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pdfExhibit D
Analysis of Violation Risk Factors
and
Violation Severity Levels
Violation Risk Factor and Violation Severity Level
Justifications
Project 2015-10 Single Points of Failure TPL-001
This document provides the standard drafting team’s (SDT’s) justification for assignment of violation risk factors (VRFs) and violation severity
levels (VSLs) for Requirement R4 in Project 2015‐10 and Single Points of Failure TPL‐001. Each requirement is assigned a VRF and a VSL. These
elements support the determination of an initial value range for the Base Penalty Amount regarding violations of requirements in FERC‐
approved Reliability Standards, as defined in the Electric Reliability Organizations (ERO) Sanction Guidelines. The SDT applied the following
NERC criteria and FERC Guidelines when developing the VRFs and VSLs for the requirements.
NERC Criteria for Violation Risk Factors
High Risk Requirement
A requirement that, if violated, could directly cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of
failures, or could place the Bulk Electric System at an unacceptable risk of 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
cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of failures, or could place the Bulk Electric System
at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition.
Medium Risk Requirement
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.
Lower Risk Requirement
A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical
state or capability of the Bulk Electric System, or the ability to effectively monitor and control the Bulk Electric System; or, a requirement that
is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or
restorative conditions anticipated by the preparations, be expected to 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.
FERC Guidelines for Violation Risk Factors
Guideline (1) – Consistency with the Conclusions of the Final Blackout Report
FERC seeks to ensure that VRFs assigned to Requirements of Reliability Standards in these identified areas appropriately reflect their historical
critical impact on the reliability of the Bulk‐Power System. In the VSL Order, FERC listed critical areas (from the Final Blackout Report) where
violations could severely affect the reliability of the Bulk‐Power System:
Emergency operations
Vegetation management
Operator personnel training
Protection systems and their coordination
Operating tools and backup facilities
Reactive power and voltage control
System modeling and data exchange
Communication protocol and facilities
Requirements to determine equipment ratings
Synchronized data recorders
Clearer criteria for operationally critical facilities
Appropriate use of transmission loading relief.
VRF and VSL Justifications
Project 2015‐10 Single Points of Failure TPL‐001
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Guideline (2) – Consistency within a Reliability Standard
FERC expects a rational connection between the sub‐Requirement VRF assignments and the main Requirement VRF assignment.
Guideline (3) – Consistency among Reliability Standards
FERC expects the assignment of VRFs corresponding to Requirements that address similar reliability goals in different Reliability Standards
would be treated comparably.
Guideline (4) – Consistency with NERC’s Definition of the Violation Risk Factor Level
Guideline (4) was developed to evaluate whether the assignment of a particular VRF level conforms to NERC’s definition of that risk level.
Guideline (5) – Treatment of Requirements that Co-mingle More Than One Obligation
Where a single Requirement co‐mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such
Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability
Standard.
VRF and VSL Justifications
Project 2015‐10 Single Points of Failure TPL‐001
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NERC Criteria for Violation Severity Levels
VSLs define the degree to which compliance with a requirement was not achieved. Each requirement must have at least one VSL. While it is
preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and
may have only one, two, or three VSLs.
VSLs should be based on NERC’s overarching criteria shown in the table below:
Lower VSL
The performance or product
measured almost meets the full
intent of the requirement.
Moderate VSL
High VSL
The performance or product
The performance or product
measured meets the majority of measured does not meet the
the intent of the requirement. majority of the intent of the
requirement, but does meet
some of the intent.
Severe VSL
The performance or product
measured does not
substantively meet the intent of
the requirement.
FERC Order of Violation Severity Levels
The FERC VSL guidelines are presented below, followed by an analysis of whether the VSLs proposed for each requirement in the standard
meet the FERC Guidelines for assessing VSLs:
Guideline (1) – Violation Severity Level Assignments Should Not Have the Unintended Consequence of Lowering the Current
Level of Compliance
Compare the VSLs to any prior levels of non‐compliance and avoid significant changes that may encourage a lower level of compliance than
was required when levels of non‐compliance were used.
Guideline (2) – Violation Severity Level Assignments Should Ensure Uniformity and Consistency in the Determination of
Penalties
A violation of a “binary” type requirement must be a “Severe” VSL.
Do not use ambiguous terms such as “minor” and “significant” to describe noncompliant performance.
Guideline (3) – Violation Severity Level Assignment Should Be Consistent with the Corresponding Requirement
VSLs should not expand on what is required in the requirement.
VRF and VSL Justifications
Project 2015‐10 Single Points of Failure TPL‐001
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Guideline (4) – Violation Severity Level Assignment Should Be Based on A Single Violation, Not on A Cumulative Number of
Violations
Unless otherwise stated in the requirement, each instance of non‐compliance with a requirement is a separate violation. Section 4 of the
Sanction Guidelines states that assessing penalties on a per violation per day basis is the “default” for penalty calculations.
VRF Justification for TPL-001-5, Requirement R1
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R1
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF Justification for TPL-001-5, Requirement R2
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R2
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF Justification for TPL-001-5, Requirement R3
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R3
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF Justification for TPL-001-5, Requirement R4
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R4
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF and VSL Justifications
Project 2015‐10 Single Points of Failure TPL‐001
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VRF Justification for TPL-001-5, Requirement R5
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R5
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF Justification for TPL-001-5, Requirement R6
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R6
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF Justification for TPL-001-5, Requirement R7
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R7
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF Justification for TPL-001-5, Requirement R8
The VRF did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VSL Justification for TPL-001-5, Requirement R8
The VSL did not change from the previously FERC approved TPL‐001‐4 Reliability Standard.
VRF and VSL Justifications
Project 2015‐10 Single Points of Failure TPL‐001
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File Type | application/pdf |
Author | Courtney Baughan |
File Modified | 2019-07-31 |
File Created | 2018-11-27 |