Ready for the New Bulk Electric System Definition?
The North American Electric Reliability Corporation (NERC) and its electric utility industry stakeholders are nearing the effective date of a definition that is critical to the role of NERC and everyone involved in the electric utility industry. That critical definition is the definition of the Bulk Electric System itself (the BES Definition). The BES Definition is important because it is used to determine the parts of the North American electric system that are “BES Elements” and critical to reliable operation of that electric system. Due to the critical nature of the BES Elements, owners of BES Elements are required to comply with all applicable NERC Reliability Standards. Failure to comply with the Reliability Standards can lead various sanctions, up to and including application of severe fines.
The core of the BES Definition is simple – “…all Transmission Elements operated at 100 kV or higher and Real Power and Reactive Power resources connected at 100 kV or higher. This does not include facilities used in the local distribution of electric energy”. However, the complexity of the electric system can make application of the BES Definition difficult in some instances. NERC has addressed that potential difficulty in several ways – first by adding to the BES Definition a list of Inclusions (classes of facilities automatically considered BES Elements) and Exclusions (classes of facilities automatically not considered BES Elements). NERC and its stakeholders have also developed several guides and held a series of seminars to help asset owners in determining whether facilities are or aren’t BES Elements. The guides and documents from seminars are publicly available on the NERC website. The general BES definition site is here, while the seminar presentations are available here.
Further, in line with FERC direction, NERC has also developed a detailed Exception Process where facility owners and certain other entities involved in the reliability of the BES can request that a specific facilities that is not a BES Element under the BES Definition be changed registered as a BES Element. The facility owner can also request the opposite – that a facility that is a BES Element under the BES Definition be removed from the list of BES Elements.
A recurring comment from FERC concerning the BES Definition was that the new definition should not result in significant registration or de-registration of BES Elements. Regardless, all owners of electric facilities are required to perform a self-evaluation, using NERC’s hierarchical process, to develop a list of owned BES Elements. The asset owners are then to register the results of their self-evaluation through a new web-based tool sponsored by NERC called “BESNet”. Registration for BESNet began in May, 2014. The tool is scheduled to “go live” on July 1, 2014. While NERC allowed a period of 24 months after July 1 to come into compliance with the new BES Definition, all asset owners should perform their individual BES Element self-evaluation as soon as possible and enter the results into BESNet. That way, if there is any disagreement on the BES Element status for any items on the owner’s list, there will be time to hold discussions with the asset owner and affected reliability entities and, if necessary, file an Exception Request well before the compliance deadline.