RD16-4, NERC Petition, without Exhibits

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. ____________

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
FAC-003-4
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Candice Castaneda
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, DC 20005
(202) 400-3000
(202) 644-8099 – facsimile
charles.berardesco@nerc.net
holly.hawkins@nerc.net
candice.castaneda@nerc.net

Counsel for the North American Electric
Reliability Corporation

March 14, 2016

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY .................................................................................................... 2
II. NOTICES AND COMMUNICATIONS ................................................................................ 4
III. BACKGROUND .................................................................................................................... 4
A.
Regulatory Framework ..................................................................................................... 4
B.

NERC Reliability Standards Development Procedure ..................................................... 5

C.

Procedural History of Proposed Reliability Standard FAC-003-4 ................................... 6
1. History of Reliability Standard FAC-003-4 and Order No. 777 ..................................... 6
2. Project 2010-07.1 Vegetation Management and EPRI Report ....................................... 8

IV. JUSTIFICATION FOR APPROVAL..................................................................................... 9
A.
Proposed Reliability Standard FAC-003-4 and Applicable Entities ................................ 9
B.

Justification for Proposed Reliability Standard FAC-003-4 and Revisions ................... 10

C.

Enforceability of Proposed Reliability Standard FAC-003-4 ........................................ 12

V. EFFECTIVE DATE .............................................................................................................. 12
VI. CONCLUSION ..................................................................................................................... 13
Exhibit A

Proposed Reliability Standard FAC-003-4

Exhibit B

Implementation Plan

Exhibit C

Order No. 672 Criteria

Exhibit D

Drafting Team Summary of EPRI Conductor-Tree Air Gap Flashover Testing

Exhibit E

EPRI Reports
Exhibit E-1 April 2015 Testing to Confirm or Refine Gap Factor Utilized in
Calculation of Minimum Vegetation Clearance Distances (MVCD)
Exhibit E-2 Final Report July 2015 as Revised February 2016 Supplemental
Testing to Confirm or Refine Gap Factor Utilized in Calculation of Minimum
Vegetation Clearance Distances (MVCD)

Exhibit F

Summary of Development History and Complete Record of Development

Exhibit G

Standard Drafting Team Roster

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
)
Docket Nos. ____________
Corporation
)
PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
FAC-003-4
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 of the
regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 2 the
North American Electric Reliability Corporation (“NERC”) 3 hereby requests Commission
approval of proposed Reliability Standard FAC-003-4 (Transmission Vegetation Management)
(Exhibit A), the associated Implementation Plan (Exhibit B), and retirement of currentlyeffective Reliability Standard FAC-003-3. Proposed Reliability Standard FAC-003-4 will apply
the same Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”) as applicable
to currently effective Reliability Standard FAC-003-3. Therefore, this Petition does not include
a separate justification for the VRFs and VSLs. This Petition also attaches copies of those
Electric Power Research Institute (“EPRI”) reports (Exhibit E), which led to the revisions
proposed in Reliability Standard FAC-003-4.The NERC Board of Trustees adopted proposed
Reliability Standard FAC-003-4 on February 11, 2016.
NERC requests that the Commission approve proposed Reliability Standard FAC-003-4,
as just, reasonable, not unduly discriminatory or preferential, and in the public interest. NERC
also requests that the Commission accept the proposed Implementation Plan and retirement of

1

16 U.S.C. § 824o (2012).
18 C.F.R. § 39.5 (2014).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
2

1

Reliability Standard FAC-003-3 effective the first day of the first calendar quarter that is three
months after the effective date of the Commission’s order approving the standard. On this
effective date, proposed Reliability Standard FAC-003-4 will supersede and replace FAC-003-3.
As required by Section 39.5(a) of the Commission’s regulations, 4 this Petition presents
the technical basis and purpose of proposed Reliability Standard FAC-003-4, a summary of the
development history (Exhibit F), and a demonstration that the proposed Reliability Standard
meets the criteria identified by the Commission in Order No. 672 (Exhibit C). 5
I.

EXECUTIVE SUMMARY
The purpose of proposed Reliability Standard FAC-003-4 is to require entities to manage

vegetation located on transmission rights of way (ROW) and minimize encroachments from
vegetation located adjacent to the ROW to reduce the risk of vegetation-related outages that
could lead to Cascading. Proposed Reliability Standard FAC-003-4 reflects revisions developed
under Project 2010-07.1 Vegetation Management to provide a revised gap factor applied in the
Gallet equation supporting the appropriate Alternating Current Minimum Vegetation Clearance
Distances (referred to herein as “MVCD values”) stated under the Reliability Standard. 6 The
MVCD value reflects the minimum distance between vegetation and conductors to prevent a
flash-over. This revised gap factor was developed as a result of the 2015 Technical Report
prepared by EPRI entitled Supplemental Testing to Confirm or Refine Gap Factor Utilized in
Calculation of Minimum Vegetation Clearance Distances (“MVCD”): Tests: Results and

4

18 C.F.R. § 39.5(a) (2014).
The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, at PP 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).
6
Non-substantive edits are also included for the standard.
5

2

Analysis (“EPRI Report”), 7 filed at the Commission in Docket No. RM12-4-000 in compliance
with the Commission’s directive in Order No. 777. 8 The EPRI Report, the preliminary report
preceding it, and EPRI’s recent update to the EPRI Report filed in Docket No. RM12-4-000 are
attached at Exhibit E.
As reflected in this Petition and the attached exhibits, the EPRI test results indicated that
MVCD values under currently effective Reliability Standard FAC-003-3 might not be suitable or
sufficiently conservative in all situations. The EPRI testing revealed that the gap factor used to
determine those MVCD values under the Gallet equation was too high for all situations with
varying tree and conductor configurations. The gap factor is a multiplier that adjusts MVCD
values for different configurations of vegetation and conductors to avoid flashover (a lower gap
factor correlates to higher MVCD values). The EPRI tests thus led to the conclusion that MVCD
values under existing Reliability Standard FAC-003-4 appeared low. The EPRI test results
demonstrated the Gallet equation should apply a more conservative, lower, gap factor of 1.0 to
calculate MVCD values for Reliability Standard FAC-003-4. Proposed Reliability Standard
FAC-003-4, therefore proposes higher and more conservative MVCD values. These higher
MVCD values will enhance reliability and provide additional confidence by applying a more
conservative approach to determining the vegetation clearing distances.

7

North American Electric Reliability Corporation submits Electric Power Research Institute 2015 Technical
Report, Docket No. RM12-4-002 (filed Aug. 12, 2015) (attaching the EPRI Report, as attachment 1).
8
See Revisions to Reliability Standard for Transmission Vegetation Management, Order No. 777, 142 FERC
¶ 61,208, at P 59 (2013) (stating, “direct NERC to conduct or contract testing to develop empirical data regarding
the flashover distances between conductors and vegetation…. A statistical analysis would then evaluate the test
results and provide empirical evidence to support an appropriate gap factor to be applied in calculating minimum
clearance distances using the Gallet equation”); and North American Electric Reliability Corporation submits
Electric Power Research Institute 2015 Technical Report, Docket No. RM12-4-002 (filed Aug. 12, 2015) (“EPRI
Report”). Unless otherwise designated, capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards (“NERC Glossary of Terms”), available at
http://www.nerc.com/files/Glossary_of_Terms.pdf.

3

This Petition accomplishes NERC’s stated intention, in submitting the EPRI Report, to
initiate a Standards Authorization Request to adjust the MVCD values in the Reliability Standard
to reflect the results of the EPRI Report. 9 NERC respectfully requests that the Commission
approve proposed Reliability Standard FAC-003-4 and the associated Implementation Plan as
just, reasonable, not unduly discriminatory or preferential, and in the public interest.
II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to: 10

Holly A. Hawkins*
Associate General Counsel
Candice Castaneda*
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, DC 20005
(202) 400-3000
(202) 644-8099 – facsimile
holly.hawkins@nerc.net
candice.castaneda@nerc.net
III.

Howard Gugel*
Director of Standards
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
Howard.Gugel@nerc.net

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005, 11 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power
System, and with the duties of certifying an ERO that would be charged with developing and

9

See, supra n. [7], at attachment 2, NERC Summary FAC-003-3 Minimum Vegetation Clearance Distances,
at p. 1 (stating, “This final report includes the final gap-factor testing results that will be used to initiate a focused
Standard Authorization Request (SAR) to adjust the MVCD values in NERC Reliability Standard FAC-003-3.”).
10
Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2014), to allow the inclusion
of more than two persons on the service list in this proceeding.
11
16 U.S.C. § 824o (2012).

4

enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
States will be subject to Commission-approved Reliability Standards. 12 Section 215(d)(5) of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability
Standard. 13 Section 39.5(a) of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes should become
mandatory and enforceable in the United States, and each modification to a Reliability Standard
that the ERO proposes should be made effective. 14
The Commission is vested with the regulatory responsibility to approve Reliability
Standards that protect the reliability of the Bulk-Power System and to ensure that such
Reliability Standards are just, reasonable, not unduly discriminatory or preferential, and in the
public interest. Pursuant to Section 215(d)(2) of the FPA 15 and Section 39.5(c) of the
Commission’s regulations, “the Commission will give due weight to the technical expertise of
the Electric Reliability Organization” with respect to the content of a Reliability Standard. 16
B.

NERC Reliability Standards Development Procedure

The proposed Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process. 17 NERC

12

Id. § 824o(b)(1).
Id. § 824o(d)(5).
14
18 C.F.R. § 39.5(a).
15
16 U.S.C. § 824o(d)(2).
16
18 C.F.R. § 39.5(c)(1).
17
Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672 at P 334, FERC Stats. &
Regs. ¶ 31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006) (“Further, in considering
whether a proposed Reliability Standard meets the legal standard of review, we will entertain comments about
whether the ERO implemented its Commission-approved Reliability Standard development process for the
development of the particular proposed Reliability Standard in a proper manner, especially whether the process was
open and fair. However, we caution that we will not be sympathetic to arguments by interested parties that choose,
13

5

develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual. 18
In its order certifying NERC as the Commission’s ERO, the Commission found that
NERC’s proposed rules provide for reasonable notice and opportunity for public comment, due
process, openness, and a balance of interests in developing Reliability Standards, 19 and thus
satisfy certain of the criteria for approving Reliability Standards. 20 The development process is
open to any person or entity with a legitimate interest in the reliability of the Bulk-Power
System. NERC considers the comments of all stakeholders, and stakeholders must approve, and
the NERC Board of Trustees must adopt a Reliability Standard before the Reliability Standard is
submitted to the Commission for approval.
C.

Procedural History of Proposed Reliability Standard FAC-003-4

This section summarizes the development history of proposed Reliability Standard FAC003-4.
1.

History of Reliability Standard FAC-003-4 and Order No. 777

The Commission approved FAC-003-1 in Order No. 693. 21 Thereafter, on December 21,
2011, NERC filed Reliability Standard FAC-003-2 in Docket No. RM12-4-000 to expand
applicability of the Reliability Standard to include overhead transmission lines that are operated
below 200 kV, if they are either an element of an Interconnection Reliability Operating Limit or
an element of a Major WECC Transfer Path. Reliability Standard FAC-003-2 incorporated a

for whatever reason, not to participate in the ERO’s Reliability Standard development process if it is conducted in
good faith in accordance with the procedures approved by FERC.”).
18
The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.
19
N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 at P 250 (2006).
20
Order No. 672 at PP 268, 270.
21
Order No. 693, at P 735.

6

new minimum annual inspection requirement, and incorporated new minimum vegetation
clearance distances into the text of the standard. On March 21, 2013, in Order No. 777, the
Commission approved Reliability Standard FAC-003-2. 22 In Order No. 777, the Commission
stated:
While we approve NERC’s use of the Gallet equation to determine the minimum
vegetation clearance distances, we believe it is important that NERC develop
empirical evidence that either confirms assumptions used in calculating the
MVCD values based on the Gallet equation, or gives reason to revisit the
Reliability Standard. Accordingly, consistent with the Notice of Proposed
Rulemaking (NOPR) proposal, the Commission directs that NERC conduct or
contract testing to obtain empirical data and submit a report to the Commission
providing the results of the testing. 23
NERC contracted EPRI to assist NERC with performing a collaborative research project, to
comply with the Commission’s directive. NERC submitted a compliance filing on Order No.
777 on July 12, 2013, which the Commission accepted on September 4, 2013. 24
While Reliability Standard FAC-003-2 was pending Commission approval, NERC filed
Reliability Standard FAC-003-3 to maintain a reliable electric transmission system by using a
defense-in-depth strategy to manage vegetation located on transmission rights of way and
minimize encroachments from vegetation located adjacent to the rights of way, thus helping to
prevent the risk that vegetation-related outages could lead to Cascading. 25 Reliability Standard
FAC-003-3 applied a phased-in effective date, to provide Generator Owners with an opportunity

22

Revisions to Reliability Standard for Transmission Vegetation Management, Order No. 777, 142 FERC ¶
61,208 (2013).
23
Order No. 777, at P 3.
24
See, Compliance Filing of NERC, Docket No. RM12-4-001 (filed Jul. 12, 2013); and N. Am. Elec.
Reliability Corp., Docket No. RM12-4-001 (Sept. 4, 2013) (unpublished letter order).
25
Petition of the North American Electric Reliability Corporation for Approval of Proposed Standards FAC001-1, FAC-003-3, PRC-004-2.1a and PRC-005-1.1b, Docket No. RM12-16-000 (filed Jul. 30, 2012).

7

to transition to compliance with the standard. 26 On September 19, 2013, in Order No. 785, the
Commission approved Reliability Standard FAC-003-3. 27
Throughout this time, NERC continued working with stakeholders and EPRI to develop
empirical data regarding flashover distances between conductors and vegetation to calculate
MVCD values. On July 31, 2014, NERC submitted an informational filing to provide an interim
status update on NERC’s activities. 28 NERC’s interim status update explained that, consistent
with NERC’s earlier 2013 compliance filing, NERC’s primary objective under this project was
to determine the appropriate gap factor for use in the Gallet equation. Preliminary results in
2014 indicated that the gap factor should be adjusted from 1.3 to 1.0, to result in MVCD values
that are higher than those in the currently effective standard. 29
2.

Project 2010-07.1 Vegetation Management and EPRI Report

In 2015, NERC worked with EPRI to finalize gap factor verification. On August 12,
2015, NERC submitted the final EPRI Report reflecting the final results of this gap-factor
testing. 30 Exhibit E reflects the EPRI Report and a preliminary report, which later culminated in
the EPRI Report. Exhibit E also includes an update prepared by EPRI in anticipation of this
Petition. The results of the EPRI Report and testing confirmed the preliminary results identified

26

Id. at pp. 23-24.
Generator Requirements at the Transmission Interface, Order No. 785, 144 FERC ¶ 61,221 (2013).
28
Informational Filing of the North American Electric Reliability Corporation, Docket Nos. RM12-4-000 et.
al. (filed Jul. 31, 2014).
29
Id. at pp. 2-3. See also, id. at n. 4 (explaining that the Gallet equation is an accepted method for calculating
the air gap required between a conductor and a transmission line tower (i.e., the grounded object) to avoid flashover.
The Gallet equation is used to calculate the minimum air gap that could exist between a conductor and vegetation
(conductor-to-vegetation gap) to avoid a flashover. This calculated minimum conductor-to-vegetation gap would
then be used to set the MVCD values. The Gallet equation is particularly useful as it works for a variety of
conductor-to-vegetation gap configurations. The conductor-to-vegetation gap configuration may consist of the
conductor being located vertically above and horizontally to the side of the vegetation in concern, or any
combination thereof.).
30
North American Electric Reliability Corporation submits Electric Power Research Institute 2015 Technical
Report, Docket No. RM12-4-002 (filed Aug. 12, 2015) (attaching the EPRI Report, as attachment 1)
27

8

in 2014 and resulted in NERC Project 2010-07.1 Vegetation Management. That project resulted
in this Petition with revised MVCD values that have been calculated using the revised gap factor.
IV.

JUSTIFICATION FOR APPROVAL
As discussed below and in Exhibit C, proposed Reliability Standard FAC-003-4 satisfies

the Commission’s criteria in Order No. 672 and is just, reasonable, not unduly discriminatory or
preferential, and in the public interest. The proposed Reliability Standard is also consistent with
the Commission’s directive in Order No. 777, that the standard apply MVCD values supported
by empirical data. The following subsections provide: (A) a description of the proposed
standard, its reliability purposes, and applicable entities; (B) justification for the proposed
Reliability Standard, detailing the proposed revisions; and (C) discussion of the enforceability of
the proposed Reliability Standard.
A.

Proposed Reliability Standard FAC-003-4 and Applicable Entities

The purpose of proposed Reliability Standard FAC-003-4 is “[t]o maintain a reliable
electric transmission system by using a defense-in-depth strategy to manage vegetation located
on transmission rights of way (ROW) and minimize encroachments from vegetation located
adjacent to the ROW, thus preventing the risk of those vegetation-related outages that could lead
to Cascading.”
The standard applies to Applicable Transmission Owners and Applicable Generator
Owners. These are the same entities currently subject to Reliability Standard FAC-003-3. The
Reliability Standard establishes Applicable Transmission Owners and Applicable Generator
Owners as follows:
•

Applicable Transmission Owners are Transmission Owners that own the
following Transmission Facilities defined in Section 4.2 of the Reliability
Standard:

9

4.2.

•

Applicable Generator Owners are Generator Owners that own the following
generation Facilities defined in Section 4.3 of the Reliability Standard:
4.3.

B.

Facilities: Defined below (referred to as “applicable lines”), including but
not limited to those that cross lands owned by federal , state, provincial,
public, private, or tribal entities:
4.2.1. Each overhead transmission line operated at 200kV or higher.
4.2.2. Each overhead transmission line operated below 200kV identified
as an element of an IROL under NERC Standard FAC-014 by the
Planning Authority. 31
4.2.3. Each overhead transmission line operated below 200 kV identified
as an element of a Major WECC Transfer Path in the Bulk Electric
System by WECC.
4.2.4. Each overhead transmission line identified above (4.2.1 through
4.2.3) located outside the fenced area of the switchyard, station or
substation and any portion of the span of the transmission line that
is crossing the substation fence

Generation Facilities: Defined below (referred to as “applicable lines”),
including but not limited to those that cross lands owned by federal , state,
provincial, public, private, or tribal entities:
4.3.1. Overhead transmission lines that (1) extend greater than one mile or
1.609 kilometers beyond the fenced area of the generating station
switchyard to the point of interconnection with a Transmission
Owner’s Facility or (2) do not have a clear line of sight from the
generating station switchyard fence to the point of interconnection
with a Transmission Owner’s Facility and are:
4.3.1.1. Operated at 200kV or higher; or
4.3.1.2. Operated below 200kV identified as an element of an
IROL under NERC Standard FAC-014 by the Planning
Authority; or
4.3.1.3. Operated below 200 kV identified as an element of a
Major WECC Transfer Path in the Bulk Electric System by
WECC.

Justification for Proposed Reliability Standard FAC-003-4 and Revisions

The proposed Reliability Standard is updated in order to reflect the revised MVCD
values, as adjusted for the revised, lower, gap factor reflected in the EPRI Report, and to reflect

31

Non-substantive edits included updating the Reliability Standard and Implementation Plan to the current
Results-Based template for Reliability Standards. Apart from the Reliability Standard, the Standard Drafting Team
took the opportunity to update the information Guideline and Technical Basis for the proposed Reliability Standard.

10

certain non-substantive edits to bring the Reliability Standard into conformity with more recently
developed Reliability Standards. The gap factor is a multiplier within the Gallet equation, which
adjusts the MVCD values required for different configurations of objects and conductors. 32 A
lower gap factor, for example, correlates with a higher MVCD values and a higher gap factor
correlates to a lower MVCD values.
In particular, the EPRI testing (i) determined the switching impulse strength of the air gap
between a conductor and natural trees, (ii) validated the revision of the gap factor to 1.0, and (iii)
determined the proper MCVD values for Reliability Standard FAC-003. 33 As planned when
NERC submitted the EPRI Report, the EPRI test results led to a Standards Authorization
Request to adjust MVCD values in Reliability Standard FAC-003-4, for submission to the
Commission by the end of the first quarter of 2016. 34 Since that time, NERC has worked with
industry to develop proposed Reliability Standard FAC-003-4, by updating Table 2 of the
standard to reflect the results of the EPRI Report and make non- substantive edits. The proposed
Reliability Standard is intended to replace and retire Reliability Standard FAC-003-3, consistent
with the Implementation Plan.
The revisions described herein and reflected at Table 2 of FAC-003-4 are reflected in
Exhibit A. 35 Table 2 was also moved out of the Guideline and Technical Basis document for

32

As the Standard Drafting Team discussed in Exhibit D, “The ‘Transmission Vegetation Management NERC
Standard FAC-003-2 Technical Reference’ states that the probability of an air gap flashover between a conductor
and a tree at MVCDs is 10-6; however, [the Standard Drafting Team] have been unsuccessful in confirming the
assumptions associated with the statement. Based on [the Standard Drafting Team] best understanding of the
approach developed by the original authors, [the Standard Drafting Team] have used accepted methodology to
provide an estimate. The resulting calculated risk of a flashover is 2.49 X 10-4, based on a probability of flashover
of 0.135% at MVCD and a transient overvoltage that has a 2% probability of exceeding the defined levels. This
equates to less than one flashover across MVCDs per 4000 switching surges.” See, Exhibit D, at p. 5 (internal
citations omitted).
33
See Exhibit E and Exhibit D (including the EPRI analyses and Standard Drafting Team summary review).
34
Id. at Transmittal.
35
See Exhibit A for full redline.

11

clarity. The modifications to Table 2 will require responsible entities to implement MVCD
values that reflect the appropriate gap factor resulting from the empirical data and analysis
summarized in the EPRI Report. In addition, based on feedback received from the advisory
group, 36 the Standard Drafting Team added MVCD values up to 15,000 feet (4,267 meters). 37
These changes to Table 2 are the only substantive changes made to the currently effective
version of the Reliability Standard.
C.

Enforceability of Proposed Reliability Standard FAC-003-4

The proposed Reliability Standard includes Measures that support each Requirement to
help ensure that the Requirements will be enforced in a clear, consistent, non-preferential manner
and without prejudice to any party. The proposed Reliability Standard also includes VRFs and
VSLs for each Requirement. The VSLs and VRFs are part of several elements used to determine
an appropriate sanction when the associated Requirement is violated. The VSLs provide
guidance on the way that NERC will enforce the Requirements of the proposed Reliability
Standards. The VRFs assess the impact to reliability of violating a specific Requirement.
In this Petition, NERC proposes to utilize the same VRFs and VSLs in effect for FAC003-3 for FAC-004-4. In 2013, the Commission approved these VRFs and VSLs. 38 As a result,
the VRFs and VSLs for the new Requirements in proposed Reliability Standard comport with
NERC and Commission guidelines.
V.

EFFECTIVE DATE
NERC respectfully requests that the Commission approve proposed Reliability Standard

36

The advisory group was the team of NERC Staff, arborists, and industry members that assisted in
developing the EPRI test plan and scope of work for the EPRI testing.
37
Non-substantive edits included updating the Reliability Standard and Implementation Plan to the current
Results-Based template for Reliability Standards. Apart from the Reliability Standard, the Standard Drafting Team
took the opportunity to update the information Guideline and Technical Basis for the proposed Reliability Standard.
38
See, Order No. 785, at P 1.

12

FAC-003-4 effective on the first day of the first calendar quarter that is three months after the
effective date of the Commission’s order approving the standard. In addition, NERC requests
retirement of Reliability Standard FAC-003-3. Reliability Standard FAC-003-4 will replace and
supersede currently-effective Reliability Standard FAC-003-3.
VI.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve

(i) proposed Reliability Standard FAC-003-4 as reflected in Exhibit A; (ii) the Implementation
Plan included in Exhibit B; and (iii) the retirement of currently-effective Reliability Standard
FAC-003-3.

Respectfully submitted,
/s/ Candice Castaneda

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Candice Castaneda
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
charles.berardesco@nerc.net
holly.hawkins@nerc.net
candice.castaneda@nerc.net

Counsel for the North American Electric
Reliability Corporation
Date: March 14, 2016

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