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Power & Pipes

FERC, CFTC, and State Energy Law Developments

The North American Electric Reliability Corporation (NERC) recently submitted two proposed Reliability Standards to improve the real-time data exchange capabilities of Reliability Coordinators, Transmission Operators, and Balancing Authorities. The modified Reliability Standards (IRO-002-5 and TOP-001-4) add new obligations requiring Reliability Coordinators, Transmission Operators, and Balancing Authorities to have real-time data exchange capabilities with redundant and diversely routed data exchange infrastructure within their primary control centers. These entities would also be required to test their redundant functionality at least every 90 days. 

The purpose of the standards is to ensure that these entities, which have significant responsibility for ensuring the real-time reliability of the bulk power system, do not lose their data exchange capabilities as the result of any single malfunction or component failure.

Although FERC has not yet acted on the submission, the proposed modifications respond to directives in FERC Order No. 817, which directed NERC to make modifications to the TOP and IRO Reliability Standards to address (i) monitoring of non-BES facilities by Transmission Operators, (ii) redundancy and diverse routing of data exchange capabilities, and (iii) testing of alternate or less frequently used data exchange capabilities.