Recent FERC Activity Andy Dodge Director, Office of Electric Reliability Federal Energy Regulatory Commission May 14, 2020 The views expressed in this presentation are my own and do not represent those of the Commission or any individual Commissioner
Commission Actions on COVID-19 Pandemic • Pandemic Liaison Team created to coordinate answers to industry questions • Caroline Wozniak named as the Pandemic Liaison • Contact: PandemicLiaison@ferc.gov • OER contacts: Mark Hegerle and Kal Ayoub • Notice Granting Extension of Time, AD20-11-000 issued 3/19/20 • Extends deadline for filing forms, non-statutory filings (e.g., compliance filings, responses to data requests, rulemakings) until 5/1/20 • OER team proposed numerous other actions, including delay of effective date of certain Reliability Standards • Joint Commission-NERC Notice on regulatory 2 discretion issued 3/18/20
FERC, NERC Guidance to Ensure Reliability Amid Potential Coronavirus Impacts • On 3/18, FERC and NERC announced that they will use their regulatory discretion to ensure all registered entities can balance healthy workforce and reliability • Effects of coronavirus will be considered an acceptable basis for non-compliance with: • Obtaining and maintaining personnel certification to comply with PER-003-2 for the period 3/1/20 to 12/31/20 • Reliability Standard requirements involving periodic actions that would have been taken between 3/1/20 and 7/31/20 • Registered entities should notify their Regional Entities of any periodic actions that will be missed during this period • Regional Entities will postpone on-site audits, certifications and other on-site activities at least until 7/31/20 3 • FERC and NERC may extend these dates as needed
Further Commission Action to Prioritize Reliability and Provide Regulatory Relief • Policy Statement on Business Continuity of Energy Infrastructure issued 4/2/20 • Commission will give highest priority to processing filings made to assure the reliable operation of energy infrastructure during COVID-19 emergency • Facilitates social distancing by approving blanket waiver of tariff requirements on holding in-person meetings and requiring notarized documents through 9/1/20 • Prioritizes efficient processing of requests for waiver and other requests for relief: • Delegates authority to OEMR to act on uncontested requests for prospective waivers of certain regulatory obligations through 6/1/20 • Delegates authority to OEPI to act on motions for extension of time to file, or requests or petitions for waiver of the requirements of FERC Form No. 552 and FERC-730 • Extends time period for RTOs/ISOs to post Uplift Reports and Operator Initiated Commitment Reports • Grants extensions of time for certain non-statutory deadlines, waiving regulations and shortening answer periods for extensions of time due to COVID-19 4
Order Granting Deferred Implementation of Certain NERC Reliability Standards • Order RM15-4, RM16-22, RM17-13 and RD18-4 issued 4/17/20 • Grants three-month deferral of the implementation of Reliability Standards: • CIP-005-6 (Cyber Security – Electronic Security Perimeter(s)) • CIP-010-3 (Cyber Security – Configuration Change Management and Vulnerability Assessments) • CIP-013-1 (Cyber Security – Supply Chain Risk Management) • Grants six-month deferral of the implementation of Reliability Standards: • PRC-002-2 (Disturbance Monitoring and Reporting Requirements) • PRC-025-2 (Generator Relay Loadability) • PRC-027-1 (Coordination of Protection Systems for Performance During Faults) • PER-006-1 (Specific Training for Personnel) • Commission recognizes that registered entities have already taken steps to ensure effective and timely implementation of these standards • Deferred implementation is a proportionate and reasonable response to deal with COVID-19 that will allow registered entities to focus immediate efforts and resources on maintaining safety and ensuring reliability of the grid 5
Virtualization, Cloud Services for Power Grid Operations • NOI in RM20-8, RD20-2 issued 2/20/20 • Seeks comments on potential benefits and risks of virtualization and cloud computing services in the bulk electric system operations and barriers to FERC-approved Critical Infrastructure Protection (CIP) Reliability Standards • Poses questions on four general topics: • Scope of potential use of virtualization or cloud computing • Associated benefits and risks • Possible impediments to their implementation • Potential new and emerging technologies beyond virtualization • Cloud computing that responsible entities may be interested in adopting • The Commission will use the NOI to decide whether to direct NERC to develop modifications to the CIP reliability standards to facilitate the use of virtualization and cloud computing by grid users and operators • Comments were due 4/27/20; reply comments due 5/27/20 • Initial and reply comments in the Virtualization and Cloud NOI 6 extended to 7/1/20 and 7/31/20, respectively
Delays on Reliability & Security Related Actions • OER has postponed all on-site audit activities in coordination with NERC and the Regional Entities • Reliability Technical Conference postponed from 6/25/20 to a future date to be determined • Compliance filings related to the NERC Five-Year Performance Assessment extended to 6/1/20 and 9/28/20 • Initial and reply comments in the Virtualization and Cloud NOI extended to 7/1/20 and 7/31/20, respectively • Time extended for NERC/WECC filing related to BAL-002- WECC to 6/3/20 7
Transmission Incentives NOPR • NOPR in RM20-10 issued 3/20/20 • Proposes to revise existing regulations implementing section 219 of the FPA to align Commission policy with statutory mandate of ensuring reliability and reducing transmission congestion • Proposes to depart from the risks and challenges approach and instead focus on granting incentives based on economic and reliability benefits • NOPR proposes to provide incentives for: • Joining/remaining in an RTO/ISO (increased from 50 to 100 basis points) • Projects that meet a pre-construction benefit-to-cost ratio (50 pts) and projects that meet a post-construction benefit-to-cost ratio (50 pts) • Projects that demonstrate reliability benefits (up to 50 pts) • Technologies that enhance existing transmission facilities (100 pts) 8 • Comments due 7/1/20
Technical Conference on Storage as a Transmission Only Resource • Staff-led workshop in ER20-588 held 5/4 via WebEx • MISO has proposed to allow for the selection of a storage facility as a transmission-only asset (SATOA) in the MISO Transmission Expansion Plan (MTEP) • On 3/10, the Commission issued an order accepting and suspending the proposed revisions for five months and establishing a technical conference • Technical conference addressed: • Evaluation and selection criteria for SATOAs • SATOA market activities and market impacts • Cost recovery for SATOA • Impact on the generator interconnection queue • Operating guides for SATOAs 9 • Commission will consider post conference comments submitted on or before 5/25/20
Upcoming Conferences • Technical Conference on Increasing Market and Planning Efficiency and Enhancing Resilience through Improved Software • To be held 6/23/20 – 6/25/20 in AD10-12-011 via WebEx • Will explore research and operational advances with respect to market modeling with potential for efficiency or resilience improvements • Topics will include representation of physical constraints, managing uncertainty, grid enhancing technologies, system flexibility, et al. • Technical Conference on Hybrid Resources • To be held 7/23/20 in AD20-9-000 (location TBD) • Will discuss technical and market issues prompted by growing interest in projects comprised of more than one resource type at same plant location (hybrid resources) • Commission will focus on a generation resource and an electric 10 storage resource paired together as a hybrid resource
Commission Meetings • Commission meetings will be held in virtual format during COVID-19 pandemic • April Open Meeting was held in virtual format with virtual press conference • Next Commission meeting: 5/21/20 • Commission meetings will be held using virtual format for the foreseeable future 11
Stay Home, Stay Safe! • Thank you! • Questions? 12
Update on Cloud Computing Lonnie J Ratliff, Senior Manager, Cyber and Physical Security Assurance Member Representatives Committee Meeting May 14, 2020 RELI ABI LI TY | RESI LI ENCE | SECURI TY
FERC Notice of I nquiry Seeking benefits and risks with virtualization and cloud services • ERO Enterprise Collaboration Potential Risks Identified Current Standard considerations and impacts • Standard Drafting Team (SDT) focus Project 2016-02 - Virtualization Project 2019-02 - BES Cyber Security Information (BCSI) 2 RELI ABI LI TY | RESI LI ENCE | SECURI TY
Storage of BCSI • ERO Enterprise Practice Guide providing clarification Focus on the ability “ obtain and use ” Physical access compared to controls deployed to secure data (e.g., cloud storage) • Input to and collaboration with SDT 3 RELI ABI LI TY | RESI LI ENCE | SECURI TY
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