Violation Risk Factors - PDF Document

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  1. Violation Risk Factors Each requirement must have an associated violation risk factor (High, Medium, or Lower). The risk factor is one of several elements used to determine an appropriate sanction when the associated requirement is violated. The risk factor assesses the impact to reliability of violating a specific requirement. (A complete description of how the violation risk factors are used in determining sanctions can be found in the ERO Sanctions Guidelines.) The following criteria have been filed with FERC as part of the ERO’s Sanctions Guidelines and must be used to determine a violation risk factor for each requirement: High Risk Requirement A requirement that, if violated, could directly cause or contribute to bulk electric system instability, separation, or a cascading sequence of failures, or could place the bulk electric system at an unacceptable risk of instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly cause or contribute to bulk electric system instability, separation, or a cascading sequence of failures, or could place the bulk electric system at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition. Medium Risk Requirement A requirement that, if violated, could directly affect the electrical state or the capability of the bulk electric system, or the ability to effectively monitor and control the bulk electric system. However, violation of a medium risk requirement is unlikely to lead to bulk electric system instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly and adversely affect the electrical state or capability of the bulk electric system, or the ability to effectively monitor, control, or restore the bulk electric system. However, violation of a medium risk requirement is unlikely, under emergency, abnormal, or restoration conditions anticipated by the preparations, to lead to bulk electric system instability, separation, or cascading failures, nor to hinder restoration to a normal condition. Lower Risk Requirement A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical state or capability of the bulk electric system, or the ability to effectively monitor and control the bulk electric system; or, a requirement that is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or restorative conditions anticipated by the preparations, be expected to adversely affect the electrical state or capability of the bulk electric system, or the ability to effectively monitor, control, or restore the bulk electric system. A planning requirement that is administrative in nature.

  2. In its May 18, 2007 Order on Violation Risk Factors, FERC identified five “guidelines” it uses to determine whether to approve the Violation Risk Factors submitted for approval. Those factors are: Guideline (1) — Consistency with the Conclusions of the Final Blackout Report The Commission seeks to ensure that Violation Risk Factors assigned to Requirements of Reliability Standards in these identified areas appropriately reflect their historical critical impact on the reliability of the Bulk-Power System. From footnote 15 of the May 18, 2007 Order, FERC’s list of critical areas (from the Final Blackout Report) where violations could severely affect the reliability of the Bulk-Power System includes: Emergency operations Vegetation management Operator personnel training Protection systems and their coordination Operating tools and backup facilities Reactive power and voltage control System modeling and data exchange Communication protocol and facilities Requirements to determine equipment ratings Synchronized data recorders Clearer criteria for operationally critical facilities Appropriate use of transmission loading relief. Guideline (2) — Consistency within a Reliability Standard The Commission expects a rational connection between the sub-Requirement Violation Risk Factor assignments and the main Requirement Violation Risk Factor assignment. Guideline (3) — Consistency among Reliability Standards The Commission expects the assignment of Violation Risk Factors corresponding to Requirements that address similar reliability goals in different Reliability Standards would be treated comparably. Guideline (4) —Consistency with NERC’s Definition of the Violation Risk Factor Level Guideline (4) was developed to evaluate whether the assignment of a particular Violation Risk Factor level conforms to NERC’s definition of that risk level. Guideline (5) — Treatment of Requirements that Co-mingle More Than One Obligation Where a single Requirement co-mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability Standard. Violation Risk Factors May 16, 2014 2

  3. Version History Version 1 Date January 28, 2010 Owner Change Tracking 1 May 16, 2014 Standards Information Staff Updated template Violation Risk Factors May 16, 2014 3