A six-year test cycle and a twelve-year test cycle would allocate recurring testing effort differently. FERC's February 8 proposal described the shorter interval for normal remedial action schemes and the longer one for limited-impact schemes. That difference is a design choice in a proposed reliability standard, not a measured saving or proof of an optimal testing budget. [2017-02331][2015-29971]

The distinction comes with constraints. FERC proposed clarifying that the standard would not modify or supersede separate system-performance obligations, including for limited-impact schemes. Its explanation also required analysis of each operation or misoperation and corrective plans for deficiencies. Less frequent scheduled testing would not mean that problems discovered between tests could be disregarded. [2017-02331][2015-29971]

Pre-service review supplies another control. A reliability coordinator would complete review before a new or functionally modified scheme entered service. For economic analysis, these different tasks should not be collapsed into a single compliance interval: advance review, event-linked analysis and periodic testing answer different questions about the same protective system. [2017-02331][2015-29971]

The earlier November 2015 Order 818 approved a revised scheme definition and accepted conditional retirement of the Special Protection System term after standards were fully updated. It did not approve the February 2017 lifecycle proposal. With comments due April 10, the February 12 question is whether differentiated testing can serve reliability efficiently within the retained constraints. The two FERC documents establish that policy question, not realized cost reductions, competitive gains or an investment opportunity. [2017-02331][2015-29971]

Source documents

  1. Remedial Action Schemes Reliability Standardhttps://www.govinfo.gov/content/pkg/FR-2017-02-08/html/2017-02331.htm
  2. Revisions to Emergency Operations Reliability Standards; Revisions to Undervoltage Load Shedding Reliability Standards; Revisions to the Definition of Remedial Action Scheme and Related Reliability Standardshttps://www.govinfo.gov/content/pkg/FR-2015-11-25/html/2015-29971.htm