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EPSA Comments on NERC's Three Year Performance Assessment and Proposed Future Actions
"In its initial three years the ERO has come a long way, and EPSA supports the continued evolution of the ERO as evidenced by the proposed future actions presented in the Three Year Performance Assessment."
WASHINGTON, D.C. - The Electric Power Supply Association (EPSA) today filed comments with the Federal Energy Regulatory Commission (FERC) supporting NERC's work as the Electric Reliability Organization (ERO), while providing input on NERCs planned actions presented in its Three-Year Electric Reliability Organization Performance Assessment Report. EPSA's comments address FERCs requirements that the ERO satisfy statutory mandates, address recommendations by users, owners and operators of the Bulk Power System (BPS), and evaluate the effectiveness of each of the eight Regional Entities (REs). EPSA commends the overall performance of the ERO while noting the importance of follow through on many of the planned actions for improving the mandatory reliability regime. "In its initial three years the ERO has come a long way, and EPSA supports the continued evolution of the ERO as evidenced by the proposed future actions presented in the Three Year Performance Assessment," EPSA's comments state.
Specifically, EPSA supports improving the standards development process by sharpening its focus and accelerating the process. Duplicative requirements should be reduced and communications among NERC staff and industry stakeholders should also be improved. In addition, EPSA strongly supports several of NERC's suggested reforms to streamline the standards development process by improving its efficiency.
EPSA's comments agree with NERC's plan to reach out to more entities that make up the BPS in order to support NERCs Compliance Monitoring and Enforcement Program and the NERC REs regarding consistency for compliance and registration across North America. EPSA broadly supports the RE delegation model, but urges NERC and the regions to expand their efforts to find solutions that support the RE delegation model while ensuring registration and compliance audit consistency. Moreover, EPSA urges NERC and the REs to engage in a collaborative effort to ensure coordination and consistent RE registration decisions. Regarding registration, EPSA strongly endorses NERCs planned action to implement the recommendations from the Ad-hoc Group for Generator Requirements at the Transmission Interface, the so-called "GOTO Team."
The filing also recommends that the Commission support NERC's plan to establish an informational compliance process, consistent with the concept of a No-Action Letter program utilized at FERC. This would allow a registered entity to describe a set of hypothetical facts and/or a proposed action for complying with a standard that would be reviewed by NERC Staff with non-binding guidance provided.
CONTACT: JOHN SHELK
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EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for nearly 40 percent of the installed generating capacity in the United States, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.