NERC's risk-based approach to electric reliability compliance gains FERC approval

The Federal Energy Regulatory Commission signed off on the Reliability Assurance Initiative, which is the North American Electric Reliability Corporation's new risk-based approach to monitoring and enforcing compliance with electric grid reliability standards. According to a release from FERC, the initiative will devote resources to mitigating high-risk threats to reliability while still maintaining standards for identifying, tracking and fixing low-risk ones.

Reliability Assurance Initiative expands a previous program
The RAI is not the first move by NERC to build a comprehensive risk-based approach to electric reliability. As FERC explained, the new initiative will be an extension of NERC's Find, Fix, Track and Report program, which focused only on noncompliance issues that posed medium- to low-risk threats.

The RAI will allow to NERC to continue to offer "reasonable assurance of reliability through compliance monitoring and appropriate deterrence through enforcement for minimal risk issues," while giving it the resources to deter high-risk noncompliance through enforcement. NERC will be required to submit an annual report to FERC to ensure that compliance standards are met.

Low-risk reporting in the hands of facilities
The main purpose of the RAI is to streamline NERCs oversight process by reducing the scope of reliability violations that would fall under the corporation's enforcement, RTO Insider reported. Essentially, the new initiative will allow for facilities and grid operators to self-report "minimal" violations.

This would allow NERC to focus on the high-risk violations by preventing the diversion of resources and time toward issues that can be more easily identifying and corrected by those closest to them. Rather than report every single minor violation to NERC, the facilities can log their findings themselves. These records will be periodically reviewed by NERC's Regional Entities. By participating, the facilities involved will avoid being penalized for minimal risk violations.

"A risk-based approach is necessary for a proper allocation of resources and to encourage registered entities to enhance internal controls, including those focused on the self-identification of noncompliance," a release by NERC read.

A new data-driven reliability assessment will help operators identify risks as soon as possible.

While the RAI was generally well-received, some stakeholders believed that NERC should make the results of the self-reporting public in the interest of transparency. In a joint filing, a group of stakeholders that included the American Public Power Association and the National Rural Electric Cooperative Association, wrote that as the RAI is implemented, transparency in violations reporting will be "essential to educating industry to avoid and mitigate noncompliance with reliability standards, and to maintain the credibility of NERC's compliance and enforcement regime."

FERC agreed with the stakeholders' comments, stating that it didn't believe NERC's reasoning that by making the reports public, it would discourage grid operators and facilities from participating in the more efficient RAI program.

FERC approves NERC's new data-driven reliability assessments
In a separate but related order, FERC approved NERC's new proposed reliability standard, known as MOD-031-1. The order will allow Planning Authorities/Planning Coordinators, Transmission and Resource Planners, Load-Serving Entities and Distribution Providers to collaborate and coordinate efforts to collect demand, net energy for load and demand-side management data.

NERC wrote that this data collection will ensure that planners and operators have access to comprehensive and accurate load forecasts. In addition, they will be able to see the exact methods used to collect the data. These moves will help all stakeholders involved better maintain grid reliability and documentation processes - potentially bolstering the upgrades to the grid throughout many regions by giving stakeholders the ability to identify risks earlier on.

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