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FERC Reaffirms Order Requiring Revised Definition of Bulk Electric System

The Federal Energy Regulatory Commission has taken steps to further ensure reliable operation of the nation’s interconnected transmission network by reaffirming that the definition of “bulk electric system” must be revised to eliminate the unchecked regional discretion that has resulted in inconsistencies and accepting revised procedures for developing mandatory reliability standards.

The order (RM09-18-001) reaffirms a final rule issued in November that said the potential for gaps in coverage of all facilities under the current definition of bulk electric system could compromise reliability. FERC directed the North American Electric Reliability Corp. (NERC) to revise the definition, and said the best approach is to eliminate regional discretion, establish a bright-line threshold that includes all facilities operated at or above 100 kilovolts except defined radial lines, and adopt a process to exclude facilities not necessary for operating the interconnected grid. The order emphasizes that local distribution facilities are excluded from FERC jurisdiction under section 215 of the Federal Power Act and therefore must be excluded from the definition of bulk electric system.

The order also reiterates that NERC can propose an alternative definition it is equally efficient and effective as FERC’s suggested approach and will not impair reliability.

Also, FERC approved changes to NERC procedures addressing conflicts between its existing standards development process and its obligation to comply with FERC directives to submit a new or modified standard. The revisions (RR09-6-003) retain the stakeholder process for developing standards, but establish procedures for NERC’s board to file a draft standard in response to a Commission directive if the stakeholder process fails to approve the standard.

In other reliability-related actions, FERC issued final rules approving:

  • System Restoration standards for blackstart planning, testing and training (RM10-16-000);
  • ReliabilityFirst Corp.’s regional standard on Planning Resource Adequacy Analysis, Assessment and Documentation (RM10-10-000);
  • The Western Electricity Coordinating Council’s regional standard on Qualified Transfer Path Unscheduled Flow Relief (RM09-19-000); and
  • Interconnection Reliability Operating Limits standards (RM10-15-000).


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