PRC-005 standard.
In addition, a note is added to each of these tables to provide that where Components of
Automatic Reclosing are common to Components listed in another specific PRC-005 table, the
Components only need to be tested once during a distinct maintenance interval. This note was
added to clarify that entities do not need to perform multiple tests on supervisory relays
associated with more than one Component.
3.

Use of Abbreviation “PSMP”

For readability, PRC-005-6 abbreviates Protection System Maintenance Program as
“PSMP” following its first mention in the standard.

20

B.

Dispersed Generation Resources Applicability Revisions (Section 4.2)

Proposed Reliability Standard PRC-005-6 carries forward certain revisions to Section 4,
Applicability that were previously approved by the Commission in PRC-005-2(i) and PRC-0053(i) and by the NERC Board of Trustees in PRC-005-5. These applicability revisions, which
were developed through Project 2014-01 Standards Applicability for Dispersed Generation
Resources based on the findings of the DGR White Paper, are intended to clarify and provide for
consistent application of the standard requirements to Bulk Electric System generator Facilities
included in the Bulk Electric System through Inclusion I4 – Dispersed Power Producing
Resources.
To accomplish this purpose, PRC-005-4 was modified as follows. Section 4.2.5 was
separated, Section 4.2.6 was added, and PRC-005-4 Section 4.2.6 Automatic Reclosing was
renumbered to Section 4.2.7, with its subsections renumbered accordingly.
Sections 4.2.5, 4.2.6, and 4.2.7 of PRC-005-4 are revised as follows:
4. Applicability:
***
4.2. Facilities:
***
4.2.5 Protection Systems and Sudden Pressure Relaying for generator
Facilities that are part of the BES, except for generators identified through
Inclusion I4 of the BES definition, including:[49]
***
4.2.5.1
Protection Systems that act to trip the generator
either directly or via lockout or auxiliary tripping relays.

49

In PRC-005-2(i) and PRC-005-3(i), this section reads, “Protection Systems for the following BES generator
Facilities for generators not identified through Inclusion I4 of the BES definition”. Based on the comments received,
the Project 2014-01 standard drafting team made minor clarification revisions to this section when drafting PRC005-5. The changes do not alter the intent or operation this section.

21

4.2.5.2
Protection Systems and Sudden Pressure Relaying
for generator step-up transformers for generators that are part of the
BES.
4.2.5.3.
Protection Systems and Sudden Pressure Relaying
for transformers connecting aggregated generation, where the
aggregated generation is part of the BES (e.g., transformers
connecting facilities such as wind farms to the BES).
4.2.5.4. 4.2.5.3
Protection Systems and Sudden Pressure
Relaying for station service or excitation transformers connected to
the generator bus of generators which are part of the BES, that act
to trip the generator either directly or via lockout or tripping
auxiliary relays.
4.2.6 Protection Systems and Sudden Pressure Relaying for the following
BES generator Facilities for dispersed power producing resources identified
through Inclusion I4 of the BES definition:
4.2.6.1
Protection Systems and Sudden Pressure Relaying
for Facilities used in aggregating dispersed BES generation from the
point where those resources aggregate to greater than 75 MVA to a
common point of connection at 100kV or above.
4.2.6 4.2.7 Automatic Reclosing, including:
***
As described further in Docket No. RD15-3-000 and the DGR White Paper,50 the Project
2014-01 standard drafting team concluded that maintenance activities on each individual
generating unit at a dispersed generation Facility would not provide any additional reliability
benefits to the Bulk-Power System, but maintenance activities on Facilities where generation
aggregates to 75 MVA or more would. The proposed revisions are consistent with the
Commission-approved revised Bulk Electric System definition and prior revisions made to the
PRC-005 standard as reflected in currently-effective PRC-005-2(i) and approved PRC-005-3(i).

50

See Petition of the North American Electric Reliability Corporation for Approval of Proposed Reliability
Standards PRC-004-2.1(i)a, PRC-004-4, PRC-005-2(i), PRC-005-3(i), and VAR-002-4, Docket No. RD15-3-000
(Feb. 6, 2015) at p. 18-22; see also DGR White Paper at P 4.10.7.

22

C.

Proposed Implementation Plan
1.

Proposed PRC-005-6 Implementation Plan

The proposed PRC-005-6 implementation plan improves upon previous PRC-005
implementation plans by aligning the dates by which entities must be compliant for all newlyapplicable systems. Specifically, the compliance deadlines for the new systems and Components
introduced in PRC-005-3, PRC-005-4, and PRC-005-6 would be measured from the regulatory
approval date of PRC-005-6, instead of the regulatory approval date of the PRC-005 standard
that first brought them in scope. As entities have already begun work to implement protections
for Protection System Components under PRC-005-2 and currently-effective PRC-005-2(i), the
proposed PRC-005-6 implementation plan would continue implementation for those devices in
accordance with the schedule set forth in the PRC-005-2 implementation plan (which is
incorporated by reference in the implementation plan for currently-effective PRC-005-2(i)).
Beginning with PRC-005-2, PRC-005 implementation plans have provided a phased
implementation approach. Depending on the type of device and specific requirement,
implementation is divided into phases, requiring registered entities to gradually ensure
compliance of a percentage of their devices until they reach 100% compliance. In the PRC-005-3
and PRC-005-4 implementation plans, NERC carried forward this phased approach. However,
recognizing that entities would need a reasonable period of time to incorporate Automatic
Reclosing and Sudden Pressure Relaying into their Protection System Maintenance Programs,
these implementation plans also provided a phased approach for compliance based on the date of
regulatory approval for the standard version that brought these systems in scope. To demonstrate,
in the implementation plan for PRC-005-4, entities would be required to calculate their
compliance dates for their Protection System, Automatic Reclosing, and Sudden Pressure

23

Relaying Components from the regulatory approval dates of PRC-005-2, PRC-005-3, and PRC005-4, respectively.
NERC now proposes to include additional in-scope Components in proposed Reliability
Standard PRC-005-6. If the previous implementation approach was continued for PRC-005-6,
registered entities would be required to perform three consecutive updates to their Protection
System Maintenance Programs to address applicable systems and Components added by PRC005-3, PRC-005-4, and proposed PRC-005-6 within a short time frame; depending on dates of
Commission approval, this could potentially be as short as 12-18 months. Updating Protection
System Maintenance Programs is expected to be a time‐consuming task for many entities. This
short period of time for review and identification of all assets subject to the various PRC‐005
versions could lead to errors, omissions, and misidentification of devices. In addition, this
approach would require entities to manage multiple PRC-005 compliance schedules for a number
of years, increasing the potential for confusion and missed devices which could in turn lead to a
decrease in the reliability of the affected devices.
The Project 2007-17.4 standard drafting team determined that a more streamlined
implementation approach was needed to govern implementation of proposed PRC-005-6. As
proposed PRC-005-6 reflects all revisions in prior versions of PRC-005 (PRC-005-2(ii),51 PRC005-3, PRC-005-3(i), PRC-005-3(ii), PRC-005-4, and PRC-005-5), NERC proposes to transition
directly from currently-effective PRC-005-2(i) to proposed PRC-005-6.
To allow entities sufficient time to address all new applicable systems in their Protection
System Maintenance Program revisions, including the supervisory devices introduced in

51

Specifically, proposed Reliability Standard PRC-005-6 – like approved Reliability Standard PRC-005-4 –
uses the defined term “Remedial Action Scheme” instead of the defined term “Special Protection System” that was
used in previous PRC-005 standard versions.

24

proposed PRC-005-6, this approach necessitates a slight delay in implementing requirements for
applicable systems that were introduced in previous PRC-005 versions.52 As a corresponding
change, the revised definition of Protection System Maintenance Program (PSMP), which in its
most recent form was approved for inclusion in the Glossary in Docket No. RM15-9-000 (PRC005-4),53 would become effective when PRC-005-6 becomes effective.
This proposed implementation approach would provide several important benefits that
would justify any delay necessary for its implementation. First, by aligning compliance dates for
all newly-applicable systems, NERC’s proposed PRC-005-6 implementation plan would provide
for the development of comprehensive Protection System Maintenance Programs informed by
the whole of NERC’s PRC-005 efforts to date. These comprehensive programs would be less
likely to contain errors, omissions, and misidentified devices, thereby promoting reliability.
Second, this approach would streamline the PRC-005 compliance date schedules for all new

52

In Order No. 803 approving PRC-005-3, the Commission directed NERC “to obtain, maintain, and make
available to the Commission upon request, one year following the effective date of the standard and on an annual
basis thereafter, data sufficient to analyze the effectiveness of PRC-005-3 . . . .” Under the proposed implementation
plan for PRC-005-6, implementation of requirements for Automatic Reclosing would be governed according to a
new, consolidated implementation timeline. Therefore, NERC respectfully requests that, if the Commission
approves the proposed PRC-005-6 implementation plan, the Commission also clarify that NERC’s Order No. 803
data collection obligations would begin one year following the effective date of PRC-005-6.
53
The approved revised definition of Protection System Maintenance Program revises the currently-effective
definition to provide for Automatic Reclosing and Sudden Pressure Relaying Components. The definition is as
follows:
An ongoing program by which Protection System, Automatic Reclosing, and
Sudden Pressure Relaying Components are kept in working order and proper
operation of malfunctioning Components is restored. A maintenance program
for a specific Component includes one or more of the following activities:
• Verify — Determine that the Component is functioning correctly.
• Monitor — Observe the routine in-service operation of the Component.
• Test — Apply signals to a Component to observe functional performance or
output behavior, or to diagnose problems.
• Inspect — Examine for signs of Component failure, reduced performance or
degradation.
• Calibrate — Adjust the operating threshold or measurement accuracy of a
measuring element to meet the intended performance requirement.

25

systems, decreasing the potential for confusion and missed device testing. Third, by eliminating
the need to create and audit multiple, successive revisions to entity Protection System
Maintenance Programs, this approach would promote the efficient use of both registered entity
and ERO Enterprise resources. Lastly, this approach would allow NERC additional time to
conduct outreach and provide training to registered entities so that they are well aware and
prepared to meet their obligations under this important Reliability Standard, further promoting
reliability.
The proposed PRC-005-6 implementation plan represents a reasonable approach that
balances the urgency in the need to implement these important protections while recognizing the
challenges that multiple, successive program revisions and compliance date schedules may pose
to registered entities.
2.

Retirement of Previous PRC-005 Standards

As NERC proposes transition directly to PRC-005-6 from currently-effective PRC-0052(i), NERC proposes to retire all intermediate PRC-005 standard versions. This includes
currently-effective PRC-005-2(i), Commission-approved but not yet effective versions PRC-0053, PRC-005-3(i), and PRC-005-4, pending versions PRC-005-2(ii) and PRC-005-3(ii), and PRC005-5, which is addressed in this petition. The implementation plan continues to reflect that the
retirement of the legacy Reliability Standards PRC-005-1.1b,54 PRC-008-0, PRC-011-0, and
PRC-017-0 will be based off the regulatory approval date of PRC-005-2.

54

PRC-005-1.1b, which was approved on September 19, 2013 and became mandatory and enforceable on
November 25, 2013, retired the prior-approved version PRC-005-1b referenced in previous PRC-005
implementation plans. Therefore, the proposed PRC-005-6 implementation refers to PRC-005-1.1b.

26

D.

Alternate Proposal to Approve PRC-005-5

As noted above, PRC-005-5 was adopted by the NERC Board of Trustees to carry
forward the dispersed generation resources applicability provisions from currently-effective
PRC-005-2(i) and approved PRC-005-3(i) with only minor clarification revisions. These
revisions, which are incorporated without further modifications in proposed PRC-005-6, are
described in Section IV.B above.
Should the Commission decline to approve proposed PRC-005-6 for reasons specific to
that version of the standard, such as the inclusion of supervisory devices or the proposed
implementation plan, NERC respectfully requests that the Commission approve PRC-005-5
(Exhibit A-2) and the PRC-005-5 implementation plan (Exhibit B-2). The PRC-005-5
implementation plan provides that PRC-005-5 shall become effective the later of: (i) the first day
following the effective date of PRC-005-4; or (ii) the first day following approval by an
applicable governmental authority. Approving PRC-005-5 would ensure that the PRC-005
standard would continue to be applied consistently and appropriately to dispersed generation
resources while NERC is addressing any issues specific to PRC-005-6.
V.

ENFORCEABILITY OF THE PROPOSED RELIABILITY STANDARD
The proposed Reliability Standards contain Violation Risk Factors (“VRFs”) and

Violation Severity Levels (“VSLs”). The VSLs provide guidance on the way that NERC will
enforce the Requirements of the proposed Reliability Standard. The VRFs are one of several
elements used to determine an appropriate sanction when the associated Requirement is violated.
The VRFs assess the impact to reliability of violating a specific Requirement.
The proposed Reliability Standard also includes Measures that support each Requirement
by clearly identifying what is required and how the Requirement will be enforced. These

27

Measures help ensure that the Requirements will be enforced in a clear, consistent, and nonpreferential manner and without prejudice to any party.55
Proposed PRC-005-6 includes corresponding changes, where necessary, to the VRFs and
VSLs to align with the revisions in proposed PRC-005-6. The VRFs and VSLs comport with
NERC and Commission guidelines related to their assignment. A detailed review of the VRFs,
VSLs, and the analysis of how the VRFs and VSLs were determined using these guidelines is
provided in Exhibit G.
Because the Requirements contained in proposed Reliability Standard PRC-005-6 track
with those contained in the previous versions, the Project 2007-17.4 standard drafting team
determined that no revisions were necessary to the VRFs for the proposed Reliability Standard.
NERC, therefore, requests that the Commission approve the VRFs as applied to the supervisory
devices now included in the proposed Reliability Standard as Automatic Reclosing Components.
The VSLs in PRC-005-6 have been revised accordingly to address the supervisory
devices now included in the proposed Reliability Standard as Automatic Reclosing Components
in the levels of severity. The changes are consistent with the approach taken for the VSLs in
Reliability Standard PRC-005-4. The VSLs provide guidance on the way that NERC will enforce
the Requirements of the proposed Reliability Standard for each of the Component Types. The
Measures for proposed PRC-005-6 have been similarly revised.

55

Order No. 672 at P 327 (“There should be a clear criterion or measure of whether an entity is in compliance
with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance so
that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner.”).

28

VI.

CONCLUSION

For the reasons set forth above, NERC respectfully requests that the Commission:
•

approve proposed Reliability Standard PRC-005-6 and associated elements included in
Exhibit A-1;

•

approve the implementation plan included in Exhibit B-1a; and

•

approve the retirement of previous versions of the PRC-005 Reliability Standard as set
forth in the PRC-005-6 implementation plan.

Respectfully submitted,
/s/ Lauren A. Perotti
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Lauren A. Perotti
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099– facsimile
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation
November 13, 2015

29