Nerc 101

NERC 101
Howard Gugel, NERC, Vice President of Engineering and Standards

Steven Noess, NERC, Director of Regulatory Programs
2019 Compliance and Standards Workshop
July 23, 2019
RELIABILITY | RESILIENCE | SECURITY

Agenda
• History of NERC
• ERO and ERO Enterprise
• Stakeholder Process
• NERC Board of Trustees
• Program Areas
2 RELIABILITY | RESILIENCE | SECURITY

History
• November 9, 1965 – Northeast Blackout

• 1968: National Electric Reliability Council established by the
electric industry
• 2002: NERC operating policy and planning standards became
mandatory and enforceable in Ontario, Canada
• August 14, 2003 – Blackout
• 2005: U.S. Energy Policy Act of 2005 creates the Electric
Reliability Organization (ERO)
• 2006: Federal Energy Regulatory Commission (FERC) certified
NERC as the ERO; Memorandum of Understanding (MOUs) with
some Canadian Provinces
• 2007: North American Electric Reliability Council became the
North American Electric Reliability Corporation (NERC)
ERO
• Section 215 of the FPA (16 U.S.C. § 824(o)) defines the ERO as
“the organization certified by the Commission . . . the purpose
of which is to establish and enforce reliability standards for the
bulk-power system, subject to Commission review”

ERO
• NERC is authorized to:

 Coordinate efforts to improve physical and cyber security for the bulk
power system;
 Conduct detailed analyses and investigations of system disturbances and
unusual events to determine root causes, uncover lessons learned, and
issue relevant findings as advisories, recommendations, and essential
actions to the industry; and
 Based on lessons learned, identify the potential need for new or modified
reliability standards, improved compliance, or other initiatives.

ERO
• As the international, multi-jurisdictional ERO, NERC is authorized

to:
 Propose, monitor compliance with, and enforce mandatory reliability
standards for the North American BPS, subject to regulatory oversight and
approvals of FERC in the U.S. and applicable authorities in Canada;
 Conduct near-term and long-term assessments of the reliability and future
adequacy of the North American BPS;
 Certify BPS operators as having and maintaining the necessary knowledge
and skills; and
 Maintain situational awareness of events and conditions that may threaten
reliability.

ERO Enterprise
• NERC provides delegated authority to Regional Entities (RE)

• Delegated functions:
 Compliance Monitoring and Enforcement
 Reliability Standards Development
 Organization Registration
 Reliability Assessments and Performance Analysis
 Training and Education
 Situation Awareness
 Infrastructure Security
• Regional consistency is key for transparency and predictability

NERC Funding
• NERC and Regional Entities allocate operating costs to load-

serving entities (LSEs):
 LSEs are owners, operators, and users of the BPS, responsible for
delivering electricity to retail customers.
• Budgets are approved by Federal Energy Regulatory Commission
(FERC) each year
 Individual Regional Entity budgets are submitted to NERC
 NERC reviews each individual budget, and sends to FERC as a
comprehensive budget for approval

ERO Enterprise

Stakeholder Process
• Through NERC’s technical committees, experts from all

segments of the electricity industry contribute their knowledge
to promote the reliability of the North American BPS
 Compliance and Certification Committee (CCC)
 Critical Infrastructure Protection Committee (CIPC)
 Operating Committee (OC)
 Personnel Certification Governance Committee (PCGC)
 Planning Committee (PC)
 Reliability Issues Steering Committee (RISC)
 Standards Committee (SC)

NERC Board of Trustees

NERC Program Areas
• Standards
• Compliance & Enforcement
• Reliability Risk Management
• Reliability Assessment and System Analysis
• System Operator Certification and Continuing Education
• Electricity Information Sharing and Analysis Center (E-ISAC)

Standards Framework
• Mandatory and enforceable to registered entities

• Reliability Standards define the reliability requirements for
planning and operating the North American bulk power system
• Requirements organized by topic areas (for example,
transmission operations, transmission planning, coordination,
communication, system protection, cybersecurity, etc.)
• Reflect a results-based approach that focuses on performance,
risk management, and entity capabilities
• Process includes opportunity for RE variances where necessary

Standards Topics
• Reliability Coordination
• Real-time Operations
• Transmission Planning
• Transmission Operations
• Generation Operations
• System Protection and Maintenance
• Training
• Infrastructure Protection
• Emergency Operations and System Restoration

Standards Committee
• Composed of industry-elected representatives

• Prioritizes standards development activities
• Reviews and authorizes Standard Authorization Requests (SARs)
• Manages progress of SARs and standards development efforts
• Reviews and authorizes drafting new or revised standards and
their supporting documents
• Makes appointments to standard drafting teams (SDTs)

Standards Development
• Fair, open, and balanced process that depends on stakeholder

input and participation
• Stakeholder technical expertise is essential to standard
development process
• Stakeholder drafting teams draft the standards
 Involves comment periods with formal review and response
 Approval achieved with two-thirds consensus vote
 Must be approved by NERC Board of Trustees and Applicable
Governmental Authorities
• Governed by Standard Processes Manual (SPM)

Standards Development Process

Standard Authorization Requests
• Required by American National Standards Institute (ANSI) to

document the scope and reliability benefit of a proposed project
• Must be accompanied by technical justification
• SAR can be submitted by anyone at any time
• Postings
 Informal
 Formal

Roles and Responsibilities of
Drafting Teams
• Develop an excellent, technically correct standard that helps

provide an adequate level of reliability and achieves consensus
 Stay within the scope of the SAR
 Address regulatory directives and stakeholder issues
 Consider Independent Experts’ Review Panel input
 Ensure standard meets criteria for approval
• Develop initial set of Violation Risk Factors (VRFs) and Violation
Severity Levels (VSLs) and associated reasoning
• Develop Implementation Plan
• Develop supporting documents (optional)
• Outreach

Drafting Team Formation and Support
• Drafting team chair

• NERC Standards Developer
• Compliance
• Subject Matter Experts (SMEs)
• Legal
• FERC staff observers
• Industry observers

Balloting
• Typically 45-day period

 45-day comment period
 10-day ballot
 These periods may vary due to waivers necessary to meet regulatory
directives or NERC Board deadlines
• Voting
 Must cast a vote for initial and additional ballots
• Consideration of comments
 The drafting team must communicate changes to stakeholders

Board Adoption
• Reliability Standards or revisions to Reliability Standards

approved by the ballot pool in accordance with NERC’s SPM shall
be submitted for adoption by the NERC Board of Trustees
• No Reliability Standard or revision to a Reliability Standard shall
be effective unless adopted by the NERC Board of Trustees

FERC Submission and Approval
• NERC Submits Petition for Approval of proposed Reliability

Standard to FERC for approval
• Petition must include a complete record of development for the
proposed Reliability Standard
• FERC must ensure that proposed Reliability Standards are just,
reasonable, not unduly discriminatory or preferential, and in the
public interest
• FERC will give due weight to the technical expertise of the
Electric Reliability Organization with respect to the content of a
Reliability Standard

• FERC “may approve, by rule or order, a proposed reliability

standard or modification to a reliability standard if it determines
that the standard is just, reasonable, not unduly discriminatory
or preferential, and in the public interest” (16 U.S.C. §
824o(d)(2) (emphasis added))
• FERC cannot write Reliability Standards
• FERC may approve or remand a Reliability Standard
 FERC “shall remand to the Electric Reliability Organization . . . a proposed
reliability standard . . . that [FERC] disapproves in whole or in part” (16
U.S.C. § 824o(d)(4))

• FERC may also direct modifications to a Reliability Standard

 FERC “may order the Electric Reliability Organization to submit to [FERC] a
proposed reliability standard or a modification to a reliability standard that
addresses a specific matter . . .” (16 U.S.C. § 824o(d)(5))

• Section 215(d) of the Federal Power Act states that FERC may
address a proposed Reliability Standard “by rule or by order”
• FERC staff will assign an “RM” prefix to rulemaking dockets (e.g.,
RM15-11-000)
• FERC staff will assign an “RD” prefix to order dockets (e.g.,
RD15-1-000)
• NERC petitions seeking approval of proposed Reliability
Standards are docketed by FERC staff generally within one week
of filing
• NERC petitions may be re-docketed (e.g., changed from
rulemaking to order) in rare cases

• Orders (RD dockets) are generally reserved for uncontroversial

NERC filings
• After docketing, FERC issues a notice setting a ~30 day deadline
for filing motions to intervene and comments
• If no protests are received, FERC staff, under the authority
delegated to the Director of the Office of Electric Reliability, may
issue a Delegated Letter Order approving the proposed
Reliability Standard
• FERC will issue a formal Commission order if protests are
received, FERC does not approve the proposed Reliability
Standard, or FERC otherwise determines that a Commission
order is appropriate
• FERC ex parte rules apply in contested Order dockets

• Rulemaking dockets are typically used for proposed Reliability

Standards that raise complex technical or policy issues
• Rulemakings involve issuance of a FERC Notice of Proposed
Rulemaking and a FERC Final Rule
• Notice of Proposed Rulemaking (NOPR)
 Identifies and explains FERC’s intentions regarding the proposed Reliability
Standards (e.g., proposes to approve Reliability Standard)
 Invites the submission of public comments on the NOPR
• Final Rule
 Addresses comments submitted in response to NOPR
 Makes final determinations regarding the proposed Reliability Standard
• FERC ex parte rules do not apply in rulemaking dockets

Petition Submitted RD or RM Docket No.

to FERC Assigned
Proceeding Type: RD RM
- Notice of Filing Issued - Notice of Proposed
Adjudication vs. - 30-Day Public Comment
Rulemaking Issued
- Public Comments
Rulemaking -Intervention required Requested (~60-days)
Delegated Letter Order Formal or Letter Order

issued by Office of issued by the full Final Rule
Final Action Electric Reliability Commission issued by the full
(no adverse comments (adverse comments filed Commission
filed) or by own election)

Compliance Foundations
• Energy Policy Act of 2005 – Federal Power Act section 215

• Rules of Procedure (ROP) – Section 400
 NERC oversight of Regional Entities
 Compliance program attributes (audit cycles, independence,
confidentiality)
 ROP Appendix 4C, Compliance Monitoring and Enforcement Program
• Regional Delegation Agreements (RDA)
 Regional Entities “contract” with NERC
 Regional Entities must adhere to ROP

Compliance Foundations
• Compliance Monitoring and Enforcement Program (CMEP)

 Outlines Compliance Monitoring processes
 Provides guidance and requirements for each monitoring method
• CMEP also addresses:
 Enforcement actions
 Mitigations of violations
 Remedial Action Directives
 Data retention and confidentiality

Risk-based Compliance
• Registered Entity specific

 Inherent Risk Assessment (IRA)
 Compliance Oversight Plan (COP)
• ERO Enterprise Guidance Documents
 Overview of the ERO Enterprise’s Risk-Based CMEP
 ERO Enterprise Guide for Compliance Monitoring

Annual Guidance Documents
• Annual ERO Enterprise CMEP Implementation Plan

 Key components and themes
 Risk Elements and areas of focus for the year
 Regional CMEP Implementation Plans
o Region-specific Risk Elements and areas of focus for the year

Compliance Tools
• Compliance Monitoring Methods

 Compliance Audits
 Self-Certifications
 Spot Checks
 Self-Reports
 Periodic Data Submittals
 Complaints
 Compliance Investigations

Compliance Activities:
Audit
• Audits occur at least once every three years for Balancing

Authority (BA), Reliability Coordinator (RC), Transmission
Operator (TOP)
• Audits of other entities may occur based on entity IRA and
Compliance Oversight Plan (COP)
 Level of risk informs compliance monitoring tool and interval
• Regional Entities typically lead compliance audits, NERC and
FERC may observe
• Audit team composition and requirements described in CMEP
• Audits based on professional auditing standards

Compliance Audit Cycle
Audit
Audit
Cycle
Cycle
Fieldwork

Compliance Audit Cycle
• Pre-audit:
 Regional Entity performs Inherent Risk Assessment (IRA) to determine audit scope
 Audit team assembled
• Planning:
 90-day notification letter delivered
 Team develops understanding of entity and makes data requests
• Fieldwork:
 Actual audit starts, interviewing and testing begins
• Reporting:
 Reports include Findings, Recommendations, and Areas of Concern
• Performance Assessment:
 Regional Entity reviews workpapers, identifies lessons learned, and process
improvement

Self-Certifications
• Regional Entities will notify registered entities about self-

certifying compliance to selected Reliability
Standard/Requirement
 Refer to Regional Annual CMEP Implementation Plans
 Regional Entities also follow notification process in CMEP
• Registered entities must identify non-compliance when
identified
• May request additional information

Spot Checks
• Regional Entity may conduct a spot check at any time to

determine compliance with any Reliability
Standard/Requirement
 Typically narrower scope than an audit
 May result after an event, system disturbance, compliance issue, or to
ensure mitigation of previous findings
 Regional Entities follow process in CMEP
 May be used in lieu of an audit

Self-Reports
• Entities should make a self-report once it becomes aware it:

 Has/may have violated a Reliability Standard or Requirement
 The Violation Severity Level (VSL) of a previously reported violation has
changed
• Regional Entities have self-reporting processes entities must
follow
 Regional Entity makes available self-report forms
 Entity should provide relevant documentation to support filing
 Regional Entity will review information to evaluate compliance and needed
mitigation

Periodic Data Submittals
• Certain Reliability Standards contain Periodic Data Submittal

(PDS) requirements
• NERC and Regional Entities may also identify PDS
• NERC and the Regional Entities notifies entities of PDS
requirements
 Refer to Annual CMEP Implementation Plan
 Refer to NERC and Regional Entity websites
• NERC and the Regional Entities collects PDS and reviews for
compliance

Complaints
• Entities/third parties may submit complaint to NERC or a

Regional Entity
• Complaints may be made through compliance hotlines, emails,
or other contact methods
• Complaints may trigger spot check or investigation
• Any findings resulting from a complaint are processed similarly
to an audit finding or spot check finding

Compliance Investigations
• May be triggered by events

• Confirm suspected non-compliance
• Specific scope at onset but scope can change
• Generally led by Regional Entity staff
 Will always have NERC participation
 Most likely will have FERC observers
• Confidential, unless conducted in response to FERC directive

Reliability Risk Management

SAFNRv2: Voltage Contour
US voltage contour (200kV+), May 29, 2013, 1116 EDT

SAFNRv2: Details
Pittsburgh, PA - May 29, 2013, 1119 EDT

Genscape PowerRT

Tools: Resource Adequacy

Tools: FNet

Tools: DOE EAGLE-I

Tools: Weather Forecasting

Tools: Space Weather

Tools: Social Media

Future Tools: PMUs for SA

Event Analysis
Safety Check
Peer Check

Event Analysis (2018, Trends, Causes)

2014-2018 Event Analysis Trends

Primary Data Sources

Deviation from Normal 2015 1st
quarter

NERC: Outages vs Temperature

Performance Analysis
Application Management
Data Management
Areas of
Focus
Application Support
Stakeholder Engagement
Analysis and Reporting

Application Management:
Data Collection Applications
• Five active data collection applications

 OATI-developed and hosted
o TADS: 2008
o DADS: 2011
o GADS: 2012
 NERC-developed and hosted
o MIDAS July 2016 -> MIDAS Portal October 2017
o GADS Wind February 2017 -> GADS Wind Portal TBD
• Data Request Development – New data collection efforts
 Geomagnetic Disturbance
 GADS Solar
 Energy Storage

Application Support
• Support
 Over 5,000 users across six applications
• Training
 Annual in-person training sessions
• Documentation
 Data Reporting Instructions updated annually
• Application web pages
 Regional Contacts
 Frequently Asked Questions
 Dashboards, Analysis, and Summary Data

Stakeholder Engagement
• Liaisons for Planning • ERO Enterprise

Committee groups with  Regional entity application group
performance analysis  Data warehouse and analytics
functions • FERC Staff
 Performance Analysis
• Industry Outreach
Subcommittee (PAS)
 Third-party GADS vendors
 Working Groups/Task Forces
 IEEE
o DADS Working Group
o GADS Working Group  American Wind Energy Association
– Conventional and Wind Generation (AWEA)
o MIDAS Working Group  Energy Systems Integration Group
o TADS Working Group (ESIG)
o GMD Task Force o Formerly UVIG: Utility Variable-
Generation Integration Group
 Forums such as NATF and NAGF
 Carnegie Mellon University
Analysis and Reporting

Reliability Indicator – Weighted Effective
Forced Outage Rate, Conventional

200 kV+ Outages by Cause Code

Reliability Indicator – Protection System
Misoperation Rate
Annual Protection System Five-Year Protection System

Misoperation Rate Misoperation Rate by Region
Q4 2013 through Q3 2018

Misoperation Rates Continuing to
Decline

Continued Decline in Average
Transmission Outage Severity

Reliability Indicator –
Frequency Response
2018 Frequency Response Performance Statistics and Trend Assessment

2018 OY Arresting Period Performance 2018 OY Stabilizing Period Performance
Interconnection Mean UFLS Lowest UFLS 2014–18 OY Mean IFRMA-B Lowest IFRMA-B 2014–18 OY
Margin (Hz) Margin (Hz) Trend (MW/0.1 Hz) (MW/0.1 Hz) Trend
Eastern 0.458 0.404 Improving 2,411 1,141 Stable
Texas 0.594 0.498 Improving 940 562 Improving
Quebec 1.075 0.678 Improving 862 364 Improving
71 Western 0.405 0.246 Stable RELIABILITY
1,789 | RESILIENCE890 | SECURITY
Improving
Severity Risk Index (SRI) - Sorted

Severity Risk Index (SRI) –
Cumulative

Reliability Assessment and
System Analysis – RASA Key Objectives
• Independently assess and report on the overall reliability,

adequacy, and associated reliability risks
• Identify emerging reliability risks and other reliability issues
garnering an in-depth analysis
• Evaluate system models and case development practices
• Conduct and coordinate interconnection-wide analysis for
steady-state power flow, frequency response, transient and
voltage stability, oscillatory behavior, and event forensics
• Establishment of reliability leadership and sound guidance
through effective outreach and communications that influence
industry and policy maker decisions

Why Reliability Assessments?
Each year, we publish the most cited and

What?
credible report on Bulk Power System
Reliability in North America
We do this by enabling others to make How?

better and more informed decisions
Everything we do helps Why?

ensure that the lights stay
on today and in the future
Rules of Procedure:
Independently assess and report on the overall reliability, adequacy, and associated
76
reliability risks impacting the North American BPS.
RELIABILITY | RESILIENCE | SECURITY
Assessments Serve as Early Warning
Indicator
• Is there sufficient supply of resources?

• Is transmission being expanded to
support new system resources?
• How does DER impact reliability?
• Do state regulators need to step in to
mitigate a potential risk?
• Will there be enough natural gas to
power the transitioning resource mix?
• Do the markets have the tools needed
to preserve reliability?
• How will a federal policy impact
reliability?
RAPA: Everything We Do
We work with industry’s best experts in reliability to fulfill our statutory obligations of
independently assessing the BPS through effective and efficient processes with our
Regional partners.
Technical Reliability ERO

Committee Assessment Management
Material Reports and
Oversight
• Technical • Independent evaluation • Ensuring Regional
Leadership/Strategy • Policymaker outreach representation
Activities
Program
• Work-plan development • Data analytics and • Implementing Oversight

• Group coordination trending Plan
• Supporting analysis • Coordination with • Coordination through
technical teams ERO groups
Deliverables
• Technical Reference • LTRA • Oversight Plan, Annual

Documents • Seasonal Assessments Metrics
• Reliability Guidelines • Special Reliability • Reliability Assessment
• Whitepapers Assessments Process
Independent Reliability Assessments
Three key reports produced annually:
Long-Term Provide a technical platform for important policy

discussions on technical challenges facing the
Assessment interconnected North American bulk power system
Seasonal Identify and report on the electric industry’s preparations

to manage potential seasonal issues for both the winter
Assessments and the summer
Special and As emerging risks and potential impacts to reliability are

identified, special assessments are performed to provide
Scenario additional insights about the range and specific aspects of
Assessments these challenges and make recommendations

Reliability Assessment Program

Reliability Assessment Focus Areas
• Changing Resource Mix

 Retirement of synchronous generation
 Increasing dependency on natural gas, wind, and solar
 Maintaining fast-acting controllable resources to support more variability
• Resource Adequacy Challenges:
 2018 Findings: Tight conditions in ERCOT and CAISO
• Accommodating large amounts of Distributed Energy Resources
• Advance NERC’s Analytic Capability
 Probabilistic Assessment
 Evaluation of Essential Reliability Services

What’s Changing?
• Higher penetration of renewables – variable resources

 Most are inverter‐connected
 Ramping needs increase for load following
 Capacity value
• Retirement of large fossil‐fired generation plants
• Changing System Inertia
 Trade‐offs between inertia and Fast Frequency Response
• Emergence of distributed energy
• Loss of dynamic reactive support for voltage control
 Lower levels of synchronizing torque
 Increasing use of power electronics
• Increasing energy constraints from the generation fleet

Peak Demand Growth Continues to
Decline
• Energy efficiency and conservation programs increase

• Continued growth in distributed photovoltaic solar and other
behind-the-meter resources
NERC-Wide Demand; 10-Year Growth Rates for Summer and Winter
225 2.2%
200 2.0%
1.8%
175
1.6%
150 1.4%
125 1.2%
CAGR
100 1.0%
GW
75 0.8%
0.6%
50
0.4%
25 0.2%
0 0.0%
1990-99
1991-00
1992-01
1993-02
1994-03
1995-04
1996-05
1997-06
1998-07
1999-08
2000-09
2001-10
2002-11
2003-12
2004-13
2005-14
2006-15
2007-16
2008-17
2009-18
2010-19
2011-21
2014-23
2015-24
2016-25
2017-26
2018-27
2019-28
2013-22*
10-Year Summer Growth (MW) 10-Year Winter Growth (MW)
83 Summer CAGR (%) WinterRELIABILITY
CAGR (%) | RESILIENCE | SECURITY
2018 Long-Term Reliability
Assessment Key Finding
Tier 1 and 2 New Peak Assessment Areas with More Than 50% Natural
Capacity Additions – 10 Year Gas as a Percent of Total Capacity
Assessment 2022 (MW) 2022 (%)
200,000 Area
180,000
FRCC 42,003 78.1%
160,000
140,000 WECC-CAMX 42,536 68.2%
120,000
Texas RE- 51,867 63.3%
100,000 ERCOT
80,000 NPCC-New 16,308 52.3%
60,000 England
WECC-SRSG 16,774 51.8%
40,000
20,000 WECC-AB 8,514 51.8%
0
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028
Natural Gas and Other Gases Solar • 96 GW of natural gas in next 5

Wind
Hydro
Nuclear
Coal
years, NERC-Wide
Biomass Petroleum
Pumped Storage Other

System Analysis Strategic Goals
1. Improve power system models and modeling cases

2. Understand changing grid characteristics, behaviors and
performance through advanced analysis
3. Provide superior technical analysis and engineering support
for ERO initiatives
4. Advance industry and technology through leadership in
technical communities (e.g., IEEE, CIGRE)
Vision: Be the leader in enhancing NERC’s analytical capabilities

across broad range of engineering topics and act as the go-to
‘brain trust’ for advanced system studies or modeling

System Analysis
• Synchrophasor technology
• Inverter-based resource performance
• Power plant model verification
• Oscillation analysis
• Power plant modeling and performance
• Load and distributed resource modeling
• Transmission planning expertise
• Frequency and control analytics
• Case quality metrics and model validation
• Event analysis and forensics – simulation of events
• Industry technical leadership – drive initiatives
• Standards support – engineering
1-Model Improvement
• Assess and improve power system models and practices

 PMU-based power plant and system model verification
 Dynamic load modeling
 Power plant model verification
 Hybrid planning-operations models
• Provide feedback loop to ensure high model quality and fidelity

 Review industry practices, available analysis
 Leverage on available studies to identify benefits
 Develop notifications for model use

2-Power System Analysis
• Perform advanced engineering analysis to understand changing

grid characteristics, behaviors and performance
 Frequency Response and Inertia—trends for critical contingencies in each
interconnection under future resource mixes
 Inter-Area Oscillation—Mode shape, frequency, and damping margin
needed for the largest damping change in each interconnection
 Voltage and reactive support—Minimum dynamic reactive support
needed for voltage excursions
 Short circuit strength—Grid strength indicators

3-Technical Support and Outreach
• Provide technical expertise, research, and insights

 Technical References, Reliability Guidelines, whitepapers
 Technical support for Reliability Standards
 Transition insights from engineering analysis to actionable industry guidance
 Partner with research and academic institutions

4-Advance Industry and Technology
• Advance industry and technology through leadership in technical

communities, such as:
• North American Synchrophasor Initiative (NASPI)
• IEEE & CIGRE
• WECC JSIS
• WECC MVWG/PPMVDTF/REMTF/LMTF
• Eastern Interconnection Reliability Assessment Group (ERAG)
• Multi-Regional Working Group (MMWG)
• NPCC SS-38 & LMTF
• ERCOT Dynamics Working Group (DWG)
• Academics & National Labs
• Department of Energy (DOE)
• North American Transmission Forum (NATF)
• North American Generator Forum (NAGF)
Blue Cut Fire
Disturbance Report & Alert

Canyon 2 Fire
Disturbance Report & Alert

2017 Long-Term Reliability Assessment:
Significant DER Expected in Near Future
• Solar PV continues to expand at a rapid pace Over 100

• Visibility is needed to plan and operate the GW by
bulk power system 2022 when
considering
utility-scale
PV

NERC Planning Committee

Reliability Guidelines
• What are Reliability Guidelines?

 Suggested approaches or behavior in a given technical area for the
purpose of improving reliability
 Not standards, binding norms, or mandatory requirements
 May be adopted by industry entities
• How are they developed?

 OC/PC/CIPC sponsored, technical groups author
 Approval needed for 45-day public comment period
 Comments and responses posted
 Approval by the sponsoring committee
 Comments may be submitted at any time

Personnel Certification Program
Personnel Certification
• “Maintaining the reliability of the Bulk Electric System through
implementation of Reliability Standards requires skilled, trained
and qualified system operators.” (Section 601 Scope of Personnel
Certification)
 International in scope
 Provides a mechanism
 Awards Certification Credentials

NERC Personnel Certification
Governance Committee (PCGC)
• Provides oversight to the policies and processes used to

implement and maintain the integrity and independence of
NERC’s System Operator Certification Program
• Structure of the PCGC shall be implemented and maintained so
that policies and procedures are established to protect against
undue influence that could compromise the integrity of the
System Operator Certification process
https://www.nerc.com/comm/PCGC/Pages/Charter.pdf

PCGC Membership Representation
• 10 voting members from the U. S. and Canada:
• Each member maintains a current NERC System Operator Credential

• The Federal Energy Regulatory Commission (FERC) and other governmental
authorities in Canada have the option of having a non-voting member.

PCGC: Exam Working Group
• Exam Working Group (EWG)

 Responsible for development and maintenance of the System Operator
Certification exams under the general guidelines set by the PCGC
 Recommend Exam Cut Scores
• Membership:
 Minimum of 12 Members
 All members hold a current NERC System Operator credential
 Subject matter experts in real time control centers or operational support
personnel
https://www.nerc.com/comm/PCGC/EWG%20DL/EWG%20Scope%20Final_Revised_No
v_2017.pdf

Exam Development and
Maintenance Cycle

Recent PCGC Projects
• Linear On-The-Fly Testing (LOFT) – 2016

• System Operator Certification Continuing Education Database
(SOCCED) Transition – 2017
• System Operator Certification Program Survey – 2017

Linear on the Fly Testing (LOFT)
• Benefits of LOFT:
 Reduced the exam development cycle from three year to real time
 Elimination of fixed forms has increased the integrity of the exams
 Item Bank currently maintained at a minimum of 3 items per task
 Ability to update exams as Standards are created or deactivated
 Implemented Q1_2017
o New Content Outlines
o New Cut Scores
Fixed Form Exams Real Time Exam Creation

SOCCED
• Previous Platform
 Multiple Tables of Same Data
 Old Technology
 System was not user-friendly
 Support from existing vendor was inadequate
 Improvements to system were costly
• Credential Maintenance Database – New Platform
 Deployed December 2017
 Current Technology
 One Source for Data
 Improved Accuracy

System Operator Certification Program
Survey
• Purpose was to gather information from industry stakeholders

related to the evolving NERC System Operator Certification
program
 Use of one credential was launched in 1998 with a 5-year expiration
 This credential was expanded to four credentials in 2001
 Credential maintenance was implemented in 2005 in lieu of testing
• The collected information was used to determine potential
future development and improvement of the program

Current State
Four System Operator Exams/Credentials:

• Reliability Coordinator (RC)
 200 Continuing Education Hours (CEHs)
• Transmission Operator (TO)
 140 CEHs
• Balancing, Interchange and Transmission Operator (BT)
 160 CEHs
• Balancing and Interchange Operator (BI)
 140 CEHs

Future State
At this time, the only proposed changes to the program are one
credential and the required CEHs to maintain this credential.
• One Credential:
 NERC Certified System Operator (NCSO)
 140 CEHs

SOC Program Highlights
• 1998: System Operator Certification Program established

• 2001: 4 Credentials with 3 year expiration
• 2005: Credential maintenance in lieu of retesting
• 2006-2014: Focused on Exam Development
• 2015-2017: Strategic Plan
• 2017- Q1_2018: System Operator Certification Program Survey
• 2018: Survey Analysis and Develop One Credential Whitepaper
• 2019: Whitepaper/Credential Maintenance Analysis
• 2021-2021: Update program

Mission and Vision
Mission
The E-ISAC reduces cyber and physical security risk to the
electricity industry across North America by providing
unique insights, leadership, and collaboration
Vision
To be a world-class, trusted source for quality analysis and rapid
sharing of security information for the electricity industry
108 TLP:GREEN RELIABILITY | RESILIENCE | SECURITY

• Established in 2014; revised in 2015
• Covers all NERC personnel
• Technical and administrative controls
• Analogous to FERC Standards of
Conduct for Transmission Providers
• Full document available here

Traffic Light Protocol (TLP)
“Originator-controlled classification system developed to encourage greater

sharing of sensitive (but unclassified) information with external entities.”
https://www.us-cert.gov/tlp

Strategic Plan Background
• The E-ISAC underwent a strategic review with the Electricity

Subsector Coordinating Council (ESCC) in 2015
• The ESCC created the Member Executive Committee (MEC),
which is a CEO-led stakeholder advisory group
• The MEC provided input into the E-ISAC Long-Term Strategic
Plan, developed in 2017
• The NERC Board approved the plan in 2017 and included it in
the NERC Business Plan and Budget for implementation in 2018
and beyond
• The E-ISAC continues to grow in both staff, tools, and
capabilities to realize its vision

Strategic Plan
Vision: To be a world-class, trusted source for quality analysis
and rapid sharing of security information for the electricity
industry
E-ISAC Strategic Plan Supported by:
• NERC Board of Trustees
• Electricity Subsector Coordinating Council (ESCC)
• ESCC Members Executive Committee (MEC)
Information Sharing Analysis Engagement
Build trust and

show value
Accelerate sharing Enhance Improve
and high priority portal information flow
notifications and security
Hire and develop Leverage Prioritize Metrics Evaluate

exceptional information sharing products and benchmarking 24x7
employees technologies and services Operations
CRISP CYOTE CAISS Strategic
resources (future)
Vendor
Partnerships to enhance
analytical capability
World-Class ISAC

Getting Started
• Request an account at
www.eisac.com
• Download our brochure

for more information

Products and Services
Products
• Incident (cyber and physical) bulletins
• Weekly and monthly summary reports
• Issue-specific reports
Services
• Monthly briefing series
• Grid Security Conference (GridSecCon)
• Grid Security Exercise (GridEx)
• Industry Engagement Program (IEP)
Tools
• E-ISAC Portal (www.eisac.com)
• Critical Broadcast Program (CBP)
• Cyber Risk Information Sharing Program (CRISP)
• Cyber Automated Indicator Sharing System (CAISS)

Key Activities
E-ISAC CBP
• Launched rapid information sharing call capability in 2018:
 February 7: Need info here
 November 29: vendor compromise (524 participants)
 December 20: Indictments of Advanced Persistent Threat Actors (1,284 participants – including
Oil and Natural Gas industry)
• All-Points Bulletins
 Part of the CBP; used to alert industry on critical, time-sensitive security events
 Provide additional context and mitigation on time-sensitive issues beyond a traditional cyber or
physical bulletin without need for a CBP call
Customer Relationship Management (CRM) Tool

• Will enhance how the E-ISAC interacts and serves members
Portal Upgrades
• Developing updated Portal governance and security controls will further
safeguard sensitive security information
IEP
• Established in 2018
• Formerly known as the Industry Augmentation Program
• Multi-day immersive learning experience at the E-ISAC
• Raise awareness of E-ISAC cyber and physical security analysis
processes
• Enhance information exchange between the E-ISAC and industry
• Increase the opportunities for the E-ISAC to receive specific
feedback from industry on tools and communications protocols
• Strengthen utility programs and staff expertise by providing a
professional development opportunity
• Six IEPs held each year

GridEx
• GridEx is an unclassified public-private exercise designed to

simulate a coordinated cyber and physical attack with
operational impacts on electric and other critical
infrastructures across North America to improve reliability,
resilience, and security
• The first GridEx occurred in 2011 and is conducted every other
year
• Due to the sensitive nature of the scenario discussion, this
exercise program is not open to the general public or the media
• The GridEx planning team designs the exercise to allow each
organization to participate in a way that is consistent with its
available resources and real-world operational environment

GridEx Components
Move 0 Distributed Play Executive Tabletop

Pre-Exercise (2 days) (1/2 day)
Preparation Utilities
Executive Tabletop
E-ISAC
Reliability Injects and and
Coordinators info BPSA
Identification sharing
by email
and phone
Support
and Fed/State/Prov
Agencies
Containment Vendors
Operators may participate in Players across the stakeholder Senior decision makers
Cyber Intrusion detection landscape will participate from participate in facilitated
activities their local geographies discussions to review
distributed play and explore
policy triggers

GridEx Communications
NERC Electricity Sub-sector Energy GCC Executive

Coordinating Council (ESCC) Other SCCs Coordination
Crisis Action Team
Trade
Regional Entities Unified Coordination Group (UCG) or
Associations
non-US equiv.
Other Federal Agencies

NERC E-ISAC DHS
DOE US: FBI, FERC, DOD
Bulk Power Electricity NCCIC Canada: Public Safety
System Information Department
ICS-CERT Canada, NRCan, RCMP, CSIS,
Awareness Sharing and of Energy
US-CERT CCIRC
(BPSA) Analysis Center
Coordination
with
Government
Local,
Vendor Electricity Industry State/Provincial
Support Government
IT, ICS, ISP, Coordinated Operations • Emergency
Anti-virus Management
Organizations
Reliability Coordinators,
• Emergency
Other Critical Balancing Authorities, Asset Operations
Infrastructures Owner Operators Centers / Fusion
Telecommunications Centers
Oil & Gas • Local FBI, PSAs
others • National Guard
• PUCs, PSCs
ExCon
GridEx IV Exercise Control
NERC staff, GEWG, Nat’l Labs, SMEs for Sim-cell, etc.

GridEx IV (2017) – Key Findings
• Participating organizations complete an after-action

survey and share lessons learned following each
exercise
• GridEx IV had the following key findings:
 Relationship building with partners is key (e.g.,
cross-sector, law enforcement, emergency managers)
 E-ISAC Portal improvements needed
 Public Affairs and Corporate Communications vs.
incorrect or misleading information important
 Communication resiliency necessary for response
 Electric Utility – Reliability Coordinator emergency
communications critical
 Cyber Mutual Assistance can aid response
 On-keyboard cyber training important to utilities

GridEx V – November 13-14, 2019
• Industry participants are able to engage

from their regular work locations and
respond to simulated events during the two-
day exercise
• Participants respond with simulated internal
and external operational activities as they
would during an actual event
• Participants include:
 Electric utilities;
 Regional (local, state, provincial) and federal
government agencies in law enforcement, Critical
infrastructure cross-sector partners (ISACs and
natural gas transmission pipeline operators); and
 Supply chain stakeholder organizations
GridSecCon 2019

E-ISAC Key Takeaways
• Reliability, resilience, and security

• E-ISAC and NERC departments should, and do work together –
carefully, and with limits
• In the second year of the E-ISAC Long-term Strategic Plan, the
E-ISAC continues to grow in staff, capability, and impact
• The E-ISAC Portal is the central location for security information
and products
• GridEx and GridSecCon are valuable sources of security
information
• Cyber and physical security risk continues to grow as foreign
nation-state adversaries target critical infrastructure


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NERC 101

Howard Gugel, NERC, Vice President of Engineering and Standards

RELIABILITY | RESILIENCE | SECURITY

2 RELIABILITY | RESILIENCE | SECURITY

• November 9, 1965 – Northeast Blackout

4 RELIABILITY | RESILIENCE | SECURITY

• NERC is authorized to:

5 RELIABILITY | RESILIENCE | SECURITY

• As the international, multi-jurisdictional ERO, NERC is authorized

6 RELIABILITY | RESILIENCE | SECURITY

• NERC provides delegated authority to Regional Entities (RE)

7 RELIABILITY | RESILIENCE | SECURITY

• NERC and Regional Entities allocate operating costs to load-

8 RELIABILITY | RESILIENCE | SECURITY

9 RELIABILITY | RESILIENCE | SECURITY

• Through NERC’s technical committees, experts from all

10 RELIABILITY | RESILIENCE | SECURITY

11 RELIABILITY | RESILIENCE | SECURITY

12 RELIABILITY | RESILIENCE | SECURITY

• Mandatory and enforceable to registered entities

13 RELIABILITY | RESILIENCE | SECURITY

14 RELIABILITY | RESILIENCE | SECURITY

• Composed of industry-elected representatives

15 RELIABILITY | RESILIENCE | SECURITY

• Fair, open, and balanced process that depends on stakeholder

16 RELIABILITY | RESILIENCE | SECURITY

17 RELIABILITY | RESILIENCE | SECURITY

• Required by American National Standards Institute (ANSI) to

18 RELIABILITY | RESILIENCE | SECURITY

• Develop an excellent, technically correct standard that helps

19 RELIABILITY | RESILIENCE | SECURITY

• Drafting team chair

20 RELIABILITY | RESILIENCE | SECURITY

• Typically 45-day period

21 RELIABILITY | RESILIENCE | SECURITY

• Reliability Standards or revisions to Reliability Standards

22 RELIABILITY | RESILIENCE | SECURITY

• NERC Submits Petition for Approval of proposed Reliability

23 RELIABILITY | RESILIENCE | SECURITY

• FERC “may approve, by rule or order, a proposed reliability

24 RELIABILITY | RESILIENCE | SECURITY

• FERC may also direct modifications to a Reliability Standard

25 RELIABILITY | RESILIENCE | SECURITY

26 RELIABILITY | RESILIENCE | SECURITY

• Orders (RD dockets) are generally reserved for uncontroversial

27 RELIABILITY | RESILIENCE | SECURITY

• Rulemaking dockets are typically used for proposed Reliability

28 RELIABILITY | RESILIENCE | SECURITY

Petition Submitted RD or RM Docket No.

Delegated Letter Order Formal or Letter Order

29 RELIABILITY | RESILIENCE | SECURITY

• Energy Policy Act of 2005 – Federal Power Act section 215

30 RELIABILITY | RESILIENCE | SECURITY

• Compliance Monitoring and Enforcement Program (CMEP)

31 RELIABILITY | RESILIENCE | SECURITY

• Registered Entity specific

32 RELIABILITY | RESILIENCE | SECURITY

• Annual ERO Enterprise CMEP Implementation Plan