Unofficial Comment Form
Risk-Based Registration Design Proposal Survey
Please DO NOT use this form for submitting comments. Please use the electronic form to submit
comments on the proposed Risk-Based Registration Design. The electronic comment form must be
completed by 8:00 p.m. ET on Monday, June 23, 2014.
If you have questions please contact Terry Brinker or Soo Jin Kim via email or by telephone at 404-4462560.
Click Here: Risk-Based Registration Initiative Webpage.
Background Information
NERC’s Risk-Based Registration (RBR) initiative seeks to ensure that the right entities are subject to the
right set of applicable Reliability Standards, using a consistent approach to risk assessment and
registration across the electric reliability organization (ERO) Enterprise. In order to achieve this goal, a
Risk-Based Registration Advisory Group (RBRAG) was formed and tasked with creating a new Registration
design.
Comment Period Now Open through June 23, 2014:
A draft design framework reflecting input from the Risk-Based Registration Advisory Group (RBRAG) and
the RBRAG technical Task Force (RBRAG Task Force) has been developed. To improve the design and
understand any implications on bulk electric system reliability, RBRAG seeks industry feedback on an
initial draft document with proposed revisions to the Registry Criteria. A comment form with specific
questions is also being posted with the Design document to focus response on key areas of the Design.
This is the first comment period on the proposed Design, and RBR will consider all comments received
before making additional modifications to be submitted for MRC input. After receiving MRC feedback, the
Design will be further revised and posted for another 45-day industry comment period in late August.
If you experience any difficulties in using the electronic form, please contact Terry Brinker or Soo Jin Kim
via email or by telephone at 404-446-2560. An off-line, unofficial copy of the comment form is also
posted on the new RBR page.
Enter all comments in plain text format. Bullets, numbers, and special formatting will not be retained.
Background Information
The Risk-Based Registration Advisory Group (RBRAG) seeks comment from industry on the draft design to
inform a final recommendation on the design and implementation of the Risk-Based Registration
program. The following questions have been formulated to gain insight into general issues, Reliability
Standard Applicability, and three functions being considered for removal from the NERC Compliance
Registry.
General Information
1. Planning Authorities/Coordinators (PA/PC), Reliability Coordinators (RCs), Balancing Authorities
(BAs), Resource Planners (RP), Transmission Planners (TP) and Transmission Operators (TOPs) are
requested to provide information on the potential impacts of the proposed Distribution Provider
(DP) thresholds explained on pages A-6 to A-11 of the Design, and TOP Reliability Standard
applicability revisions in their footprints.
2. All commenters are invited to identify issues that should be addressed in the technical
assessments or provide technical assessments to measure potential impacts on BES reliability from
the proposed registration reforms.
3. All commenters are invited to identify any other registration design reforms that may be needed in
addition to those set forth in the draft design framework.
Comments must be submitted via the electronic comment form by 8:00 p.m., Eastern on June 23, 2014.
Reliability Standard Applicability Questions
1. With respect to Transmission Operators (TOPs) that operate limited BES elements, is there a
smaller subset or group of Reliability Standards that can be applied prospectively to address the
risks posed by a TOP that operates limited BES transmission Facilities?1
See pages A-13 to A-16 of the Design Document for current proposal
Yes
No
Comments:
1
The draft Design Document includes an initial list of the subset of otherwise applicable requirements that could be applied to low-risk TOPs
that operate limited transmission facilities. The following two standards already apply to subsets of TOPs: EOP-004 on disturbance reporting
(reporting bright-lines) and MOD-001-2 on ATC (e.g., only if there is an ATC path). The following standards are proposed to apply to all TOPs
regardless of risk: BAL-005 R1, within the metered boundaries; EOP-001 on Emergency Plans; EOP-003 on Load Shedding Plans; FAC-014 on
SOLs; IRO-001 and IRO-004 on reliability directives; IRO-005 on SPSs and operating to within limits; IRO-010 on data specifications; NUC-001;
PER-001 on the authority of operators; PRC-001 on coordination of protection systems; PRC-010 and PRC-022 on UVLS; TOP-001-1; Most of
TOP-002-2; TOP-003; TOP-005-2; TOP-006-2; and TOP-007-0.
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2. With respect to Transmission Owners (TOs) that own limited BES elements, is there a smaller
subset or group of Reliability Standards (in addition to FAC-001) that can be applied prospectively
to address the risks posed by a TO that owns limited BES transmission Facilities?
See pages A-11 to A-13 of the Design Document for current proposal
Yes
No
Comments:
Purchasing-Selling Entity (PSE) Questions
Please use this section to provide any feedback that the RBRAG should consider in assessing whether to
remove PSE functions from the NERC Compliance Registry. Before the PSE function can be removed from
the NERC Compliance Registry, NERC must evaluate any potential gaps in reliability. Please provide a
detailed explanation of any potential gaps, and, if possible, please suggest a potential option for
mitigating any reliability concerns.
1. What reliability concerns should NERC consider in determining whether to remove the PSE
function from the NERC Compliance Registry? Please explain.
See page A-3 of the Design Document for the current proposal
Comments:
2. Does your entity currently use or plan in the future to use Dynamic Transfers (scheduling and
pseudo-ties)?2
See page A-3 of the Design Document for the current proposal
Yes
No
Comments:
2
There are several requirements that currently apply to PSEs in the INT family of Reliability Standards that focus on dynamic transfers. In order
to address the impact from retiring the PSE functions, the RBRAG must first make a recommendation on how to address the pertinent INT
Reliability Standards. Therefore, RBRAG seeks feedback on the number of entities using Dynamic Transfers today and where those entities
are located.
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3. If PSEs were removed from the NERC Compliance Registry and the related standards moved to a
NAESB Standard(s) or business processes, what gaps (e.g. unscheduled or parallel flows), if any,
might result that could impact the Reliable Operation of the Bulk-Electric System? Please explain.3
See page A-3 of the Design Document for the current proposal
Comments:
Interchange Authority/Coordinator (IA) Questions
Please use this section to provide any feedback that the RBRAG should consider in assessing whether to
remove the IA function from the NERC Compliance Registry. Before the IA function can be removed from
the NERC Compliance Registry, NERC must evaluate any potential gaps in reliability. Please provide a
detailed explanation of any potential gaps, and, if possible, please suggest a potential option for
mitigating any reliability concerns.
1. What reliability concerns should NERC consider in determining whether to remove the IA function
from the NERC Compliance Registry, as the IA functions would be removed from the remaining CIP
standards and the existing BA function and applicable BA standards manage interchanges? Please
explain.
See page A-3 of the Design Document for the current proposal
Comments:
Load-Serving Entity (LSE) Questions
Please use this section to provide any feedback that the RBRAG should consider in assessing whether to
remove the LSE functions from the NERC Compliance Registry. Before the LSE function can be removed
from the NERC Compliance Registry, NERC must evaluate any potential gaps in reliability. Please provide a
detailed explanation of any potential gaps, and, if possible, please suggest a potential option for
mitigating any reliability concerns.
1. Are there any material reliability gaps created by removing the LSE function from the NERC
Compliance Registry? Please explain.
See pages A-3 to A-6 of the Design Document for current proposal
Yes
No
Comments:
3
The RBRAG seeks feedback to determine if the PSE Standards that exist today should be moved to a NAESB standard or business processes.
RBRAG also seeks feedback on whether a reliability gap would be created by transitioning to a NAESB standard or process.
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2. If the LSE function were removed from the NERC Compliance Registry, do you still need NERC
Reliability Standards to require an entity to provide load data, as it is proposed to reassign the
existing LSE standards to other functions? Please explain.
See page A-5 of the Design Document for current proposal
Yes
No
Comments:
3. Will any critical emergency services be lost if LSEs are removed from the NERC Compliance
Registry and the existing LSE standards are reassigned to other functions?
See pages A-5 to A-6 of the Design Document for current proposal
Yes
No
Comments:
Distribution Provider (DP) Questions
1. Are there any material reliability gaps created by adjusting the thresholds for DPs from 25 MW to
75 MW4, while retaining and supplementing criteria for registration of DPs below that threshold
that own or operating protection systems important for BES reliability5, as proposed in the design
document?
See pages A-6 to A-10 of the Design Document for current proposal
Yes
No
Comments:
4 The proposed threshold would be “Distribution Provider system that is directly connected to the Bulk Electric System and that serves
>75 MW of peak Load.”
5 The proposed
threshold would retaining criteria covering entities that own or operating protection systems important for BES reliability (such
as Special Protection Systems (SPS), undervoltage load shedding (UVLS) and transmission Protection Systems), and add “DPs with field
switching personnel identified in the TOP’s restoration plan as performing unique tasks associated with that plan that are outside of the field
switching personnel’s normal task;” and “DP that is responsible for providing services related to Nuclear Plant Interface Requirements (NPIRs)
pursuant to an agreement executed pursuant to NUC-001.” Entities below the threshold are proposed to be registered as UFLS-Only
Distribution Provider if they 1) do not meet the registration criteria for a Distribution Provider; and 2) are the responsible entity that owns,
controls, or operates UFLS Protection System(s) needed to implement a required UFLS Program designed for the protection of the Bulk
Electric System.
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2. Are there any areas in North America where adjusting the thresholds for DPs in aggregate (or in a
specific location) would pose a material reliability gap to the BES?
See page A-7 of the Design Document for current proposal
Yes
No
Comments:
Please provide additional comments or suggestions to the registration criteria here:
Comments:
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