In a recent meeting with reporters to discuss his first six months leading the North American Electric Reliability Corporation, NERC President and CEO Jim Robb outlined some of the top of mind issues for him these days, including the restructuring of the reliability coordinator (RC) function in the West, as well as inverters and inverter-based resources.
Robb, who met with reporters at NERC’s offices in Washington, D.C., on Sept. 27, assumed the role of NERC’s President and CEO in April 2018.
Prior to his role at NERC, he served as the CEO of the Western Electricity Coordinating Council, a NERC Regional Entity. He assumed the WECC position in 2014.
In his comments, Robb said that NERC is going to take a “very measured approach to really focusing on consistency of implementation of our programs among the regional entities.”
He noted that this has been “one of the ongoing complaints of industry that I’ve grown much more appreciative of since I’ve been in this role,” specifically, the different ways that NERC Region’s operate.
“Obviously, we’re in kind of a little bit of a renewal period” for NERC and the Regional entities, with the Southwest Power Pool Regional Entity largely merging in with the Midwest Reliability Organization and “the potential for Florida to take a different approach with its regional entity.”
NERC’s role as an independent organization
Robb said that there are three things that he talks to NERC staff about on a regular basis “in terms of our job.”
The first one is that NERC has to always balance “and find the yin and yang between being an independent agency and working with industry. We’re a fairly unique regulatory model in terms of how we’re set up. We absolutely depend on and value the relationship that we have with industry.” But NERC always has to have its “independence hat in place.”
In addition, the NERC President and CEO said that “many of the issues that electric power industry’s facing right now are becoming highly politicized. Whether it’s the longevity of coal and nuclear plants, the push to add more wind and solar to the grid, any sorts of other advanced technologies that are coming down the path – many of those have political overtones, as well as technical ones.”
Robb’s goal is to “make sure that our work remains technically unimpeachable so that it’s there to inform people who are making important decisions around these issues, but not get drawn into the political and ideological arguments around them.”
Third, he said that “one thing that’s really critical for us to understand is we don’t have – the last time I checked – our hands on any controls, right? We can’t achieve anything for the industry unless we have very good relationships with decisionmakers and policymakers across the ecosystem.”
Robb said, “our work has to be relevant and has to be gotten into the hands of the right people who can take action on it – whether that’s a utility operator in a control center, a transmission planner, or a policymaker in the federal government or in the state government.”
Meanwhile, Robb told reporters that he has identified several “thematic” risk areas that are important.
One of the risk areas is security, he said. “It’s a huge issue for the industry. It’s a big issue for us here at NERC.”
Robb said that in the area of security, “the topic of standards always comes up.” NERC introduced the latest version of critical infrastructure protection (CIP) standards two years ago.
“We’re pretty pleased with them,” he said. “However, I think we’re also pretty clear-eyed that standards at best set a foundational level of protection for the system and as the threat is persistent and always evolving, the standards are going to have to evolve as well, so we’re in the process of always kind of revisiting the right kinds of definitions and approaches to providing security and we learn constantly about the threats that we need to protect against.”
In addition, Robb also highlighted the GridEx exercise, which takes place every two years. It allows utilities, government partners and other critical infrastructure participants to engage with local and regional first responders, exercise cross-sector impacts, improve unity of messages and communication, identify lessons learned and engage senior leadership.
“We’ll be doing our fifth one next year,” he noted. The exercise began in 2011 and NERC hosts the GridEx series. The 2017 GridEx, which took place over two days (Nov. 15-16), marked the fourth such exercise. On Nov. 16, an executive tabletop took place, which focused on grid restoration and recovery response by senior government and industry leaders to simulated cyber and physical security events reflected in the GridEx scenario. “Obviously, I’ve never participated in one in this role, but I’ve observed the tabletop twice in my role at WECC,” Robb noted.
With respect to GridEx, “I saw a very significant improvement between number three and number four and I hope to see more in number five in terms of the level of coordination, the understanding of the issues that would actually need to be dealt with and the translation of the findings into some concrete action plans for people to go do.”
Other topics that keep Robb “up at night”
Robb also discussed other topics that keep him “up at night,” one of which is the restructuring of the reliability coordinator function in the West. NERC rules of procedure require that all NERC registered balancing authorities and transmission operators have an approved reliability coordinator.
The current reliability coordinator in the West, Peak Reliability, on July 18 said that it will cease operation at the end of 2019. The announcement came after a year of effort by Peak Reliability to provide a viable, long-term reliability coordinator option for the West.
Meanwhile, SPP on June 5 said that it plans to offer reliability coordinator services in the western U.S., specifically the Western Interconnection, starting in late 2019 and in early 2018, the California Independent System Operator said that it would seek NERC approval as a reliability coordinator and then become its own reliability coordinator and offer services to other balancing authorities and transmission operators in the western U.S.
“The seams issues and managing seams between reliability coordinators in the West is something we’re going to be paying an awful lot of attention to as that plays out over the next 15 months,” Robb said.
“In a remarkable period of change”
Switching gears, Robb said that “we’re in a remarkable period of change right now. With the transition largely away – it’s pretty clear – from a coal, nuclear solid fuel-based industry to one that’s going to be much more based on variable resources and natural gas. Loads are becoming much less certain than what we’ve had in the past.”
He said that there is a “broad range of things that as we work through this transition we need to stay on top of. One of the ones I’m most focused on is natural gas and the role that natural gas and natural gas infrastructure will increasingly need to play in order to support the reliability needs of the electric sector.”
Another top of mind issue for Robb relates to inverters and inverter-based resources, “mostly utility-scale solar, but increasingly the use of batteries on the system.”
He said that “we’ve learned a lot through two California fires that created system disturbances in the West around how system inverters respond to that.”
Robb noted that “we’ve issued two NERC alerts around the issues that arose related to the fire.” NERC has also finalized several guidelines that relate to inverters.
Robb noted that “we’re also in the process of exploring a couple potential standards around inverters and how they interact.”
Fuel assurance standard may get a closer look
During the question-and-answer portion of the briefing with reporters, Robb noted that an issue that “we’re working on with our planning committee is to look at our existing suite of standards.”
He said that “we have a couple that start to lay out how you need to plan for contingencies on the system, but it’s relatively vague as to how to think about fuel as a contingency. So we’re talking through getting a guideline put in place that would make clear that any particular entity ought to look at a major pipeline disruption, for example, a problem on the rail system, what have you, and start to factor that into their operating and shorter term planning. So that’s underway right now.”
Robb said that “one of the other issues that we’re debating is whether we need to start to think about some form of a fuel assurance standard. There’s a lot of logic to having such a standard in place but it’s not a simple one to craft.” One of the key issues, he said, “particularly as it relates to gas, is who would you make it applicable to?”
Robb said that the challenge in evaluating the gas system is “you need to really look at it over a fairly wide area. Probably a bigger footprint than a planning coordinator – certainly a bigger footprint than an individual utility. It might be something that might be best applicable to an RC, but the RCs really aren’t set up to do that kind of planning work.”
Robb’s personal view “is I think a standard will be called for” with respect to inverters, but NERC has “not yet crafted how that standard should be configured and that’s kind of some work to be done. And I feel the same way about fuel assurance – I believe eventually we’ll conclude that a standard will need to be put in place. But my eyes are wide open to the challenges in crafting those appropriately and figuring out which entity should be accountable for them.”