80 FR 36280 - Transmission Operations Reliability Standards and Interconnection Reliability Operations and Coordination Reliability Standards
DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission Federal Register Volume 80, Issue 121 (June 24, 2015)
Federal Energy Regulatory Commission
Federal Register Volume 80, Issue 121 (June 24, 2015)
| Page Range | 36280-36293 | |
| FR Document | 2015-15433 |
[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)] [Proposed Rules] [Pages 36280-36293] From the Federal Register Online [www.thefederalregister.org] [FR Doc No: 2015-15433] [[Page 36280]] ======================================================================= ----------------------------------------------------------------------- DEPARTMENT OF ENERGY Federal Energy Regulatory Commission 18 CFR Part 40 [Docket No. RM15-16-000] Transmission Operations Reliability Standards and Interconnection Reliability Operations and Coordination Reliability Standards AGENCY: Federal Energy Regulatory Commission, DOE. ACTION: Notice of proposed rulemaking. ----------------------------------------------------------------------- SUMMARY: The Commission proposes to approve revisions to the Transmission Operations and Interconnection Reliability Operations and Coordination Reliability Standards, developed by the North American Electric Reliability Corporation, which the Commission has certified as the Electric Reliability Organization responsible for developing and enforcing mandatory Reliability Standards. DATES: Comments are due August 24, 2015. ADDRESSES: Comments, identified by docket number, may be filed in the following ways:Electronic Filing through http://www.ferc.gov. Documents created electronically using word processing software should be filed in native applications or print-to-PDF format and not in a scanned format. Mail/Hand Delivery: Those unable to file electronically may mail or hand-deliver comments to: Federal Energy Regulatory Commission, Secretary of the Commission, 888 First Street NE., Washington, DC 20426. Instructions: For detailed instructions on submitting comments and additional information on the rulemaking process, see the Comment Procedures Section of this document. FOR FURTHER INFORMATION CONTACT: Robert T. Stroh (Legal Information), Office of the General Counsel, Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, Telephone: (202) 502-8473, [email protected] Eugene Blick (Technical Information), Office of Electric Reliability, Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, Telephone: (301) 665-1759, [email protected] Darrell G. Piatt (Technical Information), Office of Electric Reliability, Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, Telephone: (205) 332-3792, [email protected] SUPPLEMENTARY INFORMATION: 1. Pursuant to section 215 of the Federal Power Act (FPA),\1\ the Commission proposes to approve revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards, developed by the North American Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability Organization (ERO). The Commission believes that the proposed TOP and IRO Reliability Standards improve on the currently- effective standards by providing a more precise set of Reliability Standards addressing operating responsibilities and improving the delineation of responsibilities between applicable entities. The Commission also believes that the revised TOP Reliability Standards eliminate gaps and ambiguities in the currently-effective TOP requirements and improve efficiency by incorporating the necessary requirements from the eight currently-effective TOP Reliability Standards into three cohesive, comprehensive Reliability Standards. Further, the Commission believes that the proposed standards clarify and improve upon the currently-effective TOP and IRO Reliability Standards by designating requirements in the proposed standards that apply to transmission operators for the TOP standards and reliability coordinators for the IRO standards. Thus, the Commission proposes to find that there are benefits to clarifying and bringing efficiencies to the TOP and IRO Reliability Standards, consistent with the Commission's policy promoting increased efficiencies in Reliability Standards and reducing requirements that are either redundant with other currently- effective requirements or have little reliability benefit.\2\ --------------------------------------------------------------------------- \1\ 16 U.S.C. 824o (2012). \2\ Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards, Order No. 788, 145 FERC ] 61,147 (2013). --------------------------------------------------------------------------- 2. The Commission also proposes to find that NERC has adequately addressed the concerns raised by the Commission in the Notice of Proposed Rulemaking (Remand NOPR) issued in November 2013.\3\ In the Remand NOPR, the Commission proposed to remand an earlier version of proposed TOP and IRO Standards due to concerns regarding the proposed treatment of system operating limits (SOLs) and interconnection reliability operating limits (IROLs) and concerns about outage coordination. Further, the Commission proposes to approve the definitions for operational planning analysis and real-time assessment, and the violation severity level and violation risk factor assignments. --------------------------------------------------------------------------- \3\ Monitoring System Conditions--Transmission Operations Reliability Standard, Transmission Operations Reliability Standards, Interconnection Reliability Operations and Coordination Reliability Standards, Notice of Proposed Rulemaking, 145 FERC ] 61,158 (2013). Concurrent with filing the proposed TOP/IRO standards in the immediate proceeding, NERC submitted a motion to withdraw the earlier petition that was the subject of the Remand NOPR. No protests to the motion were filed and the petition was withdrawn pursuant to 18 CFR 385.216(b). --------------------------------------------------------------------------- 3. While proposing to approve the TOP and IRO Reliability Standards, below the Commission seeks clarifying comments addressing four issues: (A) Possible inconsistencies in identifying IROLs; (B) monitoring of non-bulk electric system facilities; (C) removal of the load-serving entity as an applicable entity for proposed Reliability Standard TOP-001-3; and (D) data exchange capabilities. Based on comments and information received on these issues, the Commission may issue directives as appropriate. I. Background 4. Section 215 of the FPA requires a Commission-certified ERO to develop mandatory and enforceable Reliability Standards, which are subject to Commission review and approval. Once approved, the Reliability Standards are enforced by the ERO, subject to Commission oversight, or by the Commission independently. On March 16, 2007, the Commission issued Order No. 693, approving 83 of the 107 initial Reliability Standards filed by NERC, including the existing TOP and IRO Reliability Standards.\4\ In addition, in Order No. 748, the Commission approved revisions to the IRO Reliability Standards.\5\ --------------------------------------------------------------------------- \4\ Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 FR 16416 (Apr. 4, 2007), FERC Stats. & Regs. ] 31,242, order on reh'g, Order No. 693-A, 120 FERC ] 61,053 (2007). \5\ Mandatory Reliability Standards for Interconnection Reliability Operating Limits, Order No. 748, 134 FERC ] 61,213 (2011). --------------------------------------------------------------------------- 5. On April 16, 2013, in Docket No. RM13-14-000, NERC submitted for Commission approval three revised TOP Reliability Standards to replace the eight currently-effective TOP standards.\6\ Additionally, on April 16, 2013, in Docket No. RM13-15-000, NERC submitted for Commission approval four revised IRO Reliability Standards to replace six currently- [[Page 36281]] effective IRO Reliability Standards. On November 21, 2013, the Commission issued the Remand NOPR in which the Commission expressed concern that NERC had ``removed critical reliability aspects that are included in the currently-effective standards without adequately addressing these aspects in the proposed standards.'' \7\ The Commission identified two main concerns and asked for clarification and comment on a number of other issues. Among other things, the Commission expressed concern that the proposed TOP Reliability Standards did not require transmission operators to plan and operate within all SOLs, which is a requirement in the currently-effective standards. In addition, the Commission expressed concern that the proposed IRO Reliability Standards did not require outage coordination. --------------------------------------------------------------------------- \6\ On April 5, 2013, in Docket No. RM13-12-000 NERC proposed revisions to Reliability Standard TOP-006-3 to clarify that transmission operators are responsible for monitoring and reporting available transmission resources and that balancing authorities are responsible for monitoring and reporting available generation resources. \7\ Remand NOPR, 145 FERC ] 61,158 at P 4. --------------------------------------------------------------------------- 6. On December 20, 2013, NERC filed a motion requesting that the Commission defer action, until January 31, 2015, to allow NERC time to consider the reliability concerns raised by the Commission in the Remand NOPR. The Commission granted that motion on January 14, 2014.\8\ In response to the Remand NOPR, NERC initiated Project 2014-03 to develop further revisions to the TOP and IRO Reliability Standards. --------------------------------------------------------------------------- \8\ Monitoring System Conditions--Transmission Operations Reliability Standard, Transmission Operations Reliability Standards, Interconnection Reliability Operations and Coordination Reliability Standards, Order Granting Motion to Defer Action, 146 FERC ] 61,023 (2014). --------------------------------------------------------------------------- NERC Petition 7. On March 18, 2015, as supplemented on May 12, 2015, NERC submitted a petition seeking approval of two sets of Reliability Standards to replace the currently-effective TOP and IRO Reliability Standards. NERC states that the proposed TOP Reliability Standards generally address real-time operations and planning for next-day operations, and apply primarily to the responsibilities and authorities of transmission operators, with certain requirements applying to the roles and responsibilities of the balancing authority. NERC adds that the proposed IRO Reliability Standards set forth the responsibility and authority of reliability coordinators to provide for reliable operations. According to NERC, reliability coordinators have an essential role in ensuring reliable operations, as they are the functional entities with the highest level of authority and have the wide-area view of the bulk electric system.\9\ --------------------------------------------------------------------------- \9\ The TOP and IRO Reliability Standards are not attached to this NOPR. The complete text of the Reliability Standards is available on the Commission's eLibrary document retrieval system in Docket No. RM15-16 and is posted on the ERO's Web site, available at: http://www.nerc.com. --------------------------------------------------------------------------- 8. NERC states that the proposed Reliability Standards include improvements over the currently effective TOP and IRO Reliability Standards in key areas such as: (1) Operating within SOLs and IROLs; (2) outage coordination; (3) situational awareness; (4) improved clarity and content in foundational definitions; and (5) requirements for operational reliability data. 9. NERC states that the proposed TOP and IRO Reliability Standards address the coordinated efforts to plan and reliably operate the bulk electric system under both normal and abnormal conditions. NERC states that the proposed Reliability Standards provide a comprehensive framework for reliable operations, with important improvements to ensure the bulk electric system is operated within pre-established limits while enhancing situational awareness and strengthening operations planning. NERC explains that the proposed Reliability Standards establish or revise requirements for operations planning, system monitoring, real-time actions, coordination between applicable entities, and operational reliability data. According to NERC, the proposed Reliability Standards help to ensure that reliability coordinators and transmission operators work together, and with other functional entities, to operate the bulk electric system within SOLs and IROLs.\10\ Further, NERC explains that SOLs and IROLs are vital concepts in the Reliability Standards because they establish acceptable performance criteria both pre- and post-contingency to maintain reliable bulk electric system operations. NERC states that when any facility rating or stability limit is exceeded, or expected to be exceeded, these conditions should be mitigated to avoid the possibility of further deteriorating system conditions and the potential for a cascading event. In addition, NERC states that the standard drafting team developed a white paper on SOL definition and exceedance criteria which clarified the team's position on establishing and exceeding SOLs, and on implementing operating plans to mitigate exceedances. The SOL white paper explains the links between relevant reliability standards and reliability concepts to establish a common understanding necessary for developing effective operating plans to mitigate SOL exceedances.\11\ --------------------------------------------------------------------------- \10\ The NERC Glossary of Terms defines IROL as ``[a] System Operating Limit that, if violated, could lead to instability, uncontrolled separation, or Cascading outages that adversely impact the reliability of the Bulk Electric System.'' In turn, NERC defines SOL as ``[t]he value (such as MW, MVar, Amperes, Frequency or Volts) that satisfies the most limiting of the prescribed operating criteria for a specified system configuration to ensure operation within acceptable reliability criteria. . . .'' \11\ NERC Petition at 46 and Exhibit E, ``White Paper on System Operating Limit Definition and Exceedance Clarification.'' --------------------------------------------------------------------------- 10. NERC states that it reviewed the report on the Arizona-Southern California Outages on September 8, 2011, Causes and Recommendations (``2011 Southwest Outage Blackout Report'') that includes findings and recommendations applicable to transmission operators, balancing authorities and reliability coordinators, and provides explanations of how the proposed Reliability Standards address the reliability issues identified following the 2011 Southwest Outage Blackout Report. Further, NERC states that it addressed outstanding Commission directives relevant to the proposed TOP and IRO Reliability Standards. Revisions to TOP Standards 11. NERC proposes three TOP Reliability Standards to replace the existing suite of TOP standards. The proposed TOP Reliability Standards generally address real-time operations and planning for next-day operations, and apply primarily to the responsibilities and authorities of transmission operators. Among other things, NERC states that the proposed revisions to the TOP Reliability Standards help ensure that transmission operators plan and operate within all SOLs. TOP-001-3 (Transmission Operations) 12. NERC proposes Reliability Standard TOP-001-3 (Transmission Operations), which contains twenty requirements. The purpose of proposed Reliability Standard TOP-001-3 is to prevent instability, uncontrolled separation, or cascading outages that adversely affect the reliability of the interconnection, by ensuring prompt action to prevent or mitigate such occurrences. According to NERC, the proposed standard achieves this reliability goal by providing appropriate entities with the authority to take actions, or direct the actions of others, to maintain reliability during real-time operations. NERC explains that the standard includes real-time monitoring and real-time assessment requirements [[Page 36282]] to preserve reliability and ensure that applicable entities identify and address all SOL exceedances. 13. Requirements R1 and R2 require each transmission operator and balancing authority to explicitly and affirmatively act to address the reliability of its area through its own actions or by issuing operating instructions. In contrast, NERC notes that the obligation to act in currently effective Reliability Standard TOP-001-1a is implied, but not an explicit requirement. Requirements R3 and R4 together provide that each applicable entity must comply with each operating instruction issued by its transmission operator, unless doing so would violate safety, equipment, regulatory, or statutory requirements or the action cannot be physically implemented, and require an applicable entity to notify the transmission operator if it is unable to comply with the transmission operator's operating instruction. Similarly, Requirements R5 and R6 require the same actions of applicable entities with respect to an operating instruction issued by a balancing authority. 14. Requirement R7 requires each transmission operator to assist other transmission operators within its reliability coordinator area, and Requirement R8 requires a transmission operator to inform applicable entities of the transmission operator's actual or expected operations that result in, or could result in, an emergency. 15. Requirements R9, R16, and R17 address outage coordination of monitoring and control equipment. Requirement R9 provides that each balancing authority and transmission operator must notify its reliability coordinator and known impacted interconnected entities of all planned outages, and unplanned outages of 30 minutes or more, for telemetering and control equipment, monitoring and assessment capabilities, and associated communication channels between the affected entities. Requirements R16 and R17 state that each transmission operator and balancing authority must provide its system operators with the authority to approve planned outages and maintenance. 16. Requirement R10 addresses transmission operator monitoring obligations to help ensure that transmission operators have the necessary situational awareness to maintain reliable operations. Requirement R10 provides that each transmission operator must take certain steps for determining SOL exceedances within its transmission operator area. NERC explains that Requirement R10 addresses the Commission's concerns that the TOP and IRO Reliability Standards, that were the subject of the Remand NOPR, did not have sufficient requirements for real-time monitoring. Requirement R11 is the equivalent of Requirement R10 for balancing authorities. 17. Requirement R12 provides that each transmission operator must not operate outside of any identified IROL for a continuous duration exceeding its associated IROL T v. NERC states that this requirement will provide consistency with the reliability coordinators requirements contained in currently-effective Reliability Standard IRO- 009-1.\12\ Requirement R13 provides that each transmission operator must ensure that a real-time assessment is performed at least once every 30 minutes. The revised definition of ``real-time assessment'' includes additional specificity regarding various inputs for the assessment and how that information may be provided through third-party services, which may provide smaller entities an efficient method for compliance. Requirement R14 provides that each transmission operator must initiate its operating plan to mitigate a SOL exceedance identified as part of its real-time monitoring or real-time assessment.\13\ --------------------------------------------------------------------------- \12\ NERC defines Tv as ``[t]he maximum time that an Interconnection Reliability Operating Limit can be violated before the risk to the interconnection or other Reliability Coordinator Area(s) becomes greater than acceptable. Each Interconnection Reliability Operating Limit's Tv shall be less than or equal to 30 minutes.'' \13\ NERC Petition, Exhibit B at 5. --------------------------------------------------------------------------- 18. Requirement R15 provides that each transmission operator must inform its reliability coordinator of actions taken to return the system to within limits when a SOL has been exceeded. Requirement R18 provides that each transmission operator must operate to the most limiting parameter in instances where there is a difference in SOLs. Requirements R19 and R20 provide that each transmission operator and balancing authority must have data exchange capabilities with the entities from which it needs data in order to maintain reliability in its area. 19. In addition, NERC states that it removed the load-serving entity (LSE) function from proposed TOP-001-3, Requirements R3 through R6 due to the November 2014 NERC Board of Trustees action to remove the LSE as a functional entity from NERC's Rules of Procedure.\14\ On May 12, 2015, NERC supplemented its filing with additional explanation for the removal of the LSE function. --------------------------------------------------------------------------- \14\ NERC Petition, Exhibit K, Consideration of Comments January 7, 2015, at 2. --------------------------------------------------------------------------- TOP-002-4 (Operations Planning) 20. Proposed Reliability Standard TOP-002-4 contains seven requirements relating to operations planning for transmission operators and balancing authorities. NERC explains that the proposed standard addresses next-day planning and provides for the necessary notifications and coordination between various functional entities. NERC adds that the revised definition of ``operational planning analysis'' specifies the scope and inputs required for next-day analyses. According to NERC, the proposed standard also improves coordination of next-day operations by requiring transmission operators and balancing authorities to provide operating plans to their reliability coordinators. 21. Proposed Requirements R1 through R3 and R6 apply to transmission operators, and proposed Requirements R4, R5, and R7 apply to balancing authorities. Requirement R1 requires each transmission operator to have an operational planning analysis that will allow it to assess whether its planned operations for the next day within its transmission operator area will exceed any of its SOLs. Requirement R2 requires each transmission operator to have operating plans for next- day operations to address potential SOL exceedances identified in the operational planning analysis performed pursuant to Requirement R1. Requirement R4 requires each balancing authority to have operating plans for the next day that address expected generation resource commitment and dispatch, interchange scheduling, demand patterns, and capacity and energy reserve requirements, including deliverability capability. Requirements R3 and R5 require each transmission operator and balancing authority, respectively, to notify the entities identified in their operating plan as to their roles in that plan. Requirements R6 and R7 require each transmission operator and balancing authority to provide its operating plan to its reliability coordinator. TOP-003-3 (Operational Reliability Data) 22. Proposed Reliability Standard TOP-003-3 (Operational Reliability Data) establishes requirements for the provision of information and data needed by the transmission operator and balancing authority for reliable operations. The purpose of proposed Reliability Standard TOP-003-3 is to ensure that transmission operators and [[Page 36283]] balancing authorities have the data needed to fulfill their operational and planning responsibilities. The proposed Reliability Standard consists of five Requirements, including requirements for balancing authorities and transmission operators to maintain and distribute to relevant entities data specifications needed to perform various analyses and assessments. The proposed Reliability Standard also requires entities receiving data specifications to respond according to mutually agreed upon parameters including format and security protocols. 23. Requirement R1 requires each transmission operator to maintain a documented specification for the data necessary, including non-bulk electric system and external network data, for it to perform its operational planning analysis, real-time monitoring, and real-time assessments. Requirement R2 requires each balancing authority to maintain a documented specification for the data necessary for it to perform its analysis functions and real-time monitoring. Requirements R3 and R4 require each transmission operator and balancing authority to distribute its data specification to the entities that have the necessary data. Requirement R5 requires each applicable entity receiving a data specification pursuant to Requirement R3 or R4 to satisfy the obligations of the documented data specification. 24. In response to the Commission's concerns in the Remand NOPR with regard to the need for including external networks and sub-100 kV facilities in the operational planning analysis conducted by transmission operators, NERC explains that proposed Reliability Standard TOP-003-3 requires each applicable entity to develop a data specification that would cover its data needs for monitoring and analysis purposes, including non-bulk electric system data and external network data deemed necessary by the transmission operator to support its operational planning analyses, real-time monitoring, and real-time assessments. With respect to sub-100 kV facilities, NERC determined that any sub-100 kV elements that are necessary for reliable operation of the bulk electric system would be included as bulk electric system facilities through the exception process provided in Appendix 5C to the NERC Rules of Procedure. NERC explains that the exception process provides the means for transmission operators and reliability coordinators to include elements in the bulk electric system that are necessary for the reliable operation of the interconnected transmission system but were not identified in the bulk electric system definition. Accordingly, NERC concludes that it is not necessary to include non- bulk electric system monitoring in Reliability Standard TOP-001-3. In addition, NERC explains that proposed Reliability Standard TOP-001-3, Requirement R10 requires transmission operators to monitor bulk electric system facilities within their transmission operator area, and to obtain information deemed necessary by the transmission operator about such bulk electric system facilities located outside of the transmission operator area when determining SOL exceedances. 25. NERC adds that when non-bulk electric facilities have no impact on the bulk electric system, but are needed for completing system models, the Commission-approved Reliability Standard FAC-001-2, Requirement R3 addresses the issue. This Reliability Standard requires the reliability coordinator to include in its methodology its entire reliability coordinator area and critical modeling details from other reliability coordinator areas that would affect the facility under study. In addition, the reliability coordinator must include details of system models used to determine SOLs. Revisions to IRO Standards 26. The proposed IRO Reliability Standards, which complement the proposed TOP Standards, are designed to ensure that the bulk electric system is planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions. The proposed IRO Reliability Standards set forth the responsibility and authority of reliability coordinators to provide for reliable operations. NERC states that in the proposed IRO Reliability Standards reliability coordinators must continue to monitor SOLs in addition to their obligation in the currently effective Reliability Standards to monitor and analyze IROLs. These obligations require reliability coordinators to have the wide-area view necessary for situational awareness and provide them the ability to respond to system conditions that have the potential to negatively affect reliable operations. IRO-001-4 (Reliability Coordination--Responsibilities) 27. Proposed Reliability Standard IRO-001-4 (Reliability Coordination--Responsibilities) contains requirements relating to the reliability coordinator's overall responsibility for reliable operation within the reliability coordinator area. Requirement R1 provides that each reliability coordinator must act to address the reliability of its reliability coordinator area through direct actions or by issuing operating instructions. Requirement R2 provides that each applicable entity must comply with its reliability coordinator's operating instructions unless compliance cannot be implemented or would violate safety, equipment, regulatory, or statutory requirements. Requirement R3 provides that applicable entities must inform the reliability coordinator if they are unable to perform an operating instruction issued by its reliability coordinator. IRO-002-4 (Reliability Coordination--Monitoring and Analysis) 28. Proposed Reliability Standard IRO-002-4 (Reliability Coordination--Monitoring and Analysis) contains requirements relating to capabilities for monitoring and analysis of real-time operating data. The purpose of the proposed Reliability Standard is to provide system operators with the capabilities necessary to monitor and analyze data needed to perform reliability functions. Requirement R1 requires each reliability coordinator to have data exchange capabilities with its balancing authorities, transmission operators, and other entities as it deems necessary, for it to perform operational planning analyses, real-time monitoring, and real-time assessments. Requirement R2 provides that each reliability coordinator must provide its system operators with the authority to approve planned outages and maintenance of its telecommunication, monitoring, and analysis capabilities. Requirement R3 provides that each reliability coordinator must monitor facilities, the status of special protection systems and non-bulk electric system facilities identified as necessary within its reliability coordinator area and neighboring reliability coordinator areas, to identify any SOL or IROL exceedances. Requirement R4 provides that each reliability coordinator must have monitoring systems that provide information used by the reliability coordinator's operating personnel, with particular emphasis to alarm management and awareness systems, automated data transfers, and synchronized information systems, over a redundant infrastructure. IRO-008-2 (Reliability Coordinator Operational Analyses and Real-time Assessments) 29. Proposed Reliability Standard IRO-008-2 (Reliability Coordinator Operational Analyses and Real-time Assessments) contains requirements for reliability coordinators to conduct next-day analyses and assessments of [[Page 36284]] operating conditions in real-time to help prevent instability, uncontrolled separation, or cascading. NERC states that the proposed definitions of operational planning analysis and real-time assessment are integral components of proposed Reliability Standard IRO-008-2 because they specify the scope and inputs for next-day analysis and real-time assessments of operating conditions in real-time. Furthermore, NERC states that proposed Reliability Standard IRO-008-2 enhances next-day operations planning by specifying requirements for coordination of the reliability coordinator's operating plan to address potential SOL and IROL exceedances. 30. Requirement R1 provides that each reliability coordinator must perform an operational planning analysis that will allow it to assess whether the planned operations for the next day will exceed SOLs and IROLs. Requirement R2 requires each reliability coordinator to have a coordinated operating plan for next-day operations to address potential SOL and IROL exceedances identified as a result of its operating planning analysis. Requirement R3 provides that each reliability coordinator must notify impacted entities identified in its operating plan as to their role in the plan. Requirement R4 states that each reliability coordinator must ensure that a real-time assessment is performed at least once every 30 minutes. Requirement R5 provides that each reliability coordinator must notify impacted transmission operators and balancing authorities within its reliability coordinator area and other impacted reliability coordinators when a real-time assessment indicates an actual or expected condition that results in, or could result in, a SOL or IROL exceedance. Further, Requirement R6 provides that each reliability coordinator must notify impacted entities when a SOL or IROL exceedance has been prevented or mitigated. IRO-010-2 (Reliability Coordinator Data Specification and Collection) 31. Proposed Reliability Standard IRO-010-2 (Reliability Coordinator Data Specification and Collection) provides a mechanism for a reliability coordinator to obtain the information and data it needs for reliable operations and to help prevent instability, uncontrolled separation, or cascading outages. According to NERC, proposed Reliability Standard IRO-010-2 reflects recommendations from the 2011 Southwest Outage Blackout Report, including more clearly identifying necessary data and information to be included in a reliability coordinator's data specification. Requirement R1 provides that the reliability coordinator must maintain a documented specification for the data, including non-bulk electric system and external network data, necessary for it to perform its operational planning analyses, real- time monitoring, and real-time assessments. Requirement R2 provides that the reliability coordinator must distribute its data specification to entities that have the required data. Requirement R3 provides that applicable entities receiving a data specification must satisfy the obligations of the documented specification using a mutually-agreeable format, process for resolving data conflicts, and security protocol. IRO-014-3 (Coordination Among Reliability Coordinators) 32. Proposed Reliability Standard IRO-014-3 (Coordination among Reliability Coordinators) contains requirements for coordination for interconnected operations at the reliability coordinator level. The purpose of the proposed Reliability Standard is to ensure that each reliability coordinator's operations are coordinated such that they will not adversely affect other reliability coordinator areas and to preserve the reliability benefits of interconnected operations. Requirement R1 requires each reliability coordinator to have and implement operating procedures, processes, or plans for activities that require notification or coordination of actions that may affect adjacent reliability coordinator areas. Requirement R2 requires each reliability coordinator to maintain its operating procedures, processes, or plans through annual reviews and updates, with no more than 15 months passing between reviews. Requirement R3 requires each reliability coordinator to notify other impacted reliability coordinators upon identification of an expected or actual emergency. Requirement R4 specifies that, if the reliability coordinators disagree on the existence of an emergency, each must operate as though an emergency exists. Requirement R5 states that a reliability coordinator that identifies an emergency must develop an action plan to resolve the emergency, and Requirement R6 requires impacted reliability coordinators to implement the action plan. Under Requirement R7, a reliability coordinator must assist another reliability coordinator if the requesting reliability coordinator has implemented its emergency procedures. IRO-017-1 (Outage Coordination) 33. NERC states that proposed Reliability Standard IRO-017-1 (Outage Coordination) is a new Reliability Standard designed to ensure that outages are properly coordinated in the operations planning time horizon and near-term transmission planning horizon. According to NERC, the requirements in the proposed Reliability Standard, which span both time horizons, provide the necessary requirements for effective coordination of planned outages to support reliable operations. 34. NERC notes that in the Remand NOPR the Commission identified coordination of outages as a critical reliability function that should be performed by the reliability coordinator that was not adequately addressed. NERC explains that proposed Reliability Standard IRO-017-1 addresses the Commission's Remand NOPR concerns by requiring each reliability coordinator to develop, implement and maintain an outage coordination process for generation and transmission outages. NERC also explains that each transmission operator and balancing authority would then be required to perform the functions specified in its reliability coordinator's process. Further, NERC states that each planning coordinator and transmission planner will provide its planning assessment to relevant reliability coordinators and work together to solve any issues or conflicts with planned outages among the applicable entities. Additionally, NERC states that proposed Reliability Standard IRO-014-3, Requirement R1, Part 1.4 requires reliability coordinators to coordinate with adjacent reliability coordinators the exchange of planned and unplanned outage information to support operational planning analyses and real-time assessments in their operating procedures, processes, or plans. 35. Proposed Reliability Standard IRO-017-1 has four requirements. Requirement R1 provides that each reliability coordinator must develop, implement, and maintain an outage coordination process for generation and transmission outages. Requirement R2 provides that each transmission operator and balancing authority must perform the functions specified in its reliability coordinator's outage coordination process. Requirement R3 provides that each planning coordinator and transmission planner must provide its planning assessment to impacted reliability coordinators. Requirement R4 requires each planning coordinator and transmission planner to jointly develop [[Page 36285]] solutions with its respective reliability coordinators for identified issues or conflicts with planned outages in its planning assessment for the near-term transmission planning horizon. Definitions 36. NERC also proposes revised definitions for ``operational planning analysis'' and ``real-time assessment.'' \15\ NERC contends that the proposed definitions provide significant additional detail compared to the currently effective definitions to enhance the consistency and the reliability benefit of operational planning analysis and real-time assessments.\16\ NERC states that the additional specificity reflected in the proposed definitions addresses concerns raised in the Remand NOPR and includes several inputs that were identified as recommendations in the 2011 Southwest Outage Blackout Report, which, in turn, will enhance situational awareness. --------------------------------------------------------------------------- \15\ The proposed definition of operational planning analysis is ``[a]n evaluation of projected system conditions to assess anticipated (pre-Contingency) and potential (post-Contingency) conditions for next-day operations. The evaluation shall reflect applicable inputs including, but not limited to, load forecasts; generation output levels; Interchange; known Protection System and Special Protection System status or degradation; Transmission outages; generator outages; Facility Ratings; and identified phase angle and equipment limitations. (Operational Planning Analysis may be provided through internal systems or through third-party services.)'' \16\ The proposed definition of real-time assessment is ``[a]n evaluation of system conditions using Real-time data to assess existing (pre-Contingency) and potential (post-Contingency) operating conditions. The assessment shall reflect applicable inputs including, but not limited to: Load, generation output levels, known Protection System and Special Protection System status or degradation, Transmission outages, generator outages, Interchange, Facility Ratings, and identified phase angle and equipment limitations. (Real-time Assessment may be provided through internal systems or through third-party services.)'' --------------------------------------------------------------------------- 37. The proposed NERC Glossary term ``Operating Instruction'' defines the scope of commands that are covered by the proposed TOP and IRO Reliability Standards. NERC explains that the revisions in the proposed definitions are intended to ensure that operational planning analyses and real-time assessments contain sufficient details to result in an appropriate level of situational awareness for next-day planning and real-time operations, respectively. Implementation Plan 38. NERC proposes that, for all standards except proposed Reliability Standards TOP-003-3 and IRO-010-2, the effective date will be the first day of the first calendar quarter twelve months after Commission approval. The twelve month implementation period for all of the standards except TOP-003-3 and IRO-010-2 is intended to allow time for entities to update processes and train operators on the revised requirements. All of the Requirements in proposed TOP-003-3 and IRO- 010-2 except TOP-003-3, Requirements R5 and IRO-010-2, Requirement R3 would become effective three months earlier, in order to provide recipients of data requests from their reliability coordinators, transmission operators, and/or balancing authorities time to respond to the requests for data. 39. According to NERC's implementation plan, for proposed TOP-003- 3, all requirements except Requirement R5 will become effective on the first day of the first calendar quarter nine months after the date that the standard is approved. For proposed IRO-010-2, Requirements R1 and R2 would become effective on the first day of the first calendar quarter that is nine months after the date that the standard is approved. Requirement R3 would become effective on the first day of the first calendar quarter twelve months after the date that the standard is approved. NERC states that the reason for the difference in effective dates for proposed TOP-003-3 and IRO-010-2 is to allow applicable entities to have time to properly respond to the data specification requests. II. Discussion 40. Pursuant to section 215(d) of the FPA, we propose to approve NERC's proposed revisions to the TOP and IRO Reliability Standards as just, reasonable, not unduly discriminatory or preferential, and in the public interest. We believe that NERC's approach of consolidating requirements and removing redundancies generally has merit and is consistent with Commission policy promoting increased efficiencies in Reliability Standards and reducing requirements that are either redundant with other currently effective requirements or have little reliability benefit.\17\ --------------------------------------------------------------------------- \17\ Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards, Order No. 788, 145 FERC ] 61,147 (2013). --------------------------------------------------------------------------- 41. We agree with NERC that the proposed TOP and IRO Reliability Standards would improve reliability by defining an appropriate division of responsibilities between reliability coordinators and transmission operators.\18\ Specifically, NERC states that the proposed TOP Reliability Standards will be improved by eliminating multiple TOP standards, resulting in a more concise set of standards. Thus, we believe that NERC's TOP proposal would reduce redundancy and more clearly delineate responsibilities between applicable entities. In addition, we believe that the proposed Reliability Standards provide a comprehensive framework as well as important improvements to ensure that the bulk electric system is operated within pre-established limits while enhancing situational awareness and strengthening operations planning. We believe that the proposed TOP and IRO Reliability Standards address the coordinated efforts to plan and reliably operate the bulk electric system under both normal and abnormal conditions. --------------------------------------------------------------------------- \18\ See, e.g., Order No. 748, 134 FERC ] 61,213, at PP 39-40. --------------------------------------------------------------------------- 42. For these reasons, we propose to approve NERC's revisions to the TOP and IRO Reliability Standards. We also discuss below: (A) Concerns raised in the Remand NOPR plus possible inconsistencies of identifying IROLs; (B) other reliability issues including (1) monitoring of non-bulk electric system facilities; (2) removal of the load-serving entity function from proposed Reliability Standard TOP- 001-3; and (3) data exchange capabilities. A. Remand NOPR Issues 1. Operational Responsibilities and Actions of SOLs and IROLs 43. We propose to find that NERC has adequately addressed the concerns raised by the Commission in the Remand NOPR with respect to the treatment of SOLs in the proposed TOP Reliability Standards. In the Remand NOPR, the Commission expressed concern that the proposed TOP standards did not have a requirement ``for transmission operators to plan and operate within all SOLs. Without a requirement to plan and operate within all SOLs in the proposed standards and by limiting non- IROL SOLs to only those identified by the transmission operator internal to its area, system reliability is reduced and negative consequences can occur outside of the transmission operator's internal area.'' \19\ The Commission noted that ``non-IROL SOLs that appear to be excluded from the proposed standard are non-IROL SOLs that are in a transmission operator's area that impact another transmission operator's area or more than one transmission operator's area.'' \20\ --------------------------------------------------------------------------- \19\ Remand NOPR, 145 FERC ] 61,158 at P 42. \20\ Id. P 51. --------------------------------------------------------------------------- 44. The Commission believes that the proposed TOP Reliability Standards address the Commission's Remand [[Page 36286]] NOPR concerns by requiring transmission operators to plan and operate within all SOLs, and to monitor and assess SOL conditions within and outside a transmission operator's area. Specifically, proposed Reliability Standard TOP-001-3, Requirement R14 requires each transmission operator to initiate its operating plan to mitigate a SOL exceedance identified as part of its real-time monitoring or real-time assessment. Proposed Reliability Standard TOP-001-3, Requirement R10 requires each transmission operator to monitor facilities within its transmission operator area as well as certain facilities outside of its transmission operator area to determine SOL exceedances within its transmission operator area during the real-time operations time horizon. In addition, proposed Reliability Standard TOP-001-3, Requirement R15 requires that each transmission operator inform its reliability coordinator of actions taken to resolve a SOL exceedance.\21\ To address the concerns of operational planning, proposed Reliability Standard TOP-002-4, Requirement R1 requires each transmission operator to have an operational planning analysis to assess whether its next-day planned operations will exceed any of its SOLs within its area, and Requirement R2 requires the transmission operator to have a next-day operating plan(s) to address any potential SOLs exceedances identified in its operational planning analysis.\22\ --------------------------------------------------------------------------- \21\ NERC Petition at 24-25. \22\ NERC Petition at 27. --------------------------------------------------------------------------- 45. Further, proposed Reliability Standard IRO-008-2, Requirements R1, R2, R3, R5, and R6 require reliability coordinators to plan and operate within SOLs and IROLs, which we believe work in tandem with the proposed TOP Standards and address the Commission's concern that the previously-proposed Reliability Standards limited ``non-IROL SOLs'' to only those internally identified by the transmission operator. Specific to operational planning, proposed Reliability Standard IRO-008-2, Requirement R1 requires the reliability coordinator to have an operational planning analysis to assess whether its next-day planned operations will exceed SOLs and IROLs within its wide area, and Requirement R2 requires the reliability coordinator to have a coordinated next-day operating plan(s) to address potential SOLs and IROLs exceedances identified in its operational planning analysis while considering the next-day operating plan(s) provided by its transmission operators and balancing authorities.\23\ Requirement R3 requires the reliability coordinator to notify impacted entities identified in its operating plan cited in Requirement R2 as to their role in such plan(s). The Commission believes that the consideration of the transmission operators' and balancing authorities' operating plans by the reliability coordinator in its own operating plan provides the necessary situational awareness of all SOLs, internal and external to the transmission operator or balancing authority. --------------------------------------------------------------------------- \23\ NERC Petition at 52. --------------------------------------------------------------------------- 46. In the Remand NOPR, the Commission raised the concern that the then-proposed version of the TOP/IRO Standards did not consider the possibility that additional SOLs could develop or occur in the same-day or real-time operational time horizon, and therefore would pose an operational risk to the interconnected transmission network.\24\ To address this concern, Reliability Standard IRO-008-2, Requirement R5 requires each reliability coordinator to notify impacted transmission operators and balancing authorities within its reliability coordinator area and other impacted reliability coordinators when results of a real-time assessment indicate actual or expected conditions that could result in SOL or IROL exceedances, and Requirement R6 requires reliability coordinator notification to impacted transmission operators, balancing authorities and other impacted reliability coordinators when any SOLs or IROLs have been prevented or mitigated.\25\ --------------------------------------------------------------------------- \24\ Remand NOPR, 145 FERC ] 61,158 at P 55. \25\ NERC Petition at 32. --------------------------------------------------------------------------- 47. Likewise, based on NERC's explanation, we believe that the proposed Reliability Standards in the immediate proceeding are designed to improve system performance by giving reliability coordinators the authority to direct actions to prevent or mitigate instances of exceeding IROLs. This delineation of responsibilities between reliability coordinators and transmission operators is appropriate because the primary decision-making authority for mitigating IROL exceedances is assigned to reliability coordinators while transmission operators have the primary responsibility for mitigating SOL exceedances.\26\ To further support the reliability coordinator's primary responsibility for IROLs to prevent instability, uncontrolled separation, or cascading, proposed Reliability Standard TOP-001-3, Requirement R12 requires that a transmission operator must not operate outside of any identified IROLs for a continuous duration exceeding its associated IROL Tv .\27\ --------------------------------------------------------------------------- \26\ See Remand NOPR, 145 FERC ] 61,158 at P 85. Further, currently-effective Reliability Standard IRO-009-1, Requirement R4 states that ``[w]hen actual system conditions show that there is an instance of exceeding an IROL in its Reliability Coordinator Area, the Reliability Coordinator shall, without delay, act or direct others to act to mitigate the magnitude and duration of the instance of exceeding that IROL within the IROL's Tv .'' \27\ NERC Petition at 25. --------------------------------------------------------------------------- 48. In addition, NERC explains that the proposed Reliability Standard IRO-014-3 contains requirements for coordination of interconnection operations at the reliability coordinator level and ensures that each reliability coordinator's operations are coordinated such that they will not adversely affect other reliability coordinators' areas.\28\ Proposed Reliability Standard IRO-014-3 requires the reliability coordinator to have and implement operating procedures, processes, or plans for activities that require notification or coordination of actions that may affect adjacent reliability coordinators' areas. --------------------------------------------------------------------------- \28\ NERC Petition at 33. --------------------------------------------------------------------------- 49. Furthermore, the Commission believes the revised definitions of operational planning analysis and real-time assessment are critical components of the proposed TOP and IRO Reliability Standards and, together with the definitions of SOLs, IROLs and operating plans, work to ensure that reliability coordinators, transmission operators and balancing authorities plan and operate the bulk electric system within all SOLs and IROLs to prevent instability, uncontrolled separation, or cascading. In addition, the revised definitions of operational planning analysis and real-time assessment address other concerns raised in the Remand NOPR as well as multiple recommendations in the 2011 Southwest Outage Blackout Report.\29\ For example, the definition of operational planning analysis is used in proposed Reliability Standards TOP-002-4, TOP-003-3, IRO-002-4, IRO-008-2, IRO-010-2, and IRO-014-3 to ensure a consistent approach to operations planning for the reliability coordinators, transmission operators and balancing authorities.\30\ Further, the proposed revised operational planning analysis definition adds additional detail and clarity, including the evaluation of pre- and post-contingency conditions as well as the evaluation of multiple applicable inputs that are [[Page 36287]] absent in the currently-effective definition. --------------------------------------------------------------------------- \29\ NERC Petition at 17-18. \30\ NERC Petition at 19. --------------------------------------------------------------------------- 50. Likewise, the definition of real-time assessment is used in the following proposed Reliability Standards: TOP-001-3; TOP-003-3; IRO- 002-4; IRO-008-2; IRO-010-2; and IRO-014-3 to ensure a consistent approach to the real-time operation of the Bulk Power System for the reliability coordinators, transmission operators and balancing authorities.\31\ The proposed revised real-time assessment definition is the same type of evaluation as the operational planning analysis with the exception that real-time assessment uses real-time data to assess existing conditions and operational planning analysis uses projected system conditions to assess anticipated system conditions. --------------------------------------------------------------------------- \31\ NERC Petition at 18. --------------------------------------------------------------------------- 51. The Commission does note, however, that in Exhibit E (SOL White Paper) of NERC's petition, NERC states that with regard to the SOL concept, the SOL White Paper brings ``clarity and consistency to the notion of establishing SOLs, exceeding SOLs, and implementing Operating Plans to mitigate SOL exceedances.'' \32\ The Commission further notes that IROLs, as defined by NERC, are a subset of SOLs that, if violated, could lead to instability, uncontrolled separation, or cascading outages that adversely impact the reliability of the bulk electric system.\33\ The Commission agrees with NERC that clarity and consistency are important with respect to establishing and implementing operating plans to mitigate SOL and IROL exceedances. However, the Commission notes that in its 2015 State of Reliability report, NERC states that the Western Interconnection reliability coordinator definition of an IROL has additional criteria that may not exist in other reliability coordinator areas.\34\ Based on this information, it is unclear whether NERC regions apply a consistent approach to identifying IROLs. Accordingly, the Commission seeks comment on (1) identification of all regional differences or variances in the formulation of IROLs, (2) the potential reliability impacts of such differences or variations, and (3) the value of providing a uniform approach or methodology to defining and identifying IROLs. --------------------------------------------------------------------------- \32\ NERC Petition, Exhibit E, ``White Paper on System Operating Limit Definition and Exceedance Clarification'' at 1. \33\ NERC Glossary of Terms defines Interconnection Reliability Operating Limit as ``[a] System Operating Limit that, if violated, could lead to instability, uncontrolled separation, or Cascading outages that adversely impact the reliability of the Bulk Electric System.'' \34\ NERC 2015 State of Reliability report at 44, available at www.nerc.com. See also WECC Reliability Coordination System Operating Limits Methodology for the Operations Horizon, Rev. 7.0 (effective March 3, 2014) at 18 (stating that ``SOLs qualify as IROLs when . . . studies indicate that instability, Cascading, or uncontrolled separation may occur resulting in uncontrolled interruption of load equal to or greater than 1000 MW''), available at https://www.wecc.biz/Reliability/PhaseII%20WECC%20RC%20SOL%20Methodology%20FINAL.pdf. --------------------------------------------------------------------------- 2. Outage Coordination 52. We believe, too, that NERC has addressed the concerns raised in the Remand NOPR with respect to the IRO standards regarding planned outage coordination. In the Remand NOPR, the Commission expressed concern with NERC's proposal because Reliability Standards IRO-008-1, Requirement R3 and IRO-010-1a (subjects of the proposed remand and now withdrawn by NERC) did not require the coordination of outages, noting that outage coordination is a critical reliability function that should be performed by the reliability coordinator.\35\ --------------------------------------------------------------------------- \35\ Remand NOPR, 145 FERC ] 61,158 at P 90. --------------------------------------------------------------------------- 53. With respect to proposed Reliability Standard IRO-017-1, submitted by NERC for approval in the immediate proceeding, Requirement R1 requires each reliability coordinator to develop, implement and maintain an outage coordination process for generation and transmission outages within its reliability coordinator area. Under Requirement R2, each transmission operator and balancing authority, in turn, would perform the functions specified in its reliability coordinator's outage coordination process. Further, Requirement R3 requires each planning coordinator and transmission planner to provide its planning assessment to the relevant reliability coordinators and to work together to solve any issues or conflicts with planned outages among the applicable entities under Requirement R4. Additionally, proposed Reliability Standard IRO-014-3, Requirement R1, Part 1.4 requires reliability coordinators to include the exchange of planned and unplanned outage information to support operational planning analyses and real-time assessments in the operating procedures, processes, and plans for activities that require coordination with adjacent reliability coordinators. Further, the proposed revised definitions of operational planning analysis and real-time assessments require that these evaluations of system conditions include transmission and generation outages. We believe that these proposed standards and revised definitions adequately address our concerns with respect to outage coordination as outlined in the Remand NOPR. B. Other Reliability Issues 54. While proposing to approve the TOP and IRO Reliability Standards, the Commission seeks clarifying comments addressing three additional issues: (1) Monitoring of non-bulk electric system facilities; (2) removal of the load-serving entity as an applicable entity for proposed Reliability Standard TOP-001-3; and (3) data exchange capabilities. Based on comments and information received on these issues, the Commission may issue directives as appropriate. 1. Monitoring of Non-Bulk Electric System Facilities NERC Petition 55. NERC explains how the proposed Reliability Standards address the recommendations in the 2011 Southwest Outage Blackout Report, in particular with respect to Finding 17 concerning the impact of sub-100 kV facilities on the reliability of the interconnected transmission network. Finding 17 states: WECC RC and affected TOPs and BAs do not consistently recognize the adverse impact sub-100 kV facilities can have on BPS reliability. As a result, sub-100 kV facilities might not be designated as part of the BES, which can leave entities unable to address the reliability impact they can have in the planning and operations time horizons. If, prior to September 8, 2011, certain sub-100 kV facilities had been designated as part of the BES and, as a result, were incorporated into the TOPs' and RC's planning and operations studies, or otherwise had been incorporated into these studies, cascading outages may have been avoided on the day of the event. Recommendation 17 states: WECC, as the RE, should lead other entities, including TOPs and BAs, to ensure that all facilities that can adversely impact BPS reliability are either designated as part of the BES or otherwise incorporated into planning and operations studies and actively monitored and alarmed in [real-time contingency analysis] systems. NERC states that proposed Reliability Standard IRO-002-4, Requirement R3 addresses monitoring of non-bulk electric system facilities by requiring each reliability coordinator to monitor facilities and necessary non-bulk electric system facilities in order to identify SOL and IROL exceedances within its reliability coordinator area.\36\ In addition, NERC states that proposed Reliability Standards IRO-010-2, [[Page 36288]] Requirement R1.1 and TOP-003-3, Requirement R1.1 address non-bulk electric system data by specifically requiring reliability coordinators and transmission operators to incorporate any non-bulk-electric system data as deemed necessary into their operational planning analyses, real-time monitoring, and real-time assessments.\37\ --------------------------------------------------------------------------- \36\ NERC Petition at 61. \37\ Id. at 40. --------------------------------------------------------------------------- 56. However, NERC explains that the standard drafting team concluded it is unnecessary to include non-bulk electric system monitoring in proposed Reliability Standard TOP-001-3, Requirement R10 for the transmission operator, in a similar fashion as proposed Reliability Standard IRO-002-4, Requirement R3 for the reliability coordinator. Instead, the standard drafting team determined that any non-bulk electric system facility elements that are necessary for reliable operation of the bulk electric system would be included in the bulk electric system through the exception process provided in Appendix 5C to the NERC Rules of Procedure. NERC states that the exception process provides the means for transmission operators and reliability coordinators to include elements in the bulk electric system that are necessary for the reliable operation of the interconnected transmission system but not identified in the bulk electric system definition.\38\ --------------------------------------------------------------------------- \38\ Id. at 47-48. --------------------------------------------------------------------------- Commission Proposal 57. We propose to find that NERC has adequately addressed the 2011 Southwest Outage Blackout Report recommendation in connection with sub- 100 kV facilities for proposed Reliability Standards IRO-002-4, Requirement R3, IRO-010-2, Requirement R1.1 and TOP-003-3, Requirement R1.1. In doing so, we rely primarily on the proposed responsibility of the reliability coordinator to monitor such facilities to the extent necessary. 58. However, the transmission operator may have a more granular perspective than the reliability coordinator of its necessary non-bulk electric system facilities to monitor in order to identify SOL and IROL exceedances, and it is not clear whether or how the transmission operator would communicate any insight it may have to the reliability coordinator to ensure monitoring of all necessary facilities. Thus, the Commission seeks comment on how NERC will ensure that the reliability coordinator will receive information from the transmission operator regarding which non-bulk electric system facilities should be monitored. Further, as stated above, Recommendation 17 states ``. . . to ensure that all facilities that can adversely impact BPS reliability are either designated as part of the BES or otherwise incorporated into planning and operations studies and actively monitored and alarmed in [real-time contingency analysis] systems.'' (emphasis added.) Including such non-bulk electric system facilities in the definition of bulk electric system through the Rules of Procedure exception process could be an option to address any potential gaps for monitoring facilities. However, there may be potential efficiencies gained by using a more expedited method to include non-bulk electric system that requires monitoring. Thus, the Commission seeks comments on whether the exception process should be used exclusively in all cases. 59. Alternatively, we seek comment regarding whether this concern should be addressed through a review process of the transmission operators' systems to determine if there are important non-bulk- electric system facilities that require monitoring. For example, Commission staff could work with NERC, Regional Entities and applicable entities to review their system modeling and perform an analysis to identify non-bulk electric system facilities that need monitoring. Accordingly, we seek comment from NERC and other interested persons on these alternatives. 2. Removal of Load-Serving Entity Function From TOP-001-3 NERC Petition 60. Proposed Reliability Standard TOP-001-3, Requirement R3 requires that each balancing authority, generator operator and distribution provider shall comply with each operating instruction issued by its transmission operator, and proposed Reliability Standard TOP-001-3, Requirement R4 requires that each balancing authority, generator operator and distribution provider inform its transmission operator of its inability to comply with an operating instruction. Proposed Reliability Standard TOP-001-3, Requirement R5 requires that each transmission operator, generator operator and distribution provider shall comply with each operating instruction issued by its balancing authority, and proposed Reliability Standard TOP-001-3, Requirement R6 requires that each transmission operator, generator operator and distribution provider inform its balancing authority of its inability to comply with an operating instruction.\39\ --------------------------------------------------------------------------- \39\ NERC Petition at 22-23. --------------------------------------------------------------------------- 61. In its petition, NERC states that, during the standard drafting process, the load-serving entity function was removed from proposed Reliability Standard TOP-001-3, Requirements R3 through R6. NERC explains that the removal of the load-serving entity as an applicable entity was based on the November 2014 NERC Board of Trustees action to remove load-serving entity as a functional entity from NERC's Rules of Procedure.\40\ Since that time, the Commission has issued an order in Docket No. RR15-4-000 that denied, without prejudice, NERC's proposal to remove the load-serving entity as a functional entity under NERC's Risk Based Registration petition and directed NERC to submit a compliance filing to address this issue.\41\ --------------------------------------------------------------------------- \40\ NERC Petition, Exhibit K, Consideration of Comments January 7, 2015, at 2. \41\ North American Electric Reliability Corp., 150 FERC ] 61,213 (2015). --------------------------------------------------------------------------- 62. On May 12, 2015, NERC supplemented its initial petition with additional explanation for the removal of the load-serving entity function from proposed Reliability Standard TOP-001-3. NERC explains that the proposed standard gives transmission operators and balancing authorities the authority to direct the actions of certain other functional entities by issuing an operating instruction to maintain reliability during real-time operations. According to NERC, load- serving entities are not included in the list of entities that must comply with a transmission operator's or balancing authority's operating instructions. NERC contends that the exclusion is justified because none of the functions performed by load-serving entities, as described in the NERC Functional Model, necessitate that load-serving entities be subject to a requirement to comply with such operating instructions to ensure that a transmission operator or balancing authority can maintain reliability.\42\ NERC adds that a load-serving entity does not own or operate bulk electric system facilities or equipment or the facilities or equipment used to serve end-use customers and its NERC Functional Model tasks are limited in scope. As indicated by the NERC Functional Model, the load-serving entity does not play a role in shedding load in real-time. --------------------------------------------------------------------------- \42\ NERC Supplemental Filing at 6. --------------------------------------------------------------------------- 63. NERC also explains in its supplemental filing that the standard drafting team did not identify any circumstances under which a [[Page 36289]] transmission operator or balancing authority would need to issue an operating instruction to a load-serving entity to prevent instability, uncontrolled separation, or cascading outages. NERC contends that, with respect to the load-serving entity's role as a provider of information to other functional entities, that role is primarily carried out ahead of real-time and would not be the subject of an operating instruction. Additionally, NERC states that the load-serving entity's real-time role with respect to voluntary load curtailment does not necessitate requiring load-serving entities to comply with operating instructions issued by a transmission operator or balancing authority. In order to maintain reliability in their areas and prevent instability, uncontrolled separation, or cascading outages, there may be circumstances under which transmission operators and balancing authorities need to shed load. NERC states that such action is implemented in real-time to address imminent or existing reliability issues such as an exceedance of an IROL or SOL, or a voltage problem. According to NERC, due to the urgent nature of these circumstances, the reliability coordinator, balancing authority, or transmission operator may issue operating instructions directly to the distribution provider for physical implementation of load shedding (except when this can be accomplished directly by the transmission operator).\43\ --------------------------------------------------------------------------- \43\ NERC Supplemental Filing at 9. --------------------------------------------------------------------------- Commission Proposal 64. NERC proposes the removal of the load-serving entity function from proposed Reliability Standard, TOP-001-3, Requirements R3 through R6, as a recipient of an operating instruction from a transmission operator or balancing authority. However, the Commission notes that the issuance and compliance of operating instructions under proposed Reliability Standard TOP-001-3 is not limited to the real-time operations time horizon only.\44\ --------------------------------------------------------------------------- \44\ NERC TOP/IRO Petition, Exhibit A includes the following time horizons for proposed Reliability Standard TOP-001-3, Requirements R3 through R6: ``[Time Horizon: Same-Day Operations, Real-Time Operations].'' --------------------------------------------------------------------------- 65. Further, if a transmission operator or balancing authority would issue an operating instruction to a load-serving entity such as to carry out interruptible load curtailments, it is not clear what entity would respond to this operating instruction if the load-serving entity is removed from proposed TOP-001-3, Requirements R3 through R6.\45\ --------------------------------------------------------------------------- \45\ NERC Glossary of Terms defines Interruptible Load as the ``[d]emand that the end-use customer makes available to its Load- Serving Entity via contract or agreement for curtailment.'' --------------------------------------------------------------------------- 66. The Commission notes that NERC is required to make a compliance filing in July 2015 in Docket No. RR15-4-000. The Commission's decision on that filing will guide any action in this proceeding. 3. Data Exchange Capabilities NERC Petition 67. In Order No. 808, the Commission approved Reliability Standards COM-001-2 (Communications) and COM-002-4 (Operating Personnel Communications Protocols).\46\ In Order No. 808, the Commission explained that it had raised concerns in the underlying NOPR proposing to approve these COM Reliability Standards (COM NOPR) whether COM-001-2 addresses ``facilities that directly exchange or transfer data.'' \47\ In response to the COM NOPR, NERC and other commenters clarified that Reliability Standard COM-001-2, which covers communications capability requirements, is not intended to address data exchanges or transfers.\48\ As the Commission noted in Order No. 808, NERC maintained that Reliability Standard COM-001-2 need not include requirements regarding data exchange capability, ``because such capability is covered under other existing or proposed standards.'' \49\ The Commission did not make any determinations regarding facilities used for data exchange capability in Order No. 808 and, based on NERC's explanation in its supplemental filing, the Commission stated that it would address these issues in this TOP and IRO rulemaking proceeding.\50\ --------------------------------------------------------------------------- \46\ Communications Reliability Standards, Order No. 808, 151 FERC ] 61,039 (2015). \47\ Order No. 808, 151 FERC ] 61,039 at P 54, quoting Communications Reliability Standards, Notice of Proposed Rulemaking, 148 FERC ] 61,210, at P 33 (2014). \48\ Id. P 48. \49\ Id. See also NERC's Supplemental Comments in Response to Notice of Proposed Rulemaking, Communications Reliability Standards, Docket No. RM14-13-000 at 3. \50\ Order No. 808, 151 FERC ] 61,039 at P 54. --------------------------------------------------------------------------- 68. In general, it appears that facilities for data exchange capabilities are addressed in NERC's proposal. For example, proposed Reliability Standard TOP-001-3, Requirements R19 and R20 require some form of ``data exchange capabilities'' for the transmission operator and balancing authority, respectively. Similarly, proposed Reliability Standard IRO-002-4, Requirement R1 requires some form of ``data exchange capabilities'' for the reliability coordinator. However, we seek additional explanation from NERC regarding how it addresses data exchange capabilities in the TOP and IRO Reliability Standards in the following areas: (a) Redundancy and diverse routing; and (b) testing of the alternate or less frequently used data exchange capability. (i) Redundancy and Diverse Routing of Data Exchange Capabilities Background 69. The terms ``redundant'' and ``diverse routing'' of data exchange capabilities appear in Reliability Standard COM-001-1, where the reliability coordinator, transmission operator and balancing authority are required to have telecommunication facilities that are ``redundant'' and ``diversely routed'' to maintain Bulk-Power System reliability.\51\ NERC added two definitions (Interpersonal Communication and Alternative Interpersonal Communication) to Reliability Standard COM-001-2 that addressed redundant and diverse routing of communications between persons and proposed to eliminate the need to use phrases such as ``redundant and diversely routed'' that it described as ambiguous.\52\ With respect to the data exchange capabilities, NERC stated that several proposed or existing standards ``provided the necessary mandatory Requirements to ensure proper data exchange is occurring.'' \53\ NERC also asserted that four proposed IRO and TOP standards ``include specific coverage related to data exchange,'' and ``collectively require data exchange capability'' for reliability coordinators, transmission operators, balancing authorities, generator operators, and distribution providers.\54\ --------------------------------------------------------------------------- \51\ COM-001-1.1 Standard, Requirement R1 requires that ``[e]ach Reliability Coordinator, Transmission Operator and Balancing Authority shall provide adequate and reliable telecommunications facilities for the exchange of Interconnection and operating information:'' and R1.4 requires that ``[w]here applicable, these facilities shall be redundant and diversely routed.'' \52\ NERC COM Petition at 16. \53\ NERC COM Petition at 16. \54\ NERC Supp. COM Comments at 3. NERC identified these same four standards in its Initial Comments, but provides a more detailed discussion of the proposed standards and their status in its Supplemental Comments. --------------------------------------------------------------------------- 70. In Order No. 808, the Commission approved NERC's definition of the terms Interpersonal Communication and Alternative Interpersonal Communication. NERC defines Interpersonal Communication as ``[a]ny medium that allows two or more individuals to interact, consult, or [[Page 36290]] exchange information.'' NERC defines Alternative Interpersonal Communication as ``[a]ny Interpersonal Communication that is able to serve as a substitute for, and does not utilize the same infrastructure (medium) as, Interpersonal Communication used for day-to-day operation.'' \55\ Reliability Standard COM-001-2, Requirements R1 through R6 require that reliability coordinators, transmission operators, and balancing authorities have Interpersonal Communication capabilities and Alternative Interpersonal Communication capabilities in place with other defined entities (e.g., other interconnected transmission operators). In its COM Petition, NERC maintained that the defined terms make clear that an entity's communication capability must be redundant and that each of the capabilities must not utilize the same medium, while eliminating the need to use ambiguous phrases such as ``redundant and diversely routed'' (as used in the prior version of the standard governing communications capability).\56\ --------------------------------------------------------------------------- \55\ Order No. 808, 151 FERC ] 61,039, at P 45 n.54. \56\ May 14, 2014, NERC COM Petition, Docket No. RM14-13-000 at 15-16. --------------------------------------------------------------------------- 71. As noted above, NERC indicated in its response to the COM NOPR that Reliability Standard COM-001-2 need not include requirements regarding data exchange capability because such capability is or would be covered by other existing or proposed standards. Specifically, NERC explained that data exchange is addressed by the currently enforceable Reliability Standards IRO-010-1a and IRO-014-1. In addition, NERC stated that data exchange transfer capabilities are directly addressed in proposed Reliability Standard TOP-001-3, as well as in proposed Reliability Standard IRO-002-4, Requirement R1. NERC also stated that the data itself is covered in proposed Reliability Standard IRO-010-2 and proposed Reliability Standard TOP-003-3.\57\ --------------------------------------------------------------------------- \57\ NERC COM Supplemental Comments at 3. --------------------------------------------------------------------------- NERC Petition 72. In the petition in this proceeding, NERC states that in proposed Reliability Standard TOP-001-3, ``Requirements R19 and R20 provide that each Transmission Operator (Requirement R19) and Balancing Authority (Requirement R20) must have data exchange capabilities with the entities from which it needs data in order to maintain reliability in its area.'' \58\ NERC states that Requirements R19 and R20 are consistent with proposed Reliability Standard IRO-002-4, Requirement R1, which provides that each reliability coordinator must have data exchange capabilities with its balancing authorities, transmission operators, and other entities it deems necessary. Requirements R19 and R20 state: --------------------------------------------------------------------------- \58\ NERC Petition at 26. R19. Each Transmission Operator shall have data exchange capabilities with the entities that it has identified that it needs data from in order to maintain reliability in its Transmission Operator Area. R20. Each Balancing Authority shall have data exchange capabilities with the entities that it has identified that it needs data from in order to maintain reliability in its Balancing Authority Area. Reliability Standard IRO-002-4 Requirement R1 states: R1. Each Reliability Coordinator shall have data exchange capabilities with its Balancing Authorities and Transmission Operators, and with other entities it deems necessary, for it to perform its Operational Planning Analyses, Real-time monitoring, and Real-time Assessments. In addition, NERC states that IRO-002-4, Requirement R4 requires ``each Reliability Coordinator must have monitoring systems . . . over a redundant infrastructure.'' \59\ --------------------------------------------------------------------------- \59\ Id. at 31. --------------------------------------------------------------------------- Commission Proposal 73. The Commission agrees that proposed Reliability Standard TOP- 001-3, Requirements R19 and R20 require some form of ``data exchange capabilities'' for the transmission operator and balancing authority, respectively, and that proposed Reliability Standard TOP-003-3 addresses the operational data itself needed by the transmission operator and balancing authority. In addition, the Commission agrees that Reliability Standard IRO-002-4, Requirement R1 requires ``data exchange capabilities'' for the reliability coordinator and that proposed Reliability Standard IRO-010-2 addresses the operational data needed by the reliability coordinator. Further, the Commission agrees that proposed Reliability Standard IRO-002-4 Requirement R4 requires a redundant infrastructure for system monitoring. However, it is not clear whether redundancy and diverse routing of data exchange capabilities (or an equally effective alternative that eliminates the ambiguity of ``redundancy'' and ``diversely routed'') are adequately addressed in proposed Reliability Standards TOP-001-3 and IRO-002-4 for the reliability coordinator, transmission operator, and balancing authority. 74. Unlike the approach taken with COM-001-2, which requires redundancy and use of a diverse medium through the definitions of Interpersonal Communication and Alternative Interpersonal Communication, proposed Reliability Standards TOP-001-3 and IRO-002-4 do not appear to address redundancy and diverse routing of data exchange capabilities. While Reliability Standard IRO-002-4, Requirement R4 requires reliability coordinators to have a redundant infrastructure for system monitoring, it is not clear whether this requirement addresses redundancy and diverse routing of other forms of data exchange capabilities. For example, a redundant infrastructure used for system monitoring could be a subset of the total data exchange capabilities used by reliability coordinators and not include redundant infrastructure for capabilities such as control of equipment or real- time assessments. The Commission seeks explanation or clarification from NERC whether and how the proposed Reliability Standards in the immediate proceeding address redundancy and diverse routing or an equally effective alternative to redundancy and diverse routing. Further, if NERC or others believe that redundancy and diverse routing are not addressed, we seek comment on whether there are associated reliability risks of the interconnected transmission network for any failure of data exchange capabilities that are not redundant and diversely routed. (ii) Testing of the Alternate or Less Frequently Used Data Exchange Capability NERC Petition 75. Reliability Standard COM-001-2, Requirement R9 (approved in Order No. 808) requires each reliability coordinator, transmission operator and balancing authority to test its Alternative Interpersonal Communication capability at least once each calendar month and to initiate action to repair or designate a replacement Alternative Interpersonal Communication capability.\60\ --------------------------------------------------------------------------- \60\ Reliability Standard COM-001-2, Requirement R9 states: ``[e]ach Reliability Coordinator, Transmission Operator, and Balancing Authority shall test its Alternative Interpersonal Communication capability at least once each calendar month. If the test is unsuccessful, the responsible entity shall initiate action to repair or designate a replacement Alternative Interpersonal Communication capability within 2 hours.'' --------------------------------------------------------------------------- 76. As noted above, proposed Reliability Standards TOP-001-3, Requirements R19 and R20 and IRO-002-4, Requirement R1 address primary [[Page 36291]] data exchange capabilities of the transmission operator, balancing authority and reliability coordinator, respectively. However, the proposed TOP and IRO Reliability Standards do not appear to address testing requirements of alternative or less frequently used data exchange capabilities. Commission Proposal 77. The Commission is concerned that the proposed TOP and IRO Reliability Standards do not appear to address testing requirements for alternative or less frequently used mediums for data exchange to ensure they would properly function in the event that the primary or more frequently used data exchange capabilities failed. The Commission seeks comment on whether and how the TOP and IRO Reliability Standards address the testing of alternative or less frequently used data exchange capabilities for the transmission operator, balancing authority and reliability coordinator. If NERC or others believe that testing requirements for alternative or less frequently used mediums for data exchange is not necessary, we seek comment on why it is not necessary. III. Information Collection Statement 78. The collection of information contained in this Notice of Proposed Rulemaking is subject to review by the Office of Management and Budget (OMB) regulations under section 3507(d) of the Paperwork Reduction Act of 1995 (PRA).\61\ OMB's regulations require approval of certain informational collection requirements imposed by agency rules.\62\ Upon approval of a collection(s) of information, OMB will assign an OMB control number and an expiration date. Respondents subject to the filing requirements of a rule will not be penalized for failing to respond to these collections of information unless the collections of information display a valid OMB control number. --------------------------------------------------------------------------- \61\ 44 U.S.C. 3507(d) (2012). \62\ 5 CFR 1320.11 (2014). --------------------------------------------------------------------------- 79. We solicit comments on the need for this information, whether the information will have practical utility, the accuracy of the burden estimates, ways to enhance the quality, utility, and clarity of the information to be collected or retained, and any suggested methods for minimizing respondents' burden, including the use of automated information techniques. Specifically, the Commission asks that any revised burden or cost estimates submitted by commenters be supported by sufficient detail to understand how the estimates are generated. Public Reporting Burden: The Commission proposes to approve revisions to the Transmission Operations and Interconnection Reliability Operations and Coordination Reliability Standards. These revisions will impose new or revised, or retire requirements for the balancing authority, transmission operator, generator operator, distribution provider, generator owner, load-serving entity, purchasing-selling entity, transmission service provider, interchange authority, transmission owner, reliability coordinator, planning coordinator, and transmission planner functions. The Commission based its paperwork burden estimates on the NERC compliance registry as of May 15, 2015. According to the registry, there are 11 reliability coordinators, 99 balancing authorities, 450 distribution providers, 839 generator operators, 80 purchasing-selling entities, 446 load-serving entities, 886 generator owners, 320 transmission owners, 24 interchange authorities, 75 transmission service providers, 68 planning coordinators, 175 transmission planners and 171 transmission operators. The estimates are based on the change in burden from the current standards to the proposed. Not all entity types would experience an increase in burden, which is reflected by absence of those entities from the chart below. Collectively, the proposed TOP and IRO Reliability Standards along with revised definitions provide for certain enhancements over the currently-effective TOP and IRO Reliability Standards.\63\ For example, the revised definitions of operational planning analysis and real-time assessment, which are applicable to multiple proposed TOP and IRO Reliability Standards, were enhanced and provide significant additional detail over the currently-effective definitions such as including inputs that were identified as contributing to past outages on the bulk electric system.\64\ As another example, the new proposed Reliability Standard IRO-017-1 establishes operational planning requirements for each reliability coordinator to implement an outage coordination process for its area that address a reliability gap identified in the Southwest Outage Blackout Report and in the Remand NOPR.\65\ The Commission estimates the annual reporting burden and cost as follows: --------------------------------------------------------------------------- \63\ NERC Petition at 10. \64\ NERC Petition at 14. \65\ NERC Petition at 17. RM15-16-000 (Transmission Operations Reliability Standards, Interconnection Reliability Operations and Coordination Reliability Standards) -------------------------------------------------------------------------------------------------------------------------------------------------------- Annual number of Total annual burden Number of responses Total number Average burden & cost hours & total annual Cost per respondent respondents \66\ per of responses per response \67\ cost ($) respondent (1).................. (2) (1) * (2) = (4).................. (3) * (4) = (5)..... (5) / (1) (3) -------------------------------------------------------------------------------------------------------------------------------------------------------- FERC-725A -------------------------------------------------------------------------------------------------------------------------------------------------------- TOP-001-3......................... 196 (TOP & BA)....... 1 196 96 hrs. $6,369....... 18,816 hrs., 96 hrs., $6,369. $1,248,441. TOP-002-4......................... 196 (TOP & BA)....... 1 196 284 hrs., $18,843.... 55,664 hrs., 284 hrs., $18,843. $3,693,306. TOP-003-3......................... 196 (TOP & BA)....... 1 196 230 hrs., $15,260.... 45,080 hrs., 230 hrs., $15,260. $2,991,058. ---------------------------- ---------------------- Sub-Total for FERC-725A....... ..................... ............ ............ ..................... 123,252 hrs., .................... $7,932,806. -------------------------------------------------------------------------------------------------------------------------------------------------------- FERC-725Z -------------------------------------------------------------------------------------------------------------------------------------------------------- IRO-001-4 \68\.................... 177 (RC & TOP)....... 1 177 0 hrs. $0............ 0 hrs. $0........... 0 hrs. $0. IRO-002-4......................... 11 (RC).............. 1 11 24 hrs., $1,592...... 264 hrs., $17,516... 24 hrs., $1,592. IRO-008-2......................... 11 (RC).............. 1 11 228 hrs., $15,127.... 2,508 hrs., $166,405 228 hrs., $15,127. IRO-010-2......................... 11 (RC).............. 1 11 36 hrs., $2,388...... 396 hrs., $26,274... 36 hrs., $2,388. IRO-014-3......................... 11 (RC).............. 1 11 12 hrs., $796........ 132 hrs., $8,758.... 12 hrs., $796. [[Page 36292]] IRO-017-1......................... 180 (RC, PC, & TP)... 1 180 218 hrs., $14,464.... 39,240 hrs., 218 hrs., $14,464. $2,603,574. ---------------------------- ---------------------- Sub-Total for FERC-725Z....... ..................... ............ ............ ..................... 42,540 hrs., .................... $2,822,529.00. -------------------------------------------------------------------------------------------------------------------------------------------------------- Retirement of current standards 457 (RC, TOP, BA, 1 457 -223 hrs., -$14,796.. -101,911 hrs., - -223 hrs., -$14,796. currently in FERC-725A. TSP, LSE, PSE, & IA). $6,761,794. ---------------------------- ---------------------- Net Total of NOPR in RM15-16.. ..................... ............ ............ ..................... 63,881 hrs, $3,993,540. -------------------------------------------------------------------------------------------------------------------------------------------------------- Title: FERC-725Z, Mandatory Reliability Standards: IRO Reliability Standards, and FERC-725A, Mandatory Reliability Standards for the Bulk- Power System --------------------------------------------------------------------------- \66\ The number of respondents is the number of entities for which a change in burden from the current standards to the proposed exists, not the total number of entities from the current or proposed standards that are applicable.\67\ The estimated hourly costs (salary plus benefits) are based on Bureau of Labor Statistics (BLS) information, as of April 1, 2015, for an electrical engineer ($66.35/hour). These figures are available at http://bls.gov/oes/current/naics3_221000.htm#17-0000.\68\ IRO-001-4 is a revised standard with no increase in burden. --------------------------------------------------------------------------- Action: Proposed Changes to Collections. OMB Control Nos: 1902-0276 (FERC-725Z); 1902-0244(FERC-725A) Respondents: Business or other for-profit and not-for-profit institutions. Frequency of Responses: On-going. 80. Necessity of the Information and Internal review: The Commission has reviewed the requirements pertaining to the proposed Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO- 002-4, IRO-008-2, IRO-010-2, IRO-014-3, and IRO-017-1 and made a determination that the proposed requirements of these standards are necessary to implement section 215 of the FPA. These requirements conform to the Commission's plan for efficient information collection, communication and management within the energy industry. The Commission has assured itself, by means of its internal review, that there is specific, objective support for the burden estimates associated with the information requirements. 81. Interested persons may obtain information on the reporting requirements by contacting the Federal Energy Regulatory Commission, Office of the Executive Director, 888 First Street NE., Washington, DC 20426 [Attention: Ellen Brown, email: [email protected], phone: (202) 502-8663, fax: (202) 273-0873]. 82. Comments concerning the information collections proposed in this NOPR and the associated burden estimates, should be sent to the Commission in this docket and may also be sent to the Office of Management and Budget, Office of Information and Regulatory Affairs [Attention: Desk Officer for the Federal Energy Regulatory Commission]. For security reasons, comments should be sent by email to OMB at the following email address: [email protected]. Please reference OMB Control Nos. 1902-0276 (FERC-725Z) and 1902-0244 (FERC-725A)) in your submission. IV. Environmental Analysis 83. The Commission is required to prepare an Environmental Assessment or an Environmental Impact Statement for any action that may have a significant adverse effect on the human environment.\69\ The Commission has categorically excluded certain actions from this requirement as not having a significant effect on the human environment. Included in the exclusion are rules that are clarifying, corrective, or procedural or that do not substantially change the effect of the regulations being amended.\70\ The actions approved herein fall within this categorical exclusion in the Commission's regulations. --------------------------------------------------------------------------- \69\ Regulations Implementing the National Environmental Policy Act of 1969, Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. Preambles 1986-1990 ] 30,783 (1987). \70\ 18 CFR 380.4(a)(2)(ii). --------------------------------------------------------------------------- V. Regulatory Flexibility Act Analysis 84. The Regulatory Flexibility Act of 1980 (RFA) generally requires a description and analysis of Proposed Rules that will have significant economic impact on a substantial number of small entities.\71\ The Small Business Administration's (SBA) Office of Size Standards develops the numerical definition of a small business.\72\ The SBA revised its size standard for electric utilities (effective January 22, 2014) to a standard based on the number of employees, including affiliates (from a standard based on megawatt hours).\73\ Proposed Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-002-4, IRO-008-2, IRO- 010-2, IRO-014-3, and IRO-017-1 are expected to impose an additional burden on 196 entities (reliability coordinators, transmission operators, balancing authorities, transmission service providers, and planning authorities). Comparison of the applicable entities with the Commission's small business data indicates that approximately 82 of these entities are small entities that will be affected by the proposed Reliability Standards.\74\ As discussed above, proposed Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-002-4, IRO- 008-2, IRO-010-2, IRO-014-3, and IRO-017-1 will serve to enhance reliability by imposing mandatory requirements for operations planning, system monitoring, real-time actions, coordination between [[Page 36293]] applicable entities, and operational reliability data. The Commission estimates that each of the small entities to whom the proposed Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO- 002-4, IRO-008-2, IRO-010-2, IRO-014-3, and IRO-017-1 applies will incur costs of approximately $147,364 (annual ongoing) per entity. The Commission does not consider the estimated costs to have a significant economic impact on a substantial number of small entities. The Commission seeks comment on this proposal. --------------------------------------------------------------------------- \71\ 5 U.S.C. 601-12. \72\ 13 CFR 121.101 (2013). \73\ SBA Final Rule on ``Small Business Size Standards: Utilities,'' 78 FR 77343 (Dec. 23, 2013). \74\ The Small Business Administration sets the threshold for what constitutes a small business. Public utilities may fall under one of several different categories, each with a size threshold based on the company's number of employees, including affiliates, the parent company, and subsidiaries. For the analysis in this NOPR, we are using a 750 employee threshold for each affected entity to conduct a comprehensive analysis. --------------------------------------------------------------------------- VI. Comment Procedures 85. The Commission invites interested persons to submit comments on the matters and issues proposed in this notice to be adopted, including any related matters or alternative proposals that commenters may wish to discuss. Comments are due August 24, 2015. Comments must refer to Docket No. RM15-16-000, and must include the commenter's name, the organization they represent, if applicable, and their address in their comments. 86. The Commission encourages comments to be filed electronically via the eFiling link on the Commission's Web site at http://www.ferc.gov. The Commission accepts most standard word processing formats. Documents created electronically using word processing software should be filed in native applications or print-to-PDF format and not in a scanned format. Commenters filing electronically do not need to make a paper filing. 87. Commenters that are not able to file comments electronically must send an original of their comments to: Federal Energy Regulatory Commission, Secretary of the Commission, 888 First Street NE., Washington, DC 20426. 88. All comments will be placed in the Commission's public files and may be viewed, printed, or downloaded remotely as described in the Document Availability section below. Commenters on this proposal are not required to serve copies of their comments on other commenters. VII. Document Availability 89. In addition to publishing the full text of this document in the Federal Register, the Commission provides all interested persons an opportunity to view and/or print the contents of this document via the Internet through the Commission's Home Page (http://www.ferc.gov) and in the Commission's Public Reference Room during normal business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street NE., Room 2A, Washington, DC 20426. 90. From the Commission's Home Page on the Internet, this information is available on eLibrary. The full text of this document is available on eLibrary in PDF and Microsoft Word format for viewing, printing, and/or downloading. To access this document in eLibrary, type the docket number of this document, excluding the last three digits, in the docket number field. 91. User assistance is available for eLibrary and the Commission's Web site during normal business hours from the Commission's Online Support at 202-502-6652 (toll free at 1-866-208-3676) or email at [email protected], or the Public Reference Room at (202) 502- 8371, TTY (202) 502-8659. Email the Public Reference Room at [email protected]. List of Subjects in 18 CFR Part 40 Reliability standards. By direction of the Commission. Dated: June 18, 2015. Kimberly D. Bose, Secretary. [FR Doc. 2015-15433 Filed 6-23-15; 8:45 am] BILLING CODE 6717-01-P
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DEPARTMENT OF ENERGY SUPPLEMENTARY INFORMATION: the Commission proposed to remand an
1. Pursuant to section 215 of the earlier version of proposed TOP and
Federal Energy Regulatory Federal Power Act (FPA),1 the IRO Standards due to concerns
Commission Commission proposes to approve regarding the proposed treatment of
revisions to the Transmission system operating limits (SOLs) and
18 CFR Part 40 Operations (TOP) and Interconnection interconnection reliability operating
[Docket No. RM15–16–000]
Reliability Operations and Coordination limits (IROLs) and concerns about
(IRO) Reliability Standards, developed outage coordination. Further, the
Transmission Operations Reliability by the North American Electric Commission proposes to approve the
Standards and Interconnection Reliability Corporation (NERC), the definitions for operational planning
Reliability Operations and Commission-certified Electric analysis and real-time assessment, and
Coordination Reliability Standards Reliability Organization (ERO). The the violation severity level and violation
Commission believes that the proposed risk factor assignments.
AGENCY: Federal Energy Regulatory TOP and IRO Reliability Standards 3. While proposing to approve the
Commission, DOE. improve on the currently-effective TOP and IRO Reliability Standards,
ACTION: Notice of proposed rulemaking. standards by providing a more precise below the Commission seeks clarifying
set of Reliability Standards addressing comments addressing four issues: (A)
SUMMARY: The Commission proposes to
operating responsibilities and Possible inconsistencies in identifying
approve revisions to the Transmission
improving the delineation of IROLs; (B) monitoring of non-bulk
Operations and Interconnection
responsibilities between applicable electric system facilities; (C) removal of
Reliability Operations and Coordination
entities. The Commission also believes the load-serving entity as an applicable
Reliability Standards, developed by the
that the revised TOP Reliability entity for proposed Reliability Standard
North American Electric Reliability
Standards eliminate gaps and TOP–001–3; and (D) data exchange
Corporation, which the Commission has
ambiguities in the currently-effective capabilities. Based on comments and
certified as the Electric Reliability
TOP requirements and improve information received on these issues,
Organization responsible for developing
efficiency by incorporating the the Commission may issue directives as
and enforcing mandatory Reliability
necessary requirements from the eight appropriate.
Standards.
currently-effective TOP Reliability
DATES: Comments are due August 24, Standards into three cohesive, I. Background
2015. comprehensive Reliability Standards. 4. Section 215 of the FPA requires a
ADDRESSES: Comments, identified by Further, the Commission believes that Commission-certified ERO to develop
docket number, may be filed in the the proposed standards clarify and mandatory and enforceable Reliability
following ways: improve upon the currently-effective Standards, which are subject to
• Electronic Filing through http:// TOP and IRO Reliability Standards by Commission review and approval. Once
www.ferc.gov. Documents created designating requirements in the approved, the Reliability Standards are
electronically using word processing proposed standards that apply to enforced by the ERO, subject to
software should be filed in native transmission operators for the TOP Commission oversight, or by the
applications or print-to-PDF format and standards and reliability coordinators Commission independently. On March
not in a scanned format. for the IRO standards. Thus, the 16, 2007, the Commission issued Order
• Mail/Hand Delivery: Those unable Commission proposes to find that there No. 693, approving 83 of the 107 initial
to file electronically may mail or hand- are benefits to clarifying and bringing Reliability Standards filed by NERC,
deliver comments to: Federal Energy efficiencies to the TOP and IRO including the existing TOP and IRO
Regulatory Commission, Secretary of the Reliability Standards, consistent with Reliability Standards.4 In addition, in
Commission, 888 First Street NE., the Commission’s policy promoting Order No. 748, the Commission
Washington, DC 20426. increased efficiencies in Reliability approved revisions to the IRO
Instructions: For detailed instructions Standards and reducing requirements Reliability Standards.5
on submitting comments and additional that are either redundant with other 5. On April 16, 2013, in Docket No.
information on the rulemaking process, currently-effective requirements or have RM13–14–000, NERC submitted for
see the Comment Procedures Section of little reliability benefit.2 Commission approval three revised TOP
this document. 2. The Commission also proposes to Reliability Standards to replace the
FOR FURTHER INFORMATION CONTACT: find that NERC has adequately eight currently-effective TOP
Robert T. Stroh (Legal Information), addressed the concerns raised by the standards.6 Additionally, on April 16,
Office of the General Counsel, Federal Commission in the Notice of Proposed 2013, in Docket No. RM13–15–000,
Energy Regulatory Commission, 888 Rulemaking (Remand NOPR) issued in NERC submitted for Commission
First Street NE., Washington, DC November 2013.3 In the Remand NOPR, approval four revised IRO Reliability
20426, Telephone: (202) 502–8473, Standards to replace six currently-
1 16 U.S.C. 824o (2012).
Robert.Stroh@ferc.gov
2 Electric Reliability Organization Proposal to
Eugene Blick (Technical Information), 4 Mandatory Reliability Standards for the Bulk-
Retire Requirements in Reliability Standards, Order
Office of Electric Reliability, Federal No. 788, 145 FERC ¶ 61,147 (2013). Power System, Order No. 693, 72 FR 16416 (Apr.
Energy Regulatory Commission, 888 3 Monitoring System Conditions—Transmission 4, 2007), FERC Stats. & Regs. ¶ 31,242, order on
First Street NE., Washington, DC reh’g, Order No. 693–A, 120 FERC ¶ 61,053 (2007).
Operations Reliability Standard, Transmission 5 Mandatory Reliability Standards for
tkelley on DSK3SPTVN1PROD with PROPOSALS
20426, Telephone: (301) 665–1759, Operations Reliability Standards, Interconnection
Reliability Operations and Coordination Reliability Interconnection Reliability Operating Limits, Order
Eugene.Blick@ferc.gov Standards, Notice of Proposed Rulemaking, 145 No. 748, 134 FERC ¶ 61,213 (2011).
Darrell G. Piatt (Technical Information), FERC ¶ 61,158 (2013). Concurrent with filing the 6 On April 5, 2013, in Docket No. RM13–12–000
Office of Electric Reliability, Federal proposed TOP/IRO standards in the immediate NERC proposed revisions to Reliability Standard
Energy Regulatory Commission, 888 proceeding, NERC submitted a motion to withdraw TOP–006–3 to clarify that transmission operators
the earlier petition that was the subject of the are responsible for monitoring and reporting
First Street NE., Washington, DC Remand NOPR. No protests to the motion were filed available transmission resources and that balancing
20426, Telephone: (205) 332–3792, and the petition was withdrawn pursuant to 18 CFR authorities are responsible for monitoring and
Darrell.Piatt@ferc.gov 385.216(b). reporting available generation resources.
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effective IRO Reliability Standards. On wide-area view of the bulk electric exceedance criteria which clarified the
November 21, 2013, the Commission system.9 team’s position on establishing and
issued the Remand NOPR in which the 8. NERC states that the proposed exceeding SOLs, and on implementing
Commission expressed concern that Reliability Standards include operating plans to mitigate exceedances.
NERC had ‘‘removed critical reliability improvements over the currently The SOL white paper explains the links
aspects that are included in the effective TOP and IRO Reliability between relevant reliability standards
currently-effective standards without Standards in key areas such as: (1) and reliability concepts to establish a
adequately addressing these aspects in Operating within SOLs and IROLs; (2) common understanding necessary for
the proposed standards.’’ 7 The outage coordination; (3) situational developing effective operating plans to
Commission identified two main awareness; (4) improved clarity and mitigate SOL exceedances.11
content in foundational definitions; and 10. NERC states that it reviewed the
concerns and asked for clarification and
(5) requirements for operational report on the Arizona-Southern
comment on a number of other issues.
reliability data. California Outages on September 8,
Among other things, the Commission 9. NERC states that the proposed TOP
expressed concern that the proposed 2011, Causes and Recommendations
and IRO Reliability Standards address (‘‘2011 Southwest Outage Blackout
TOP Reliability Standards did not the coordinated efforts to plan and Report’’) that includes findings and
require transmission operators to plan reliably operate the bulk electric system recommendations applicable to
and operate within all SOLs, which is under both normal and abnormal transmission operators, balancing
a requirement in the currently-effective conditions. NERC states that the authorities and reliability coordinators,
standards. In addition, the Commission proposed Reliability Standards provide and provides explanations of how the
expressed concern that the proposed a comprehensive framework for reliable proposed Reliability Standards address
IRO Reliability Standards did not operations, with important the reliability issues identified
require outage coordination. improvements to ensure the bulk following the 2011 Southwest Outage
6. On December 20, 2013, NERC filed electric system is operated within pre- Blackout Report. Further, NERC states
a motion requesting that the established limits while enhancing that it addressed outstanding
Commission defer action, until January situational awareness and strengthening Commission directives relevant to the
31, 2015, to allow NERC time to operations planning. NERC explains proposed TOP and IRO Reliability
that the proposed Reliability Standards Standards.
consider the reliability concerns raised
establish or revise requirements for
by the Commission in the Remand Revisions to TOP Standards
operations planning, system monitoring,
NOPR. The Commission granted that real-time actions, coordination between
motion on January 14, 2014.8 In 11. NERC proposes three TOP
applicable entities, and operational Reliability Standards to replace the
response to the Remand NOPR, NERC reliability data. According to NERC, the
initiated Project 2014–03 to develop existing suite of TOP standards. The
proposed Reliability Standards help to proposed TOP Reliability Standards
further revisions to the TOP and IRO ensure that reliability coordinators and generally address real-time operations
Reliability Standards. transmission operators work together, and planning for next-day operations,
NERC Petition and with other functional entities, to and apply primarily to the
operate the bulk electric system within responsibilities and authorities of
7. On March 18, 2015, as SOLs and IROLs.10 Further, NERC transmission operators. Among other
supplemented on May 12, 2015, NERC explains that SOLs and IROLs are vital things, NERC states that the proposed
submitted a petition seeking approval of concepts in the Reliability Standards revisions to the TOP Reliability
two sets of Reliability Standards to because they establish acceptable Standards help ensure that transmission
replace the currently-effective TOP and performance criteria both pre- and post- operators plan and operate within all
IRO Reliability Standards. NERC states contingency to maintain reliable bulk SOLs.
that the proposed TOP Reliability electric system operations. NERC states
that when any facility rating or stability TOP–001–3 (Transmission Operations)
Standards generally address real-time
operations and planning for next-day limit is exceeded, or expected to be 12. NERC proposes Reliability
exceeded, these conditions should be Standard TOP–001–3 (Transmission
operations, and apply primarily to the
mitigated to avoid the possibility of Operations), which contains twenty
responsibilities and authorities of
further deteriorating system conditions requirements. The purpose of proposed
transmission operators, with certain
and the potential for a cascading event. Reliability Standard TOP–001–3 is to
requirements applying to the roles and In addition, NERC states that the
responsibilities of the balancing prevent instability, uncontrolled
standard drafting team developed a separation, or cascading outages that
authority. NERC adds that the proposed white paper on SOL definition and
IRO Reliability Standards set forth the adversely affect the reliability of the
responsibility and authority of interconnection, by ensuring prompt
9 The TOP and IRO Reliability Standards are not
reliability coordinators to provide for attached to this NOPR. The complete text of the
action to prevent or mitigate such
Reliability Standards is available on the occurrences. According to NERC, the
reliable operations. According to NERC,
Commission’s eLibrary document retrieval system proposed standard achieves this
reliability coordinators have an essential in Docket No. RM15–16 and is posted on the ERO’s reliability goal by providing appropriate
role in ensuring reliable operations, as Web site, available at: http://www.nerc.com.
entities with the authority to take
they are the functional entities with the 10 The NERC Glossary of Terms defines IROL as
‘‘[a] System Operating Limit that, if violated, could actions, or direct the actions of others,
tkelley on DSK3SPTVN1PROD with PROPOSALS
highest level of authority and have the
lead to instability, uncontrolled separation, or to maintain reliability during real-time
Cascading outages that adversely impact the operations. NERC explains that the
7 Remand NOPR, 145 FERC ¶ 61,158 at P 4. reliability of the Bulk Electric System.’’ In turn, standard includes real-time monitoring
8 Monitoring System Conditions—Transmission NERC defines SOL as ‘‘[t]he value (such as MW,
Operations Reliability Standard, Transmission MVar, Amperes, Frequency or Volts) that satisfies and real-time assessment requirements
Operations Reliability Standards, Interconnection the most limiting of the prescribed operating
Reliability Operations and Coordination Reliability criteria for a specified system configuration to 11 NERC Petition at 46 and Exhibit E, ‘‘White
Standards, Order Granting Motion to Defer Action, ensure operation within acceptable reliability Paper on System Operating Limit Definition and
146 FERC ¶ 61,023 (2014). criteria. . . .’’ Exceedance Clarification.’’
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![36282 Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Proposed Rules
to preserve reliability and ensure that that the TOP and IRO Reliability explanation for the removal of the LSE
applicable entities identify and address Standards, that were the subject of the function.
all SOL exceedances. Remand NOPR, did not have sufficient
13. Requirements R1 and R2 require TOP–002–4 (Operations Planning)
requirements for real-time monitoring.
each transmission operator and Requirement R11 is the equivalent of 20. Proposed Reliability Standard
balancing authority to explicitly and Requirement R10 for balancing TOP–002–4 contains seven
affirmatively act to address the authorities. requirements relating to operations
reliability of its area through its own planning for transmission operators and
actions or by issuing operating 17. Requirement R12 provides that balancing authorities. NERC explains
instructions. In contrast, NERC notes each transmission operator must not that the proposed standard addresses
that the obligation to act in currently operate outside of any identified IROL next-day planning and provides for the
effective Reliability Standard TOP–001– for a continuous duration exceeding its necessary notifications and coordination
1a is implied, but not an explicit associated IROL Tv. NERC states that between various functional entities.
requirement. Requirements R3 and R4 this requirement will provide NERC adds that the revised definition of
together provide that each applicable consistency with the reliability ‘‘operational planning analysis’’
entity must comply with each operating coordinators requirements contained in specifies the scope and inputs required
instruction issued by its transmission currently-effective Reliability Standard for next-day analyses. According to
operator, unless doing so would violate IRO–009–1.12 Requirement R13 NERC, the proposed standard also
safety, equipment, regulatory, or provides that each transmission improves coordination of next-day
statutory requirements or the action operator must ensure that a real-time operations by requiring transmission
cannot be physically implemented, and assessment is performed at least once operators and balancing authorities to
require an applicable entity to notify the every 30 minutes. The revised definition provide operating plans to their
transmission operator if it is unable to of ‘‘real-time assessment’’ includes reliability coordinators.
comply with the transmission operator’s additional specificity regarding various 21. Proposed Requirements R1
operating instruction. Similarly, inputs for the assessment and how that through R3 and R6 apply to
Requirements R5 and R6 require the information may be provided through transmission operators, and proposed
same actions of applicable entities with third-party services, which may provide Requirements R4, R5, and R7 apply to
respect to an operating instruction smaller entities an efficient method for balancing authorities. Requirement R1
issued by a balancing authority. compliance. Requirement R14 provides requires each transmission operator to
14. Requirement R7 requires each that each transmission operator must have an operational planning analysis
transmission operator to assist other initiate its operating plan to mitigate a that will allow it to assess whether its
transmission operators within its SOL exceedance identified as part of its planned operations for the next day
reliability coordinator area, and real-time monitoring or real-time within its transmission operator area
Requirement R8 requires a transmission assessment.13 will exceed any of its SOLs.
operator to inform applicable entities of Requirement R2 requires each
the transmission operator’s actual or 18. Requirement R15 provides that transmission operator to have operating
expected operations that result in, or each transmission operator must inform plans for next-day operations to address
could result in, an emergency. its reliability coordinator of actions potential SOL exceedances identified in
15. Requirements R9, R16, and R17 taken to return the system to within the operational planning analysis
address outage coordination of limits when a SOL has been exceeded. performed pursuant to Requirement R1.
monitoring and control equipment. Requirement R18 provides that each Requirement R4 requires each balancing
Requirement R9 provides that each transmission operator must operate to authority to have operating plans for the
balancing authority and transmission the most limiting parameter in instances next day that address expected
operator must notify its reliability where there is a difference in SOLs. generation resource commitment and
coordinator and known impacted Requirements R19 and R20 provide that dispatch, interchange scheduling,
interconnected entities of all planned each transmission operator and demand patterns, and capacity and
outages, and unplanned outages of 30 balancing authority must have data energy reserve requirements, including
minutes or more, for telemetering and exchange capabilities with the entities deliverability capability. Requirements
control equipment, monitoring and from which it needs data in order to R3 and R5 require each transmission
assessment capabilities, and associated maintain reliability in its area. operator and balancing authority,
communication channels between the 19. In addition, NERC states that it respectively, to notify the entities
affected entities. Requirements R16 and removed the load-serving entity (LSE) identified in their operating plan as to
R17 state that each transmission function from proposed TOP–001–3, their roles in that plan. Requirements R6
operator and balancing authority must Requirements R3 through R6 due to the and R7 require each transmission
provide its system operators with the November 2014 NERC Board of Trustees operator and balancing authority to
authority to approve planned outages action to remove the LSE as a functional provide its operating plan to its
and maintenance. entity from NERC’s Rules of reliability coordinator.
16. Requirement R10 addresses
Procedure.14 On May 12, 2015, NERC TOP–003–3 (Operational Reliability
transmission operator monitoring
supplemented its filing with additional Data)
obligations to help ensure that
transmission operators have the 12 NERC defines T as ‘‘[t]he maximum time that
22. Proposed Reliability Standard
tkelley on DSK3SPTVN1PROD with PROPOSALS
necessary situational awareness to v
an Interconnection Reliability Operating Limit can
TOP–003–3 (Operational Reliability
maintain reliable operations. be violated before the risk to the interconnection or Data) establishes requirements for the
Requirement R10 provides that each other Reliability Coordinator Area(s) becomes provision of information and data
transmission operator must take certain greater than acceptable. Each Interconnection needed by the transmission operator
Reliability Operating Limit’s Tv shall be less than
steps for determining SOL exceedances or equal to 30 minutes.’’
and balancing authority for reliable
within its transmission operator area. 13 NERC Petition, Exhibit B at 5. operations. The purpose of proposed
NERC explains that Requirement R10 14 NERC Petition, Exhibit K, Consideration of Reliability Standard TOP–003–3 is to
addresses the Commission’s concerns Comments January 7, 2015, at 2. ensure that transmission operators and
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![Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Proposed Rules 36285
solutions with its respective reliability after Commission approval. The twelve eliminating multiple TOP standards,
coordinators for identified issues or month implementation period for all of resulting in a more concise set of
conflicts with planned outages in its the standards except TOP–003–3 and standards. Thus, we believe that NERC’s
planning assessment for the near-term IRO–010–2 is intended to allow time for TOP proposal would reduce
transmission planning horizon. entities to update processes and train redundancy and more clearly delineate
operators on the revised requirements. responsibilities between applicable
Definitions
All of the Requirements in proposed entities. In addition, we believe that the
36. NERC also proposes revised TOP–003–3 and IRO–010–2 except proposed Reliability Standards provide
definitions for ‘‘operational planning TOP–003–3, Requirements R5 and IRO– a comprehensive framework as well as
analysis’’ and ‘‘real-time assessment.’’ 15 010–2, Requirement R3 would become important improvements to ensure that
NERC contends that the proposed effective three months earlier, in order the bulk electric system is operated
definitions provide significant to provide recipients of data requests within pre-established limits while
additional detail compared to the from their reliability coordinators, enhancing situational awareness and
currently effective definitions to transmission operators, and/or strengthening operations planning. We
enhance the consistency and the balancing authorities time to respond to believe that the proposed TOP and IRO
reliability benefit of operational the requests for data. Reliability Standards address the
planning analysis and real-time 39. According to NERC’s coordinated efforts to plan and reliably
assessments.16 NERC states that the implementation plan, for proposed operate the bulk electric system under
additional specificity reflected in the TOP–003–3, all requirements except both normal and abnormal conditions.
proposed definitions addresses concerns Requirement R5 will become effective 42. For these reasons, we propose to
raised in the Remand NOPR and on the first day of the first calendar approve NERC’s revisions to the TOP
includes several inputs that were quarter nine months after the date that and IRO Reliability Standards. We also
identified as recommendations in the the standard is approved. For proposed discuss below: (A) Concerns raised in
2011 Southwest Outage Blackout IRO–010–2, Requirements R1 and R2 the Remand NOPR plus possible
Report, which, in turn, will enhance would become effective on the first day inconsistencies of identifying IROLs; (B)
situational awareness. of the first calendar quarter that is nine other reliability issues including (1)
37. The proposed NERC Glossary term months after the date that the standard monitoring of non-bulk electric system
‘‘Operating Instruction’’ defines the is approved. Requirement R3 would facilities; (2) removal of the load-serving
scope of commands that are covered by become effective on the first day of the entity function from proposed
the proposed TOP and IRO Reliability first calendar quarter twelve months Reliability Standard TOP–001–3; and (3)
Standards. NERC explains that the after the date that the standard is data exchange capabilities.
revisions in the proposed definitions are approved. NERC states that the reason
intended to ensure that operational for the difference in effective dates for A. Remand NOPR Issues
planning analyses and real-time proposed TOP–003–3 and IRO–010–2 is 1. Operational Responsibilities and
assessments contain sufficient details to to allow applicable entities to have time Actions of SOLs and IROLs
result in an appropriate level of to properly respond to the data
situational awareness for next-day specification requests. 43. We propose to find that NERC has
planning and real-time operations, adequately addressed the concerns
II. Discussion raised by the Commission in the
respectively.
40. Pursuant to section 215(d) of the Remand NOPR with respect to the
Implementation Plan FPA, we propose to approve NERC’s treatment of SOLs in the proposed TOP
38. NERC proposes that, for all proposed revisions to the TOP and IRO Reliability Standards. In the Remand
standards except proposed Reliability Reliability Standards as just, reasonable, NOPR, the Commission expressed
Standards TOP–003–3 and IRO–010–2, not unduly discriminatory or concern that the proposed TOP
the effective date will be the first day of preferential, and in the public interest. standards did not have a requirement
the first calendar quarter twelve months We believe that NERC’s approach of ‘‘for transmission operators to plan and
consolidating requirements and operate within all SOLs. Without a
15 The proposed definition of operational removing redundancies generally has requirement to plan and operate within
planning analysis is ‘‘[a]n evaluation of projected merit and is consistent with all SOLs in the proposed standards and
system conditions to assess anticipated (pre-
Contingency) and potential (post-Contingency)
Commission policy promoting increased by limiting non-IROL SOLs to only
conditions for next-day operations. The evaluation efficiencies in Reliability Standards and those identified by the transmission
shall reflect applicable inputs including, but not reducing requirements that are either operator internal to its area, system
limited to, load forecasts; generation output levels; redundant with other currently effective reliability is reduced and negative
Interchange; known Protection System and Special requirements or have little reliability
Protection System status or degradation; consequences can occur outside of the
Transmission outages; generator outages; Facility benefit.17 transmission operator’s internal area.’’ 19
Ratings; and identified phase angle and equipment 41. We agree with NERC that the The Commission noted that ‘‘non-IROL
limitations. (Operational Planning Analysis may be proposed TOP and IRO Reliability SOLs that appear to be excluded from
provided through internal systems or through third- Standards would improve reliability by
party services.)’’ the proposed standard are non-IROL
16 The proposed definition of real-time
defining an appropriate division of SOLs that are in a transmission
assessment is ‘‘[a]n evaluation of system conditions responsibilities between reliability operator’s area that impact another
using Real-time data to assess existing (pre- coordinators and transmission transmission operator’s area or more
Contingency) and potential (post-Contingency) operators.18 Specifically, NERC states
tkelley on DSK3SPTVN1PROD with PROPOSALS
operating conditions. The assessment shall reflect
than one transmission operator’s
that the proposed TOP Reliability area.’’ 20
applicable inputs including, but not limited to:
Load, generation output levels, known Protection Standards will be improved by 44. The Commission believes that the
System and Special Protection System status or proposed TOP Reliability Standards
degradation, Transmission outages, generator 17 Electric Reliability Organization Proposal to
outages, Interchange, Facility Ratings, and Retire Requirements in Reliability Standards, Order
address the Commission’s Remand
identified phase angle and equipment limitations. No. 788, 145 FERC ¶ 61,147 (2013).
19 Remand NOPR, 145 FERC ¶ 61,158 at P 42.
(Real-time Assessment may be provided through 18 See, e.g., Order No. 748, 134 FERC ¶ 61,213, at
internal systems or through third-party services.)’’ PP 39–40. 20 Id. P 51.
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NOPR concerns by requiring authorities.23 Requirement R3 requires reliability coordinator’s primary
transmission operators to plan and the reliability coordinator to notify responsibility for IROLs to prevent
operate within all SOLs, and to monitor impacted entities identified in its instability, uncontrolled separation, or
and assess SOL conditions within and operating plan cited in Requirement R2 cascading, proposed Reliability
outside a transmission operator’s area. as to their role in such plan(s). The Standard TOP–001–3, Requirement R12
Specifically, proposed Reliability Commission believes that the requires that a transmission operator
Standard TOP–001–3, Requirement R14 consideration of the transmission must not operate outside of any
requires each transmission operator to operators’ and balancing authorities’ identified IROLs for a continuous
initiate its operating plan to mitigate a operating plans by the reliability duration exceeding its associated IROL
SOL exceedance identified as part of its coordinator in its own operating plan Tv.27
real-time monitoring or real-time provides the necessary situational 48. In addition, NERC explains that
assessment. Proposed Reliability awareness of all SOLs, internal and the proposed Reliability Standard IRO–
Standard TOP–001–3, Requirement R10 external to the transmission operator or 014–3 contains requirements for
requires each transmission operator to balancing authority. coordination of interconnection
monitor facilities within its 46. In the Remand NOPR, the
operations at the reliability coordinator
transmission operator area as well as Commission raised the concern that the
level and ensures that each reliability
certain facilities outside of its then-proposed version of the TOP/IRO
coordinator’s operations are coordinated
transmission operator area to determine Standards did not consider the
such that they will not adversely affect
SOL exceedances within its possibility that additional SOLs could
other reliability coordinators’ areas.28
transmission operator area during the develop or occur in the same-day or
Proposed Reliability Standard IRO–014–
real-time operations time horizon. In real-time operational time horizon, and
3 requires the reliability coordinator to
addition, proposed Reliability Standard therefore would pose an operational risk
have and implement operating
TOP–001–3, Requirement R15 requires to the interconnected transmission
procedures, processes, or plans for
that each transmission operator inform network.24 To address this concern,
activities that require notification or
its reliability coordinator of actions Reliability Standard IRO–008–2,
coordination of actions that may affect
taken to resolve a SOL exceedance.21 To Requirement R5 requires each reliability
adjacent reliability coordinators’ areas.
address the concerns of operational coordinator to notify impacted
planning, proposed Reliability Standard transmission operators and balancing 49. Furthermore, the Commission
TOP–002–4, Requirement R1 requires authorities within its reliability believes the revised definitions of
each transmission operator to have an coordinator area and other impacted operational planning analysis and real-
operational planning analysis to assess reliability coordinators when results of time assessment are critical components
whether its next-day planned operations a real-time assessment indicate actual or of the proposed TOP and IRO Reliability
will exceed any of its SOLs within its expected conditions that could result in Standards and, together with the
area, and Requirement R2 requires the SOL or IROL exceedances, and definitions of SOLs, IROLs and
transmission operator to have a next-day Requirement R6 requires reliability operating plans, work to ensure that
operating plan(s) to address any coordinator notification to impacted reliability coordinators, transmission
potential SOLs exceedances identified transmission operators, balancing operators and balancing authorities plan
in its operational planning analysis.22 authorities and other impacted and operate the bulk electric system
reliability coordinators when any SOLs within all SOLs and IROLs to prevent
45. Further, proposed Reliability
or IROLs have been prevented or instability, uncontrolled separation, or
Standard IRO–008–2, Requirements R1,
mitigated.25 cascading. In addition, the revised
R2, R3, R5, and R6 require reliability
47. Likewise, based on NERC’s definitions of operational planning
coordinators to plan and operate within
explanation, we believe that the analysis and real-time assessment
SOLs and IROLs, which we believe
proposed Reliability Standards in the address other concerns raised in the
work in tandem with the proposed TOP
immediate proceeding are designed to Remand NOPR as well as multiple
Standards and address the
improve system performance by giving recommendations in the 2011
Commission’s concern that the
reliability coordinators the authority to Southwest Outage Blackout Report.29
previously-proposed Reliability
direct actions to prevent or mitigate For example, the definition of
Standards limited ‘‘non-IROL SOLs’’ to
instances of exceeding IROLs. This operational planning analysis is used in
only those internally identified by the
delineation of responsibilities between proposed Reliability Standards TOP–
transmission operator. Specific to
reliability coordinators and 002–4, TOP–003–3, IRO–002–4, IRO–
operational planning, proposed
transmission operators is appropriate 008–2, IRO–010–2, and IRO–014–3 to
Reliability Standard IRO–008–2,
because the primary decision-making ensure a consistent approach to
Requirement R1 requires the reliability
authority for mitigating IROL operations planning for the reliability
coordinator to have an operational
exceedances is assigned to reliability coordinators, transmission operators
planning analysis to assess whether its
coordinators while transmission and balancing authorities.30 Further, the
next-day planned operations will
operators have the primary proposed revised operational planning
exceed SOLs and IROLs within its wide
responsibility for mitigating SOL analysis definition adds additional
area, and Requirement R2 requires the
exceedances.26 To further support the detail and clarity, including the
reliability coordinator to have a
evaluation of pre- and post-contingency
coordinated next-day operating plan(s) 23 NERC Petition at 52. conditions as well as the evaluation of
tkelley on DSK3SPTVN1PROD with PROPOSALS
to address potential SOLs and IROLs 24 Remand NOPR, 145 FERC ¶ 61,158 at P 55. multiple applicable inputs that are
exceedances identified in its operational 25 NERC Petition at 32.
planning analysis while considering the 26 See Remand NOPR, 145 FERC ¶ 61,158 at P 85.
the magnitude and duration of the instance of
next-day operating plan(s) provided by Further, currently-effective Reliability Standard
exceeding that IROL within the IROL’s Tv.’’
its transmission operators and balancing IRO–009–1, Requirement R4 states that ‘‘[w]hen 27 NERC Petition at 25.
actual system conditions show that there is an
28 NERC Petition at 33.
instance of exceeding an IROL in its Reliability
21 NERC Petition at 24–25. 29 NERC Petition at 17–18.
Coordinator Area, the Reliability Coordinator shall,
22 NERC Petition at 27. without delay, act or direct others to act to mitigate 30 NERC Petition at 19.
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absent in the currently-effective Accordingly, the Commission seeks adequately address our concerns with
definition. comment on (1) identification of all respect to outage coordination as
50. Likewise, the definition of real- regional differences or variances in the outlined in the Remand NOPR.
time assessment is used in the following formulation of IROLs, (2) the potential
proposed Reliability Standards: TOP– B. Other Reliability Issues
reliability impacts of such differences or
001–3; TOP–003–3; IRO–002–4; IRO– variations, and (3) the value of 54. While proposing to approve the
008–2; IRO–010–2; and IRO–014–3 to providing a uniform approach or TOP and IRO Reliability Standards, the
ensure a consistent approach to the real- methodology to defining and identifying Commission seeks clarifying comments
time operation of the Bulk Power IROLs. addressing three additional issues: (1)
System for the reliability coordinators, Monitoring of non-bulk electric system
transmission operators and balancing 2. Outage Coordination
facilities; (2) removal of the load-serving
authorities.31 The proposed revised real- 52. We believe, too, that NERC has entity as an applicable entity for
time assessment definition is the same addressed the concerns raised in the proposed Reliability Standard TOP–
type of evaluation as the operational Remand NOPR with respect to the IRO 001–3; and (3) data exchange
planning analysis with the exception standards regarding planned outage capabilities. Based on comments and
that real-time assessment uses real-time coordination. In the Remand NOPR, the information received on these issues,
data to assess existing conditions and Commission expressed concern with the Commission may issue directives as
operational planning analysis uses NERC’s proposal because Reliability appropriate.
projected system conditions to assess Standards IRO–008–1, Requirement R3
anticipated system conditions. and IRO–010–1a (subjects of the 1. Monitoring of Non-Bulk Electric
51. The Commission does note, proposed remand and now withdrawn System Facilities
however, that in Exhibit E (SOL White by NERC) did not require the NERC Petition
Paper) of NERC’s petition, NERC states coordination of outages, noting that
55. NERC explains how the proposed
that with regard to the SOL concept, the outage coordination is a critical
Reliability Standards address the
SOL White Paper brings ‘‘clarity and reliability function that should be
recommendations in the 2011
consistency to the notion of establishing performed by the reliability
Southwest Outage Blackout Report, in
SOLs, exceeding SOLs, and coordinator.35
53. With respect to proposed particular with respect to Finding 17
implementing Operating Plans to
Reliability Standard IRO–017–1, concerning the impact of sub-100 kV
mitigate SOL exceedances.’’ 32 The
submitted by NERC for approval in the facilities on the reliability of the
Commission further notes that IROLs, as
defined by NERC, are a subset of SOLs immediate proceeding, Requirement R1 interconnected transmission network.
that, if violated, could lead to requires each reliability coordinator to Finding 17 states:
instability, uncontrolled separation, or develop, implement and maintain an WECC RC and affected TOPs and BAs do
cascading outages that adversely impact outage coordination process for not consistently recognize the adverse impact
the reliability of the bulk electric generation and transmission outages sub-100 kV facilities can have on BPS
system.33 The Commission agrees with within its reliability coordinator area. reliability. As a result, sub-100 kV facilities
Under Requirement R2, each might not be designated as part of the BES,
NERC that clarity and consistency are which can leave entities unable to address
important with respect to establishing transmission operator and balancing the reliability impact they can have in the
and implementing operating plans to authority, in turn, would perform the planning and operations time horizons. If,
mitigate SOL and IROL exceedances. functions specified in its reliability prior to September 8, 2011, certain sub-100
However, the Commission notes that in coordinator’s outage coordination kV facilities had been designated as part of
its 2015 State of Reliability report, process. Further, Requirement R3 the BES and, as a result, were incorporated
NERC states that the Western requires each planning coordinator and into the TOPs’ and RC’s planning and
Interconnection reliability coordinator transmission planner to provide its operations studies, or otherwise had been
definition of an IROL has additional planning assessment to the relevant incorporated into these studies, cascading
criteria that may not exist in other reliability coordinators and to work outages may have been avoided on the day
together to solve any issues or conflicts of the event.
reliability coordinator areas.34 Based on
this information, it is unclear whether with planned outages among the Recommendation 17 states:
NERC regions apply a consistent applicable entities under Requirement WECC, as the RE, should lead other
approach to identifying IROLs. R4. Additionally, proposed Reliability entities, including TOPs and BAs, to ensure
Standard IRO–014–3, Requirement R1, that all facilities that can adversely impact
31 NERC Petition at 18. Part 1.4 requires reliability coordinators BPS reliability are either designated as part
32 NERC Petition, Exhibit E, ‘‘White Paper on to include the exchange of planned and of the BES or otherwise incorporated into
System Operating Limit Definition and Exceedance unplanned outage information to planning and operations studies and actively
Clarification’’ at 1. monitored and alarmed in [real-time
33 NERC Glossary of Terms defines
support operational planning analyses
and real-time assessments in the contingency analysis] systems.
Interconnection Reliability Operating Limit as ‘‘[a]
System Operating Limit that, if violated, could lead operating procedures, processes, and NERC states that proposed Reliability
to instability, uncontrolled separation, or Cascading plans for activities that require Standard IRO–002–4, Requirement R3
outages that adversely impact the reliability of the
Bulk Electric System.’’
coordination with adjacent reliability addresses monitoring of non-bulk
34 NERC 2015 State of Reliability report at 44, coordinators. Further, the proposed electric system facilities by requiring
available at www.nerc.com. See also WECC revised definitions of operational each reliability coordinator to monitor
tkelley on DSK3SPTVN1PROD with PROPOSALS
Reliability Coordination System Operating Limits planning analysis and real-time facilities and necessary non-bulk
Methodology for the Operations Horizon, Rev. 7.0
(effective March 3, 2014) at 18 (stating that ‘‘SOLs
assessments require that these electric system facilities in order to
qualify as IROLs when . . . studies indicate that evaluations of system conditions identify SOL and IROL exceedances
instability, Cascading, or uncontrolled separation include transmission and generation within its reliability coordinator area.36
may occur resulting in uncontrolled interruption of outages. We believe that these proposed In addition, NERC states that proposed
load equal to or greater than 1000 MW’’), available
at https://www.wecc.biz/Reliability/PhaseII%20
standards and revised definitions Reliability Standards IRO–010–2,
WECC%20RC%20SOL%20Methodology%20
FINAL.pdf. 35 Remand NOPR, 145 FERC ¶ 61,158 at P 90. 36 NERC Petition at 61.
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![36288 Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Proposed Rules
Requirement R1.1 and TOP–003–3, monitored. Further, as stated above, inability to comply with an operating
Requirement R1.1 address non-bulk Recommendation 17 states ‘‘. . . to instruction.39
electric system data by specifically ensure that all facilities that can 61. In its petition, NERC states that,
requiring reliability coordinators and adversely impact BPS reliability are during the standard drafting process, the
transmission operators to incorporate either designated as part of the BES or load-serving entity function was
any non-bulk-electric system data as otherwise incorporated into planning removed from proposed Reliability
deemed necessary into their operational and operations studies and actively Standard TOP–001–3, Requirements R3
planning analyses, real-time monitoring, monitored and alarmed in [real-time through R6. NERC explains that the
and real-time assessments.37 contingency analysis] systems.’’ removal of the load-serving entity as an
56. However, NERC explains that the (emphasis added.) Including such non- applicable entity was based on the
standard drafting team concluded it is bulk electric system facilities in the November 2014 NERC Board of Trustees
unnecessary to include non-bulk definition of bulk electric system action to remove load-serving entity as
electric system monitoring in proposed through the Rules of Procedure a functional entity from NERC’s Rules of
Reliability Standard TOP–001–3, Procedure.40 Since that time, the
exception process could be an option to
Requirement R10 for the transmission Commission has issued an order in
address any potential gaps for
operator, in a similar fashion as Docket No. RR15–4–000 that denied,
monitoring facilities. However, there
proposed Reliability Standard IRO–002– without prejudice, NERC’s proposal to
4, Requirement R3 for the reliability may be potential efficiencies gained by
using a more expedited method to remove the load-serving entity as a
coordinator. Instead, the standard functional entity under NERC’s Risk
drafting team determined that any non- include non-bulk electric system that
requires monitoring. Thus, the Based Registration petition and directed
bulk electric system facility elements NERC to submit a compliance filing to
that are necessary for reliable operation Commission seeks comments on
whether the exception process should address this issue.41
of the bulk electric system would be 62. On May 12, 2015, NERC
included in the bulk electric system be used exclusively in all cases.
supplemented its initial petition with
through the exception process provided 59. Alternatively, we seek comment additional explanation for the removal
in Appendix 5C to the NERC Rules of regarding whether this concern should of the load-serving entity function from
Procedure. NERC states that the be addressed through a review process proposed Reliability Standard TOP–
exception process provides the means of the transmission operators’ systems to 001–3. NERC explains that the proposed
for transmission operators and determine if there are important non- standard gives transmission operators
reliability coordinators to include bulk-electric system facilities that and balancing authorities the authority
elements in the bulk electric system that require monitoring. For example, to direct the actions of certain other
are necessary for the reliable operation Commission staff could work with functional entities by issuing an
of the interconnected transmission NERC, Regional Entities and applicable operating instruction to maintain
system but not identified in the bulk entities to review their system modeling reliability during real-time operations.
electric system definition.38 and perform an analysis to identify non- According to NERC, load-serving
Commission Proposal bulk electric system facilities that need entities are not included in the list of
monitoring. Accordingly, we seek entities that must comply with a
57. We propose to find that NERC has
comment from NERC and other transmission operator’s or balancing
adequately addressed the 2011
interested persons on these alternatives. authority’s operating instructions. NERC
Southwest Outage Blackout Report
recommendation in connection with contends that the exclusion is justified
2. Removal of Load-Serving Entity
sub-100 kV facilities for proposed because none of the functions
Function From TOP–001–3 performed by load-serving entities, as
Reliability Standards IRO–002–4,
Requirement R3, IRO–010–2, NERC Petition described in the NERC Functional
Requirement R1.1 and TOP–003–3, Model, necessitate that load-serving
60. Proposed Reliability Standard entities be subject to a requirement to
Requirement R1.1. In doing so, we rely TOP–001–3, Requirement R3 requires
primarily on the proposed responsibility comply with such operating instructions
that each balancing authority, generator to ensure that a transmission operator or
of the reliability coordinator to monitor operator and distribution provider shall
such facilities to the extent necessary. balancing authority can maintain
comply with each operating instruction reliability.42 NERC adds that a load-
58. However, the transmission
issued by its transmission operator, and serving entity does not own or operate
operator may have a more granular
proposed Reliability Standard TOP– bulk electric system facilities or
perspective than the reliability
001–3, Requirement R4 requires that equipment or the facilities or equipment
coordinator of its necessary non-bulk
each balancing authority, generator used to serve end-use customers and its
electric system facilities to monitor in
operator and distribution provider NERC Functional Model tasks are
order to identify SOL and IROL
inform its transmission operator of its limited in scope. As indicated by the
exceedances, and it is not clear whether
inability to comply with an operating NERC Functional Model, the load-
or how the transmission operator would
instruction. Proposed Reliability serving entity does not play a role in
communicate any insight it may have to
Standard TOP–001–3, Requirement R5 shedding load in real-time.
the reliability coordinator to ensure
requires that each transmission 63. NERC also explains in its
monitoring of all necessary facilities.
Thus, the Commission seeks comment operator, generator operator and supplemental filing that the standard
distribution provider shall comply with drafting team did not identify any
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on how NERC will ensure that the
reliability coordinator will receive each operating instruction issued by its circumstances under which a
information from the transmission balancing authority, and proposed
operator regarding which non-bulk Reliability Standard TOP–001–3, 39 NERC Petition at 22–23.
40 NERC Petition, Exhibit K, Consideration of
electric system facilities should be Requirement R6 requires that each
Comments January 7, 2015, at 2.
transmission operator, generator 41 North American Electric Reliability Corp., 150
37 Id. at 40. operator and distribution provider FERC ¶ 61,213 (2015).
38 Id. at 47–48. inform its balancing authority of its 42 NERC Supplemental Filing at 6.
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![Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Proposed Rules 36289
transmission operator or balancing removed from proposed TOP–001–3, ‘‘data exchange capabilities’’ for the
authority would need to issue an Requirements R3 through R6.45 reliability coordinator. However, we
operating instruction to a load-serving 66. The Commission notes that NERC seek additional explanation from NERC
entity to prevent instability, is required to make a compliance filing regarding how it addresses data
uncontrolled separation, or cascading in July 2015 in Docket No. RR15–4–000. exchange capabilities in the TOP and
outages. NERC contends that, with The Commission’s decision on that IRO Reliability Standards in the
respect to the load-serving entity’s role filing will guide any action in this following areas: (a) Redundancy and
as a provider of information to other proceeding. diverse routing; and (b) testing of the
functional entities, that role is primarily 3. Data Exchange Capabilities alternate or less frequently used data
carried out ahead of real-time and exchange capability.
NERC Petition
would not be the subject of an operating (i) Redundancy and Diverse Routing of
instruction. Additionally, NERC states 67. In Order No. 808, the Commission Data Exchange Capabilities
that the load-serving entity’s real-time approved Reliability Standards COM–
001–2 (Communications) and COM– Background
role with respect to voluntary load
curtailment does not necessitate 002–4 (Operating Personnel 69. The terms ‘‘redundant’’ and
requiring load-serving entities to Communications Protocols).46 In Order ‘‘diverse routing’’ of data exchange
No. 808, the Commission explained that capabilities appear in Reliability
comply with operating instructions
it had raised concerns in the underlying Standard COM–001–1, where the
issued by a transmission operator or
NOPR proposing to approve these COM reliability coordinator, transmission
balancing authority. In order to Reliability Standards (COM NOPR) operator and balancing authority are
maintain reliability in their areas and whether COM–001–2 addresses required to have telecommunication
prevent instability, uncontrolled ‘‘facilities that directly exchange or facilities that are ‘‘redundant’’ and
separation, or cascading outages, there transfer data.’’ 47 In response to the COM ‘‘diversely routed’’ to maintain Bulk-
may be circumstances under which NOPR, NERC and other commenters Power System reliability.51 NERC added
transmission operators and balancing clarified that Reliability Standard COM– two definitions (Interpersonal
authorities need to shed load. NERC 001–2, which covers communications Communication and Alternative
states that such action is implemented capability requirements, is not intended Interpersonal Communication) to
in real-time to address imminent or to address data exchanges or transfers.48 Reliability Standard COM–001–2 that
existing reliability issues such as an As the Commission noted in Order No. addressed redundant and diverse
exceedance of an IROL or SOL, or a 808, NERC maintained that Reliability routing of communications between
voltage problem. According to NERC, Standard COM–001–2 need not include persons and proposed to eliminate the
due to the urgent nature of these requirements regarding data exchange need to use phrases such as ‘‘redundant
circumstances, the reliability capability, ‘‘because such capability is and diversely routed’’ that it described
coordinator, balancing authority, or covered under other existing or as ambiguous.52 With respect to the data
transmission operator may issue proposed standards.’’ 49 The exchange capabilities, NERC stated that
operating instructions directly to the Commission did not make any several proposed or existing standards
distribution provider for physical determinations regarding facilities used ‘‘provided the necessary mandatory
implementation of load shedding for data exchange capability in Order Requirements to ensure proper data
(except when this can be accomplished No. 808 and, based on NERC’s exchange is occurring.’’ 53 NERC also
directly by the transmission operator).43 explanation in its supplemental filing, asserted that four proposed IRO and
the Commission stated that it would TOP standards ‘‘include specific
Commission Proposal address these issues in this TOP and coverage related to data exchange,’’ and
IRO rulemaking proceeding.50 ‘‘collectively require data exchange
64. NERC proposes the removal of the 68. In general, it appears that facilities capability’’ for reliability coordinators,
load-serving entity function from for data exchange capabilities are transmission operators, balancing
proposed Reliability Standard, TOP– addressed in NERC’s proposal. For authorities, generator operators, and
001–3, Requirements R3 through R6, as example, proposed Reliability Standard distribution providers.54
a recipient of an operating instruction TOP–001–3, Requirements R19 and R20 70. In Order No. 808, the Commission
from a transmission operator or require some form of ‘‘data exchange approved NERC’s definition of the terms
balancing authority. However, the capabilities’’ for the transmission Interpersonal Communication and
Commission notes that the issuance and operator and balancing authority, Alternative Interpersonal
compliance of operating instructions respectively. Similarly, proposed Communication. NERC defines
under proposed Reliability Standard Reliability Standard IRO–002–4, Interpersonal Communication as ‘‘[a]ny
TOP–001–3 is not limited to the real- Requirement R1 requires some form of medium that allows two or more
time operations time horizon only.44 individuals to interact, consult, or
45 NERC Glossary of Terms defines Interruptible
65. Further, if a transmission operator
Load as the ‘‘[d]emand that the end-use customer 51 COM–001–1.1 Standard, Requirement R1
or balancing authority would issue an makes available to its Load-Serving Entity via requires that ‘‘[e]ach Reliability Coordinator,
operating instruction to a load-serving contract or agreement for curtailment.’’ Transmission Operator and Balancing Authority
entity such as to carry out interruptible 46 Communications Reliability Standards, Order
shall provide adequate and reliable
load curtailments, it is not clear what No. 808, 151 FERC ¶ 61,039 (2015). telecommunications facilities for the exchange of
47 Order No. 808, 151 FERC ¶ 61,039 at P 54, Interconnection and operating information:’’ and
entity would respond to this operating
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quoting Communications Reliability Standards, R1.4 requires that ‘‘[w]here applicable, these
instruction if the load-serving entity is Notice of Proposed Rulemaking, 148 FERC ¶ 61,210, facilities shall be redundant and diversely routed.’’
at P 33 (2014). 52 NERC COM Petition at 16.
43 NERC 48 Id. P 48.
Supplemental Filing at 9. 53 NERC COM Petition at 16.
44 NERC 49 Id. See also NERC’s Supplemental Comments
TOP/IRO Petition, Exhibit A includes 54 NERC Supp. COM Comments at 3. NERC
the following time horizons for proposed Reliability in Response to Notice of Proposed Rulemaking, identified these same four standards in its Initial
Standard TOP–001–3, Requirements R3 through R6: Communications Reliability Standards, Docket No. Comments, but provides a more detailed discussion
‘‘[Time Horizon: Same-Day Operations, Real-Time RM14–13–000 at 3. of the proposed standards and their status in its
Operations].’’ 50 Order No. 808, 151 FERC ¶ 61,039 at P 54. Supplemental Comments.
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![36290 Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Proposed Rules
exchange information.’’ NERC defines Standard IRO–002–4, Requirement R1, 74. Unlike the approach taken with
Alternative Interpersonal which provides that each reliability COM–001–2, which requires
Communication as ‘‘[a]ny Interpersonal coordinator must have data exchange redundancy and use of a diverse
Communication that is able to serve as capabilities with its balancing medium through the definitions of
a substitute for, and does not utilize the authorities, transmission operators, and Interpersonal Communication and
same infrastructure (medium) as, other entities it deems necessary. Alternative Interpersonal
Interpersonal Communication used for Requirements R19 and R20 state: Communication, proposed Reliability
day-to-day operation.’’ 55 Reliability R19. Each Transmission Operator shall Standards TOP–001–3 and IRO–002–4
Standard COM–001–2, Requirements R1 have data exchange capabilities with the do not appear to address redundancy
through R6 require that reliability entities that it has identified that it needs and diverse routing of data exchange
coordinators, transmission operators, data from in order to maintain reliability in capabilities. While Reliability Standard
and balancing authorities have its Transmission Operator Area. IRO–002–4, Requirement R4 requires
Interpersonal Communication R20. Each Balancing Authority shall have reliability coordinators to have a
capabilities and Alternative data exchange capabilities with the entities redundant infrastructure for system
Interpersonal Communication that it has identified that it needs data from monitoring, it is not clear whether this
in order to maintain reliability in its requirement addresses redundancy and
capabilities in place with other defined Balancing Authority Area.
entities (e.g., other interconnected diverse routing of other forms of data
transmission operators). In its COM Reliability Standard IRO–002–4 exchange capabilities. For example, a
Petition, NERC maintained that the Requirement R1 states: redundant infrastructure used for
defined terms make clear that an entity’s system monitoring could be a subset of
R1. Each Reliability Coordinator shall have
communication capability must be data exchange capabilities with its Balancing the total data exchange capabilities used
redundant and that each of the Authorities and Transmission Operators, and by reliability coordinators and not
capabilities must not utilize the same with other entities it deems necessary, for it include redundant infrastructure for
medium, while eliminating the need to to perform its Operational Planning capabilities such as control of
use ambiguous phrases such as Analyses, Real-time monitoring, and Real- equipment or real-time assessments.
‘‘redundant and diversely routed’’ (as time Assessments. The Commission seeks explanation or
used in the prior version of the standard In addition, NERC states that IRO– clarification from NERC whether and
governing communications 002–4, Requirement R4 requires ‘‘each how the proposed Reliability Standards
capability).56 Reliability Coordinator must have in the immediate proceeding address
71. As noted above, NERC indicated monitoring systems . . . over a redundancy and diverse routing or an
in its response to the COM NOPR that redundant infrastructure.’’ 59 equally effective alternative to
Reliability Standard COM–001–2 need redundancy and diverse routing.
not include requirements regarding data Commission Proposal Further, if NERC or others believe that
exchange capability because such 73. The Commission agrees that redundancy and diverse routing are not
capability is or would be covered by proposed Reliability Standard TOP– addressed, we seek comment on
other existing or proposed standards. 001–3, Requirements R19 and R20 whether there are associated reliability
Specifically, NERC explained that data require some form of ‘‘data exchange risks of the interconnected transmission
exchange is addressed by the currently capabilities’’ for the transmission network for any failure of data exchange
enforceable Reliability Standards IRO– operator and balancing authority, capabilities that are not redundant and
010–1a and IRO–014–1. In addition, respectively, and that proposed diversely routed.
NERC stated that data exchange transfer Reliability Standard TOP–003–3 (ii) Testing of the Alternate or Less
capabilities are directly addressed in addresses the operational data itself Frequently Used Data Exchange
proposed Reliability Standard TOP– needed by the transmission operator Capability
001–3, as well as in proposed Reliability and balancing authority. In addition, the
Standard IRO–002–4, Requirement R1. NERC Petition
Commission agrees that Reliability
NERC also stated that the data itself is Standard IRO–002–4, Requirement R1 75. Reliability Standard COM–001–2,
covered in proposed Reliability requires ‘‘data exchange capabilities’’ Requirement R9 (approved in Order No.
Standard IRO–010–2 and proposed for the reliability coordinator and that 808) requires each reliability
Reliability Standard TOP–003–3.57 proposed Reliability Standard IRO–010– coordinator, transmission operator and
2 addresses the operational data needed balancing authority to test its
NERC Petition
by the reliability coordinator. Further, Alternative Interpersonal
72. In the petition in this proceeding, the Commission agrees that proposed Communication capability at least once
NERC states that in proposed Reliability Reliability Standard IRO–002–4 each calendar month and to initiate
Standard TOP–001–3, ‘‘Requirements Requirement R4 requires a redundant action to repair or designate a
R19 and R20 provide that each infrastructure for system monitoring. replacement Alternative Interpersonal
Transmission Operator (Requirement However, it is not clear whether Communication capability.60
R19) and Balancing Authority redundancy and diverse routing of data 76. As noted above, proposed
(Requirement R20) must have data exchange capabilities (or an equally Reliability Standards TOP–001–3,
exchange capabilities with the entities effective alternative that eliminates the Requirements R19 and R20 and IRO–
from which it needs data in order to ambiguity of ‘‘redundancy’’ and 002–4, Requirement R1 address primary
maintain reliability in its area.’’ 58 NERC ‘‘diversely routed’’) are adequately
tkelley on DSK3SPTVN1PROD with PROPOSALS
states that Requirements R19 and R20 addressed in proposed Reliability
60 Reliability Standard COM–001–2, Requirement
are consistent with proposed Reliability R9 states: ‘‘[e]ach Reliability Coordinator,
Standards TOP–001–3 and IRO–002–4 Transmission Operator, and Balancing Authority
55 Order
for the reliability coordinator, shall test its Alternative Interpersonal
No. 808, 151 FERC ¶ 61,039, at P 45 n.54.
56 May
transmission operator, and balancing Communication capability at least once each
14, 2014, NERC COM Petition, Docket No. calendar month. If the test is unsuccessful, the
RM14–13–000 at 15–16. authority.
responsible entity shall initiate action to repair or
57 NERC COM Supplemental Comments at 3.
designate a replacement Alternative Interpersonal
58 NERC Petition at 26. 59 Id. at 31. Communication capability within 2 hours.’’
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RM15–16–000 (TRANSMISSION OPERATIONS RELIABILITY STANDARDS, INTERCONNECTION RELIABILITY OPERATIONS AND
COORDINATION RELIABILITY STANDARDS)—Continued
Annual
number of
Number of Total number Average burden & cost per Total annual burden hours Cost per respondent
responses
respondents 66 of responses response 67 & total annual cost ($)
per
respondent
(1) (2) (1) * (2) = (3) (4) (3) * (4) = (5) (5) ÷ (1)
IRO–017–1 ............... 180 (RC, PC, & TP) 1 180 218 hrs., $14,464 ............... 39,240 hrs., $2,603,574 ... 218 hrs., $14,464.
Sub-Total for ................................... ...................... ...................... ............................................. 42,540 hrs.,
FERC–725Z. $2,822,529.00.
Retirement of current 457 (RC, TOP, BA, 1 457 ¥223 hrs., ¥$14,796 ........ ¥101,911 hrs., ¥223 hrs., ¥$14,796.
standards currently TSP, LSE, PSE, & ¥$6,761,794.
in FERC–725A. IA).
Net Total of ................................... ...................... ...................... ............................................. 63,881 hrs, $3,993,540.
NOPR in
RM15–16.
Title: FERC–725Z, Mandatory Street NE., Washington, DC 20426 description and analysis of Proposed
Reliability Standards: IRO Reliability [Attention: Ellen Brown, email: Rules that will have significant
Standards, and FERC–725A, Mandatory DataClearance@ferc.gov, phone: (202) economic impact on a substantial
Reliability Standards for the Bulk-Power 502–8663, fax: (202) 273–0873]. number of small entities.71 The Small
System 82. Comments concerning the Business Administration’s (SBA) Office
Action: Proposed Changes to information collections proposed in this of Size Standards develops the
Collections. NOPR and the associated burden numerical definition of a small
OMB Control Nos: 1902–0276 (FERC– estimates, should be sent to the business.72 The SBA revised its size
725Z); 1902–0244(FERC–725A) Commission in this docket and may also standard for electric utilities (effective
Respondents: Business or other for- be sent to the Office of Management and January 22, 2014) to a standard based on
profit and not-for-profit institutions. Budget, Office of Information and the number of employees, including
Frequency of Responses: On-going. Regulatory Affairs [Attention: Desk affiliates (from a standard based on
80. Necessity of the Information and Officer for the Federal Energy megawatt hours).73 Proposed Reliability
Internal review: The Commission has Regulatory Commission]. For security Standards TOP–001–3, TOP–002–4,
reviewed the requirements pertaining to reasons, comments should be sent by TOP–003–3, IRO–001–4, IRO–002–4,
the proposed Reliability Standards email to OMB at the following email IRO–008–2, IRO–010–2, IRO–014–3,
TOP–001–3, TOP–002–4, TOP–003–3, address: oira_submission@omb.eop.gov. and IRO–017–1 are expected to impose
IRO–001–4, IRO–002–4, IRO–008–2, Please reference OMB Control Nos. an additional burden on 196 entities
IRO–010–2, IRO–014–3, and IRO–017–1 1902–0276 (FERC–725Z) and 1902–0244 (reliability coordinators, transmission
and made a determination that the (FERC–725A)) in your submission. operators, balancing authorities,
proposed requirements of these IV. Environmental Analysis transmission service providers, and
standards are necessary to implement planning authorities). Comparison of the
section 215 of the FPA. These 83. The Commission is required to applicable entities with the
requirements conform to the prepare an Environmental Assessment Commission’s small business data
Commission’s plan for efficient or an Environmental Impact Statement indicates that approximately 82 of these
information collection, communication for any action that may have a entities are small entities that will be
and management within the energy significant adverse effect on the human affected by the proposed Reliability
industry. The Commission has assured environment.69 The Commission has Standards.74 As discussed above,
itself, by means of its internal review, categorically excluded certain actions proposed Reliability Standards TOP–
that there is specific, objective support from this requirement as not having a 001–3, TOP–002–4, TOP–003–3, IRO–
for the burden estimates associated with significant effect on the human 001–4, IRO–002–4, IRO–008–2, IRO–
the information requirements. environment. Included in the exclusion 010–2, IRO–014–3, and IRO–017–1 will
81. Interested persons may obtain are rules that are clarifying, corrective, serve to enhance reliability by imposing
information on the reporting or procedural or that do not mandatory requirements for operations
requirements by contacting the Federal substantially change the effect of the planning, system monitoring, real-time
Energy Regulatory Commission, Office regulations being amended.70 The actions, coordination between
of the Executive Director, 888 First actions approved herein fall within this
categorical exclusion in the 71 5 U.S.C. 601–12.
66 The number of respondents is the number of Commission’s regulations. 72 13 CFR 121.101 (2013).
73 SBA Final Rule on ‘‘Small Business Size
entities for which a change in burden from the
current standards to the proposed exists, not the
V. Regulatory Flexibility Act Analysis Standards: Utilities,’’ 78 FR 77343 (Dec. 23, 2013).
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total number of entities from the current or 84. The Regulatory Flexibility Act of 74 The Small Business Administration sets the
proposed standards that are applicable.67 The threshold for what constitutes a small business.
estimated hourly costs (salary plus benefits) are
1980 (RFA) generally requires a Public utilities may fall under one of several
based on Bureau of Labor Statistics (BLS) different categories, each with a size threshold
69 Regulations Implementing the National
information, as of April 1, 2015, for an electrical based on the company’s number of employees,
engineer ($66.35/hour). These figures are available Environmental Policy Act of 1969, Order No. 486, including affiliates, the parent company, and
at http://bls.gov/oes/current/ 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. subsidiaries. For the analysis in this NOPR, we are
naics3_221000.htm#17-0000.68 IRO–001–4 is a Preambles 1986–1990 ¶ 30,783 (1987). using a 750 employee threshold for each affected
revised standard with no increase in burden. 70 18 CFR 380.4(a)(2)(ii). entity to conduct a comprehensive analysis.
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![Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Proposed Rules 36293
applicable entities, and operational 90. From the Commission’s Home Operations (EOP) and Protection and
reliability data. The Commission Page on the Internet, this information is Control (PRC) standards. The
estimates that each of the small entities available on eLibrary. The full text of Commission also proposes to approve
to whom the proposed Reliability this document is available on eLibrary NERC’s revised definition of the term
Standards TOP–001–3, TOP–002–4, in PDF and Microsoft Word format for ‘‘Remedial Action Scheme’’ as set forth
TOP–003–3, IRO–001–4, IRO–002–4, viewing, printing, and/or downloading. in the NERC Glossary of Terms Used in
IRO–008–2, IRO–010–2, IRO–014–3, To access this document in eLibrary, Reliability Standards, and modifications
and IRO–017–1 applies will incur costs type the docket number of this of specified Reliability Standards to
of approximately $147,364 (annual document, excluding the last three incorporate the revised definition.
ongoing) per entity. The Commission digits, in the docket number field. Further, the Commission proposes to
does not consider the estimated costs to 91. User assistance is available for approve the proposed implementation
have a significant economic impact on eLibrary and the Commission’s Web site plans, and the retirement of certain
a substantial number of small entities. during normal business hours from the currently-effective Reliability Standards.
The Commission seeks comment on this Commission’s Online Support at 202– The Commission discusses concerns
proposal. 502–6652 (toll free at 1–866–208–3676) regarding several of NERC’s proposals
VI. Comment Procedures or email at ferconlinesupport@ferc.gov, and, depending on the comments
or the Public Reference Room at (202) provided in response, the Commission
85. The Commission invites interested 502–8371, TTY (202) 502–8659. Email may direct NERC to develop further
persons to submit comments on the the Public Reference Room at modifications to address the concerns
matters and issues proposed in this public.referenceroom@ferc.gov. and possibly delay the retirement of one
notice to be adopted, including any currently-effective standard.
related matters or alternative proposals List of Subjects in 18 CFR Part 40
DATES: Comments are due August 24,
that commenters may wish to discuss. Reliability standards.
2015.
Comments are due August 24, 2015.
Comments must refer to Docket No. By direction of the Commission. ADDRESSES: Comments, identified by
RM15–16–000, and must include the Dated: June 18, 2015. docket number, may be filed in the
commenter’s name, the organization Kimberly D. Bose, following ways:
they represent, if applicable, and their Secretary. • Electronic Filing through http://
address in their comments. [FR Doc. 2015–15433 Filed 6–23–15; 8:45 am] www.ferc.gov. Documents created
86. The Commission encourages BILLING CODE 6717–01–P
electronically using word processing
comments to be filed electronically via software should be filed in native
the eFiling link on the Commission’s applications or print-to-PDF format and
Web site at http://www.ferc.gov. The DEPARTMENT OF ENERGY not in a scanned format.
Commission accepts most standard • Mail/Hand Delivery: Those unable
word processing formats. Documents Federal Energy Regulatory to file electronically may mail or hand-
created electronically using word Commission deliver comments to: Federal Energy
processing software should be filed in Regulatory Commission, Secretary of the
native applications or print-to-PDF 18 CFR Part 40 Commission, 888 First Street NE.,
format and not in a scanned format. Washington, DC 20426.
[Docket Nos. RM15–7–000, RM15–12–000, Instructions: For detailed instructions
Commenters filing electronically do not and RM15–13–000]
need to make a paper filing. on submitting comments and additional
87. Commenters that are not able to information on the rulemaking process,
Revisions to Emergency Operations
file comments electronically must send see the Comment Procedures Section of
Reliability Standards; Revisions to
an original of their comments to: this document.
Undervoltage Load Shedding
Federal Energy Regulatory Commission, Reliability Standards; Revisions to the FOR FURTHER INFORMATION CONTACT:
Secretary of the Commission, 888 First Definition of ‘‘Remedial Action Nick Henery (Technical Information),
Street NE., Washington, DC 20426. Scheme’’ and Related Reliability Office of Electric Reliability, Federal
88. All comments will be placed in Standards Energy Regulatory Commission, 888
the Commission’s public files and may First Street NE., Washington, DC 20426,
be viewed, printed, or downloaded AGENCY: Federal Energy Regulatory (202) 502–8636, Nick.Henery@ferc.gov.
remotely as described in the Document Commission, DOE. Mark Bennett (Legal Information),
Availability section below. Commenters ACTION: Notice of proposed rulemaking. Office of the General Counsel, Federal
on this proposal are not required to Energy Regulatory Commission, 888
serve copies of their comments on other SUMMARY: The Commission proposes to First Street NE., Washington, DC 20426,
commenters. approve Reliability Standards and (202) 502–8524, Mark.Bennett@ferc.gov.
definitions of terms submitted in three SUPPLEMENTARY INFORMATION:
VII. Document Availability related petitions by the North American 1. Pursuant to section 215 of the
89. In addition to publishing the full Electric Reliability Corporation (NERC), Federal Power Act (FPA),1 the
text of this document in the Federal the Commission-approved Electric Commission proposes to approve
Register, the Commission provides all Reliability Organization. The Reliability Standards and definitions of
interested persons an opportunity to Commission proposes to approve terms submitted in three related
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view and/or print the contents of this Reliability Standards EOP–011–1 petitions by the North American Electric
document via the Internet through the (Emergency Operations) and PRC–010– Reliability Corporation (NERC), the
Commission’s Home Page (http:// 1 (Undervoltage Load Shedding). Commission-approved Electric
www.ferc.gov) and in the Commission’s According to NERC, the proposed Reliability Organization (ERO). In
Public Reference Room during normal Reliability Standards consolidate, particular, the Commission proposes to
business hours (8:30 a.m. to 5:00 p.m. streamline and clarify the existing approve Reliability Standards EOP–
Eastern time) at 888 First Street NE., requirements of certain currently-
Room 2A, Washington, DC 20426. effective Emergency Preparedness and 1 16 U.S.C. 824o.
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Document Created: 2015-12-15 14:08:59
Document Modified: 2015-12-15 14:08:59
| Category | Regulatory Information | |
| Collection | Federal Register | |
| sudoc Class | AE 2.7: GS 4.107: AE 2.106: | |
| Publisher | Office of the Federal Register, National Archives and Records Administration | |
| Section | Proposed Rules | |
| Action | Notice of proposed rulemaking. | |
| Dates | Comments are due August 24, 2015. | |
| Contact | Robert T. Stroh (Legal Information), Office of the General Counsel, Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, Telephone: (202) 502-8473, [email protected] Eugene Blick (Technical Information), Office of Electric Reliability, Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, Telephone: (301) 665-1759, [email protected] Darrell G. Piatt (Technical Information), Office of Electric Reliability, Federal Energy Regulatory Commission, 888 First Street NE., Washington, DC 20426, Telephone: (205) 332-3792, [email protected] | |
| FR Citation | 80 FR 36280 |
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