Request For Interpretation (RFI)
 

​Section 7.0 of the Standard Processes Manual (Appendix 3A of the NERC Rules of Procedure) provides the Process for Developing an Interpretation.

A valid Request for Interpretation (RFI) is one that seeks additional clarity about one or more Requirements in approved NERC Reliability Standards, but does not request approval as to how to comply with one or more Requirements. A valid Interpretation response provides additional clarity about one or more Requirements, but does not expand on any Requirement and does not explain how to comply with any Requirement. Any entity that is directly and materially affected by the reliability of the North American Bulk Power Systems may request an Interpretation of any Requirement in any continent-wide Reliability Standard. Interpretations will only be provided for Board of Trustees-approved Reliability Standards i.e. (i) the current effective version of a Reliability Standard; or (ii) a version of a Reliability Standard with a future effective date.

The requesting entity can submit an RFI form to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the Interpretation provided. The NERC Reliability Standards and Legal Staffs will review the request for interpretation to determine whether it meets the requirements for a valid interpretation and will make a recommendation to the Standards Committee (SC) whether to accept the RFI or reject it.

For example, an Interpretation request may be rejected where it:

  1. Requests approval of a particular compliance approach;
  2. Identifies a gap or perceived weakness in the approved Reliability Standard;
  3. Where an issue can be addressed by an active standard drafting team;
  4. Where it requests clarification of any element of a Reliability Standard other than a Requirement;
  5. Where a question has already been addressed in the record;
  6. Where the Interpretation identifies an issue and proposes the development of a new or modified Reliability Standard, (such issues should be addressed via submission of a SAR);
  7. Where an Interpretation seeks to expand the scope of a Reliability Standard; or
  8. Where the meaning of a Reliability Standard is plain on its face.

If the SC rejects the RFI, it shall provide a written explanation for rejecting the Interpretation to the entity requesting the Interpretation within 10 business days of the decision. If the SC accepts the RFI, the NERC Standards Staff shall (i) form a ballot pool and (ii) assemble an Interpretation drafting team with the relevant expertise. Interpretations will be balloted in the same manner as Reliability Standards.

The RFIs that are not accepted by the SC can be found below with the corresponding responses to the Entity that submitted the request.

 
  
  
  
  
  
collapse Year : 2018 ‎(3)
SC Response to Enel Green Power RFI - MOD-026-1.pdfSC Response to Enel Green Power RFI - MOD-026-1MOD-026-1Enel Green Power12/12/2018
SC Response to CMPC RFI - EOP-004-3.pdfSC Response to CMPC RFI - EOP-004-3EOP-004-3Central Maine Power Company9/12/2018
SC Response to NAGF RFI - MOD-027-1.pdfSC Response to NAGF RFI - MOD-027-1MOD-027-1North American Generator Forum4/23/2018
collapse Year : 2017 ‎(5)
SC Response to SPP RFI - FAC-002-2.pdfSC Response to SPP RFI - FAC-002-2FAC-002-2Southwest Power Pool9/12/2017
SC Response to CAISO RFI - PRC-024-2.pdfSC Response to CAISO RFI - PRC-024-2PRC-024-2California ISO7/21/2017
SC Response to NEI-NITF RFI - PRC-024-2.pdfSC Response to NEI-NITF RFI - PRC-024-2PRC-024-2Nuclear Energy Institute NERC Issues Task Force7/20/2017
SC Response to PNM Resources Inc RFI - EOP-008-1.pdfSC Response to PNM Resources Inc RFI - EOP-008-1EOP-008-1PNM Resources, Inc.6/15/2017
SC Response to Utility Services RFI - PRC-006-2.pdfSC Response to Utility Services RFI - PRC-006-2PRC-006-2Utility Services, Inc.6/15/2017
collapse Year : 2016 ‎(6)
SC Response to Cleco RFI - CIP-010-2.pdfSC Response to Cleco RFI - CIP-010-2CIP-010-2Cleco Corporation12/23/2016
SC Response to Xcel RFI - PRC-005-6.pdfSC Response to Xcel RFI - PRC-005-6PRC-005-6Xcel Energy12/23/2016
SC Response to Hydro Quebec RFI - PRC-002-2.pdfSC Response to Hydro Quebec RFI - PRC-002-2PRC-002-2Hydro-Québec TransÉnergie10/20/2016
SC Response to Hydro Quebec RFI PRC-002-.pdfSC Response to Hydro Quebec RFI PRC-002-PRC-002-2Hydro-Québec TransÉnergie10/20/2016
SC Response to Orlando Utilities Commission RFI - BAL-001-2.pdfSC Response to Orlando Utilities Commission RFI - BAL-001-2BAL-001-2Orlando Utilities Commission9/28/2016
SC Response to Cleco RFI - CIP-006-6.pdfSC Response to Cleco RFI - CIP-006-6CIP-006-6Cleco Corporation9/28/2016