Category: FERC

TariffShark Software Update Available Now

TariffShark Software Update Available Now

On April 17, 2020, FERC issued a notice that introduced a new eTariff validation rule to become effective May 18, 2020. The new validation verifies that “Normal” and “Amendment” type filings contain at least one (1) “actual” (non-Pro Forma) tariff record.

A TariffShark software update (release 5.1.3) is available now that introduces a parallel validation. The new validation rule in TariffShark is “F065” and its message reads as follows:

When making a Normal or Amendment filing, the Filing cannot contain exclusively FTRVs of Record Change Type “Pro Forma”.

If you’re running TariffShark release 5.1.2, the only component affected is the Application Server (unaffected are the TariffShark desktop client and the TariffShark database). Consult the TariffShark Releases page to assess the impact to your installation.

For customers who utilize hosted TariffShark servers and are running a current software release, there is nothing for you to do. We will update your hosted server prior to May 18.

Please contact TariffShark Support at 847-252-1611 or at support@tariffshark.com if you have any questions or concerns.

If you’re not yet using TariffShark to meet your FERC eTariff obligations, we invite you to contact sales and ask for a demo of TariffShark Tiger today.

FERC Released Recommendations to Improve Security

FERC Released Recommendations to Improve Security

On March 29, the Federal Energy Regulatory Commission (FERC) issued a report that had recommendations to help the “users, owners and operators of the bulk-power system assess their risks, compliance efforts and overall cyber security posture.” The suggestions in the report are all based upon the lessons FERC learned during the 2018 fiscal year from “non-public audits of several registered entities of the Bulk Electric System and staff reviews of emerging advanced cyber and physical threats to energy infrastructure.” Those lessons will help FERC improve security for “the nation’s electric grid, strengthen cyber security and help facilitate compliance with mandatory reliability standards.”

“FERC’s Office of Electric Reliability, with assistance from its Office of Enforcement, conducted the audits in collaboration with the North American Electric Reliability Corporation (NERC) and its regional entities.” The FERC Office of Energy Infrastructure also assisted with analyzing the data obtained by the audit.

The report’s recommendations are:

  • “Enhance documented processes and procedures for security awareness training to consider NIST SP 800-50, ‘Building an Information Technology Security Awareness and Training Program’ guidance.
  • Consider implementing valid Security Certificates within the boundaries of BES Cyber Systems with encryption sufficiently strong enough to ensure proper authentication of internal connections.
  • Consider implementing encryption for Interactive Remote Access (IRA) that is sufficiently strong enough to protect the data that is sent between the remote access client and the BES Cyber System’s Intermediate System.
  • Consider Internet Control Message Protocol (ICMP) as a logical access port for all the BES Cyber Assets.
  • Enhance documented processes and procedures for incident response to consider the NIST SP 800-61, “Computer Security Incident Handling Guide.”
  • Consider the remote configuration of applicable Cyber Assets via a TCP/IP-toRS232 Bridge during vulnerability assessments.
  • Consider the use of secure administrative hosts to perform administrative tasks when accessing either Electronic Access Control or Monitoring Systems (EACMS) or Physical Access Control Systems (PACS).
  • Consider replacing or upgrading “End-of-Life” system components of an applicable Cyber Asset.
  • Consider incorporating file verification methods, such as hashing, during manual patching processes and procedures, where appropriate.
  • Consider using automated mechanisms that enforce asset inventory updates during configuration management.”

The report also notes some lessons they previously learned:

  • “Conduct a thorough review of CIP Reliability Standards compliance documentation to identify where the documented instructional processes are inconsistent with actual processes employed.
  • For each remote cyber asset conducting IRA, disable all other network access outside of the connection to the applicable Cyber System that is being remotely accessed, unless there is a documented business or operational need.
  • Enhance documented processes and procedures for identifying BES Cyber System Information to consider the NERC Critical Infrastructure Protection Committee guidance document, ‘Security Guideline for the Electricity Sector: Protecting Sensitive Information.’”

“The audits evaluated the registered entities’ compliance with the applicable Critical Infrastructure Protection (CIP) Reliability Standards and identified other possible areas for improvement not specifically addressed by the CIP reliability standards.”

FERC Issues Final Rules to Revise Regulations to Confirm with the FPA’s Recent Changes

FERC Issues Final Rules to Revise Regulations to Confirm with the FPA’s Recent Changes

On February 21, the Federal Energy Regulatory Commission (FERC) issued two final rules revising regulations in order to conform to recent changes made by Congress to the Federal Power Act (FPA), in relation to FERC’s review of hydropower permits and public utility mergers.

The rule related to mergers “implements statutory changes to FPA section 203 by amending FERC regulations requiring a public utility to seek authorization to merge or consolidate jurisdictional facilities so that such authorization is required only when those facilities are valued at more than $10 million.”

These revisions will also require public utility companies to tell FERC about “mergers or consolidations if the facilities are valued at more than $1 million but less than $10 million.” It will also “reduce the regulatory burden on utilities for lower-value transactions, and the final action comes within the 180-day period set by Congress.”

The rule about hydropower “conforms the Commission’s regulations to the America’s Water Infrastructure Act of 2018, which amended sections of the FPA related to preliminary permits, qualifying conduit hydropower facilities, and start for payment of annual charges. Under the Act and the Commission’s amended rules, FERC can issue preliminary permits for four years and extend a permit once for an additional four years, instead of three-year terms for preliminary permits with a possible two-year extension.”

This rule also now allows FERC to “issue a second four-year extension if warranted by extraordinary circumstances.” FERC also increased the “maximum installed capacity for qualifying conduit exemptions is increased from five megawatts (MW) to 40 MW.”

FERC was authorized by the Act to “to issue extensions of the start of construction deadline for licenses for up to eight years, which affects the start of the payment of annual charges … Annual charges will begin two years after a license is issued or any extension deadline expires.”

The third rule FERC issued was to clarify and update the “requirements related to interlocking officers and directors.” FERC’s position on “late-filed applications and informational reports” was also clarified.

FERC Clarifies Reforms of Generator Interconnection Procedures and Agreements

FERC Clarifies Reforms of Generator Interconnection Procedures and Agreements

The Federal Energy Regulatory Commission (FERC) clarified its position on Order 845 on February 21. “Order No. 845 adopted ten reforms to improve certainty for interconnection customers, promote more informed interconnection decisions, and enhance the interconnection process.”

FERC received 12 requests for a rehearing or clarification on Order 845. “The draft order grants in part and denies in part the requests for rehearing and clarification.” While most of the reforms in 845 will remain unchanged, FERC granted the rehearing for some of the reforms. The rehearing was granted to clarify “two aspects of the reform to remove a limitation on the interconnection customer’s option to build.”

The Order requires “transmission providers [to] explain why they do not consider a specific network upgrade to be a standalone network upgrade, and second, allows transmission providers to recover option to build oversight costs.” It also clarifies two different parts of the “option to build reform by finding, first, that the Order No. 845 option to build provisions apply to all public utility transmission providers, including those that reimburse interconnection customers for network upgrades, and second, that the option to build does not apply to stand alone network upgrades on affected systems.”

The rehearing also covered reforms to “create a surplus interconnection service process,” explaining that FERC has no intentions to “limit the ability of RTOs and ISOs to argue that an independent entity variation is appropriate.”

There were clarifications regarding the “study model and assumption transparency.” It found that:

  • “Transmission providers may use the Commission’s critical energy/electric infrastructure information regulations as a model for evaluating entities that request network model information and assumptions.”
  • “The phrase ‘current system conditions’ does not require transmission providers to maintain network models that reflect current real-time operating conditions of the transmission provider’s system but should reflect the system conditions currently used in interconnection studies.”

They also clarified the reforms to “institute interconnection study deadline reporting requirements.” Another clarification was on “the date for measuring study performance metrics and clarifies that the reporting requirements do not require transmission providers to post 2017 interconnection study metrics. Instead, the first required report will be for the first quarter of 2020.”

As for the reforms on “requesting interconnection service below generating facility capacity,” a partial rehearing was granted “to find that an interconnection customer may propose control technologies at any time at which it is permitted to request interconnection service below generating facility capacity.”

They also addressed “the reform that allows interconnection customers to request interconnection service below generating facility capacity,” clarifying that transmission providers “must provide a detailed explanation if it determines additional studies at the full generating facility capacity are necessary when the interconnection customer has requested service below full generating facility capacity.”

The draft order denied other requests for rehearings or clarification.

The draft order will go into effect 75 days after it is published in the Federal Register. Public utility transmission providers have to “submit a single compliance filing, within 90 days of the issuance of this order, to comply with Order No. 845 and this draft order on rehearing and clarification.”