On Jan. 18, 2018, the Federal Energy Regulatory Commission (FERC) issued Order 840 addressing Emergency Preparedness and Operations Reliability Standards. The final rule approved:

  • Emergency Preparedness and Operations (EOP) Reliability Standards EOP-004-4 (event reporting)
  • EOP-005-3 (system restoration from black start resources)
  • EOP-006-3 (system restoration coordination)
  • EOP-008-2 (loss of control center functionality)

In the order, FERC also approved the associated violation risk factors, violation severity levels, implementation plans and effective dates for the above standards. FERC set the retirement of the currently effective Reliability Standards EOP-004-3, EOP-005-2, EOP-006-2 and EOP-008-1 for “immediately prior to the effective dates of the EOP Reliability Standards.” Check out the full 20-page FERC order here.

FERC assessed that the approved EOP Reliability Standards will improve reliability by:

  1. Providing accurate reporting of events to the North American Electric Reliability Corp.’s (NERC) event analysis (Reliability Standard EOP-004-4)
  2. Delineating the roles and responsibilities of entities that support system restoration from black start resources (Reliability Standard EOP-005-3)
  3. Clarifying the procedures and coordination requirements for reliability coordinator personnel (Reliability Standard EOP-006-3)
  4. Refining the required elements of an operating plan used to continue reliable operations of the bulk electric system in the event that primary control center functionality is lost (Reliability Standard EOP-008-2)

NERC filed a petition with FERC on March 27, 2017, seeking approval for the proposed EOP standards and retirement of the currently effective Reliability Standards EOP-004-3, EOP-005-2, EOP-006-2 and EOP-008-1. NERC explained in the petition that the changes were intended to:

  1. Streamline the currently effective EOP Reliability Standards
  2. Remove redundancies and other unnecessary language while making the reliability standards more results-based
  3. Address the commission’s concern articulated in Order No. 749 regarding system restoration training
James Crawford III is senior consultant and project manager at Burns & McDonnell for the Governance, Risk, Cybersecurity and Compliance Group. Over a career spanning almost three decades, James has specialized in helping utility clients improve governance and mitigate risk, with a focus on filing and compliance requirements set by the U.S. Federal Energy Regulatory Commission.