The North American Reliability Corporation's Recent Paper “Adequate Level of Reliability” Deserves Our Full Attention. Achieving this in the nation's electric system is the overall goal behind reliability standards. These standards ultimately result in utilities, power producers and others spending billions of dollars annually. If the reliability standards are improperly defined or focused, the money will be spent but will result in insufficient rules to prevent multi-state cascading outages.

RESPONSE TO MULTI-STATE OUTAGES

In 2003, a large part of the Eastern Interconnection blacked out. As expected, the public outcry resulted in a significant emphasis on reliability compliance of the U.S. and Canadian governments, industry and the public. The most significant change after the 2003 Eastern Interconnection blackout was a transition from a voluntary to a mandatory reliability compliance model. The Energy Policy Act of 2005 paved the way to mandatory compliance rules, with penalties now being assessed for noncompliance.

The process began with the development of the NERC Functional Model and then the functional registration process for regional reliability organizations, balancing authorities and transmission operators. By 2007, all owners, operators and users of the bulk electric system were expected to register under the appropriate functions. Registration was based on the NERC Statement of Compliance Registry Criteria (Revision 3) that uses generation thresholds of 20 MW, load thresholds of 25 MW and facilities thresholds of 100 kV as bright-line tests for registration and reliability standard compliance.

This was a significant change in the electric industry, forcing many to address a myriad of local system requirements that have no significant impact on regional reliability issues. Many distribution and local network systems are exposed to various outage risks. As a result, many small organizations that had never previously engaged in electric industry reliability efforts were required to register and identify which of the 1400 NERC reliability requirements were applicable to their systems. These efforts are detracting from our ability to focus on needed system reinforcements that positively impact wide-area reliability. Instead, a significant amount of effort is focused on the local system impact of NERC Compliance Registry Criteria.

For Snohomish County PUD, for example, the loss of 5 MW to 25 MW is comparable to a car-pole accident or equipment failure, and the loss of 200 MW to 300 MW load for two to four hours is typical of a wind event. However, NERC bright-line definitions based on specific voltage and megavolt-ampere limits, rather than performance, can make local service issues appear like national security issues requiring significant documentation and reporting to NERC, FERC and the Department of Energy, which could launch investigations that result in fines.

ELECTRIC INDUSTRY REACTION

Whether NERC has shifted its focus or simply increased the number and details of the requirements, the effort required to simply document compliance has increased exponentially.

The actions advocated by many consultants and justified by the application of NERC reliability standards, without regard to actual impacts, serves to increase costs to electric utilities, which ultimately results in higher costs and reduced levels of service to customers. This issue also impacts large transmission provider utilities because most also own and operate local networks and load serving systems. Furthermore, customers of larger electric utilities are looking to them for interpretations, delegation agreements and other support, significantly detracting from their efforts to meet the reliability requirements that may directly impact regional reliability.

It is clear that the cost of widespread multi-state outages to our lives, the economy and security is significant. Few, if any, would argue that addressing this issue is not of the utmost importance to the industry. However, the current standards and interpretations are resulting in misdirected efforts. Utilities are focusing on documentation, analysis, operation and protection of local systems that only impact local service issues. These efforts are not adding long-term solutions that would protect our bulk power system from suffering widespread multi-state outages.

To more efficiently use limited electric industry resources, NERC should refine reliability standards and the defined terms that are used in the standards glossary to better identify reliability efforts that focus on preventing region-wide cascading rather than requirements that impact local load service. This effort would go a long way to prioritize utility efforts in promoting regional reliability rather than local service levels that are already being addressed by other agencies.

John Martinsen, a professional engineer, is a senior regional transmission engineer for Snohomish County Public Utility District (Everett, Washington, U.S.). jdmartinsen@snopud.com