NERC Petition

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 STANDARDS
IRO-018-1 AND TOP-010-1
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
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

May 26, 2016

TABLE OF CONTENTS
EXECUTIVE SUMMARY .................................................................................................... 2
NOTICES AND COMMUNICATIONS ................................................................................ 5
BACKGROUND ................................................................................................................. 5
A.

Regulatory Framework ..................................................................................................... 5

B.

NERC Reliability Standards Development Procedure ..................................................... 6

C.

Commission Directives Relating to Real-time Monitoring and Analysis Capabilities.... 7

D.

Report Recommendations Relating to Real-time Monitoring and Analysis Capabilities 8
1.

The August 2003 Blackout Report and the 2008 RTBP Task Force Report ................ 9

2.

The 2011 Southwest Outage Report ........................................................................... 10

E.

Project 2009-02, Real-time Reliability Monitoring and Analysis Capabilities ............. 11
JUSTIFICATION FOR APPROVAL................................................................................ 14

A.

Overview of Requirements Relating to Real-time Monitoring and Analysis Capabilities
........................................................................................................................................ 15

B.

Proposed Reliability Standard Requirements ................................................................. 18
1.
Requirements to Address Real-time Data Quality Issues: IRO-018-1 R1, TOP-010-1
R1, and TOP-010-1 R2 ......................................................................................................... 18
2.
Requirements to Assess the Quality of Analysis used in Real-time Assessments: IRO018-1 R2 and TOP-010-1 R3 ................................................................................................ 21
3.
R4

C.

D.

Requirements for Alarm Processor Failure Monitoring: IRO-018-1 R3, TOP-010-1
.................................................................................................................................... 22
Consideration of FERC Directives ................................................................................. 23

1.

Order No. 693 P 905 Directive ................................................................................... 23

2.

Order No. 693 P 1660 Directive ................................................................................. 24

3.

Order No. 693 P 1875 Directive ................................................................................. 25
Enforceability of the Proposed Reliability Standards .................................................... 27

EFFECTIVE DATE .............................................................................................................. 30
CONCLUSION .................................................................................................................. 31

i

Exhibit A

Proposed Reliability Standards IRO-018-1 and TOP-010-1

Exhibit B

Implementation Plan

Exhibit C

Order No. 672 Criteria

Exhibit D

Violation Risk Factors and Violation Severity Levels

Exhibit E

Consideration of Directives

Exhibit F

Standard Authorization Request Justification, Project 2009-02 Real-time
Monitoring and Analysis Capabilities

Exhibit G

Reports Considered in Project 2009-02:
Exhibit G-1 August 2003 Blackout Report
Exhibit G-2 2008 NERC Real-time Tools Best Practices Task Force Report
Exhibit G-3 2011 Southwest Outage Report

Exhibit H

Summary of Development and Complete Record of Development

Exhibit I

Standard Drafting Team Roster

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 STANDARDS
IRO-018-1 AND TOP-010-1
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 hereby submits for Commission approval
proposed Reliability Standards IRO-018-1 – Reliability Coordinator Real-time Reliability
Monitoring and Analysis Capabilities and TOP-010-1 – Real-time Reliability Monitoring and
Analysis Capabilities. NERC requests that the Commission approve the proposed Reliability
Standards (Exhibit A) and find that they are just, reasonable, not unduly discriminatory or
preferential, and in the public interest. 4 NERC also requests approval of the associated
implementation plan (Exhibit B) and the associated Violation Risk Factors and Violation
Severity Levels for the proposed standards (Exhibit D).
As required by Section 39.5(a) 5 of the Commission’s regulations, this petition presents
the technical basis and purpose of the proposed Reliability Standards, a demonstration that the

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. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
4
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.
5
18 C.F.R. § 39.5(a) (2012).
2

1

proposed Reliability Standards meet the criteria identified by the Commission in Order No. 672 6
(Exhibit C), and a summary of the standard development history (Exhibit H). The proposed
Reliability Standards were adopted by the NERC Board of Trustees on May 5, 2016.
This Petition is organized as follows: Section I of the Petition presents an executive
summary of the proposed Reliability Standards. Section II of the Petition provides the
individuals to whom notices and communications related to the filing should be provided.
Section III provides background on the regulatory structure governing the Reliability Standards
approval process. This section also provides information on the development of the proposed
Reliability Standards through Project 2009-02, Real-time Reliability Monitoring and Analysis
Capabilities and the Commission directives and report recommendations considered as part of
the scope for this project. Section IV of the Petition provides a detailed discussion of the
proposed Reliability Standards and explains how the proposed standards address report
recommendations and satisfy certain outstanding Commission directives related to Real-time
monitoring and analysis capabilities.
EXECUTIVE SUMMARY
Inadequate situational awareness has been cited as one of the causes of the August 2003
blackout affecting the northeastern United States and Canada and the 2011 blackout affecting the
southwestern United States and Baja, Mexico. Reports prepared following these events have
provided recommendations for new and revised Reliability Standards to enhance Real-time
situational awareness and address the other primary and contributing causes of these events.

6

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).

2

Over the last several years, NERC has addressed many of the recommendations from these
reports. As a result, Reliability Standards affecting the operating reliability of the Bulk Electric
System have improved significantly since first becoming mandatory in 2007. Among other
things, the revised Transmission Operations (“TOP”) and Interconnection Reliability Operations
and Coordination (“IRO”) Reliability Standards approved by the Commission in Order No. 817 7
(referred to herein as the “revised TOP and IRO Reliability Standards”) provide rigorous
functional requirements for Real-time monitoring and analysis.
In reviewing these reports and the Commission’s outstanding directives from Order No.
693, 8 NERC identified further opportunity to enhance reliability and complement the existing
functional requirements for Real-time monitoring and analysis. Specifically, NERC developed
proposed Reliability Standards IRO-018-1 and TOP-010-1 to improve Real-time situational
awareness capabilities and enhance reliable operations by requiring Reliability Coordinators,
Transmission Operators, and Balancing Authorities to provide operators with awareness of
monitoring and analysis capabilities, including alarm availability, so that operators may take
appropriate steps to protect reliability. The proposed standards accomplish this as follows. First,
the proposed standards require applicable entities to provide notification to operators of Realtime monitoring alarm failures. Second, the proposed standards require applicable entities to
implement Operating Processes or Operating Procedures to: (i) provide operators with
indication(s) of the quality of information being provided by their monitoring and analysis
7
Order No. 817, Transmission Operations Reliability Standards and Interconnection Reliability Operations
and Coordination Reliability Standards, 153 FERC ¶ 61,178 (2015) (“Order No. 817”). In Order No. 817, the
Commission approved Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-002-4, IRO-0082, IRO-010-2, IRO-014-3, and IRO-017-1. However, the Commission directed that NERC make certain
modifications to the standards within 18 months of the effective date of the Final Rule. See Order No. 817 at P 35,
47, and 51. These directives are currently being considered through Project 2016-01 Modifications to TOP and IRO
Standards.
8
Order No. 693, Mandatory Reliability Standards for the Bulk-Power System, FERC Stats. & Regs. ¶ 31,242
(“Order No. 693”), order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).

3

capabilities; and (ii) address deficiencies in the quality of information being provided by their
monitoring and analysis capabilities.
The proposed Reliability Standards address certain Commission directives from Order
No. 693 related to requiring a minimum set of capabilities be made available to operators. 9
Further, the proposed Reliability Standards address certain recommendations from the 2008
report of the NERC Operating Committee Real-time Tools Best Practices Task Force (“RTBP
Task Force”) relating to the availability of key Real-time monitoring and analysis capabilities. 10
The proposed Reliability Standards also address a recommendation from the joint FERC and
NERC report on the 2011 Arizona-Southern California outage that entities take steps to ensure
the adequacy and operation of their Real-time tools. 11 As such, the proposed Reliability
Standards represent an important addition to the body of Reliability Standards for the reliability
of the Bulk Power System.

9

See Order No. 693 at PP 905, 1660, and 1875 and infra Section III.C.
See RTBP Task Force, Real-Time Tools Survey Analysis and Recommendations (Mar. 2008) (“2008 RTBP
Task Force Report”), included as Exhibit G-2 to this Petition. The report is available on NERCs website at:
http://www.nerc.com/comm/OC/Realtime%20Tools%20Best%20Practices%20Task%20Force%20RTBPTF%2020/
Real-Time%20Tools%20Survey%20Analysis%20and%20Recommendations.pdf.
As explained in further detail below, the RTBP Task Force was initiated in response to Recommendation
22 of the final report on the August 2003 blackout. 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 (Apr. 2004)
(“August 2003 Blackout Report”), available at
http://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/BlackoutFinal-Web.pdf. For convenience, the August
2003 Blackout Report is also included as Exhibit G-1 to this Petition.
11
See FERC and NERC, Arizona-Southern California Outages on September 8, 2011, Causes and
Recommendations (Apr. 2012) (“2011 Southwest Outage Report”), included as Exhibit G-3 to this Petition. The
report is also available on NERC’s website at:
http://www.nerc.com/pa/rrm/ea/September%202011%20Southwest%20Blackout%20Event%20Document%20L/AZ
Outage_Report_01MAY12.pdf.
10

4

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following: 12
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]

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, 13 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) 14 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) 15 of the FPA
authorizes the Commission to order the ERO to submit a new or modified Reliability Standard.
Section 39.5(a) 16 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
12

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 (2016), to allow the inclusion
of more than two persons on the service list in this proceeding.
13
16 U.S.C. § 824o (2012).
14
Id. § 824o(b)(1).
15
Id. § 824o(d)(5).
16
18 C.F.R. § 39.5(a) (2016).

5

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 FPA 17 and Section 39.5(c) 18 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 Standards were developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process. 19 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual. 20
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, 21 and thus
satisfy certain of 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.

17

16 U.S.C. § 824o(d)(2).
18 C.F.R. § 39.5(c)(1).
19
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,
order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
20
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.
21
N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 at P 250 (2006).
22
Order No. 672 at PP 268, 270.
18

6

NERC considers the comments of all stakeholders. Stakeholders must approve, and the NERC
Board of Trustees must adopt, a Reliability Standard before NERC submits the Reliability
Standard to the Commission for approval.
C.

Commission Directives Relating to Real-time Monitoring and Analysis
Capabilities

In Order No. 693, the Commission approved 83 Reliability Standards, including the
original TOP and IRO Reliability Standards. While approving those standards, the Commission
directed NERC to develop modifications to ensure that operating entities would have adequate
tools to perform their Real-time reliability functions.
First, the Commission directed NERC to develop modifications to Reliability Standard
IRO-002-1 – Reliability Coordination – Facilities 23 as follows:
[T]he Commission directs the ERO to modify IRO-002-1 to require
a minimum set of tools that must be made available to the reliability
coordinator. We believe that this requirement will ensure that a
reliability coordinator has the tools it needs to perform its functions.
Further…such a requirement promotes a more proactive approach
to maintaining reliability. 24
As “a particular product could become obsolete and technology improves over time,” the
Commission clarified that its intent behind this directive was “to have the ERO develop a
requirement that identifies capabilities, not actual tools or products.” 25

23

Order No. 693 at P 905. The Commission approved the currently-effective version of the standard, IRO002-2, in Docket No. RM10-15-000. See Order No. 748, Mandatory Reliability Standards for Interconnection
Reliability Operating Limits, 134 FERC ¶ 61,213, order on clarification, Order No. 748-A, 136 FERC ¶ 61,030
(2011) (“Order No. 748”). In Order No. 817, the Commission approved Reliability Standard IRO-002-4 – Reliability
Coordination – Monitoring and Analysis, to become effective April 1, 2017.
24
Order No. 693 at P 905.
25
Order No. 693 at P 906.

7

Second, the Commission directed NERC to develop modifications to TOP-006-1 –
Monitoring System Conditions. 26 Again, the Commission stated that its intent was for NERC to
identify minimum capabilities, not specific sets of tools:
We adopt our proposal to require the ERO to develop a modification
related to the provision of a minimum set of analytical tools . . . we
note that our intent was not to identify specific sets of tools, but
rather the minimum capabilities that are necessary to enable
operators to deal with real-time situations and to ensure reliable
operation of the Bulk-Power System. 27
In addition to the revisions to TOP and IRO standards, the Commission directed NERC
to develop a modification to Reliability Standard VAR-001-1 – Voltage and Reactive Control
related to Real-time tools. 28 Specifically, the Commission directed NERC to modify the standard
to require periodic performance of voltage stability analysis “using online techniques where
commercially available, and offline simulation tools where online tools are not available, to
assist Real-time operations.” 29
D.

Report Recommendations Relating to Real-time Monitoring and Analysis
Capabilities

The Commission’s Order No. 693 directives highlighted the need for a minimum set of
capabilities to be available to assist operators in making Real-time decisions, a concern that has
been echoed in reports prepared following the August 2003 blackout and the 2011 Southwest
outage events. Reliability Standards relating to the operating reliability of the Bulk Power

26

Order No. 693 at P 1660. The Commission approved the currently-effective version of the standard, TOP006-2, in Order No. 748. In Order No. 817, the Commission approved three TOP Reliability Standards to replace the
existing suite of TOP standards, including Reliability Standard TOP-006-2, effective April 1, 2017.
27
Order No. 693 at P 1660.
28
Order No. 693 at P 1875. VAR-001 was most recently revised as part of Project 2013-04 – Voltage and
Reactive Control and was approved by the Commission in Docket No. RD14-11-000. See N. Am. Elec. Reliability
Corp. (Aug. 1, 2014) (unpublished letter order) and N. Am. Elec. Reliability Corp., Docket No. RD15-6-000 (Nov.
13, 2015) (unpublished letter order) (approving errata version VAR-001-4.1).
29
See Order No. 693 at ¶ 1875.

8

System have improved significantly since 2007, and many of the issues and recommendations
highlighted in these reports have since been addressed. However, these reports provide additional
considerations for improving Real-time monitoring and analysis capabilities, as discussed below.
1.

The August 2003 Blackout Report and the 2008 RTBP Task Force Report

The largest blackout in history to affect North America began on the afternoon of August
14, 2003 and disrupted over 61,800 megawatts of electric load in the northeastern United States
and the Canadian province of Ontario. The August 2003 Blackout Report identified inadequate
situational awareness as one of the key causes of the blackout, among a number of principal and
contributing causes. 30 The August 2003 blackout was linked to dysfunction of Supervisory
Control and Data Acquisition and energy management systems. 31 Additionally, investigators
pointed out that several deficiencies leading to the August 2003 blackout were identified as
weaknesses in previous outages, indicating the need for more effective response. 32 A recurring
recommendation focused on providing capabilities for operators to evaluate courses of action.
These observations led to Recommendation 22 of the August 2003 Blackout Report for NERC to
“evaluate and adopt better real-time tools for operators and reliability coordinators.” 33
In response to this recommendation, NERC formed the RTBP Task Force in 2004. The
RTBP Task Force was charged with identifying the best practices for Real-time reliability tools
used to build and maintain Real-time network models, perform state estimation and contingency
analysis, and maintain situational awareness in accordance with NERC Reliability Standards.
The RTBP Task Force was also instructed to develop guidelines for minimally acceptable

30
31
32
33

See August 2003 Blackout Report at 18.
See, e.g., id. at 52.
See id. at 159.
Id.

9

capabilities for these reliability tools and to recommend specific requirements to be included in
Reliability Standards for these tools. In 2008, following extensive information gathering and
analysis, the RTBP Task Force issued a report which included recommendations for new and
enhanced Reliability Standards, operating guidelines, and areas for further analysis.
In the years since the issuance of this report, many of its recommendations have been
addressed by other Reliability Standards, including the revised TOP and IRO Reliability
Standards. However, certain recommendations relating to Real-time monitoring and analysis
capabilities were not fully addressed or remained to be considered.
Among these recommendations was the recommendation that NERC develop new or
revised Reliability Standards to mandate certain tools as mandatory monitoring and analysis
tools. 34 The RTBP Task Force also recommended developing new or revised Reliability
Standards to address availability of various monitoring and analysis capability processes, 35 as
well as to “monitor and maintain awareness of critical equipment status to ensure that lack of
availability of critical equipment does not impair reliable operation.” 36
Collectively, these recommendations center on developing Reliability Standards that
would enhance situational awareness by providing operator awareness of key monitoring and
analysis capabilities, including when alarms are not available or performing their intended
function.
2.

The 2011 Southwest Outage Report

The need for improved Real-time monitoring and analysis capabilities was again
highlighted in the 2011 Southwest Outage Report. On the afternoon of September 8, 2011, the

34

Specifically, alarm tools, telemetry data systems, network topology processor, state estimator, and
contingency analysis. See 2008 RTBP Task Force Report at Summary of Recommendations (Recommendation S1).
35
See, e.g., id. Recommendation S7 (“Specify and measure minimum availability for alarm tools.”).
36
See id. Recommendation S40.

10

loss of a single 500 kV line led to widespread cascading outages affecting 2.7 million customers
in Arizona, Southern California, and Baja, Mexico. Like the August 2003 blackout, this event
was partly due to, or exacerbated by, inadequate Real-time situational awareness. Inadequate
operations planning was a significant factor in the failure to maintain a secure N-1 state. 37
However, the 2011 Southwest Outage Report also highlighted several concerns with entities and
their ability to monitor, identify, and plan for the next critical contingency in Real-time. 38
Recommendation 12 of this report states that entities “should take measures to ensure that
their real-time tools are adequate, operational, and run frequently enough to provide their
operators the situational awareness necessary to identify and plan for contingencies and reliably
operate their systems.” 39 While the 2011 Southwest Outage Report’s recommendations relating
to operations planning, Real-time situational awareness, and frequency of Real-time monitoring
and analysis have been primarily addressed by the revised TOP and IRO Reliability Standards, 40
the parts of Recommendation 12 relating to adequacy and operation of Real-time tools are not
explicitly covered by Reliability Standard requirements and therefore present areas for
improvement.
E.

Project 2009-02, Real-time Reliability Monitoring and Analysis Capabilities

Project 2009-02 was formed to address issues relating to Real-time reliability monitoring
and analysis capabilities, as highlighted in the Commission’s Order No. 693 directives and the
report recommendations discussed in the preceding section. Project 2009-02 was first initiated in

37

2011 Southwest Outage Report at 5.
Id.
39
Id. at 89.
40
See Petition of the North American Electric Reliability Corporation for Approval of Proposed
Transmission Operations and Interconnection Reliability Operations and Coordination Reliability Standards,
Docket No. RM15-16-000 (Mar. 18, 2015) at Ex. F (Mapping Document of Proposed Reliability Standards to
Southwest Outage Report Recommendations).
38

11

2009 in response to the work of the RTBP Task Force and used the 2008 RTBP Task Force
Report as the basis for the initial work. A Standard Authorization Request (“SAR”) drafting team
worked to develop a SAR and a concept white paper to establish requirements for the
“functionality, performance, and maintenance of Real-time Monitoring and Analysis
Capabilities.” 41 In early 2011, formal development on Project 2009-02 was paused to prioritize
efforts on other projects, including other projects to revise the TOP and IRO Reliability
Standards.
NERC resumed work on Project 2009-02 in early 2015. As many Reliability Standards
and definitions had been developed or revised in the intervening years, including the revised
TOP and IRO Reliability Standards, it was necessary to develop a new project scope to
determine which issues had been addressed through other projects and which issues remained to
be addressed through Project 2009-02.
To develop the new project scope, the Project 2009-02 drafting team reviewed the prior
work on the project, the Commission’s directives from Order No. 693 relating to Real-time
monitoring and analysis capabilities, and the findings and recommendations of the August 2003
Blackout Report and the 2008 RTPB Task Force Report. The drafting team also reviewed the
2011 Southwest Outage Report, which was issued after the initial work on Project 2009-02 was
paused in 2011, as well as recently-developed Reliability Standards addressing Real-time
situational awareness. 42 In June 2015, the drafting team hosted a technical conference to obtain

41

See Ex. H (Summary of Development and Complete Record of Development) Item 15, April 2010 Standard
Authorization Request.
42
To assist in its work, the drafting team prepared a comprehensive mapping document to show which report
recommendations relating to Real-time monitoring and analysis capabilities had been addressed through other
Reliability Standards and which recommendations remained to be considered. See Exhibit F (Standard Authorization
Request Justification, Project 2009-02) Appendix – Report Recommendations.

12

industry input on reliability issues to be addressed in this project and to hear industry
perspectives on the use of Real-time situational awareness capabilities for reliable operations.
Based on its comprehensive review and outreach, the Project 2009-02 drafting team
determined that identified reliability issues persist in the area of Real-time situational awareness
capabilities. The Project 2009-02 drafting team determined that reliability could be improved by:
(i) promoting a common understanding of monitoring as it applies to Real-time situational
awareness; (ii) providing operators with indication(s) of the quality of information being
provided by monitoring and analysis capabilities; and (iii) providing operators with
notification(s) during unplanned loss of monitoring capabilities.
Although certain recommendations from the 2008 RTBP Task Force Report
recommended developing Reliability Standards to require a minimum set of tools, the Project
2009-02 drafting team concluded that prescriptive requirements for Real-time tools should not be
within the scope of Project 2009-02. The revised definition of Real-time Assessment and the
requirements in Reliability Standards IRO-008-2 and TOP-001-3, discussed below, provide
applicable entities with the flexibility to determine which Real-time tools, such as state
estimator, contingency analysis, and stability applications, are necessary to meet their Real-time
reliability functions. Therefore, rather than prescribing specific tools, the Project 2009-02
drafting team determined that it would be appropriate to address the recommendations by
developing technology-neutral Reliability Standards.
The drafting team began work on proposed Reliability Standards IRO-018-1 and TOP010-1 in August 2015. Following two comment and ballot periods, the proposed standards were
approved by the ballot pool in February 2016. The NERC Board of Trustees adopted the
proposed standards on May 5, 2016.

13

JUSTIFICATION FOR APPROVAL
As discussed in Exhibit C and below, proposed Reliability Standards IRO-018-1 and
TOP-010-1 satisfy the Commission’s criteria in Order No. 672, and are just, reasonable, not
unduly discriminatory or preferential, and in the public interest.
Maintaining adequate situational awareness is essential for the reliable operation of the
Bulk Power System. As described in the 2008 RTBP Task Force Report, situational awareness
means “ensuring that accurate information on current system conditions, including the likely
effects of future contingencies, is continuously available in a form that allows operators to
quickly grasp and fully understand actual operating conditions and take corrective action when
necessary to maintain or restore reliable operations.” 43 Situational awareness may be thought of
as encompassing two broad capabilities: monitoring and analysis. To be effective in support of
situational awareness, Real-time monitoring and analysis must:
•
•

•

be performed with sufficient frequency to allow operators to understand operating
conditions and take corrective actions when necessary;
provide awareness of information quality to allow operators to assess the accuracy of
information being received on system conditions and take corrective actions when
necessary; and
indicate when monitoring or analysis processes are not operating normally or are
unavailable in order to provide operator awareness of the accuracy of the information
being provided. 44
The existing, Commission-approved Reliability Standards, including the revised TOP and

IRO Reliability Standards and revised definition of Real-time Assessment, provide rigorous
requirements for performing Real-time monitoring and analysis to support the reliable operation
of the Bulk Power System. However, reliability would be improved by instituting requirements

43
44

2008 RTBP Task Force Report at 3.
See Ex. F (Standard Authorization Request Justification, Project 2009-02) at 10.

14

to provide operator awareness of monitoring, alarming, and analysis quality and tool availability
to perform as intended. Proposed Reliability Standards IRO-018-1 and TOP-010-1 support
effective Real-time monitoring and analysis and thereby enhance reliable operations by ensuring
that:
•
•
•

operators are provided with indications of the quality of information being provided by
monitoring and analysis capabilities;
applicable entities have procedures in place to identify and address high-priority data and
analysis quality issues; and
operators receive notifications during unplanned loss of alarming capabilities.
In this section, NERC: (i) describes how the proposed Reliability Standards complement

the revised TOP and IRO Reliability Standards and definitions approved by the Commission in
Order No. 817 to improve Real-time situational awareness; 45 (ii) discusses the requirements of
the proposed standards on a requirement-by-requirement basis; and (iii) explains how the
proposed standards address the report recommendations and Commission directives related to
Real-time monitoring and awareness capabilities.
A.

Overview of Requirements Relating to Real-time Monitoring and Analysis
Capabilities

Real-time monitoring, or monitoring the Bulk Electric System in Real-time, is a primary
function of Reliability Coordinators, Transmission Operators, and Balancing Authorities as
required by TOP and IRO Reliability Standards. As used in TOP and IRO Reliability Standards,
monitoring involves observing operating status and operating values in Real-time for awareness
of system conditions. Real-time monitoring may include the following activities performed in
Real-time:

45
Requirements for Real-time monitoring and analysis are also contained in currently-effective Reliability
Standards which are pending retirement under the Project 2014-03 implementation plan. Please refer to Exhibit E
(Consideration of Directives) for the currently-effective requirements.

15

•

Acquisition of operating data;

•

Display of operating data as needed for visualization of system conditions;

•

Audible or visual alerting when warranted by system conditions; and

•

Audible or visual alerting when monitoring and analysis capabilities degrade or
become unavailable.

Requirements for the Reliability Coordinator, Transmission Operator, and Balancing
Authority to perform Real-time monitoring are specified in Commission-approved Reliability
Standards IRO-002-4 46 (Reliability Coordinator); TOP-001-3 47 (Transmission Operator); and
TOP-001-3 48 and the BAL standards (Balancing Authority).
The analysis component of Real-time situational awareness is described by the revised
definition of Real-time Assessment:
Real-time Assessment
An evaluation of system conditions using Real-time data to assess
existing (pre-Contingency) and potential (post-Contingency)
operating conditions. The assessment shall reflect applicable inputs
46

47

48

See IRO-002-4 Requirement R3:
Each Reliability Coordinator shall monitor Facilities, the status of Special
Protection Systems, and non-BES facilities identified as necessary by the
Reliability Coordinator, within its Reliability Coordinator Area and neighboring
Reliability Coordinator Areas to identify any System Operating Limit
exceedances and to determine any Interconnection Reliability Operating Limit
exceedances within its Reliability Coordinator Area.
See TOP-001-3 Requirement R10:
R10. Each Transmission Operator shall perform the following as necessary for
determining System Operating Limit (SOL) exceedances within its Transmission
Operator Area:
10.1. Within its Transmission Operator Area, monitor Facilities and the status
of Special Protection Systems, and
10.2. Outside its Transmission Operator Area, obtain and utilize status,
voltages, and flow data for Facilities and the status of Special Protection
Systems.
See TOP-001-3 Requirement R11:
R11. Each Balancing Authority shall monitor its Balancing Authority Area,
including the status of Special Protection Systems that impact generation or
Load, in order to maintain generation-Load-interchange balance within its
Balancing Authority Area and support Interconnection frequency.

16

including, but not limited to: load, generation output levels, known
Protection System and Special Protection System status or
degradation, Transmission outages, generator outages, Interchange,
Facility Ratings, and identified phase angle and equipment
limitations. (Real-time Assessment may be provided through
internal systems or through third-party services.)
Requirements for the Reliability Coordinator to perform Real-time Assessments are
specified in IRO-008-2, 49 and requirements for the Transmission Operator to perform Real-time
Assessments are specified in TOP-001-3. 50
The Reliability Coordinator uses a set of Real-time data identified in IRO-010-2
Requirement R1 to perform its Real-time monitoring and Real-time Assessments, whereas the
Transmission Operator uses a set of Real-time data identified in TOP-003-3 Requirement R1.
The Balancing Authority uses a set of Real-time data identified in TOP-003-3 Requirement R2 to
perform its analysis functions and Real-time monitoring.
Proposed Reliability Standards IRO-018-1 and TOP-010-1 do not create new obligations
to perform Real-time monitoring or analysis. Rather, the proposed standards build upon existing
requirements to support effective Real-time monitoring and analysis and improved situational
awareness and thereby enhance reliable operations. Proposed Reliability Standard IRO-018-1 is
applicable to Reliability Coordinators. Proposed Reliability Standard TOP-010-1 contains
Requirements which are applicable to Transmission Operators and Balancing Authorities.

49

50

See IRO-008-2 Requirement R4:
Each Reliability Coordinator shall ensure that a Real-time Assessment is
performed at least once every 30 minutes.
See revised definition of Real-time Assessment and TOP-001-3 Requirement R13:
Each Transmission Operator shall ensure that a Real-time Assessment is
performed at least once every 30 minutes.

17

B.

Proposed Reliability Standard Requirements
1.

Requirements to Address Real-time Data Quality Issues: IRO-018-1 R1,
TOP-010-1 R1, and TOP-010-1 R2

As noted in the preceding section, existing Reliability Standards contain requirements to
perform monitoring and Real-time Assessments. Proposed Reliability Standards IRO-018-1
Requirement R1, TOP-010-1 Requirement R1, and TOP-010-1 Requirement R2 build upon these
requirements to support effective situational awareness by requiring each Reliability
Coordinator, Transmission Operator, and Balancing Authority to implement an Operating
Process 51 or Operating Procedure 52 to address the quality of the Real-time data necessary to
perform its Real-time data monitoring and Real-time Assessments or analysis functions. Entities
continue to address lower-priority data quality issues (i.e. data quality issues not affecting Realtime monitoring or analysis) according to their operating practices.
These requirements, along with the proposed requirements discussed in the subsequent
sections, address recommendations from the 2008 RTBP Task Force Report by specifying
monitoring and analysis capabilities for situational awareness. Further, the proposed
requirements address the 2011 Southwest Outage Report’s recommendation that entities should
take measures to ensure the adequacy and operation of their Real-time tools.

51

52

Operating Process is defined in the Glossary of Terms Used in NERC Reliability Standards (“Glossary”) as:
A document that identifies general steps for achieving a generic operating goal.
An Operating Process includes steps with options that may be selected depending
upon Real-time conditions. A guideline for controlling high voltage is an example
of an Operating Process.
Operating Procedure is defined in the Glossary as:
A document that identifies specific steps or tasks that should be taken by one or
more specific operating positions to achieve specific operating goal(s). The steps
in an Operating Procedure should be followed in the order in which they are
presented, and should be performed by the position(s) identified. A document that
lists the specific steps for a system operator to take in removing a specific
transmission line from service is an example of an Operating Procedure.

18

The specific requirements are as follows.
IRO-018-1 Requirement R1, applicable to Reliability Coordinators, provides:
IRO-018-1
R1. Each Reliability Coordinator shall implement an Operating
Process or Operating Procedure to address the quality of the Realtime data necessary to perform its Real-time monitoring and Realtime Assessments. The Operating Process or Operating Procedure
shall include: [Violation Risk Factor: Medium] [Time Horizon:
Real-time Operations]
1.1. Criteria for evaluating the quality of Real-time data;
1.2. Provisions to indicate the quality of Real-time data to the
System Operator; and
1.3. Actions to address Real-time data quality issues with the
entity(ies) responsible for providing the data when data quality
affects Real-time Assessments.
Proposed Reliability Standard TOP-010-1 Requirement R1 contains identical
requirements applicable to Transmission Operators.
Similarly, proposed Reliability Standard TOP-010-1 Requirement R2 requires each
Balancing Authority to implement an Operating Process or Operating Procedure to address the
quality of the Real-time data necessary to perform its required analysis functions and Real-time
monitoring as follows:
TOP-010-1
R2. Each Balancing Authority shall implement an Operating
Process or Operating Procedure to address the quality of the Realtime data necessary to perform its analysis functions and Real-time
monitoring. The Operating Process or Operating Procedure shall
include: [Violation Risk Factor: Medium] [Time Horizon: Real-time
Operations]
2.1. Criteria for evaluating the quality of Real-time data;
2.2. Provisions to indicate the quality of Real-time data to the
System Operator; and
2.3. Actions to address Real-time data quality issues with the
entity(ies) responsible for providing the data when data quality
affects its analysis functions.
19

The Operating Process or Operating Procedure required by proposed IRO-018-1
Requirement R1 and proposed TOP-010-1 Requirements R1 and R2 consists of three parts. First,
the Operating Process or Operating Procedure must contain criteria for evaluating the quality of
Real-time data. As described in the Guidelines and Technical Basis section of the proposed
standards, the criteria support identification of data quality issues, which may include: (i) data
outside of a prescribed data range; (ii) analog data not updated within a predetermined time
period; (iii) data entered manually to override telemetered information; or (iv) data otherwise
identified as invalid or suspect.
Second, the Operating Process or Operating Procedure must include provisions for
indicating the quality of Real-time data to operating personnel. To satisfy this requirement, the
applicable entity could use descriptions of quality indicators such as display color codes, data
quality flags, or other such indicators as found in Real-time monitoring specifications.
Third, the required Operating Process or Operating Procedure must include actions to
address Real-time data quality issues affecting the Reliability Coordinator or Transmission
Operator’s Real-time Assessments, or in the case of the Balancing Authority, Real-time data
quality issues affecting its analysis functions.
In drafting these requirements, the Project 2009-02 drafting team recognized that the
applicable entity may have limited ability to resolve (or correct) bad or suspect data coming from
a third party. Therefore, the proposed requirements provide applicable entities with the flexibility
to determine which steps are appropriate to maintain adequate situational awareness. The actions
an entity may take to address Real-time data quality issues could be the same as the process used
to resolve data conflicts required by IRO-010-2 Requirement R3 Part 3.2 or TOP-003-3
Requirement R5 Part 5.2, provided that this process addresses Real-time data quality issues.

20

Other examples of actions to address data quality issues include, but are not limited to: (i)
notifying the entities that are providing the Real-time data; (ii) taking corrective actions on the
applicable entity’s own data; (iii) changing data sources or other inputs so the data quality issue
no longer affects Real-time Assessments; or (iv) entering data manually and updating as
necessary.
2.

Requirements to Address the Quality of Analysis used in Real-time
Assessments: IRO-018-1 R2 and TOP-010-1 R3

Proposed Reliability Standards IRO-018-1 Requirement R2 and TOP-010-1 Requirement
R3 ensure that Reliability Coordinators and Transmission Operators implement Operating
Processes or Operating Procedures to address issues related to the quality of the analysis used in
Real-time Assessments. As discussed above, requirements to perform Real-time Assessments
appear in other Reliability Standards. Examples of the type of analysis used in Real-time
Assessments may include state estimation, Real-time contingency analysis, stability analysis, or
other studies used for Real-time Assessments.
Proposed IRO-018-1 Requirement R2, applicable to Reliability Coordinators, provides as
follows:
R2. Each Reliability Coordinator shall implement an Operating
Process or Operating Procedure to address the quality of analysis
used in its Real-time Assessments. The Operating Process or
Operating Procedure shall include: [Violation Risk Factor: Medium]
[Time Horizon: Real-time Operations]
2.1. Criteria for evaluating the quality of analysis used in its Realtime Assessments;
2.2. Provisions to indicate the quality of analysis used in its Realtime Assessments; and
2.3. Actions to address analysis quality issues affecting its Real-time
Assessments.
Proposed Reliability Standard TOP-010-1 Requirement R3 contains identical
requirements applicable to Transmission Operators.
21

These requirements have the same general structure as the proposed requirements for data
quality issues. First, the Reliability Coordinator or Transmission Operator’s Operating Process or
Operating Procedure must include criteria for evaluating the quality of analysis. Examples of the
types of criteria that may be used to evaluate the quality of analysis include, but are not limited
to, solution tolerances, correlation with Real-time data, or the number of contingencies analyzed
from the set of potential contingencies.
Second, the Operating Process or Operating Procedure must describe how the quality of
analysis results used in Real-time Assessments will be shown to operating personnel. Operating
personnel includes System Operators and staff responsible for supporting Real-time operations.
Third, the Operating Process or Operating Procedure must include actions to address
those analysis quality issues affecting its Real-time Assessments. Similar to the requirements for
data quality issues, Reliability Coordinators and Transmission Operators have flexibility to
determine the appropriate actions to take in situations where analysis quality issues are affecting
their ability to perform Real-time Assessments.
3.

Requirements for Alarm Processor Failure Monitoring: IRO-018-1 R3,
TOP-010-1 R4

In the 2008 RTBP Task Force Report, the RTBP Task Force recommended developing a
requirement to specify minimum availability of alarm tools (Recommendation S7). Proposed
Reliability Standards IRO-018-1 Requirement R3 and TOP-010-1 Requirement R4 address the
situational awareness objectives associated with this recommendation by providing for operator
awareness when key alarming tools are not performing as intended.
Proposed Reliability Standard IRO-018-1 Requirement R3, applicable to Reliability
Coordinators, states:
R3. Each Reliability Coordinator shall have an alarm process
monitor that provides notification(s) to its System Operators when a
22

failure of its Real-time monitoring alarm processor has occurred.
[Violation Risk Factor: Medium] [Time Horizon: Real-time
Operations]
Proposed TOP-010-1 Requirement R4 contains an identical requirement applicable to
Transmission Operators and Balancing Authorities.
As specified in the Guidelines and Technical Basis section of the proposed Reliability
Standards, the alarm process monitor should be designed and implemented such that a stall of the
Real-time monitoring alarm processor does not cause a failure of the alarm process monitor. The
proposed requirements provide applicable entities with flexibility to determine whether to use an
alarm process monitor that is a separate system or an application within a Real-time monitoring
system.
C.

Consideration of FERC Directives

As discussed in Section III.C above, the Commission directed NERC in Order No. 693 to
modify TOP and IRO Reliability Standards to require a minimum set of capabilities be made
available to operators. 53 Although the Commission contemplated modifications to specific
Reliability Standards, NERC submits that proposed Reliability Standards IRO-018-1 and TOP010-1, together with other currently-effective and Commission-approved Reliability Standards,
address the reliability concerns underlying the Commission’s directives in an equally effective
and efficient manner, as set forth below.
1.

Order No. 693 P 905 Directive

In Order No. 693, the Commission directed NERC to modify IRO-002-1 to develop a
requirement that identifies the minimum capabilities that must be made available to the
Reliability Coordinator to ensure “that a reliability coordinator has the tools it needs to perform

53

Order No. 693 at P 905-906 (directing NERC to modify IRO-002-1) and P 1660 (directing NERC to
modify TOP-006-1).

23

its functions.” 54 The monitoring and analysis capabilities required by proposed Reliability
Standard IRO-018-1 and other IRO Reliability Standards ensure Reliability Coordinators have
the capabilities to maintain Real-time situational awareness.
Monitoring capabilities. Requirements for the Reliability Coordinator to perform Realtime monitoring are specified in Commission-approved Reliability Standard IRO-002-4. 55 As
discussed in the preceding section, proposed Reliability Standard IRO-018-1 Requirement R1
addresses the quality of the Real-time data needed by the Reliability Coordinator to perform its
monitoring and Real-time Assessments by requiring each Reliability Coordinator to implement a
documented procedure to address data quality issues. Proposed IRO-018-1 Requirement R3
addresses capabilities for operator awareness of failures in Real-time monitoring alarm processes
by requiring Reliability Coordinators to have an alarm process monitor.
Analysis Capabilities. Requirements for the Reliability Coordinator to perform Real-time
Assessments are specified in Commission-approved Reliability Standard IRO-008-2 and the
approved revised definition of Real-time Assessment. Under proposed Reliability Standard IRO018-1 Requirement R2, each Reliability Coordinator is required to implement a documented
procedure to address the quality of the analysis used in its Real-time Assessments.
2.

Order No. 693 P 1660 Directive

In Order No. 693, the Commission directed NERC to develop a modification to
Reliability Standard TOP-006-1 related to the provision of a minimum set of analytical tools (i.e.
capabilities) “that are necessary to enable operators to deal with real-time situations and to
ensure reliable operation of the Bulk-Power System.” 56 As discussed below, the monitoring and

54

Order No. 693 at P 905.
As noted above, please refer to Exhibit E (Consideration of Directives) for the currently-effective
requirements for Real-time monitoring and analysis.
56
Order No. 693 at P 1660.
55

24

analysis capabilities required by proposed TOP-010-1 and other Commission-approved TOP
Reliability Standards ensure that Transmission Operators and Balancing Authorities have the
capabilities to maintain Real-time situational awareness and thus address the Commission’s
directive in an equally effective and efficient manner.
Monitoring Capabilities. Requirements for Transmission Operators and Balancing
Authorities to perform Real-time monitoring are specified in Commission-approved Reliability
Standard TOP-001-3 and the BAL Reliability Standards. As discussed in the preceding section,
proposed Reliability Standard TOP-010-1 Requirements R1 and R2 address the quality of the
Real-time data needed by Transmission Operators and Balancing Authorities to perform their
Real-time monitoring and Real-time Assessments or analysis functions by requiring these
entities to implement a documented procedure for addressing data quality issues. Proposed
Reliability Standard TOP-010-1 Requirement R4 addresses capabilities for operator awareness of
failures in Real-time monitoring alarm processes by requiring Transmission Operators and
Balancing Authorities to have an alarm process monitor.
Analysis Capabilities. Requirements for the Transmission Operator to perform Real-time
Assessments are specified in Commission-approved Reliability Standard TOP-001-3. Under
proposed Reliability Standard TOP-010-1 Requirement R3, each Transmission Operator is
required to implement a documented procedure to address the quality of the analysis used in its
Real-time Assessments.
3.

Order No. 693 P 1875 Directive

In addition to the two directives discussed above, the Commission also directed NERC to
modify Reliability Standard VAR-001-1 to “to include Requirements to perform voltage stability

25

analysis periodically, using online techniques where commercially-available, and offline
simulation tools where online tools are not available, to assist real-time operations.” 57
This directive was considered in establishing the scope of Project 2009-02. However,
NERC maintains that this directive has now been addressed by other TOP, IRO, and VAR
standards approved by the Commission. Accordingly, Project 2009-02 did not develop additional
requirements to address this directive. NERC respectfully requests that the Commission find that
the concerns underlying this directive have been addressed in an equally effective and efficient
manner through the framework provided by these other standards.
Reliability Standard VAR-001 was most recently revised in Project 2013-04 Voltage &
Reactive Control. 58 Reliability Standard VAR-001-4.1 Requirement R1 provides that the
Transmission Operator shall specify a system voltage schedule as part of its plan to operate
within System Operating Limits (“SOLs”) and Interconnection Reliability Operating Limits
(“IROLs”). Reliability Standard VAR-001-4.1 does not include an explicit requirement for
periodic performance of voltage stability analysis because "such analysis would be performed
pursuant to the SOL methodology developed under FAC standards.” 59
Reliability Coordinators and Transmission Operators are required to periodically perform
Real-time Assessments consisting of an evaluation of system conditions "to assess existing (preContingency) and potential (post-Contingency) operating conditions." 60 Requirements for
performing Real-time Assessments are contained in currently-effective Reliability Standard IRO-

57

Order No. 693 at P 1875.
Reliability Standard VAR-001-4 was approved by the Commission in Docket No. RD14-11-000. See N.
Am. Elec. Reliability Corp. (Aug. 1, 2014) (unpublished letter order). The Commission approved the currentlyeffective errata version VAR-001-4.1 in Docket No. RD15-6-000. See N. Am. Elec. Reliability Corp. (Nov. 13,
2015) (unpublished letter order).
59
Reliability Standard VAR-001-4.1, Guidelines and Technical Basis.
60
See revised definition of Real-time Assessment.
58

26

008-1 and Commission-approved Reliability Standards IRO-008-2 and TOP-001-3 as discussed
above. Real-time Assessments assist operators in maintaining operations within established
SOLs and IROLs, to include voltage stability criteria. Under these requirements, applicable
entities must use whatever analysis is necessary to obtain an evaluation of system conditions,
which may include Real-time voltage stability analysis. These requirements do not prescribe the
use of specific techniques or tools.
In light of the comprehensive and flexible framework that is now in place, NERC submits
that the Commission’s underlying concern from Order No. 693 has been addressed, and that it is
no longer necessary to modify the VAR-001 Reliability Standard to specifically require the
performance of voltage stability analysis using online techniques when available or offline
simulation tools when not available.
D.

Enforceability of the Proposed Reliability Standards

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 Standards. 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 VRFs and
VSLs comport with NERC and Commission guidelines related to their assignment. A description
of how the proposed VRF and VSL assignments meet these guidelines is provided in Exhibit D.
Below, NERC provides additional detail to explain how the proposed VRF assignments meet
these guidelines.

27

Each of the Requirements in proposed Reliability Standards IRO-018-1 and TOP-010-1
were assigned a “Medium” VRF. Under NERC’s criteria for VRFs, a Medium Risk Requirement
is defined as follows:
A requirement that, if violated, could directly affect the electrical
state or the capability of the Bulk Electric System, or the ability to
effectively monitor and control the Bulk Electric System. However,
violation of a medium risk requirement is unlikely to lead to Bulk
Electric System instability, separation, or cascading failures; or, a
requirement in a planning time frame that, if violated, could, under
emergency, abnormal, or restorative conditions anticipated by the
preparations, directly and adversely affect the electrical state or
capability of the Bulk Electric System, or the ability to effectively
monitor, control, or restore the Bulk Electric System. However,
violation of a medium risk requirement is unlikely, under
emergency, abnormal, or restoration conditions anticipated by the
preparations, to lead to Bulk Electric System instability, separation,
or cascading failures, nor to hinder restoration to a normal condition.
The Commission has set forth several guidelines for evaluating proposed VRFs. 61 First,
for Reliability Standard Requirements addressing areas identified in the August 2003 Blackout
Report as causes of previous blackouts, the Commission looks to determine whether the assigned
VRFs “appropriately reflect their historical critical impact on the reliability of the Bulk Power
System.” Second, the Commission looks to whether the assigned VRFs are consistent within the
Reliability Standard. Third, the Commission evaluates whether the assigned VRFs are consistent
among other Reliability Standards with similar Requirements. Fourth, the Commission evaluates
whether the proposed VRF assignments are consistent with NERC’s definition of the VRF level.
Lastly, where a single Requirement co-mingles higher and lower risk reliability objectives, the
Commission evaluates whether the VRF has been “watered down” to reflect the lower risk level.
Under these guidelines, NERC’s proposed assignment of “Medium” VRFs for the
proposed Reliability Standard Requirements is appropriate. First, the proposed Requirements are
61

See N. Am. Electric Reliability Corp., Order on Violation Risk Factors, 119 FERC ¶ 61,145 (2007).

28

not directly connected to the conclusions or critical areas identified in the August 2003 Blackout
Report, but rather address specific recommendations from a NERC technical committee. With
respect to the final guideline, the proposed VRF assignments do not reflect the lower of multiple
reliability objectives as each requirement contains one reliability objective. With respect to the
second, third, and fourth guidelines, the proposed VRF assignments are consistent within the
proposed Reliability Standards, among other Reliability Standards with similar Requirements,
and with the NERC definition of the VRF level, as discussed below.
The proposed Medium VRF assignments are consistent with the NERC definition. The
purpose of the proposed Reliability Standards is to address recommendations regarding Realtime situational awareness and to require entities to take steps to address data or analysis quality
concerns to the extent that it affects their ability to perform Real-time monitoring and analysis.
The requirements in IRO-018-1 and TOP-010-1 address issues related to the quality and
availability of monitoring and analysis capabilities used by Reliability Coordinators,
Transmission Operators, and Balancing Authorities in maintaining reliable operations. Violation
of any of these requirements could directly affect the ability to effectively monitor and control
the Bulk Electric System. However, violation of any of these requirements is unlikely to lead to
Bulk Electric System instability, separation, or cascading failures.
Further, NERC’s proposed assignment of Medium VRFs is both consistent within the
proposed Reliability Standards, which contain similar responsibilities for different applicable
entities, and with other Reliability Standards that involve effective monitoring and control of the
Bulk Electric System. For example, Reliability Standards TOP-003-3 Requirement 5 and IRO010-2 Requirement R3, which provide that applicable entities shall provide the data necessary
for Transmission Operators and Reliability Coordinators to perform Real-time monitoring and

29

Real-time Assessments, have each been assigned a Medium VRF. Reliability Standard TOP-0013 Requirement R9, which requires Transmission Operators and Balancing Authorities to notify
Reliability Coordinators and others of planned and unplanned outages of monitoring and
assessment capabilities, has also been assigned a Medium VRF. 62
In addition to the proposed VRFs and VSLs, the proposed Reliability Standards also
include Measures that support each Requirement by clearly identifying what is required and how
the Requirement will be enforced. These Measures help ensure that the Requirements will be
enforced in a clear, consistent, and non-preferential manner and without prejudice to any party. 63
EFFECTIVE DATE
NERC respectfully requests that the Commission approve the proposed implementation
plan attached to this Petition as Exhibit B. NERC proposes a single implementation plan, to
govern implementation of both proposed Reliability Standards IRO-018-1 and TOP-010-1.
Under this plan, the proposed Reliability Standards would become effective the first day of the
first calendar quarter that is 18 months following regulatory approval.
The proposed implementation period is designed to allow applicable entities sufficient
time to develop and implement the required Operating Processes or Procedures and, if necessary,
implement any upgrades to their Real-time monitoring systems.

62

In addition, NERC’s proposed VRF assignments are appropriate in light of the Commission-approved VRF
assignments for related Reliability Standards. The proposed requirements relate to implementing Operational
Processes or Operational Procedures to address Real-time data quality and analysis issues. The actual Requirements
to perform Real-time Assessments have been assigned a High VRF. See, e.g., TOP-001-3 Requirement 13.
Requirements to maintain data specifications for the data needed to perform Real-time monitoring and Real-time
Assessments have been assigned a Low VRF. See, e.g., TOP-003-3 Requirement R1.
63
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.”).

30

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

approve proposed Reliability Standards IRO-018-1, TOP-010-1, and associated elements
included in Exhibit A; and

•

approve the implementation plan included in Exhibit B.

Respectfully submitted,
/s/ Lauren A. Perotti
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
May 26, 2016

31