Large Public Power Council Board Member Testifies at FERC Technical Conference on NERC Compliance Reform and Reliability Assurance, June 4, 2015

June 4, 2015
Contact: Lawrence Pacheco
(202) 346-8855

Washington, D.C. —Steve Wright, General Manager of Chelan County Public Utility District No. 1 and Large Public Power Council (LPPC) board member, testified today before the Federal Energy Regulatory Commission (FERC) on North American Electric Reliability Corporation (NERC) compliance reform and on the need for reliability assessments in advance of new federal or state energy regulations. Wright also addressed the state of reliability standards, security challenges and Critical Infrastructure Protection (CIP) Version 5 implementation and compliance challenges. His comments were heard at a FERC reliability technical conference on policy issues related to the reliability of the bulk-power system.

Wright told FERC that NERC’s current “steady-state” in respect to its FERC-approved mandatory and enforceable reliability standards has been a welcome change from past years and that achieving stability will enable industry subject matter experts to focus their attention on responding to existing standards more effectively and efficiently.

“NERC and stakeholders should collectively address remaining reliability gaps but the highest priority now is the completion of a risk-based approach to reliability compliance and enforcement.” Wright stated.

In his testimony Wright stated that NERC’s Risk-Based Compliance Monitoring and Enforcement Program appears to be sound.

“The program should not be one-size-fits-all. By starting with a risk assessment at the Regional Entity level and then working down to individualized assessments for registered entities, NERC appears to be taking actions that will lead to an approach tailored to individual registered entities.” He also suggested that the extension of audit cycles for appropriate entities would result in significant savings without compromising reliability.

In regards to security challenges, Wright told FERC that LPPC strongly supports the Electric Sub-Sector Coordinating Council process. Though, he noted that one area of improvement would be greater speed in sharing actionable information.

Wright commended NERC’s CIP Version 5, stating that the key to the new approach lies in giving registered entities flexibility in evaluating the risks they face and needed responses, enabling them to take into account their unique circumstances. He noted that LPPC has concerns regarding the transition from Version 3 to Version 5 and warned that forceful NERC compliance guidance may be altering the meaning of approved standards.

Finally, Wright spoke on the importance of reliability reviews in future federal and state regulatory proposals in order to maintain security of the electric grid and affordable power prices. Because of NERC’s unparalleled core competence on electric reliability matters and its unbiased approach, he stressed the importance of involvement from FERC and NERC as future regulations are considered.

Click here for Wright’s full testimony from today’s hearing.

LPPC represents 25 of the largest locally governed and operated not-for-profit electric systems in the United States. Our member utilities are located in 13 states and Puerto Rico and own and operate more than 71,000 megawatts of generation capacity and more than 30,000 circuit miles of high voltage transmission lines. LPPC member utilities supply electricity to some of the largest cities in the country including Los Angeles, Seattle, Omaha, Phoenix, Sacramento, Jacksonville, San Antonio, Orlando and Austin.