FERC, NERC, FRCC, FPSC An Update

FERC, NERC, FRCC, FPSC

An Update

Florida Electric Cooperative AssociationEngineers Conference

June 13, 2012

Glenn SpurlockManager of Transmission PlanningSeminole Electric Cooperative, Inc.

FERC, NERC, FRCC, FPSCMajor Components of the electric Industry

1. Generation Resources2. Transmission System3. Distribution System


• 1935 Congress• Federal Power Act• Public Utility Holding Company Act• FPC (the predecessor to FERC) now had

responsibility to provide effective federal regulation of the expanding business of transmitting and selling of electric power in interstate commerce.

• Nov. 1965 - N. E. US & Canada Black Out• • Nov. 1965 - NERC Founded

FERC, NERC, FRCC, FPSC2003 N.E. U.S. and Canada Blackout

August 14, 200361,800 MW of load lost55 Million people affectedCost estimates between $7-14 bnLed Congress to pass EPAct 2005


Cleveland – August 14, 2003


• July 2006 - FERC certifies NERC as the ERO

• Sept. 2006 - FERC Issues NOPR to adopt Reliability Standards

• 1st Qtr 2007 - FERC Approves Reliability Standards Order 693

• June 2007 - NERC Begins ERO Operations

FERC, NERC, FRCC, FPSCNERC is the Electric Reliability

Organization (ERO)•Organizations were responsible to register and comply with Reliability Standards based on their functions

•The ERO delegated registration and compliance monitoring and enforcement to the Regional Entities (Florida Reliability Coordinating Council - FRCC)(Southeastern Electric Reliability Council – SERC)•

•Regional Entities maintain Compliance Registries listing Entities in their Regions performing various functions

FERC, NERC, FRCC, FPSC1. 2003 N.E. U.S. and Canada Blackout2. 2008 S.E Florida Blackout3. 2011 S.W. US Blackout4. Reliability Legislation5. ERO and Regional Entities6. Bulk Electric System Definition7. Compliance Registry8. Joint Registration9. Future of Reliability Standards

FERC, NERC, FRCC, FPSCReliability Prior to June 18, 2007

1.NERC Standards were good industry practice

2.NERC Standards were not mandatory

3.NERC Standards were not enforceable

FERC, NERC, FRCC, FPSCReliability After June 18, 2007

1.Mandatory compliance with Electric Reliability Organization (ERO) Standards

2.Monetary fines, non-monetary sanctions, operational restrictions are allowed penalty actions by RE, ERO, or FERC

3.Due process at the RE, ERO, then FERC

4.Standards apply to 15 different functional entities

FERC, NERC, FRCC, FPSCSeminole’s Registration

FERC, NERC, FRCC, FPSCFuture of Reliability Standards

•FERC and NERC have developed an aggressive plan for the drafting and adoption of new and revised Standards

•Penalties are now well-established

•The “courtship” period has ended; all registered entities are to have well-established compliance programs

FERC, NERC, FRCC, FPSC2008 S.E Florida Blackout

February 26, 2008

3,650 MW of load lost• 1350 MW of Direct Load Loss• 2300 MW of UFLS Load Loss3 Hours to Restore all Load

4,399 MW of Generation Lost

22 Transmission Lines Lost

24 Recommendations To Industry

FERC, NERC, FRCC, FPSC2011 S.W. US Blackout

September 8, 2011

7,835 MW of load lost2.7 Million people affected12 hours to Restore All Load

6,681 MW of Generation Lost87 hours to Restore All Generation

13 Hours to Restore All Transmission

27 Recommendations to Industry


Finding 3:

TOPs and RCs should ensure that their next day studies include all internal and external facilities (including those below 100 kV) that can impact BPS reliability.


Finding 6:

TOPs should expand the focus of their seasonal planning to include external facilities and internal and external sub-100 kV facilities that impact BPS reliability.


Finding 17:

WECC RC and affected TOPs and BAs do not consistently recognize the adverse impact sub-100 KV facilities can have on BPS reliability. As a result sub-100 kV facilities might not be designated as part of the BES, which can leave entities unable to address the reliability impact they can have in the planning and operations time horizons. If, prior to September 8, 2011, certain sub-100 KV facilities had been designated as part of the BES and, as a result, were incorporated into the TOPs’ and RC’s planning and operations studies, or otherwise had been incorporated into these studies, cascading outages may have been avoided on the day of the event.


Recommendation 17:

WECC, as the RE, should lead other entities, including TOPs and BAs, to ensure that all facilities that can adversely impact BPS reliability are either designated as part of the BPS or otherwise incorporated into planning and operations studies and actively monitored and alarmed in RTCA systems.

FERC, NERC, FRCC, FPSCNERC Standards Under Development

• COM-003 Operating Personnel Communications Protocols

• VAR-002 Interpretation

• PRC-005 Protection System Maintenance & Testing

• PRC-001 & PRC-027 System Protection Coordination


• COM-001, COM-002 and IRO-001-3 Reliability Coordination

• BAL-001-1, BAL-002-2, BAL-012-1, & BAL-013-1 Balancing Authority Reliability-based Controls: Reserves

• Cost Effective Analysis Process (CEAP) for NERC ERO Standards


• MOD-025-2, MOD-027-2, & PRC-019-1 Generator Verification

• Frequency Response

• CIP-002-5 through CIP-009-5, CIP-010-1, and CIP-011-1 Cyber Security

• CIP-001 & EOP-004 Disturbance Sabotage and Reporting


• Protection Systems (Misoperations)

• PRC-023 Transmission Relay Loadability

• EOP-03, PRC-006, PRC-007, & PRC-009 Underfrequency Load Shedding

• TPL Table 1, Footnote B Asses Transmission & Future Needs


• FAC-003 Vegetation Management

• Definition of Bulk Electric System – Rules of Procedure Modifications to Support BES Exceptions

• PRC-006 SERC Regional Reliability Standard

• PRC-006 NPCC Regional Reliability Standard

• Etc., Etc., Etc.

http://www.nerc.com/filez/standards/Rules_of_Procedure-BES.html

FERC, NERC, FRCC, FPSCFERC Activities

FPL Energy Imbalance Filing• Seminole has Intervened

PEF Wholesale CWIP Rate Case Filing• Seminole has Intervened


FERC Order 1000• Applies to entities with OATT filed at FERC• Requires Regional Planning• Requires Inter-Regional Planning

• Requires a non-discriminatory open, transparent, stakeholder involved process

• Must allow for non-incumbent transmission developers (removes ROFR for regional cost sharing projects)


FERC Order 1000 (continued)

• New Regional Cost Allocation methodology is applicable to the following categories of regional projects:

1. Reliability 2. Economic 3. Public Policy 4. Multiple Categories

FERC, NERC, FRCC, FPSCFPSC Activities

Proposed FPSC Workshop – 6/21/2012Rule 25-6.019 - Notifications of Accidents

Rule 25-6.0345 - Safety Standards for Construction of New Transmission and Distribution Facilities

Rule 25-6.0346 - Quarterly Reports of Work Orders and Safety Compliance

Rule 25-6.060 – Meter Test – Referee

FERC, NERC, FRCC, FPSC25-6.019 Notification of Certain Events Involving Electrical

Systems Accident

….. As soon as practicable, but by the end of the next business day after it learns of the occurrence, each investor-owned electric utility, rural electric cooperative, and municipal electric utility shall notify the Director of the Division of Safety, Reliability and Consumer Assistance Commission, in writing, using Form PSC/SCR 159 (XX/XX) of any event involving an accident occurring in connection with any part of the electrical system which: (a) Involves death or injury requiring hospitalization of non-utility persons, or (b) Is significant from a safety standpoint in the judgment of the utility even though it is not required by paragraph (a).

FERC, NERC, FRCC, FPSC25-6.019 Notification of Certain Events Involving Electrical

Systems Accident

.....Each investor-owned electric utility, rural electric cooperative, and municipal electric utility shall report, in writing, to the Director of the Division of Safety, Reliability and Consumer Assistance using Form PSC/SRC 158 (XX/XX) Commission within 30 days of any event malfunction of or accident involving any part of the electrical system, fire, or explosion, that: (a)Involves damage to the property of others for an amount in excess of $10,000 or, (b) Causes significant damage, in the judgment of the utility, to the utility's facilities. (3) Unless requested by the Commission, [Reports are not required with respect to personal injury, death, or property damage resulting from vehicular equipment striking poles]

FERC, NERC, FRCC, FPSC25-6.0345 Safety Standards for Construction of New Transmission and Distribution Facilities.

ProposedThe Commission adopts and incorporates by reference the 2012 edition of the National Electrical Safety Code (ANSI C-2) [NESC], as the applicable safety standards for transmission and distribution facilities subject to the Commission's safety jurisdiction.

Existing For electrical facilities constructed on or after February 1,2007, the 2007 NESC shall apply. Electrical facilities constructed prior to February 1,2007, shall be governed by the edition of the NESC specified by subsections 013 .B.I, 013.8.2, and 013 .B.3 of the 2007 NESC. Each investor-owned electric utility, rural electric cooperative, and municipal electric system shall, at a minimum, comply with the standards in these provisions.

FERC, NERC, FRCC, FPSC25-6.0346 Quarterly Reports of Work Orders and Safety Compliance

….(1) Each investor-owned electric utility, rural electric cooperative and municipal electric utility shall report all completed electric work orders, whether completed by the utility or one of its contractors, at the end of each quarter of the year. The report shall be electronically filed with the Director of the Division of Safety, Reliability and Consumer Assistance no later than the 30th working day after the last day of the reporting quarter using Form PSC/SRC 157 (xxI12), …… (2) In its quarterly report, each utility shall identify all transmission and distribution facilities subject to the Commission's safety jurisdiction, and shall certify to the Commission that they meet or exceed the applicable standards. Compliance inspections by the Commission shall be made on a random basis or as appropriate.

FERC, NERC, FRCC, FPSC25-6.060 Meter Test - Refereed Dispute Referee

(1) In the event of a dispute, upon request written application to the Commission by any customer, a test of the customer's meter will be made by the utility as soon as practicable. Said test will be supervised and witnessed by a representative of the Commission.

(2) A meter shall in no way be disturbed after the utility has received notice that application has been made for such referee test unless a representative of the Commission is present or unless authority to do so is first given in writing by the Commission or by the customer.

(3) A report of the results of the test will be made by the Commission to the customer.

(4) For equipment tested under this rule, any previous accuracy test result on record at the time the meter test is requested must be retained in accordance with Rule 25-6.022, F.A.C.

FERC Large Generator Interconnection Procedures (LGIP)

Generation = 20MW +

Complete LGIA Application w/site control

Feasibility Study• $10 k deposit• 45 days to complete study

System Impact Study•$50 k deposit•90 days to complete study

Facility Study•$100 k deposit•90 days (+/- 20%) or 180 days (+/- 10%) to complete study

FERC Small Generator Interconnection Procedures (SGIP)

Generation = 0 – 20 MW

Complete SGIA Application w/site control

Feasibility Study• $1 k deposit

System Impact Study

Facility Study

FERC Small Generator Interconnection Procedures - Fast

Track (SGIP Fast Track)Generation = 0 – 2 MW

Complete SGIA Application w/site control

Evaluate Project Against Screening Criteria• $500 Processing Fee

FERC, NERC, FRCC, FPSCTransmission Industry Oversight

Business/Commercial Standards

• North American Energy Standards BoardNAESB

FERC, NERC, FRCC, FPSCRice Rule

On May 22,2012, the Environmental Protection Agency proposed amendments to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for stationary.


EPA published its proposed revisions to the RICE NESHAP in the June 7th’s Federal Register.

The deadline for comments is July 23, 2012, or 30 days after the date of a public meeting if later.

The schedule for completing this rule is part of a settlement agreement with EnerNOC, which requires the EPA Administrator to issue a final rule by December 14, 2012.

FERC, NERC, FRCC, FPSCEmergency Demand Response and Peak Shaving

• In an emergency demand response situation, RICE may be used to assure the stability of electrical service. RICE could be called upon to provide power to a facility and/or to the electrical grid to assure available power at peak times also known as peak shaving.

• EPA proposes to allow emergency engines to operate for 100 hours per year without meeting emission limits for the following purposes:

o monitoring and testing,o demand response for Energy Emergency Alert Level 2 situations, ando responding to situations when there is at least a five percent or more change in voltage.

• This amendment would allow emergency engines to participate in demand response programs with regional electricity wholesale markets operated by independent system operators and regional transmission operators.


• This amendment would allow emergency engines to participate in demand response programs with regional electricity wholesale markets operated by independent system operators and regional transmission operators.

• Demand response programs vary in their requirements and engines may need to be available for 100 hours per year to participate in the programs.

• As part of the 100 hours allowed for monitoring and testing, demand response, and voltage change situations a temporary allowance of 50 hours per year would be provided for any purpose, including peak shaving, and may be used until April 2017. This would apply to units at area sources of hazardous air pollutants.


• If an emergency engine operates for more than 100 hours per year for non-emergency purposes, the engine will need to meet emission limits required for non-emergency engines for the life of the engine.

• The amendments restate that in a true emergency there is no time limit on use of the engines.


EPA Webinar – Thursday 6/14/12 – 1:00-3:30 PM

EPA Air Quality Regulations for Reciprocating Internal Combustion Engines

FERC, NERC, FRCC, FPSC An Update

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