Emergency Preparedness and Operations Reliability Standards

Most of the world was stunned to hear that Hurricane Maria left the island of Puerto Rico completely without electricity. When Hurricane Irma hit Florida, utilities across the United States sent thousands of linemen and other utility workers to assist Florida utilities. The picture below highlights a portion of the visiting crews ready to provide help.    

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Photo credit: Eversource

Upon hearing of an island-wide blackout, I thought, “Crews drove across the United States to Florida. The effort required to send utility trucks and other equipment to Puerto Rico will be epic. Ferries will be in high demand.” And sadly, even before the island was hit by Hurricane Maria, the Puerto Rico Electric Power Authority had already filed for bankruptcy in July 2017. The Authority stated then it needed more than $4 billion to overhaul its outdated power plants and reduce its heavy reliance on imported oil. In 2016, 47% of Puerto Rico’s electricity came from petroleum, 34% from natural gas, 17% from coal and 2% from renewable energy. Most American utilities rely on natural gas, coal, nuclear and renewable resources. Fuel source aside, how does a utility recover from an island-wide outage?

In the U.S., the Federal Energy Regulatory Commission (FERC) has rules to address this very issue. And on September 20, 2017 the FERC issued a Notice of Proposed Rulemaking (NOPR) regarding revised Emergency Preparedness and Operations (EOP) Reliability Standards (please note that the document is large and may take some time to load) submitted by the North American Electric Reliability Corporation (NERC), intended to:

  • provide accurate reporting of events to NERC’s event analysis group to analyze the impact on the reliability of the bulk electric system (EOP-004-4);
  • delineate the roles and responsibilities of entities that support system restoration from blackstart resources that generate power without the support of the grid (EOP-005-3);
  • clarify the procedures and coordination requirements for reliability coordinator personnel to execute system restoration processes (EOP-006-3); and
  • refine the required elements of an operating plan used to continue reliable operations of the bulk electric system if that primary control functionality is lost (EOP-008-2). 

I appreciate the work done by regulators and utilities to provide a reliable and resilient electric grid. Comments on the NOPR are due 60 days after publication in the Federal Register

The Office of Energy Efficiency and Renewable Energy recently issued a Funding Opportunity Announcement (“FOA”) that requires the recipient to provide only twenty percent of the total budget. Funding will focus on three areas of interest: 

  1. Advancing Energy Efficiency in Public Facilities that will assist states to develop holistic, whole-building, deep retrofit programs or strategies across as broad a segment of the state’s public building portfolio as possible to achieve significant energy and cost savings.
  2. Stimulating Energy Efficiency Action that will assist states in generating the necessary policy and program frameworks to support investment in cost-effective energy efficiency and establish or increase a statewide energy savings goal by calendar year 2015.
  3. Improving or Developing A Fee-Based Self-Funded Public Facilities Energy Retrofit Program that will assist states in developing/improving and implementing a comprehensive and well-designed self-funded program which relies on a fee-for-services model that can successfully be used to retrofit public facilities statewide across many sectors (e.g., state buildings, municipal buildings, National Guard assets, school districts, water and wastewater treatment facilities, street lighting, etc.).

In accordance with 10 CFR 600.6(b), eligibility for award for Areas of Interest 1, 2 and 3 is restricted to the 50 States, the District of Columbia, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico and the US Virgin Islands. Applications must be submitted by the State Energy Office (“SEO”) or other agency responsible for administering the State Energy Program pursuant to 10 CFR 420, although States may work in collaboration with non-State entities. Non-State entities interested in collaborating with their respective State Energy Office must contact their respective SEO. It is a great opportunity for states, advocates and utilities to work together.