Now is the appropriate time to look back at the reliability standards to which the industry is subject to determine appropriateness and efficacy, the Midwest Independent Transmission System Operator told FERC Dec. 9.
“With several years of experience, the time is ripe to start improving existing reliability standards to better target areas [the North American Electric Reliability Corporation] and the industry know to be high risk, to remove redundant or superfluous standard requirements, and to enhance reliability standard language to clear up any gaps or areas of confusion,” MISO said in its post-technical conference comments.
MISO urged NERC and FERC to undertake an independent evaluation of the current standards development process to determine whether and where delays and problems exist.
FERC should continue promoting the prioritization of efforts at NERC to address current and future reliability issues and reliability standards development initiatives through a risk-based approach, MISO said.
While NERC has taken important steps to focus its efforts on high-risk, high-priority issues and to develop a risk-based approach to better focus reliability standard activities on areas of high impact and importance to bulk power system (BPS) reliability, MISO is concerned that this shift in culture and focus remains hindered by contradictory practices and objectives.
NERC has taken actions it says are directed to “improve the pace of the standards process” by expediting that process. MISO also said that although it supports NERC’s efforts to encourage efficiency, it is concerned that the drive to do more, faster could negatively affect the quality of new standards, as well as the process under which they are developed.
Additionally, MISO said that while there has been discussion by FERC and NERC about balancing cost and reliability and focusing the development and enforcement of reliability standards on issues and areas with significant impact on BPS reliability, the parallel focus on more standards, faster is undermining the parallel movement towards results-based standards and a risk-based approach. Results-based standards were originally envisioned as focusing on issues and areas that contribute directly to reliability.
NERC’s primary focus should be on quality, MISO said, adding that together, the approved reliability standards are more than 1,000 pages and growing.
“MISO encourages NERC to work with the industry to determine what should be included in a standard’s five-year review and to develop criteria for determining whether an existing standard should be enhanced or improved based on the results of the five-year review,” MISO added.
The interpretation process is being underutilized, MISO said, noting that the time needed to process interpretation requests is frequently cited as a reason for the increase in compliance application notices (CANs); the time to process interpretations does not need to be nearly as long as is espoused.
The perceived delay in processing interpretations has led to an overreliance on CANs, MISO said, adding that it is not appropriate to use the CAN process as an alternate means of quickly processing an interpretation.
“The CAN process lacks the formality and due process necessary for standards development and should not be used as a vehicle for developing new requirements or substantive interpretations of reliability standard requirements.”
Among other things, MISO said it has preliminarily identified three institutional barriers to economic capacity sales across the MISO/PJM Interconnection seam, including difficulty in obtaining long-term transmission service to accommodate prospective capacity sales.
MISO said FERC should direct regional transmission organizations to eliminate administrative barriers between themselves that prevent customers from accessing compliant resources so that the lowest cost of compliance can be achieved for end use customers.