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RELIABILITY | RESILIENCE | SECURITY Reliability and Security Technical Committee Update Greg Ford, Chair Member Representatives Committee Meeting February 5, 2020

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Page 1: Reliability and Security Technical Committee Update Highlights nad...• Create Reliability and Security Technical Committee (RSTC) • Retain existing subcommittees, working groups,

RELIABILITY | RESILIENCE | SECURITY

Reliability and Security Technical Committee UpdateGreg Ford, Chair Member Representatives Committee MeetingFebruary 5, 2020

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• Approved Committee Structure• Chair and Vice Chair, Nominating Subcommittee• Sector Nominations• At-Large Nominations• Transition Plan

Discussion Topics

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• Create Reliability and Security Technical Committee (RSTC)• Retain existing subcommittees, working groups, and task forces

Approved Committee Structure

NERC Board

OC Subcommittees, Working Groups,

Task Forces

Reliability and Security Technical Committee

PC Subcommittees, Working Groups,

Task Forces

CIPC Subcommittees, Working Groups,

Task Forces

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• The Board appointed the officers of the RSTC at the November board meeting. Both positions are for two-year terms Chair: Greg Ford, Georgia System Operations Vice Chair: David Zwergel, MISO

• Per the RSTC proposal, the nominating subcommittee developed a proposed slate of At-Large members to the NERC Board

• For the initial seating of At-Large members, the Nominating Subcommittee consisted of: NERC Board Vice Chair NERC CEO RSTC Chair RSTC Vice Chair MRC Vice Chair

Chair, Vice Chair and Nominating Subcommittee

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• The Sector Nomination period was held November 12 – December 6, 2019

• Nominees were sought for two representatives from Sectors 1-10, 12.• All Sector Election material can be found here:

https://www.nerc.com/comm/RSTC/Pages/2019-RSTC-Election.aspx• The following sectors had more than two nominees: Sector 1 – Investor Owned Utility Sector 2 – State/Municipal Utility Sector 4 – Federal or Provincial Utility/Power Marketing Administration Sector 6 – Merchant Electricity Generator Sector 7 – Electricity Marketer Sector 8 – Large End Use Electricity Customer Sector 9 – Small End Use Electricity Customer

• Sector elections were December 9-20, 2019

Sector Nominations

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• The final Sector slate, pending Board approval at its February 6, 2020 meeting:

Sector Representatives

Sector Elected Members1. Investor-owned utility Greg Stone (Duke Energy) – 2020-2023

Kayla Messamore (Evergy) – 2020-2022

2. State/municipal utility Saul Rojas (NYPA) – 2020-2023Chris Shepherd (Gannett Fleming) – 2020-2022

3. Cooperative utility Marc Child (Great River Energy) – 2020-2023Ben Engelby (Arizona G&T Cooperatives) – 2020-2022

4. Federal or provincial utility/Federal

Power Marketing Administration

Robert Reinmuller (Hydro One) – 2020-2023Edison Elizeh (Bonneville Power) – 2020-2022

5. Transmission dependent utility John Stephens (City Utilities of Springfield) – 2020-2023Carl Turner (Florida Municipal Power) – 2020-2022

6. Merchant electricity generator Allen Schriver (NextEra Energy) – 2020-2023Sheranee Nedd (Public Service Enterprise Group) – 2020-2022

7. Electricity Marketer Kyle Vander Helm (Tenaska, Inc.) – 2020-2023Jodirah Green (ACES Power) – 2020-2022

8. Large end-use electricity customer John Hughes (Electricity Consumers Resource Council) – 2020-2023Venona Greaff (Occidental Chemical) – 2020-2022

9. Small end-use electricity customer Darryl Lawrence (PA Office of Consumer Advocate) – 2020-2023David Mulcahy (Modern Energy) – 2020-2022

10. Independent system operator/regional transmission organization

Wesley Yeomans (NY Independent System Operator) – 2020-2023Christine Hasha (ERCOT) – 2020-2022

12. State Government Christine Ericson (Illinois Commerce Commission) – 2020-2023Cezar Panait (Minnesota Public Utilities Commission) – 2020-2022

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• The At-Large Nomination period was held December 27, 2019 through January 10, 2020

• All At-Large Election material can be found here: https://www.nerc.com/comm/RSTC/Pages/2019-At-Large-Nominations.aspx

• The Nominating Subcommittee reviewed all At-Large nominees and recommend a slate of 10 nominees for NERC Board appointment

• Factors considered: Interconnection Diversity Canadian Representation Broad spectrum of entity sector/size Areas of expertise such as operations, planning and security

At-Large Nominations

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• At-Large Nominees, Company and Terms: Patrick Doyle, Hydro Quebec – 2020-2023 David Jacobson, Manitoba Hydro – 2020-2023 Sandra Ellis, Pacific Gas & Electric Company – 2020-2023 Rich Hydzik, Avista – 2020-2023 Todd Lucas, Southern Company – 2020-2023 Wayne Guttormson, Sask Power – 2020-2022 Lloyd Linke, WAPA, Upper Great Plains Region – 2020-2022 Brian Evans-Mongeon, Utility Service – 2020-2022 Jeff Harrison, Associated Electric Cooperative – 2020-2022 Peter Brandien, ISO NE – 2020-2022

At-Large Nominations

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Transition Plan Highlights Completed

• Past meeting agenda/notes packages posted on SET web page https://www.nerc.com/comm/Pages/Stakeholder-Engagement-Team.aspx

• November 5, 2019 – Board approved Proposal, Charter, and Transition Plan; appointed chair and vice chair

• November 6, 2019 – Open Sector nomination period • December 6, 2019 – Sector nomination period ends. Sector

elections ended December 20, 2019• December 27, 2019 – January 10, 2020 – At-Large nomination

period • January, 2020 – Nominating Subcommittee to develop slate of

At-Large nominees for presentation to the Board

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Transition Plan Highlights Going Forward

• February 6, 2020 – Board appoints RSTC members (Sector and At-Large). Two year terms will expire in June of alternating years following initial terms (two or three years)

• February 7–May 29, 2020 – RSTC develops transition plan and work plans for RSTC and subcommittees

• March 3-4, 2020 – OC, PC, and CIPC will meet for final work plan and any other approvals. The RSTC will meet March 4, 2020 for the inaugural meeting

• June 10-11, 2020 –The RSTC will hold initial regular meeting

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Future Work

• Board appointed Chair and Vice Chair will review October, 2019 Policy Input for potential implementation plan enhancements

• Chair and Vice Chair coordinating with OC, PC and CIPC leadership on transition plan details

• Appoint Executive Committee• More detailed Work Plan development will begin

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ERO Enterprise Effectiveness Survey UpdateKristin Iwanechko, Associate Director, Regional and Stakeholder RelationsMember Representatives Committee MeetingFebruary 5, 2020

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• Survey issued as one measure of the effectiveness of the ERO Enterprise in executing program activities

• Reevaluated survey approach for effectiveness and efficiency• Current approach Complicated Inefficient Ineffective Duplicative

ERO Enterprise Effectiveness Survey

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• Focus on more targeted efforts to maintain effective engagement Discontinue ERO Enterprise Effectiveness Survey E-ISAC to conduct targeted surveys to E-ISAC members Compliance and Certification Committee reviewing its survey questions

and reevaluating how it receives input on stakeholder perceptions Continue to receive industry feedback through existing avenues

• Actively work to minimize survey burden on industry Coordinate the need for and timing of surveys to minimize overlaps Coordinate with Regional Entity survey efforts

Approach for Future Surveys

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EMP Strategic RecommendationsHoward Gugel, Vice President of Engineering and StandardsMember Representatives Committee MeetingFebruary 5, 2020

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EMP Phased Approach

Phase 1• Strategic Recommendations

Phase 2• Technical Committee Work

Phase 3• Standard Drafting Team (if applicable)

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Key Task Force Milestones – Phase 1

June July August October November

• Numerous TF calls• Face-to-face

meeting (Washington DC)

• Numerous TF calls• Charter development• Technical workshop (ATL)

• Develop Strategic Recommendations

• Post for industry comment (30 days, end of August)

• Review industry comments• Present recommendations with

action items and next steps to appropriate committee

• Present recommendations to Board of Trustees

Phase 2

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• EMP Task Force report to Reliability and Security Technical Committee

• EMP Task Force priorities Establish performance expectations Provide guidance on asset hardening Provide guidance to industry for supporting systems and equipment for

recovery

• ERO Enterprise priorities Support additional research to close gaps Develop tools and methods for assessing electromagnetic pulse impacts

NERC Staff Recommendations

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• Agree with the recommendations?• Agree with the priority levels?• Additional recommendations for consideration?

Policy Input Request

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Summary of Policy Input

• Support EMP Task Force continuation with work plan• Recognize boundaries• Review December 20, 2019 US federal law• Reconcile policy input letter and Task Force recommendations• Potential broader scope (communications and fleet)• Implement holistically with respect to resiliency

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Summary of Policy Input

• Consideration of Distributed Energy Resources and battery management systems

• Involve the Nuclear Regulatory Commission in any impact to nuclear plants

• Global ranking should be established• Action should be taken on all recommendations• Reason for EMP Task Force omitted• Responsible parties different from Task Force recommendations

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Changes based on policy input

• Add “to regularly coordinate and collaborate with governmental authorities to procure and effectively disseminate information needed by industry” to Task Force recommendation for clarity

• Require detailed work plan EMP Task Force NERC staff

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Supply Chain Risk Assessment

Howard Gugel, Vice President of Engineering and StandardsMember Representatives Committee MeetingFebruary 5, 2020

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• Support effective and efficient implementation (e.g. CIP V5 transition)

• Supply chain risk study• Communicate supply chain risks to industry • Forum and Association white papers• Plan to evaluate effectiveness of supply chain standards

Board Resolution

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• Include in Supply Chain Standards Electronic access controls for medium and high impact Bulk Electric System

(BES) Cyber Systems Physical access controls for medium and high impact BES Cyber Systems

• Do not include in Supply Chain Standards Electronic access monitoring and logging Physical access monitoring and logging Protected Cyber Assets(PCAs)

• Collect more data on low impact BES Cyber Systems• Develop guidelines with CIPC Supply Chain Working Group

(SCWG) Application to lows Evaluation of PCAs

Recommendations from Study

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• Issued on August 19• Responses due October 3• Applicable to entities in CIP-002-5.1a• Focused on low impact BES

Data Request Issued

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BES Cyber Assets

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BES Cyber Assets with Medium and High

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BES Cyber Assets with Lows Only

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• Most low impact assets reside in organizations with higher impact assets

• Many are not planning to apply supply chain risk management plans to low impact assets

• Most low impact assets are individually lowest risk, but a coordinated attack could impact reliability

• Significant percentage of generation resources allow third party access

• Significant percentage of “low only” transmission stations and substations allow third party access

Observations

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• Include low impact BES Cyber Systems with remote electronic access connectivity in future modification of Supply Chain Standards

Recommendation

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• Agree with the recommendation?• Alternate cost effective way to address the risk?

Policy Input Request

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• Premature to act until highs and mediums implemented Modifications should wait until at least July 2021

• Unclear whether existing CIP-003 risk mitigation was considered See electronic access controls in CIP-003-7, Attachment 1 Consider augmenting CIP-003 Adding lows in Supply Chain Standards conflicts with CIP-002 model Conflicts with “no inventory” approach for lows

• Risk conclusions need more thorough technical analysis• Additional data needed

Summary of Policy Input

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• Coordination with entities that use third party access to have monitoring and controls in place to limit the exposure

• Not a supply chain risk, but connectivity risk• Focus on entry points• Focus on risk, not a particular standard• Survey did not take into account existing strategies

Summary of Policy Input

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• Continual revisions add to risk• Concern about lack of consideration of SCWG input• Adds burden to challenged supplier/vendor relationship • Use the NATF industry collaboration initiative• Supply chain certification program for vendors

Summary of Policy Input

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• Confine changes to CIP-003• Include policies to: Detect known or suspected malicious communications for both inbound

and outbound communications Determine active vendor remote access sessions Disable active vendor remote access

• After implementation of Supply Chain Standards Evaluate effectiveness Consider adding supply chain policy in CIP-003 for low impact BES Cyber

Systems

Changes Based on Policy Input

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Recent FERC ActivityAndy DodgeDirector, Office of Electric ReliabilityFederal Energy Regulatory CommissionFebruary 5, 2020

The views expressed in this presentation are my own and do not represent those of the Commission or any individual Commissioner

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NERC Five-Year Performance Assessment

• Order in RR19-7 issued 1/23/20• Accepts NERC’s filing and finds that NERC and REs continue to satisfy

statutory and regulatory criteria for ERO certification• Recognizes the achievements of NERC and the REs over the last five

years, including risk-based approach focusing ERO resources on matters of most significance to reliability

• Identifies improvements and provides directives on NERC’s:• Provide oversight of the Regional Entities per the Rules of Procedure• Document the process for developing and evaluating reliability and

security guidelines• Oversight and performance metrics for E-ISAC• Update sanction guidelines• Develop and document the organization certification program

• Directs NERC to submit a compliance filing within 90 days and a second compliance filing within 180 days revising its Rules of Procedure 2

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Reliability Standard TPL-001-5:Transmission System Planning Performance• Final rule issued in RM19-10-000 issued 1/23/20• Improves upon currently-effective TPL-001-4 by providing for:

• More comprehensive study of single points of failure of protection systems

• Stability analysis to assess the impact of the possible unavailability of long lead time equipment

• More complete consideration of factors for study of planned maintenance outages

• Declines to pursue other proposals from NOPR• Effective 60 days after publication in Federal Register

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Reliability Standard CIP-012-1: Communications Between Control Centers

• Final Rule in RM18-20-000 issued 1/23/20• Approves Reliability Standard CIP-012-1 because it is largely

responsive to the Commission’s directive in Order No. 822 and improves the cyber security posture of responsible entities

• Requires responsible entities to protect the confidentiality and integrity of Real-time Assessment and Real-time monitoring data transmitted between bulk electric system Control Centers

• Directs NERC to develop and submit modifications to the Reliability Standards to require protections regarding the availability of communication links and data communicated between bulk electric system Control Centers

• Declines to adopt other directive in NOPR regarding identification of data

• Effective 60 days after publication in Federal Register4

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Standards Efficiency Review Phase I

• NOPR issued in RM19-16 and RM19-17 on 1/23/20• Proposes to approve the retirement of 74 Reliability Standard

requirements associated largely with the calculation of Available Transfer Capacity

• Proposes to remand one requirement submitted for retirement by NERC (VAR-001-6 R2) because it is the only requirement that requires the scheduling of reactive power

• Seeks additional information from NERC on two requirements submitted for retirement (FAC-008-3 Requirements R7 and R8) regarding identifying the most limiting element of a facility and sharing facility ratings

• Comments due 60 days after publication in Federal Register

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Compliance Filings on Reform of Generator Interconnection Procedures & Agreements• Order No. 845 Final Rule in RM17-8 issued 2/21/19

• Adopted 10 reforms to improve certainty for interconnection customers, promote more informed interconnection decisions and enhance the interconnection process

• Required each public utility transmission provider to submit a compliance filing by 5/22/19

• Commission acted on first batch of filings on 11/21/19 and second batch on 12/19/19

• Third batch of orders on compliance for Order No. 845 issued 1/23/20

• Commission partially accepted compliance filings and directing further compliance filings for seven utilities and SPP

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Compliance Filings on Storage Rule

• Enacted in February 2018, Order No. 841 requires RTOs and ISOs to develop rules to remove barriers to participation of electric storage resources in the capacity, energy and ancillary services markets operated by RTOs/ISOs

• Each organized power market must revise its tariff to establish a participation model with market rules to recognize the physical and operational characteristics of electric storage resources and facilitate their participation in markets

• Deadline for initial compliance filings was 12/3/19• Commission issued orders on compliance:

• NYISO, 12/19/19• CAISO, ISO-NE and MISO, 11/21/19• PJM and SPP, 10/17/19

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Grid-Enhancing Technologies Workshop

• Staff-led workshop in AD19-19 held 11/5-6/19 at FERC headquarters• Grid-enhancing technologies include, but are not limited to: power

flow control and transmission switching equipment, storage technologies and advanced line rating methodologies

• Panels addressed GETs that increase the capacity, efficiency or reliability of transmission facilities and explored:• How GETs are currently used in transmission planning and

operations• The challenges to deployment and implementation of GETs• Regulatory approaches and actions the Commission can take to

facilitate adoption of GETs• Post workshop comments due 2/14/20

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• Thank you!

• Questions?

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Framework for Risk Identification & Mitigation

Mark Lauby, Senior Vice President & Chief EngineerMember Representatives Committee MeetingFebruary 5, 2020

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Declaration & Problem

• Declaration:The Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

• Problem Statement: ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes,

for example: webinars and conferences, lessons learned, Alerts, Guidelines, and standard development.

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include: risk identification, deployment of mitigation strategies, to monitoring the success of these mitigations

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Six-Step Framework

1. Risk Identification2. Risk Prioritization3. Mitigation Identification and Evaluation4. Mitigation Deployment5. Measurement of Success6. Monitor Residual Risk

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Risk Identification

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Risk Prioritization

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Mitigation Identification and Evaluation

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Mitigation Deployment

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Measurement of Success

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Monitor Residual Risk

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Monitor Residual Risk

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Monitor Residual Risk

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Monitor Residual Risk

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Reliability Toolkit: Guiding Principles

1. Reliability Standards address sustained risks with moderate impacts which are probable, and severe impacts which are probable or improbable.

2. Reliability Guidelines used to address sustained risks that are probable or improbable. Guidelines are also used for items not in the ERO Enterprise’s jurisdiction, or are practices that improve reliability beyond standards.

3. Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable.

4. Alerts will be used for time sensitive information, for information, to request action or direct action.

5. A combination of tools can be used towards gaining industry action, setting the stage for standards as well as addressing a risk while a Standard is being developed. Likelihood, pervasiveness, and severity have a bearing when a Reliability Standard is required.

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Reliability Tools: Risk Likelihood and Impact

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Reliability Tools: Risk Likelihood and Impact

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RELIABILITY | RESILIENCE | SECURITY16

Reliability Tools: Risk Likelihood and Impact

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Reliability Tools: Risk Likelihood and Impact

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RELIABILITY | RESILIENCE | SECURITY18

Reliability Tools: Risk Likelihood and Impact

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Risk Management Timeframe

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Risk Management Timeframe

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Risk Management Timeframe

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Risk Management Timeframe

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Risk Management Timeframe

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Risk Management Timeframe

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Risk Management Timeframe

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RELIABILITY | RESILIENCE | SECURITY26

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Grid Transformation Impacts on Reliability Framework

SYLVAIN CLERMONT – Director, Operational Technologies ConvergenceHydro-Québec TransÉnergie

ERIC UDREN – Executive Advisor, Quanta Technology LLC

HOWARD GUGEL – VP Engineering and standards,NERC

MUKUND KAUSHIK – Director of Digital, Southern California Edison

NERC Member Representative Committee| February 5, 2020

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2 Hydro-Québec

Transformations in:• Power generation, transmission and

distribution• Energy consumption habits• Utility business model

Factors contributing to this:• Climate change• Technology• Desire to make power system more

efficient• Aging infrastructures

We are in the midst of an energy transition

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3 Hydro-Québec

Major Trends: the 3 Ds

DECENTRALIZATION– Utility customers are

becoming prosumers– Electric vehicles– Microgrids– Demand-side

management– Solar panels, energy

storage

DIGITALIZATION– Digital substations– Advanced analytics– Assets performance

management– Increased infrastructure

automation– Smarter grids– Increase cybersecurity

DECARBONIZATION– Declining renewable

costs– Declining Energy storage

costs

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4 Hydro-Québec

Possible evolutions1. The introduction of a new

technological platform enabling, in particular, the remote control of assets (intelligent electronic devices, IED);

2. The move towards dynamic asset management;

3. The move towards autonomous, adaptive, predictable and flexible operations.

Possible applications

• Situational Awareness

• Internet of Things

• Dynamic State Estimators (local and centralized)

• Numerical Twin

• Artificial Intelligence

• Dynamic Load Forecast

• Augmented Reality

Digitalization

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5 Hydro-Québec

• Standards and standards development

• Compliance

• Reliability Assessments

What is the reliability framework?

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6 Hydro-Québec

–Cloud-based solutions–Virtualization–Cybersecurity with Intelligent Electronic Devices (IED)–Traceability of supply chain with high level of

numerical devices–Dynamic Relay Setting–Communication between substations–Flood of data–Wide area synchrophasor

What are the impacts on the reliability framework?

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7 Hydro-Québec

• Eric Udren• Executive Advisor – Quanta

Technology LLC

• Howard Gugel• VP Engineering and standards –

NERC

• Mukund Kaushik• Director of Digital – Southern

California Edison

Panelists