POWER February 2017 - 46

REGULATIONS
4. People remain critical. Regardless
of the number and nature of reliability standards,
well-trained and diligent staff are the
most important element of a reliability program.
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ments, more training requirements for generator
owners and operators required by the
standards, and CIP awareness and procedure
measures for Low Impact Cyber Systems.
Under the bright line criteria of the CIP-0025.1
BES Cyber System Categorization standard,
any BES element that employs Cyber
Systems is at least a Low Impact Cyber System.
This would include all wind and solar
generators who meet the BES registration
criteria and who utilize some form of cyber
control or monitoring of their facility.
Third, as compliance programs continue
to evolve and mature, and as Registered
Entities implement comprehensive compliance
programs, the risk of the requirements
becoming a matter of routine presents other
challenges. David Hilt, a former vice president
of compliance at NERC, and a key
contributor to the 2003 blackout investigation
and report, was asked what he sees as
the greatest threat to reliability in the coming
years. He answered: " Complacency. As
NERC and the regulators throughout North
America have implemented a regime of mandatory
reliability standards that have focused
on improving reliability of this most critical
infrastructure, we cannot become complacent
about reliability and believe it has been taken
care of. We will continue to face emerging
issues and new challenges to the reliable operation
of the Bulk Electric System. "
Fourth, the cost of compliance remains
a high priority both among regulators and
Registered Entities. In 2016, NERC initiated
a pilot program to consider the balance
of cost and benefits for the implementation
of reliability standards. Reliability
Standard TPL-001-4 Transmission System
Planning Performance Requirements was
selected as the pilot standard. The pilot
sought to define the relative risks of not
complying with the requirements within
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the standard, followed by industry input
on costs. There was a wide variation in the
responses that ranged from " one additional
FTE " to " considerable costs. "
On an industry-wide basis, a fair average
is $40,000 to $50,000 for small Registered
Entities to manage their compliance risks
through additional staff duties or staff augmentation
from outside advisors. For larger,
transmission-oriented entities, a core compliance
staff of four to six experts and supporting
personnel, with input and associated time
contributed by dozens of subject matter experts
and process owners, can easily run into
the hundreds of thousands of dollars.
Finally, as the electric power industry
continues to improve its approach to system
reliability, we come back to where we started-with
the people who operate, monitor, and
maintain the interconnected grids (Figure 4).
Human performance was identified as one of
the key risk factors to reliability in the NERC
Compliance Monitoring and Enforcement Implementation
Plan, because the performance of
personnel who make the decisions, both in real
time and in the planning of the system, is perhaps
the single greatest risk factor.
Until we have a system monitored and operated
by robots or software (which could present
its own unintended consequences), the people
who manage the production and delivery of
electric power are absolutely vital to everything
the regulators and the reliability standards are
trying to achieve. Human performance is, of
course, a vital issue in many industries, but the
BES can pose unique challenges.
When asked if there is a difference in how
electric system operation approaches human
performance when compared to other industries,
Pam Ey, PhD, a widely acknowledged
expert on human performance, describes it
this way: " Absolutely. Our electric grid is an
amazing complex system, plugged into business
architectures that make optimization of
Human Performance initiatives particularly
challenging. We can see impacts in our industry
in the way that work instructions are
written, information is shared, and metrics
are used, for instance in training programs.
But I am energized by discussions with leaders
in utilities concerned with creating proactive
HP practices as a sturdy framework
for resilient operations. Thankfully, both the
medical and airline industry have paved the
way. "
Standards and processes, procedures and
audits are all important, but the talented and
dedicated people who keep our lights on and
our security intact will always be the critical
element. ■
-James Stanton (james.stanton@sosintl.
com) is director of advisory services at
SOS International.
POWER | February 2017
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POWER February 2017

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