In the June Quarterly Report, we explained how the North American Transmission Forum promotes the highest level of reliability in the operation of the U.S. and Canadian electric transmission systems. We're doing this, not by writing rules (or standards) and enforcing compliance — that's NERC's job — but by writing and sharing effective practices that focus on how to operate the transmission systems reliably.
Now I'm not suggesting we don't need rules, but we need to openly recognize that rules are limited in what they can accomplish. For example, in Dov Seidman's book How: Why How We Do Anything Means Everything… in Business (and in Life), he states, “What makes a company or government sustainable is not when it adds more coercive rules and regulations to control behaviors. It is when its employees or citizens are propelled by values and principles to do the right things, no matter how difficult the situation.”
The Problems with Rules
Government regulations alone will not ensure a reliable electric system. When something goes wrong, whether it be on the electric grid, Wall Street or in the Gulf of Mexico, the government quickly reaches one of two conclusions: someone broke a rule, or there was no rule and one needs to be written. That is what governments do. Unfortunately, citizens expect these rules to stop grid failures, financial failures and drilling failures, and that will not happen because of these five problems with rules, according to Seidman.
- Rules are external
They are made by others and present us with a puzzle to be solved and loopholes to be found.
- Rules are both over- and under-inclusive
Because they are proxies for the almost limitless number of situations that can arise, they cannot be precise.
- Rules require enforcement
With laxity, they lose credibility and effectiveness, and they necessitate expensive bureaucracies of compliance.
- Rules are typically prohibitions
They speak of can and can't, and people view them as confining and constricting.
- Too many rules breeds overreliance
We think, “If it mattered, they would make a rule.”
Practices are the key to “how.” We've been operating interconnected electric systems for almost 90 years, and we know how to do it reliably and safely. The Forum will continue to be successful because our members bring their expertise to the table to discuss practices in areas including vegetation management, system protection, operator training and more.
There's another side to this story: human performance. Human performance is the key to “why.” Every major grid failure was caused, at least in part, by a human error. Our own practices, with all their built-in wisdom and goals of excellence, won't prevent blackouts if people don't follow them. And rules, with their performance criteria, penalties and limits, are of no help when it comes to the human element of keeping the grid reliable.
If rules are written to explain what you have to do, and practices provide guidance on how you do it to ensure excellence, then we have to pay attention to human performance to understand why people do what they do. This is so important that some utilities have spent small fortunes tackling human performance errors.
Maintaining the grid's reliability is not just about the rules, it's about how we do our jobs and the choices we make when we have to take action. And that's why sharing best practices and understanding human performance are so important.
As an independent, nonprofit organization, the Forum has one main goal: to promote the highest level of reliability in the operation of the electric transmission system. Any organization that owns, operates or controls at least 50 circuit miles of integrated (network) transmission facilities at 100 kV or above, operates a 24/7 transmission control center with North American Electric Reliability Corporation (NERC)-certified transmission or reliability operators, or has an open-access transmission tariff or equivalent on file with a regulatory authority, is welcome to join the Forum.
Our members know how to do their jobs, are passionate about doing them the right way and are anxious to share their knowledge with their colleagues. In fact, they're just as eager to explain why things go wrong, even though the “right” rules were in place. That kind of sharing, helping and learning can only happen within the privacy of the Forum.
Don Benjamin (email@example.com) is the executive director of the North American Transmission Forum. Prior to joining the forum in 2008, he was the vice president of operations at NERC and served as secretary of the NERC Operating Committee since 1983. Before moving to NERC, he joined the Florida Electric Power Coordinating Group as its first staff engineer.
Editor's note: For more information on the North American Transmission Forum, contact Don Benjamin at 609-882-0680.