Comments

APPA, ELCON, NRECA, and TAPS submitted comments in FERC Docket No. RR15-2-005 on proposed changes to NERC's CMEP (3-14-17)

APPA, LPPC, and TAPS submitted comments in FERC Docket No. RM16-18 on possible modifications to the Critical Infrastructure Protection (CIP) reliability standards regarding the cybersecurity of Control Centers (9-26-16)

APPA, EEI, EPSA, ELCON, and LPPC submitted a Request for Clarification in resonse to Order No. 824 issued by FERC; the order requires NERC to provide the Commission and staff with access on a non-public and ongoing basis to certain NERC databases (7-29-16)

APPA Vice President of Policy Analysis Allen Mosher speaks at June 1 FERC Reliability Technical Conference Written Statement Conference Webpage

APPA, LPPC, and TAPS filed joint post-technical comments in FERC Docket RM15-14 in response to the supply chain NORP (4-19-2016)

Joint comments of APPA, NRECA, and TAPS supporting NERC’s July 17 Compliance Filing on it Risk-Based Registration Initiative (8-17-2015)

APPA comments on FERC's NOPR that approves the Disturbance Monitoring and Reporting Requirements Reliability Standard, PRC-002-2, submitted by NERC (6-22-2015)

APPA, NRECA, and TAPS jointly filed an intervention and comments in support of NERC's important risk-based registration initiative (1-26-2015)

APPA, NRECA, and TAPS filed a joint MTI and initial comments in support of NERC's risk-based registration (1-12-2015)

APPA, NRECA, LPPC, and others filed a motion to intervene regarding NERC reliability assurance initiative (12-3-2014)

APPA joined an amicus curiae brief in Ninth Circuit arguing vioaltions of NERC reliabilty standards do no create tort liability (8-29-2014)

APPA and Snohomish County Public Utility District submitted a filing with FERC in support of NERC’s December 13, 2013 Petition for Approval of Revisions to the Definition of Bulk Electric System. (1-17-2014)

Joint Comments submitted by APPA, NRECA, EEI, and EPSA in response to the Notice of Proposed Rulemaking issued by FERC in Docket No. RM13-11-000 in support FERC’s proposal to approve BAL-003-1 believing that it represents a significant improvement over the previous version while resolving a known reliability gap and satisfying Order No. 693 directives. The trade associations also ask FERC to not issue new directives before NERC has had adequate time to evaluate the effectiveness of the proposed standard through the studies being considered. (9-30-2013)

Allen Mosher Written Statement to FERC Reliability Technical Conference, Dockets AD13-5, RC11-6-004 and RR13-2) (7-10-2013)

APPA Comments in Version 5 Critical Infrastructure Protection Reliability Standards, RM13-5 (6-24-2013)

APPA Comments in Generator Requirements at the Transmission Interface, Docket No. RM12-16 (6-24-2013)

APPA, et al.  Motion to Intervene and Comments in Support of NERC proposal filed on February 28, 2013 seeking Commission approval of various changes to the Standard Processes Manual, which governs the development of mandatory reliability standards for the planning and operation of the Bulk-Power System, RR13-2 (3-21-2013)

APPA, NRECA and TAPS Motion to Intervene and Comment Out-of-Time in Support of February 1, 2013 Compliance Filing of NERC in Response to Paragraph 30 of November 2, 2012 Commission Order – NERC Written Criteria for Determining Whether a Reliability Activity is Eligible to be Funded under Federal Power Act Section 215, Docket No. FA11-21 (3-8-2013)

APPA, NRECA and TAPS Submit Comments in FERC Docket RM12-22 on Reliability Standards for Geomagnetic Disturbances. (12-21-2012)

APPA, EEI, LPPC, NRECA and TAPS Submit Comments in FERC Docket RM12-4 on Commission’s Notice of Proposed Rulemaking (NOPR) to Accept Proposed Reliability Standard FAC-003-2, a Revised Mandatory Reliability Standard for Vegetation Management, submitted by the North American Electric Reliability Corporation (NERC). (12-20-2012)

APPA Submits Motion to Intervene and Comments in FERC Docket No. RR12-13 North American Electric Reliability Corporation 2013 Business Plan and Budget (09/28/2012)

APPA Files Comments in FERC Docket Nos. RM12-6 and RM12-7 Revisions to Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure (09/04/2012)

APPA, EEI, ELCON, EPSA, LPPC, TAPS and NRECA File a Joint Brief in FERC Docket FA11-21 Regarding the "Performance Audit of the North American Electric Reliability Corporation for Budget Formulation, Administration, and Execution" (08/20/2012)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, EEI, ELCON, EPSA and NRECA File a Motion to Intervene and Comments in FERC Docket RR12-8 Petition of the North American Electric Reliability Corporation for Approval of Revisions to its Rules of Procedure (05/29/2012)

APPA, EEI, NRECA and EPSA Submit Comments in FERC Docket RM12-4 on Revision to Transmission Vegetation Management Reliability Standard (05/23/2012)

APPA, EEI, EPSA, ELCON, LPPC, NRECA and TAPS File Comments in FERC Docket FA11-21 on NERC Final Audit Report (05/23/2012)

DOE Handbook - Training Program Handbook - A Systematic Approach to Training [pdf]

DOE Handbook - Guide to Good Practices for On-the-Job Training [pdf]

APPA Files Post-Technical Conference Comments in FERC Docket AD12-1 et al. the FERC Reliability Technical Conference Panel 1: Identifying Priorities for NERC Activities(12/09/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

Written Statement of Allen Mosher in FERC Docket AD12-1 et al. at the FERC Reliability Technical Conference Panel 1: Identifying Priorities for NERC Activities(11/29/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, EEI, ELCON, NRECA, TAPS and EPSA  File Comments in FERC Docket RM11-11 in Support of FERC's Proposal to Approve "Version 4" of Proposed NERC Mandatory Reliability Standards for Critical Infrastructure Protection (11/21/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Comments in FERC Docket RM11-16 on NOPR Transmission Relay Loadability Reliability Standard (11/21/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, EEI, ELCON, NRECA, TAPS, EPSA and LPPC File Motion to Intervene and Comments in FERC Docket RC11-6 In Support of the Petition Filed by NERC Asking the FERC for Approval of NERC's Proposed New Enforcement Mechanism Known as Find, Fix Track and Report (FFTR) (10/21/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Motion to Intervene and Comments in FERC Docket RC11-5 Concerning the City of Holland, Michigan Board of Public Works Inclusion on the NERC Compliance Registry (10/03/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, TAPS and LPPC File Joint Comments with NERC on NERC's Compliance Enforcement Initiative to "Find, Fix, Track and Report" (08/26/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA with other Trade Associations File Request for Clarification or Rehearing  in FERC Docket NP10-18 of the Order on Review of Notice of Penalty. (04/18/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Comments in FERC Docket RM10-5 Regarding the Commission’s Proposed Approval of NERC’s Interpretation of Requirement R1 of Commission-approved Reliability Standard PRC-005-1 (Transmission and Generation Protection System Maintenance and Testing) and the Commission’s Proposal, Pursuant to Section 215(d)(5) of the Federal Power Act, to Direct the North American Electric Reliability Corporation (“NERC”) to Develop and Submit to the Commission Several Modifications to the Instant Reliability Standard to Address Concerns Identified in the NOPR (02/25/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, EEI, ELCON, EPSA, LPPC and TAPS File Joint Comments in FERC Docket RR09-6 in support of the December 23, 2010 Compliance Filing of the North American Electric Reliability Corporation ("NERC" or the "ERO") ("Compliance Filing") in response to the Commission's March 18, 2010 Order Directing Revisions to Standards Development Procedure ("March 18 Order") (01/24/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Comments in FERC Docket RM10-16 Regarding the Commission’s Proposal to Approve Three Reliability Standards, EOP-001-1 (Emergency Operations Planning), EOP-005-2 (System Restoration from Blackstart Resources), and EOP-006-2 (System Restoration Coordination) (01/24/2011)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Comments in FERC Docket RM09-25 on NERC's Proposed System Personnel Training Reliability Standards PER 005-1 and 004-2 (08/23/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Post-Conference Comments in FERC Docket AD10-14 on Reliability Standards Development and NERC and Regional Entity Enforcement (07/26/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, Edison Electric Institute, NRECA, Transmission Access Policy Study Group (TAPS), LPPC and the Electric Power Supply Association File Motion to Intervene in FERC Docket RR10-12 in Support NERC's Petition for Approval of Its Proposed Reliability Standards Processes Manual (07/12/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, Edison Electric Institute, NRECA, Transmission Access Policy Study Group (TAPS), LPPC and the Electric Power Supply Association File Joint Comments in FERC Docket RR09-7 in Support of NERC's Motion Asking the Federal Energy Regulatory Commission "to Issue a Staff Preliminary Assessment in Response to the Three-Year Electric Reliability Organization Performance Assessment Report Filed by NERC on July 20, 2009" (05/26/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, Edison Electric Institute, Canadian Electricity Association, NRECA, Transmission Access Policy Study Group (TAPS), and Electric Power Supply Association File Joint Comments in FERC Docket RM10-6 in Notice of Proposed Rulemaking (NOPR) on Interpretation of Transmission Planning Reliability Standard TPL-002-0 Requirement R1.3.10 (05/10/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA and NRECA File Joint Comments in FERC Docket RM09-18 in Notice of Proposed Rulemaking (NOPR) on Revision to Electric Reliability Organization Definition of Bulk Electric System (05/10/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, NRECA and TAPS (Transmission Access Policy Study Group) File Request for Rehearing and Clarification of Order No. 733, the Commission’s March 18, 2010 Final Rule (RM08-13) regarding the Transmission Relay Loadability (TRL) Reliability Standard, PRC-023-1 (04/19/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Request for Rehearing and Clarification in FERC Docket RM06-16 of the FERC's “Order Setting Deadline for Compliance,” issued March 18, 2010, concerning the Commission’s directive to the NERC to submit a specific modification to Reliability Standard BAL-003-0. (04/19/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Files Motion to Intervene in FERC Docket NP10-18 on Certain Policy Issues Raised by the Commission’s February 26 "Order Initiating Review of Notice of Penalty" (03/18/2010)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA, EEI and NRECA Submitted Joint Comments to NERC on paper concerning Regional Delegation Agreements (RDAs) (12/09/2009)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Submitted a Comments in FERC Docket RM06-16 Regarding the August 2009 Preliminary Report on the Topological and Impedance Element Ranking (TIER) of the Bulk-Power System (“TIER Report”) (10/28/2009)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 and Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

APPA Filed Comments in FERC Docket RM08-19 Regarding FERC's Proposal to Approve and Direct Modifications to Six Modeling, Data and Analysis (MOD) Reliability Standards Submitted by NERC (05/26/2009)
Contacts: Sue Kelly, APPA Vice President of Policy Analysis and General Counsel, 202/467-2933 or Allen Mosher, APPA Senior Director of Policy Analysis and Reliability, 202/467-2944.

NERC Compliance Manual For Cooperative and Public Power Utilities

To assist APPA member efforts to ensure compliance with NERC reliability standards and demonstrate a culture of compliance, APPA’s research and grant program Demonstration of Energy-Efficient Developments (DEED) worked with the National Rural Electric Cooperative Association to develop the NERC Compliance Overview, Users Guide and Sample NERC/Regional Entity Compliance Plan documents shown below. Consulting assistance provided by AESI-US, Inc.

The Overview presents a summary of the NERC standards development and compliance processes, as well as links to relevant provisions of the NERC Rules of Procedure, reliability standards development procedures, NERC compliance documents and processes, and relevant FERC orders. The User’s Guide provides a step-by-step list of considerations relevant to developing a NERC/Regional Entity Reliability Compliance Plan that fits the specific business and operational considerations applicable to particular municipal and cooperative utilities. The Sample Compliance Plan is a pro forma document, provided in Microsoft Word 97-2003 (*.doc) format, which each public power utility should customize to fit its particular circumstances as applicable. The Sample Compliance Plan identifies and highlights text which must be replaced by each utility user.

APPA regular utility members are authorized to use each of these documents, in whole or in part, to support their internal compliance programs. APPA regular utility members are authorized to modify the “NERC/RE Sample Compliance Plan” in order to incorporate some or all of this plan into their respective utility-specific compliance plans and programs. All other rights are reserved and no warranties are implied.

This project was funded by a Demonstration of Energy-Efficient Developments (DEED) grant. The DEED program pools its member’s resources to invest in the future technologies and best practices of the electric industry. To learn more about the DEED program and funding opportunities visit www.publicpower.org/DEED.cfm or contact Michele Suddleson, DEED Program Manager, at 202-467-2960 or DEED@publicpower.org.

APPA Issue Brief on Bulk Power System Cyber Security

Join APPA’s NERC-NAESB-L Discussion Forum

Presentation by Allen Mosher, Senior Director of Policy Analysis and Reliability, American Public Power Association, at the NERC Standards and Compliance Workshop, Atlanta, Georgia, October 2008, "NERC Compliance: Lessons to Learn, Pitfalls to Avoid," 15 pp. [Powerpoint]. Other NERC presentations.

Michael Gianunzio, Sacramento Municipal Utility District, California, "Building a Compliance Program," IntroHistorical OverviewMandatory StandardsRegional Compliance ProcessInternal Compliance ProgramsAudit Experience [Powerpoint]

Preparing for NERC Compliance Audits (Public Power magazine, October 2008)

CIP 001 – 009 Standards

APPA Submits Comments to NERC on Reliability Impacts of Climate Change. (07/16/2008)

Ralph Anderson, Florida Municipal Power Agency, "My Utility is on the NERC Compliance Registry - What Do I Do Now?," presented at the 2008 APPA National Conference

Danny Dees, MEAG Power, Atlanta, GA, "What Do You Do When Your Utility Gets Put on the NERC Compliance Registry?," presented at the 2008 APPA National Conference

Stan Johnson, North American Electric Reliability Corporation, "NERC Cyber Security Standards," presented at the 2008 APPA National Conference

City of Vero Beach NERC Reliability Standard CIP-001-0 Sabotage Reporting Procedure [Microsoft Word]

Muscatine Power and Water Security Incident Reporting Procedure ESPR-002 [Microsoft Word]

Tom Berry, Member, NERC Board of Trustees, and Retired Partner, Goldman Sachs, Chatham, New Jersey, "Special Luncheon Address: NERC Governance and the Role of the NERC Board of Trustees," 7pp. [PDF]

Dave Hilt, North American Electric Reliability Corporation, Princeton, New Jersey, "Keeping the Lights On Mandatory Reliability Standards Actions You Can Take," 22 pp. [Powerpoint]

APPA has updated its list of consultants and software vendors for NERC/ERO reliability standards compliance, enforcement, and training. APPA members: Download the list in either PDF format or Excel format. Of course, all listings are for informational purposes only, without APPA endorsement as to the qualifications or suitability of these individuals and firms for your particular needs. Contact: Allen Mosher, senior director of policy analysis and reliability

Contacts

Delia Patterson, APPA Acting Senior Vice President of Advocacy and Communications & General Counsel, 202/467-2993

Jack Cashin, APPA Director of Policy Analysis & Reliability Standards, 202/467-2979