In a Notice of Proposed Rulemaking (NOPR) related to the approval of NERC Reliability Standard PRC-027-1, FERC has requested additional changes that if implemented as proposed will increase protection system study requirements and create extensive new burdens for both transmission and generating companies which may strain existing technical staff resources.
PRC-027-1 aims to maintain the coordination of protection systems installed to detect and isolate faults on bulk electric system elements, so that they operate in the intended sequence during faults.
FERC’s NOPR proposes that NERC develop modifications to require utilities perform a comprehensive initial protection system coordination study on all Bulk Electric System (BES) system elements to establish a baseline analysis and demonstrate proper coordination of protection systems. NERC must submit the modified Reliability Standard for FERC approval within 12 months following the effective date of a final rule in this proceeding.
Although the standard is still pending approval, it is possible that some form of baseline study requirement will be included in the final standard. This imposition, even if limited, will create a substantial bottleneck in protection engineering resources. It is prudent to plan ahead to identify the resources that may be needed to maintain compliance.
To learn more about the Standard's background, industry comments submitted in response to the NOPR, and suggested next steps, please download our Regulatory Update.