The current Violation Risk Factor (VRF) definitions were never vetted through the NERC Standards Process, primarily due to time constraints during the Electric Reliability Organization (ERO) startup.  While the current definitions were a useful start, the lack of examples and clear divisions between risk levels led to inconsistency in their application and potential misallocation of resources.

 

Another primary problem is that risk is confused with importance.  There are many requirements in the standards that are important, but implementing them incorrectly or late does not necessarily lead to cascading failures.  Risk, as it applies to the Bulk Electric System (BES), includes both the impact of an event and the probability of the event occurring.

There has been a ratcheting effect in the current standards development and approval process that tends to inflate assigned risk.  While this may seem to enhance reliability, it actually draws attention and resources away from true priorities.

 

The documents below provide two things: 1) a plan to develop a clearer set of VRF definitions, and 2) a plan to develop a more consistent and objective approach of assigning VRFs to reliability standards.

A subteam of the Standards Committee’s Process Subcommittee is seeking comments on the following documents until 8 p.m. Eastern on May 7, 2010: Improved VRF Proposal, Instructions for using the VRF Tool, and the VRF Tool.  This is the first comment period for the Violation Risk Factor Criteria and Tool documents.  Stakeholders are encouraged to experiment with the VRF Tool and provide feedback using the comment form.

Comment Period is closed.