Compliance Follies

After the 2003 blackout, the balance of authority shifted dramatically. For the past several decades, even through the deregulation disaster of the late 90's, the control areas and transmission providers existed in a sort of self-policing arrangement where the North American Reliability Council (NERC) maintained non-binding Operating Policies that the members sort of agreed to follow even though there was no real enforcement or punishment for noncompliance.

After the 2003 incident and the (non)revelation that not everyone treated the Policies as the gospel, the Federal Energy Regulatory Commission (FERC) decided to flex some federal muscle and lay down the law. FERC (government) deputized NERC (industry nanny) to stop being a helpless nanny and learn to be a mean, justice-delivering pit bull (apologies to pit bull lovers).

Sorry, this is getting boring, let me get back on track. We'll have to come back to this stuff in bits and pieces eventually, young padawans... there is much to learn.

So, FERC's new NERC dog chucked the vaguely all-pleasing Policies and replaced them with strictly-defined Standards. These Standards now include definitions for different degrees of noncompliance and the associated financial penalties that can be assessed for violations. Huge penalties. HUGE. In fact, Grumpy's company got whacked with an 8-figure NERC/FERC fine relatively recently.

Anyway, drilling in to one specific Policy.... there is a requirement that each control area be able to monitor the system frequency (normally 60.00Hz +/-0.20... what produces the hum you hear coming from power substations and lines). It isn't enough to monitor it in one place, however. Each dispatcher must be capable of seeing the system frequency as measured in multiple locations. This is vital in case your system is broken into pieces in a collapse so that, for example, you do not direct a power station to change its output to correct a problem in an area it is no longer connected to. In addition, the frequency monitors must be independent of the software application used to control the grid, so that in theory you can still see the different frequencies even while you are helpless to do anything because your Energy Management System (EMS) app is dead. It's nice to see the ground coming up to meet you through the window when the stick is dead. Yeah.

In essence, the Policy actually is a good idea. In practice as written, you get what happened here at Grumpy's office.... just another thing that makes him Grumpy.

First off, according to the guy tasked to set this up, the company could not find any digital displays capable of talking to our non-EMS frequency app smaller than the huge LED boxes with retina-burning redness aimed at our faces from just six feet away, now hanging on the wall a few feet from our desk. Hanging. By zip ties. Real professional looking. We would like to reprogram them to scroll game scores or something. They are that big. I cannot fathom that a company owning $billions$ in assets is unable to find a way to convert data in some magical way to be viewed on an appropriately-sized LED number display. OK, whatever.

Secondly, as it turns out, of the four frequencies displayed, the two on one side are measured from stations about three miles apart, while the two on the other side are perhaps ten miles apart. This will be very useful if the system is split neatly in half down the middle of these specific cities, so that each side is attached to isolated islands. The reality is, splits occur at major substations where one or a handful of major lines ties one region to another. Cities do not get split into independently-surviving halves in collapses.

Yip-de-flipping-yay. We're compliant. With ugly hanging oversized scoreboards of no value except the once-a-decade blackout, except that they are of no value unless we split this or that city in half, which happens once every never. But we're compliant!