Calling a grid protection scheme limited-impact does not settle what its operator owes the wider system. FERC's February 8 proposal expressly addressed that boundary: the proposed remedial-action-scheme standard would not modify or supersede separate system-performance obligations. The ethical issue is how to recognize differences in risk without letting a reassuring category replace responsibility. [2017-02331][2015-29971]

The proposed testing schedule illustrates the distinction. Normal schemes would undergo performance testing every six years; limited-impact schemes every twelve. Yet FERC's explanation also described analysis of each operation or misoperation and corrective-action plans for deficiencies. A longer periodic interval would not make operating experience irrelevant or turn identified defects into matters to ignore. [2017-02331][2015-29971]

There is also a responsibility to describe institutional change accurately. FERC's November 2015 Order 818 approved a revised definition and accepted retiring the older Special Protection System term once standards were fully updated. That earlier decision supplied terminology and transition context. It was not approval of the lifecycle standard proposed in February 2017. [2017-02331][2015-29971]

As of this February 12 reflection, comments on the new proposal were due April 10, and its preventive purpose remained an aim rather than a measured result. The two agency documents invite a practical account of stewardship: review before a new or functionally modified scheme enters service, learn from operation, and address deficiencies. They do not demonstrate fewer failures or supply a religious consensus about how much risk society should accept. [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