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Request For Interpretation (RFI)

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​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 for 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 RFI 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 System can 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.

Completed RFI forms should explain the ​clarification required, the specific circumstances surrounding the request, and the impact of not having the Interpretation provided. Submit completed forms via the NERC Helpdesk by selecting “Standards” from the “Service” drop-down menu then “Standards Request for Interpretation” under “Category”. NERC Reliability Standards and Legal staff will review the RFI to determine if 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 to the entity within 10 business days of the decision. If the SC accepts the RFI, NERC Standards Staff shall (i) form a ballot pool and (ii) assemble an Interpretation drafting team with the relevant expertise. Interpretations are balloted in the same manner as Reliability Standards.

Below are the RFIs not accepted by the SC. They include the corresponding responses to the entity that submitted the request.