On November 16, 2017, FERC issued a Notice of Proposed Rulemaking (“NOPR”) in which it proposed to approve two Reliability Standards—PRC-027-1 (Coordination of Protection Systems for Performance During Faults) and PER-006-1 (Specific Training for Personnel)—that the North American Electric Reliability Corporation (“NERC”) submitted in a petition on September 2, 2016, and which are intended to replace currently-effective Reliability Standard PRC-001-1.1(ii) (System Protection Coordination). FERC also proposed to direct NERC to modify PRC-027-1 to require an initial protection system coordination study to ensure that applicable entities will perform (or have performed), as a baseline, a study demonstrating proper coordination of their protection systems. Lastly, FERC proposed in the NOPR to approve new and revised definitions to the NERC Glossary of Terms, the associated violation risk factors, violation severity levels, implementation plans, and effective dates for PRC-027-1 and PER-006-1, and the retirement of currently-effective PRC-001-1.1(ii).

In the NOPR, FERC stated that the purpose of Reliability Standard PRC-027-1 is to maintain the coordination of protection systems installed to detect and isolate faults on bulk electric system elements, such that those protection systems operate in the intended sequence during faults, and the purpose of Reliability Standard PER-006-1 is to ensure that personnel are trained on specific topics essential to reliability to perform or support real-time operations of the bulk electric system. FERC proposed to approve both Reliability Standards, characterizing PRC-027-1 and PER-006-1 as improving upon currently-effective Reliability Standard PRC-001-1.1(ii) in “important ways.”

Specifically, FERC stated that PRC-027-1 improves upon PRC-001-1.1(ii) by (1) modifying the applicability section to include the appropriate functional entity types with the responsibilities, resources, and skill sets to conduct the studies required to coordinate protection systems, and (2) listing the protection system functions on all bulk electric system elements that require coordination. FERC found that PER-006-1 improves upon PRC-001-1.1(ii) by ensuring that the necessary personnel are familiar with and understand the purpose and limitations of protection systems schemes while providing more precise and auditable requirements. FERC noted however that PRC-027-1, Requirement 2 “does not appear to ensure coordination of all bulk electric system elements with protection system functions” and accordingly proposed to direct NERC to develop modifications to Reliability Standard PRC-027-1 “that address our concern regarding this gap”— specifically, a requirement for an initial protection system coordination study to ensure that applicable entities will perform (or have performed), as a baseline, a study demonstrating proper coordination of their protection systems.

Comments on the NOPR are due 60 days after publication in the Federal Register.

A copy of the NOPR is available here.