Transmission Planning Reliability Standards, 26714-26723 [2012-10943]
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26714
Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
Energy Regulatory Commission, 888
First Street NE., Washington, DC 20426,
Telephone: (202) 502–8473,
Robert.Stroh@ferc.gov.
SUPPLEMENTARY INFORMATION:
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
18 CFR Part 40
139 FERC ¶ 61,059
[Docket No. RM12–1–000]
Notice of Proposed Rulemaking
Transmission Planning Reliability
Standards
Federal Energy Regulatory
Commission, DOE.
ACTION: Notice of Proposed Rulemaking.
AGENCY:
The North American Electric
Reliability Corporation (NERC), the
Commission-certified Electric
Reliability Organization, petitions for
the approval of modified Transmission
Planning Reliability Standard, TPL–
001–2 (Transmission System Planning
Performance Requirements), which
combines four currently effective TPL
Reliability Standards, TPL–001–1, TPL–
002–1b, TPL–003–1a, and TPL–004–1,
into a single standard. NERC also
requests retirement of the currentlyeffective TPL standards. Pursuant to
section 215 of the Federal Power Act,
the Federal Energy Regulatory
Commission proposes to remand
proposed Reliability Standard, TPL–
001–2. The proposed Reliability
Standard includes a provision that
would allow a transmission planner to
plan for non-consequential load loss
following a single contingency provided
that the plan is documented and vetted
in an open and transparent stakeholder
process. The Commission believes that,
with the inclusion of this provision,
proposed TPL–001–2 does not meet the
statutory criteria for approval.
DATES: Comments are due July 6, 2012.
ADDRESSES: You may submit comments,
identified by docket number by any of
the following methods:
• Agency Web Site: https://ferc.gov.
Documents created electronically using
word processing software should be
filed in native applications or print-toPDF format and not in a scanned format.
• Mail/Hand Delivery: Commenters
unable to file comments electronically
must mail or hand deliver comments to:
Federal Energy Regulatory Commission,
Secretary of the Commission, 888 First
Street NE., Washington, DC 20426.
FOR FURTHER INFORMATION CONTACT:
Eugene Blick (Technical Information),
Office of Electric Reliability, Federal
Energy Regulatory Commission, 888
First Street NE., Washington, DC 20426,
Telephone: (202) 502–8066,
Eugene.Blick@ferc.gov.
Robert T. Stroh (Legal Information),
Office of the General Counsel, Federal
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SUMMARY:
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1. The North American Electric
Reliability Corporation (NERC), the
Commission-certified Electric
Reliability Organization (ERO), petitions
for the approval of Reliability Standard,
TPL–001–2 (Transmission System
Planning Performance Requirements),
which combines four currently effective
TPL Reliability Standards, TPL–001–1,
TPL–002–1b, TPL–003–1a, and TPL–
004–1, into a single standard. NERC also
requests retirement of the currently
effective TPL standards. Pursuant to
section 215(d) of the Federal Power Act
(FPA), the Federal Energy Regulatory
Commission (FERC) proposes to remand
proposed Reliability Standard, TPL–
001–2. The proposed Reliability
Standard includes a provision in Table
1 (Steady State and Stability
Performance Extreme Events), footnote
12 that would allow a transmission
planner to plan for ‘‘non-consequential
load loss,’’ i.e., load shedding, following
a single contingency provided that the
plan is documented and alternatives are
considered and subject to review in an
open and transparent stakeholder
process. As discussed below, the
Commission believes that this provision
is vague and unenforceable because it
does not adequately define the
circumstance in which an entity can
plan for non-consequential load loss
following a single contingency.
Accordingly, the Commission proposes
to find that, with the inclusion of this
provision, proposed TPL–001–2 does
not meet the statutory criteria for
approval that a mandatory Reliability
Standard must be just, reasonable, not
unduly discriminatory or preferential,
and in the public interest.
2. NERC states that proposed
Reliability Standard TPL–001–2
introduces significant revisions and
improvements to the Transmission
Planning Reliability Standards,
including increased specificity of data
required for modeling conditions, and
requires planners to address the impact
of the unavailability of long lead-time
critical equipment in a manner
consistent with the entity’s spare
equipment strategy.1 Further, according
to NERC, the proposed Reliability
Standard addresses twenty-seven
1 NERC
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Commission directives set forth in
Order No. 693 and subsequent
Commission orders.2 We agree with
NERC that proposed TPL–001–2
includes specific improvements over the
currently effective Transmission
Planning Reliability Standards and, as
discussed below, is responsive to
certain Commission directives.
However, the provision in the proposed
Reliability Standard allowing for
transmission planners to plan for nonconsequential load loss following a
single contingency without adequate
safeguards undermines the potential
benefits the proposed Reliability
Standard may provide. Section 215(d)(4)
requires that the Commission remand to
the ERO for further consideration a
Reliability Standard ‘‘that the
Commission disapproves in whole or in
part.’’ 3 Thus, notwithstanding
improvements contained in other
provisions of proposed Reliability
Standard TPL–001–2, our concerns
regarding the stakeholder process set
forth in Table 1, footnote 12 provides us
no option other than to propose to
remand the entire Reliability Standard.
3. We are concurrently issuing a Final
Rule in Docket No. RM11–18–000 that
remands a related Reliability Standard,
TPL–002–0b, which contains the same
objectionable stakeholder process
provision in Table 1, footnote ‘b’.4 In the
Final Rule in Docket No. RM11–18–000,
the Commission urges NERC to employ
its Expedited Reliability Standards
Development Process to timely develop
a modified provision regarding planned
shedding of non-consequential load loss
that satisfies the relevant Commission’s
directives in Order No. 693 and the
subsequent orders. A rapid resolution of
this one matter will allow the industry,
NERC and the Commission to go
forward with the consideration of other
improvements contained in proposed
Reliability Standard TPL–001–2.
I. Background
4. Section 215 of the FPA requires a
Commission-certified ERO to develop
mandatory and enforceable Reliability
Standards, which are subject to
Commission review and approval.
Approved Reliability Standards are
enforced by the ERO, subject to
Commission oversight, or by the
Commission independently.
5. Pursuant to section 215 of the FPA,
the Commission established a process to
2 Mandatory Reliability Standards for the BulkPower System, Order No. 693, FERC Stats. & Regs.
¶ 31,242, order on reh’g, Order No. 693–A, 120
FERC ¶ 61,053 (2007).
3 16 U.S.C. 824o(d)(4) (2006) (emphasis added).
4 Transmission Planning Reliability Standards,
Order No. 762, 139 FERC ¶ 61,060 (2012).
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Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
select and certify an ERO 5 and,
subsequently, certified NERC as the
ERO.6 On March 16, 2007, the
Commission issued Order No. 693,
approving 83 of the 107 Reliability
Standards filed by NERC, including the
existing TPL Reliability Standards. In
addition, pursuant to section 215(d)(5)
of the FPA,7 the Commission directed
NERC to develop modifications to 56 of
the 83 approved Reliability Standards,
including the TPL Reliability
Standards.8
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A. Transmission Planning (TPL)
Reliability Standards and Order No. 693
Directives
6. The currently-effective TPL
Reliability Standards consists of four
approved standards and are intended to
ensure that the transmission system is
planned and designed to meet an
appropriate and specific set of reliability
criteria. Transmission planning is a
process that involves a number of stages
including developing a model of the
Bulk-Power System, using this model to
assess the performance of the system for
a range of operating conditions and
contingencies, determining those
operating conditions and contingencies
that have an undesirable reliability
impact, identifying the nature of
potential options, and developing and
evaluating a range of solutions and
selecting the preferred solution, taking
into account the time needed to place
the solution in service.
7. In Order No. 693, the Commission
accepted the Version 0 TPL Reliability
Standards and directed NERC, pursuant
to FPA section 215(d)(5), to develop
modifications to TPL–001–0 through
TPL–004–0 through the Reliability
Standards development process. In
addition, the Commission neither
approved nor remanded two other
planning Reliability Standards, TPL–
005–0 and TPL–006–0, as these two
Reliability Standards applied only to
regional reliability organizations.9 The
Commission encouraged the ERO to
monitor a series of technical
5 Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the
Establishment, Approval and Enforcement of
Electric Reliability Standards, Order No. 672, FERC
Stats. & Regs. ¶ 31,204, order on reh’g, Order No.
672–A, FERC Stats. & Regs. ¶ 31,212 (2006).
6 North American Electric Reliability Corp., 116
FERC ¶ 61,062, order on reh’g and compliance, 117
FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc.
v. FERC, 564 F.3d 1342 (DC Cir. 2009).
7 16 U.S.C. 824o(d)(5).
8 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
PP 1691–1845.
9 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
PP 1840, 1845. The currently-effective versions of
the TPL Reliability Standards are as follows: TPL–
001–0.1, TPL–002–0b, TPL–003–0a, and TPL–004–
0.
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conferences and regional meetings to
obtain industry input to achieve the goal
of regional planning and use the results
as input to the standards development
process to revise TPL–005–0 to address
regional planning and related
processes.10
8. With regard to Reliability Standard
TPL–002–0b, Table 1, footnote ‘b’, the
Commission directed NERC to clarify
footnote ‘b’ regarding the loss of nonconsequential load for a single
contingency event. In a March 18, 2010
order, the Commission directed NERC to
submit a modification to footnote ‘b’
responsive to the Commission’s
directive in Order No. 693, by June 30,
2010.11 In a June 11, 2010 order, the
Commission granted partial clarification
to NERC and extended the compliance
deadline until March 31, 2011.12
B. RM11–18–000 Proposed Remand of
Footnote ‘b’—Version 1
9. In response to the March 2010 and
June 2010 Orders, on March 31, 2011,
NERC submitted proposed TPL–002–1
(Version 1), which proposed to modify
footnote ‘b’ to permit planned
interruption of Firm Demand when
documented and subject to an open
stakeholder process. On October 20,
2011, the Commission issued a Notice of
Proposed Rulemaking that proposed to
remand to NERC the proposed
modification to footnote ‘b’ because it
does not adequately clarify or define the
circumstances in which an entity can
plan to use interruption of Firm
Demand as a mitigation plan to resolve
a single contingency.13 The Commission
stated that the procedural and
substantive parameters of NERC’s
proposal are too undefined to provide
assurances that the process will be
effective in determining when it is
appropriate to plan for interrupting
Firm Demand, do not contain NERCdefined criteria on circumstances to
determine when an exception for
planned interruption of Firm Demand is
permissible, and could result in
inconsistent results in implementation.
In the Final Rule issued concurrently
with the NOPR in the immediate
proceeding, the Commission remanded
proposed Reliability Standard TPL–
002–0b.
10 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 1841.
11 Mandatory Reliability Standards for the Bulk
Power System, 130 FERC ¶ 61,200 (2010) (March
2010 Order).
12 Mandatory Reliability Standards for the Bulk
Power System, 131 FERC ¶ 61,231 (2010) (June 2010
Order).
13 Transmission Planning Reliability Standards,
137 FERC ¶ 61,077 (2011).
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C. NERC’s Petition for Approval of TPL–
001–2
10. On October 19, 2011, NERC filed
a petition seeking approval of Reliability
Standard TPL–001–2, the associated
implementation plan and Violation Risk
Factors (VRFs) and Violation Severity
Levels (VSLs), as well as five new
definitions to be added to the NERC
Glossary of Terms (Version 2). NERC
also seeks approval of the retirement of
the following four Reliability Standards:
TPL–001–1 (System Performance Under
Normal (No Contingency) Conditions
(Category A)); TPL–002–1b (System
Performance Following Loss of a Single
Bulk Electric System (BES) Element
(Category B)); TPL–003–1a (System
Performance Following Loss of Two or
More BES Elements (Category C)); and
TPL–004–1 (System Performance
Following Extreme Events Resulting in
the Loss of Two or More Bulk Electric
System Elements (Category D)). In
addition, NERC requests to withdraw
two pending Reliability Standards:
TPL–005–0 (Regional and Interregional
Self-Assessment Reliability Reports) and
TPL–006–0.1 (Data from the Regional
Reliability Organization Needed to
Assess Reliability).
11. The Version 2 standard also
includes language similar to NERC’s
Version 1 March 31, 2011, proposal to
revise and clarify footnote ‘b’ of Table
1 applicable in four currently-effective
TPL Reliability Standards ‘‘in regard to
non-consequential firm load loss in the
event of a single contingency.’’ 14 The
proposed Reliability Standard TPL–
001–2 (Version 2) expands upon NERC’s
proposed footnote ‘b’ (Version 1) and as
a result, Version 2 replaces in its
entirety the Version 1 footnote ‘b.’ In
creating TPL–001–2, the proposed
footnote ‘b’ in Version 1 was modified
slightly and carried over as Steady State
& Stability Performance Footnotes 9 and
12 in Version 2. In other words, footnote
‘b’ in Version 1 has been divided into
two footnotes in Version 2, and the
subject of the concerns raised by the
Commission with respect to the Version
1 footnote ‘b’ are now contained in
footnote 12 of Version 2. Footnote 12 in
Version 2 is in all material respects the
same as the portion of footnote ‘b’ in
Version 1 that is the subject of the Final
Rule issued today in Docket No. RM11–
18–000.
D. Proposed Reliability Standard
12. As proposed by NERC, TPL–001–
2 includes eight requirements and Table
1, summarized as follows:
14 NERC
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Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
Requirement R1: Requires the
transmission planner and planning
coordinator to maintain system models
and provides a specific list of items
required for the system models and that
the models represent projected system
conditions. The planner is required to
model the items that are variable, such
as load and generation dispatch, based
specifically on the expected system
conditions.
Requirement R2: Requires each
transmission planner and planning
coordinator to prepare an annual
planning assessment of its portion of the
bulk electric system and must use
current or qualified past studies,
document assumptions, and document
summarized results of the steady state
analyses, short circuit analyses, and
stability analyses. Requirement R2, Part
2.1.3 requires the planner to assess
system performance utilizing a current
annual study or qualified past study for
each known outage with a duration of
at least six months for certain events
listed in Table 1, P1. NERC states that
this requirement ensures planners
evaluate every known outage with
known duration of six months or more,
even if the known outage is not within
one of the study years selected by the
planner. NERC states that the
requirements and parts of proposed
TPL–001–2 provide for what a valid
study must entail, timeframes for use of
past studies, minimum conditions, what
needs to be included in the model, and
what performance must be achieved. It
also clarifies that qualified past studies
can be utilized in the analysis while
tightly defining the qualifications for
those studies. The use of qualified past
studies allows an entity to continue to
use validated studies to complete its
assessment. Requirement R2 includes a
new part (2.7.3) that allows
transmission planners and planning
coordinators to utilize NonConsequential Load Loss to meet
performance requirements if the
applicable entities are unable to
complete a Corrective Action Plan due
to circumstances beyond their control.
Requirements R3 and R4:
Requirement R3 describes the
requirements for steady state studies
and Requirement R4 explains the
requirements for stability studies.
Requirement R3 and Requirement R4
also require that simulations duplicate
what will occur in an actual power
system based on the expected
performance of the protection systems.
These requirements are intended to
ensure that if a protection system is
designed to remove multiple elements
from service for an event that the
simulation will be run with all of those
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elements removed from service.
Requirement R3 and Requirement R4
also include new parts that require the
planners to conduct an evaluation of
possible actions designed to reduce the
likelihood or the consequences of
extreme events that cause cascading.
Requirement R5: Requirement R5
deals with voltage criteria and voltage
performance. NERC proposes in
Requirement R5 that each transmission
planner and planning coordinator must
have criteria for acceptable system
steady state voltage limits, postcontingency voltage deviations, and the
transient voltage response for its system.
For transient voltage response the
criteria must specify a low-voltage level
and a maximum length of time that
transient voltages may remain below
that level. This requirement will
establish more robust transmission
planning for organizations and greater
consistency as these voltage criteria are
shared.
Requirement R6: Specifies that an
entity must define and document the
criteria or methodology used to identify
system instability for conditions such as
cascading, voltage instability, or
uncontrolled islanding within its
planning assessment.
Requirement R7: Mandates
coordination of individual and joint
responsibilities for the planning
coordinator and the transmission
planner which is intended to eliminate
confusion regarding the responsibilities
of the applicable entities and assures
that all elements needed for regional
and wide area studies are defined with
a specific entity responsible for each
element and that no gaps will exist in
planning for the Bulk-Power System.
Requirement R8: Addresses the
sharing of planning assessments with
neighboring systems. The requirement
ensures that information is shared with
and input received from adjacent
entities and other entities with a
reliability related need that may be
affected an entity’s system planning.
Table 1: Similar to the existing TPL
Standard, NERC’s proposal contains a
series of planning events and describes
system performance requirements in
Table 1 for a range of potential system
contingencies required to be evaluated
by the planner. Table 1 includes three
parts: Steady State & Stability
Performance Planning Events, Steady
State & Stability Performance Extreme
Events, and Steady State & Stability
Performance Footnotes. Table 1
describes system performance
requirements for a range of potential
system contingencies required to be
evaluated by the planner. The table
categorizes the events as either
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‘‘planning events’’ or ‘‘extreme events.’’
The proposed table lists seven
Contingency planning events (P1
through P7) that require steady-state and
stability analysis as well as five extreme
event contingencies—three for steadystate and two for stability. The proposed
table also includes a no contingency
‘‘event’’ labeled as P0 which requires
steady state analysis. Footnote 12 of
Table 1 provides:
An objective of the planning process
should be to minimize the likelihood and
magnitude of Non-Consequential Load Loss
following Contingency events. However, in
limited circumstances Non-Consequential
Load Loss may be needed to address BES
performance requirements. When NonConsequential Load Loss is utilized within
the planning process to address BES
performance requirements, such interruption
is limited to circumstances where the NonConsequential Load Loss is documented,
including alternatives evaluated; and where
the utilization of Non-Consequential Load
Loss is subject to review in an open and
transparent stakeholder process that includes
addressing stakeholder comments.15
II. Discussion
13. The Commission proposes to
remand proposed Reliability Standard
TPL–001–2. The proposed footnote 12
included as part of Reliability Standard
TPL–001–2, which is in all material
respects the same as the Version 1
footnote ‘b’ proposal described in
Docket No. RM11–18–000, is unjust and
unreasonable, unduly discriminatory or
preferential, and not in the public
interest. Although there are many
improvements in the proposed TPL–
001–2, the presence of footnote 12 in
proposed Reliability Standard TPL–
001–2 requires that the Commission
remand the entire proposed Reliability
Standard.16
14. As described in the Final Rule in
Docket No. RM11–18–000, the
Commission believes that NERC’s
footnote ‘b’ proposal (footnote 12 in this
NOPR proceeding) does not clarify or
define the circumstances in which an
entity can plan to interrupt NonConsequential Load Loss for a single
contingency. The Commission is
concerned that footnote 12 is inadequate
and fails to address the Commission’s
concerns for three reasons. First,
proposed footnote 12 lacks adequate
parameters. Second, the NERC proposal
leaves undefined the circumstances in
15 NERC Petition at 12. In NERC’s proposal in
Docket No. RM11–18–000, Table 1, footnote ‘b’
planned load shed is called planned ‘‘interruption
of Firm Demand.’’ In footnote 12, NERC has
changed the term from ‘‘interruption of Firm
Demand’’ to utilization of ‘‘Non-Consequential Load
Loss.’’
16 16 U.S.C. 824o(d)(4).
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which it is allowable to plan for NonConsequential Load Loss to be utilized.
The Commission believes that footnote
12 could function as a means to override
the reliability objective and system
performance requirements of the TPL
Reliability Standard without any
technical or other criteria specified to
determine when planning to use NonConsequential Load Loss to meet single
contingency performance requirements
would be allowable.17 While NERC
expects that such determinations will be
made in a stakeholder process, this
provides no assurance that such a
process will use technically sound
means of approving or denying
exceptions.18 Third, while the
Commission recognizes that some
variation among regions or entities is
reasonable given varying grid
topography and other considerations,
there are no technical criteria to
determine whether varied results are
arbitrary or based on meaningful
distinctions.19 The Commission, thus,
concludes that NERC’s proposal lacks
safeguards to ensure against
inconsistent results and arbitrary
determinations to allow for the planned
interruption of load shed.
15. While we propose to remand
Reliability Standard TPL–001–2 because
of footnote 12, the Commission sees
improvements to the balance of the
proposed Reliability Standard. The
Commission recognizes the level of
complexity and substantial revision that
NERC undertook to consolidate the
requirements in the four currentlyeffective TPL Reliability Standards into
one standard, and that effort has yielded
improvements relative to the current set
of standards. The Commission,
however, seeks comments from the ERO
and other interested persons regarding
the following important reliability
issues to ensure that the proposed
Reliability Standard adequately
maintains reliability and that the
directives have been met: (a) Planned
Maintenance Outages, (b) Violation Risk
Factors, (c) Protection System Failures
versus Relay Failures, (d) Assessment of
Backup or Redundant Protection
Systems, (e) Single Line to Ground
Faults, and (f) Order No. 693 Directives.
A. Planned Maintenance Outages
16. NERC proposed new language in
TPL–001–2, Requirement R1 to remove
an ambiguity in the current standard
concerning what the planner needs to
include in the specific studies. It also
requires the planner to evaluate six-
month or longer duration outages within
its system. NERC states that while
Requirement R1.3.12 of the currentlyeffective TPL–002–0b, includes planned
outages (including maintenance
outages) in the planning studies and
requires simulations at the demands
levels for which the planned outages are
performed, it is not appropriate to have
the planner select specific planned
outages for inclusion in their studies.
Consequently, NERC proposes a brightline test to determine whether an outage
should be included in the system
models. Specifically, NERC proposes
that Requirement R1, Part 1.1.2 mandate
that the system models ‘‘shall represent
* * * known outage(s) of generation or
Transmission Facility(ies) with a
duration of at least six months.’’ 20
NERC determined that, in the planning
horizon, a six-month or longer outage
duration would necessarily extend over
a seasonal peak load period and should
be included in the planning models.
Therefore, NERC states that the specific
elements selected to be evaluated are
selected by the transmission planner or
planning coordinator and must be
acceptable to the associated regional
reliability organization.21
17. In Order No. 693 the Commission
stated that in the currently-effective TPL
Reliability Standards a planner must
demonstrate through a valid assessment
that the transmission system
performance requirements can be met.
The TPL Reliability Standards require
that planned outages of transmission
equipment must be considered for those
demand levels for which planned
outages are performed. By modeling the
planned transmission equipment
outages and through the simulation of
various contingency events, a planner
must demonstrate that the system can be
operated to supply projected customer
demands for all maintenance outage
conditions and that amongst other
things, cascading or system instability
will not occur.22
18. For example, PJM has recently
evaluated a Doubs-Mt. Storm project
which includes the replacement of
structures that have deteriorated beyond
repair, which has resulted in the need
to rebuild the transmission circuit. PJM
indicates the maintenance outages will
be scheduled in four month blocks,
September—December and February—
May, starting in 2011 through 2015.
PJM’s analysis indicates that a list of
facilities has been determined that
should not be scheduled out
20 NERC
17 Order
No. 762, 139 FERC ¶ 61,160 at P 13.
18 Id. P 14.
19 June 2010 Order, 131 FERC ¶ 61,231 at P 21.
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concurrently with the Doubs-Mt. Storm
project. Furthermore, PJM analysis
indicated that if any outage on this list
of identified facilities must be taken out
of service, every effort shall be made to
align them with the lightest load period
possible.23 Based on NERC’s proposed
Requirement R1, Part 1.1.2 and the
Doubs-Mt. Storm example, it appears
that this type of planned maintenance
outage would be excluded from future
planning assessments and its potential
impact to bulk electric system reliability
would be unknown because the outage
duration in this example is less than six
months.
19. The Commission seeks comment
from the ERO and interested persons
whether the six month threshold would
materially change the number of
planned outages as compared to the
current standard. The Commission also
seeks comment on whether the
threshold would exclude almost all
planned outages from future planning
assessments, such as nuclear plant
refueling, large fossil and hydro
generating station maintenance, spring
and fall transmission construction
projects and items indentified in
correction actions plans of planning
assessments including neighboring
corrective action plans. The
Commission also seeks comment on
what alternative, whether based on
outage duration shorter than six months
or some other method, such as planners’
accounting for planned maintenance
outages of high capacity lines, critical
transformers, or nuclear outages during
non-peak load periods in their
assessments, captures the appropriate
number of planned outages and types of
planned outages to ensure that the BulkPower System can be operated to meet
system performance requirements
during high maintenance periods like
the spring and fall seasons. In addition
to seasonal peaks, there have been
significant system incidents which
occur because of unusual weather
events during non-seasonal peak
periods. The Commission seeks
comment on whether a six month
outage window would sufficiently
capture these events or if they would
not be addressed in the proposed
planning process. In addition, with
respect to protection system
maintenance, currently-effective
Reliability Standard TPL–002–0,
Requirement R1.3.12 requires the
planner to ‘‘[i]nclude the planned
(including maintenance) outage of any
bulk electric equipment (including
Petition at 35–36.
21 Id.
22 Order
No. 693, FERC Stats. & Regs. ¶ 31,242 at
PP 1772, 1799, 1827.
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protection systems or their components)
at those demand levels for which
planned (including maintenance)
outages are performed.’’ 24 NERC did not
carry over this language because
protection system maintenance or other
outages are not anticipated to last six
months. The Commission, however,
believes that it is critical to plan the
system so that a protection system can
be removed for maintenance and still be
operated reliably. Therefore, the
Commission seeks comment on its belief
that protection systems are necessary to
be included as a type of planned outage.
B. Violation Risk Factors
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1. VRF for Proposed TPL–001–2,
Requirement R1 VRF
20. NERC assigned a ‘‘Medium’’ VRF
for proposed Reliability Standard TPL–
001–2, Requirement R1 and its subrequirements. NERC states each primary
requirement in the proposed Reliability
Standard TPL–001–2 is assigned a VRF
considering the NERC guidelines and
consistent with NERC’s August 10, 2009
informational filing.25 NERC maintains
that Requirements R1.3.5, R1.3.7,
R1.3.8, and R1.3.9 of the currentlyeffective Reliability Standard TPL–001–
0.1 carry a VRF of ‘‘Medium’’ and are
similar in purpose and effect to
proposed Reliability Standard TPL–
001–2, Requirement R1. NERC states
that the Requirements are similar
because they refer to models that
include firm transfers, existing and
planned facilities, and reactive power
requirements, and they refer to the
Table 1 P0 condition. NERC believes
that a ‘‘medium VRF for Requirement
R1 is consistent with past Commission
guidance.’’ 26
21. NERC stated in its filing that
‘‘Requirement R1 of the proposed TPL–
001–2 explicitly requires the
Transmission Planner and Planning
Coordinator to maintain System
models.’’ 27 The Commission believes
that when the planning coordinator or
the transmission planner are
maintaining the system models to reflect
the normal system condition, if the
system models are not properly
modeled or maintained, the analysis
required in the Reliability Standard that
uses the models in Requirement R1,
such as Category P0 as the normal
24 Reliability Standard TPL–002–0, Requirement
R1.3.12.
25 Informational Filing of the North American
Electric Reliability Corporation Regarding the
Assignment of Violation Risk Factors and Violation
Severity Levels, Docket Nos. RM08–11–000, RR08–
4–000, RR07–9–000, and RR07–10–000 (August 10,
2009).
26 NERC Petition at Exhibit C, Table 1.
27 NERC Petition at 34.
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System condition in Table 1, may lose
their validity and ‘‘could, under
emergency, abnormal, or restorative
conditions anticipated by the
preparations, directly cause or
contribute to Bulk-Power System
instability, separation, or a cascading
sequence of failures, or could place the
Bulk-Power System at an unacceptable
risk of instability, separation, or
cascading failures, or could hinder
restoration to a normal condition.’’ 28
22. Furthermore, Requirement R1 of
the proposed Reliability Standard TPL–
001–2 explicitly addresses the
establishment of Category P0 as the
normal system condition in Table 1,
which creates the model of the normal
system as the ‘‘Initial Condition’’ prior
to any contingency.29 Requirement R1
of the currently-effective Reliability
Standard TPL–001–0, which has a VRF
of ‘‘High,’’ explicitly establishes
Category A as the normal system (all
facilities in service) in Table 1, which
also creates the model of the normal
system prior to any contingency. The
Commission believes that Requirement
R1 of proposed Reliability Standard
TPL–001–2 and Requirement 1 of
currently-effective TPL–001–0 both
establish the normal system planning
model that serves as the foundation for
all other conditions and contingencies
that are required to be studied and
evaluated in a planning assessment.
23. Consistent with Guideline 3 of the
Commission’s VRF Guidelines, the
Commission ‘‘expects the assignment of
Violation Risk Factors corresponding to
Requirements that address similar
reliability goals to be treated
comparably.’’ 30 The Commission seeks
comment on why Requirement R1 of
proposed Reliability Standard TPL–
001–2 carries a VRF of ‘‘Medium’’ while
Requirement R1 of the currentlyeffective Reliability Standard TPL–001–
0 carries a VRF of ‘‘High.’’
2. VRF for Proposed TPL–001–2,
Requirement R6
24. NERC proposes to assign a ‘‘Low’’
VRF for Requirement R6 from the
proposed Reliability Standard TPL–
001–2 because ‘‘failure to have
established criteria for determining
System instability is an administrative
requirement affecting a planning time
28 North American Electric Reliability Corp., order
on violation risk factors, 119 FERC ¶ 61,145, at P
9 (2007), order on reh’g and compliance filing, 120
FERC ¶ 61,145 (2007).
29 Proposed Reliability Standard TPL–001–2,
Table 1.
30 North American Electric Reliability Corp., order
on violation risk factors, 119 FERC ¶ 61,145, at P
25 (2007), order on reh’g and compliance filing, 120
FERC ¶ 61,145 (2007).
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frame.’’ 31 NERC explains that
Requirement R6 is a new requirement
and that violations would not be
expected to adversely affect the
electrical state or capability of the bulk
electric system.
25. Requirement R6 requires planning
coordinators and transmission planners
to define and document the criteria or
methodology used in their analyses to
identify system instability for
conditions such as cascading, voltage
instability or uncontrolled islanding.
The Commission recognizes that
documenting criteria or methodology is
an administrative act. However,
defining the criteria or methodology to
be used is not an administrative act. If
the criteria or methodology used by
planning coordinators and transmission
planners are not defined properly, the
analysis based on this criteria or
methodology could lose its validity and
‘‘could, under emergency, abnormal, or
restorative conditions anticipated by the
preparations, directly cause or
contribute to Bulk-Power System
instability, separation, or a cascading
sequence of failures, or could place the
Bulk-Power System at an unacceptable
risk of instability, separation, or
cascading failures, or could hinder
restoration to a normal condition.’’ 32
26. Requirement R6 co-mingles a
higher reliability objective (defining
criteria or methodology) with a lower
reliability objective (documentation).
Consistent with Guideline 5 of the
Commission’s VRF Guidelines, the
Commission seeks to ensure that the
assignment of Violation Risk Factors
corresponding to co-mingled
Requirements reflect the higher
reliability objective of the co-mingled
requirement.33 The Commission seeks
clarification from the ERO why the VRF
level assigned to Requirement R6 is
‘‘Low’’ since it is appears that
Requirement R6 requires more than a
purely administrative task.
C. Protection System Failures Versus
Relay Failures
27. NERC states that its modification
to the planning contingency categories
in Table 1 of the proposed standard is
intended to add clarity and consistency
regarding how a delayed fault clearing
will be modeled in planning studies.
NERC states that the basic elements of
any protection system design involve
inputs (i.e., current and D/C and A/C
voltage) to protective relays and outputs
(i.e., trip signals, close signals, and
31 NERC
Petition, Exhibit C, at 110.
American Electric Reliability Corp., order
on violation risk factors, 119 FERC ¶ 61,145 at P 9.
33 Id. P 32.
32 North
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alarms) from protective relays and that
reliability issues associated with
improper clearing of a fault on the bulk
electric system can result from the
failure of hundreds of individual
protection system components in a
substation. However, NERC believes
that while the population of
components that could fail and result in
improper clearing is large, that
population can be reduced dramatically
by eliminating those components which
share failure modes with other
components. NERC states that the
critical components in protection
systems are the protective relays
themselves, and a failure of a nonredundant protective relay will often
result in undesired consequences during
a fault. According to NERC, other
protection system components related to
the protective relay could fail and lead
to a bulk electric system issue, but the
event that would be studied is identical,
from both transient and steady state
perspectives, to the event resulting from
a protective relay failure if an adequate
population of protective relays is
considered.34
28. In the currently-effective TPL
Reliability Standards, Table 1
contingencies address the initiating
event and contingency of a single line
to ground (SLG) fault with delayed
clearing (stuck breaker or protection
system failure) for a generator,
transformer, transmission circuit and
bus section. For this initiating event and
set of contingencies, the planner must
demonstrate that Table 1 system
performance criteria can be met.35
29. Currently-effective Reliability
Standard TPL–003–0, Requirement
R1.3.1 states that current or past study
and/or system simulation testing ‘‘[b]e
performed and evaluated only for those
Category C contingencies that would
produce the more severe system results
or impacts.’’ 36 Referring to Table 1,
Category C6–C9, the initiating event and
contingency is described as ‘‘SLG Fault,
with Delayed Clearing (stuck breaker or
protection system failure).’’ 37
30. Requirement R1.3.1 states that in
the study and simulation of a protection
system failure, the planner should
assess the contingencies that produce
the more severe system results.38 If the
34 NERC
Petition at 48.
Reliability Standard TPL–
004–0, Categories C1–C4 address the same initiating
event and set of contingencies as currently-effective
TPL–003–0, Categories C6–C9, but the system
performance criteria are different for TPL–003–0
versus TPL–004–0.
36 Reliability Standard TPL–003–0a.
37 Reliability Standard TPL–003–0a (Category C).
38 Requirement R1.3.1 is included in TPL–002–
0b, TPL–003–0a and TPL–004–0.
35 Currently-effective
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contingency is a protection system
failure, delayed clearing is described as
a fault due to the failure of any
protection system component such as a
relay, circuit breaker, or current
transformer, and not because of an
intentional design delay.39
31. The Commission believes that
based on various protection system asbuilt designs, the planner will have to
choose which protection system
component failure would have the most
significant impact on the Bulk-Power
System because as-built designs are not
standardized and the most critical
component failure may not always be
the relay. For example, if a protection
system design used one set of fuses to
supply power to both the primary and
breaker failure relays, failure of one fuse
would be more severe than failure of
either one of the relays. Similar
dependencies can occur in specific
designs in the implementation of
microprocessor installations. As another
example, if a protection system
designed includes a shared voltage or
current sensing device that provides
input to relays for both the primary and
backup protection systems, failure of
this voltage sensing device would be
more severe than failure of either one of
the relays.
32. As a result, the planner’s selection
of a protection system component
failure may be influenced by the
protection system as-built design. If one
protection system component was an
integral component of primary
protection and breaker failure
protection, then it is possible that the
loss of that one component would
produce the more severe system impact.
If, in this example, the protection
system component failure was not a
relay component, as described in
Category P5 of the proposed TPL
Standard, it appears that this more
severe contingency (loss of both the
primary protection and breaker failure
protection systems due to the loss of one
protection system component) would
not be assessed under the proposed TPL
Reliability Standard.
33. The Commission seeks comments
on whether the proposed TPL
Reliability Standard, in the provisions
pertaining to study of multiple
contingencies, limits the planners’
assessment of a protection system
failure because it only includes the
contingency of a faulty relay
component. The Commission also seeks
comments on whether, based on
protection system as-built designs, the
relay may not always be the larger
39 Reliability Standard TPL–003–0, Table 1,
footnote e.
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contingency, and how the loss of
protection system components that may
be integral to multiple protection
systems impacts reliability.
D. Assessment of Backup or Redundant
Protection Systems
34. NERC states that proposed
Reliability Standard TPL–001–2,
Requirement R3, Part 3.3.1 and
Requirement R4, Part 4.3.1 require that
simulations faithfully duplicate what
will happen in an actual power system
based on the expected performance of
the protection systems.40 According to
NERC, these requirements ensure that if
a protection system is designed ‘‘to
remove multiple Elements from service
for an event that the simulation will be
run with all of those Elements removed
from service.’’ 41 This proposal is
intended to instill event-based analysis
over simple element analysis which will
provide for more accurate simulations.
35. The current TPL Reliability
Standards state that a planner must
include the effects of existing and
planned protection systems, including
any backup or redundant systems in its
planning assessment.42 Specifically,
Reliability Standard TPL–003–0,
Requirement R1.3.10 requires the
planner to ‘‘[i]nclude the effects of
existing and planned protection
systems, including any backup or
redundant systems.’’ 43 For this
requirement, the planner must include
the effects all protection systems,
including backup or redundant
protection systems.
36. NERC states that Reliability
Standard TPL–001–2, Requirement R3,
Part 3.3.1 and Requirement R4, Part
4.3.1 require the planner to ‘‘[s]imulate
the removal of all elements that the
Protection System and other automatic
controls are expected to disconnect for
each Contingency without operator
intervention.’’ The proposed NERC
provision, however, does not explicitly
refer to ‘‘backup or redundant systems’’
as in the currently effective TPL
standards. The Commission seeks
clarification from the ERO whether the
proposed Requirements address all
protection systems, including backup
and redundant protection systems that
can have an impact on the performance
of the bulk electric system.
E. P5 Single Line to Ground Faults
37. Table 1 of the proposed Reliability
Standard TPL–001–2 identifies the
40 NERC
Petition at 20.
41 Id.
42 E.g., Reliability Standards TPL–003–0, R1.3.10
and TPL–004–0, R1.3.7.
43 Reliability Standard TPL–003–0, R1.3.10 and
TPL–004–0, Requirement R1.3.7.
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initiating contingencies that must be
evaluated to ensure that the planned
system meets the performance
requirements. These proposed
modifications to Table 1 include
changing the classification of the events,
clarifying events and fault types, and
removing the ambiguity of performance
requirements. NERC states the proposed
Reliability Standard TPL–001–2, Table
1, P5 events are limited to the Single
Line to Ground (SLG) Fault type
consistent with the comparable C6–C9
events from Table 1 in the currentlyeffective TPL Reliability Standards.
NERC treats SLG and three phase faults
as different events even if an SLG event
evolves into a three phase fault.44
38. The proposed Reliability Standard
TPL–001–2, Table 1 includes a column
titled ‘‘fault type,’’ which contains the
specific designation of the fault type
such as SLG or three-phase faults.
‘‘Fault type’’ is described as a SLG or
three-phase fault types that must be
evaluated in stability simulations for the
event described. For example, a SLG
fault could evolve into a 3-phase fault,
but the initiating fault is the SLG fault
and the associated SLG performance
criteria must be applied, not the threephase performance criteria. The
Commission seeks clarification from the
ERO whether ‘‘fault types’’ in Table 1 of
the proposed Reliability Standard refers
to the initiating event or initiating fault
for the contingency rather than the type
of fault in to which the initiating fault
may evolve and how the clarification is
consistent with the simulations being
representative of what will occur in
real-time.
F. Order No. 693 Directives
39. While the Commission proposes
to remand based on the presence of
footnote 12, the balance of proposed
Reliability Standard TPL–001–2 appears
responsive to the Order No. 693
directives regarding the TPL Reliability
Standards. The Commission, however,
seeks clarification and comment on the
following.
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1. Peer Review of Planning Assessments
40. In Order No. 693, the Commission
stated that it ‘‘sees no reason why peer
reviews should not be part of a
Reliability Standard since TPL–001–0
through TPL–004–0 already include…a
review of assessment by the associated
regional reliability organization.’’ 45
44 NERC Petition at 49. Three phase events in the
existing TPL standards are shown in Table 1, D1–
D4 and are retained in TPL–001–2, Table 1, Extreme
Events.
45 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 1755.
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The Commission also stated that
because neighboring systems may be
adversely impacted by other
neighboring systems, such systems
should be involved in determining and
reviewing system conditions and
contingencies to be assessed under the
currently-effective TPL Standards.46
Furthermore, the peer review provides
for a neighboring entity to identify
possible interdependent or adverse
impacts on its neighboring systems and
thus, provides for an early opportunity
to provide input and coordinate plans.47
41. NERC states the proposed
Reliability Standard does not include a
‘‘peer review’’ of planning assessments
but instead includes ‘‘an equally
effective and efficient manner to
provide for the appropriate sharing of
information with neighboring systems’’
with the incorporation of Requirement
R3, Part 3.4.1, Requirement R4, Part
4.4.1, and Requirement R8.48 Part 3.4.1
provides:
The Planning Coordinator and
Transmission Planner shall coordinate with
adjacent Planning Coordinators and
Transmission Planners to ensure that
Contingencies on adjacent Systems which
may impact their Systems are included in the
Contingency list.49
NERC explains that ‘‘an entity may
always decline an offer to participate in
a peer review even when they should
participate’’ and ‘‘the distribution
approach means that the entity will
always receive the Planning
Assessment.’’ 50 NERC further states in
‘‘the course of the continuing cycle of
Planning Assessments, comments from
other entities at the end of a planning
cycle will be utilized at the beginning of
the next cycle as the planner moves
forward in time.’’ 51
42. The Commission seeks
clarification on how the NERC proposal
ensures the early input of peers into the
planning assessments or any type of
coordination amongst peers will occur.
The Commission seeks comment on
whether and how there is a sufficient
level of evaluation and ability to
provide feedback to the planners on the
development and result of assessments.
In addition, NERC states that that
Requirement R8 ‘‘ensures that
46 Id.
P 1750.
P 1754.
48 NERC Petition at 21.
49 Proposed Reliability Standard, TPL–001–2,
Requirement R3, Part 3.3.1. Part 4.4.1 is in all
material respects the same as Part 3.3.1.
50 NERC Petition at 22. Requirement R8 requires
distribution to adjacent planning coordinators and
transmission planners within 90 days and to others
with a reliability related need that submits a request
within 30 days of receiving such a request.
51 NERC Petition at 22.
47 Id.
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information is shared with * * *
adjacent entities’’ which ‘‘ensures * * *
input received from adjacent
entities.’’ 52 The Commission also seeks
comment on whether Requirement R8
requires input on the comments to be
included in the results or the
development of the Planning
Assessments.
2. Spare Equipment Strategy
43. In Order No. 693, the Commission
directed NERC to develop a
modification ‘‘to require assessments of
outages of critical long lead-time
equipment, consistent with the entity’s
spare equipment strategy.’’ 53 In
response, NERC developed proposed
Requirement 2, Part 2.1.5 which
addresses steady state conditions to
determine system response when
equipment is unavailable for prolonged
periods of time. The studies must be
performed for the P0, P1, and P2
categories in Table 1 ‘‘under the
condition that the system is expected to
experience during the possible periods
of unavailability of the long lead-time
equipment.’’ NERC states that
‘‘[s]tability impacts related to outages of
critical long lead-time equipment will
not be addressed in a separated
requirement but rather will be analyzed
in the normal planning process.’’ 54
44. NERC’s spare equipment strategy
appears to have limited the strategy to
steady state analysis (excluded stability
analysis).55 While including a spare
equipment strategy in the proposed
Reliability Standard is an improvement,
the Commission seeks clarification as to
why stability analysis conditions were
excluded from the spare equipment
strategy.
3. Controlled Load Interruption
45. In Order No. 693, the Commission
directed the ERO to modify footnote (c)
of Table 1 to the Reliability Standard
TPL–003–0a to clarify the term
‘‘controlled load interruption’’ to
‘‘ensure that third parties have access to
the same options that the transmission
owner uses to alleviate reliability
constraints including those related to
controlled load shedding.’’ 56 NERC
states in its petition that it excluded the
term ‘‘controlled load interruption’’ in
the proposed Reliability Standard TPL–
001–2, but NERC does not explain the
52 Id.
at 44.
No. 693, FERC Stats. & Regs. ¶ 31,242 at
53 Order
P 1786.
54 NERC Petition at 25.
55 Proposed Reliability Standard TPL–001–2,
Requirement R 2.1.5.
56 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 1818.
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reason for its exclusion.57 NERC added
the term ‘‘Non-Consequential Load
Loss’’ to the proposed Reliability
Standard TPL–001–2, Table 1 and
defined ‘‘Non-Consequential Load Loss’’
as: Non-Interruptible Load loss that does
not include: (1) Consequential Load
Loss, (2) the response of voltage
sensitive Load, or (3) Load that is
disconnected from the System by enduser equipment.58 In addition, NERC
added a new Requirement R2.1.4 for the
Near-Term Transmission Planning
Horizon portion of steady-state analysis
that includes ‘‘Controllable Loads’’ as
one of the conditions the planning
assessment must vary in the sensitivity
analysis for system peak load for year
one or year two, and for year five and
for system off-peak load for one of the
five years.
46. The term ‘‘controlled load
interruption’’ is found in footnote (c)
which is applicable to ‘‘Loss of Demand
or Curtailed Firm Transfers’’ in Table 1
of the existing TPL Reliability
Standards. The term ‘‘Loss of Demand
or Curtailed Firm Transfers’’ for
controlled load interruptions in Table 1
of the current TPL Standards appears to
be applicable to ‘‘Non-Consequential
Load Loss Allowed’’ in Table 1 of the
proposed TPL Standard. The
Commission seeks clarification from the
ERO if third-parties have access to the
same options that the transmission
owner has to alleviate reliability
constraints including load shedding
options for ‘‘Controllable Loads’’ in
Requirement 2.1.4 and ‘‘NonConsequential Load Loss Allowed’’ in
Table 1 of the proposed Reliability
Standard TPL–001–2.
4. Range of Extreme Events
47. In Order No. 693 the Commission
directed the ERO to modify Reliability
Standard TPL–004–0 to require that, in
determining the range of the extreme
events to be assessed, the contingency
list of Category D would be expanded to
include recent events such as hurricanes
and ice storms. NERC’s proposed
Reliability Standard TPL–001–2
appropriately expands the list of
extreme event examples in Table 1, but
the list limits these items to the loss of
two generating stations under Item No.
3a.59
48. The Commission seeks
clarification from the ERO on
57 NERC
Petition at 28.
Order No. 693, the Commission explained
that the term ‘‘consequential load loss’’ referred to
‘‘the load that is directly served by the elements
that are removed from service as a result of the
contingency.’’ Order No. 693, FERC Stats. & Regs.
¶ 31,242 at P 1794 n.461.
59 NERC Petition at 29–30.
58 In
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conditioning extreme events on the loss
of two generating stations.60 The
Commision understands that there are
scenarios where an extreme event can
impact more than two generation
stations that might not be captured due
to the ‘‘two generation stations’’
restriction in Item No. 3a. For example,
within the Florida peninsula, depending
on the location within the state, either
two or three main gas pipelines supply
the majority of the generation for the
area. In this scenario, the loss of one of
the gas pipelines would result in the
loss of more than two generation
stations. The Commission seeks
clarification regarding whether this
scenario is otherwise covered under the
catch-all provision in Item No. 3b which
states ‘‘[o]ther events based upon
operating experience that may result in
wide area disturbances.’’
5. Assessments and Documentation
49. The Commission seeks
clarification from the ERO that planning
assessments and associated
documentation will include accurate
representations of results on the bulk
electric system with respect to the
following.
a. Dynamic Load Models
50. In Order No. 693, the Commission
directed ‘‘the ERO to modify the
Reliability Standard to require
documentation of load models used in
system studies and the supporting
rationale for their use.’’ 61 Proposed
Reliability Standard TPL–001–2,
Requirement 2.4, Part 2.4.1 requires a
load model which represents the
expected dynamic behavior of loads that
could impact a study area, considering
the behavior of induction motor loads.
NERC states that this addition to the
proposed standard addresses the
specifics of the Order No. 693 directive
that requires ‘‘[d]ocument(ing) the load
models used in system studies and the
supporting rationale for their use.’’ 62
Under the proposed Requirement R2,
entities are required to document
assumptions made in the planning
assessments. The Commission seeks
clarification on whether the
documentation of the dynamic load
models used in system studies and the
supporting rationale for their use under
Requirement 2.4, Part 2.4.1 will be
included in the documented
assumptions under Requirement R2.
60 Id.
61 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 1789.
62 NERC Petition at 26.
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b. Proxies To Simulate Cascade
51. In Order No. 693, the Commission
observed that ‘‘if an entity models
overload relays, undervoltage relays, all
remedial action schemes including
those of neighboring systems and has a
good load representation, then proxies
are not required. However, due to
modeling and simulation limitations
this is often not the case and planners
invariably use proxies.’’ 63 Additionally,
the Commission stated that sharing of
proxies will improve knowledge and
understanding and promote a more
rigorous approach to analyzing
cascading outages. Accordingly, the
Commission directed the ERO to modify
the Reliability Standard to require
‘‘definition and documentation of
proxies necessary to simulate cascading
outages.’’ 64
52. NERC states that proposed
Requirement R6 ‘‘specifies that an entity
must define and document the criteria
or methodology used to identify system
instability for conditions such as
cascading, voltage instability, or
uncontrolled islanding within its
Planning Assessment.’’ 65 NERC adds
that this specificity in identifying these
‘‘proxies’’ is an important clarification
in the proposed revised standard and
‘‘will lead to greater transparency in the
planner’s evaluation techniques.’’ 66 The
Commission seeks clarification on
whether Requirement R6 includes the
documentation of proxies and that
Requirement R8 includes the sharing of
the documented proxies in the planning
assessments.
c. Footnote ‘a’
53. In Order No. 693 the Commission
directed NERC to modify ‘‘footnote (a)
of Table 1 with regard to applicability
of emergency rating and consistency of
normal ratings and voltages with values
obtained from other reliability
standards.’’ 67 NERC notes that proposed
Table 1, header note ‘e,’ which states
planned system adjustments must be
executable within the time duration
applicable to facility ratings, and header
note ‘f,’ which states applicable facility
ratings shall not be exceeded, meets this
directive thereby replacing footnote ‘a’
in the current standard.
54. The Commission observes that the
proposed standard applies header note
‘e’ to ‘‘Steady State and Stability’’ while
header note ‘f’ is excluded from
‘‘Stability’’ and only applies to ‘‘Steady
63 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at
P 1819.
64 Id. P 1820.
65 NERC Petition at 43–44.
66 Id.
67 Id. at 24.
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Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
State’’ studies. The Commission seeks
clarification from the ERO regarding the
rationale for excluding header note ‘f’
from ‘‘Stability’’ studies. Additionally,
the Commission seeks clarification on
which Reliability Standards the entities
should utilize when obtaining the
values to be used in their Planning
Assessments. In addition, for Table 1,
header notes ‘e’ and ‘f,’ the Commission
seeks comment on whether the normal
facility ratings align with, for example,
FAC–008–1 and normal voltage ratings
align with VAR–001–1. Furthermore,
the Commission seeks clarification from
the ERO whether facility ratings used in
planning assessments align with other
reliability standards such as NUC–001–
2, BAL–001–0.1a and PRC Standards for
UFLS and UVLS.
G. Commission Proposal
55. The Commission proposes to
remand NERC’s proposed TPL
Reliability Standard. While much of the
proposed Reliability Standard TPL–
001–2 appears just, reasonable, not
unduly discriminatory or preferential,
and in the public interest, we find that
footnote 12, allowing for transmission
planners to plan for non-consequential
load loss following a single contingency
without adequate safeguards,
undermines the potential benefits the
proposed Reliability Standard may
provide . This is consistent with the
Commission’s Final Rule in Docket No.
RM11–18–000 remanding footnote ‘b,’
which is substantially the same as
footnote 12. Thus, the Commission
proposes to remand the proposed
Reliability Standard TPL–001–2 to
NERC.
srobinson on DSK4SPTVN1PROD with PROPOSALS
III. Information Collection Statement
56. The Office of Management and
Budget (OMB) regulations require that
OMB approve certain reporting and
recordkeeping (collections of
information) imposed by an agency.68
The information contained here is also
subject to review under section 3507(d)
of the Paperwork Reduction Act of
1995.69
57. As stated above, the subject of this
NOPR is NERC’s proposed
modifications to the TPL Reliability
Standards. This NOPR proposes to
remand the proposed revisions to NERC.
By remanding the proposal, the
applicable Reliability Standards and any
information collection requirements are
unchanged. Therefore, the Commission
will submit this NOPR to OMB for
informational purposes only.
58. Interested persons may obtain
information on the reporting
requirements by contacting the
following: Federal Energy Regulatory
Commission, 888 First Street NE.,
Washington, DC 20426 [Attention: Ellen
Brown, Office of the Executive Director,
email: data.clearance@ferc.gov, phone:
(202) 502–8663, or fax: (202) 273–0873].
IV. Regulatory Flexibility Act
59. The Regulatory Flexibility Act of
1980 (RFA) 70 generally requires a
description and analysis of final rules
that will have significant economic
impact on a substantial number of small
entities. The RFA mandates
consideration of regulatory alternatives
that accomplish the stated objectives of
a proposed rule and that minimize any
significant economic impact on a
substantial number of small entities.
The Small Business Administration’s
(SBA) Office of Size Standards develops
the numerical definition of a small
business.71 The SBA has established a
size standard for electric utilities,
stating that a firm is small if, including
its affiliates, it is primarily engaged in
the transmission, generation and/or
distribution of electric energy for sale
and its total electric output for the
preceding twelve months did not exceed
four million megawatt hours.72 The RFA
is not implicated by this NOPR because
the Commission is remanding the
proposed TPL Reliability Standard and
not proposing any modifications to the
existing burden or reporting
requirements. With no changes to the
Reliability Standards as approved, the
Commission certifies that this NOPR
will not have a significant economic
impact on a substantial number of small
entities.
V. Comment Procedures
60. 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 60 days from
publication in the Federal Register.
Comments must refer to Docket No.
RM12–1–000, and must include the
commenter’s name, the organization
they represent, if applicable, and their
address in their comments.
61. 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
70 5
U.S.C. 601–612.
CFR 121.201.
72 Id.
68 5
CFR 1320.11.
69 44 U.S.C. 3507(d).
VerDate Mar<15>2010
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71 13
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word processing formats. Documents
created electronically using word
processing software should be filed in
native applications or print-to-PDF
format and not in a scanned format.
Commenters filing electronically do not
need to make a paper filing.
62. Commenters that are not able to
file comments electronically must send
an original of their comments to:
Federal Energy Regulatory Commission,
Secretary of the Commission, 888 First
Street NE., Washington, DC 20426.
63. 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.
VI. Document Availability
64. In addition to publishing the full
text of this document in the Federal
Register, the Commission provides all
interested persons an opportunity to
view and/or print the contents of this
document via the Internet through
FERC’s Home Page (https://www.ferc.gov)
and in FERC’s Public Reference Room
during normal business hours (8:30 a.m.
to 5:00 p.m. Eastern time) at 888 First
Street NE., Room 2A, Washington DC
20426.
65. From FERC’s Home Page on the
Internet, this information is available on
eLibrary. The full text of this document
is available on eLibrary in PDF and
Microsoft Word format for viewing,
printing, and/or downloading. To access
this document in eLibrary, type the
docket number excluding the last three
digits of this document in the docket
number field.
66. User assistance is available for
eLibrary and the FERC’s Web site during
normal business hours from FERC
Online Support at (202) 502–6652 (toll
free at 1–866–208–3676) or email at
ferconlinesupport@ferc.gov, or the
Public Reference Room at (202) 502–
8371, TTY (202) 502–8659. Email the
Public Reference Room at
public.referenceroom@ferc.gov.
By direction of the Commission.
Commissioner Norris is concurring in part
with a separate statement attached.
Kimberly D. Bose,
Secretary.
Norris, Commissioner, concurring in
part:
In today’s order, the Commission proposes
to remand proposed Transmission Planning
Reliability Standard TPL–001–2 to NERC,
based on the decision by the Commission to
remand proposed TPL–002–0b in the
concurrently-issued Transmission Planning
E:\FR\FM\07MYP1.SGM
07MYP1
Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
Reliability Standards.1 For the reasons
articulated in my separate statement in Order
No. 762, I agree with the decision here to
remand proposed TPL–001–2, but I do not
fully agree with the basis identified by the
majority in their decision.
Thus, I respectfully concur in part.
John R. Norris,
Commissioner
[FR Doc. 2012–10943 Filed 5–4–12; 8:45 am]
BILLING CODE 6717–01–P
DEPARTMENT OF TRANSPORTATION
Federal Transit Administration
49 CFR Part 661
[Docket No. FTA–2012–0009]
Notice of Proposed Buy America
Waivers
Federal Transit Administration
(FTA), DOT.
ACTION: Notice of proposed Buy America
waivers and request for comments.
AGENCY:
The Federal Transit
Administration (FTA) received several
requests to waive its Buy America
requirements for products used in ticket
vending machines—the Mars
Electronics International (MEI) Sodeco
BNA57/542 Bill Handling Unit, and
BNR3–XX, BNR4–XX and BNR5–XX
Bank Note Recycler product; and the
Nextek Corporation (Nextek) BV–
6000AG (BV–6000) Currency Validator
Tekpak. FTA seeks public comment
before deciding whether to grant the
requests.
SUMMARY:
Comments must be received by
June 6, 2012. Late filed comments will
be considered to the extent practicable.
ADDRESSES: Please submit your
comments by only one of the following
means, identifying your submissions by
docket number FTA–2012–0009. All
electronic submissions must be made to
the U.S. Government electronic site at
www.regulations.gov. Commenters
should follow the instructions below for
mailed and hand delivered comments.
(1) Web site: www.regulations.gov.
Follow the instructions for submitting
comments on the U.S. Government
electronic docket site;
(2) Fax: (202) 493–2251;
(3) Mail: U.S. Department of
Transportation, 1200 New Jersey
Avenue SE., Docket Operations, M–30,
Room W12–140, Washington DC,
20590–0001.
(4) Hand Delivery: Room W12–140 on
the first floor of the West Building, 1200
srobinson on DSK4SPTVN1PROD with PROPOSALS
DATES:
1 Order
No. 762, 139 FERC ¶ 61,060 (2012).
VerDate Mar<15>2010
17:41 May 04, 2012
Jkt 226001
New Jersey Avenue SE, Washington, DC
20590, between 9:00 a.m. and 5:00 p.m.,
Monday through Friday, except Federal
holidays.
Instructions: All submissions must
refer to the ‘‘Federal Transit
Administration’’ and include docket
number FTA–2012–0009. Due to
security procedures in effect since
October 2001, mail received through the
U.S. Postal Service may be subject to
delays. Parties making submissions
responsive to this notice should
consider using an express mail firm to
ensure the prompt filing of any
submissions not filed electronically or
by hand. Note that all submissions
received, including any personal
information therein, will be posted
without change or alteration to
www.regulations.gov. For More
information, you may review DOT’s
complete Privacy Act Statement in the
Federal Register published on April 11,
2000 (65 FR 19477), or visit
www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Jayme L. Blakesley at (202) 366–0304 or
jayme.blakesley@dot.gov.
SUPPLMENTARY INFORMATION: The
purpose of this notice is to seek public
comment on whether the Federal
Transit Administration should continue
to waive its Buy America requirements
for two years for Mars Electronics
International (MEI)’s Sodeco BNA57/
542 Bill Handling Unit BNR3–XX,
BNR4–XX and BNR5–XX Bank Note
Recycler products, and the Nextek
Corporation’s (Nextek) BV–6000AG
(BV–6000) Currency Validator Tekpak,
or whether FTA should extend the nonshift approach adopted in its 2007 Final
Rule (72 FR 53688, September 20, 2007)
to the procurement of such devices.
Waiver Request: MEI Sodeco BNA57/
542 Bill Handling Unit
MEI requested an extension of the
Buy-America non-availability
component waiver under CFR 661.7(g)
for the MEI Sodeco BNA57/542 Bill
Handling Units. The FTA granted the
initial waiver for these products on July
21, 2000, and has extended the waiver
periodically ever since, on December 10,
2003, November 12, 2004, October 20,
2006, and February 23, 2009.
Buy America requires, with few
exceptions, that all steel, iron and
manufactured goods used in FTAfunded projects be produced in the
United States. One such exception is
that of non-availability, that in some
instances steel, iron, and goods
produced in the United States are not
produced in the United States in
sufficient and reasonably available
PO 00000
Frm 00018
Fmt 4702
Sfmt 4702
26723
quantities or are not of a satisfactory
quality. Therefore, Congress authorized
FTA to waive the above requirement
and allow, based on non-availability,
the use in an FTA-funded project of
steel, iron or manufactured goods
produced outside the United States.
According to MEI, the Sodeco
BNA57/542 Bill Handling Units
includes a multiple bill escrow (up to 15
bills) that enables return of the
customer’s inserted bills in situations
where the transaction is not complete.
The unit has the ability to identify,
validate and accept multiple note
denominations (US $1, $5, $10, $20,
$50, $100) utilizing all optical
recognition, and allowing for the
acceptance of bills in a face up or face
down orientation. It also supports
remote download, giving a transit
agency the option of downloading new
bill recognition software (bill variants)
via network from one central location.
MEI’s customers include the
Washington Metropolitan Area Transit
Authority (WMATA), New York City
Transit (MTA), and the Bay Area Rapid
Transit Authority (BART).
In 1999, to support its initial waiver
request, MEI performed a market
research study. It found no equivalent
products manufactured within the
United States. In preparation of the
instant waiver request, MEI reviewed its
earlier findings and compared them
with the known providers of payment
systems to the transit market. They
found no US manufacturers of
functionally equivalent products.
Companies they identified who supply
a similar product—GAO/Geiseke &
Deviran (G&D), Toyocom, and
Cashcode—all manufacture their
products outside of the United States.
Waiver Request: MEI BNY3–XX &
BNR5–XX Bank Note Recycler Products
In a letter dated February 28, 2011,
MEI requested an extension of the Buy
America non-availability component
waiver under CFR 667.7(g) for BNY3–
XX & BNR5–XX Bank Note Recycler
products. The initial waiver was granted
by FTA on October 20, 2008. The Bank
Note Recycler (BNR) can accept and
validate bank notes and pay them back
out as change. The unit has the ability
to identify, validate and accept multiple
bank note denominations (US $1, $5,
$10, $20, $50, $100) utilizing all optical
recognition. This allows for the
acceptance of bank notes in a face-up or
facedown orientation. The unit has
multiple-note escrow function (up to 15
Bank notes) that enables return of the
customer’s inserted bank notes, in
situations where the transaction is not
complete, or presentation of bank notes
E:\FR\FM\07MYP1.SGM
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Agencies
[Federal Register Volume 77, Number 88 (Monday, May 7, 2012)]
[Proposed Rules]
[Pages 26714-26723]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-10943]
[[Page 26714]]
=======================================================================
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
18 CFR Part 40
[Docket No. RM12-1-000]
Transmission Planning Reliability Standards
AGENCY: Federal Energy Regulatory Commission, DOE.
ACTION: Notice of Proposed Rulemaking.
-----------------------------------------------------------------------
SUMMARY: The North American Electric Reliability Corporation (NERC),
the Commission-certified Electric Reliability Organization, petitions
for the approval of modified Transmission Planning Reliability
Standard, TPL-001-2 (Transmission System Planning Performance
Requirements), which combines four currently effective TPL Reliability
Standards, TPL-001-1, TPL-002-1b, TPL-003-1a, and TPL-004-1, into a
single standard. NERC also requests retirement of the currently-
effective TPL standards. Pursuant to section 215 of the Federal Power
Act, the Federal Energy Regulatory Commission proposes to remand
proposed Reliability Standard, TPL-001-2. The proposed Reliability
Standard includes a provision that would allow a transmission planner
to plan for non-consequential load loss following a single contingency
provided that the plan is documented and vetted in an open and
transparent stakeholder process. The Commission believes that, with the
inclusion of this provision, proposed TPL-001-2 does not meet the
statutory criteria for approval.
DATES: Comments are due July 6, 2012.
ADDRESSES: You may submit comments, identified by docket number by any
of the following methods:
Agency Web Site: https://ferc.gov. Documents created
electronically using word processing software should be filed in native
applications or print-to-PDF format and not in a scanned format.
Mail/Hand Delivery: Commenters unable to file comments
electronically must mail or hand deliver comments to: Federal Energy
Regulatory Commission, Secretary of the Commission, 888 First Street
NE., Washington, DC 20426.
FOR FURTHER INFORMATION CONTACT: Eugene Blick (Technical Information),
Office of Electric Reliability, Federal Energy Regulatory Commission,
888 First Street NE., Washington, DC 20426, Telephone: (202) 502-8066,
Eugene.Blick@ferc.gov.
Robert T. Stroh (Legal Information), Office of the General Counsel,
Federal Energy Regulatory Commission, 888 First Street NE., Washington,
DC 20426, Telephone: (202) 502-8473, Robert.Stroh@ferc.gov.
SUPPLEMENTARY INFORMATION:
139 FERC ] 61,059
Notice of Proposed Rulemaking
April 19, 2012
1. The North American Electric Reliability Corporation (NERC), the
Commission-certified Electric Reliability Organization (ERO), petitions
for the approval of Reliability Standard, TPL-001-2 (Transmission
System Planning Performance Requirements), which combines four
currently effective TPL Reliability Standards, TPL-001-1, TPL-002-1b,
TPL-003-1a, and TPL-004-1, into a single standard. NERC also requests
retirement of the currently effective TPL standards. Pursuant to
section 215(d) of the Federal Power Act (FPA), the Federal Energy
Regulatory Commission (FERC) proposes to remand proposed Reliability
Standard, TPL-001-2. The proposed Reliability Standard includes a
provision in Table 1 (Steady State and Stability Performance Extreme
Events), footnote 12 that would allow a transmission planner to plan
for ``non-consequential load loss,'' i.e., load shedding, following a
single contingency provided that the plan is documented and
alternatives are considered and subject to review in an open and
transparent stakeholder process. As discussed below, the Commission
believes that this provision is vague and unenforceable because it does
not adequately define the circumstance in which an entity can plan for
non-consequential load loss following a single contingency.
Accordingly, the Commission proposes to find that, with the inclusion
of this provision, proposed TPL-001-2 does not meet the statutory
criteria for approval that a mandatory Reliability Standard must be
just, reasonable, not unduly discriminatory or preferential, and in the
public interest.
2. NERC states that proposed Reliability Standard TPL-001-2
introduces significant revisions and improvements to the Transmission
Planning Reliability Standards, including increased specificity of data
required for modeling conditions, and requires planners to address the
impact of the unavailability of long lead-time critical equipment in a
manner consistent with the entity's spare equipment strategy.\1\
Further, according to NERC, the proposed Reliability Standard addresses
twenty-seven Commission directives set forth in Order No. 693 and
subsequent Commission orders.\2\ We agree with NERC that proposed TPL-
001-2 includes specific improvements over the currently effective
Transmission Planning Reliability Standards and, as discussed below, is
responsive to certain Commission directives. However, the provision in
the proposed Reliability Standard allowing for transmission planners to
plan for non-consequential load loss following a single contingency
without adequate safeguards undermines the potential benefits the
proposed Reliability Standard may provide. Section 215(d)(4) requires
that the Commission remand to the ERO for further consideration a
Reliability Standard ``that the Commission disapproves in whole or in
part.'' \3\ Thus, notwithstanding improvements contained in other
provisions of proposed Reliability Standard TPL-001-2, our concerns
regarding the stakeholder process set forth in Table 1, footnote 12
provides us no option other than to propose to remand the entire
Reliability Standard.
---------------------------------------------------------------------------
\1\ NERC Petition at 4.
\2\ Mandatory Reliability Standards for the Bulk-Power System,
Order No. 693, FERC Stats. & Regs. ] 31,242, order on reh'g, Order
No. 693-A, 120 FERC ] 61,053 (2007).
\3\ 16 U.S.C. 824o(d)(4) (2006) (emphasis added).
---------------------------------------------------------------------------
3. We are concurrently issuing a Final Rule in Docket No. RM11-18-
000 that remands a related Reliability Standard, TPL-002-0b, which
contains the same objectionable stakeholder process provision in Table
1, footnote `b'.\4\ In the Final Rule in Docket No. RM11-18-000, the
Commission urges NERC to employ its Expedited Reliability Standards
Development Process to timely develop a modified provision regarding
planned shedding of non-consequential load loss that satisfies the
relevant Commission's directives in Order No. 693 and the subsequent
orders. A rapid resolution of this one matter will allow the industry,
NERC and the Commission to go forward with the consideration of other
improvements contained in proposed Reliability Standard TPL-001-2.
---------------------------------------------------------------------------
\4\ Transmission Planning Reliability Standards, Order No. 762,
139 FERC ] 61,060 (2012).
---------------------------------------------------------------------------
I. Background
4. Section 215 of the FPA requires a Commission-certified ERO to
develop mandatory and enforceable Reliability Standards, which are
subject to Commission review and approval. Approved Reliability
Standards are enforced by the ERO, subject to Commission oversight, or
by the Commission independently.
5. Pursuant to section 215 of the FPA, the Commission established a
process to
[[Page 26715]]
select and certify an ERO \5\ and, subsequently, certified NERC as the
ERO.\6\ On March 16, 2007, the Commission issued Order No. 693,
approving 83 of the 107 Reliability Standards filed by NERC, including
the existing TPL Reliability Standards. In addition, pursuant to
section 215(d)(5) of the FPA,\7\ the Commission directed NERC to
develop modifications to 56 of the 83 approved Reliability Standards,
including the TPL Reliability Standards.\8\
---------------------------------------------------------------------------
\5\ Rules Concerning Certification of the Electric Reliability
Organization; and Procedures for the Establishment, Approval and
Enforcement of Electric Reliability Standards, Order No. 672, FERC
Stats. & Regs. ] 31,204, order on reh'g, Order No. 672-A, FERC
Stats. & Regs. ] 31,212 (2006).
\6\ North American Electric Reliability Corp., 116 FERC
61,062, order on reh'g and compliance, 117 FERC ] 61,126
(2006), aff'd sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (DC Cir.
2009).
\7\ 16 U.S.C. 824o(d)(5).
\8\ Order No. 693, FERC Stats. & Regs. ] 31,242 at PP 1691-1845.
---------------------------------------------------------------------------
A. Transmission Planning (TPL) Reliability Standards and Order No. 693
Directives
6. The currently-effective TPL Reliability Standards consists of
four approved standards and are intended to ensure that the
transmission system is planned and designed to meet an appropriate and
specific set of reliability criteria. Transmission planning is a
process that involves a number of stages including developing a model
of the Bulk-Power System, using this model to assess the performance of
the system for a range of operating conditions and contingencies,
determining those operating conditions and contingencies that have an
undesirable reliability impact, identifying the nature of potential
options, and developing and evaluating a range of solutions and
selecting the preferred solution, taking into account the time needed
to place the solution in service.
7. In Order No. 693, the Commission accepted the Version 0 TPL
Reliability Standards and directed NERC, pursuant to FPA section
215(d)(5), to develop modifications to TPL-001-0 through TPL-004-0
through the Reliability Standards development process. In addition, the
Commission neither approved nor remanded two other planning Reliability
Standards, TPL-005-0 and TPL-006-0, as these two Reliability Standards
applied only to regional reliability organizations.\9\ The Commission
encouraged the ERO to monitor a series of technical conferences and
regional meetings to obtain industry input to achieve the goal of
regional planning and use the results as input to the standards
development process to revise TPL-005-0 to address regional planning
and related processes.\10\
---------------------------------------------------------------------------
\9\ Order No. 693, FERC Stats. & Regs. ] 31,242 at PP 1840,
1845. The currently-effective versions of the TPL Reliability
Standards are as follows: TPL-001-0.1, TPL-002-0b, TPL-003-0a, and
TPL-004-0.
\10\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 1841.
---------------------------------------------------------------------------
8. With regard to Reliability Standard TPL-002-0b, Table 1,
footnote `b', the Commission directed NERC to clarify footnote `b'
regarding the loss of non-consequential load for a single contingency
event. In a March 18, 2010 order, the Commission directed NERC to
submit a modification to footnote `b' responsive to the Commission's
directive in Order No. 693, by June 30, 2010.\11\ In a June 11, 2010
order, the Commission granted partial clarification to NERC and
extended the compliance deadline until March 31, 2011.\12\
---------------------------------------------------------------------------
\11\ Mandatory Reliability Standards for the Bulk Power System,
130 FERC ] 61,200 (2010) (March 2010 Order).
\12\ Mandatory Reliability Standards for the Bulk Power System,
131 FERC ] 61,231 (2010) (June 2010 Order).
---------------------------------------------------------------------------
B. RM11-18-000 Proposed Remand of Footnote `b'--Version 1
9. In response to the March 2010 and June 2010 Orders, on March 31,
2011, NERC submitted proposed TPL-002-1 (Version 1), which proposed to
modify footnote `b' to permit planned interruption of Firm Demand when
documented and subject to an open stakeholder process. On October 20,
2011, the Commission issued a Notice of Proposed Rulemaking that
proposed to remand to NERC the proposed modification to footnote `b'
because it does not adequately clarify or define the circumstances in
which an entity can plan to use interruption of Firm Demand as a
mitigation plan to resolve a single contingency.\13\ The Commission
stated that the procedural and substantive parameters of NERC's
proposal are too undefined to provide assurances that the process will
be effective in determining when it is appropriate to plan for
interrupting Firm Demand, do not contain NERC-defined criteria on
circumstances to determine when an exception for planned interruption
of Firm Demand is permissible, and could result in inconsistent results
in implementation. In the Final Rule issued concurrently with the NOPR
in the immediate proceeding, the Commission remanded proposed
Reliability Standard TPL-002-0b.
---------------------------------------------------------------------------
\13\ Transmission Planning Reliability Standards, 137 FERC ]
61,077 (2011).
---------------------------------------------------------------------------
C. NERC's Petition for Approval of TPL-001-2
10. On October 19, 2011, NERC filed a petition seeking approval of
Reliability Standard TPL-001-2, the associated implementation plan and
Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs), as
well as five new definitions to be added to the NERC Glossary of Terms
(Version 2). NERC also seeks approval of the retirement of the
following four Reliability Standards: TPL-001-1 (System Performance
Under Normal (No Contingency) Conditions (Category A)); TPL-002-1b
(System Performance Following Loss of a Single Bulk Electric System
(BES) Element (Category B)); TPL-003-1a (System Performance Following
Loss of Two or More BES Elements (Category C)); and TPL-004-1 (System
Performance Following Extreme Events Resulting in the Loss of Two or
More Bulk Electric System Elements (Category D)). In addition, NERC
requests to withdraw two pending Reliability Standards: TPL-005-0
(Regional and Interregional Self-Assessment Reliability Reports) and
TPL-006-0.1 (Data from the Regional Reliability Organization Needed to
Assess Reliability).
11. The Version 2 standard also includes language similar to NERC's
Version 1 March 31, 2011, proposal to revise and clarify footnote `b'
of Table 1 applicable in four currently-effective TPL Reliability
Standards ``in regard to non-consequential firm load loss in the event
of a single contingency.'' \14\ The proposed Reliability Standard TPL-
001-2 (Version 2) expands upon NERC's proposed footnote `b' (Version 1)
and as a result, Version 2 replaces in its entirety the Version 1
footnote `b.' In creating TPL-001-2, the proposed footnote `b' in
Version 1 was modified slightly and carried over as Steady State &
Stability Performance Footnotes 9 and 12 in Version 2. In other words,
footnote `b' in Version 1 has been divided into two footnotes in
Version 2, and the subject of the concerns raised by the Commission
with respect to the Version 1 footnote `b' are now contained in
footnote 12 of Version 2. Footnote 12 in Version 2 is in all material
respects the same as the portion of footnote `b' in Version 1 that is
the subject of the Final Rule issued today in Docket No. RM11-18-000.
---------------------------------------------------------------------------
\14\ NERC Petition at 11.
---------------------------------------------------------------------------
D. Proposed Reliability Standard
12. As proposed by NERC, TPL-001-2 includes eight requirements and
Table 1, summarized as follows:
[[Page 26716]]
Requirement R1: Requires the transmission planner and planning
coordinator to maintain system models and provides a specific list of
items required for the system models and that the models represent
projected system conditions. The planner is required to model the items
that are variable, such as load and generation dispatch, based
specifically on the expected system conditions.
Requirement R2: Requires each transmission planner and planning
coordinator to prepare an annual planning assessment of its portion of
the bulk electric system and must use current or qualified past
studies, document assumptions, and document summarized results of the
steady state analyses, short circuit analyses, and stability analyses.
Requirement R2, Part 2.1.3 requires the planner to assess system
performance utilizing a current annual study or qualified past study
for each known outage with a duration of at least six months for
certain events listed in Table 1, P1. NERC states that this requirement
ensures planners evaluate every known outage with known duration of six
months or more, even if the known outage is not within one of the study
years selected by the planner. NERC states that the requirements and
parts of proposed TPL-001-2 provide for what a valid study must entail,
timeframes for use of past studies, minimum conditions, what needs to
be included in the model, and what performance must be achieved. It
also clarifies that qualified past studies can be utilized in the
analysis while tightly defining the qualifications for those studies.
The use of qualified past studies allows an entity to continue to use
validated studies to complete its assessment. Requirement R2 includes a
new part (2.7.3) that allows transmission planners and planning
coordinators to utilize Non-Consequential Load Loss to meet performance
requirements if the applicable entities are unable to complete a
Corrective Action Plan due to circumstances beyond their control.
Requirements R3 and R4: Requirement R3 describes the requirements
for steady state studies and Requirement R4 explains the requirements
for stability studies. Requirement R3 and Requirement R4 also require
that simulations duplicate what will occur in an actual power system
based on the expected performance of the protection systems. These
requirements are intended to ensure that if a protection system is
designed to remove multiple elements from service for an event that the
simulation will be run with all of those elements removed from service.
Requirement R3 and Requirement R4 also include new parts that require
the planners to conduct an evaluation of possible actions designed to
reduce the likelihood or the consequences of extreme events that cause
cascading.
Requirement R5: Requirement R5 deals with voltage criteria and
voltage performance. NERC proposes in Requirement R5 that each
transmission planner and planning coordinator must have criteria for
acceptable system steady state voltage limits, post-contingency voltage
deviations, and the transient voltage response for its system. For
transient voltage response the criteria must specify a low-voltage
level and a maximum length of time that transient voltages may remain
below that level. This requirement will establish more robust
transmission planning for organizations and greater consistency as
these voltage criteria are shared.
Requirement R6: Specifies that an entity must define and document
the criteria or methodology used to identify system instability for
conditions such as cascading, voltage instability, or uncontrolled
islanding within its planning assessment.
Requirement R7: Mandates coordination of individual and joint
responsibilities for the planning coordinator and the transmission
planner which is intended to eliminate confusion regarding the
responsibilities of the applicable entities and assures that all
elements needed for regional and wide area studies are defined with a
specific entity responsible for each element and that no gaps will
exist in planning for the Bulk-Power System.
Requirement R8: Addresses the sharing of planning assessments with
neighboring systems. The requirement ensures that information is shared
with and input received from adjacent entities and other entities with
a reliability related need that may be affected an entity's system
planning.
Table 1: Similar to the existing TPL Standard, NERC's proposal
contains a series of planning events and describes system performance
requirements in Table 1 for a range of potential system contingencies
required to be evaluated by the planner. Table 1 includes three parts:
Steady State & Stability Performance Planning Events, Steady State &
Stability Performance Extreme Events, and Steady State & Stability
Performance Footnotes. Table 1 describes system performance
requirements for a range of potential system contingencies required to
be evaluated by the planner. The table categorizes the events as either
``planning events'' or ``extreme events.'' The proposed table lists
seven Contingency planning events (P1 through P7) that require steady-
state and stability analysis as well as five extreme event
contingencies--three for steady-state and two for stability. The
proposed table also includes a no contingency ``event'' labeled as P0
which requires steady state analysis. Footnote 12 of Table 1 provides:
An objective of the planning process should be to minimize the
likelihood and magnitude of Non-Consequential Load Loss following
Contingency events. However, in limited circumstances Non-
Consequential Load Loss may be needed to address BES performance
requirements. When Non-Consequential Load Loss is utilized within
the planning process to address BES performance requirements, such
interruption is limited to circumstances where the Non-Consequential
Load Loss is documented, including alternatives evaluated; and where
the utilization of Non-Consequential Load Loss is subject to review
in an open and transparent stakeholder process that includes
addressing stakeholder comments.\15\
---------------------------------------------------------------------------
\15\ NERC Petition at 12. In NERC's proposal in Docket No. RM11-
18-000, Table 1, footnote `b' planned load shed is called planned
``interruption of Firm Demand.'' In footnote 12, NERC has changed
the term from ``interruption of Firm Demand'' to utilization of
``Non-Consequential Load Loss.''
II. Discussion
13. The Commission proposes to remand proposed Reliability Standard
TPL-001-2. The proposed footnote 12 included as part of Reliability
Standard TPL-001-2, which is in all material respects the same as the
Version 1 footnote `b' proposal described in Docket No. RM11-18-000, is
unjust and unreasonable, unduly discriminatory or preferential, and not
in the public interest. Although there are many improvements in the
proposed TPL-001-2, the presence of footnote 12 in proposed Reliability
Standard TPL-001-2 requires that the Commission remand the entire
proposed Reliability Standard.\16\
---------------------------------------------------------------------------
\16\ 16 U.S.C. 824o(d)(4).
---------------------------------------------------------------------------
14. As described in the Final Rule in Docket No. RM11-18-000, the
Commission believes that NERC's footnote `b' proposal (footnote 12 in
this NOPR proceeding) does not clarify or define the circumstances in
which an entity can plan to interrupt Non-Consequential Load Loss for a
single contingency. The Commission is concerned that footnote 12 is
inadequate and fails to address the Commission's concerns for three
reasons. First, proposed footnote 12 lacks adequate parameters. Second,
the NERC proposal leaves undefined the circumstances in
[[Page 26717]]
which it is allowable to plan for Non-Consequential Load Loss to be
utilized. The Commission believes that footnote 12 could function as a
means to override the reliability objective and system performance
requirements of the TPL Reliability Standard without any technical or
other criteria specified to determine when planning to use Non-
Consequential Load Loss to meet single contingency performance
requirements would be allowable.\17\ While NERC expects that such
determinations will be made in a stakeholder process, this provides no
assurance that such a process will use technically sound means of
approving or denying exceptions.\18\ Third, while the Commission
recognizes that some variation among regions or entities is reasonable
given varying grid topography and other considerations, there are no
technical criteria to determine whether varied results are arbitrary or
based on meaningful distinctions.\19\ The Commission, thus, concludes
that NERC's proposal lacks safeguards to ensure against inconsistent
results and arbitrary determinations to allow for the planned
interruption of load shed.
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\17\ Order No. 762, 139 FERC ] 61,160 at P 13.
\18\ Id. P 14.
\19\ June 2010 Order, 131 FERC ] 61,231 at P 21.
---------------------------------------------------------------------------
15. While we propose to remand Reliability Standard TPL-001-2
because of footnote 12, the Commission sees improvements to the balance
of the proposed Reliability Standard. The Commission recognizes the
level of complexity and substantial revision that NERC undertook to
consolidate the requirements in the four currently-effective TPL
Reliability Standards into one standard, and that effort has yielded
improvements relative to the current set of standards. The Commission,
however, seeks comments from the ERO and other interested persons
regarding the following important reliability issues to ensure that the
proposed Reliability Standard adequately maintains reliability and that
the directives have been met: (a) Planned Maintenance Outages, (b)
Violation Risk Factors, (c) Protection System Failures versus Relay
Failures, (d) Assessment of Backup or Redundant Protection Systems, (e)
Single Line to Ground Faults, and (f) Order No. 693 Directives.
A. Planned Maintenance Outages
16. NERC proposed new language in TPL-001-2, Requirement R1 to
remove an ambiguity in the current standard concerning what the planner
needs to include in the specific studies. It also requires the planner
to evaluate six-month or longer duration outages within its system.
NERC states that while Requirement R1.3.12 of the currently-effective
TPL-002-0b, includes planned outages (including maintenance outages) in
the planning studies and requires simulations at the demands levels for
which the planned outages are performed, it is not appropriate to have
the planner select specific planned outages for inclusion in their
studies. Consequently, NERC proposes a bright-line test to determine
whether an outage should be included in the system models.
Specifically, NERC proposes that Requirement R1, Part 1.1.2 mandate
that the system models ``shall represent * * * known outage(s) of
generation or Transmission Facility(ies) with a duration of at least
six months.'' \20\ NERC determined that, in the planning horizon, a
six-month or longer outage duration would necessarily extend over a
seasonal peak load period and should be included in the planning
models. Therefore, NERC states that the specific elements selected to
be evaluated are selected by the transmission planner or planning
coordinator and must be acceptable to the associated regional
reliability organization.\21\
---------------------------------------------------------------------------
\20\ NERC Petition at 35-36.
\21\ Id.
---------------------------------------------------------------------------
17. In Order No. 693 the Commission stated that in the currently-
effective TPL Reliability Standards a planner must demonstrate through
a valid assessment that the transmission system performance
requirements can be met. The TPL Reliability Standards require that
planned outages of transmission equipment must be considered for those
demand levels for which planned outages are performed. By modeling the
planned transmission equipment outages and through the simulation of
various contingency events, a planner must demonstrate that the system
can be operated to supply projected customer demands for all
maintenance outage conditions and that amongst other things, cascading
or system instability will not occur.\22\
---------------------------------------------------------------------------
\22\ Order No. 693, FERC Stats. & Regs. ] 31,242 at PP 1772,
1799, 1827.
---------------------------------------------------------------------------
18. For example, PJM has recently evaluated a Doubs-Mt. Storm
project which includes the replacement of structures that have
deteriorated beyond repair, which has resulted in the need to rebuild
the transmission circuit. PJM indicates the maintenance outages will be
scheduled in four month blocks, September--December and February--May,
starting in 2011 through 2015. PJM's analysis indicates that a list of
facilities has been determined that should not be scheduled out
concurrently with the Doubs-Mt. Storm project. Furthermore, PJM
analysis indicated that if any outage on this list of identified
facilities must be taken out of service, every effort shall be made to
align them with the lightest load period possible.\23\ Based on NERC's
proposed Requirement R1, Part 1.1.2 and the Doubs-Mt. Storm example, it
appears that this type of planned maintenance outage would be excluded
from future planning assessments and its potential impact to bulk
electric system reliability would be unknown because the outage
duration in this example is less than six months.
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\23\ See https://www.pjm.com/~/media/committees-groups/
committees/pc/20110203/20110203-item-12-doubs-mt-storm-impact-
summary.ashx.
---------------------------------------------------------------------------
19. The Commission seeks comment from the ERO and interested
persons whether the six month threshold would materially change the
number of planned outages as compared to the current standard. The
Commission also seeks comment on whether the threshold would exclude
almost all planned outages from future planning assessments, such as
nuclear plant refueling, large fossil and hydro generating station
maintenance, spring and fall transmission construction projects and
items indentified in correction actions plans of planning assessments
including neighboring corrective action plans. The Commission also
seeks comment on what alternative, whether based on outage duration
shorter than six months or some other method, such as planners'
accounting for planned maintenance outages of high capacity lines,
critical transformers, or nuclear outages during non-peak load periods
in their assessments, captures the appropriate number of planned
outages and types of planned outages to ensure that the Bulk-Power
System can be operated to meet system performance requirements during
high maintenance periods like the spring and fall seasons. In addition
to seasonal peaks, there have been significant system incidents which
occur because of unusual weather events during non-seasonal peak
periods. The Commission seeks comment on whether a six month outage
window would sufficiently capture these events or if they would not be
addressed in the proposed planning process. In addition, with respect
to protection system maintenance, currently-effective Reliability
Standard TPL-002-0, Requirement R1.3.12 requires the planner to
``[i]nclude the planned (including maintenance) outage of any bulk
electric equipment (including
[[Page 26718]]
protection systems or their components) at those demand levels for
which planned (including maintenance) outages are performed.'' \24\
NERC did not carry over this language because protection system
maintenance or other outages are not anticipated to last six months.
The Commission, however, believes that it is critical to plan the
system so that a protection system can be removed for maintenance and
still be operated reliably. Therefore, the Commission seeks comment on
its belief that protection systems are necessary to be included as a
type of planned outage.
---------------------------------------------------------------------------
\24\ Reliability Standard TPL-002-0, Requirement R1.3.12.
---------------------------------------------------------------------------
B. Violation Risk Factors
1. VRF for Proposed TPL-001-2, Requirement R1 VRF
20. NERC assigned a ``Medium'' VRF for proposed Reliability
Standard TPL-001-2, Requirement R1 and its sub-requirements. NERC
states each primary requirement in the proposed Reliability Standard
TPL-001-2 is assigned a VRF considering the NERC guidelines and
consistent with NERC's August 10, 2009 informational filing.\25\ NERC
maintains that Requirements R1.3.5, R1.3.7, R1.3.8, and R1.3.9 of the
currently-effective Reliability Standard TPL-001-0.1 carry a VRF of
``Medium'' and are similar in purpose and effect to proposed
Reliability Standard TPL-001-2, Requirement R1. NERC states that the
Requirements are similar because they refer to models that include firm
transfers, existing and planned facilities, and reactive power
requirements, and they refer to the Table 1 P0 condition. NERC believes
that a ``medium VRF for Requirement R1 is consistent with past
Commission guidance.'' \26\
---------------------------------------------------------------------------
\25\ Informational Filing of the North American Electric
Reliability Corporation Regarding the Assignment of Violation Risk
Factors and Violation Severity Levels, Docket Nos. RM08-11-000,
RR08-4-000, RR07-9-000, and RR07-10-000 (August 10, 2009).
\26\ NERC Petition at Exhibit C, Table 1.
---------------------------------------------------------------------------
21. NERC stated in its filing that ``Requirement R1 of the proposed
TPL-001-2 explicitly requires the Transmission Planner and Planning
Coordinator to maintain System models.'' \27\ The Commission believes
that when the planning coordinator or the transmission planner are
maintaining the system models to reflect the normal system condition,
if the system models are not properly modeled or maintained, the
analysis required in the Reliability Standard that uses the models in
Requirement R1, such as Category P0 as the normal System condition in
Table 1, may lose their validity and ``could, under emergency,
abnormal, or restorative conditions anticipated by the preparations,
directly cause or contribute to Bulk-Power System instability,
separation, or a cascading sequence of failures, or could place the
Bulk-Power System at an unacceptable risk of instability, separation,
or cascading failures, or could hinder restoration to a normal
condition.'' \28\
---------------------------------------------------------------------------
\27\ NERC Petition at 34.
\28\ North American Electric Reliability Corp., order on
violation risk factors, 119 FERC ] 61,145, at P 9 (2007), order on
reh'g and compliance filing, 120 FERC ] 61,145 (2007).
---------------------------------------------------------------------------
22. Furthermore, Requirement R1 of the proposed Reliability
Standard TPL-001-2 explicitly addresses the establishment of Category
P0 as the normal system condition in Table 1, which creates the model
of the normal system as the ``Initial Condition'' prior to any
contingency.\29\ Requirement R1 of the currently-effective Reliability
Standard TPL-001-0, which has a VRF of ``High,'' explicitly establishes
Category A as the normal system (all facilities in service) in Table 1,
which also creates the model of the normal system prior to any
contingency. The Commission believes that Requirement R1 of proposed
Reliability Standard TPL-001-2 and Requirement 1 of currently-effective
TPL-001-0 both establish the normal system planning model that serves
as the foundation for all other conditions and contingencies that are
required to be studied and evaluated in a planning assessment.
---------------------------------------------------------------------------
\29\ Proposed Reliability Standard TPL-001-2, Table 1.
---------------------------------------------------------------------------
23. Consistent with Guideline 3 of the Commission's VRF Guidelines,
the Commission ``expects the assignment of Violation Risk Factors
corresponding to Requirements that address similar reliability goals to
be treated comparably.'' \30\ The Commission seeks comment on why
Requirement R1 of proposed Reliability Standard TPL-001-2 carries a VRF
of ``Medium'' while Requirement R1 of the currently-effective
Reliability Standard TPL-001-0 carries a VRF of ``High.''
---------------------------------------------------------------------------
\30\ North American Electric Reliability Corp., order on
violation risk factors, 119 FERC ] 61,145, at P 25 (2007), order on
reh'g and compliance filing, 120 FERC ] 61,145 (2007).
---------------------------------------------------------------------------
2. VRF for Proposed TPL-001-2, Requirement R6
24. NERC proposes to assign a ``Low'' VRF for Requirement R6 from
the proposed Reliability Standard TPL-001-2 because ``failure to have
established criteria for determining System instability is an
administrative requirement affecting a planning time frame.'' \31\ NERC
explains that Requirement R6 is a new requirement and that violations
would not be expected to adversely affect the electrical state or
capability of the bulk electric system.
---------------------------------------------------------------------------
\31\ NERC Petition, Exhibit C, at 110.
---------------------------------------------------------------------------
25. Requirement R6 requires planning coordinators and transmission
planners to define and document the criteria or methodology used in
their analyses to identify system instability for conditions such as
cascading, voltage instability or uncontrolled islanding. The
Commission recognizes that documenting criteria or methodology is an
administrative act. However, defining the criteria or methodology to be
used is not an administrative act. If the criteria or methodology used
by planning coordinators and transmission planners are not defined
properly, the analysis based on this criteria or methodology could lose
its validity and ``could, under emergency, abnormal, or restorative
conditions anticipated by the preparations, directly cause or
contribute to Bulk-Power System instability, separation, or a cascading
sequence of failures, or could place the Bulk-Power System at an
unacceptable risk of instability, separation, or cascading failures, or
could hinder restoration to a normal condition.'' \32\
---------------------------------------------------------------------------
\32\ North American Electric Reliability Corp., order on
violation risk factors, 119 FERC ] 61,145 at P 9.
---------------------------------------------------------------------------
26. Requirement R6 co-mingles a higher reliability objective
(defining criteria or methodology) with a lower reliability objective
(documentation). Consistent with Guideline 5 of the Commission's VRF
Guidelines, the Commission seeks to ensure that the assignment of
Violation Risk Factors corresponding to co-mingled Requirements reflect
the higher reliability objective of the co-mingled requirement.\33\ The
Commission seeks clarification from the ERO why the VRF level assigned
to Requirement R6 is ``Low'' since it is appears that Requirement R6
requires more than a purely administrative task.
---------------------------------------------------------------------------
\33\ Id. P 32.
---------------------------------------------------------------------------
C. Protection System Failures Versus Relay Failures
27. NERC states that its modification to the planning contingency
categories in Table 1 of the proposed standard is intended to add
clarity and consistency regarding how a delayed fault clearing will be
modeled in planning studies. NERC states that the basic elements of any
protection system design involve inputs (i.e., current and D/C and A/C
voltage) to protective relays and outputs (i.e., trip signals, close
signals, and
[[Page 26719]]
alarms) from protective relays and that reliability issues associated
with improper clearing of a fault on the bulk electric system can
result from the failure of hundreds of individual protection system
components in a substation. However, NERC believes that while the
population of components that could fail and result in improper
clearing is large, that population can be reduced dramatically by
eliminating those components which share failure modes with other
components. NERC states that the critical components in protection
systems are the protective relays themselves, and a failure of a non-
redundant protective relay will often result in undesired consequences
during a fault. According to NERC, other protection system components
related to the protective relay could fail and lead to a bulk electric
system issue, but the event that would be studied is identical, from
both transient and steady state perspectives, to the event resulting
from a protective relay failure if an adequate population of protective
relays is considered.\34\
---------------------------------------------------------------------------
\34\ NERC Petition at 48.
---------------------------------------------------------------------------
28. In the currently-effective TPL Reliability Standards, Table 1
contingencies address the initiating event and contingency of a single
line to ground (SLG) fault with delayed clearing (stuck breaker or
protection system failure) for a generator, transformer, transmission
circuit and bus section. For this initiating event and set of
contingencies, the planner must demonstrate that Table 1 system
performance criteria can be met.\35\
---------------------------------------------------------------------------
\35\ Currently-effective Reliability Standard TPL-004-0,
Categories C1-C4 address the same initiating event and set of
contingencies as currently-effective TPL-003-0, Categories C6-C9,
but the system performance criteria are different for TPL-003-0
versus TPL-004-0.
---------------------------------------------------------------------------
29. Currently-effective Reliability Standard TPL-003-0, Requirement
R1.3.1 states that current or past study and/or system simulation
testing ``[b]e performed and evaluated only for those Category C
contingencies that would produce the more severe system results or
impacts.'' \36\ Referring to Table 1, Category C6-C9, the initiating
event and contingency is described as ``SLG Fault, with Delayed
Clearing (stuck breaker or protection system failure).'' \37\
---------------------------------------------------------------------------
\36\ Reliability Standard TPL-003-0a.
\37\ Reliability Standard TPL-003-0a (Category C).
---------------------------------------------------------------------------
30. Requirement R1.3.1 states that in the study and simulation of a
protection system failure, the planner should assess the contingencies
that produce the more severe system results.\38\ If the contingency is
a protection system failure, delayed clearing is described as a fault
due to the failure of any protection system component such as a relay,
circuit breaker, or current transformer, and not because of an
intentional design delay.\39\
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\38\ Requirement R1.3.1 is included in TPL-002-0b, TPL-003-0a
and TPL-004-0.
\39\ Reliability Standard TPL-003-0, Table 1, footnote e.
---------------------------------------------------------------------------
31. The Commission believes that based on various protection system
as-built designs, the planner will have to choose which protection
system component failure would have the most significant impact on the
Bulk-Power System because as-built designs are not standardized and the
most critical component failure may not always be the relay. For
example, if a protection system design used one set of fuses to supply
power to both the primary and breaker failure relays, failure of one
fuse would be more severe than failure of either one of the relays.
Similar dependencies can occur in specific designs in the
implementation of microprocessor installations. As another example, if
a protection system designed includes a shared voltage or current
sensing device that provides input to relays for both the primary and
backup protection systems, failure of this voltage sensing device would
be more severe than failure of either one of the relays.
32. As a result, the planner's selection of a protection system
component failure may be influenced by the protection system as-built
design. If one protection system component was an integral component of
primary protection and breaker failure protection, then it is possible
that the loss of that one component would produce the more severe
system impact. If, in this example, the protection system component
failure was not a relay component, as described in Category P5 of the
proposed TPL Standard, it appears that this more severe contingency
(loss of both the primary protection and breaker failure protection
systems due to the loss of one protection system component) would not
be assessed under the proposed TPL Reliability Standard.
33. The Commission seeks comments on whether the proposed TPL
Reliability Standard, in the provisions pertaining to study of multiple
contingencies, limits the planners' assessment of a protection system
failure because it only includes the contingency of a faulty relay
component. The Commission also seeks comments on whether, based on
protection system as-built designs, the relay may not always be the
larger contingency, and how the loss of protection system components
that may be integral to multiple protection systems impacts
reliability.
D. Assessment of Backup or Redundant Protection Systems
34. NERC states that proposed Reliability Standard TPL-001-2,
Requirement R3, Part 3.3.1 and Requirement R4, Part 4.3.1 require that
simulations faithfully duplicate what will happen in an actual power
system based on the expected performance of the protection systems.\40\
According to NERC, these requirements ensure that if a protection
system is designed ``to remove multiple Elements from service for an
event that the simulation will be run with all of those Elements
removed from service.'' \41\ This proposal is intended to instill
event-based analysis over simple element analysis which will provide
for more accurate simulations.
---------------------------------------------------------------------------
\40\ NERC Petition at 20.
\41\ Id.
---------------------------------------------------------------------------
35. The current TPL Reliability Standards state that a planner must
include the effects of existing and planned protection systems,
including any backup or redundant systems in its planning
assessment.\42\ Specifically, Reliability Standard TPL-003-0,
Requirement R1.3.10 requires the planner to ``[i]nclude the effects of
existing and planned protection systems, including any backup or
redundant systems.'' \43\ For this requirement, the planner must
include the effects all protection systems, including backup or
redundant protection systems.
---------------------------------------------------------------------------
\42\ E.g., Reliability Standards TPL-003-0, R1.3.10 and TPL-004-
0, R1.3.7.
\43\ Reliability Standard TPL-003-0, R1.3.10 and TPL-004-0,
Requirement R1.3.7.
---------------------------------------------------------------------------
36. NERC states that Reliability Standard TPL-001-2, Requirement
R3, Part 3.3.1 and Requirement R4, Part 4.3.1 require the planner to
``[s]imulate the removal of all elements that the Protection System and
other automatic controls are expected to disconnect for each
Contingency without operator intervention.'' The proposed NERC
provision, however, does not explicitly refer to ``backup or redundant
systems'' as in the currently effective TPL standards. The Commission
seeks clarification from the ERO whether the proposed Requirements
address all protection systems, including backup and redundant
protection systems that can have an impact on the performance of the
bulk electric system.
E. P5 Single Line to Ground Faults
37. Table 1 of the proposed Reliability Standard TPL-001-2
identifies the
[[Page 26720]]
initiating contingencies that must be evaluated to ensure that the
planned system meets the performance requirements. These proposed
modifications to Table 1 include changing the classification of the
events, clarifying events and fault types, and removing the ambiguity
of performance requirements. NERC states the proposed Reliability
Standard TPL-001-2, Table 1, P5 events are limited to the Single Line
to Ground (SLG) Fault type consistent with the comparable C6-C9 events
from Table 1 in the currently-effective TPL Reliability Standards. NERC
treats SLG and three phase faults as different events even if an SLG
event evolves into a three phase fault.\44\
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\44\ NERC Petition at 49. Three phase events in the existing TPL
standards are shown in Table 1, D1-D4 and are retained in TPL-001-2,
Table 1, Extreme Events.
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38. The proposed Reliability Standard TPL-001-2, Table 1 includes a
column titled ``fault type,'' which contains the specific designation
of the fault type such as SLG or three-phase faults. ``Fault type'' is
described as a SLG or three-phase fault types that must be evaluated in
stability simulations for the event described. For example, a SLG fault
could evolve into a 3-phase fault, but the initiating fault is the SLG
fault and the associated SLG performance criteria must be applied, not
the three-phase performance criteria. The Commission seeks
clarification from the ERO whether ``fault types'' in Table 1 of the
proposed Reliability Standard refers to the initiating event or
initiating fault for the contingency rather than the type of fault in
to which the initiating fault may evolve and how the clarification is
consistent with the simulations being representative of what will occur
in real-time.
F. Order No. 693 Directives
39. While the Commission proposes to remand based on the presence
of footnote 12, the balance of proposed Reliability Standard TPL-001-2
appears responsive to the Order No. 693 directives regarding the TPL
Reliability Standards. The Commission, however, seeks clarification and
comment on the following.
1. Peer Review of Planning Assessments
40. In Order No. 693, the Commission stated that it ``sees no
reason why peer reviews should not be part of a Reliability Standard
since TPL-001-0 through TPL-004-0 already include[hellip]a review of
assessment by the associated regional reliability organization.'' \45\
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\45\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 1755.
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The Commission also stated that because neighboring systems may be
adversely impacted by other neighboring systems, such systems should be
involved in determining and reviewing system conditions and
contingencies to be assessed under the currently-effective TPL
Standards.\46\ Furthermore, the peer review provides for a neighboring
entity to identify possible interdependent or adverse impacts on its
neighboring systems and thus, provides for an early opportunity to
provide input and coordinate plans.\47\
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\46\ Id. P 1750.
\47\ Id. P 1754.
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41. NERC states the proposed Reliability Standard does not include
a ``peer review'' of planning assessments but instead includes ``an
equally effective and efficient manner to provide for the appropriate
sharing of information with neighboring systems'' with the
incorporation of Requirement R3, Part 3.4.1, Requirement R4, Part
4.4.1, and Requirement R8.\48\ Part 3.4.1 provides:
---------------------------------------------------------------------------
\48\ NERC Petition at 21.
The Planning Coordinator and Transmission Planner shall
coordinate with adjacent Planning Coordinators and Transmission
Planners to ensure that Contingencies on adjacent Systems which may
impact their Systems are included in the Contingency list.\49\
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\49\ Proposed Reliability Standard, TPL-001-2, Requirement R3,
Part 3.3.1. Part 4.4.1 is in all material respects the same as Part
3.3.1.
NERC explains that ``an entity may always decline an offer to
participate in a peer review even when they should participate'' and
``the distribution approach means that the entity will always receive
the Planning Assessment.'' \50\ NERC further states in ``the course of
the continuing cycle of Planning Assessments, comments from other
entities at the end of a planning cycle will be utilized at the
beginning of the next cycle as the planner moves forward in time.''
\51\
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\50\ NERC Petition at 22. Requirement R8 requires distribution
to adjacent planning coordinators and transmission planners within
90 days and to others with a reliability related need that submits a
request within 30 days of receiving such a request.
\51\ NERC Petition at 22.
---------------------------------------------------------------------------
42. The Commission seeks clarification on how the NERC proposal
ensures the early input of peers into the planning assessments or any
type of coordination amongst peers will occur. The Commission seeks
comment on whether and how there is a sufficient level of evaluation
and ability to provide feedback to the planners on the development and
result of assessments. In addition, NERC states that that Requirement
R8 ``ensures that information is shared with * * * adjacent entities''
which ``ensures * * * input received from adjacent entities.'' \52\ The
Commission also seeks comment on whether Requirement R8 requires input
on the comments to be included in the results or the development of the
Planning Assessments.
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\52\ Id. at 44.
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2. Spare Equipment Strategy
43. In Order No. 693, the Commission directed NERC to develop a
modification ``to require assessments of outages of critical long lead-
time equipment, consistent with the entity's spare equipment
strategy.'' \53\ In response, NERC developed proposed Requirement 2,
Part 2.1.5 which addresses steady state conditions to determine system
response when equipment is unavailable for prolonged periods of time.
The studies must be performed for the P0, P1, and P2 categories in
Table 1 ``under the condition that the system is expected to experience
during the possible periods of unavailability of the long lead-time
equipment.'' NERC states that ``[s]tability impacts related to outages
of critical long lead-time equipment will not be addressed in a
separated requirement but rather will be analyzed in the normal
planning process.'' \54\
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\53\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 1786.
\54\ NERC Petition at 25.
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44. NERC's spare equipment strategy appears to have limited the
strategy to steady state analysis (excluded stability analysis).\55\
While including a spare equipment strategy in the proposed Reliability
Standard is an improvement, the Commission seeks clarification as to
why stability analysis conditions were excluded from the spare
equipment strategy.
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\55\ Proposed Reliability Standard TPL-001-2, Requirement R
2.1.5.
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3. Controlled Load Interruption
45. In Order No. 693, the Commission directed the ERO to modify
footnote (c) of Table 1 to the Reliability Standard TPL-003-0a to
clarify the term ``controlled load interruption'' to ``ensure that
third parties have access to the same options that the transmission
owner uses to alleviate reliability constraints including those related
to controlled load shedding.'' \56\ NERC states in its petition that it
excluded the term ``controlled load interruption'' in the proposed
Reliability Standard TPL-001-2, but NERC does not explain the
[[Page 26721]]
reason for its exclusion.\57\ NERC added the term ``Non-Consequential
Load Loss'' to the proposed Reliability Standard TPL-001-2, Table 1 and
defined ``Non-Consequential Load Loss'' as: Non-Interruptible Load loss
that does not include: (1) Consequential Load Loss, (2) the response of
voltage sensitive Load, or (3) Load that is disconnected from the
System by end-user equipment.\58\ In addition, NERC added a new
Requirement R2.1.4 for the Near-Term Transmission Planning Horizon
portion of steady-state analysis that includes ``Controllable Loads''
as one of the conditions the planning assessment must vary in the
sensitivity analysis for system peak load for year one or year two, and
for year five and for system off-peak load for one of the five years.
---------------------------------------------------------------------------
\56\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 1818.
\57\ NERC Petition at 28.
\58\ In Order No. 693, the Commission explained that the term
``consequential load loss'' referred to ``the load that is directly
served by the elements that are removed from service as a result of
the contingency.'' Order No. 693, FERC Stats. & Regs. ] 31,242 at P
1794 n.461.
---------------------------------------------------------------------------
46. The term ``controlled load interruption'' is found in footnote
(c) which is applicable to ``Loss of Demand or Curtailed Firm
Transfers'' in Table 1 of the existing TPL Reliability Standards. The
term ``Loss of Demand or Curtailed Firm Transfers'' for controlled load
interruptions in Table 1 of the current TPL Standards appears to be
applicable to ``Non-Consequential Load Loss Allowed'' in Table 1 of the
proposed TPL Standard. The Commission seeks clarification from the ERO
if third-parties have access to the same options that the transmission
owner has to alleviate reliability constraints including load shedding
options for ``Controllable Loads'' in Requirement 2.1.4 and ``Non-
Consequential Load Loss Allowed'' in Table 1 of the proposed
Reliability Standard TPL-001-2.
4. Range of Extreme Events
47. In Order No. 693 the Commission directed the ERO to modify
Reliability Standard TPL-004-0 to require that, in determining the
range of the extreme events to be assessed, the contingency list of
Category D would be expanded to include recent events such as
hurricanes and ice storms. NERC's proposed Reliability Standard TPL-
001-2 appropriately expands the list of extreme event examples in Table
1, but the list limits these items to the loss of two generating
stations under Item No. 3a.\59\
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\59\ NERC Petition at 29-30.
---------------------------------------------------------------------------
48. The Commission seeks clarification from the ERO on conditioning
extreme events on the loss of two generating stations.\60\ The
Commision understands that there are scenarios where an extreme event
can impact more than two generation stations that might not be captured
due to the ``two generation stations'' restriction in Item No. 3a. For
example, within the Florida peninsula, depending on the location within
the state, either two or three main gas pipelines supply the majority
of the generation for the area. In this scenario, the loss of one of
the gas pipelines would result in the loss of more than two generation
stations. The Commission seeks clarification regarding whether this
scenario is otherwise covered under the catch-all provision in Item No.
3b which states ``[o]ther events based upon operating experience that
may result in wide area disturbances.''
---------------------------------------------------------------------------
\60\ Id.
---------------------------------------------------------------------------
5. Assessments and Documentation
49. The Commission seeks clarification from the ERO that planning
assessments and associated documentation will include accurate
representations of results on the bulk electric system with respect to
the following.
a. Dynamic Load Models
50. In Order No. 693, the Commission directed ``the ERO to modify
the Reliability Standard to require documentation of load models used
in system studies and the supporting rationale for their use.'' \61\
Proposed Reliability Standard TPL-001-2, Requirement 2.4, Part 2.4.1
requires a load model which represents the expected dynamic behavior of
loads that could impact a study area, considering the behavior of
induction motor loads. NERC states that this addition to the proposed
standard addresses the specifics of the Order No. 693 directive that
requires ``[d]ocument(ing) the load models used in system studies and
the supporting rationale for their use.'' \62\ Under the proposed
Requirement R2, entities are required to document assumptions made in
the planning assessments. The Commission seeks clarification on whether
the documentation of the dynamic load models used in system studies and
the supporting rationale for their use under Requirement 2.4, Part
2.4.1 will be included in the documented assumptions under Requirement
R2.
---------------------------------------------------------------------------
\61\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 1789.
\62\ NERC Petition at 26.
---------------------------------------------------------------------------
b. Proxies To Simulate Cascade
51. In Order No. 693, the Commission observed that ``if an entity
models overload relays, undervoltage relays, all remedial action
schemes including those of neighboring systems and has a good load
representation, then proxies are not required. However, due to modeling
and simulation limitations this is often not the case and planners
invariably use proxies.'' \63\ Additionally, the Commission stated that
sharing of proxies will improve knowledge and understanding and promote
a more rigorous approach to analyzing cascading outages. Accordingly,
the Commission directed the ERO to modify the Reliability Standard to
require ``definition and documentation of proxies necessary to simulate
cascading outages.'' \64\
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\63\ Order No. 693, FERC Stats. & Regs. ] 31,242 at P 1819.
\64\ Id. P 1820.
---------------------------------------------------------------------------
52. NERC states that proposed Requirement R6 ``specifies that an
entity must define and document the criteria or methodology used to
identify system instability for conditions such as cascading, voltage
instability, or uncontrolled islanding within its Planning
Assessment.'' \65\ NERC adds that this specificity in identifying these
``proxies'' is an important clarification in the proposed revised
standard and ``will lead to greater transparency in the planner's
evaluation techniques.'' \66\ The Commission seeks clarification on
whether Requirement R6 includes the documentation of proxies and that
Requirement R8 includes the sharing of the documented proxies in the
planning assessments.
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\65\ NERC Petition at 43-44.
\66\ Id.
---------------------------------------------------------------------------
c. Footnote `a'
53. In Order No. 693 the Commission directed NERC to modify
``footnote (a) of Table 1 with regard to applicability of emergency
rating and consistency of normal ratings and voltages with values
obtained from other reliability standards.'' \67\ NERC notes that
proposed Table 1, header note `e,' which states planned system
adjustments must be executable within the time duration applicable to
facility ratings, and header note `f,' which states applicable facility
ratings shall not be exceeded, meets this directive thereby replacing
footnote `a' in the current standard.
---------------------------------------------------------------------------
\67\ Id. at 24.
---------------------------------------------------------------------------
54. The Commission observes that the proposed standard applies
header note `e' to ``Steady State and Stability'' while header note `f'
is excluded from ``Stability'' and only applies to ``Steady
[[Page 26722]]
State'' studies. The Commission seeks clarification from the ERO
regarding the rationale for excluding header note `f' from
``Stability'' studies. Additionally, the Commission seeks clarification
on which Reliability Standards the entities should utilize when
obtaining the values to be used in their Planning Assessments. In
addition, for Table 1, header notes `e' and `f,' the Commission seeks
comment on whether the normal facility ratings align with, for example,
FAC-008-1 and normal voltage ratings align with VAR-001-1. Furthermore,
the Commission seeks clarification from the ERO whether facility
ratings used in planning assessments align with other reliability
standards such as NUC-001-2, BAL-001-0.1a and PRC Standards for UFLS
and UVLS.
G. Commission Proposal
55. The Commission proposes to remand NERC's proposed TPL
Reliability Standard. While much of the proposed Reliability Standard
TPL-001-2 appears just, reasonable, not unduly discriminatory or
preferential, and in the public interest, we find that footnote 12,
allowing for transmission planners to plan for non-consequential load
loss following a single contingency without adequate safeguards,
undermines the potential benefits the proposed Reliability Standard may
provide . This is consistent with the Commission's Final Rule in Docket
No. RM11-18-000 remanding footnote `b,' which is substantially the same
as footnote 12. Thus, the Commission proposes to remand the proposed
Reliability Standard TPL-001-2 to NERC.
III. Information Collection Statement
56. The Office of Management and Budget (OMB) regulations require
that OMB approve certain reporting and recordkeeping (collections of
information) imposed by an agency.\68\ The information contained here
is also subject to review under section 3507(d) of the Paperwork
Reduction Act of 1995.\69\
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\68\ 5 CFR 1320.11.
\69\ 44 U.S.C. 3507(d).
---------------------------------------------------------------------------
57. As stated above, the subject of this NOPR is NERC's proposed
modifications to the TPL Reliability Standards. This NOPR proposes to
remand the proposed revisions to NERC. By remanding the proposal, the
applicable Reliability Standards and any information collection
requirements are unchanged. Therefore, the Commission will submit this
NOPR to OMB for informational purposes only.
58. Interested persons may obtain information on the reporting
requirements by contacting the following: Federal Energy Regulatory
Commission, 888 First Street NE., Washington, DC 20426 [Attention:
Ellen Brown, Office of the Executive Director, email:
data.clearance@ferc.gov, phone: (202) 502-8663, or fax: (202) 273-
0873].
IV. Regulatory Flexibility Act
59. The Regulatory Flexibility Act of 1980 (RFA) \70\ generally
requires a description and analysis of final rules that will have
significant economic impact on a substantial number of small entities.
The RFA mandates consideration of regulatory alternatives that
accomplish the stated objectives of a proposed rule and that minimize
any significant economic impact on a substantial number of small
entities. The Small Business Administration's (SBA) Office of Size
Standards develops the numerical definition of a small business.\71\
The SBA has established a size standard for electric utilities, stating
that a firm is small if, including its affiliates, it is primarily
engaged in the transmission, generation and/or distribution of electric
energy for sale and its total electric output for the preceding twelve
months did not exceed four million megawatt hours.\72\ The RFA is not
implicated by this NOPR because the Commission is remanding the
proposed TPL Reliability Standard and not proposing any modifications
to the existing burden or reporting requirements. With no changes to
the Reliability Standards as approved, the Commission certifies that
this NOPR will not have a significant economic impact on a substantial
number of small entities.
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\70\ 5 U.S.C. 601-612.
\71\ 13 CFR 121.201.
\72\ Id.
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V. Comment Procedures
60. 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 60 days from publication in the Federal
Register. Comments must refer to Docket No. RM12-1-000, and must
include the commenter's name, the organization they represent, if
applicable, and their address in their comments.
61. 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 format
and not in a scanned format. Commenters filing electronically do not
need to make a paper filing.
62. Commenters that are not able to file comments electronically
must send an original of their comments to: Federal Energy Regulatory
Commission, Secretary of the Commission, 888 First Street NE.,
Washington, DC 20426.
63. 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.
VI. Document Availability
64. In addition to publishing the full text of this document in the
Federal Register, the Commission provides all interested persons an
opportunity to view and/or print the contents of this document via the
Internet through FERC's Home Page (https://www.ferc.gov) and in FERC's
Public Reference Room during normal business hours (8:30 a.m. to 5:00
p.m. Eastern time) at 888 First Street NE., Room 2A, Washington DC
20426.
65. From FERC's Home Page on the Internet, this information is
available on eLibrary. The full text of this document is available on
eLibrary in PDF and Microsoft Word format for viewing, printing, and/or
downloading. To access this document in eLibrary, type the docket
number excluding the last three digits of this document in the docket
number field.
66. User assistance is available for eLibrary and the FERC's Web
site during normal business hours from FERC Online Support at (202)
502-6652 (toll free at 1-866-208-3676) or email at
ferconlinesupport@ferc.gov, or the Public Reference Room at (202) 502-
8371, TTY (202) 502-8659. Email the Public Reference Room at
public.referenceroom@ferc.gov.
By direction of the Commission. Commissioner Norris is
concurring in part with a separate statement attached.
Kimberly D. Bose,
Secretary.
Norris, Commissioner, concurring in part:
In today's order, the Commission proposes to remand proposed
Transmission Planning Reliability Standard TPL-001-2 to NERC, based
on the decision by the Commission to remand proposed TPL-002-0b in
the concurrently-issued Transmission Planning
[[Page 26723]]
Reliability Standards.\1\ For the reasons articulated in my separate
statement in Order No. 762, I agree with the decision here to remand
proposed TPL-001-2, but I do not fully agree with the basis
identified by the majority in their decision.
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\1\ Order No. 762, 139 FERC ] 61,060 (2012).
---------------------------------------------------------------------------
Thus, I respectfully concur in part.
John R. Norris,
Commissioner
[FR Doc. 2012-10943 Filed 5-4-12; 8:45 am]
BILLING CODE 6717-01-P