PRC-002-NPCC-01 Retirement Petition

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

)
)

Docket No. _________

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND NORTHEAST
POWER COORDINATING COUNCIL FOR APPROVAL OF RETIREMENT OF
REGIONAL RELIABILITY STANDARD PRC-002-NPCC-01
Edward A. Schwerdt
President and Chief Executive Officer
Kristin McKeown
General Counsel
Northeast Power Coordinating Council, Inc.
1040 Avenue of the Americas, 10th Floor
New York, NY 10018
(212) 840-1070
[email protected]
[email protected]

Charles A. Berardesco
Senior Vice President and General Counsel
Shamai Elstein
Senior 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

June 9, 2016

TABLE OF CONTENTS
NOTICES AND COMMUNICATIONS ................................................................................ 2
BACKGROUND .................................................................................................................... 2
A.

Regulatory Framework ..................................................................................................... 2

B.

Procedural History............................................................................................................ 4
1.
Development and Approval of NPCC Regional Reliability Standard PRC-002NPCC-01 ................................................................................................................................. 4
2.

Approval of Continent-Wide Reliability Standard PRC-002-2 .................................... 6

3.

Summary of PRC-002-NPCC-01 Retirement History.................................................. 7
JUSTIFICATION FOR APPROVAL.................................................................................. 8

A.
PRC-002-NPCC-01 Requirements for Sequence of Events Recording, Fault Recording,
and Equipment Siting are Addressed by the Continent-wide Reliability Standard .................... 9
B.
PRC-002-NPCC-01 Requirements for Dynamic Disturbance Recording are Addressed
by the Continent-wide Reliability Standard .............................................................................. 11
C.
The PRC-002-NPCC-01 Requirement for Time Synchronization is Addressed by the
Continent-wide Reliability Standard......................................................................................... 12
D.
PRC-002-NPCC-01 Requirements for Data Specifications are Addressed by the
Continent-wide Reliability Standard......................................................................................... 13
E.
The PRC-002-NPCC-01 Requirement for Status of Recording Capability is Addressed
by the Continent-wide Reliability Standard .............................................................................. 13
EFFECTIVE DATE ........................................................................................................... 14
CONCLUSION ..................................................................................................................... 15

i

Exhibit A

Order No. 672 Criteria

Exhibit B

Comparison of PRC-002-NPCC-01 Regional Reliability Standard Requirements
to Continent-Wide Reliability Standard PRC-002-2 Requirements

Exhibit C

Complete Record of Retirement Development

ii

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

)
)

Docket No. ________

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND NORTHEAST
POWER COORDINATING COUNCIL FOR APPROVAL OF RETIREMENT OF
REGIONAL RELIABILITY STANDARD PRC-002-NPCC-01
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 2 of
the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”) 3 and the Northeast Power Coordinating
Council, Inc. (“NPCC”) respectfully request that the Commission approve the retirement of
NPCC Regional Reliability Standard PRC-002-NPCC-01 – Disturbance Monitoring and the two
related NPCC regional definitions, Current Zero Time and Generating Plant.
The primary purpose of Regional Reliability Standard PRC-002-NPCC-01 is to ensure
that adequate disturbance data is available to facilitate Bulk Electric System (“BES”) event
analyses. As discussed below, the issues addressed by Regional Reliability Standard PRC-002NPCC-01 are addressed by the recently-approved continent-wide Reliability Standard PRC-0022 – Disturbance Monitoring and Reporting Requirements. Therefore, Regional Reliability
Standard PRC-002-NPCC-01 is now redundant and unnecessary for reliability. The retirement of
the regional standard and related regional definitions will have no adverse effect on the reliability
of the Bulk-Power System and is in the public interest.

1

16 U.S.C. § 824o (2012).

2

18 C.F.R. § 39.5 (2015).

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).

1

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following: 4
Shamai Elstein*
Senior 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]

Edward A. Schwerdt*
President and Chief Executive Officer
Kristin McKeown*
General Counsel
Northeast Power Coordinating Council, Inc.
1040 Avenue of the Americas, 10th Floor
New York, NY 10018
(212) 840-1070
[email protected]
[email protected]

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005, 5 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) 6 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) 7 of the FPA authorizes
the Commission to order the ERO to submit a new or modified Reliability Standard. Section
39.5(a) 8 of the Commission’s regulations requires the ERO to file with the Commission for its

4

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, to allow the inclusion of more
than two persons on the service list in this proceeding.

5

16 U.S.C. § 824o.

6

Id. § 824o(b)(1).

7

Id. § 824o(d)(5).

8

18 C.F.R. § 39.5(a).

2

approval each Reliability Standard that the ERO proposes should become mandatory and
enforceable in the United States, each modification to a Reliability Standard that the ERO
proposes should be made effective, and each Reliability Standard that the ERO proposes for
retirement.
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 FPA 9 and Section 39.5(c) 10 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.
A Regional Reliability Standard proposed by a Regional Entity must meet the same
standards that NERC’s Reliability Standards must meet; i.e., the Regional Reliability Standard
must be shown to be just, reasonable, not unduly discriminatory or preferential, and in the public
interest. 11 Order No. 672 provides additional criteria that a Regional Reliability Standard must
satisfy. Specifically, a regional difference from a continent-wide Reliability Standard must either
be: (1) more stringent than the continent-wide Reliability Standard (which includes a regional
standard that addresses matters that the continent-wide Reliability Standard does not), or (2)
necessitated by a physical difference in the Bulk-Power System. 12

9

16 U.S.C. § 824o(d)(2).

10

18 C.F.R. § 39.5(c)(1).

11

16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a).

12
Order No. 672, Rules Concerning Certification of the Electric Reliability Organization; and Procedures for
the Establishment, Approval, and Enforcement of Electric Reliability Standards, FERC Stats. & Regs. ¶ 31,204 at P
291, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).

3

NPCC is not a Regional Entity organized on an Interconnection-wide basis. NPCC
Reliability Standards are intended to apply only to that part of the Eastern Interconnection within
the NPCC geographical footprint. NPCC develops Regional Reliability Standards in accordance
with its Regional Standard Processes Manual (“RSPM”). 13 NPCC’s RSPM provides a regional
standard development process that has the following key characteristics: fair due process;
openness; inclusive; balanced; transparent; and conducted without undue delay. Proposed NPCC
Regional Reliability Standards are subject to approval by NERC, as the ERO, and FERC before
becoming mandatory and enforceable under Section 215 of the FPA.
B.

Procedural History

This section provides a discussion of the development and approval of the standard being
proposed for retirement, NPCC Regional Reliability Standard PRC-002-NPCC-01, as well as a
brief discussion of the development and approval of the continent-wide disturbance monitoring
standard, Reliability Standard PRC-002-2. This section concludes with an overview of the
standard development process for the proposed retirement of the regional standard.
1.

Development and Approval of NPCC Regional Reliability Standard PRC002-NPCC-01

The Commission approved Regional Reliability Standard PRC-002-NPCC-01 Disturbance Monitoring in 2011. 14 The standard was developed to ensure that requirements exist
in the NPCC region to ensure adequate disturbance data and equipment are available to facilitate
BES event analyses. In developing the standard, NPCC drew upon previously-developed

13

The NPCC RSPM was approved by the Commission on December 23, 2014 (see N. Am. Elec. Reliability
Corp., RR14-7-000 (Dec. 23, 2014) (unpublished letter order) and is available at
https://www.npcc.org/Standards/Regional%20Standards%20General/NPCC%20Regional%20%20Standard%20Proc
esses%20Manual_FERC_Approved_version_1_20141223.pdf.
14

See N. Am. Elec. Reliability Corp., 137 FERC ¶ 61,043 (2011). In addition to approving NPCC regional
Reliability Standard PRC-002-NPCC-01, the Commission also approved two related NPCC regional terms: Current
Zero Time and Generating Plant.

4

Regional Criteria regarding the placement of disturbance monitoring equipment. 15 The
Commission-approved phased-in implementation plan provided for entities in the NPCC region
to gradually become compliant with the standard’s requirements beginning in 2013, with full
compliance expected since October 2015.
While the regional standard was being developed, efforts were underway at NERC
through Project 2007-11 Disturbance Monitoring to develop a revised continent-wide Reliability
Standard that would establish requirements for the collection and reporting of disturbance data to
facilitate event analysis and verify system models. In Order No. 693, 16 the Commission approved
83 of the 107 Reliability Standards proposed by NERC, including Reliability Standard PRC-0181 - Disturbance Monitoring Equipment Installation and Data Reporting. 17 However, the
Commission declined to take action on certain proposed “fill-in-the-blank” Reliability Standards,
including Reliability Standard PRC-002-1 - Define Regional Disturbance Monitoring and

15
See NPCC Document A-15, Disturbance Monitoring Equipment Criteria (adopted Aug. 23, 2007),
available at https://www.npcc.org/Standards/Criteria/A-15.pdf.

The development of Regional Criteria is addressed in Section 313 of the NERC Rules of Procedure. NPCC
Directories are developed in order to provide a consistent and comprehensive set of more stringent and specific
reliability requirements for the NPCC region. NPCC Directories are developed in accordance with the NPCC
Directory Development and Revision Manual, which is available on the NPCC website at:
https://www.npcc.org/Standards/Directories/NPCC%20Directory%20Manual%20RSC%20approved%2020141003.
pdf.
The NPCC Criteria contained within each NPCC Directory apply to NPCC Full Member organizations; however,
compliance with NPCC Criteria is required by other rules and mechanisms, including FERC-approved independent
system operator tariffs, generator interconnection agreements, and New York Public Service Commission approved
rules that adopt the criteria as New York State Reliability Rules. (See Section 215(i)(3) of the FPA (16 U.S.C. §
824o(i)(3), which provides that the State of New York “may establish rules that result in greater reliability within
that State, as long as such action does not result in lesser reliability outside the State than that provided by the
reliability standards.”)
Unlike NPCC Regional Reliability Standards, NPCC Criteria are not subject to NERC or Commission approval and
there are no monetary sanctions for noncompliance. However, NPCC Criteria play an important role in ensuring an
enhanced level of reliability in the NPCC region.
16

Order No. 693, Mandatory Reliability Standards for the Bulk-Power System, FERC Stats. & Regs. ¶ 31,242
(2007), reh’g denied, Order No. 693-A, 120 FERC ¶ 61,053 (2007) (“Order No. 693”).
17

Order No. 693 at PP 1550-51.

5

Reporting Requirements. 18 PRC-002-1, which never became mandatory and enforceable, would
have required regional reliability organizations to establish: (i) installation requirements for
sequence of event recording, fault recording, and dynamic disturbance recording; and (ii)
reporting requirements for recorded disturbance data. NPCC Regional Reliability Standard PRC002-NPCC-01 was intended to establish a standard for disturbance monitoring requirements in
the NPCC region until such time that a revised continent-wide Reliability Standard could be
developed through Project 2007-11.
2.

Approval of Continent-Wide Reliability Standard PRC-002-2

In Order No. 814, the Commission approved the continent-wide Reliability Standard
PRC-002-2 Disturbance Monitoring and Reporting Requirements, which was developed as a part
of Project 2007-11. 19 As stated by the Commission, “Reliability Standard PRC-002-2 enhances
reliability by imposing mandatory requirements concerning the monitoring and reporting of
disturbances” and “provides greater continent-wide consistency regarding collection methods for
data used in the analysis of disturbances on the Bulk-Power System.” 20 Consistent with other
NERC Reliability Standards, the PRC-002-2 Reliability Standard provides a results-based
approach to the capture of data, rather than prescriptive requirements on equipment necessary to
capture the data.

18

See Order No. 693 at P 1455. The term “fill-in-the blank” standards refers to those proposed Reliability
Standards that required supplemental information from regional reliability organizations, such as regional criteria or
procedures, that had not been submitted to the Commission for approval.
19

Order No. 814, Disturbance Monitoring and Reporting Requirements Reliability Standard, 152 FERC ¶
61,198 (2015). In addition, the Commission approved the retirement of PRC-018-1 due to its consolidation with
PRC-002-2 and considered the pending PRC-002-1 Reliability Standard withdrawn.
20

Order No. 814 at P 13.

6

3.

Summary of PRC-002-NPCC-01 Retirement History

Following the NERC Board of Trustees adoption of Reliability Standard PRC-002-2 in
November 2014, NPCC initiated a project to review the NPCC Regional Reliability Standard for
potential revision or retirement. In accordance with NPCC’s RSPM, a Regional Standard
Authorization Request (“RSAR”) to review PRC-002-NPCC-01 was approved by the NPCC
Regional Standards Committee on February 18, 2015 and was posted publicly on February 23,
2015.
The purpose of the RSAR was as follows:
…to review the regional standard for potential revisions made
necessary by the industry’s adoption of the new NERC BES
definition, the Paragraph 81 directive [21], and the development of
NERC’s PRC-002-2 Disturbance Monitoring and Reporting
Requirements standard. Retiring PRC-002-NPCC-01 is to be
considered if it is determined that it can be retired without sacrificing
the ability to capture post-disturbance data. 22
The NPCC Task Force on System Protection, acting as a standard review/drafting team,
performed a comprehensive comparison of Regional Reliability Standard PRC-002-NPCC-01
and the continent-wide Reliability Standard PRC-002-2. This review also included a comparison
of NPCC Document A-15, Disturbance Monitoring Equipment Criteria. 23 Following its review,
the drafting team determined that the continent-wide Reliability Standard would be sufficient to
achieve the reliability objectives of the regional standard and that the regional standard should be
retired. In accordance with the NPCC RSPM, the proposed retirement of PRC-002-NPCC-01
was posted for a 30-day pre-ballot review beginning October 16, 2015, followed by a 10-day

21

See N. Am. Elec. Reliability Corp., 138 FERC ¶ 61,193 (2012) at P 81 (inviting NERC to propose for
revision or retirement Reliability Standards that provide little protection for Bulk-Power System reliability or that
are redundant).

22

See Exhibit C Item 7.

23

See supra n. 15.

7

final ballot beginning November 16, 2015. The proposed retirement achieved a 69% quorum and
97.10% approval and received no negative ballots with comments.
In accordance with Section 312 of NERC’s Rules of Procedure, NERC posted the
proposed retirement of PRC-002-NPCC-01 for a 45-day comment period beginning January 6,
2016. Commenters agreed that NPCC’s process was open, inclusive, balanced, transparent, and
that due process was followed. The NPCC Board of Directors approved the retirement of PRC002-NPCC-01 on March 23, 2016. The NERC Board of Trustees approved the retirement on
May 5, 2016.
JUSTIFICATION FOR APPROVAL
As discussed above, NPCC Regional Reliability Standard PRC-002-NPCC-01 was
intended to establish a standard for disturbance monitoring requirements until such time that a
continent-wide Reliability Standard could be developed with equivalent and adequate
requirements. As also noted above, in 2015, the Commission approved such a Reliability
Standard, PRC-002-2, which will become mandatory and enforceable on July 1, 2016 in
accordance with the Commission-approved implementation plan.
Reliability Standard PRC-002-2 specifies disturbance data requirements for sequence of
event recording (“SER”), fault recording (“FR”), and dynamic Disturbance recording (“DDR”)
and the recording specifications of these devices. The standard is results-based and technology
neutral; it does not specify how to achieve the required disturbance monitoring capability or
prescribe specific types of equipment. By contrast, the NPCC regional Reliability Standard
specifies the equipment and identifies locations to achieve the adequate level of disturbance
monitoring capability on the BES. The NPCC drafting team determined that the capability to
capture the necessary disturbance monitoring data was the necessary component to protect
reliability, not the specific equipment required for the capability.
8

Following a comprehensive review and comparison of the regional and the continentwide Reliability Standards, the results of which are discussed more fully below and in Exhibit B,
it was determined that the continent-wide Reliability Standard PRC-002-2 would ensure that the
capabilities and availability of disturbance monitoring data are adequate to efficiently and
effectively perform event analysis. NPCC’s more stringent criteria (currently set forth in
Document A-15, Disturbance Monitoring Equipment Criteria) would continue to apply to NPCC
Full Members and those with other legal obligations to adhere to the criteria until superseded by
an additional or revised NPCC Directory or alternately, made unnecessary by future Reliability
Standard revisions. In light of the above, NERC and NPCC submit that NPCC Regional
Reliability Standard PRC-002-NPCC-01 is redundant and no longer necessary for reliability.
NERC and NPCC respectfully request that the Commission approve its retirement.
NERC and NPCC also request that the Commission approve the retirement of the related
NPCC regional definitions, Current Zero Time and Generating Plant. These terms are used only
within the regional standard that is proposed for retirement, and there is no reliability need to
maintain the definitions with the standard being retired. Their retirement would present no risk to
reliability and is in the public interest.
A.

PRC-002-NPCC-01 Requirements for Sequence of Events Recording, Fault
Recording, and Equipment Siting are Addressed by the Continent-wide
Reliability Standard

NPCC Regional Reliability Standard PRC-002-NPCC-01 contains detailed requirements
that specify the locations at which disturbance monitoring data is to be captured. Requirement
R1 specifies that Transmission Owners and Generator Owners provide SER capabilities, either
by installing sequence of event recorders or as part of another device, at specified locations.
Requirement R2 specifies that each Transmission Owner must provide FR capability at certain
specified locations where fault recording equipment is required to be installed. Requirement R3
9

specifies that this FR capability must calculate Current Zero Time for loss of BES transmission
Elements. 24 Requirement R4 requires each Generator Owner to provide FR capabilities at certain
specified Generating Plants. 25 Requirements R5 and R6 specify the data that must be recorded
and the recording specifications for that data, such as minimum recording rate and minimum
trigger settings. 26
Although the approaches of NPCC Regional Reliability Standard PRC-002-NPCC-01
and the continent-wide Reliability Standard PRC-002-2 differ, the requirements of Reliability
Standard PRC-002-2 cover the same reliability objectives as the regional standard and are
sufficient to ensure that adequate SER and FR data is available to conduct event analysis.
Reliability Standard PRC-002-2 Requirement R1 requires Transmission Owners to identify BES
buses for which SER and FR data is required, notify other owners of BES Elements connected to
those particular BES buses where SER and FR data will be necessary, and to re-evaluate all BES
buses at least every five calendar years. Attachment 1 to the standard provides the methodology
for selecting buses for capturing SER and FR data. Requirement R2 requires Transmission
Owners and Generator Owners to collect SER data for circuit breaker position at specified circuit
breakers. Requirement R3 specifies that Transmission Owners and Generation Owners must
have FR data to determine certain electrical quantities for each triggered FR, and Requirement
R4 specifies the parameters of such data, such as minimum recording rate and cycles to be

24

Current Zero Time is an NPCC regional definition and is defined as “the time of the final current zero on
the last phase to interrupt.”

25

Generating Plant is an NPCC regional definition and is defined as “one or more generators at a single
physical location whereby any single contingency can affect all the generators at that location.”

26

In addition, PRC-002-NPCC-01 Requirement R17 provides that each Reliability Coordinator, Transmission
Owner, and Generator Owner shall maintain and provide to the Regional Entity upon request certain data on
disturbance monitoring equipment installed to meet the standard. A similar requirement is contained in currentlyeffective Reliability Standard PRC-018-1 Requirement R3. Such a requirement is not reflected in the approved but
not yet effective Reliability Standard PRC-002-2 as PRC-002-2 contains requirements for recorded data and not
equipment.

10

recorded. Because the continent-wide Reliability Standard will ensure that sufficient SER and
FR data are collected, the NPCC Regional Reliability Standard requirements may be retired with
no adverse effect on reliability.
B.

PRC-002-NPCC-01 Requirements for Dynamic Disturbance Recording are
Addressed by the Continent-wide Reliability Standard

NPCC Regional Reliability Standard PRC-002-NPCC-01 contains detailed requirements
for capturing DDR data. PRC-002-NPCC-01 Requirement R7 provides that each Reliability
Coordinator must establish its areas needs for DDR. Requirement R8 provides for each
Reliability Coordinator to specify that DDR devices installed after the approval of the standard
function as continuous recorders, and Requirement R9 specifies settings for DDR devices,
including minimal recording duration, minimum sample rate, and triggers. Requirement R10
provides that each Reliability Coordinator shall establish requirements such that certain
quantities are monitored or derived where DDR devices are installed, and Requirement R11
provides that each Reliability Coordinator shall document these monitored quantities as well as
any additional settings or deviations from those specified in Requirement R9 and provide to the
Regional Entity upon request. Requirement R12 provides that each Reliability Coordinator shall
specify its DDR requirements to Transmission Owners and Generator Owners, and Requirement
R13 provides that each Transmission Owner and Generator Owner shall install DDR capabilities
as requested by the Reliability Coordinator.
The regional standard requirements will become redundant and unnecessary when
continent-wide Reliability Standard PRC-002-2, which contains requirements for the capture of
DDR data, becomes mandatory and enforceable. PRC-002-2 Requirement R5 provides that

11

Responsible Entities 27 shall: (i) identify the BES Elements for which DDR data is required,
including those meeting certain criteria set out in Part 5.1; (ii) identify minimum DDR coverage;
(iii) provide notifications to owners of the identified BES Elements; and (iv) re-evaluate all BES
Elements at least once every five years. Requirements R6 and R7 require each Transmission
Owner and Generator Owner, respectively, to have DDR data sufficient to determine certain
specified electrical qualities for each BES Element that it owns and for which it has received
notification under Requirement R5. Requirement R8 specifies that each Transmission Owner and
Generator Owner responsible for DDR data shall have continuous recording and storage or else
meet certain requirements for triggered data. Requirement R9 specifies that the DDR data shall
meet a minimum input sampling rate and minimum output recording rate.
The requirements of the continent-wide Reliability Standard are designed to ensure that
adequate wide-area DDR data is available to facilitate accurate and efficient disturbance
analysis. The DDR requirements of the NPCC Regional Reliability Standard will be made
redundant with those requirements and should be retired.
C.

The PRC-002-NPCC-01 Requirement for Time Synchronization is
Addressed by the Continent-wide Reliability Standard

NPCC Regional Reliability Standard PRC-002-NPCC-01 contains requirements for
Transmission Owners and Generator Owners to time-synchronize data. 28 PRC-002-NPCC-01
Requirement R14 Part 14.4 provides that each Transmission Owner and Generator Owner shall
establish a maintenance and testing program for stand-alone disturbance monitoring equipment

27

Reliability Standard PRC-002-2 Section 4 Applicability defines “Responsible Entities” as the Planning
Coordinator, Reliability Coordinator, or Planning Coordinator or Reliability Coordinator, depending on the
Interconnection.
28

Recommendation 28 of the 2003 blackout report recommended requiring use of time-synchronized data
recorders. See U.S.-Canada Power System Outage Task Force, Final Report on the August 14, 2003 Blackout in the
United States and Canada: Causes and Recommendations at 162 (Apr. 2004), available at
http://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/BlackoutFinal-Web.pdf.

12

that includes performing monthly verification of time synchronization. Because time
synchronization is also addressed in the continent-wide disturbance monitoring Reliability
Standard, the regional standard can be retired with no adverse effect on reliability. Specifically,
currently-effective Reliability Standard PRC-018-1 Requirement R1 provides that disturbance
monitoring equipment have internal clocks that are time-synchronized to within 2 milliseconds
or less of Coordinated Universal Time (“UTC”). Commission-approved Reliability Standard
PRC-002-2 Requirement R10 specifies time synchronization for SER, FR, and DDR data. 29
D.

PRC-002-NPCC-01 Requirements for Data Specifications are Addressed by
the Continent-wide Reliability Standard

NPCC Regional Reliability Standard PRC-002-NPCC-01 provides requirements for data
sharing (Requirement R15) and data format and naming (Requirement R16). Data retrieval,
sharing, and detailed data format specifications are specified in Reliability Standard PRC-002-2
Requirement R11. (Data retrieval and sharing requirements are also addressed in currentlyeffective Reliability Standard PRC-018-1 Requirements R1, R4, and R5.) As these continentwide data specification requirements provide that entities are to provide disturbance monitoring
data upon request and establish specific guidelines to ensure the usefulness of the data in
analyzing events, the NPCC Regional Reliability Standard requirements for data specifications
may be retired with no adverse effect on reliability.
E.

29

The PRC-002-NPCC-01 Requirement for Status of Recording Capability is

Specifically, PRC-002-2 Requirement R10 provides as follows:
R10. Each Transmission Owner and Generator Owner shall time synchronize all
SER and FR data for the BES buses identified in Requirement R1 and DDR data
for the BES Elements identified in Requirement R5 to meet the following:
[Violation Risk Factor: Lower] [Time Horizon: Long-term Planning]
10.1 Synchronization to Coordinated Universal Time (UTC) with or without
a local time offset.
10.2 Synchronized device clock accuracy within ± 2 milliseconds of UTC.

13

Addressed by the Continent-wide Reliability Standard
The NPCC Regional Reliability Standard requirement for status of recording capability is
addressed in the continent-wide Reliability Standard and may be retired with no adverse effect
on reliability. NPCC Regional Reliability Standard PRC-002-NPCC-01 Requirement R14
requires each Transmission Owner and Generator Owner to establish a maintenance and testing
program for stand-alone disturbance monitoring equipment that includes, among other things,
requirements for restoring failed units back to service within 90 days or keeping records of
efforts to return to service if kept out of service for longer than 90 days. Reliability Standard
PRC-002-2 Requirement R12 requires Transmission Owners and Generator Owners to either
restore failed SER, FR, or DDR data recording capability within 90 days or implement a
Corrective Action Plan that it submits to its Regional Entity. 30
EFFECTIVE DATE
NERC and NPCC respectfully request that the Commission approve the retirement of
NPCC Regional Reliability Standard PRC-002-NPCC-01 and the related NPCC regional
definitions of Current Zero Time and Generating Plant to be effective as of July 1, 2016. This
would align the retirement of PRC-002-NPCC-01 with the effective date for Reliability Standard
PRC-002-2. Entities in the NPCC region have been required to be fully compliant with PRC002-NPCC-01 since October 2015. NERC and NPCC’s proposal to align the effective dates
would allow entities in the NPCC Region to efficiently transition from compliance with the
NPCC Regional Reliability Standard to compliance with the continent-wide Reliability Standard.

30
Currently-effective Reliability Standard PRC-018-1 Requirement R6 requires each Transmission Owner
and Generator Owner required to have disturbance monitoring equipment to have a maintenance and testing
program for that equipment.

14

CONCLUSION
For the reasons set forth above, NERC and NPCC respectfully request that the
Commission approve the proposed retirement of Regional Reliability Standard PRC-002-NPCC01 and the NPCC regional definitions Current Zero Time and Generating Plant, effective as
proposed herein.

Respectfully submitted,
/s/ Lauren A. Perotti
Edward A. Schwerdt
President and Chief Executive Officer
Kristin McKeown
General Counsel
Northeast Power Coordinating Council, Inc.
1040 Avenue of the Americas, 10th Floor
New York, NY 10018
(212) 840-1070
[email protected]
[email protected]

Charles Berardesco
Senior Vice President and General Counsel
Shamai Elstein
Senior 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

June 9, 2016

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