Public Power - January/February 2008 - (Page 39) Joseph McClelland, director of FERC’s Office of Electric Reliability, said the remaining 24 are “fill-in-theblank” standards, contingent on information provided to NERC from the regions. “We are waiting for NERC to return these to us. Specifically, in Order 693 we said that we would not approve or remand these standards until the ERO submits further information. Until we have those revised standards from NERC, however, we expect compliance with the fill-in-the-blank standards as good utility practice.” For public power utilities, particularly smaller ones, the mandates may be daunting, said Henery. One concern involves who is covered and who is not. The EPAct 2005 makes it clear that all entities responsible for the reliability of the bulk power system must register with the electric reliability organization (NERC). However, it is not clear where the bulk power system begins and ends. A 765-kV line is obviously part of the system. However, what about a 69-kV line in a community? Any public power utility with under-voltage load-shedding equipment will be considered a grid participant. Henery recommended that public power utilities provide descriptions of their electric systems to their joint action agencies or regional entities, to determine the extent of their impact (or lack thereof) on the bulk system. The American Public Power Association has asked NERC and FERC to allow joint action agencies or other state or regional entities to handle reliability paperwork on behalf of smaller public power utilities. FERC has provided some examples of who is covered in its www.APPAnet.org final rule, Order 693, Paragraph 93: “NERC plans to register only those distribution providers or load-serving entities that have a peak load of 25 megawatts or greater and are directly connected to the bulk electric system, or are designated as a responsible entity as part of a required load-shedding program.” In addition, for generators, NERC plans to register individual units of 20MvA or greater that are directly connected to the bulk electric system. The commission relied on NERC’s registration criteria rather than creating new criteria, said McClelland. The Energy Policy Act says all users, owners and operators have to comply with the standards developed by the electric reliability organization and approved by the commission, Whiteley said. To determine who are users, owners and operators, NERC created a registry, a list of entities to which the standards can be applied, which is based on its own knowledge as well as that of the regional reliability organizations. There has also been some self-designation. “We also created a mechanism by which entities can challenge being placed on the list,” said Whiteley. Currently, there are more than 1,500 entities on the registry, and they have been notified. A small handful of them have appealed, and these appeals are being processed. “There is also an opportunity for a group of entities to get together either to form or designate a joint registration organization that takes over responsibility for the compliance activities,” said Whiteley. This allows small entities, such as some small municipal electric utilities, to avoid the bureau- cratic processes. “This is strictly for efficiency, though,” he said. “It does not mean that these entities are off the hook for compliance.” One of the biggest challenges to administering the new standards involves the creation of “violation risk factors” and “violation severity levels.” “When we put ‘Version 0’ together, there were no such things as ‘violation risk factors’ and ‘violation severity levels,’” said Henery. “The closest thing we had was a section in the standards relating to non-compliance.” The new structure creates sanctions guidelines, displayed in a grid format. Violation risk factors are on the vertical axis, and each requirement now has a violation risk factor, based on the degree to which the requirement, if unmet, would endanger the electric system. Some requirements are low risk, such as not keeping up with the administrative aspects of reliability. A medium risk factor would stress the system and possibly cause a cascading outage. A failure to respond to a disturbance control standard within 15 minutes would constitute a high-risk factor violation. Violation severity levels are on the horizontal axis. There are four levels of severity: low, medium, high, and severe. “For example, there may be a requirement with three or four subsections,” said Henery. “If someone misses only one of these, the violation severity level is low.” If a utility has a situation with a low violation risk factor and a low violation severity level, it ends up in the highest left-hand corner of the matrix, in the sanction box that says between $1,000 and $5,000. However, if the utility has an incident with a high violation risk factor and a severe violation severity level, it ends up in the lowest right-hand corner of the matrix, in the sanction box for a $1 million-a-day fine. However, said Henery, compliance personnel in the districts, regions, and even at FERC, have some discretion. For example, if a utility happens to realize that it has some bad metering in the field, and it hasn’t been checked like it should have been, this might be causing bad feeds and causing frequency to jump around. “It’s always better if you self-report rather than try to hide a violation. If you pick up the phone and report yourself, FERC would consider the cooperation as a positive move and may reduce the fine or they might even approve a mitigation plan instead of a fine,” Complete Billing Solutions for Utilities o Order Entry, Work Order and Billing for Video, Data and Voice Services o Automated Provisioning of FTTH Network and All Other Technologies o Use Your Existing Utility Billing System or ETI’s Optional Module o Proven Technology in over 100 Satisfied Customers JANUARY-FEBRUARY 2008 39 http://www.etisoftware.com http://www.APPAnet.org
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