Mandatory Reliability Standards for Interconnection Reliability Operating Limits, 71613-71625 [2010-29575]
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
Category
Integrated average
temperatures
Test procedure
(i) Refrigerator with Solid Door(s) .....................................................
(ii) Refrigerator with Transparent Door(s) .........................................
(iii) Freezer with Solid Door(s) ..........................................................
(iv) Freezer with Transparent Door(s) ..............................................
(v) Refrigerator-Freezer with Solid Door(s) ......................................
ARI
ARI
ARI
ARI
ARI
(vi) Commercial Refrigerator with a Self-Contained Condensing
Unit Designed for Pull-Down Temperature Applications and
Transparent Doors.
(vii) Ice-Cream Freezer .....................................................................
(viii) Commercial Refrigerator, Freezer, and Refrigerator-Freezer
with a Self-Contained Condensing Unit and without Doors.
38 °F (±2 °F).
38 °F (±2 °F).
0 °F (±2 °F).
0 °F (±2 °F).
38 °F (±2 °F) for refrigerator compartment.
0 °F (±2 °F) for freezer compartment.
38 °F (±2 °F).
ARI Standard 1200–2010*
(ix) Commercial Refrigerator, Freezer, and Refrigerator-Freezer
with a Remote Condensing Unit.
Standard
Standard
Standard
Standard
Standard
71613
1200–2010*
1200–2010*
1200–2010*
1200–2010*
1200–2010*
ARI Standard 1200–2010*
ARI Standard 1200–2010*
ARI Standard 1200–2010* ....
¥15.0 °F (±2 °F).
(A) For low temperature applications, the integrated average temperature of all test
package averages shall be 0 °F (±2 °F).
(B) For medium temperature applications,
the integrated average temperature of all
test package averages shall be 38.0 °F
(±2 °F).
(A) For low temperature applications, the integrated average temperature of all test
package averages shall be 0 °F (±2 °F).
(B) For medium temperature applications,
the integrated average temperature of all
test package averages shall be 38.0 °F
(±2 °F).
* Incorporated by reference, see § 431.63.
(4) Determine the volume of each
covered commercial refrigerator, freezer,
or refrigerator-freezer using the
methodology set forth in the AHAM
HRF–1–2008, ‘‘Energy and Internal
Volume of Refrigerating Appliances,’’
(incorporated by reference, see § 431.63)
section 3.30, ‘‘Volume,’’ and sections 4.1
through 4.3, ‘‘Method for Computing
Refrigerated Volume of Refrigerators,
Refrigerator-Freezers, Wine Chillers and
Freezers.’’
[FR Doc. 2010–29210 Filed 11–23–10; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
18 CFR Part 40
[Docket No. RM10–15–000]
Mandatory Reliability Standards for
Interconnection Reliability Operating
Limits
November 18, 2010.
Federal Energy Regulatory
Commission.
ACTION: Notice of proposed rulemaking.
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AGENCY:
Under section 215 of the
Federal Power Act, the Federal Energy
Regulatory Commission proposes to
approve three new Interconnection
Reliability Operations and Coordination
Reliability Standards and seven revised
Reliability Standards related to
Emergency Preparedness and
SUMMARY:
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Operations, Interconnection Reliability
Operations and Coordination, and
Transmission Operations. These
proposed Reliability Standards were
submitted to the Commission for
approval 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. The proposed
Reliability Standards were designed to
prevent instability, uncontrolled
separation, or cascading outages that
adversely impact the reliability of the
interconnection by ensuring prompt
action to prevent or mitigate instances
of exceeding Interconnection Reliability
Operating Limits. The Commission also
proposes to approve the addition of two
new terms to the NERC Glossary of
Terms. In addition, pursuant to section
215(d)(5) of the Federal Power Act, the
Commission proposes to direct NERC to
develop a modification to the proposed
term ‘‘Real-time Assessment’’ to address
a specific concern identified by the
Commission. The Commission raises
some concerns with regard to certain
aspects of NERC’s proposals and, based
on the responses from NERC and
industry, may choose to direct certain
modifications to the proposed new and
revised Reliability Standard, as well as
the new Glossary Terms, as discussed
below.
DATES: Comments are due January 24,
2011.
ADDRESSES: You may submit comments,
identified by docket number and in
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accordance with the requirements
posted on the Commission’s Web site,
https://www.ferc.gov. Comments may be
submitted by any of the following
methods:
• Agency Web site: Documents
created electronically using word
processing software should be filed in
native applications or print-to-PDF
format, and not in a scanned format, at
https://www.ferc.gov/docs-filing/
efiling.asp.
• Mail/Hand Delivery: Commenters
unable to file comments electronically
must mail or hand-deliver an original
copy of their comments to: Federal
Energy Regulatory Commission,
Secretary of the Commission, 888 First
Street, NE., Washington, DC 20426.
These requirements can be found on the
Commission’s Web site, see, e.g., the
‘‘Quick Reference Guide for Paper
Submissions,’’ available at
https://www.ferc.gov/docs-filing/
efiling.asp or via phone from FERC
Online Support at (202) 502–6652 or
toll-free at 1–866–208–3676.
FOR FURTHER INFORMATION CONTACT:
Darrell Piatt (Technical Information),
Office of Electric Reliability, Division
of Reliability Standards, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, Telephone: (202) 502–6687;
A. Cory Lankford (Legal Information),
Office of the General Counsel, Federal
Energy Regulatory Commission, 888
First Street, NE. Washington, DC
20426, Telephone: (202) 502–6711;
William Edwards (Legal Information),
Office of the General Counsel, Federal
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, Telephone: (202) 502–6669.
SUPPLEMENTARY INFORMATION:
Table of Contents
Paragraph
numbers
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I. Background ............................................................................................................................................................................................
A. Mandatory Reliability Standards .................................................................................................................................................
B. Order No. 693 Directives ..............................................................................................................................................................
II. Discussion ............................................................................................................................................................................................
A. System Operating Limits .............................................................................................................................................................
B. Proposed New Reliability Standards ...........................................................................................................................................
1. IRO–008–1 ..............................................................................................................................................................................
2. IRO–009–1 ..............................................................................................................................................................................
3. IRO–010–1a ............................................................................................................................................................................
C. Proposed Revised Reliability Standards ......................................................................................................................................
1. EOP–001–1 .............................................................................................................................................................................
2. IRO–002–2 ..............................................................................................................................................................................
3. IRO–004–2 ..............................................................................................................................................................................
4. IRO–005–3 ..............................................................................................................................................................................
5. TOP–003–1 .............................................................................................................................................................................
6. TOP–005–2 .............................................................................................................................................................................
7. TOP–006–2 .............................................................................................................................................................................
D. Violation Severity Levels and Violation Risk Factors ................................................................................................................
III. Information Collection Statement ......................................................................................................................................................
IV. Environmental Analysis .....................................................................................................................................................................
V. Regulatory Flexibility Act Certification .............................................................................................................................................
VI. Comment Procedures .........................................................................................................................................................................
VII. Document Availability ......................................................................................................................................................................
Notice of Proposed Rulemaking
1. Under section 215 of the Federal
Power Act (FPA),1 the Federal Energy
Regulatory Commission (Commission)
proposes to approve three new
Interconnection Reliability Operations
and Coordination (IRO) Reliability
Standards and seven revised Reliability
Standards related to Emergency
Preparedness and Operations (EOP),
IRO, and Transmission Operations
(TOP). The proposed Reliability
Standards were submitted to the
Commission for approval by the North
American Electric Reliability
Corporation (NERC), which the
Commission has certified as the Electric
Reliability Organization (ERO)
responsible for developing and
enforcing mandatory Reliability
Standards.2 The proposed Reliability
Standards were designed to prevent
instability, uncontrolled separation, or
cascading outages that adversely impact
the reliability of the interconnection by
ensuring prompt action to prevent or
mitigate instances of exceeding
interconnection reliability operating
limits (IROL). The Commission also
proposes to approve the addition of two
new terms to the NERC Glossary of
Terms (NERC Glossary). In addition,
pursuant to section 215(d)(5) of the
Federal Power Act, the Commission
1 16
U.S.C. 824o.
American Electric Reliability Corp., 116
FERC ¶ 61,062, order on reh’g & compliance, 117
FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc.
v. FERC, 564 F.3d 1342 (DC Cir. 2009).
2 North
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proposes to direct NERC to develop a
modification to the proposed term
‘‘Real-time Assessment’’ to address a
specific concern identified by the
Commission. The Commission raises
some concerns with regard to certain
aspects of these proposals and, based on
the responses from NERC and from
industry, may choose to direct certain
modifications to the proposed new and
revised Reliability Standard, as well as
the new Glossary Terms, as discussed
below.
2. The three new Reliability Standards
proposed by NERC are designated as
IRO–008–1 (Reliability Coordinator
Operational Analyses and Real-time
Assessments), IRO–009–1 (Reliability
Coordinator Actions to Operate Within
IROLs), and IRO–010–1a 3 (Reliability
Coordinator Data Specification and
Collection). In preparing these new
Reliability Standards, the standards
drafting team determined that it was
necessary to retire or modify certain
requirements from several existing
standards. Accordingly, NERC requests
3 NERC designates the version number of a
Reliability Standard as the last digit of the
Reliability Standard number. Therefore, original
Reliability Standards end with ‘‘–0’’ and modified
version one Reliability Standards end with ‘‘–1.’’
The NERC Board of Trustees approved the proposed
IRO–010–1 Reliability Standard on October 17,
2008. Subsequently, on August 5, 2009, the NERC
Board of Trustees approved an interpretation to the
proposed IRO–010–1 standard. Accordingly, NERC
is requesting approval of both the proposed
standard and the appended interpretation, and
NERC has designated the proposed standard and
appended interpretation as IRO–010–1a.
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3
4
7
10
22
22
30
33
38
38
42
47
54
58
61
66
69
77
82
83
84
88
Commission approval of revised
Reliability Standards EOP–001–2,4 IRO–
002–2, IRO–004–2, IRO–005–3, and
TOP–006–2. NERC also proposes to add
the following new terms to the NERC
Glossary: ‘‘Operational Planning
Analysis’’ and ‘‘Real-time Assessment.’’ 5
I. Background
A. Mandatory Reliability Standards
3. 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
4 Concurrent with its filing in this Docket, NERC
filed a petition in Docket No. RM10–16–000 seeking
approval of certain Emergency Preparedness and
Operations Reliability Standards. NERC, Petition for
Approval of Three Emergency Preparedness and
Operations Reliability Standards, Docket No.
RM10–16–000 (filed Dec. 31, 2009). As part of its
filing in RM10–16–000, NERC proposed to retire
Requirement R3.4 of EOP–001–0. Each petition
proposes unique changes to EOP–001–0 reflecting
the distinct issues addressed by the respective
Reliability Standards drafting teams. NERC
indicated in both petitions that it could not
anticipate the sequence in which the Commission
would act and therefore included two sets of
proposed amendments to EOP–001–0 in each
petition. The Commission will clarify upon
issuance of Final Rules in each proceeding which
revised version of EOP–001–0 it is addressing in its
determination.
5 The proposed new Reliability Standards and
other modified Reliability Standards are not
codified in the CFR and are not attached to the
NOPR. They are, however, available on the
Commission’s eLibrary document retrieval system
in Docket No. RM10–15–000 and are available on
the ERO’s Web site, https://www.nerc.com.
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enforced by the ERO, subject to
Commission oversight, or by the
Commission independently.
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B. Order No. 693 Directives
4. On March 16, 2007, the
Commission issued Order No. 693,
approving 83 of the 107 initial
Reliability Standards filed by NERC,
including the existing IRO Reliability
Standards.6 Under section 215(d)(5) of
the FPA, the Commission directed
NERC to develop modifications to the
IRO Reliability Standards to address
certain issues identified by the
Commission.
5. With respect to IRO–001–1, the
Commission directed the ERO to
develop modifications to eliminate the
regional reliability organization as an
applicable entity.7 The Commission also
directed the ERO to modify IRO–002–1
to require a minimum set of capabilities
that must be made available to the
reliability coordinator to ensure that a
reliability coordinator has the
capabilities it needs to perform its
functions.8 With respect to IRO–003–2,
the Commission directed the ERO to
develop a modification to create criteria
to define the term ‘‘critical facilities’’ in
a reliability coordinator’s area and its
adjacent systems.9 The Commission also
directed the ERO to modify IRO–004–1
to require the next-day analysis to
identify control actions that can be
implemented and effective within 30
minutes after a contingency. In addition,
the Commission directed the ERO to
consider adding Measures and Levels of
Non-Compliance to Reliability
Standards IRO–004–1 and IRO–005–1
that are commensurate with the
magnitude, duration, frequency and
causes of the violations and whether
these occur during normal or
contingency conditions.10
6. The Commission also directed the
ERO to conduct a survey on IROL
practices and actual operating
experiences by requiring reliability
coordinators to report any violations of
IROLs, their causes, the date and time,
the durations and magnitudes in which
actual operations exceed IROLs to the
ERO on a monthly basis for one year
6 Mandatory Reliability Standards for the BulkPower 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).
7 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 896.
8 Id. P 908.
9 Id. P 914.
10 Id. P 935. NERC has subsequently replaced
Levels of Non-Compliance with Violation Severity
Levels. See Order on Violation Severity Levels
Proposed by the Electric Reliability Organization,
123 FERC ¶ 61,284 (Violation Severity Level Order),
order on reh’g, 125 FERC ¶ 61,212 (2008).
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beginning two months after the effective
date of Order No. 693.11 On October 31,
2008, NERC filed the results of its yearlong survey with the Commission.12 On
February 8, 2009, NERC supplemented
those results in a second filing.13
II. Discussion
7. In a December 31, 2009 filing
(NERC Petition),14 NERC requests
Commission approval of proposed
Reliability Standards IRO–008–1, IRO–
009–1, and IRO–010–1a. NERC contends
that these new Reliability Standards
would address certain Commission
directives from Order No. 693. In
developing the new IRO Reliability
Standards, NERC determined that it was
necessary to retire or modify certain
requirements from several existing
standards. Accordingly, NERC proposes
revised Reliability Standards EOP–001–
1, IRO–002–2, IRO–004–2, IRO–005–3,
TOP–003–1, TOP–005–2, and TOP–
006–2. NERC also requests approval of
new definitions ‘‘Operational Planning
Analysis’’ and ‘‘Real-time Assessment.’’
8. As discussed below, the
Commission proposes to approve new
Reliability Standards IRO–008–1, IRO–
009–1, and IRO–010–1a. The
Commission also proposes to approve
revised Reliability Standards EOP–001–
1, IRO–002–2, IRO–004–2, IRO–005–3,
TOP–003–1, TOP–005–2, and TOP–
006–2 as well as the two new NERC
Glossary terms.
9. In addition, the Commission seeks
comment on specific concerns related to
the proposed IRO Reliability Standards,
as set forth below.
A. System Operating Limits
10. To maintain the reliable operation
of the Bulk-Power System, reliability
coordinators, balancing authorities, and
transmission operators must be aware of
the applicable system operating limits
(SOLs) and interconnection reliability
operating limits (IROLs) on their system.
NERC defines SOLs as the value (such
as MW, MVar, Amperes, Frequency or
Volts) that satisfies the most limiting of
the prescribed operating criteria for a
specific system configuration to ensure
operation within acceptable reliability
criteria. These SOLs are based upon
certain operating criteria. IROLs are,
essentially, a subset of SOLs. NERC
11 Id.
P 951.
12 NERC, Compliance Filing, Docket No. RM06–
16–006 (filed Oct. 31, 2008).
13 NERC, Compliance Filing, Docket No. RM06–
16–006 (filed Feb. 8, 2009).
14 North American Electric Reliability Corp., Dec.
31, 2009 Petition for Approval of Proposed New
and Revised Reliability Standards for Operating
Within Interconnection Operating Limits (NERC
Petition).
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defines IROLs as the value (such as MW,
MVar, Amperes, Frequency or Volts)
derived from, or a subset of the SOLs,
which if exceeded, could expose a
widespread area of the bulk electric
system to instability, uncontrolled
separation, or cascading outages.15
NERC Proposal
11. The proposed IRO Reliability
Standards together with the proposed
revisions to existing Reliability
Standards would divide responsibility
for SOLs and IROLs between reliability
coordinators and transmission operators
according to the Functional Model.16
NERC explains that having two entities
with the same primary responsibility is
not supported by the Functional Model.
However, NERC notes that the proposed
Reliability Standards should not imply
that the reliability coordinator will not
look at its future operations with respect
to specific SOLs.17 NERC states that the
reliability coordinator must look at its
future operations with respect to
specific SOLs to ensure that their
transmission operators are taking
actions at appropriate times, but the
primary responsibility for SOLs rests
with the transmission operators. NERC
explains that, under the proposed
Reliability Standards, the reliability
coordinator retains overall visibility of
all operations within its Wide-Area
view, including some SOLs, although
the transmission operator is primarily
responsible for actions related to
SOLs.18 NERC states that the IRO
standards were developed in support of
the authority and assignment of tasks in
the Functional Model.19 NERC explains
that under the Functional Model, while
reliability coordinators will assign their
transmission operators tasks associated
with IROLs, the reliability coordinator
has ultimate responsibility for these
tasks, and the reliability coordinator is
sanctioned if these tasks are not
performed as required by the Reliability
Standards.20
12. NERC explains that, under the
Functional Model, the reliability
coordinator is the functional entity with
the highest level of responsibility and
authority for real-time reliability of the
Bulk-Power System. NERC states that
the reliability coordinator is responsible
15 See NERC Glossary, available at https://
www.nerc.com/docs/standards/rs/
Glossary_of_Terms_2010April20.pdf.
16 NERC, Reliability Functional Model, version 5,
at 30 (Nov. 2009), available at https://
www.nerc.com/files/
Functional_Model_V5_Final_2009Dec1.pdf.
17 NERC Petition at 77.
18 Id. at 78.
19 Id. at 7–9.
20 Id. at 8.
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
for identifying the subset of SOLs that
are known as IROLs, and may direct its
transmission operators to take actions
associated with IROLs. In assigning a
single task to a single functional entity,
under the Functional Model, the
reliability coordinator is the sole
functional entity responsible for
developing IROLs and for actions to
prevent/mitigate instances of exceeding
IROLs. While the transmission operator
has no ‘‘direct’’ responsibility for
developing IROLs, the transmission
operator may be assigned the task of
developing some IROLs, monitoring
real-time values against identified
IROLs, and taking actions to prevent
reaching an IROL or to mitigate an
instance of exceeding an IROL.
However, the transmission operator
only performs these tasks when directed
to do so by its reliability coordinator.21
13. NERC further explains that, in a
similar fashion, the Functional Model
assigns responsibility for SOLs that are
not IROLs to the transmission operator.
But, NERC states, this too is a shared
responsibility.22 NERC states that where
the Transmission Operator has primary
responsibility for developing the SOLs
within its transmission operator area,
the transmission operator may request
the assistance of its reliability
coordinator in developing these SOLs.
In addition, NERC states that it is the
reliability coordinator that is held
responsible for ensuring that
transmission operators develop SOLs for
its reliability coordinator area in
accordance with a methodology
developed by the reliability coordinator.
NERC states that the transmission
operator must share its SOLs with its
reliability coordinator, and the
reliability coordinator must share any
SOLs it develops with its transmission
operator. NERC also states that the
reliability coordinator monitors the
status of some, but not all, SOLs.
14. According to NERC, the reliability
coordinator’s visualization capabilities
are not expected to display all SOLs
within the Wide-Area that the reliability
coordinator monitors because this
would mix SOLs that have little impact
on reliability with those SOLs that are
associated with facilities that are
important to the Bulk-Power System.
NERC states that the reliability
coordinator’s visualization capabilities
are expected to display the real-time
status of parameters against all IROLs
that the reliability coordinator monitors
and also display the subset of SOLs
associated with facilities that are most
critical to the portions of the Bulk21 Id.
22 Id.
at 9.
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Power System that are monitored by the
reliability coordinator.
15. Under proposed new Reliability
Standards, IRO–008–1, IRO–009–1, and
IRO–010–1a, reliability coordinators
must monitor and analyze IROLs within
their Wide-Area to prevent instability,
uncontrolled separation, or cascading
outages that adversely impact the
reliability of the interconnection. These
Reliability Standards would not require
the reliability coordinator to monitor
and analyze SOLs other than IROLs
within their reliability coordinator area.
Similarly, NERC’s proposed revisions to
Reliability Standards EOP–001–1, IRO–
002–2, IRO–004–2, IRO–005–3, TOP–
003–1, TOP–005–2, and TOP–006–2,
inter alia, would remove requirements
for the reliability coordinator to monitor
and analyze SOLs other than IROLs.
Discussion
16. We believe that it is appropriate
to develop requirements for Reliability
Standards that offer a clear division of
responsibilities among reliability
coordinators and transmission
operators. We, therefore, propose to
approve NERC’s proposed division of
responsibility for SOLs and IROLs
among reliability coordinators and
transmission operators. Although we
support NERC’s proposal and propose
here to approve it with only a limited
directive regarding one proposed
definition, we are also seeking
comments from NERC and industry to
obtain further information and ensure
that there will not be gaps in the
analysis of SOLs by reliability
coordinators going forward, particularly
those SOLs that could become IROLs.
NERC acknowledges in its filing that the
transmission operator must develop and
share its SOLs with its reliability
coordinator, and the reliability
coordinator must develop and share any
SOLs it develops with its transmission
operator.23 NERC also states that the
reliability coordinator monitors the
status of some, but not all, SOLs.24 In
addition, the Commission is aware that
NERC is currently working on a project
to identify a subset of SOLs, other than
IROLs, that a reliability coordinator
must continuously monitor and
analyze.25 Taken together, NERC’s
statements and its ongoing project
indicate a need for reliability
coordinators to continue to analyze
certain SOLs. We, therefore, seek
comment on whether there is a need for
23 Id.
reliability coordinators to continue to
analyze, in addition to continuing to
monitor and coordinate data on,26 SOLs
other than IROLs.
17. Since the ERO has stated that
responsibility for the SOLs is shared
between the reliability coordinator and
their transmission operators, we also
believe it may be beneficial for the
reliability coordinator to have a
documented methodology for
identifying the SOL information it needs
to fulfill its responsibilities for
monitoring, day ahead and real-time
assessments, and operational control
within the reliability coordinator’s area.
We seek comment on this matter.
18. In addition, we request comment
from NERC, reliability coordinators, and
other interested entities on the current
practices of reliability coordinators and
transmission operators with respect to
coordinating operational responsibilities
for monitoring, day ahead and real-time
assessments; and operating SOLs and
IROLs, the practical division of
responsibilities for preventing and
mitigating SOL and IROL violations,
and the monitoring capabilities of the
reliability coordinator with respect to
IROLs as well as SOLs. The Commission
further seeks comment as to whether a
reliability coordinator can provide an
accurate assessment of the Bulk-Power
System to its transmission operators on
a Wide-Area basis, without evaluating:
(1) The operating environment on SOLs
that will impact the transmission
operators within the reliability
coordinator’s areas; (2) SOLs that have
the potential to become IROLs; and (3)
the existing IROLs within the reliability
coordinator area. In addition, the
Commission seeks comments as to
whether a transmission operator can
provide reliable operating assessments
or make reliable operating instructions
on an SOL that is on the border between
two different transmission operator’s
areas. The Commission also requests
comment on whether the reliability
coordinator should have responsibility
to monitor certain SOLs other than
IROLs, and whether such a
responsibility would place an
unreasonable burden on reliability
coordinators. If a reliability coordinator
should monitor certain SOLs other than
IROLs, comments should address in
detail how reliability coordinators
should determine which SOLs to
monitor.
19. The Commission has noted that
NERC Standard IRO–006, Transmission
24 Id.
25 NERC identifies this as ‘‘Project 2007–03: Realtime Operations,’’ available at https://
www.nerc.com/filez/standards/Realtime_Operations_Project_2007-03.html.
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26 Existing reliability standards that NERC does
not propose to change here continue to require
reliability coordinators to monitor SOLs. See
Reliability Standard IRO–002–1 Requirement R6.
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reliability coordinators and
transmission operators. Our intent in
seeking comments from NERC and
industry in this NOPR is to better
understand the proposed division of
responsibilities, as well as the future
modifications to those responsibilities
that NERC intends to pursue.
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Loading Relief (TLR), requires the
reliability coordinators in the Eastern
Interconnection to relieve overloads on
the facilities modeled in the Interchange
Distribution Calculator (IDC). IRO–006
requires the reliability coordinator to
model the SOLs and IROLs in the IDC
to perform the TLR procedures. The
Commission seeks comments on how
the reliability coordinators in the
Eastern Interconnections selects the
SOLs for evaluation by the IDC and the
extent of any burden this has caused the
reliability coordinator.
20. The NERC Functional Model is a
reference document developed by NERC
that outlines functions for each
responsible entity in the NERC
Reliability Standards.27 NERC explains
in its filing that the NERC Functional
Model was developed by first
identifying all of the operating tasks
necessary for reliability, and then
assigning each of these operating tasks
to a single functional entity.28 NERC
states that this approach results in a
clear identification of a single functional
entity with responsibility for each
reliability task. However, NERC also
states that in later versions of the
Functional Model, there are
circumstances where the Functional
Model assigns some activities to more
than one planning entity.29 NERC
explains that, under the Functional
Model, the reliability coordinator is
responsible for identifying the subset of
SOLs known as IROLs and that the
transmission operator is responsible for
other SOLs. But the Functional Model
assigns a much broader role to the
reliability coordinator to maintain the
real-time operating reliability of the
bulk electric system within its area. The
Commission seeks comments from
NERC and the public as to how the
current Functional Model represents the
delineation of assessment and operating
responsibilities between the reliability
coordinator and transmission operator
with respect to SOLs and IROLs.
21. Based on the foregoing, the
Commission proposes to approve the
proposed new and revised Reliability
Standards without modification (with
the exception of the limited directive
proposed below), as they appear to be
an improvement over the existing
Reliability Standards with respect to the
division of responsibilities between
1. IRO–008–1
22. Proposed Reliability Standard
IRO–008–1 has the stated purpose of
preventing instability, uncontrolled
separation, or cascading outages that
adversely impact the reliability of the
interconnection by ensuring that the
Bulk Electric System is assessed during
the operations horizon. The proposed
Reliability Standard applies to
reliability coordinators. IRO–008–1
requires the reliability coordinator to
use analyses and assessments as
methods of achieving the stated goal.
The Reliability Standard requires
analysis of the reliability coordinator’s
Wide-Area 30 ahead of time and during
real-time. It also requires
communication with the entities that
need to take specific operational actions
based on the analyses and assessments.
23. Reliability Standard IRO–008–1
contains three requirements.
Requirement R1 requires each reliability
coordinator to perform an Operational
Planning Analysis to assess whether the
planned operations for the next day
within its Wide Area, will exceed any
of its IROLs during anticipated normal
and contingency event conditions.
Requirement R2 requires the reliability
coordinator to perform a Real-Time
Assessment at least once every 30
minutes to determine if its Wide Area is
exceeding any IROLs or is expected to
exceed any IROLs. Requirement R3
requires a reliability coordinator to
share the results of an Operational
Planning Analysis or Real-Time
Assessment that indicates the need for
specific operational actions to prevent
or mitigate an instance of exceeding an
IROL with those entities that are
expected to take those actions.
24. NERC explains that IRO–008–1,
Requirement R1 does not specify any
single application program that all
reliability coordinators must use
because the Requirement assumes that
the reliability coordinator has a suite of
27 NERC, Reliability Functional Model, version 5
at 30 (Nov. 2009), available at https://
www.nerc.com/files/
Functional_Model_V5_Final_2009Dec1.pdf. NERC
developed the current version of the Functional
Model after it developed the proposed Reliability
Standards.
28 NERC Petition at 7.
29 Id. at 7 n.9.
30 The term ‘‘Wide-Area’’ is defined in the NERC
Glossary, approved by the Commission. As defined,
Wide-Area includes not only the reliability
coordinator’s Area, but also critical flow and status
information from adjacent reliability Coordinator
areas as determined by detailed system studies to
allow the calculation of IROLs. See NERC Glossary
available at https://www.nerc.com/docs/standards/
rs/Glossary_of_Terms_2010April20.pdf.
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applications that it can use to conduct
its assessment, verified as part of the
certification process. NERC notes that
having the ability to conduct a dayahead contingency analysis is a
requirement for reliability coordinator
certification.
25. NERC also requests approval of
two new terms that appear in IRO–008–
1: ‘‘Operational Planning Analysis’’ and
‘‘Real-time Assessment.’’ Operational
Planning Analysis is defined as:
An analysis of the expected system
conditions for the next day’s operation. (That
analysis may be performed either a day ahead
or as much as 12 months ahead.) Expected
system conditions include things such as
load forecast(s), generation output levels, and
known system constraints (transmission
facility outages, generator outages, equipment
limitations, etc.).
NERC states that the definition was
designed to provide greater specificity
regarding the day-ahead study. NERC
explains that the term ‘‘unique’’ used in
the currently-effective IRO–004–1
causes confusion. NERC states that in
the event there are no changes to the
expected conditions from one day to the
next, the reliability coordinator would
not be forced to conduct a new analysis
of the expected system conditions solely
to have documentation for compliance.
26. The proposed term ‘‘Real-time
Assessment’’ is defined as ‘‘[a]n
examination of existing and expected
system conditions, conducted by
collecting and reviewing immediately
available data.’’ The purpose of the new
term is to assure that the reliability
coordinator is required to conduct a
real-time assessment, including
situations when the reliability
coordinator is operating without its
primary control facilities, by collecting
and reviewing available data. NERC
explains that the definition of Real-Time
Assessment is purposefully ambiguous
to allow the assessment to be conducted
either through the energy management
system or manually.
NOPR Proposal
27. We agree with NERC that the
proposed Reliability Standard IRO–008–
1 would prevent instability,
uncontrolled separation, or cascading
outages that adversely impact the
reliability of the interconnection by
ensuring that the bulk electric system is
assessed during the operations horizon.
In addition, the Commission recognizes
NERC’s effort to create a body of IRO
Reliability Standards that clearly define
which functional entity has the ultimate
responsibility for SOLs and IROLs.
Accordingly, pursuant to section
215(d)(2) of the FPA, the Commission
proposes to approve Reliability
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Standards IRO–008–1, as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. To ensure that the proposed
changes are supported by the Functional
Model, the Commission requests
comment whether the proposed
Reliability Standards, such as IRO–008–
1, appropriately resolve the division of
responsibilities for SOLs and IROLs or
whether some level of sharing of
responsibility needs to exist.
28. The Commission also proposes to
approve the addition of two new
definitions to the NERC Glossary:
‘‘Operational Planning Analysis’’ and
‘‘Real-time Assessment’’ with limited
modification, as discussed below.
Although the proposed definition of
Operational Planning Analysis would
permit entities to use an analysis of the
expected system conditions for the next
day’s operation that was performed up
to twelve months earlier, the discretion
to use an existing analysis is limited to
circumstances where the expected
system conditions, such as load
forecasts, generation output levels, and
known system constraints are the same
for both days. Nevertheless, the
Commission requests comments from
NERC and the public on the prudence
of using an Operational Planning
Analysis up to twelve months old. We
request comment on whether this
timeframe is reasonable or whether the
timeframe should be shorter to ensure
that the analysis is not outdated. In
addition, the Commission also seeks
comments from NERC and the public on
whether the definition should include
measurable criteria needed to determine
whether it is appropriate to use an
existing analysis.
29. In addition, the Commission seeks
comment on the meaning of
‘‘immediately available data’’ within the
proposed definition of Real-Time
Assessment. Requirement R6 of
proposed Reliability Standard IRO–002–
2 would require reliability coordinators
to have adequate analysis capabilities
such as state estimation, pre- and postcontingency analysis capabilities
(thermal, stability, and voltage), and
wide-area overview displays.31 Thus, it
appears that any immediately available
data used by the reliability coordinator
in the development of a Real-time
Assessment should be data obtained
from one of these analysis capabilities.
We believe this could be clearer.
Accordingly, under section 215(d)(5) of
the FPA, the Commission proposes to
31 As discussed below, NERC proposes to revise
IRO–002–1 by removing one provision,
Requirement R2. Thus, Requirement R6 of proposed
IRO–002–2 is the same as Requirement R7 of the
existing version 1 Reliability Standard.
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direct NERC to modify the definition of
‘‘Real-time Assessment’’ to specify that
the type of data to be relied upon by a
reliability coordinator in conducting a
Real-time Assessment must be based on
adequate analysis capabilities such as
those referenced in Requirement R6 of
IRO–002–2 when the tools are available.
2. IRO–009–1
30. As proposed, Reliability Standard
IRO–009–1 is designed to prevent
instability, uncontrolled separation, or
cascading outages that adversely impact
the reliability of the interconnection by
‘‘ensuring prompt action to prevent or
mitigate instances of exceeding
[IROLs].’’ Proposed Reliability Standard
IRO–009–1 applies only to reliability
coordinators.
31. For each IROL that the reliability
coordinator identifies one or more days
in advance, the reliability coordinator
must, under Requirements R1 and R2,
have one or more operating processes,
procedures, or plans that identify
actions it shall take that can be
implemented in time to prevent
exceeding those IROLs and to mitigate
the magnitude and duration of
exceeding that IROL such that the IROL
is alleviated within the maximum time
duration allowed for a violation of an
IROL. Reliability Standard IRO–009–1
refers to the maximum response period
for alleviating an IROL as its ‘‘IROL
Tv.’’ 32 Under Requirements R3 and R4,
the reliability coordinator must use
those operating processes, procedures,
or plans to prevent and mitigate IROLs.
If reliability coordinators cannot agree
on the value for an IROL or its IROL Tv,
Requirement R5 would require each
reliability coordinator that monitors that
facility to use the most conservative
value.
NOPR Proposal
32. The Commission agrees that
having action plans developed and
implemented with respect to IROLs to
prevent instability, uncontrolled
separation, or cascading outages that
adversely impact the reliability of the
interconnection increases the likelihood
that reliability coordinators will take
appropriate action. Accordingly, under
section 215(d)(2) of the FPA, the
Commission proposes to approve
Reliability Standard IRO–009–1, as just,
reasonable, not unduly discriminatory
32 The NERC Glossary of Terms defines ‘‘IROL Tv’’
as:
The maximum time that an Interconnection
Reliability Operating Limit can be violated before
the risk to the interconnection or other Reliability
Coordinator Areas becomes greater than acceptable.
Each Interconnection Reliability Operating Limit’s
Tv shall be less than or equal to 30 minutes.
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or preferential, and in the public
interest. However, as discussed above,
the Commission requests comment on
the extent that reliability coordinators
should have action plans developed and
implemented with respect to other SOLs
apart from IROLs and if so, which SOLs.
3. IRO–010–1a
33. NERC proposes the addition of a
new Reliability Standard, IRO–010–1a
to the current suite of IRO Reliability
Standards. IRO–010–1a is designed to
prevent instability, uncontrolled
separation, or cascading outages that
adversely impact the reliability of the
interconnection by mandating that the
reliability coordinator have the data it
needs to monitor and assess the
operation of its reliability coordinator
Area.
34. The requirements in the
Reliability Standard specify a formal
request process for the reliability
coordinator to explicitly identify the
data and information it needs for
reliability; and require the entities with
the data to provide it as requested. The
Reliability Standard applies to the
reliability coordinator and to the other
functional entities that must supply data
to the reliability coordinator.33 This
includes entities that have been
identified as owners, users, or operators
of the bulk-power system.
35. Because the interpretation for
IRO–010–1 was completed before the
filing of IRO–010–1, NERC requests
Commission approval of IRO–010–1a,
which includes the standard as
interpreted. The WECC Reliability
Coordination Subcommittee requested
clarification on: (1) The type of data to
be supplied to the reliability
coordinator; (2) which entities are
ultimately responsible for ensuring data
are provided; and (3) what actions are
expected of the reliability coordinator
regarding a ‘‘mutually acceptable
format.’’
36. In response to the questions posed
by the WECC Reliability Coordination
Subcommittee, NERC’s interpretation
team clarified that the data to be
supplied in Requirement R3 applies to
the documented specification for data
and information referenced in
Requirement R1. They also explained
that the intent of Requirement R3 is for
each responsible entity to ensure that its
data and information (as stated in the
documented specification in
33 The requirements in the standard are
specifically applicable to the following functional
entities: (1) Reliability coordinator; (2) balancing
authority; (3) generator owner; (4) generator
operator; (5) interchange authority; (6) load-serving
entity; (7) transmission operator; and (8)
transmission owner.
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Requirement R1) are provided to the
reliability coordinator. NERC’s
interpretation team stated that another
entity may provide that data or
information to the reliability
coordinator on behalf of the responsible
entity, but the responsibility remains
with the responsible entity. Finally,
they explained that Requirement R1.2
mandates that the parties will reach a
mutual agreement with respect to the
format of the data and information. If
the parties can not mutually agree on
the format, it is expected that they will
negotiate to reach agreement or enter
into dispute resolution to resolve the
disagreement.34
NOPR Proposal
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37. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard IRO–010–
1a, including the proposed
interpretation, as just, reasonable, not
unduly discriminatory or preferential,
and in the public interest. However, the
Commission notes that the requirements
of Reliability Standard IRO–010–1a do
not require reliability coordinators to
specify a list of minimum data needed
for reliable operation of the Bulk-Power
System. The Commission is concerned
that, without such a minimum list,
neighboring reliability coordinators
could experience problems regarding
compatibility and, therefore, common
understanding of data. For example, if
differing data requirements were
specified by adjacent reliability
coordinators, the analysis performed by
one could indicate a more severe result
from a possible contingency and result
in conflicting operating procedures for
mitigation of risk to the Bulk-Power
System. Therefore, the Commission
requests comments from the ERO and
industry on whether a minimum list of
data is necessary for the effective
sharing of data between neighboring
reliability coordinators and, if so, what
data should be included. The
Commission also requests comments
from NERC and the industry on how
compatibility of data between
neighboring reliability coordinators can
be assured absent a list of minimum
data as part of this proposed Reliability
Standard.
C. Proposed Revised Reliability
Standards
1. EOP–001–1
38. NERC proposes to retire
Requirement R2 of Reliability Standard
EOP–001–0. To implement this revision,
NERC proposes a revised Reliability
34 NERC
15:12 Nov 23, 2010
NOPR Proposal
41. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard EOP–001–
1 as just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. The Commission
also proposes to find that the ERO has
35 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 548, 556, 566.
Petition at 108.
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Standard EOP–001–1. The purpose of
EOP–001–1 is to require each
transmission operator and balancing
authority to develop, maintain, and
implement a set of plans to mitigate
operating emergencies. These plans
need to be coordinated with other
transmission operators and balancing
authorities, and the reliability
coordinator. Revised Reliability
Standard EOP–001–1 would apply only
to balancing authorities and
transmission operators.
39. NERC contends that, upon IRO–
009–1 becoming effective, Requirement
R2 of EOP–001–0 should be retired.
Under Requirement R2 transmission
operators must have an emergency load
reduction plan for all identified IROLs.
NERC contends that this requirement
would no longer be appropriate upon
IRO–009–1 becoming effective because
the reliability coordinator, not the
transmission operator, is responsible for
developing plans for mitigating IROLs.
Accordingly, NERC requests approval of
EOP–001–1, which is identical to
existing Reliability Standard EOP–001–
0 except for the retirement of
Requirement R2.
40. NERC contends that the proposed
new Requirements R1 and R2 of IRO–
009–1 combined with the revisions in
proposed Reliability Standard EOP–
001–1 address the Commission’s
directives in Order No. 693 to modify
EOP–001–0 to include the reliability
coordinator as an applicable entity and
to require the reliability coordinator to
act to mitigate IROL violations within
30 minutes.35 In developing IRO–009–1,
NERC states that the drafting team
determined that there are some IROLs
that must be resolved in a time frame
that is shorter than 30 minutes.
Accordingly, Requirement R2 of IRO–
009–1 requires that each action plan
developed to resolve an IROL must be
capable of being executed such that the
IROL is relieved within its IROL Tv. In
addition, Requirement R4 of IRO–009–
1 requires the reliability coordinator to
act, without delay, when actual system
conditions show that there is an
instance of exceeding an IROL.
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satisfied the first and second directives
from P 566 of Order No. 693.36
2. IRO–002–2
42. NERC proposes to retire
Requirement R2 of Reliability Standard
IRO–002–1. To implement this revision,
NERC requests Commission approval of
revised Reliability standard IRO–002–2.
The purpose of IRO–002–2 is to provide
reliability coordinators with the
information, tools and other capabilities
that they need to perform their
responsibilities. IRO–002–2 would
apply only to reliability coordinators.
43. Requirement R2 of IRO–002–1
requires each reliability coordinator to
determine the data requirements to
support its reliability coordinator tasks
and to request such data from its
transmission operators, balancing
authorities, transmission owners,
generation owners, generation operators,
and load-serving entities, or adjacent
reliability coordinators. NERC explains
that proposed Reliability Standard IRO–
010–1a (discussed above) requires the
reliability coordinator to develop and
distribute a data specification to ensure
that entities provide data as needed to
support monitoring, analyses, and
assessments. NERC contends that the
proposed requirements are more explicit
than the associated requirement in
Reliability Standard IRO–002–1.
44. Reliability Standard IRO–002–2
continues to require each reliability
coordinator to monitor SOLs other than
IROLs both within its reliability
coordinator area and in surrounding
reliability coordinator areas. Under
Requirement R4 of IRO–002–2, each
reliability coordinator must have
detailed real-time monitoring capability
of its reliability coordinator area and
sufficient monitoring capability of its
surrounding reliability coordinator areas
to ensure that potential or actual SOLs
or IROL violations are identified. In
addition, under Requirement R5, each
reliability coordinator must monitor
bulk electric system elements such as
generators, transmission lines, buses,
transformers and breakers that could
result in SOL or IROL violations within
its reliability coordinator area.
45. In Order No. 693, the Commission
directed the ERO to develop a
modification to IRO–002–1 that requires
a minimum set of capabilities that
should be made available to reliability
coordinators. NERC acknowledges that
the proposed modification does not
36 The Commission notes that the third and fourth
directives listed in P 566 of Order No. 693 remain
outstanding. Further, the Commission directed the
ERO to consider a pilot program for implementing
system states. Order No. 693, FERC Stats. & Regs.
¶ 31,242 at P 566.
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address this directive. NERC states that
this directive is being considered in
Project 2009–02—Real-time Tools and
Analysis Capabilities.
NOPR Proposal
46. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard IRO–002–
2. The Commission proposes to find that
the data specification requirements of
proposed Reliability Standard IRO–001–
1a are more explicit than the direction
provided in Requirement R2 of IRO–
002–1. In addition, the Commission
accepts NERC’s commitment to develop
a minimum set of capabilities that
should be made available to reliability
coordinators.
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3. IRO–004–2
47. NERC proposes to revise IRO–
004–1 by retiring Requirements R1
through R6. To implement these
revisions, NERC requests Commission
approval of Reliability Standard IRO–
004–2. The purpose of IRO–004–2 is to
require each reliability coordinator to
conduct next-day reliability analyses for
its reliability coordinator area to ensure
the bulk electric system can be operated
reliably in anticipated normal and
contingency conditions. IRO–004–2
would apply to balancing authorities,
transmission operators, and
transmission service providers.
48. NERC states that, upon approval
of proposed IRO–008–1, Requirement
R1 of the currently-effective IRO–004–1
should be retired because the
requirement only requires a next-day
reliability analysis of its own reliability
coordinator area as opposed to its WideArea, which also would include critical
flow and status information from
adjacent reliability coordinator areas to
allow the calculation of IROLs. NERC
explains that because proposed IRO–
008–1 requires the reliability
coordinator to assess a wider area than
is currently required by IRO–004–1, the
reliability coordinator is required to
continuously look beyond its own area
boundaries and assess a broader portion
of the interconnected Bulk-Power
System. NERC further states that the
purpose of conducting a day-ahead
analysis is not to ‘‘ensure’’ but to ‘‘assess’’
the system and, thus, Requirement R1 of
currently-effective IRO–004–1 is
inaccurate.
49. NERC also seeks to retire
Requirement R2 of IRO–004–1, which
requires each reliability coordinator to
‘‘pay particular attention to parallel
flows to ensure one reliability
coordinator area does not place an
unacceptable or undue burden on an
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adjacent reliability coordinator area.’’ 37
NERC states that the phrase ‘‘to pay
particular attention to’’ is neither clear
nor measurable. NERC asserts that the
requirements in currently-effective IRO–
014, IRO–015, and IRO–016 are aimed at
ensuring that reliability coordinators
coordinate their actions with one
another and act in the best interest of
the interconnection as a whole. In
addition, NERC explains that, under the
Functional Model, the transmission
operator is responsible for the real-time
operation of the transmission system
with the reliability coordinator
providing oversight of the transmission
operator’s actions, directing additional
or alternate actions when needed. NERC
states that the requirements proposed in
the new IRO Reliability Standards focus
specifically on IROLs and are inclusive
of any reliability implications due to
parallel flows.
50. In support of retiring
Requirements R1 and R2 of IRO–004–1,
NERC posits that under the Functional
Model, the reliability coordinator is the
functional entity with primary
responsibility for IROLs and the
transmission operator is the functional
entity with primary responsibility for
SOLs. NERC states that, under certain
circumstances, the transmission
operator may request the assistance of
its reliability coordinator in developing
an SOL but the responsibility for
addressing the SOL remains with the
transmission operator.38 NERC explains
that, under the Functional Model and
Requirement R11 of Reliability Standard
TOP–002–2, the transmission operator
is responsible for conducting analyses to
identify where there may be instances of
exceeding SOLs. NERC also states that,
under TOP–008–1, the transmission
operator is responsible for taking actions
to either prevent or mitigate instances of
exceeding SOLs. NERC states that, by
contrast, it is the reliability coordinator
that is responsible for ensuring that
IROLs are developed for its reliability
coordinator area in accordance with a
methodology developed by the
reliability coordinator. Further, NERC
states that the transmission operator
must share its SOLs with its reliability
coordinator, and the reliability
coordinator must share any SOLs it
develops with its transmission operator.
NERC states that the reliability
coordinator monitors the status of some,
but not all, SOLs.
37 Reliability
Standard IRO–004–1, Requirement
R2.
38 See Reliability Standard TOP–008–1, requiring
transmission operators to take action to prevent or
mitigate violations of SOLs.
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51. NERC also contends that, upon
proposed Reliability Standard IRO–009–
1 becoming effective, Requirements R3
and R6 of currently-effective IRO–004–
0 should be retired. Under Requirement
R3 of IRO–004–0, reliability
coordinators must, in conjunction with
its transmission operators and balancing
authorities, develop action plans,
including for reducing load to return
transmission loading to within
acceptable SOLs or IROLs. NERC states
that the use of the phrase, ‘‘in
conjunction with’’ is not supported by
the responsibilities of the reliability
coordinator in the Functional Model
and would be inconsistent with the
requirements of proposed Reliability
Standard IRO–009–1. NERC also states
that proposed Requirement R3 of IRO–
009–1 includes language that is more
explicit than the language in
Requirement R6 of existing Reliability
Standard IRO–004–1.
52. Finally, NERC proposes to retire
Requirements R4 and R5 from IRO–004–
1. Requirement R4 requires each
transmission operator, balancing
authority, transmission owner, generator
owner, generator operator, and loadserving entity in the reliability
coordinator area to provide information
required for system studies. NERC
proposes to retire Requirement R4
because it identifies only a fraction of
the reliability-related data needed by the
reliability coordinator. Requirement R5
requires each reliability coordinator to
share the results of its system studies
with other reliability coordinators and
transmission operators, balancing
authorities, and transmission service
providers within its reliability
coordinator area. NERC states that
proposed Reliability IRO–010–1a offers
a suitable replacement for currentlyeffective Requirements R4 and R5
because IRO–010–1a requires reliability
coordinators to know, in advance, what
data and information it needs and what
data and information it needs to share
with other reliability entities. In
addition, requirement R3 of proposed
Reliability Standard IRO–008–1 would
require the reliability coordinator to
share the results of its analyses with
entities within its reliability coordinator
area.
NOPR Proposal
53. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard IRO–004–
2, as just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. The Commission
recognizes NERC’s efforts to more
clearly define which functional entity
has the ultimate responsibility for SOLs
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and IROLs, and to synchronize existing
standards with the proposed new IRO
Reliability Standards. We propose to
find that the requirements proposed for
retirement from IRO–004–1 are
appropriately addressed in new
Reliability Standards IRO–008–1, IRO–
009–1, and IRO–010–1a.
reliability coordinator to collect and
relay interchange information to other
entities. If a reliability coordinator
needs this information, NERC states that
the reliability coordinator can add this
item to the list of data and information
on its data specification under proposed
Requirement R1 of IRO–010–1a.
4. IRO–005–3
54. NERC proposes to retire
Requirement R2, R3, R5, R16, and R17
of currently-effective Reliability
Standard IRO–005–2, and to modify
Requirements R9, R13, and R14. To
implement these revisions, NERC
requests Commission approval of
proposed Reliability Standard IRO–005–
3. The purpose of proposed Reliability
Standard IRO–005–3 is to require the
reliability coordinator to be
continuously aware of conditions
within its reliability coordinator area
and include this information in its
reliability assessments. In addition, the
reliability coordinator must monitor the
bulk electric system parameters that
may have significant impacts upon the
reliability coordinator area and
neighboring reliability coordinator
areas. IRO–005–3 would apply to
reliability coordinators, balancing
authorities, transmission operators,
transmission service providers,
generator operators, load-serving
entities, and purchasing-selling entities.
55. NERC contends that, upon the
new IRO Reliability Standards becoming
effective, Requirements R2, R3, R5, R16,
and R17 of IRO–005–2 should be retired
and Requirements R9, R13, and R14
should be modified. Except for
Requirement R2, all of the requirements
proposed for retirement set
responsibilities for the reliability
coordinator to be continuously aware of
SOLs and IROLs within its reliability
coordinator area and to identify the
cause for each SOL and IROL. Similarly,
all of the requirements proposed for
modification include requirements for
the reliability coordinator to address
SOLs and for the transmission operator
to address IROLs. NERC contends that
these existing requirements should be
retired or modified in light of the
division of responsibilities between
reliability coordinators and
transmission operators expressed in
new Reliability Standard IRO–009–1.
56. Requirement R2 requires the
reliability coordinator ‘‘to be aware of’’
all interchange transactions that wheel
through its reliability coordinator area.
NERC contends that it is not possible to
measure how an entity is ‘‘aware of’’
specific information. In addition, NERC
states that the e-tag system that has been
implemented no longer requires the
NOPR Proposal
57. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard IRO–005–
3, as just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. The Commission
recognizes NERC’s efforts to more
clearly define which functional entity
has the ultimate responsibility for SOLs
and IROLs, and to synchronize existing
standards with the proposed new IRO
Reliability Standards. We propose to
find that the requirements of IRO–005–
2 proposed for retirement and
modification are appropriately
addressed in new Reliability Standards
IRO–008–1, IRO–009–1, and IRO–010–
1a.
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5. TOP–003–1
58. NERC proposes to modify
Requirement R1.2 of currently-effective
Reliability Standard TOP–003–0. To
implement this revision, NERC requests
approval of proposed Reliability
Standard TOP–003–1. The purpose of
TOP–003–1 is to require balancing
authorities, transmission operators, and
reliability coordinators to plan and
coordinate scheduled generator and
transmission outages that may affect the
reliability of interconnected operations.
TOP–003–1 would apply to generator
operators, transmission operators,
balancing authorities, and reliability
coordinators.
59. NERC explains that Requirement
R1.2 of TOP–003–0 includes two
distinct activities—a requirement for the
transmission operator to provide the
reliability coordinator and other entities
with daily outage information and a
requirement for the reliability
coordinator to establish outage reporting
requirements. NERC contends that both
elements of Requirement R1.2 are
captured in proposed Reliability
Standard IRO–010–1a. NERC proposes
to remove the transmission operator’s
obligation to provide daily outage
information to reliability coordinators
and strike the requirement for the
reliability coordinator to establish
outage reporting requirements.
According to NERC, Requirement R1
of proposed IRO–010–1a requires the
reliability coordinator to specify what
data and information it needs, as well as
the frequency and format for providing
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that data and information. NERC states
that, because the reliability coordinator
needs outage data for modeling and
analysis, the specification will include
outage data. Requirement R3 of IRO–
010–1a requires entities to provide data
and information to the reliability
coordinator in accordance with the
reliability coordinator’s specifications.
NERC states that if TOP–003–0
Requirement R1.2 is not modified, it
will be redundant with IRO–010–1a,
Requirement R3.
NOPR Proposal
60. Under section 215(d)(2) of the
FPA, we propose to approve Reliability
Standard TOP–003–1, as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. We propose to find that the
requirements of currently-effective
Reliability Standard TOP–003–0 that
NERC proposed for modification are
appropriately addressed in new
Reliability Standard IRO–010–1a.
However, under Requirement R3, it is
incumbent on the reliability coordinator
to request sufficient scheduled outage
data. The Commission is concerned that
IRO–010–1a does not specify outage
coordination data and the reliability
coordinator may not receive adequate
outage coordination data to support the
Operational Planning Analysis.
Therefore, the Commission seeks
comments from NERC and the public on
whether IRO–010–1a should specify the
necessary outage coordination data.
6. TOP–005–2
61. NERC proposes to retire
Requirements R1 and R1.1 of currentlyeffective Reliability Standard TOP–005–
1 and modify Attachment 1 of the
Reliability Standard. To implement
these revisions, NERC requests approval
of proposed Reliability Standard TOP–
005–2. The purpose of TOP–005–2 is to
ensure reliability entities have the
operating data needed to monitor
system conditions within their areas.
TOP–005–2 would apply to
transmission operators, balancing
authorities, and purchasing selling
entities.
62. Requirement R1 of TOP–005–1
requires transmission operators to
provide the reliability coordinator with
the data and information that the
reliability coordinator needs to perform
its reliability-related tasks. Requirement
R1.1 of TOP–005–1 requires reliability
coordinators to identify the data
requirements, listed in Attachment 1 of
TOP–005–1, and any additional
operating information requirements
relating to the operation of the BulkPower System with its reliability
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coordinator area. NERC states that
Requirement R1 implies that the
reliability coordinator will limit its use
of the data and information it collects to
operations within its reliability
coordinator area. According to NERC,
this does not support the Functional
Model, which requires the reliability
coordinator to monitor the Wide-Area.
NERC states that, under other Reliability
Standards such as IRO–014–1 and IRO–
015–1, each reliability coordinator is
expected to coordinate the activities
within its reliability coordinator area
with other reliability coordinators.
63. NERC states that, under proposed
Reliability Standard IRO–010–1a, each
reliability coordinator must document
what data and information it needs and
which entities must provide that data.
NERC explains that the reliability
coordinator needs this data to perform
reliability assessments and for real-time
monitoring. Under the Functional
Model, the reliability coordinator
collects data and information not just
from transmission operators and
balancing authorities, but also from
generator operators, load-serving
entities, transmission owners, and
generator owners.
64. NERC also proposes conforming
revisions to Attachment 1 to TOP–005–
2. As currently written, Attachment 1 of
TOP–005–1 lists the types of data that
reliability coordinators, balancing
authorities, and transmission operators
are expected to provide, and are
expected to share with each other.
Consistent with the proposed revisions
in Reliability Standard TOP–005–2,
NERC proposes to remove references to
the reliability coordinator from
Attachment 1.
NOPR Proposal
65. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard TOP–005–
2, as just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. The Commission
recognizes NERC’s efforts to more
clearly define the reliability
coordinator’s need to know, in advance,
what data is needed, insure the timely
availability of the data; and how that
data will be communicated to other
functional entities. We propose to find
that the requirements of TOP–005–1
that are proposed for retirement are
appropriately addressed in new
Reliability Standard IRO–010–1a. We
are concerned, however, about whether
the proposal adequately ensures the
compatibility of data between
neighboring reliability coordinators.
Having compatible data allows for an
essential level of interoperability. The
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Commission requests comment from the
reliability coordinators and the industry
on whether a list of minimum ‘‘Electric
System Reliability Data,’’ such as shown
in Attachment 1 of currently-effective
Reliability Standard TOP–005–1, is
beneficial for reliability coordinators to
meet the requirements of IRO–008–1
and IRO–009–1.
supporting data for the load forecast;
and how that data will communicated to
other functional entities. We propose to
find that the reliability coordinator
functions that are removed from
Requirement R4 of TOP–006–2 are
appropriately addressed in
Requirements R1 and R3 of new
Reliability Standard IRO–010–1a.
7. TOP–006–2
66. NERC proposes to modify
Requirement R4 of currently-effective
Reliability Standard TOP–006–1. To
implement this revision, NERC requests
approval of proposed Reliability
Standard TOP–006–2. The purpose of
TOP–006–2 is to ensure critical
reliability parameters are monitored in
real-time. Its requirements would be
applicable to transmission operators,
balancing authorities, generator
operators, and reliability coordinators.
67. Requirement R4 of TOP–006–1
requires each reliability coordinator,
transmission operator, and balancing
authority to have information, including
weather forecasts and past load patterns,
available to predict the system’s nearterm load pattern. NERC proposes to
modify Requirement R4 by removing the
reference to reliability coordinators.
NERC states that the information
identified in existing Requirement R4 of
TOP–006–1 is not inclusive, and is
addressed more globally for the
reliability coordinator in Requirements
R1 and R3 of the proposed new
Reliability Standard IRO–010–1a.
Proposed Requirement R1 of IRO–010–
1a requires each reliability coordinator
to have a documented specification for
data and information to build and
maintain models to support real-time
monitoring, operational planning
analyses, and real-time assessments of
its reliability coordinator area to prevent
instability, uncontrolled separation, and
cascading outages. Requirement R3 of
IRO–010–1a requires each balancing
authority, generator owner, generator
operator, interchange authority, loadserving entity, reliability coordinator,
transmission operator, and transmission
owner to provide data and information,
as specified, to their reliability
coordinator.
D. Violation Severity Levels and
Violation Risk Factors
NOPR Proposal
68. Under section 215(d)(2) of the
FPA, the Commission proposes to
approve Reliability Standard TOP–006–
2, as just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. The Commission
recognizes NERC’s efforts to more
clearly define the reliability
coordinator’s need to know, in advance,
what load forecast data is needed, the
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69. In the event of a violation of a
Reliability Standard, NERC will
establish the initial value range for the
corresponding base penalty amount. To
do so, NERC will assign a violation risk
factor for each requirement of a
Reliability Standard that relates to the
expected or potential impact of a
violation of the requirement on the
reliability of the Bulk-Power System. In
addition, NERC will define up to four
violation severity levels—Lower,
Moderate, High, and Severe—as
measurements for the degree to which
the requirement was violated in a
specific circumstance.
70. In Order No. 705, the Commission
approved 63 of NERC’s 72 proposed
violation risk factors for the version one
FAC Reliability Standards and directed
NERC to file violation severity level
assignments before the version one FAC
Reliability Standards become
effective.39 Subsequently, NERC
developed violation severity levels for
each requirement of the Commissionapproved FAC Reliability Standards, as
measurements for the degree to which
the requirement was violated in a
specific circumstance.
71. On June 19, 2008, the Commission
issued its Violation Severity Level Order
approving the violation severity level
assignments filed by NERC for the 83
Reliability Standards approved in Order
No. 693.40 In that order, the Commission
offered four guidelines for evaluating
the validity of violation severity levels,
and ordered a number of reports and
further compliance filing to bring the
remainder of NERC’s violation severity
levels into conformance with the
Commission’s guidelines. The four
guidelines are: (1) Violation severity
level assignments should not have the
unintended consequence of lowering
the current level of compliance; (2)
violation severity level assignments
should ensure uniformity and
consistency among all approved
Reliability Standards in the
39 Facilities Design, Connections and
Maintenance Reliability Standards, Order No. 705,
121 FERC ¶ 61,296, at P 137 (2007).
40 Violation Severity Level Order, 123 FERC
¶ 61,284.
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determination of penalties; 41 (3)
violation severity level assignments
should be consistent with the
corresponding requirement; and (4)
violation severity level assignments
should be based on a single violation,
not a cumulative number of
violations.42 The Commission found
that these guidelines will provide a
consistent and objective means for
assessing, inter alia, the consistency,
fairness and potential consequences of
violation severity level assignments.
The Commission noted that these
guidelines were not intended to replace
NERC’s own guidance classifications,
but rather, to provide an additional level
of analysis to determine the validity of
violation severity level assignments.
72. On August 10, 2009, NERC
submitted an informational filing setting
forth a summary of revised guidelines
that NERC intends to use in determining
the assignment of violation risk factors
and violation severity levels for
Reliability Standards. NERC states that
these revised guidelines were consistent
with Commission’s guidelines. On May
5, 2010, NERC submitted the subject
informational filing as a supplement to
its March 5, 2010 Violation Severity
Level Order compliance filing.43
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NERC Proposal
73. NERC proposes a complete set of
violation severity levels and violation
risk factors for proposed new Reliability
Standards IRO–008–1, IRO–009–1, and
IRO–010–1a. In addition, NERC
proposes to apply the existing set of
violation severity levels and violation
risk factors assigned to the proposed
modified requirements.
74. NERC states that it developed the
violation severity levels for the new IRO
Reliability Standards before the
Commission issued its June 19, 2008
order on violation severity levels.44
NERC also notes that the proposed
violation severity levels were developed
before NERC proposed a new
methodology for assigning violation
severity levels and violation risk
factors.45 As a result, NERC states that
41 Guideline 2 contains two sub-parts: (a) The
single violation severity level assignment category
for binary requirements should be consistent and
(b) violation severity levels assignments should not
contain ambiguous language.
42 Violation Severity Level Order, 123 FERC
¶ 61,284 at P 17.
43 North American Reliability Corporation, Filing
of the North American Electric Reliability
Corporation regarding the Assignment of Violation
Risk Factors and Violation Severity Levels, Docket
No. RR08–4–005 (filed May 5, 2010).
44 Id.
45 NERC, Informational Filing Regarding the
Assignment of Violation Risk Factors and Violation
Severity Levels, Docket Nos. RM08–11–000, RR07–
9–000, and RR07–10–000, (filed Aug. 10, 2009).
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some of the proposed violation severity
levels do not comport with the
Commission’s guidelines on violation
severity levels and some do not comport
with the NERC’s revised guidelines.
NERC has identified differences and
commits to propose revisions to the
violation severity levels.
NOPR Proposal
75. The Commission proposes to
accept the proposed violation risk
factors and violation severity levels
presented in NERC’s petition. In
addition, we propose to accept NERC’s
commitment to review the proposed
violation risk factors and violation
severity levels to ensure compliance
with the Commission’s guidelines.
Accordingly, we propose to direct NERC
to submit a compliance filing within six
months of the effective date of the final
rule in this proceeding that would
provide the results of NERC’s review
including any modifications necessary
to comply with the Commission’s
guidelines on violation risk factors and
violation severity levels.
76. The violation risk factors and
violation severity levels for proposed
new Reliability Standards IRO–008–1,
IRO–009–1, and IRO–010–1a, and the
proposed modified requirements also
would be impacted by NERC’s revised
guidelines for assigning violation
severity levels currently pending before
the Commission in Docket No. RR08–4–
005. Subject to Commission action on
NERC’s revised guidelines, NERC may
need to make additional revisions to the
proposed violation risk factors and
violation severity levels.
III. Information Collection Statement
77. The Office of Management and
Budget (OMB) regulations require
approval of certain information
collection requirements imposed by
agency rules.46 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 this 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.
The Paperwork Reduction Act (PRA) 47
requires each federal agency to seek and
obtain OMB approval before
undertaking a collection of information
directed to ten or more persons, or
continuing a collection for which OMB
approval and validity of the control
number are about to expire.48
CFR 1320.11.
U.S.C. 3501–20.
48 44 U.S.C. 3502(3)(A)(i), 44 U.S.C. 3507(a)(3).
71623
78. The Commission is submitting
these reporting and recordkeeping
requirements to OMB for its review and
approval under section 3507(d) of the
PRA. Comments are solicited on the
Commission’s need for this information,
whether the information will have
practical utility, the accuracy of
provided burden estimates, ways to
enhance the quality, utility, and clarity
of the information to be collected, and
any suggested methods for minimizing
the respondent’s burden, including the
use of automated information
techniques.
79. This NOPR proposes to approve
three new Reliability Standards, IRO–
008–1, IRO–009–1 and IRO–010–1a
governing reliability coordinator
analyses, operational actions and data
collection, which standards will replace
parts of the currently-effective
Reliability Standards EOP–001–0, IRO–
002–1, IRO–004–1, IRO–005–2, TOP–
003–0, TOP–005–1 and TOP–006–1
approved by the Commission in Order
No. 693. Many of the proposed
requirements are based requirements in
currently-effective Reliability Standards
and match common industry practice.
Thus, this proposed rulemaking does
not impose entirely new burdens on the
effected entities. With the exception of
the addition of Interchange Authority as
an applicable entity in IRO–010–1a, the
currently-effective standards EOP–001–
0, IRO–002–1, IRO–004–1, IRO–005–2,
TOP–003–0, TOP–005–1 and TOP–006–
1 require actions by the same applicable
group of entities. IRO–010–1a clarifies
for balancing authorities, generator
owners, generator operators, interchange
authorities, load-serving entities,
reliability coordinators, transmission
operators, and transmission owners
shall provide data and information, as
specified, to the reliability
coordinator(s) with which it has a
reliability relationship.49 The
requirements of IRO–008–1 and IRO–
009–a provide clarification from
existing requirements, dictating the
analysis and operational roles of the
reliability coordinator.
80. Public Reporting Burden: Our
estimate below regarding the number of
respondents is based on the NERC
compliance registry as of September 28,
2010. According to the NERC
compliance registry, there are 134
balancing authorities, 824 generator
owners, 773 generator operators, 61
interchange authorities, 541 loadserving entities, 26 reliability
coordinators, 178 transmission
operators, and 332 transmission owners
46 5
47 44
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49 Proposed Reliability Standard IRO–010–1a,
Requirement R3.
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that would be involved in providing
information. However, under NERC’s
compliance registration program,
entities may be registered for multiple
functions, and as such there is some
duplication of functions regarding the
number of registered entities that would
be required to provide information.
Number of
annual
responses
Number of
respondents
Data collection
Given these parameters, the
Commission estimates that the Public
Reporting burden for the requirements
contained in the NOPR is as follows:
Hours per
respondent
Total annual
hours
FERC–725A
Reliability Coordinators distribution of data specification to entities
Balancing Authorities, Generator Owners, Generator Operators,
Interchange Authorities, Load-serving Entities, Reliability Coordinators, Transmission Operators, and Transmission Owners
reporting data to their Reliability Coordinator ..............................
26
*1
8
208
1,501
*1
8
12,008
Total ..........................................................................................
............................
............................
............................
12,216
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* As needed.
• Total Annual hours for Collection:
(Reporting + recordkeeping) = hours.
Information Collection Costs: The
Commission seeks comments on the
costs to comply with the reporting and
recordkeeping burden associated with
the proposed Reliability Standards. It
has projected the average annualized
cost to be the total annual hours
Recordkeeping = 12,216 hours @
$120/hour = $1,465,920.
• Total costs = $1,465,920.
• Title: Mandatory Reliability
Standards for the Bulk-Power System.
• Action: Proposed Collection of
Information.
• OMB Control No: 1902–0244.
• Respondents: Business or other for
profit, and/or not for profit institutions.
• Frequency of Responses: Annually,
or as needed.
• Necessity of the Information: This
proposed rule would approve revised
Reliability Standards that create new
requirements for reliability coordinator
responsibilities. The proposed
Reliability Standards require entities to
supply required data and information
needed by the reliability coordinator.
• Internal review: The Commission
has reviewed the requirements
pertaining to the proposed Reliability
Standards for the Bulk-Power System
and determined that the proposed
requirements are necessary to meet the
statutory provisions of the Energy Policy
Act of 2005. 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 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: Federal
Energy Regulatory Commission, 888
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First Street, NE., Washington, DC 20426
[Attention: Ellen Brown, Office of the
Executive Director, Phone: (202) 502–
8663, fax: (202) 273–0873, e-mail:
DataClearance@ferc.gov]. Comments on
the requirements of this order may also
be sent to the Office of Information and
Regulatory Affairs, Office of
Management and Budget, Washington,
DC 20503 [Attention: Desk Officer for
the Federal Energy Regulatory
Commission]. For security reasons,
comments should be sent by e-mail to
OMB at oira_submission@omb.eop.gov.
Please reference docket number RM10–
15–000 in your submission.
IV. Environmental Analysis
82. 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.50 The actions proposed
here fall within the categorical
exclusion in the Commission’s
regulations for rules that are clarifying,
corrective or procedural, for information
gathering, analysis, and
dissemination.51 Accordingly, neither
an environmental impact statement nor
environmental assessment is required.
V. Regulatory Flexibility Act
Certification
83. The Regulatory Flexibility Act of
1980 (RFA) 52 generally requires a
description and analysis of final rules
that will have significant economic
impact on a substantial number of small
entities. The requirements of this rule
would apply primarily to reliability
coordinators, which do not fall within
50 Order No. 486, Regulations Implementing the
National Environmental Policy Act, 52 FR 47897
(Dec. 17, 1987), FERC Stats. & Regs. ¶ 30,783 (1987).
51 18 CFR 380.4(a)(5).
52 5 U.S.C. 601–12.
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the definition of small entities.53
Moreover, the proposed Reliability
Standards reflect a continuation of
existing requirements for reliability
coordinators and other entities to
monitor, analyze, prevent, and mitigate
the occurrence of operating limit
violations on the Bulk-Power System.
The one exception is the proposed new
requirements in Reliability Standard
IRO–010–1a for interchange authorities,
which also do not fall within the
definition of small entities. Based on the
foregoing, the Commission certifies that
this proposed rule will not have a
significant impact on a substantial
number of small entities. Accordingly,
no regulatory flexibility analysis is
required.
VI. Comment Procedures
84. 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 January 24, 2011.
Comments must refer to Docket No.
RM10–15–000, and must include the
commenter’s name, the organization
they represent, if applicable, and their
address in their comments.
85. The Commission encourages
comments to be filed electronically via
the eFiling link on the Commission’s
Web site at https://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
53 The RFA definition of ‘‘small entity’’ refers to
the definition provided in the Small Business Act
(SBA), which defines a ‘‘small business concern’’ as
a business that is independently owned and
operated and that is not dominant in its field of
operation. See 15 U.S.C. 632. According to the SBA,
a small electric utility is defined as one that has a
total electric output of less than four million MWh
in the preceding year.
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
format and not in a scanned format.
Commenters filing electronically do not
need to make a paper filing.
86. Commenters unable to file
comments electronically must mail or
hand-deliver an original copy of their
comments to: Federal Energy Regulatory
Commission, Secretary of the
Commission, 888 First Street, NE.,
Washington, DC 20426. These
requirements can be found on the
Commission’s Web site, see, e.g., the
‘‘Quick Reference Guide for Paper
Submissions,’’ available at https://
www.ferc.gov/docs-filing/efiling.asp or
via phone from FERC Online Support at
(202) 502–6652 or toll-free at 1–866–
208–3676.
87. 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.
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
18 CFR Part 40
[Docket No. RM10–16–000]
System Restoration Reliability
Standards
November 18, 2010.
Federal Energy Regulatory
Commission, DOE.
ACTION: Notice of proposed rulemaking.
AGENCY:
Under section 215 of the
Federal Power Act (FPA), the Federal
Energy Regulatory Commission
(Commission) proposes to approve
Reliability Standards EOP–001–1
(Emergency Operations Planning), EOP–
005–2 (System Restoration from
Blackstart Resources), and EOP–006–2
(System Restoration Coordination)
submitted to the Commission by the
North American Electric Reliability
Corporation, the Electric Reliability
VII. Document Availability
Organization (ERO) certified by the
Commission. In addition, the
88. In addition to publishing the full
Commission seeks comment from the
text of this document in the Federal
ERO and other interested parties
Register, the Commission provides all
regarding specific concerns. The
interested persons an opportunity to
Commission may determine that, after
view and/or print the contents of this
considering such comments, it is
document via the Internet through
appropriate to direct the ERO, under
FERC’s Home Page (https://www.ferc.gov) section 215(d)(5) of the FPA, to develop
and in FERC’s Public Reference Room
additional modifications to proposed
during normal business hours (8:30 a.m. EOP–005–2 and EOP–006–2. The
to 5 p.m. Eastern time) at 888 First
proposed Reliability Standards require
Street, NE., Room 2A, Washington DC
that plans, facilities and personnel are
20426.
prepared to enable system restoration
89. From FERC’s Home Page on the
using designated blackstart resources.
Internet, this information is available on DATES: Comments are due January 24,
eLibrary. The full text of this document
2011.
is available on eLibrary in PDF and
ADDRESSES: You may submit comments,
Microsoft Word format for viewing,
identified by Docket No. RM10–16–000
printing, and/or downloading. To access
and in accordance with the
this document in eLibrary, type the
requirements posted on the
docket number excluding the last three
Commission’s Web site, https://
digits of this document in the docket
www.ferc.gov. Comments may be
number field.
submitted by any of the following
90. User assistance is available for
methods:
eLibrary and the FERC’s Web site during
• Agency Web Site: Documents
normal business hours from FERC
created electronically using word
Online Support at (202) 502–6652 (toll
processing software should be filed in
free at 1–866–208–3676) or e-mail at
native applications or print-to-PDF
ferconlinesupport@ferc.gov, or the
format, and not in a scanned format, at
Public Reference Room at (202) 502–
https://www.ferc.gov/docs-filing/
8371, TTY (202) 502–8659. E-mail the
efiling.asp.
Public Reference Room at
• Mail/Hand Delivery: Commenters
public.referenceroom@ferc.gov.
unable to file comments electronically
must mail or hand deliver their
By direction of the Commission.
comments to: Federal Energy Regulatory
Kimberly D. Bose,
Commission, Secretary of the
Secretary.
Commission, 888 First Street, NE.,
[FR Doc. 2010–29575 Filed 11–23–10; 8:45 am]
Washington, DC 20426. These
requirements can be found on the
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Commission’s Web site, see, e.g., the
‘‘Quick Reference Guide for Paper
Submissions,’’ available at https://
www.ferc.gov/docs-filing/efiling.asp or
via phone from FERC Online Support at
202–502–6652 or toll-free at 1–866–
208–3676.
FOR FURTHER INFORMATION CONTACT:
David O’Connor (Technical
Information), Office of Electric
Reliability, Division of Reliability
Standards, Federal Energy Regulatory
Commission, 888 First Street, NE.,
Washington, DC 20426, (202) 502–
6695.
Nick Henery (Technical Information),
Office of Electric Reliability, Division
of Reliability Standards, Federal
Energy Regulatory Commission, 888
First Street, NE. Washington, DC
20426, (202) 502–8636.
Terence Burke (Legal Information),
Office of the General Counsel, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, (202) 502–6498.
Jonathan First (Legal Information),
Office of the General Counsel, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, (202) 502–8529.
SUPPLEMENTARY INFORMATION:
Notice of Proposed Rulemaking
1. Under section 215 of the Federal
Power Act (FPA),1 the Commission
proposes to approve three Reliability
Standards, EOP–001–1 (Emergency
Operations Planning), EOP–005–2
(System Restoration from Blackstart
Resources), and EOP–006–2 (System
Restoration Coordination) developed by
the North American Electric Reliability
Corporation (NERC), the Commissioncertified Electric Reliability
Organization (ERO), as well as the
definition of the term ‘‘Blackstart
Resource’’ to be added to the NERC
Glossary of Terms. The proposed
Reliability Standards were drafted to
ensure plans, facilities and personnel
are prepared to enable system
restoration from blackstart resources in
order that reliability is maintained
during system restoration. The
Commission also seeks comment from
the ERO and other interested entities
regarding the Commission’s specific
concerns discussed below. The
Commission may determine that, after
considering such comments, it is
appropriate to direct the ERO, under
section 215(d)(5) of the FPA, to develop
additional modifications to proposed
EOP–005–2 and EOP–006–2. The
Commission also proposes to approve
1 16
E:\FR\FM\24NOP1.SGM
U.S.C. 824o (2006).
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Agencies
[Federal Register Volume 75, Number 226 (Wednesday, November 24, 2010)]
[Proposed Rules]
[Pages 71613-71625]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-29575]
=======================================================================
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
18 CFR Part 40
[Docket No. RM10-15-000]
Mandatory Reliability Standards for Interconnection Reliability
Operating Limits
November 18, 2010.
AGENCY: Federal Energy Regulatory Commission.
ACTION: Notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: Under section 215 of the Federal Power Act, the Federal Energy
Regulatory Commission proposes to approve three new Interconnection
Reliability Operations and Coordination Reliability Standards and seven
revised Reliability Standards related to Emergency Preparedness and
Operations, Interconnection Reliability Operations and Coordination,
and Transmission Operations. These proposed Reliability Standards were
submitted to the Commission for approval 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. The proposed Reliability
Standards were designed to prevent instability, uncontrolled
separation, or cascading outages that adversely impact the reliability
of the interconnection by ensuring prompt action to prevent or mitigate
instances of exceeding Interconnection Reliability Operating Limits.
The Commission also proposes to approve the addition of two new terms
to the NERC Glossary of Terms. In addition, pursuant to section
215(d)(5) of the Federal Power Act, the Commission proposes to direct
NERC to develop a modification to the proposed term ``Real-time
Assessment'' to address a specific concern identified by the
Commission. The Commission raises some concerns with regard to certain
aspects of NERC's proposals and, based on the responses from NERC and
industry, may choose to direct certain modifications to the proposed
new and revised Reliability Standard, as well as the new Glossary
Terms, as discussed below.
DATES: Comments are due January 24, 2011.
ADDRESSES: You may submit comments, identified by docket number and in
accordance with the requirements posted on the Commission's Web site,
https://www.ferc.gov. Comments may be submitted by any of the following
methods:
Agency Web site: Documents created electronically using
word processing software should be filed in native applications or
print-to-PDF format, and not in a scanned format, at https://www.ferc.gov/docs-filing/efiling.asp.
Mail/Hand Delivery: Commenters unable to file comments
electronically must mail or hand-deliver an original copy of their
comments to: Federal Energy Regulatory Commission, Secretary of the
Commission, 888 First Street, NE., Washington, DC 20426. These
requirements can be found on the Commission's Web site, see, e.g., the
``Quick Reference Guide for Paper Submissions,'' available at
https://www.ferc.gov/docs-filing/efiling.asp or via phone from FERC
Online Support at (202) 502-6652 or toll-free at 1-866-208-3676.
FOR FURTHER INFORMATION CONTACT:
Darrell Piatt (Technical Information), Office of Electric Reliability,
Division of Reliability Standards, Federal Energy Regulatory
Commission, 888 First Street, NE., Washington, DC 20426, Telephone:
(202) 502-6687;
A. Cory Lankford (Legal Information), Office of the General Counsel,
Federal Energy Regulatory Commission, 888 First Street, NE. Washington,
DC 20426, Telephone: (202) 502-6711;
William Edwards (Legal Information), Office of the General Counsel,
Federal
[[Page 71614]]
Energy Regulatory Commission, 888 First Street, NE., Washington, DC
20426, Telephone: (202) 502-6669.
SUPPLEMENTARY INFORMATION:
Table of Contents
Paragraph
numbers
I. Background............................................... 3
A. Mandatory Reliability Standards...................... 3
B. Order No. 693 Directives............................. 4
II. Discussion.............................................. 7
A. System Operating Limits.............................. 10
B. Proposed New Reliability Standards................... 22
1. IRO-008-1........................................ 22
2. IRO-009-1........................................ 30
3. IRO-010-1a....................................... 33
C. Proposed Revised Reliability Standards............... 38
1. EOP-001-1........................................ 38
2. IRO-002-2........................................ 42
3. IRO-004-2........................................ 47
4. IRO-005-3........................................ 54
5. TOP-003-1........................................ 58
6. TOP-005-2........................................ 61
7. TOP-006-2........................................ 66
D. Violation Severity Levels and Violation Risk Factors. 69
III. Information Collection Statement....................... 77
IV. Environmental Analysis.................................. 82
V. Regulatory Flexibility Act Certification................. 83
VI. Comment Procedures...................................... 84
VII. Document Availability.................................. 88
Notice of Proposed Rulemaking
1. Under section 215 of the Federal Power Act (FPA),\1\ the Federal
Energy Regulatory Commission (Commission) proposes to approve three new
Interconnection Reliability Operations and Coordination (IRO)
Reliability Standards and seven revised Reliability Standards related
to Emergency Preparedness and Operations (EOP), IRO, and Transmission
Operations (TOP). The proposed Reliability Standards were submitted to
the Commission for approval by the North American Electric Reliability
Corporation (NERC), which the Commission has certified as the Electric
Reliability Organization (ERO) responsible for developing and enforcing
mandatory Reliability Standards.\2\ The proposed Reliability Standards
were designed to prevent instability, uncontrolled separation, or
cascading outages that adversely impact the reliability of the
interconnection by ensuring prompt action to prevent or mitigate
instances of exceeding interconnection reliability operating limits
(IROL). The Commission also proposes to approve the addition of two new
terms to the NERC Glossary of Terms (NERC Glossary). In addition,
pursuant to section 215(d)(5) of the Federal Power Act, the Commission
proposes to direct NERC to develop a modification to the proposed term
``Real-time Assessment'' to address a specific concern identified by
the Commission. The Commission raises some concerns with regard to
certain aspects of these proposals and, based on the responses from
NERC and from industry, may choose to direct certain modifications to
the proposed new and revised Reliability Standard, as well as the new
Glossary Terms, as discussed below.
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\1\ 16 U.S.C. 824o.
\2\ North American Electric Reliability Corp., 116 FERC ]
61,062, order on reh'g & compliance, 117 FERC ] 61,126 (2006), aff'd
sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (DC Cir. 2009).
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2. The three new Reliability Standards proposed by NERC are
designated as IRO-008-1 (Reliability Coordinator Operational Analyses
and Real-time Assessments), IRO-009-1 (Reliability Coordinator Actions
to Operate Within IROLs), and IRO-010-1a \3\ (Reliability Coordinator
Data Specification and Collection). In preparing these new Reliability
Standards, the standards drafting team determined that it was necessary
to retire or modify certain requirements from several existing
standards. Accordingly, NERC requests Commission approval of revised
Reliability Standards EOP-001-2,\4\ IRO-002-2, IRO-004-2, IRO-005-3,
and TOP-006-2. NERC also proposes to add the following new terms to the
NERC Glossary: ``Operational Planning Analysis'' and ``Real-time
Assessment.'' \5\
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\3\ NERC designates the version number of a Reliability Standard
as the last digit of the Reliability Standard number. Therefore,
original Reliability Standards end with ``-0'' and modified version
one Reliability Standards end with ``-1.'' The NERC Board of
Trustees approved the proposed IRO-010-1 Reliability Standard on
October 17, 2008. Subsequently, on August 5, 2009, the NERC Board of
Trustees approved an interpretation to the proposed IRO-010-1
standard. Accordingly, NERC is requesting approval of both the
proposed standard and the appended interpretation, and NERC has
designated the proposed standard and appended interpretation as IRO-
010-1a.
\4\ Concurrent with its filing in this Docket, NERC filed a
petition in Docket No. RM10-16-000 seeking approval of certain
Emergency Preparedness and Operations Reliability Standards. NERC,
Petition for Approval of Three Emergency Preparedness and Operations
Reliability Standards, Docket No. RM10-16-000 (filed Dec. 31, 2009).
As part of its filing in RM10-16-000, NERC proposed to retire
Requirement R3.4 of EOP-001-0. Each petition proposes unique changes
to EOP-001-0 reflecting the distinct issues addressed by the
respective Reliability Standards drafting teams. NERC indicated in
both petitions that it could not anticipate the sequence in which
the Commission would act and therefore included two sets of proposed
amendments to EOP-001-0 in each petition. The Commission will
clarify upon issuance of Final Rules in each proceeding which
revised version of EOP-001-0 it is addressing in its determination.
\5\ The proposed new Reliability Standards and other modified
Reliability Standards are not codified in the CFR and are not
attached to the NOPR. They are, however, available on the
Commission's eLibrary document retrieval system in Docket No. RM10-
15-000 and are available on the ERO's Web site, https://www.nerc.com.
---------------------------------------------------------------------------
I. Background
A. Mandatory Reliability Standards
3. 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
[[Page 71615]]
enforced by the ERO, subject to Commission oversight, or by the
Commission independently.
B. Order No. 693 Directives
4. On March 16, 2007, the Commission issued Order No. 693,
approving 83 of the 107 initial Reliability Standards filed by NERC,
including the existing IRO Reliability Standards.\6\ Under section
215(d)(5) of the FPA, the Commission directed NERC to develop
modifications to the IRO Reliability Standards to address certain
issues identified by the Commission.
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\6\ 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).
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5. With respect to IRO-001-1, the Commission directed the ERO to
develop modifications to eliminate the regional reliability
organization as an applicable entity.\7\ The Commission also directed
the ERO to modify IRO-002-1 to require a minimum set of capabilities
that must be made available to the reliability coordinator to ensure
that a reliability coordinator has the capabilities it needs to perform
its functions.\8\ With respect to IRO-003-2, the Commission directed
the ERO to develop a modification to create criteria to define the term
``critical facilities'' in a reliability coordinator's area and its
adjacent systems.\9\ The Commission also directed the ERO to modify
IRO-004-1 to require the next-day analysis to identify control actions
that can be implemented and effective within 30 minutes after a
contingency. In addition, the Commission directed the ERO to consider
adding Measures and Levels of Non-Compliance to Reliability Standards
IRO-004-1 and IRO-005-1 that are commensurate with the magnitude,
duration, frequency and causes of the violations and whether these
occur during normal or contingency conditions.\10\
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\7\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 896.
\8\ Id. P 908.
\9\ Id. P 914.
\10\ Id. P 935. NERC has subsequently replaced Levels of Non-
Compliance with Violation Severity Levels. See Order on Violation
Severity Levels Proposed by the Electric Reliability Organization,
123 FERC ] 61,284 (Violation Severity Level Order), order on reh'g,
125 FERC ] 61,212 (2008).
---------------------------------------------------------------------------
6. The Commission also directed the ERO to conduct a survey on IROL
practices and actual operating experiences by requiring reliability
coordinators to report any violations of IROLs, their causes, the date
and time, the durations and magnitudes in which actual operations
exceed IROLs to the ERO on a monthly basis for one year beginning two
months after the effective date of Order No. 693.\11\ On October 31,
2008, NERC filed the results of its year-long survey with the
Commission.\12\ On February 8, 2009, NERC supplemented those results in
a second filing.\13\
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\11\ Id. P 951.
\12\ NERC, Compliance Filing, Docket No. RM06-16-006 (filed Oct.
31, 2008).
\13\ NERC, Compliance Filing, Docket No. RM06-16-006 (filed Feb.
8, 2009).
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II. Discussion
7. In a December 31, 2009 filing (NERC Petition),\14\ NERC requests
Commission approval of proposed Reliability Standards IRO-008-1, IRO-
009-1, and IRO-010-1a. NERC contends that these new Reliability
Standards would address certain Commission directives from Order No.
693. In developing the new IRO Reliability Standards, NERC determined
that it was necessary to retire or modify certain requirements from
several existing standards. Accordingly, NERC proposes revised
Reliability Standards EOP-001-1, IRO-002-2, IRO-004-2, IRO-005-3, TOP-
003-1, TOP-005-2, and TOP-006-2. NERC also requests approval of new
definitions ``Operational Planning Analysis'' and ``Real-time
Assessment.''
---------------------------------------------------------------------------
\14\ North American Electric Reliability Corp., Dec. 31, 2009
Petition for Approval of Proposed New and Revised Reliability
Standards for Operating Within Interconnection Operating Limits
(NERC Petition).
---------------------------------------------------------------------------
8. As discussed below, the Commission proposes to approve new
Reliability Standards IRO-008-1, IRO-009-1, and IRO-010-1a. The
Commission also proposes to approve revised Reliability Standards EOP-
001-1, IRO-002-2, IRO-004-2, IRO-005-3, TOP-003-1, TOP-005-2, and TOP-
006-2 as well as the two new NERC Glossary terms.
9. In addition, the Commission seeks comment on specific concerns
related to the proposed IRO Reliability Standards, as set forth below.
A. System Operating Limits
10. To maintain the reliable operation of the Bulk-Power System,
reliability coordinators, balancing authorities, and transmission
operators must be aware of the applicable system operating limits
(SOLs) and interconnection reliability operating limits (IROLs) on
their system. NERC defines SOLs as the value (such as MW, MVar,
Amperes, Frequency or Volts) that satisfies the most limiting of the
prescribed operating criteria for a specific system configuration to
ensure operation within acceptable reliability criteria. These SOLs are
based upon certain operating criteria. IROLs are, essentially, a subset
of SOLs. NERC defines IROLs as the value (such as MW, MVar, Amperes,
Frequency or Volts) derived from, or a subset of the SOLs, which if
exceeded, could expose a widespread area of the bulk electric system to
instability, uncontrolled separation, or cascading outages.\15\
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\15\ See NERC Glossary, available at https://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf.
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NERC Proposal
11. The proposed IRO Reliability Standards together with the
proposed revisions to existing Reliability Standards would divide
responsibility for SOLs and IROLs between reliability coordinators and
transmission operators according to the Functional Model.\16\ NERC
explains that having two entities with the same primary responsibility
is not supported by the Functional Model. However, NERC notes that the
proposed Reliability Standards should not imply that the reliability
coordinator will not look at its future operations with respect to
specific SOLs.\17\ NERC states that the reliability coordinator must
look at its future operations with respect to specific SOLs to ensure
that their transmission operators are taking actions at appropriate
times, but the primary responsibility for SOLs rests with the
transmission operators. NERC explains that, under the proposed
Reliability Standards, the reliability coordinator retains overall
visibility of all operations within its Wide-Area view, including some
SOLs, although the transmission operator is primarily responsible for
actions related to SOLs.\18\ NERC states that the IRO standards were
developed in support of the authority and assignment of tasks in the
Functional Model.\19\ NERC explains that under the Functional Model,
while reliability coordinators will assign their transmission operators
tasks associated with IROLs, the reliability coordinator has ultimate
responsibility for these tasks, and the reliability coordinator is
sanctioned if these tasks are not performed as required by the
Reliability Standards.\20\
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\16\ NERC, Reliability Functional Model, version 5, at 30 (Nov.
2009), available at https://www.nerc.com/files/Functional_Model_V5_Final_2009Dec1.pdf.
\17\ NERC Petition at 77.
\18\ Id. at 78.
\19\ Id. at 7-9.
\20\ Id. at 8.
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12. NERC explains that, under the Functional Model, the reliability
coordinator is the functional entity with the highest level of
responsibility and authority for real-time reliability of the Bulk-
Power System. NERC states that the reliability coordinator is
responsible
[[Page 71616]]
for identifying the subset of SOLs that are known as IROLs, and may
direct its transmission operators to take actions associated with
IROLs. In assigning a single task to a single functional entity, under
the Functional Model, the reliability coordinator is the sole
functional entity responsible for developing IROLs and for actions to
prevent/mitigate instances of exceeding IROLs. While the transmission
operator has no ``direct'' responsibility for developing IROLs, the
transmission operator may be assigned the task of developing some
IROLs, monitoring real-time values against identified IROLs, and taking
actions to prevent reaching an IROL or to mitigate an instance of
exceeding an IROL. However, the transmission operator only performs
these tasks when directed to do so by its reliability coordinator.\21\
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\21\ Id.
---------------------------------------------------------------------------
13. NERC further explains that, in a similar fashion, the
Functional Model assigns responsibility for SOLs that are not IROLs to
the transmission operator. But, NERC states, this too is a shared
responsibility.\22\ NERC states that where the Transmission Operator
has primary responsibility for developing the SOLs within its
transmission operator area, the transmission operator may request the
assistance of its reliability coordinator in developing these SOLs. In
addition, NERC states that it is the reliability coordinator that is
held responsible for ensuring that transmission operators develop SOLs
for its reliability coordinator area in accordance with a methodology
developed by the reliability coordinator. NERC states that the
transmission operator must share its SOLs with its reliability
coordinator, and the reliability coordinator must share any SOLs it
develops with its transmission operator. NERC also states that the
reliability coordinator monitors the status of some, but not all, SOLs.
---------------------------------------------------------------------------
\22\ Id. at 9.
---------------------------------------------------------------------------
14. According to NERC, the reliability coordinator's visualization
capabilities are not expected to display all SOLs within the Wide-Area
that the reliability coordinator monitors because this would mix SOLs
that have little impact on reliability with those SOLs that are
associated with facilities that are important to the Bulk-Power System.
NERC states that the reliability coordinator's visualization
capabilities are expected to display the real-time status of parameters
against all IROLs that the reliability coordinator monitors and also
display the subset of SOLs associated with facilities that are most
critical to the portions of the Bulk-Power System that are monitored by
the reliability coordinator.
15. Under proposed new Reliability Standards, IRO-008-1, IRO-009-1,
and IRO-010-1a, reliability coordinators must monitor and analyze IROLs
within their Wide-Area to prevent instability, uncontrolled separation,
or cascading outages that adversely impact the reliability of the
interconnection. These Reliability Standards would not require the
reliability coordinator to monitor and analyze SOLs other than IROLs
within their reliability coordinator area. Similarly, NERC's proposed
revisions to Reliability Standards EOP-001-1, IRO-002-2, IRO-004-2,
IRO-005-3, TOP-003-1, TOP-005-2, and TOP-006-2, inter alia, would
remove requirements for the reliability coordinator to monitor and
analyze SOLs other than IROLs.
Discussion
16. We believe that it is appropriate to develop requirements for
Reliability Standards that offer a clear division of responsibilities
among reliability coordinators and transmission operators. We,
therefore, propose to approve NERC's proposed division of
responsibility for SOLs and IROLs among reliability coordinators and
transmission operators. Although we support NERC's proposal and propose
here to approve it with only a limited directive regarding one proposed
definition, we are also seeking comments from NERC and industry to
obtain further information and ensure that there will not be gaps in
the analysis of SOLs by reliability coordinators going forward,
particularly those SOLs that could become IROLs. NERC acknowledges in
its filing that the transmission operator must develop and share its
SOLs with its reliability coordinator, and the reliability coordinator
must develop and share any SOLs it develops with its transmission
operator.\23\ NERC also states that the reliability coordinator
monitors the status of some, but not all, SOLs.\24\ In addition, the
Commission is aware that NERC is currently working on a project to
identify a subset of SOLs, other than IROLs, that a reliability
coordinator must continuously monitor and analyze.\25\ Taken together,
NERC's statements and its ongoing project indicate a need for
reliability coordinators to continue to analyze certain SOLs. We,
therefore, seek comment on whether there is a need for reliability
coordinators to continue to analyze, in addition to continuing to
monitor and coordinate data on,\26\ SOLs other than IROLs.
---------------------------------------------------------------------------
\23\ Id.
\24\ Id.
\25\ NERC identifies this as ``Project 2007-03: Real-time
Operations,'' available at https://www.nerc.com/filez/standards/Real-time_Operations_Project_2007-03.html.
\26\ Existing reliability standards that NERC does not propose
to change here continue to require reliability coordinators to
monitor SOLs. See Reliability Standard IRO-002-1 Requirement R6.
---------------------------------------------------------------------------
17. Since the ERO has stated that responsibility for the SOLs is
shared between the reliability coordinator and their transmission
operators, we also believe it may be beneficial for the reliability
coordinator to have a documented methodology for identifying the SOL
information it needs to fulfill its responsibilities for monitoring,
day ahead and real-time assessments, and operational control within the
reliability coordinator's area. We seek comment on this matter.
18. In addition, we request comment from NERC, reliability
coordinators, and other interested entities on the current practices of
reliability coordinators and transmission operators with respect to
coordinating operational responsibilities for monitoring, day ahead and
real-time assessments; and operating SOLs and IROLs, the practical
division of responsibilities for preventing and mitigating SOL and IROL
violations, and the monitoring capabilities of the reliability
coordinator with respect to IROLs as well as SOLs. The Commission
further seeks comment as to whether a reliability coordinator can
provide an accurate assessment of the Bulk-Power System to its
transmission operators on a Wide-Area basis, without evaluating: (1)
The operating environment on SOLs that will impact the transmission
operators within the reliability coordinator's areas; (2) SOLs that
have the potential to become IROLs; and (3) the existing IROLs within
the reliability coordinator area. In addition, the Commission seeks
comments as to whether a transmission operator can provide reliable
operating assessments or make reliable operating instructions on an SOL
that is on the border between two different transmission operator's
areas. The Commission also requests comment on whether the reliability
coordinator should have responsibility to monitor certain SOLs other
than IROLs, and whether such a responsibility would place an
unreasonable burden on reliability coordinators. If a reliability
coordinator should monitor certain SOLs other than IROLs, comments
should address in detail how reliability coordinators should determine
which SOLs to monitor.
19. The Commission has noted that NERC Standard IRO-006,
Transmission
[[Page 71617]]
Loading Relief (TLR), requires the reliability coordinators in the
Eastern Interconnection to relieve overloads on the facilities modeled
in the Interchange Distribution Calculator (IDC). IRO-006 requires the
reliability coordinator to model the SOLs and IROLs in the IDC to
perform the TLR procedures. The Commission seeks comments on how the
reliability coordinators in the Eastern Interconnections selects the
SOLs for evaluation by the IDC and the extent of any burden this has
caused the reliability coordinator.
20. The NERC Functional Model is a reference document developed by
NERC that outlines functions for each responsible entity in the NERC
Reliability Standards.\27\ NERC explains in its filing that the NERC
Functional Model was developed by first identifying all of the
operating tasks necessary for reliability, and then assigning each of
these operating tasks to a single functional entity.\28\ NERC states
that this approach results in a clear identification of a single
functional entity with responsibility for each reliability task.
However, NERC also states that in later versions of the Functional
Model, there are circumstances where the Functional Model assigns some
activities to more than one planning entity.\29\ NERC explains that,
under the Functional Model, the reliability coordinator is responsible
for identifying the subset of SOLs known as IROLs and that the
transmission operator is responsible for other SOLs. But the Functional
Model assigns a much broader role to the reliability coordinator to
maintain the real-time operating reliability of the bulk electric
system within its area. The Commission seeks comments from NERC and the
public as to how the current Functional Model represents the
delineation of assessment and operating responsibilities between the
reliability coordinator and transmission operator with respect to SOLs
and IROLs.
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\27\ NERC, Reliability Functional Model, version 5 at 30 (Nov.
2009), available at https://www.nerc.com/files/Functional_Model_V5_Final_2009Dec1.pdf. NERC developed the current version of the
Functional Model after it developed the proposed Reliability
Standards.
\28\ NERC Petition at 7.
\29\ Id. at 7 n.9.
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21. Based on the foregoing, the Commission proposes to approve the
proposed new and revised Reliability Standards without modification
(with the exception of the limited directive proposed below), as they
appear to be an improvement over the existing Reliability Standards
with respect to the division of responsibilities between reliability
coordinators and transmission operators. Our intent in seeking comments
from NERC and industry in this NOPR is to better understand the
proposed division of responsibilities, as well as the future
modifications to those responsibilities that NERC intends to pursue.
B. Proposed New Reliability Standards
1. IRO-008-1
22. Proposed Reliability Standard IRO-008-1 has the stated purpose
of preventing instability, uncontrolled separation, or cascading
outages that adversely impact the reliability of the interconnection by
ensuring that the Bulk Electric System is assessed during the
operations horizon. The proposed Reliability Standard applies to
reliability coordinators. IRO-008-1 requires the reliability
coordinator to use analyses and assessments as methods of achieving the
stated goal. The Reliability Standard requires analysis of the
reliability coordinator's Wide-Area \30\ ahead of time and during real-
time. It also requires communication with the entities that need to
take specific operational actions based on the analyses and
assessments.
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\30\ The term ``Wide-Area'' is defined in the NERC Glossary,
approved by the Commission. As defined, Wide-Area includes not only
the reliability coordinator's Area, but also critical flow and
status information from adjacent reliability Coordinator areas as
determined by detailed system studies to allow the calculation of
IROLs. See NERC Glossary available at https://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf.
---------------------------------------------------------------------------
23. Reliability Standard IRO-008-1 contains three requirements.
Requirement R1 requires each reliability coordinator to perform an
Operational Planning Analysis to assess whether the planned operations
for the next day within its Wide Area, will exceed any of its IROLs
during anticipated normal and contingency event conditions. Requirement
R2 requires the reliability coordinator to perform a Real-Time
Assessment at least once every 30 minutes to determine if its Wide Area
is exceeding any IROLs or is expected to exceed any IROLs. Requirement
R3 requires a reliability coordinator to share the results of an
Operational Planning Analysis or Real-Time Assessment that indicates
the need for specific operational actions to prevent or mitigate an
instance of exceeding an IROL with those entities that are expected to
take those actions.
24. NERC explains that IRO-008-1, Requirement R1 does not specify
any single application program that all reliability coordinators must
use because the Requirement assumes that the reliability coordinator
has a suite of applications that it can use to conduct its assessment,
verified as part of the certification process. NERC notes that having
the ability to conduct a day-ahead contingency analysis is a
requirement for reliability coordinator certification.
25. NERC also requests approval of two new terms that appear in
IRO-008-1: ``Operational Planning Analysis'' and ``Real-time
Assessment.'' Operational Planning Analysis is defined as:
An analysis of the expected system conditions for the next day's
operation. (That analysis may be performed either a day ahead or as
much as 12 months ahead.) Expected system conditions include things
such as load forecast(s), generation output levels, and known system
constraints (transmission facility outages, generator outages,
equipment limitations, etc.).
NERC states that the definition was designed to provide greater
specificity regarding the day-ahead study. NERC explains that the term
``unique'' used in the currently-effective IRO-004-1 causes confusion.
NERC states that in the event there are no changes to the expected
conditions from one day to the next, the reliability coordinator would
not be forced to conduct a new analysis of the expected system
conditions solely to have documentation for compliance.
26. The proposed term ``Real-time Assessment'' is defined as ``[a]n
examination of existing and expected system conditions, conducted by
collecting and reviewing immediately available data.'' The purpose of
the new term is to assure that the reliability coordinator is required
to conduct a real-time assessment, including situations when the
reliability coordinator is operating without its primary control
facilities, by collecting and reviewing available data. NERC explains
that the definition of Real-Time Assessment is purposefully ambiguous
to allow the assessment to be conducted either through the energy
management system or manually.
NOPR Proposal
27. We agree with NERC that the proposed Reliability Standard IRO-
008-1 would prevent instability, uncontrolled separation, or cascading
outages that adversely impact the reliability of the interconnection by
ensuring that the bulk electric system is assessed during the
operations horizon. In addition, the Commission recognizes NERC's
effort to create a body of IRO Reliability Standards that clearly
define which functional entity has the ultimate responsibility for SOLs
and IROLs. Accordingly, pursuant to section 215(d)(2) of the FPA, the
Commission proposes to approve Reliability
[[Page 71618]]
Standards IRO-008-1, as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. To ensure that the proposed
changes are supported by the Functional Model, the Commission requests
comment whether the proposed Reliability Standards, such as IRO-008-1,
appropriately resolve the division of responsibilities for SOLs and
IROLs or whether some level of sharing of responsibility needs to
exist.
28. The Commission also proposes to approve the addition of two new
definitions to the NERC Glossary: ``Operational Planning Analysis'' and
``Real-time Assessment'' with limited modification, as discussed below.
Although the proposed definition of Operational Planning Analysis would
permit entities to use an analysis of the expected system conditions
for the next day's operation that was performed up to twelve months
earlier, the discretion to use an existing analysis is limited to
circumstances where the expected system conditions, such as load
forecasts, generation output levels, and known system constraints are
the same for both days. Nevertheless, the Commission requests comments
from NERC and the public on the prudence of using an Operational
Planning Analysis up to twelve months old. We request comment on
whether this timeframe is reasonable or whether the timeframe should be
shorter to ensure that the analysis is not outdated. In addition, the
Commission also seeks comments from NERC and the public on whether the
definition should include measurable criteria needed to determine
whether it is appropriate to use an existing analysis.
29. In addition, the Commission seeks comment on the meaning of
``immediately available data'' within the proposed definition of Real-
Time Assessment. Requirement R6 of proposed Reliability Standard IRO-
002-2 would require reliability coordinators to have adequate analysis
capabilities such as state estimation, pre- and post-contingency
analysis capabilities (thermal, stability, and voltage), and wide-area
overview displays.\31\ Thus, it appears that any immediately available
data used by the reliability coordinator in the development of a Real-
time Assessment should be data obtained from one of these analysis
capabilities. We believe this could be clearer. Accordingly, under
section 215(d)(5) of the FPA, the Commission proposes to direct NERC to
modify the definition of ``Real-time Assessment'' to specify that the
type of data to be relied upon by a reliability coordinator in
conducting a Real-time Assessment must be based on adequate analysis
capabilities such as those referenced in Requirement R6 of IRO-002-2
when the tools are available.
---------------------------------------------------------------------------
\31\ As discussed below, NERC proposes to revise IRO-002-1 by
removing one provision, Requirement R2. Thus, Requirement R6 of
proposed IRO-002-2 is the same as Requirement R7 of the existing
version 1 Reliability Standard.
---------------------------------------------------------------------------
2. IRO-009-1
30. As proposed, Reliability Standard IRO-009-1 is designed to
prevent instability, uncontrolled separation, or cascading outages that
adversely impact the reliability of the interconnection by ``ensuring
prompt action to prevent or mitigate instances of exceeding [IROLs].''
Proposed Reliability Standard IRO-009-1 applies only to reliability
coordinators.
31. For each IROL that the reliability coordinator identifies one
or more days in advance, the reliability coordinator must, under
Requirements R1 and R2, have one or more operating processes,
procedures, or plans that identify actions it shall take that can be
implemented in time to prevent exceeding those IROLs and to mitigate
the magnitude and duration of exceeding that IROL such that the IROL is
alleviated within the maximum time duration allowed for a violation of
an IROL. Reliability Standard IRO-009-1 refers to the maximum response
period for alleviating an IROL as its ``IROL Tv.'' \32\ Under
Requirements R3 and R4, the reliability coordinator must use those
operating processes, procedures, or plans to prevent and mitigate
IROLs. If reliability coordinators cannot agree on the value for an
IROL or its IROL Tv, Requirement R5 would require each reliability
coordinator that monitors that facility to use the most conservative
value.
---------------------------------------------------------------------------
\32\ The NERC Glossary of Terms defines ``IROL Tv'' as:
The maximum time that an Interconnection Reliability Operating
Limit can be violated before the risk to the interconnection or
other Reliability Coordinator Areas becomes greater than acceptable.
Each Interconnection Reliability Operating Limit's Tv shall be less
than or equal to 30 minutes.
---------------------------------------------------------------------------
NOPR Proposal
32. The Commission agrees that having action plans developed and
implemented with respect to IROLs to prevent instability, uncontrolled
separation, or cascading outages that adversely impact the reliability
of the interconnection increases the likelihood that reliability
coordinators will take appropriate action. Accordingly, under section
215(d)(2) of the FPA, the Commission proposes to approve Reliability
Standard IRO-009-1, as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. However, as discussed above,
the Commission requests comment on the extent that reliability
coordinators should have action plans developed and implemented with
respect to other SOLs apart from IROLs and if so, which SOLs.
3. IRO-010-1a
33. NERC proposes the addition of a new Reliability Standard, IRO-
010-1a to the current suite of IRO Reliability Standards. IRO-010-1a is
designed to prevent instability, uncontrolled separation, or cascading
outages that adversely impact the reliability of the interconnection by
mandating that the reliability coordinator have the data it needs to
monitor and assess the operation of its reliability coordinator Area.
34. The requirements in the Reliability Standard specify a formal
request process for the reliability coordinator to explicitly identify
the data and information it needs for reliability; and require the
entities with the data to provide it as requested. The Reliability
Standard applies to the reliability coordinator and to the other
functional entities that must supply data to the reliability
coordinator.\33\ This includes entities that have been identified as
owners, users, or operators of the bulk-power system.
---------------------------------------------------------------------------
\33\ The requirements in the standard are specifically
applicable to the following functional entities: (1) Reliability
coordinator; (2) balancing authority; (3) generator owner; (4)
generator operator; (5) interchange authority; (6) load-serving
entity; (7) transmission operator; and (8) transmission owner.
---------------------------------------------------------------------------
35. Because the interpretation for IRO-010-1 was completed before
the filing of IRO-010-1, NERC requests Commission approval of IRO-010-
1a, which includes the standard as interpreted. The WECC Reliability
Coordination Subcommittee requested clarification on: (1) The type of
data to be supplied to the reliability coordinator; (2) which entities
are ultimately responsible for ensuring data are provided; and (3) what
actions are expected of the reliability coordinator regarding a
``mutually acceptable format.''
36. In response to the questions posed by the WECC Reliability
Coordination Subcommittee, NERC's interpretation team clarified that
the data to be supplied in Requirement R3 applies to the documented
specification for data and information referenced in Requirement R1.
They also explained that the intent of Requirement R3 is for each
responsible entity to ensure that its data and information (as stated
in the documented specification in
[[Page 71619]]
Requirement R1) are provided to the reliability coordinator. NERC's
interpretation team stated that another entity may provide that data or
information to the reliability coordinator on behalf of the responsible
entity, but the responsibility remains with the responsible entity.
Finally, they explained that Requirement R1.2 mandates that the parties
will reach a mutual agreement with respect to the format of the data
and information. If the parties can not mutually agree on the format,
it is expected that they will negotiate to reach agreement or enter
into dispute resolution to resolve the disagreement.\34\
---------------------------------------------------------------------------
\34\ NERC Petition at 108.
---------------------------------------------------------------------------
NOPR Proposal
37. Under section 215(d)(2) of the FPA, the Commission proposes to
approve Reliability Standard IRO-010-1a, including the proposed
interpretation, as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. However, the Commission notes
that the requirements of Reliability Standard IRO-010-1a do not require
reliability coordinators to specify a list of minimum data needed for
reliable operation of the Bulk-Power System. The Commission is
concerned that, without such a minimum list, neighboring reliability
coordinators could experience problems regarding compatibility and,
therefore, common understanding of data. For example, if differing data
requirements were specified by adjacent reliability coordinators, the
analysis performed by one could indicate a more severe result from a
possible contingency and result in conflicting operating procedures for
mitigation of risk to the Bulk-Power System. Therefore, the Commission
requests comments from the ERO and industry on whether a minimum list
of data is necessary for the effective sharing of data between
neighboring reliability coordinators and, if so, what data should be
included. The Commission also requests comments from NERC and the
industry on how compatibility of data between neighboring reliability
coordinators can be assured absent a list of minimum data as part of
this proposed Reliability Standard.
C. Proposed Revised Reliability Standards
1. EOP-001-1
38. NERC proposes to retire Requirement R2 of Reliability Standard
EOP-001-0. To implement this revision, NERC proposes a revised
Reliability Standard EOP-001-1. The purpose of EOP-001-1 is to require
each transmission operator and balancing authority to develop,
maintain, and implement a set of plans to mitigate operating
emergencies. These plans need to be coordinated with other transmission
operators and balancing authorities, and the reliability coordinator.
Revised Reliability Standard EOP-001-1 would apply only to balancing
authorities and transmission operators.
39. NERC contends that, upon IRO-009-1 becoming effective,
Requirement R2 of EOP-001-0 should be retired. Under Requirement R2
transmission operators must have an emergency load reduction plan for
all identified IROLs. NERC contends that this requirement would no
longer be appropriate upon IRO-009-1 becoming effective because the
reliability coordinator, not the transmission operator, is responsible
for developing plans for mitigating IROLs. Accordingly, NERC requests
approval of EOP-001-1, which is identical to existing Reliability
Standard EOP-001-0 except for the retirement of Requirement R2.
40. NERC contends that the proposed new Requirements R1 and R2 of
IRO-009-1 combined with the revisions in proposed Reliability Standard
EOP-001-1 address the Commission's directives in Order No. 693 to
modify EOP-001-0 to include the reliability coordinator as an
applicable entity and to require the reliability coordinator to act to
mitigate IROL violations within 30 minutes.\35\ In developing IRO-009-
1, NERC states that the drafting team determined that there are some
IROLs that must be resolved in a time frame that is shorter than 30
minutes. Accordingly, Requirement R2 of IRO-009-1 requires that each
action plan developed to resolve an IROL must be capable of being
executed such that the IROL is relieved within its IROL Tv. In
addition, Requirement R4 of IRO-009-1 requires the reliability
coordinator to act, without delay, when actual system conditions show
that there is an instance of exceeding an IROL.
---------------------------------------------------------------------------
\35\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 548, 556,
566.
---------------------------------------------------------------------------
NOPR Proposal
41. Under section 215(d)(2) of the FPA, the Commission proposes to
approve Reliability Standard EOP-001-1 as just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The
Commission also proposes to find that the ERO has satisfied the first
and second directives from P 566 of Order No. 693.\36\
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\36\ The Commission notes that the third and fourth directives
listed in P 566 of Order No. 693 remain outstanding. Further, the
Commission directed the ERO to consider a pilot program for
implementing system states. Order No. 693, FERC Stats. & Regs. ]
31,242 at P 566.
---------------------------------------------------------------------------
2. IRO-002-2
42. NERC proposes to retire Requirement R2 of Reliability Standard
IRO-002-1. To implement this revision, NERC requests Commission
approval of revised Reliability standard IRO-002-2. The purpose of IRO-
002-2 is to provide reliability coordinators with the information,
tools and other capabilities that they need to perform their
responsibilities. IRO-002-2 would apply only to reliability
coordinators.
43. Requirement R2 of IRO-002-1 requires each reliability
coordinator to determine the data requirements to support its
reliability coordinator tasks and to request such data from its
transmission operators, balancing authorities, transmission owners,
generation owners, generation operators, and load-serving entities, or
adjacent reliability coordinators. NERC explains that proposed
Reliability Standard IRO-010-1a (discussed above) requires the
reliability coordinator to develop and distribute a data specification
to ensure that entities provide data as needed to support monitoring,
analyses, and assessments. NERC contends that the proposed requirements
are more explicit than the associated requirement in Reliability
Standard IRO-002-1.
44. Reliability Standard IRO-002-2 continues to require each
reliability coordinator to monitor SOLs other than IROLs both within
its reliability coordinator area and in surrounding reliability
coordinator areas. Under Requirement R4 of IRO-002-2, each reliability
coordinator must have detailed real-time monitoring capability of its
reliability coordinator area and sufficient monitoring capability of
its surrounding reliability coordinator areas to ensure that potential
or actual SOLs or IROL violations are identified. In addition, under
Requirement R5, each reliability coordinator must monitor bulk electric
system elements such as generators, transmission lines, buses,
transformers and breakers that could result in SOL or IROL violations
within its reliability coordinator area.
45. In Order No. 693, the Commission directed the ERO to develop a
modification to IRO-002-1 that requires a minimum set of capabilities
that should be made available to reliability coordinators. NERC
acknowledges that the proposed modification does not
[[Page 71620]]
address this directive. NERC states that this directive is being
considered in Project 2009-02--Real-time Tools and Analysis
Capabilities.
NOPR Proposal
46. Under section 215(d)(2) of the FPA, the Commission proposes to
approve Reliability Standard IRO-002-2. The Commission proposes to find
that the data specification requirements of proposed Reliability
Standard IRO-001-1a are more explicit than the direction provided in
Requirement R2 of IRO-002-1. In addition, the Commission accepts NERC's
commitment to develop a minimum set of capabilities that should be made
available to reliability coordinators.
3. IRO-004-2
47. NERC proposes to revise IRO-004-1 by retiring Requirements R1
through R6. To implement these revisions, NERC requests Commission
approval of Reliability Standard IRO-004-2. The purpose of IRO-004-2 is
to require each reliability coordinator to conduct next-day reliability
analyses for its reliability coordinator area to ensure the bulk
electric system can be operated reliably in anticipated normal and
contingency conditions. IRO-004-2 would apply to balancing authorities,
transmission operators, and transmission service providers.
48. NERC states that, upon approval of proposed IRO-008-1,
Requirement R1 of the currently-effective IRO-004-1 should be retired
because the requirement only requires a next-day reliability analysis
of its own reliability coordinator area as opposed to its Wide-Area,
which also would include critical flow and status information from
adjacent reliability coordinator areas to allow the calculation of
IROLs. NERC explains that because proposed IRO-008-1 requires the
reliability coordinator to assess a wider area than is currently
required by IRO-004-1, the reliability coordinator is required to
continuously look beyond its own area boundaries and assess a broader
portion of the interconnected Bulk-Power System. NERC further states
that the purpose of conducting a day-ahead analysis is not to
``ensure'' but to ``assess'' the system and, thus, Requirement R1 of
currently-effective IRO-004-1 is inaccurate.
49. NERC also seeks to retire Requirement R2 of IRO-004-1, which
requires each reliability coordinator to ``pay particular attention to
parallel flows to ensure one reliability coordinator area does not
place an unacceptable or undue burden on an adjacent reliability
coordinator area.'' \37\ NERC states that the phrase ``to pay
particular attention to'' is neither clear nor measurable. NERC asserts
that the requirements in currently-effective IRO-014, IRO-015, and IRO-
016 are aimed at ensuring that reliability coordinators coordinate
their actions with one another and act in the best interest of the
interconnection as a whole. In addition, NERC explains that, under the
Functional Model, the transmission operator is responsible for the
real-time operation of the transmission system with the reliability
coordinator providing oversight of the transmission operator's actions,
directing additional or alternate actions when needed. NERC states that
the requirements proposed in the new IRO Reliability Standards focus
specifically on IROLs and are inclusive of any reliability implications
due to parallel flows.
---------------------------------------------------------------------------
\37\ Reliability Standard IRO-004-1, Requirement R2.
---------------------------------------------------------------------------
50. In support of retiring Requirements R1 and R2 of IRO-004-1,
NERC posits that under the Functional Model, the reliability
coordinator is the functional entity with primary responsibility for
IROLs and the transmission operator is the functional entity with
primary responsibility for SOLs. NERC states that, under certain
circumstances, the transmission operator may request the assistance of
its reliability coordinator in developing an SOL but the responsibility
for addressing the SOL remains with the transmission operator.\38\ NERC
explains that, under the Functional Model and Requirement R11 of
Reliability Standard TOP-002-2, the transmission operator is
responsible for conducting analyses to identify where there may be
instances of exceeding SOLs. NERC also states that, under TOP-008-1,
the transmission operator is responsible for taking actions to either
prevent or mitigate instances of exceeding SOLs. NERC states that, by
contrast, it is the reliability coordinator that is responsible for
ensuring that IROLs are developed for its reliability coordinator area
in accordance with a methodology developed by the reliability
coordinator. Further, NERC states that the transmission operator must
share its SOLs with its reliability coordinator, and the reliability
coordinator must share any SOLs it develops with its transmission
operator. NERC states that the reliability coordinator monitors the
status of some, but not all, SOLs.
---------------------------------------------------------------------------
\38\ See Reliability Standard TOP-008-1, requiring transmission
operators to take action to prevent or mitigate violations of SOLs.
---------------------------------------------------------------------------
51. NERC also contends that, upon proposed Reliability Standard
IRO-009-1 becoming effective, Requirements R3 and R6 of currently-
effective IRO-004-0 should be retired. Under Requirement R3 of IRO-004-
0, reliability coordinators must, in conjunction with its transmission
operators and balancing authorities, develop action plans, including
for reducing load to return transmission loading to within acceptable
SOLs or IROLs. NERC states that the use of the phrase, ``in conjunction
with'' is not supported by the responsibilities of the reliability
coordinator in the Functional Model and would be inconsistent with the
requirements of proposed Reliability Standard IRO-009-1. NERC also
states that proposed Requirement R3 of IRO-009-1 includes language that
is more explicit than the language in Requirement R6 of existing
Reliability Standard IRO-004-1.
52. Finally, NERC proposes to retire Requirements R4 and R5 from
IRO-004-1. Requirement R4 requires each transmission operator,
balancing authority, transmission owner, generator owner, generator
operator, and load-serving entity in the reliability coordinator area
to provide information required for system studies. NERC proposes to
retire Requirement R4 because it identifies only a fraction of the
reliability-related data needed by the reliability coordinator.
Requirement R5 requires each reliability coordinator to share the
results of its system studies with other reliability coordinators and
transmission operators, balancing authorities, and transmission service
providers within its reliability coordinator area. NERC states that
proposed Reliability IRO-010-1a offers a suitable replacement for
currently-effective Requirements R4 and R5 because IRO-010-1a requires
reliability coordinators to know, in advance, what data and information
it needs and what data and information it needs to share with other
reliability entities. In addition, requirement R3 of proposed
Reliability Standard IRO-008-1 would require the reliability
coordinator to share the results of its analyses with entities within
its reliability coordinator area.
NOPR Proposal
53. Under section 215(d)(2) of the FPA, the Commission proposes to
approve Reliability Standard IRO-004-2, as just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The
Commission recognizes NERC's efforts to more clearly define which
functional entity has the ultimate responsibility for SOLs
[[Page 71621]]
and IROLs, and to synchronize existing standards with the proposed new
IRO Reliability Standards. We propose to find that the requirements
proposed for retirement from IRO-004-1 are appropriately addressed in
new Reliability Standards IRO-008-1, IRO-009-1, and IRO-010-1a.
4. IRO-005-3
54. NERC proposes to retire Requirement R2, R3, R5, R16, and R17 of
currently-effective Reliability Standard IRO-005-2, and to modify
Requirements R9, R13, and R14. To implement these revisions, NERC
requests Commission approval of proposed Reliability Standard IRO-005-
3. The purpose of proposed Reliability Standard IRO-005-3 is to require
the reliability coordinator to be continuously aware of conditions
within its reliability coordinator area and include this information in
its reliability assessments. In addition, the reliability coordinator
must monitor the bulk electric system parameters that may have
significant impacts upon the reliability coordinator area and
neighboring reliability coordinator areas. IRO-005-3 would apply to
reliability coordinators, balancing authorities, transmission
operators, transmission service providers, generator operators, load-
serving entities, and purchasing-selling entities.
55. NERC contends that, upon the new IRO Reliability Standards
becoming effective, Requirements R2, R3, R5, R16, and R17 of IRO-005-2
should be retired and Requirements R9, R13, and R14 should be modified.
Except for Requirement R2, all of the requirements proposed for
retirement set responsibilities for the reliability coordinator to be
continuously aware of SOLs and IROLs within its reliability coordinator
area and to identify the cause for each SOL and IROL. Similarly, all of
the requirements proposed for modification include requirements for the
reliability coordinator to address SOLs and for the transmission
operator to address IROLs. NERC contends that these existing
requirements should be retired or modified in light of the division of
responsibilities between reliability coordinators and transmission
operators expressed in new Reliability Standard IRO-009-1.
56. Requirement R2 requires the reliability coordinator ``to be
aware of'' all interchange transactions that wheel through its
reliability coordinator area. NERC contends that it is not possible to
measure how an entity is ``aware of'' specific information. In
addition, NERC states that the e-tag system that has been implemented
no longer requires the reliability coordinator to collect and relay
interchange information to other entities. If a reliability coordinator
needs this information, NERC states that the reliability coordinator
can add this item to the list of data and information on its data
specification under proposed Requirement R1 of IRO-010-1a.
NOPR Proposal
57. Under section 215(d)(2) of the FPA, the Commission proposes to
approve Reliability Standard IRO-005-3, as just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The
Commission recognizes NERC's efforts to more clearly define which
functional entity has the ultimate responsibility for SOLs and IROLs,
and to synchronize existing standards with the proposed new IRO
Reliability Standards. We propose to find that the requirements of IRO-
005-2 proposed for retirement and modification are appropriately
addressed in new Reliability Standards IRO-008-1, IRO-009-1, and IRO-
010-1a.
5. TOP-003-1
58. NERC proposes to modify Requirement R1.2 of currently-effective
Reliability Standard TOP-003-0. To implement this revision, NERC
requests approval of proposed Reliability Standard TOP-003-1. The
purpose of TOP-003-1 is to require balancing authorities, transmission
operators, and reliability coordinators to plan and coordinate
scheduled generator and transmission outages that may affect the
reliability of interconnected operations. TOP-003-1 would apply to
generator operators, transmission operators, balancing authorities, and
reliability coordinators.
59. NERC explains that Requirement R1.2 of TOP-003-0 includes two
distinct activities--a requirement for the transmission operator to
provide the reliability coordinator and other entities with daily
outage information and a requirement for the reliability coordinator to
establish outage reporting requirements. NERC contends that both
elements of Requirement R1.2 are captured in proposed Reliability
Standard IRO-010-1a. NERC proposes to remove the transmission
operator's obligation to provide daily outage information to
reliability coordinators and strike the requirement for the reliability
coordinator to establish outage reporting requirements.
According to NERC, Requirement R1 of proposed IRO-010-1a requires
the reliability coordinator to specify what data and information it
needs, as well as the frequency and format for providing that data and
information. NERC states that, because the reliability coordinator
needs outage data for modeling and analysis, the specification will
include outage data. Requirement R3 of IRO-010-1a requires entities to
provide data and information to the reliability coordinator in
accordance with the reliability coordinator's specifications. NERC
states that if TOP-003-0 Requirement R1.2 is not modified, it will be
redundant wi