FERC Approval Still Pending for Second Phase of NERC’s Geomagnetic Disturbance Planning and Mitigation Program This Fall, FERC continues to deliberate on the approval of TPL-007-1, the standard to implement the second phase of NERC’s Geomagnetic Disturbance (GMD) program. While the initial Notice of Proposed Rulemaking (NOPR) comment period closed months ago, Congress has called on FERC to revisit the standard and ensure that it provides adequate protection for reliability. Recently FERC extended the comment period until October 22, 2015 to allow for additional commenters to submit their views regarding the GMD benchmark. Despite the current regulatory uncertainty, planning ahead to meet compliance obligations will support success. Background GMDs induce electric currents in the Earth’s surface. When these currents enter the power system, they disrupt protection systems and negatively impact large transformers. These events can cause power outages and lead to early failure of equipment that has a long lead time to replace and repair. Under TPL-007-1 owners and operators of the Bulk Power System are required to conduct initial and on-going vulnerability assessments of the potential impact GMD events may have on power system equipment and the power system as a whole. Utilities that do not meet the requirements under the standard, based on the results of their vulnerability assessments, must develop a plan to achieve the requirements. Many utilities and other organizations filed comments as part of the NOPR process both in support of the standard as written and proposing modifications to the standard. Some comments advocate for making the standard more stringent. In its NOPR FERC expressed some concerns and sought comments on the parameters used for the benchmark GMD event described in Attachment 1 of TPL-007-1. FERC noted that while there is limited historical geomagnetic data and scientific understanding of geomagnetic disturbance events, their concern related to the proposed Reliability Standard’s heavy reliance on spatial averaging. FERC proposed to direct NERC to make several modifications to better ensure that, going forward, the study and benchmarking of geomagnetic disturbance events are based on a more complete set of data and a reasonable scientific and engineering approach. FERC also proposed specific revisions to Requirement R7 of the proposed Reliability Standard to ensure that, when a utility identifies the need for a corrective action plan, the utility acts in a timely manner. NERC submitted comments supporting the standard as written and did not support the FERC proposals for change. For more information, please contact: Jim Whitaker, Supervisor of Power System Studies at jwhitaker@trcsolutions.com or 303.395.4018. New Mandatory Obligations In the second stage of NERC’s GMD regulatory program, utilities in the Planning Coordinator, Transmission Planner and Transmission Owner functions must identify benchmark GMD events and specify the magnitude of event a responsible entity must assess against. A vulnerability assessment1 is required for transformers with a high-side, wye ground winding with terminal voltage greater the 200kV2. If the assessments identify potential impacts, owners and operators are required to develop and implement corrective action plans to protect against instability, uncontrolled separation, or cascading failures of the BPS. Each utility that concludes through the GMD Vulnerability Assessment that their System does not meet the performance requirements must develop a formal Corrective Action Plan. The development of proactive strategies is based on the age, condition, technical specifications, system configuration, and location of specific equipment. These strategies could, for example, include: Consideration of automatically blocking geomagnetic currents from entering the BPS; Instituting more stringent specifications for new equipment; Improved spare equipment inventory management; and Isolating certain equipment that is not cost effective to retrofit. Regulated entities will need to review existing procedures or develop and implement new procedures in order to maintain compliance. Critical areas of attention include: Systems configurations Modeling and analysis Monitoring and measurement Mitigation planning 1 The study or studies shall include the following conditions: System On-Peak Load for at least one year within the Near-Term Transmission Planning Horizon; and System Off-Peak Load for at least one year within the Near-Term Transmission Planning Horizon. The study or studies shall be conducted based on the benchmark GMD event described in Attachment 1 of TPL007-1 to determine whether the System meets the performance requirements in Table 1 of TPL-007-1. The GMD Vulnerability Assessment shall be provided within 90 calendar days of completion to the responsible entity’s Reliability Coordinator, adjacent Planning Coordinators, adjacent Transmission Planners, and to any functional entity that submits a written request and has a reliability-related need. 2 The GIC application guide is available at: http://www.nerc.com/comm/PC/Geomagnetic%20Disturbance%20Task%20Force%20GMDTF%202013/GIC%20Application %20Guide%202013_approved.pdf For more information, please contact: Jim Whitaker, Supervisor of Power System Studies at jwhitaker@trcsolutions.com or 303.395.4018. NERC continues to support the industry with technical guidance in order to comply with the proposed standard. NERC is also raising awareness about the impact of GMD on the power system through information exchange and focused training between industry, researchers and policymakers. TRC Can Help While we await the outcome of FERC’s deliberations on the standard, it is not too soon to begin to develop your plans to address the new obligations. There is a great deal of modeling called for in the standard which may be unfamiliar to your current staff. TRC is well positioned to assist you with studies in this new area of utility planning. We have the engineering resources and experience to support your company’s vulnerability assessment and mitigation planning under TPL-007-1. Resources 2012 NERC Interim report on the Effects of Geomagnetic Disturbances on the Bulk power System FERC Order 799 Concerning GMDs NERC GMD Task Force page GMD Planning Guide NERC TPL-007-1 filing to FERC TPL-007-1 FERC NOPR on TPL-007-1 TRC NERC Compliance Support Services TRC Power Delivery Engineering Services About Us TRC’s Power Delivery Engineers provide full service transmission planning, consulting and construction management for utilities, municipalities and industry. Comprised of over 1,000 personnel, many of whom are experienced utility engineers, our project teams know how to plan, design, and install facilities that meet a client’s financial, technical, and scheduling goals. This regulatory update is a service to our utility clients, helping keep you informed of issues that impact your reliability risk and business goals. October 14, 2015 For more information, please contact: Jim Whitaker, Supervisor of Power System Studies at jwhitaker@trcsolutions.com or 303.395.4018.