DECEMBER 2020 “Adopt the pace of nature: her secret is patience.” - Ralph Waldo Emerson MIDWEST RELIABILITY MATTERS Inside This Issue CEO MESSAGE 3 CEO Message 5 External Affairs 6 Compliance Monitoring and Enforcement Program 9 Registration, Certification and Standards 12 Bulk Power System Reliability 16 Volunteer Recognition Program 18 Security Corner 21 Operational Update 22 Industry News and Events Midwest Reliability Matters - December 2020 CEO MESSAGE A Closing Letter Resiliency in the face of Adversity As I write this end of year letter, I trust that you are healthy and safe wherever you are at the moment. This has been a challenging year for us all, both professionally and personally, and my thoughts and well wishes go out to anyone that has been affected by the COVID-19 pandemic. This year has been one of continuing uncertainty as our Nation and communities grapple with the effects of a global health crisis. Added to the challenges presented by the pandemic were a number of severe weather events that tested the resiliency of the bulk power system and necessitated deployment of mutual assistance networks across North America. Amidst these challenges, and throughout mandatory government shutdowns, corporate safety restrictions, and a paramount shift to remote work, the critical functions of our industry continued with very little interruption. I am incredibly grateful for the hard work and efforts of our industry partners throughout this turbulent time! Also in 2020, racial discrimination confronted us head on with the tragic death of George Floyd in Minneapolis. For MRO, this was in our neighborhood—at many of our doorsteps—adding to the stress and anxiety already experienced with the pandemic. This event called for us to condemn injustice and 3 CEO MESSAGE discrimination and reaffirm our commitment to live by our values and continue to cultivate a workplace that makes equality, diversity, and openness priorities. MRO created a staff-led Diversity and Inclusion Committee to take an introspective look at the organization and identify areas of silent discrimination or intolerance. We remain deeply committed to this work. At MRO, we kicked 2020 off with a renewed sense of optimism, having successfully integrated more than 100 registered entities into our regional work as a result of the dissolution of the SPP RE. In February, I spoke to staff about what our “new normal” might look like as we reached the end of this two-year journey. None of us could have imagined the remarkable events that would unfold. Instead of a new normal, we are now trying to assess and plan for the “novel normal” that will emerge post-pandemic. Although the events of 2020 presented significant challenges, I am extremely proud of how MRO staff, the ERO Enterprise, our board and registered entities, and the entire reliability community have competently risen to the occasion with courage, curiosity, commitment…and resilience. Our ability to be flexible and adapt—to seamlessly shift course and chart new paths—has allowed us to thrive in the face of adversity. Thank you again for your extraordinary efforts. We will continue to face challenges in the months ahead, but I’m confident that we will succeed, even under the most difficult circumstances. I look forward to a heathy 2021, and continuing to advance our mission and vision for the betterment of all those that depend on us. Our future is bright! - Sara Patrick, President and CEO 4 Midwest Reliability Matters - December 2020 EXTERNAL AFFAIRS ERO Enterprise State Outreach Initiative The ERO Enterprise operates in a complex and interconnected ecosystem, with regulatory oversight happening across North America at the provincial, federal, state and local levels. Developing relationships and sharing information on risks to reliability and security of the North American bulk power system across these regulatory agencies is critical to our success. Earlier this year, the ERO Enterprise began an initiative to increase awareness and share information with state regulators to inform these individuals of standards and publicly available reliability and security information, and enhance visibility within the states about ERO Enterprise work. A group was formed comprised of External Affairs staff from NERC and each of the six Regional Entities to coordinate a consistent approach and develop a strategy for executing this state outreach initiative. Because MRO’s communication with state regulatory agencies has historically been limited to the annual meeting of the MidAmerican Regulatory Conference, which is comprised of most of the states in MRO’s footprint, we are taking a phased approach to implementing this initiative. As Director of External Affairs, I’ve been working over the past few months to compile contact information on each state regulatory agency in our region and develop materials introducing MRO and the ERO Enterprise. I’ve also been coordinating with bordering Regional Entities (ReliabilityFirst, SERC Reliability Corporation, and WECC) on communications with the states where our regional borders intersect. In December, the ERO Enterprise External Affairs group will send a coordinated communication to all of the state regulatory agencies informing them of the release of NERC’s Long-Term Reliability Assessment (LTRA). The LTRA is a forward-looking annual assessment of the North American bulk power system that identifies trends, emerging issues, and potential risks over a ten-year horizon across North America. The purpose of sharing this information with state regulatory agencies is to provide details on how the electricity sector is undergoing significant change that is unprecedented in both its transformational nature and rapid pace, and how such an extraordinary evolution presents new challenges and opportunities for assuring reliability throughout this transition. Although we do have existing relationships with some of the state commissioners in our footprint, I will be using the broader ERO Enterprise communication on the LTRA as a way of introducing MRO to the states where no relationship exists. The next phase of this initiative for MRO will be to follow up with each state regulatory agency in Q1 of 2021 to see what questions they might have on the information provided. Going forward, these relationships will be maintained through period outreach on important assessments and reports with the goal to become a trusted resource for information related bulk power system reliability and security. This initiative is not a lobbying or advocacy effort and no confidential information will be shared with state regulatory agencies. If you have questions on this initiative, please feel free to reach out to me at tasha. [email protected]. - Tasha Ward, Senior Counsel and Director of External Affairs 5 COMPLIANCE monitoring AND ENFORCEMENT PROGRAM COMPLIANCE MONITORING AND ENFORCEMENT PROGRAM Compliance Program Management Going above and beyond standard requirements MRO is committed to providing non-binding guidance to industry stakeholders on important industry topics. Subject Matter Experts (SMEs) from MRO’s organizational groups authored this article, and the views expressed herein are the SMEs and do not represent the opinions and views of MRO. Starting with FERC Order 693, FERC stated in part, in paragraph 253: The most critical element of a Reliability Standard is the Requirements. As NERC explains, “the Requirements within a standard define what an entity must do to be compliant . [and] binds an entity to certain obligations of performance under section 215 of the FPA.” This statement is the basis for all registered entities to follow and to reasonably assure that they remain compliant, thus supporting the reliability and security of the bulk power system. Many Reliability Standards instruct entities to review or update information within a certain prescribed time frame. We are all familiar with words such as every 35 days, annual, every 15 calendar months, every 12 years, and so on. The evidence required for these types of standards is very straightforward to interpret and understand. In these cases, the nature of the requirements themselves create an environment where staff is kept current and practiced 6 Midwest Reliability Matters - December 2020 on processes. However, there are some standards that do not have a reoccurring, prescribed timeframe within which to perform the prescribed action. For example, COM-002-4 - Operating Personnel Communications Protocols. Requirement 2 of this standard requires a Balancing Authority, Transmission Operator, and Reliability Coordinator to provide initial training for its operating personnel on documented communication protocols developed per Requirement 1. An entity will have to determine if this “initial” training is enough for their operating personnel for the course of their career. But what happens when the Operating Protocols don’t change for several years? Requirement 4 is an element of the standard where you assess the effectiveness of your communication protocols and modify, as necessary. Retraining and reiterating your initial training curriculum will remind the System Operators of their requirements to utilize three-part communications during daily operations. Now the question will be, how often should you retrain? You will need to determine this based on the risks associated with having to use three-part communications for your System Operators. Some entities use three- part communication daily, where other smaller entities may infrequently use three-part