United States: FERC Approves Transmission GMD Reliability Standard

On September 22, 2016, the Commission approved Reliability Standard TPL-007-1 (Transmission System Planned Performance for Geomagnetic Disturbance Events), which establishes for the first time mandatory requirements for Transmission Owners and other entities to assess the vulnerability of transmission systems to geomagnetic disturbance events ("GMDs"), which occur when the sun ejects charged particles that cause changes in the earth's magnetic fields. The Standard requires that entities who do not meet certain performance requirements, based on the results of their vulnerability assessments, develop a plan to achieve those performance requirements. The Commission also affirmed that recovery for prudent costs to comply with TPL-007-1, including for the purchase and installation of monitoring devices, will be available to registered entities.

In Order No. 779, the Commission directed the North American Electric Reliability Corporation ("NERC") to develop and submit for approval proposed Reliability Standards that address the impact of GMD on the reliable operation of the Bulk-Power System ("BPS") (see May 20, 2013 edition of the WER). Specifically, the Commission directed NERC to submit one or more Reliability Standards that require owners and operators of the BPS to conduct initial and on-going assessments of the potential impact of "benchmark" GMD events—meaning events with a 1-in-100 year frequency of occurrence and based on specific technical factors—on BPS equipment and on the BPS as a whole. In the event that the assessments identified potential impacts from benchmark GMD events, the Commission directed that the Standard require owners and operators to develop and implement a plan to protect against instability, uncontrolled separation, or cascading failures of the BPS. NERC submitted TPL-007-1 for approval on January 21, 2015.

In its September 22, 2016 order, the Commission found that TPL-007-1 complied with its directives from Order No. 779 by requiring applicable entities to: (i) conduct, on a recurring five-year cycle, initial and on-going vulnerability assessments regarding the potential impact of a benchmark GMD event on the BPS as a whole and on BPS components; and (ii) develop and implement corrective action plans to mitigate vulnerabilities identified through those recurring vulnerability assessments. The Commission noted that potential mitigation strategies identified in the proposed Reliability Standard include, but are not limited to, the installation, modification or removal of transmission and generation facilities and associated equipment. Additionally, the Commission approved the inclusion of the term "Geomagnetic Disturbance Vulnerability Assessment or GMD Vulnerability Assessment" in the NERC Glossary, the associated violation risk factors and violation severity levels for TPL-007-1, and NERC's proposed implementation plan and effective dates. The Commission also affirmed that cost recovery for prudent costs associated with or incurred to comply with TPL-007-1, and future revisions to the Reliability Standard, will be available to registered entities.

Lastly, the Commission directed NERC to develop and submit, within 18 months of the effective date of the order, modifications to TPL-007-1 to: (1) revise the benchmark GMD event definition set forth in Attachment 1 of the Reliability Standard so that the definition is not based solely on "spatially-averaged data"— meaning the averaging of geoelectric field amplitude readings within a given area; (2) require the collection of necessary geomagnetically induced current ("GIC") monitoring and magnetometer data and make such data publicly available; and (3) include a one-year deadline for the completion of corrective action plans and two- and four-year deadlines to complete mitigation actions involving non-hardware and hardware mitigation, respectively. The Commission also directed NERC to submit a work plan within six months of the effective date of the order and, subsequently, one or more informational filings that address specific GMD-related research areas.

A copy of the Commission's order, Order No. 830, can be found here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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