2017 Electric Reliability Standards for Solar Geomagnetic Disturbances
Background
In FERC Order 779, FERC directed NERC to develop Second Stage Geomagnetic Disturbance (GMD) Reliability Standards:1
The Second Stage GMD Reliability Standards must identify benchmark GMD events that specify what severity GMD events a responsible entity must assess for potential impacts on the Bulk-Power System. If the assessments identify potential impacts from benchmark GMD events, the Reliability Standards should require owners and operators to develop and implement a plan to protect against instability, uncontrolled separation, or cascading failures of the Bulk-Power System, caused by damage to critical or vulnerable Bulk- Power System equipment, or otherwise, as a result of a benchmark GMD event. (Emphasis added.)
As we will show in this comment, both the Benchmark GMD Event and the assessment criteria to identify potential impacts from the Benchmark GMD Event are fatally flawed. As a result, it is exceedingly unlikely that GMD Vulnerability Assessments by owners and operators will result in any significant protection against instability, uncontrolled separation, or cascading failures of the Bulk-Power System, except by voluntary action beyond the requirements of this standard.
