Summary of NERC Penalties
Quarter 4 - September 2023
FAC-009-1 R1, FAC-008-3 R6, and FAC-008-5 R6
Avangrid, encompassing companies like New York State Electric & Gas, was fined $615,000 for breaches of Facility Ratings Standards, notably violations of FAC-009-1 R1, FAC-008-3 R6, and FAC-008-5 R6. These infringements posed risks to the Bulk Power System. 17% of Avangrid's facilities had errors, with 7.7% needing rating reductions. These consistent issues highlight a systemic problem with their Facility Ratings, resulting in the penalty.
Extent of Condition
Avangrid performed an EOC review and found numerous instances of inaccurate Facility Ratings, but none of the derates involved resulted in Avangrid operating above the correct Facility Rating over the past three years. The issue resulted in 41 NYSEG Facilities (5.6 percent of Avangrid Facilities), 2 RG&E Facilities (0.3 percent of Avangrid Facilities), 72 CMP Facilities (10.2 percent of Avangrid Facilities), 4 MEPCO Facilities (0.6 percent of Avangrid Facilities), and no UI Facilities requiring a Facility Rating change. Of these, 14 NYSEG Facilities and 40 CMP Facilities required a decrease ranging from 2 percent to 70 percent. Avangrid expects to complete its EOC walkdowns of all its Facilities by the end of 2024. While no Facility Ratings inaccuracies were identified for UI, UI was unable to locate engineering documentation to support some Facility Ratings and there was not a clear identification as to what version of the Facility Rating Methodology UI had used.
The cause of this violation was (1) ineffective interdepartmental coordination or silos between departments; (2) inadequate internal controls for ensuring the accuracy of Facility Ratings; (3) lack of Company-wide rating modification process; and (4) inadequate ratings validation program, including but not limited to a process of reviewing equipment ratings during the transition from a manually maintained database to the current thermal limit database software.
Basis for Penalty
The NPCC has assessed a penalty of six hundred fifteen thousand dollars ($615,000) for the referenced violations. In reaching this determination, NPCC considered the following factors:
1. Three of the seven violations posed a serious risk to the reliability of the BPS.
2. The Entity self-reported all of the violations, but two did not warrant self-reporting credit as they were discovered due to the NPCC self-certification process.
3. The Entity was cooperative throughout the compliance enforcement process.
4. The Entity agreed to the settlement and admitted to the violations.
5. There were no other mitigating or aggravating factors or extenuating circumstances that would affect the assessed penalty/disposition method.
After consideration of the above factors, NPCC determined that, in this instance, the penalty amount of six hundred fifteen thousand dollars ($615,000) is appropriate and bears a reasonable relation to the seriousness and duration of the violations.
Avangrid is headquartered in Orange, Connecticut, and has a footprint in 24 states with $41 billion in assets. Its primary businesses are Networks (including NYSEG, RG&E, CMP, MEPCO, and UI) that serve 3.3 million electric and natural gas customers in the Northeast, and Renewables, the third-largest renewable energy company in the U.S. with a diverse onshore and offshore renewable energy portfolio. NYSEG, RG&E, CMP, MEPCO, and UI are subsidiaries of Avangrid. NYSEG operates approximately 35,000 miles of electric distribution lines and 4,500 miles of electric transmission lines across more than 40% of upstate New York. It serves approximately 907,000 electricity customers. RG&E operates approximately 8,900 miles of electric distribution lines and 1,100 miles of electric transmission lines. It serves approximately 385,900 electricity customers in a nine-county region in New York surrounding the City of Rochester. CMP is Maine’s largest electricity transmission and distribution utility. CMP operates approximately 23,500 miles of distribution lines and 2,900 miles of transmission lines. CMP serves approximately 646,000 customers across 346 communities in central and southern Maine. MEPCO is partially owned by CMP, which has a 78 percent ownership interest. MEPCO owns and operates a 345kV transmission interconnection extending from Wiscasset, Maine to the Maine-New Brunswick international border at Orient, Maine, where it interconnects with the New Brunswick Power Corporation’s facilities in the province of New Brunswick, Canada. UI operates approximately 3,600 miles of electric distribution lines and 138 miles of transmission lines. UI serves approximately 341,000 customers in the greater New Haven and Bridgeport areas of Connecticut.
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