Arlington, VA; October 21, 2011 — Today, the National Rural Electric Cooperative Association (NRECA) joined other trade associations representing the electric utility industry in filing comments to FERC in support of NERC’s decision to revamp how it deals with possible violations of reliability standards that pose a lesser risk to the bulk power system (BPS).
NERC’s proposed enforcement mechanism, termed “Find, Fix, Track and Report” (FFTR), allows NERC to differentiate between violations that pose a significant risk to the Bulk Power System (BPS) and lesser risk issues, particularly violations associated with demonstrating compliance and administrative or paperwork violations.
This reform would allow both the NERC and covered utilities, who are now being overwhelmed by the current burdensome administrative process, to direct valuable resources of time and effort to where they are most needed: addressing significant violations of the reliability standards.
Barry Lawson, Associate Director for Power Delivery and Reliability at NRECA, asserts the change will strengthen enforcement of reliability standards.
In the four and a half years that NERC has been administering this process, the flaws have become abundantly clear to our member cooperatives. Facing a financial penalty for minor paperwork shortcomings while having complied with the operational elements of the standard is not an effective and efficient way to administer a reliability compliance program. The FFTR program is a welcome first step by NERC to address these issues and we hope FERC will agree.
NERC’s FFTR program will help co-ops by providing for a more efficient and less time-consuming process for dealing with minor potential violations of reliability standards. With the FFTR program, NERC is taking welcome steps to address concerns of industry stakeholders and NRECA will continue to work with NERC and the industry to pursue additional ways to improve the NERC program.”
The proposed FFTR mechanism would add needed compliance and enforcement flexibility without diminishing the accountability of the utilities under the standards.
As part of the proposal, all possible violations will continue to be found, fixed, tracked and reported; however, lesser risk issues that have already been corrected will be presented as Remediated Issues in a Find, Fix, Track and Report spreadsheet that will be submitted to the Commission in a monthly informational filing.
The filing also suggests that the Commission consider convening a policy-level technical conference to address the broader goals, priorities, costs, and practical challenges for NERC compliance and enforcement.
NRECA joined in the filing with The Edison Electric Institute (EEI), the American Public Power Association (APPA), the Transmission Access Policy Study Group (TAPS), the Electricity Consumers Resource Council (ELCON), the Electric Power Supply Association (EPSA), and the Large Public Power Council (LPPC).