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22. As a BA, I am required to own and maintain UFLS equipment. Why am I required toregister as a DP or LSE?Entities are registered in accordance with the criteria specified in the NERC Rules ofProcedure and the Statement of Compliance Registry Criteria (currently Revision 5.0). While aBA is a “responsible entity that integrates resource plans ahead of time, maintains loadinterchange-generationbalance within a BA area, and supports Interconnection frequency inreal time” and must have the capability to shed load to restore balance between generationand load, the responsible entity for owning and maintaining UFLS equipment is a TO or DP.The responsible entity for operating UFLS equipment is a TOP or LSE. Therefore, entitieswho own, operate or maintain UFLS equipment must be registered as a TOP and/or LSE andas a TO and/or DP, in accordance with the criteria. This ensures that no gap exists inreliability responsibility for UFLS devices.23. In VAR-002 R1, the GOP is required to operate with Automatic Voltage Regulator (AVR)in ‘service’ and in ‘auto’ unless the GOP has notified the TOP. What is SERC’s positionon standing notifications (i.e., one-time notification) for units without AVRs and/or unitsthat normally start up in manual and shut down in manual AVR?If an entity can provide evidence of a written notification that has been acknowledged andagreed upon by both parties (GOP and TOP) that the entity does not have AVR or that theunits are normally started and shut down with the AVR in manual, such evidence may beacceptable. The entity and TOP may want to consider, at a minimum, annual review of thisnotification and acknowledgement that the conditions still exist and such treatment isacceptable to both parties.24. Does SERC find that companies are filing TFEs in relation to remote access devicesthat are CCAs (i.e., laptop computers) where a “six-wall” perimeter cannot always beestablished? (Relates to CIP-006, R1.1.)No, we are not aware of any CIP-006 TFEs being submitted within SERC to cover remoteaccess CCAs at this time.25. All Regional Entities, including SERC, are experiencing significant backlogs inaudit/spot check “throughput” to resolution. Gerry Cauley has mentioned, during acouple of meetings, that it might be time to “wipe the slate clean and start over”. IsSERC pursuing with NERC permission for the possibility of suspending audits/spotchecks until they can clear their backlog?There is no initiative underway to suspend compliance monitoring activities or to provide foranother “amnesty period” similar to the opportunity provided during the period immediatelyprior to June 18, 2007. NERC and the Regions have implemented a new “AdministrativeCitation Process” beginning in January 2011 to provide for a more streamlined mechanism forPage 10 of 12
processing minor violations of the Reliability Standards. The risk-based, performance-basedcompliance monitoring approach discussed in the 2011 CMEP Annual Implementation Planrepresents an additional effort to prioritize compliance activities and more effectively managethe workload.26. Regarding the Aurora process, the documents (NERC documents on SERC website)“Pre-assessment Facility Checklist” describes under purpose, “facility managers” and“operators” of utility facilities. Would SERC please provide definitions for thesepositions and for utility facilities?SERC cannot provide the requested definitions. NERC has listed a point of contact forquestions regarding the Aurora process, and entities should reach out to NERC for necessaryclarifications.27. RE: Aurora, on the “Quick-Look Checklist”, question 1 asks if a facility containssusceptible equipment. Some utilities have large medium voltage pump motors whichwould/could be impacted by an Aurora event. But, question 2 asks, “Is it connected tothe grid?” If the answer is “no”, it says to quit the assessment. What doesNERC/SERC expect utilities to do? Please define “the grid”. Is it the transmissiongrid? Checklist item 3 uses the term “commercial power grid”. Is that the BES or alower voltage grid such as a distribution system?SERC cannot provide guidance on this request. NERC has listed a point of contact forquestions regarding the Aurora process, and entities should reach out to NERC for necessaryclarifications.28. With respect to the Aurora questions, how do you handle utility intentionalinstantaneous reclosers?SERC cannot provide guidance on this request. NERC has listed a point of contact forquestions regarding the Aurora process, and entities should reach out to NERC for necessaryclarifications.29. For EOP-004, are distribution system outages caused by natural disasters that exceed50% of a utility’s total customers reportable?A Registered Entity is expected to follow the reporting criteria established in EOP-004. EOP-004 states that reports are to be made for “[e]quipment failures/system operational activitieswhich result in the loss of firm system demand for more than 15 minutes…for all such lossesof firm demands totaling more than 200 MW or 50% of the total customers being suppliedimmediately prior to the incident, whichever is less.” While EOP-004 does not specificallyPage 11 of 12
Page 6 and 7: NOPRhttp://www.nerc.com/files/Suppl
Page 8 and 9: Also, SERC is developing a Regional
Page 12: address “distribution system outa

REF Questions & Answers - Charlotte Seminar - SERC Home Page

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