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Risk-Based Registration

Risk-Based Registration. Terry Brinker, NERC Manager, Registration Services June 05, 2014. Current Registration Challenges. Some Functions may have minimal impact on reliability Must follow all standard requirements according to Function, regardless of reliability impacts

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Risk-Based Registration

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  1. Risk-Based Registration Terry Brinker, NERC Manager, Registration Services June 05, 2014

  2. Current Registration Challenges • Some Functions may have minimal impact on reliability • Must follow all standard requirements according to Function, regardless of reliability impacts • Conservative criteria and thresholds used to register entities • Flexibility to use entity risk, but limited application to date • Entities registered in multiple regions are subject to inconsistent criteria

  3. Risk-based Registration Vision • Understand and manage risk by ensuring right entities registered according to risk to reliability • Differentiate entities exhibiting different levels of risk: • Clear thresholds • Registration using consistent risk assessment methods • Focused Reliability Standard requirements • Align with: • Bulk Electric System definition • Reliability Assurance Initiative • Reliability Standard reform

  4. RBR Approach • Target functional categories not contributing to reliability • Reliability Standard requirements tailored to risk • Two options to use consistent risk-based methods: • Modify thresholds • Tiers within existing criteria • Systematic, repeatable and comprehensive process

  5. Proposed Elimination • The functional category of PSE has been identified for potential removal from NCR • The PSE function is a market/commercial function • The BAL standards already require the BA to manage total interchange • NERC standards applicable to the PSE can be transferred to NAESB

  6. Proposed Elimination • The functional category of IA has been identified for potential removal from NCR • Changes to the INT standards remove the requirements applicable to the IA • P81 efforts identified the INT standards as commercial in nature

  7. Proposed Elimination • The functional category of LSE has been identified for potential removal from NCR • LSE serves mainly commercial purposes • Many standards are applicable to both the DP and LSE • Activities of an LSE can be better handled by other registered entities

  8. Proposed Revisions Distribution Provider • Increase the threshold to 75 MW for Distribution Providers • pending studies of the aggregate impact of such change • UFLS-Only Distribution Provider • Entities 75 MW or below that have UFLS Protection Systems • Only be responsible for complying with PRC-006-1 as Distribution Providers

  9. Proposed Revisions Continued • Generation Owner and Operators • Incorporation of the BES Definition, through the addition of the term “Facility(ies)” units • Project 2014-01 Standard Drafting Team • Transmission Owner and Operators • No change to the Registry Criteria • Potential for tiering

  10. Centralized Review Process • Comprised of a NERC lead with Regional Entity participants • To provide a basis for NERC and regional consistency • To vet threshold applications, materiality, or Reliability Standard requirement applicability issues • Decisions will be shared throughout the ERO Enterprise and publicly posted on the NERC web site

  11. Factors for Materiality • Is the entity specifically identified in the emergency operation plans and/or restoration plans of an associated Reliability Coordinator (RC), Balancing Authority (BA), GOP or TOP? • Will intentional or inadvertent removal of a resource or Element owned or operated by the entity lead to loss of a BES resource or a BES transmission Element of an associated GOP or TOP? • Will intentional or inadvertent removal of a resource or Element owned or operated by the entity lead to a material loss of BES connected load of an associated BA or TOP?

  12. Factors for Materiality • Can the normal operation, Misoperation or malicious use of the entity’s cyber assets cause a material detrimental impact on the operational reliability of an associated BA, GOP or TOP? • Can the normal operation, Misoperation or malicious use of the entity’s Protective Systems cause a detrimental adverse impact on the operational reliability of any associated BA, GOP or TOP, or the automatic load shedding programs of a PC or TP (UFLS, UVLS)?

  13. RBR Overview Flowchart

  14. RBR Timeline

  15. Questions and Answers

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