Nerc Compliance And The Scarlet Letter

Michael Giberson

While the North American Electric Reliability Council (NERC) has monitored compliance with its reliability standards for years, lately it has taken compliance more seriously. (What with the big blackout in 2003, NERC’s desire to take a more prominent role in industry developments, and such things.) As of the 2004 Third Quarter Report, NERC began publicly identifying utilities determined to have violated standards.

The Third Quarter Report listed 57 “instances of non-compliance” (otherwise known as “violations”), 29 of which had been confirmed and 28 of which remained unresolved as of the report. The Fourth Quarter Report listed 210 violations, 182 of which had been confirmed. The two reports are not directly comparable – don’t conclude that violations skyrocketed in the fourth quarter – because compliance with some standards is only monitored on an annual basis.

At the May 4, 2005 open meeting of the Federal Energy Regulatory Commission (FERC), the Commissioners heard a NERC staffer’s report on compliance with NERC reliability standards. FERC Chairman Pat Wood drew attention to “naming of names” in the recent quarterly compliance, and encouraged the public to check the reports. He said he thought the “Scarlet Letter” factor would serve to encourage compliance with NERC’s reliability standard.

To find out whether your local utility has been tagged with a “Scarlet Letter,” check the quarterly reports available from the NERC website. A list of violations from the Third Quarter Report is included in the extended entry, select the “Continue reading” link below.


Here is the list of violations from the Third Quarter Report:

· 26 Operator Certification Violations: Kissimmee Utility Authority (3), Louisiana Generating Company LLC (5), Utilities Commission of New Smyrna Beach (3), Unconfirmed (15)

· 15 Consistency Violations With Regional Underfrequency Load Shedding Requirements: Louisiana Generating Company LLC, North Carolina Electric Membership Corp., Old Dominion Electric Cooperative, Unconfirmed (12)

· 5 Transmission Protection System Maintenance and Testing Violations: AEN Transmission, Alabama Power Company, Georgia Power Company, Missouri Public Service, Savannah Electric & Power Company

· 3 Backup Control Center Violations: AEN Transmission, Missouri Public Service, Sunflower Electric

· 2 Control Performance Standard Violations: Dayton Power and Light, Columbia Water and Light Department

· 2 Disturbance Control Standard Violations: ERCOT, Unconfirmed (1)

· 1 System Adequacy and Security, Transmission Systems, Extreme Contingencies Violation: Associated Electric Cooperative Inc.

· 1 Capacity and Energy Emergency Plans Violation: Sunflower Electric

· 1 Blackout Restoration Plan Violation: Sunflower Electric

· 1 Regional Measure Violation: Missouri Public Service

In all of these cases, the violations were judged not to have had a significant adverse affect on system reliability. The reports includes additional detail on the “instances of non-compliance,” sometimes including notes on planned remedies. The Fourth Quarter Report is a little too long to post here, but with 210 violations reported it is certainly possible that your local utility or a utility close by was in violation of one of NERC’s standards.