FERC Proposes To Approve NERC's New Definition Of The 'Bulk Electric System'

On June 22, 2012, the Federal Energy Regulatory Commission (Commission) issued a Notice of Proposed Rulemaking (NOPR) in which it proposes to approve revised rules of the North American Electric Reliability Corporation (NERC), including a revised definition of the "bulk electric system." The revised definition would eliminate regional discretion over whether to treat facilities as part of the "bulk electric system" and instead would establish a bright-line threshold that includes all facilities operated at or above 100 kV. The revised rules also would provide further clarity by identifying specific categories of facilities that will be treated as included in, and others that will be treated as excluded from, the redefined bulk electric system.

On the other hand, the revised rules would create an exception procedure to add or subtract facilities from the redefined bulk electric system on a case-by-case basis. Requests for an exception can be made by Regional Entities, planning authorities, reliability coordinators, transmission operators, transmission planners, balancing authorities, or owners of transmission elements. Anyone requesting an exception would need to complete the same proposed form, which would help to ensure NERC uses a consistent baseline in making exception decisions.

Comments on the NOPR are due by September 4, 2012.

Included Facilities

The NOPR clarifies that the following facilities will be among those treated as part of the bulk electric system:

I1 – Transformers with the primary terminal and at least one secondary terminal operated at 100 kV or higher, unless excluded under Exclusion E1 or E3 below. The Commission notes, however, that it may be necessary to include some transformers operated below 100 kV on all their secondary windings. The Commission noted how the loss of two such transformers impacted system reliability in the recent Arizona-Southern California blackout. I2 – A generating resource with a gross individual nameplate rating greater than 20 MVA or gross plant/facility aggregate nameplate rating greater than 75 MVA, including the generator terminals through the high-side of the step-up transformer(s) connected at a voltage of 100 kV or above. This inclusion is intended to mirror the text of the NERC Registry Criteria for generating units. I3 – Blackstart Resources identified in the Transmission Operator's restoration plan. These resources are included facilities regardless of their size (MVA) or the voltage...