Regulations and Standards
Written by Doug Houseman
Regulation driving technical standards is not a new phenomenon in the electric power domain. It’s been happening ever since regulation was formalized in the early 20th Century. What is new for the electric power industry is the rate at which regulation is now driving the need for both updates and brand-new technical standards. When technical standard-setting bodies do not respond in time, regulations developed without knowledgeable input can end up taking the place of technical standards, as happened with California Rule 21. IEEE did not update IEEE 1547 fast enough to satisfy the regulators of California, which resulted in the multi-year effort needed to write a California-only set of standards governing the technical requirements for inverters and interconnection.
To a large extent, the update in-process to IEEE 1547-2018 and the creation of P2800 have developed new technical standards that exceed the requirements of California Rule 21. This is happening not only in California and the US, but around the world as the energy transition pushes us beyond existing standards. We IEEE members need to push for leadership in determining the technical requirements in standards rather than just codifying the status quo.
Over the last 36 months, the US Federal Energy Regulatory Commission (FERC) has released regulations allowing access to the wholesale market at the transmission level for distribution-connected resources. Beginning with FERC-841 that opened the market to energy storage, FERC-842 that required primary frequency response from inverter-based resources, and FERC-845 that pushed the door further open for energy storage, dramatic changes to the electric power market have occurred. These three regulations were followed by FERC-2222 which allows aggregation of distribution connections (including behind-the-meter customer resources) into the wholesale market. While this example is US-based, the issues these orders address apply wherever there a wholesale energy market exists. Implementing these orders will require technical solutions, solutions that will either be specified by regulations in each individual market, or by technical standards that can address multiple regulatory requirements across multiple markets and address potential future issues.
One standard that requires an almost-immediate response to FERC regulations is an update to IEEE 2030. IEEE 2030 provides a model of power grid systems and domains. This model allows an analyst to simulate the paths that messages take, allowing each participant in a power grid system to understand what they need to do to comply with the requirements of the standard. IEEE 2030.5 also needs review to ensure that all the key message types are supported in the protocol.
Because of the way FERC-2222 was laid out, a distribution utility must determine if a resource can participate in aggregation within a very short time period, a time so brief that conventional modeling and study by the distribution utility cannot be completed before the decision is required. This has triggered informal discussions around developing a standard for what could be routinely allowed in an aggregation while also maintaining grid safety. Because of the potential for much higher power exports at periods of high prices on the wholesale market under FERC-2222, new standards are required for protection, sizing conductors, cooling algorithms and transformer overloading. The National Fire Protection Association (NFPA) is now addressing issues in the National Electric Code regarding storage fire protection and other aspects of keeping premises safe. The National Electrical System Code (NESC), an ANSI standard maintained by IEEE PES, is also undergoing an update because of the new demands created by FERC-2222. This update may not be sufficient to make the NFPA comfortable with the requirements in the NESC standard, and NFPA may continue to require all utilities to use NFPA’s standards for storage instead of the existing NESC standards. Regulations in process in multiple states are expected to drive utilities to install storage at a much faster rate. Without an update to NESC, these installations will follow the NFPA standards. This could mean that costs to install storage are driven significantly higher for utilities, and that large installations of storage, especially battery storage, will become even more costly and complex for utilities or businesses to install and operate.
Other areas where regulation is rapidly evolving are in communications. Radio frequencies that were reserved for grid operations released for new uses, some of which will rapidly disrupt traditional utility practice. Another is cyber-security, where not only regulation, but state-sponsored hacking is driving the urgent need to develop new standards and methods including development of private networks with a closed membership list.
Finally, if the UN goals to slow and mitigate climate change are to be met, everything from heating to transportation energy will be served by and through ONE network: the electrical network. Any outage will not just mean that people are without lights, microwaves, and the internet, but rather they will not be able to power their vehicles, heat their homes, or otherwise carry on with their lives with only minor inconvenience. Regulations are coming to require higher levels of power grid resiliency and reliability, for longer asset life and other important aspects of grid design and operation. Are we ready to write the standards that society needs in order to progress to a new generation of grid design, one that makes it possible for society to operate safely and efficiently with only one network?
IEEE PES, The Computer Society, the Communications Society, PELS, and other IEEE societies will need much more volunteer help to write and review these essential standards. Technical Activities can use your help to make your family’s life better over the next decade or two. How can you not find the time to dig in and help?
This article edited by Peter Wung.