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Regulating electricity reliability
The RCA is evaluating how to mandate the use and maintenance of reliability standards for the Alaska Railbelt electrical system Alan Bailey Petroleum News
During a Jan. 23 meeting of the Regulatory Commission of Alaska the commission staff presented the results of developing a prototype manual for the reliability standards for the Alaska Railbelt electrical system. The idea is to figure out a practical means of commission regulation of the standards. The initiative comes as part of efforts by the commission to facilitate a more unified approach to the operation of the system.
Reliability standards are critically important in assuring the continuity of electricity supplies of an acceptable quality.
Unifying the standards For many years the six Railbelt utilities operated under two different sets of standards, neither of which were mandated. The commission has been very concerned about this situation and has been steering the utilities towards unifying and enforcing the standards. In April 2018 the utilities did indeed file a unified set of standards. The commission is now figuring out how to enforce the standards through regulation.
In addition to enforcing the use of the standards, there needs to be a means of updating the standards. For example, the utilities are still working on the development of standards for cybersecurity, a topic not encompassed by the standards filed in 2018.
Regulatory options During an RCA meeting on Dec. 12, commission staff had presented four possible options for standards regulation and enforcement: simply incorporate the reliability standards into the RCA regulations; develop and maintain a standards manual, enforced by reference through the regulations; have a regulated electricity reliability organization maintain and enforce the standards; or use a docket that would specifically apply to the Railbelt utilities, to order the maintenance and enforcement of the standards.
Commissioner Robert Pickett had expressed concern about incorporating the standards into regulation. He pointed out that this would have the effect of increasing the size of the RCA regulations document by about 50 percent, a very challenging exercise, especially given the need for legal scrutiny of the new regulations and of any subsequent changes to the regulations. Staff also pointed out that the standards would need to be rewritten in the form of language used for regulations.
Regulation by reference Enforcing the standards through regulatory reference to a standards manual enjoys the advantage of requiring minimal changes to RCA regulations while also enabling the standards to be documented in a similar format to that used by the utilities. And there is a precedent from the telecommunications industry for this method of standards enforcement. The method would, however, require the commission to open a regulatory docket, staff pointed out.
The formation of an electricity reliability organization would have the advantage of being similar to the established federal mechanism enforced by the Federal Energy Regulatory Commission. However, the disadvantage is that, as yet, there is no reliability organization for the Alaska Railbelt: The Railbelt utilities have proposed the formation of a Railbelt Reliability Council, but this proposal has yet to come to fruition.
Enforcing the standards through commission orders could become cumbersome and confusing, and would only apply to the utilities named in the docket for the orders, staff commented.
The prototype manual The staff presentation during the Jan. 23 meeting demonstrated the results of an effort to test the development of a standards manual. Although a manual of this type could potentially be used for regulation by the RCA by reference, the idea is to develop a document layout that could be adaptable to a FERC style approach, involving an electricity reliability organization.
Staff explained that they had searched for some existing format of manual, structured in a manner that would accommodate the Railbelt electrical standards that the utilities had filed in 2018. Having done so, they pasted into the document format the various components of those standards. And staff incorporated language into the manual that would support a FERC style of approval process.
The resulting manual appears to work quite well, staff commented.
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