[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)]
[Proposed Rules]
[Pages 36280-36293]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-15433]



[[Page 36280]]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

18 CFR Part 40

[Docket No. RM15-16-000]


Transmission Operations Reliability Standards and Interconnection 
Reliability Operations and Coordination Reliability Standards

AGENCY:  Federal Energy Regulatory Commission, DOE.

ACTION: Notice of proposed rulemaking.

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SUMMARY: The Commission proposes to approve revisions to the 
Transmission Operations and Interconnection Reliability Operations and 
Coordination Reliability Standards, developed by the North American 
Electric Reliability Corporation, which the Commission has certified as 
the Electric Reliability Organization responsible for developing and 
enforcing mandatory Reliability Standards.

DATES:  Comments are due August 24, 2015.

ADDRESSES:  Comments, identified by docket number, may be filed in the 
following ways:
     Electronic Filing through http://www.ferc.gov. Documents 
created electronically using word processing software should be filed 
in native applications or print-to-PDF format and not in a scanned 
format.
     Mail/Hand Delivery: Those unable to file electronically 
may mail or hand-deliver comments to: Federal Energy Regulatory 
Commission, Secretary of the Commission, 888 First Street NE., 
Washington, DC 20426.
    Instructions: For detailed instructions on submitting comments and 
additional information on the rulemaking process, see the Comment 
Procedures Section of this document.

FOR FURTHER INFORMATION CONTACT:
Robert T. Stroh (Legal Information), Office of the General Counsel, 
Federal Energy Regulatory Commission, 888 First Street NE., Washington, 
DC 20426, Telephone: (202) 502-8473, [email protected]
Eugene Blick (Technical Information), Office of Electric Reliability, 
Federal Energy Regulatory Commission, 888 First Street NE., Washington, 
DC 20426, Telephone: (301) 665-1759, [email protected]
Darrell G. Piatt (Technical Information), Office of Electric 
Reliability, Federal Energy Regulatory Commission, 888 First Street 
NE., Washington, DC 20426, Telephone: (205) 332-3792, 
[email protected]

SUPPLEMENTARY INFORMATION: 
    1. Pursuant to section 215 of the Federal Power Act (FPA),\1\ the 
Commission proposes to approve revisions to the Transmission Operations 
(TOP) and Interconnection Reliability Operations and Coordination (IRO) 
Reliability Standards, developed by the North American Electric 
Reliability Corporation (NERC), the Commission-certified Electric 
Reliability Organization (ERO). The Commission believes that the 
proposed TOP and IRO Reliability Standards improve on the currently-
effective standards by providing a more precise set of Reliability 
Standards addressing operating responsibilities and improving the 
delineation of responsibilities between applicable entities. The 
Commission also believes that the revised TOP Reliability Standards 
eliminate gaps and ambiguities in the currently-effective TOP 
requirements and improve efficiency by incorporating the necessary 
requirements from the eight currently-effective TOP Reliability 
Standards into three cohesive, comprehensive Reliability Standards. 
Further, the Commission believes that the proposed standards clarify 
and improve upon the currently-effective TOP and IRO Reliability 
Standards by designating requirements in the proposed standards that 
apply to transmission operators for the TOP standards and reliability 
coordinators for the IRO standards. Thus, the Commission proposes to 
find that there are benefits to clarifying and bringing efficiencies to 
the TOP and IRO Reliability Standards, consistent with the Commission's 
policy promoting increased efficiencies in Reliability Standards and 
reducing requirements that are either redundant with other currently-
effective requirements or have little reliability benefit.\2\
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    \1\ 16 U.S.C. 824o (2012).
    \2\ Electric Reliability Organization Proposal to Retire 
Requirements in Reliability Standards, Order No. 788, 145 FERC ] 
61,147 (2013).
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    2. The Commission also proposes to find that NERC has adequately 
addressed the concerns raised by the Commission in the Notice of 
Proposed Rulemaking (Remand NOPR) issued in November 2013.\3\ In the 
Remand NOPR, the Commission proposed to remand an earlier version of 
proposed TOP and IRO Standards due to concerns regarding the proposed 
treatment of system operating limits (SOLs) and interconnection 
reliability operating limits (IROLs) and concerns about outage 
coordination. Further, the Commission proposes to approve the 
definitions for operational planning analysis and real-time assessment, 
and the violation severity level and violation risk factor assignments.
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    \3\ Monitoring System Conditions--Transmission Operations 
Reliability Standard, Transmission Operations Reliability Standards, 
Interconnection Reliability Operations and Coordination Reliability 
Standards, Notice of Proposed Rulemaking, 145 FERC ] 61,158 (2013). 
Concurrent with filing the proposed TOP/IRO standards in the 
immediate proceeding, NERC submitted a motion to withdraw the 
earlier petition that was the subject of the Remand NOPR. No 
protests to the motion were filed and the petition was withdrawn 
pursuant to 18 CFR 385.216(b).
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    3. While proposing to approve the TOP and IRO Reliability 
Standards, below the Commission seeks clarifying comments addressing 
four issues: (A) Possible inconsistencies in identifying IROLs; (B) 
monitoring of non-bulk electric system facilities; (C) removal of the 
load-serving entity as an applicable entity for proposed Reliability 
Standard TOP-001-3; and (D) data exchange capabilities. Based on 
comments and information received on these issues, the Commission may 
issue directives as appropriate.

I. Background

    4. Section 215 of the FPA requires a Commission-certified ERO to 
develop mandatory and enforceable Reliability Standards, which are 
subject to Commission review and approval. Once approved, the 
Reliability Standards are enforced by the ERO, subject to Commission 
oversight, or by the Commission independently. On March 16, 2007, the 
Commission issued Order No. 693, approving 83 of the 107 initial 
Reliability Standards filed by NERC, including the existing TOP and IRO 
Reliability Standards.\4\ In addition, in Order No. 748, the Commission 
approved revisions to the IRO Reliability Standards.\5\
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    \4\ Mandatory Reliability Standards for the Bulk-Power System, 
Order No. 693, 72 FR 16416 (Apr. 4, 2007), FERC Stats. & Regs. ] 
31,242, order on reh'g, Order No. 693-A, 120 FERC ] 61,053 (2007).
    \5\ Mandatory Reliability Standards for Interconnection 
Reliability Operating Limits, Order No. 748, 134 FERC ] 61,213 
(2011).
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    5. On April 16, 2013, in Docket No. RM13-14-000, NERC submitted for 
Commission approval three revised TOP Reliability Standards to replace 
the eight currently-effective TOP standards.\6\ Additionally, on April 
16, 2013, in Docket No. RM13-15-000, NERC submitted for Commission 
approval four revised IRO Reliability Standards to replace six 
currently-

[[Page 36281]]

effective IRO Reliability Standards. On November 21, 2013, the 
Commission issued the Remand NOPR in which the Commission expressed 
concern that NERC had ``removed critical reliability aspects that are 
included in the currently-effective standards without adequately 
addressing these aspects in the proposed standards.'' \7\ The 
Commission identified two main concerns and asked for clarification and 
comment on a number of other issues. Among other things, the Commission 
expressed concern that the proposed TOP Reliability Standards did not 
require transmission operators to plan and operate within all SOLs, 
which is a requirement in the currently-effective standards. In 
addition, the Commission expressed concern that the proposed IRO 
Reliability Standards did not require outage coordination.
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    \6\ On April 5, 2013, in Docket No. RM13-12-000 NERC proposed 
revisions to Reliability Standard TOP-006-3 to clarify that 
transmission operators are responsible for monitoring and reporting 
available transmission resources and that balancing authorities are 
responsible for monitoring and reporting available generation 
resources.
    \7\ Remand NOPR, 145 FERC ] 61,158 at P 4.
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    6. On December 20, 2013, NERC filed a motion requesting that the 
Commission defer action, until January 31, 2015, to allow NERC time to 
consider the reliability concerns raised by the Commission in the 
Remand NOPR. The Commission granted that motion on January 14, 2014.\8\ 
In response to the Remand NOPR, NERC initiated Project 2014-03 to 
develop further revisions to the TOP and IRO Reliability Standards.
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    \8\ Monitoring System Conditions--Transmission Operations 
Reliability Standard, Transmission Operations Reliability Standards, 
Interconnection Reliability Operations and Coordination Reliability 
Standards, Order Granting Motion to Defer Action, 146 FERC ] 61,023 
(2014).
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NERC Petition

    7. On March 18, 2015, as supplemented on May 12, 2015, NERC 
submitted a petition seeking approval of two sets of Reliability 
Standards to replace the currently-effective TOP and IRO Reliability 
Standards. NERC states that the proposed TOP Reliability Standards 
generally address real-time operations and planning for next-day 
operations, and apply primarily to the responsibilities and authorities 
of transmission operators, with certain requirements applying to the 
roles and responsibilities of the balancing authority. NERC adds that 
the proposed IRO Reliability Standards set forth the responsibility and 
authority of reliability coordinators to provide for reliable 
operations. According to NERC, reliability coordinators have an 
essential role in ensuring reliable operations, as they are the 
functional entities with the highest level of authority and have the 
wide-area view of the bulk electric system.\9\
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    \9\ The TOP and IRO Reliability Standards are not attached to 
this NOPR. The complete text of the Reliability Standards is 
available on the Commission's eLibrary document retrieval system in 
Docket No. RM15-16 and is posted on the ERO's Web site, available 
at: http://www.nerc.com.
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    8. NERC states that the proposed Reliability Standards include 
improvements over the currently effective TOP and IRO Reliability 
Standards in key areas such as: (1) Operating within SOLs and IROLs; 
(2) outage coordination; (3) situational awareness; (4) improved 
clarity and content in foundational definitions; and (5) requirements 
for operational reliability data.
    9. NERC states that the proposed TOP and IRO Reliability Standards 
address the coordinated efforts to plan and reliably operate the bulk 
electric system under both normal and abnormal conditions. NERC states 
that the proposed Reliability Standards provide a comprehensive 
framework for reliable operations, with important improvements to 
ensure the bulk electric system is operated within pre-established 
limits while enhancing situational awareness and strengthening 
operations planning. NERC explains that the proposed Reliability 
Standards establish or revise requirements for operations planning, 
system monitoring, real-time actions, coordination between applicable 
entities, and operational reliability data. According to NERC, the 
proposed Reliability Standards help to ensure that reliability 
coordinators and transmission operators work together, and with other 
functional entities, to operate the bulk electric system within SOLs 
and IROLs.\10\ Further, NERC explains that SOLs and IROLs are vital 
concepts in the Reliability Standards because they establish acceptable 
performance criteria both pre- and post-contingency to maintain 
reliable bulk electric system operations. NERC states that when any 
facility rating or stability limit is exceeded, or expected to be 
exceeded, these conditions should be mitigated to avoid the possibility 
of further deteriorating system conditions and the potential for a 
cascading event. In addition, NERC states that the standard drafting 
team developed a white paper on SOL definition and exceedance criteria 
which clarified the team's position on establishing and exceeding SOLs, 
and on implementing operating plans to mitigate exceedances. The SOL 
white paper explains the links between relevant reliability standards 
and reliability concepts to establish a common understanding necessary 
for developing effective operating plans to mitigate SOL 
exceedances.\11\
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    \10\ The NERC Glossary of Terms defines IROL as ``[a] System 
Operating Limit that, if violated, could lead to instability, 
uncontrolled separation, or Cascading outages that adversely impact 
the reliability of the Bulk Electric System.'' In turn, NERC defines 
SOL as ``[t]he value (such as MW, MVar, Amperes, Frequency or Volts) 
that satisfies the most limiting of the prescribed operating 
criteria for a specified system configuration to ensure operation 
within acceptable reliability criteria. . . .''
    \11\ NERC Petition at 46 and Exhibit E, ``White Paper on System 
Operating Limit Definition and Exceedance Clarification.''
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    10. NERC states that it reviewed the report on the Arizona-Southern 
California Outages on September 8, 2011, Causes and Recommendations 
(``2011 Southwest Outage Blackout Report'') that includes findings and 
recommendations applicable to transmission operators, balancing 
authorities and reliability coordinators, and provides explanations of 
how the proposed Reliability Standards address the reliability issues 
identified following the 2011 Southwest Outage Blackout Report. 
Further, NERC states that it addressed outstanding Commission 
directives relevant to the proposed TOP and IRO Reliability Standards.

Revisions to TOP Standards

    11. NERC proposes three TOP Reliability Standards to replace the 
existing suite of TOP standards. The proposed TOP Reliability Standards 
generally address real-time operations and planning for next-day 
operations, and apply primarily to the responsibilities and authorities 
of transmission operators. Among other things, NERC states that the 
proposed revisions to the TOP Reliability Standards help ensure that 
transmission operators plan and operate within all SOLs.

TOP-001-3 (Transmission Operations)

    12. NERC proposes Reliability Standard TOP-001-3 (Transmission 
Operations), which contains twenty requirements. The purpose of 
proposed Reliability Standard TOP-001-3 is to prevent instability, 
uncontrolled separation, or cascading outages that adversely affect the 
reliability of the interconnection, by ensuring prompt action to 
prevent or mitigate such occurrences. According to NERC, the proposed 
standard achieves this reliability goal by providing appropriate 
entities with the authority to take actions, or direct the actions of 
others, to maintain reliability during real-time operations. NERC 
explains that the standard includes real-time monitoring and real-time 
assessment requirements

[[Page 36282]]

to preserve reliability and ensure that applicable entities identify 
and address all SOL exceedances.
    13. Requirements R1 and R2 require each transmission operator and 
balancing authority to explicitly and affirmatively act to address the 
reliability of its area through its own actions or by issuing operating 
instructions. In contrast, NERC notes that the obligation to act in 
currently effective Reliability Standard TOP-001-1a is implied, but not 
an explicit requirement. Requirements R3 and R4 together provide that 
each applicable entity must comply with each operating instruction 
issued by its transmission operator, unless doing so would violate 
safety, equipment, regulatory, or statutory requirements or the action 
cannot be physically implemented, and require an applicable entity to 
notify the transmission operator if it is unable to comply with the 
transmission operator's operating instruction. Similarly, Requirements 
R5 and R6 require the same actions of applicable entities with respect 
to an operating instruction issued by a balancing authority.
    14. Requirement R7 requires each transmission operator to assist 
other transmission operators within its reliability coordinator area, 
and Requirement R8 requires a transmission operator to inform 
applicable entities of the transmission operator's actual or expected 
operations that result in, or could result in, an emergency.
    15. Requirements R9, R16, and R17 address outage coordination of 
monitoring and control equipment. Requirement R9 provides that each 
balancing authority and transmission operator must notify its 
reliability coordinator and known impacted interconnected entities of 
all planned outages, and unplanned outages of 30 minutes or more, for 
telemetering and control equipment, monitoring and assessment 
capabilities, and associated communication channels between the 
affected entities. Requirements R16 and R17 state that each 
transmission operator and balancing authority must provide its system 
operators with the authority to approve planned outages and 
maintenance.
    16. Requirement R10 addresses transmission operator monitoring 
obligations to help ensure that transmission operators have the 
necessary situational awareness to maintain reliable operations. 
Requirement R10 provides that each transmission operator must take 
certain steps for determining SOL exceedances within its transmission 
operator area. NERC explains that Requirement R10 addresses the 
Commission's concerns that the TOP and IRO Reliability Standards, that 
were the subject of the Remand NOPR, did not have sufficient 
requirements for real-time monitoring. Requirement R11 is the 
equivalent of Requirement R10 for balancing authorities.
    17. Requirement R12 provides that each transmission operator must 
not operate outside of any identified IROL for a continuous duration 
exceeding its associated IROL Tv. NERC states that this 
requirement will provide consistency with the reliability coordinators 
requirements contained in currently-effective Reliability Standard IRO-
009-1.\12\ Requirement R13 provides that each transmission operator 
must ensure that a real-time assessment is performed at least once 
every 30 minutes. The revised definition of ``real-time assessment'' 
includes additional specificity regarding various inputs for the 
assessment and how that information may be provided through third-party 
services, which may provide smaller entities an efficient method for 
compliance. Requirement R14 provides that each transmission operator 
must initiate its operating plan to mitigate a SOL exceedance 
identified as part of its real-time monitoring or real-time 
assessment.\13\
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    \12\ NERC defines Tv as ``[t]he maximum time that an 
Interconnection Reliability Operating Limit can be violated before 
the risk to the interconnection or other Reliability Coordinator 
Area(s) becomes greater than acceptable. Each Interconnection 
Reliability Operating Limit's Tv shall be less than or 
equal to 30 minutes.''
    \13\ NERC Petition, Exhibit B at 5.
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    18. Requirement R15 provides that each transmission operator must 
inform its reliability coordinator of actions taken to return the 
system to within limits when a SOL has been exceeded. Requirement R18 
provides that each transmission operator must operate to the most 
limiting parameter in instances where there is a difference in SOLs. 
Requirements R19 and R20 provide that each transmission operator and 
balancing authority must have data exchange capabilities with the 
entities from which it needs data in order to maintain reliability in 
its area.
    19. In addition, NERC states that it removed the load-serving 
entity (LSE) function from proposed TOP-001-3, Requirements R3 through 
R6 due to the November 2014 NERC Board of Trustees action to remove the 
LSE as a functional entity from NERC's Rules of Procedure.\14\ On May 
12, 2015, NERC supplemented its filing with additional explanation for 
the removal of the LSE function.
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    \14\ NERC Petition, Exhibit K, Consideration of Comments January 
7, 2015, at 2.
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TOP-002-4 (Operations Planning)

    20. Proposed Reliability Standard TOP-002-4 contains seven 
requirements relating to operations planning for transmission operators 
and balancing authorities. NERC explains that the proposed standard 
addresses next-day planning and provides for the necessary 
notifications and coordination between various functional entities. 
NERC adds that the revised definition of ``operational planning 
analysis'' specifies the scope and inputs required for next-day 
analyses. According to NERC, the proposed standard also improves 
coordination of next-day operations by requiring transmission operators 
and balancing authorities to provide operating plans to their 
reliability coordinators.
    21. Proposed Requirements R1 through R3 and R6 apply to 
transmission operators, and proposed Requirements R4, R5, and R7 apply 
to balancing authorities. Requirement R1 requires each transmission 
operator to have an operational planning analysis that will allow it to 
assess whether its planned operations for the next day within its 
transmission operator area will exceed any of its SOLs. Requirement R2 
requires each transmission operator to have operating plans for next-
day operations to address potential SOL exceedances identified in the 
operational planning analysis performed pursuant to Requirement R1. 
Requirement R4 requires each balancing authority to have operating 
plans for the next day that address expected generation resource 
commitment and dispatch, interchange scheduling, demand patterns, and 
capacity and energy reserve requirements, including deliverability 
capability. Requirements R3 and R5 require each transmission operator 
and balancing authority, respectively, to notify the entities 
identified in their operating plan as to their roles in that plan. 
Requirements R6 and R7 require each transmission operator and balancing 
authority to provide its operating plan to its reliability coordinator.

TOP-003-3 (Operational Reliability Data)

    22. Proposed Reliability Standard TOP-003-3 (Operational 
Reliability Data) establishes requirements for the provision of 
information and data needed by the transmission operator and balancing 
authority for reliable operations. The purpose of proposed Reliability 
Standard TOP-003-3 is to ensure that transmission operators and

[[Page 36283]]

balancing authorities have the data needed to fulfill their operational 
and planning responsibilities. The proposed Reliability Standard 
consists of five Requirements, including requirements for balancing 
authorities and transmission operators to maintain and distribute to 
relevant entities data specifications needed to perform various 
analyses and assessments. The proposed Reliability Standard also 
requires entities receiving data specifications to respond according to 
mutually agreed upon parameters including format and security 
protocols.
    23. Requirement R1 requires each transmission operator to maintain 
a documented specification for the data necessary, including non-bulk 
electric system and external network data, for it to perform its 
operational planning analysis, real-time monitoring, and real-time 
assessments. Requirement R2 requires each balancing authority to 
maintain a documented specification for the data necessary for it to 
perform its analysis functions and real-time monitoring. Requirements 
R3 and R4 require each transmission operator and balancing authority to 
distribute its data specification to the entities that have the 
necessary data. Requirement R5 requires each applicable entity 
receiving a data specification pursuant to Requirement R3 or R4 to 
satisfy the obligations of the documented data specification.
    24. In response to the Commission's concerns in the Remand NOPR 
with regard to the need for including external networks and sub-100 kV 
facilities in the operational planning analysis conducted by 
transmission operators, NERC explains that proposed Reliability 
Standard TOP-003-3 requires each applicable entity to develop a data 
specification that would cover its data needs for monitoring and 
analysis purposes, including non-bulk electric system data and external 
network data deemed necessary by the transmission operator to support 
its operational planning analyses, real-time monitoring, and real-time 
assessments. With respect to sub-100 kV facilities, NERC determined 
that any sub-100 kV elements that are necessary for reliable operation 
of the bulk electric system would be included as bulk electric system 
facilities through the exception process provided in Appendix 5C to the 
NERC Rules of Procedure. NERC explains that the exception process 
provides the means for transmission operators and reliability 
coordinators to include elements in the bulk electric system that are 
necessary for the reliable operation of the interconnected transmission 
system but were not identified in the bulk electric system definition. 
Accordingly, NERC concludes that it is not necessary to include non-
bulk electric system monitoring in Reliability Standard TOP-001-3. In 
addition, NERC explains that proposed Reliability Standard TOP-001-3, 
Requirement R10 requires transmission operators to monitor bulk 
electric system facilities within their transmission operator area, and 
to obtain information deemed necessary by the transmission operator 
about such bulk electric system facilities located outside of the 
transmission operator area when determining SOL exceedances.
    25. NERC adds that when non-bulk electric facilities have no impact 
on the bulk electric system, but are needed for completing system 
models, the Commission-approved Reliability Standard FAC-001-2, 
Requirement R3 addresses the issue. This Reliability Standard requires 
the reliability coordinator to include in its methodology its entire 
reliability coordinator area and critical modeling details from other 
reliability coordinator areas that would affect the facility under 
study. In addition, the reliability coordinator must include details of 
system models used to determine SOLs.

Revisions to IRO Standards

    26. The proposed IRO Reliability Standards, which complement the 
proposed TOP Standards, are designed to ensure that the bulk electric 
system is planned and operated in a coordinated manner to perform 
reliably under normal and abnormal conditions. The proposed IRO 
Reliability Standards set forth the responsibility and authority of 
reliability coordinators to provide for reliable operations. NERC 
states that in the proposed IRO Reliability Standards reliability 
coordinators must continue to monitor SOLs in addition to their 
obligation in the currently effective Reliability Standards to monitor 
and analyze IROLs. These obligations require reliability coordinators 
to have the wide-area view necessary for situational awareness and 
provide them the ability to respond to system conditions that have the 
potential to negatively affect reliable operations.

IRO-001-4 (Reliability Coordination--Responsibilities)

    27. Proposed Reliability Standard IRO-001-4 (Reliability 
Coordination--Responsibilities) contains requirements relating to the 
reliability coordinator's overall responsibility for reliable operation 
within the reliability coordinator area. Requirement R1 provides that 
each reliability coordinator must act to address the reliability of its 
reliability coordinator area through direct actions or by issuing 
operating instructions. Requirement R2 provides that each applicable 
entity must comply with its reliability coordinator's operating 
instructions unless compliance cannot be implemented or would violate 
safety, equipment, regulatory, or statutory requirements. Requirement 
R3 provides that applicable entities must inform the reliability 
coordinator if they are unable to perform an operating instruction 
issued by its reliability coordinator.

IRO-002-4 (Reliability Coordination--Monitoring and Analysis)

    28. Proposed Reliability Standard IRO-002-4 (Reliability 
Coordination--Monitoring and Analysis) contains requirements relating 
to capabilities for monitoring and analysis of real-time operating 
data. The purpose of the proposed Reliability Standard is to provide 
system operators with the capabilities necessary to monitor and analyze 
data needed to perform reliability functions. Requirement R1 requires 
each reliability coordinator to have data exchange capabilities with 
its balancing authorities, transmission operators, and other entities 
as it deems necessary, for it to perform operational planning analyses, 
real-time monitoring, and real-time assessments. Requirement R2 
provides that each reliability coordinator must provide its system 
operators with the authority to approve planned outages and maintenance 
of its telecommunication, monitoring, and analysis capabilities. 
Requirement R3 provides that each reliability coordinator must monitor 
facilities, the status of special protection systems and non-bulk 
electric system facilities identified as necessary within its 
reliability coordinator area and neighboring reliability coordinator 
areas, to identify any SOL or IROL exceedances. Requirement R4 provides 
that each reliability coordinator must have monitoring systems that 
provide information used by the reliability coordinator's operating 
personnel, with particular emphasis to alarm management and awareness 
systems, automated data transfers, and synchronized information 
systems, over a redundant infrastructure.

IRO-008-2 (Reliability Coordinator Operational Analyses and Real-time 
Assessments)

    29. Proposed Reliability Standard IRO-008-2 (Reliability 
Coordinator Operational Analyses and Real-time Assessments) contains 
requirements for reliability coordinators to conduct next-day analyses 
and assessments of

[[Page 36284]]

operating conditions in real-time to help prevent instability, 
uncontrolled separation, or cascading. NERC states that the proposed 
definitions of operational planning analysis and real-time assessment 
are integral components of proposed Reliability Standard IRO-008-2 
because they specify the scope and inputs for next-day analysis and 
real-time assessments of operating conditions in real-time. 
Furthermore, NERC states that proposed Reliability Standard IRO-008-2 
enhances next-day operations planning by specifying requirements for 
coordination of the reliability coordinator's operating plan to address 
potential SOL and IROL exceedances.
    30. Requirement R1 provides that each reliability coordinator must 
perform an operational planning analysis that will allow it to assess 
whether the planned operations for the next day will exceed SOLs and 
IROLs. Requirement R2 requires each reliability coordinator to have a 
coordinated operating plan for next-day operations to address potential 
SOL and IROL exceedances identified as a result of its operating 
planning analysis. Requirement R3 provides that each reliability 
coordinator must notify impacted entities identified in its operating 
plan as to their role in the plan. Requirement R4 states that each 
reliability coordinator must ensure that a real-time assessment is 
performed at least once every 30 minutes. Requirement R5 provides that 
each reliability coordinator must notify impacted transmission 
operators and balancing authorities within its reliability coordinator 
area and other impacted reliability coordinators when a real-time 
assessment indicates an actual or expected condition that results in, 
or could result in, a SOL or IROL exceedance. Further, Requirement R6 
provides that each reliability coordinator must notify impacted 
entities when a SOL or IROL exceedance has been prevented or mitigated.

IRO-010-2 (Reliability Coordinator Data Specification and Collection)

    31. Proposed Reliability Standard IRO-010-2 (Reliability 
Coordinator Data Specification and Collection) provides a mechanism for 
a reliability coordinator to obtain the information and data it needs 
for reliable operations and to help prevent instability, uncontrolled 
separation, or cascading outages. According to NERC, proposed 
Reliability Standard IRO-010-2 reflects recommendations from the 2011 
Southwest Outage Blackout Report, including more clearly identifying 
necessary data and information to be included in a reliability 
coordinator's data specification. Requirement R1 provides that the 
reliability coordinator must maintain a documented specification for 
the data, including non-bulk electric system and external network data, 
necessary for it to perform its operational planning analyses, real-
time monitoring, and real-time assessments. Requirement R2 provides 
that the reliability coordinator must distribute its data specification 
to entities that have the required data. Requirement R3 provides that 
applicable entities receiving a data specification must satisfy the 
obligations of the documented specification using a mutually-agreeable 
format, process for resolving data conflicts, and security protocol.

IRO-014-3 (Coordination Among Reliability Coordinators)

    32. Proposed Reliability Standard IRO-014-3 (Coordination among 
Reliability Coordinators) contains requirements for coordination for 
interconnected operations at the reliability coordinator level. The 
purpose of the proposed Reliability Standard is to ensure that each 
reliability coordinator's operations are coordinated such that they 
will not adversely affect other reliability coordinator areas and to 
preserve the reliability benefits of interconnected operations. 
Requirement R1 requires each reliability coordinator to have and 
implement operating procedures, processes, or plans for activities that 
require notification or coordination of actions that may affect 
adjacent reliability coordinator areas. Requirement R2 requires each 
reliability coordinator to maintain its operating procedures, 
processes, or plans through annual reviews and updates, with no more 
than 15 months passing between reviews. Requirement R3 requires each 
reliability coordinator to notify other impacted reliability 
coordinators upon identification of an expected or actual emergency. 
Requirement R4 specifies that, if the reliability coordinators disagree 
on the existence of an emergency, each must operate as though an 
emergency exists. Requirement R5 states that a reliability coordinator 
that identifies an emergency must develop an action plan to resolve the 
emergency, and Requirement R6 requires impacted reliability 
coordinators to implement the action plan. Under Requirement R7, a 
reliability coordinator must assist another reliability coordinator if 
the requesting reliability coordinator has implemented its emergency 
procedures.

IRO-017-1 (Outage Coordination)

    33. NERC states that proposed Reliability Standard IRO-017-1 
(Outage Coordination) is a new Reliability Standard designed to ensure 
that outages are properly coordinated in the operations planning time 
horizon and near-term transmission planning horizon. According to NERC, 
the requirements in the proposed Reliability Standard, which span both 
time horizons, provide the necessary requirements for effective 
coordination of planned outages to support reliable operations.
    34. NERC notes that in the Remand NOPR the Commission identified 
coordination of outages as a critical reliability function that should 
be performed by the reliability coordinator that was not adequately 
addressed. NERC explains that proposed Reliability Standard IRO-017-1 
addresses the Commission's Remand NOPR concerns by requiring each 
reliability coordinator to develop, implement and maintain an outage 
coordination process for generation and transmission outages. NERC also 
explains that each transmission operator and balancing authority would 
then be required to perform the functions specified in its reliability 
coordinator's process. Further, NERC states that each planning 
coordinator and transmission planner will provide its planning 
assessment to relevant reliability coordinators and work together to 
solve any issues or conflicts with planned outages among the applicable 
entities. Additionally, NERC states that proposed Reliability Standard 
IRO-014-3, Requirement R1, Part 1.4 requires reliability coordinators 
to coordinate with adjacent reliability coordinators the exchange of 
planned and unplanned outage information to support operational 
planning analyses and real-time assessments in their operating 
procedures, processes, or plans.
    35. Proposed Reliability Standard IRO-017-1 has four requirements. 
Requirement R1 provides that each reliability coordinator must develop, 
implement, and maintain an outage coordination process for generation 
and transmission outages. Requirement R2 provides that each 
transmission operator and balancing authority must perform the 
functions specified in its reliability coordinator's outage 
coordination process. Requirement R3 provides that each planning 
coordinator and transmission planner must provide its planning 
assessment to impacted reliability coordinators. Requirement R4 
requires each planning coordinator and transmission planner to jointly 
develop

[[Page 36285]]

solutions with its respective reliability coordinators for identified 
issues or conflicts with planned outages in its planning assessment for 
the near-term transmission planning horizon.

Definitions

    36. NERC also proposes revised definitions for ``operational 
planning analysis'' and ``real-time assessment.'' \15\ NERC contends 
that the proposed definitions provide significant additional detail 
compared to the currently effective definitions to enhance the 
consistency and the reliability benefit of operational planning 
analysis and real-time assessments.\16\ NERC states that the additional 
specificity reflected in the proposed definitions addresses concerns 
raised in the Remand NOPR and includes several inputs that were 
identified as recommendations in the 2011 Southwest Outage Blackout 
Report, which, in turn, will enhance situational awareness.
---------------------------------------------------------------------------

    \15\ The proposed definition of operational planning analysis is 
``[a]n evaluation of projected system conditions to assess 
anticipated (pre-Contingency) and potential (post-Contingency) 
conditions for next-day operations. The evaluation shall reflect 
applicable inputs including, but not limited to, load forecasts; 
generation output levels; Interchange; known Protection System and 
Special Protection System status or degradation; Transmission 
outages; generator outages; Facility Ratings; and identified phase 
angle and equipment limitations. (Operational Planning Analysis may 
be provided through internal systems or through third-party 
services.)''
    \16\ The proposed definition of real-time assessment is ``[a]n 
evaluation of system conditions using Real-time data to assess 
existing (pre-Contingency) and potential (post-Contingency) 
operating conditions. The assessment shall reflect applicable inputs 
including, but not limited to: Load, generation output levels, known 
Protection System and Special Protection System status or 
degradation, Transmission outages, generator outages, Interchange, 
Facility Ratings, and identified phase angle and equipment 
limitations. (Real-time Assessment may be provided through internal 
systems or through third-party services.)''
---------------------------------------------------------------------------

    37. The proposed NERC Glossary term ``Operating Instruction'' 
defines the scope of commands that are covered by the proposed TOP and 
IRO Reliability Standards. NERC explains that the revisions in the 
proposed definitions are intended to ensure that operational planning 
analyses and real-time assessments contain sufficient details to result 
in an appropriate level of situational awareness for next-day planning 
and real-time operations, respectively.

Implementation Plan

    38. NERC proposes that, for all standards except proposed 
Reliability Standards TOP-003-3 and IRO-010-2, the effective date will 
be the first day of the first calendar quarter twelve months after 
Commission approval. The twelve month implementation period for all of 
the standards except TOP-003-3 and IRO-010-2 is intended to allow time 
for entities to update processes and train operators on the revised 
requirements. All of the Requirements in proposed TOP-003-3 and IRO-
010-2 except TOP-003-3, Requirements R5 and IRO-010-2, Requirement R3 
would become effective three months earlier, in order to provide 
recipients of data requests from their reliability coordinators, 
transmission operators, and/or balancing authorities time to respond to 
the requests for data.
    39. According to NERC's implementation plan, for proposed TOP-003-
3, all requirements except Requirement R5 will become effective on the 
first day of the first calendar quarter nine months after the date that 
the standard is approved. For proposed IRO-010-2, Requirements R1 and 
R2 would become effective on the first day of the first calendar 
quarter that is nine months after the date that the standard is 
approved. Requirement R3 would become effective on the first day of the 
first calendar quarter twelve months after the date that the standard 
is approved. NERC states that the reason for the difference in 
effective dates for proposed TOP-003-3 and IRO-010-2 is to allow 
applicable entities to have time to properly respond to the data 
specification requests.

II. Discussion

    40. Pursuant to section 215(d) of the FPA, we propose to approve 
NERC's proposed revisions to the TOP and IRO Reliability Standards as 
just, reasonable, not unduly discriminatory or preferential, and in the 
public interest. We believe that NERC's approach of consolidating 
requirements and removing redundancies generally has merit and is 
consistent with Commission policy promoting increased efficiencies in 
Reliability Standards and reducing requirements that are either 
redundant with other currently effective requirements or have little 
reliability benefit.\17\
---------------------------------------------------------------------------

    \17\ Electric Reliability Organization Proposal to Retire 
Requirements in Reliability Standards, Order No. 788, 145 FERC ] 
61,147 (2013).
---------------------------------------------------------------------------

    41. We agree with NERC that the proposed TOP and IRO Reliability 
Standards would improve reliability by defining an appropriate division 
of responsibilities between reliability coordinators and transmission 
operators.\18\ Specifically, NERC states that the proposed TOP 
Reliability Standards will be improved by eliminating multiple TOP 
standards, resulting in a more concise set of standards. Thus, we 
believe that NERC's TOP proposal would reduce redundancy and more 
clearly delineate responsibilities between applicable entities. In 
addition, we believe that the proposed Reliability Standards provide a 
comprehensive framework as well as important improvements to ensure 
that the bulk electric system is operated within pre-established limits 
while enhancing situational awareness and strengthening operations 
planning. We believe that the proposed TOP and IRO Reliability 
Standards address the coordinated efforts to plan and reliably operate 
the bulk electric system under both normal and abnormal conditions.
---------------------------------------------------------------------------

    \18\ See, e.g., Order No. 748, 134 FERC ] 61,213, at PP 39-40.
---------------------------------------------------------------------------

    42. For these reasons, we propose to approve NERC's revisions to 
the TOP and IRO Reliability Standards. We also discuss below: (A) 
Concerns raised in the Remand NOPR plus possible inconsistencies of 
identifying IROLs; (B) other reliability issues including (1) 
monitoring of non-bulk electric system facilities; (2) removal of the 
load-serving entity function from proposed Reliability Standard TOP-
001-3; and (3) data exchange capabilities.

A. Remand NOPR Issues

1. Operational Responsibilities and Actions of SOLs and IROLs
    43. We propose to find that NERC has adequately addressed the 
concerns raised by the Commission in the Remand NOPR with respect to 
the treatment of SOLs in the proposed TOP Reliability Standards. In the 
Remand NOPR, the Commission expressed concern that the proposed TOP 
standards did not have a requirement ``for transmission operators to 
plan and operate within all SOLs. Without a requirement to plan and 
operate within all SOLs in the proposed standards and by limiting non-
IROL SOLs to only those identified by the transmission operator 
internal to its area, system reliability is reduced and negative 
consequences can occur outside of the transmission operator's internal 
area.'' \19\ The Commission noted that ``non-IROL SOLs that appear to 
be excluded from the proposed standard are non-IROL SOLs that are in a 
transmission operator's area that impact another transmission 
operator's area or more than one transmission operator's area.'' \20\
---------------------------------------------------------------------------

    \19\ Remand NOPR, 145 FERC ] 61,158 at P 42.
    \20\ Id. P 51.
---------------------------------------------------------------------------

    44. The Commission believes that the proposed TOP Reliability 
Standards address the Commission's Remand

[[Page 36286]]

NOPR concerns by requiring transmission operators to plan and operate 
within all SOLs, and to monitor and assess SOL conditions within and 
outside a transmission operator's area. Specifically, proposed 
Reliability Standard TOP-001-3, Requirement R14 requires each 
transmission operator to initiate its operating plan to mitigate a SOL 
exceedance identified as part of its real-time monitoring or real-time 
assessment. Proposed Reliability Standard TOP-001-3, Requirement R10 
requires each transmission operator to monitor facilities within its 
transmission operator area as well as certain facilities outside of its 
transmission operator area to determine SOL exceedances within its 
transmission operator area during the real-time operations time 
horizon. In addition, proposed Reliability Standard TOP-001-3, 
Requirement R15 requires that each transmission operator inform its 
reliability coordinator of actions taken to resolve a SOL 
exceedance.\21\ To address the concerns of operational planning, 
proposed Reliability Standard TOP-002-4, Requirement R1 requires each 
transmission operator to have an operational planning analysis to 
assess whether its next-day planned operations will exceed any of its 
SOLs within its area, and Requirement R2 requires the transmission 
operator to have a next-day operating plan(s) to address any potential 
SOLs exceedances identified in its operational planning analysis.\22\
---------------------------------------------------------------------------

    \21\ NERC Petition at 24-25.
    \22\ NERC Petition at 27.
---------------------------------------------------------------------------

    45. Further, proposed Reliability Standard IRO-008-2, Requirements 
R1, R2, R3, R5, and R6 require reliability coordinators to plan and 
operate within SOLs and IROLs, which we believe work in tandem with the 
proposed TOP Standards and address the Commission's concern that the 
previously-proposed Reliability Standards limited ``non-IROL SOLs'' to 
only those internally identified by the transmission operator. Specific 
to operational planning, proposed Reliability Standard IRO-008-2, 
Requirement R1 requires the reliability coordinator to have an 
operational planning analysis to assess whether its next-day planned 
operations will exceed SOLs and IROLs within its wide area, and 
Requirement R2 requires the reliability coordinator to have a 
coordinated next-day operating plan(s) to address potential SOLs and 
IROLs exceedances identified in its operational planning analysis while 
considering the next-day operating plan(s) provided by its transmission 
operators and balancing authorities.\23\ Requirement R3 requires the 
reliability coordinator to notify impacted entities identified in its 
operating plan cited in Requirement R2 as to their role in such 
plan(s). The Commission believes that the consideration of the 
transmission operators' and balancing authorities' operating plans by 
the reliability coordinator in its own operating plan provides the 
necessary situational awareness of all SOLs, internal and external to 
the transmission operator or balancing authority.
---------------------------------------------------------------------------

    \23\ NERC Petition at 52.
---------------------------------------------------------------------------

    46. In the Remand NOPR, the Commission raised the concern that the 
then-proposed version of the TOP/IRO Standards did not consider the 
possibility that additional SOLs could develop or occur in the same-day 
or real-time operational time horizon, and therefore would pose an 
operational risk to the interconnected transmission network.\24\ To 
address this concern, Reliability Standard IRO-008-2, Requirement R5 
requires each reliability coordinator to notify impacted transmission 
operators and balancing authorities within its reliability coordinator 
area and other impacted reliability coordinators when results of a 
real-time assessment indicate actual or expected conditions that could 
result in SOL or IROL exceedances, and Requirement R6 requires 
reliability coordinator notification to impacted transmission 
operators, balancing authorities and other impacted reliability 
coordinators when any SOLs or IROLs have been prevented or 
mitigated.\25\
---------------------------------------------------------------------------

    \24\ Remand NOPR, 145 FERC ] 61,158 at P 55.
    \25\ NERC Petition at 32.
---------------------------------------------------------------------------

    47. Likewise, based on NERC's explanation, we believe that the 
proposed Reliability Standards in the immediate proceeding are designed 
to improve system performance by giving reliability coordinators the 
authority to direct actions to prevent or mitigate instances of 
exceeding IROLs. This delineation of responsibilities between 
reliability coordinators and transmission operators is appropriate 
because the primary decision-making authority for mitigating IROL 
exceedances is assigned to reliability coordinators while transmission 
operators have the primary responsibility for mitigating SOL 
exceedances.\26\ To further support the reliability coordinator's 
primary responsibility for IROLs to prevent instability, uncontrolled 
separation, or cascading, proposed Reliability Standard TOP-001-3, 
Requirement R12 requires that a transmission operator must not operate 
outside of any identified IROLs for a continuous duration exceeding its 
associated IROL Tv.\27\
---------------------------------------------------------------------------

    \26\ See Remand NOPR, 145 FERC ] 61,158 at P 85. Further, 
currently-effective Reliability Standard IRO-009-1, Requirement R4 
states that ``[w]hen actual system conditions show that there is an 
instance of exceeding an IROL in its Reliability Coordinator Area, 
the Reliability Coordinator shall, without delay, act or direct 
others to act to mitigate the magnitude and duration of the instance 
of exceeding that IROL within the IROL's Tv.''
    \27\ NERC Petition at 25.
---------------------------------------------------------------------------

    48. In addition, NERC explains that the proposed Reliability 
Standard IRO-014-3 contains requirements for coordination of 
interconnection operations at the reliability coordinator level and 
ensures that each reliability coordinator's operations are coordinated 
such that they will not adversely affect other reliability 
coordinators' areas.\28\ Proposed Reliability Standard IRO-014-3 
requires the reliability coordinator to have and implement operating 
procedures, processes, or plans for activities that require 
notification or coordination of actions that may affect adjacent 
reliability coordinators' areas.
---------------------------------------------------------------------------

    \28\ NERC Petition at 33.
---------------------------------------------------------------------------

    49. Furthermore, the Commission believes the revised definitions of 
operational planning analysis and real-time assessment are critical 
components of the proposed TOP and IRO Reliability Standards and, 
together with the definitions of SOLs, IROLs and operating plans, work 
to ensure that reliability coordinators, transmission operators and 
balancing authorities plan and operate the bulk electric system within 
all SOLs and IROLs to prevent instability, uncontrolled separation, or 
cascading. In addition, the revised definitions of operational planning 
analysis and real-time assessment address other concerns raised in the 
Remand NOPR as well as multiple recommendations in the 2011 Southwest 
Outage Blackout Report.\29\ For example, the definition of operational 
planning analysis is used in proposed Reliability Standards TOP-002-4, 
TOP-003-3, IRO-002-4, IRO-008-2, IRO-010-2, and IRO-014-3 to ensure a 
consistent approach to operations planning for the reliability 
coordinators, transmission operators and balancing authorities.\30\ 
Further, the proposed revised operational planning analysis definition 
adds additional detail and clarity, including the evaluation of pre- 
and post-contingency conditions as well as the evaluation of multiple 
applicable inputs that are

[[Page 36287]]

absent in the currently-effective definition.
---------------------------------------------------------------------------

    \29\ NERC Petition at 17-18.
    \30\ NERC Petition at 19.
---------------------------------------------------------------------------

    50. Likewise, the definition of real-time assessment is used in the 
following proposed Reliability Standards: TOP-001-3; TOP-003-3; IRO-
002-4; IRO-008-2; IRO-010-2; and IRO-014-3 to ensure a consistent 
approach to the real-time operation of the Bulk Power System for the 
reliability coordinators, transmission operators and balancing 
authorities.\31\ The proposed revised real-time assessment definition 
is the same type of evaluation as the operational planning analysis 
with the exception that real-time assessment uses real-time data to 
assess existing conditions and operational planning analysis uses 
projected system conditions to assess anticipated system conditions.
---------------------------------------------------------------------------

    \31\ NERC Petition at 18.
---------------------------------------------------------------------------

    51. The Commission does note, however, that in Exhibit E (SOL White 
Paper) of NERC's petition, NERC states that with regard to the SOL 
concept, the SOL White Paper brings ``clarity and consistency to the 
notion of establishing SOLs, exceeding SOLs, and implementing Operating 
Plans to mitigate SOL exceedances.'' \32\ The Commission further notes 
that IROLs, as defined by NERC, are a subset of SOLs that, if violated, 
could lead to instability, uncontrolled separation, or cascading 
outages that adversely impact the reliability of the bulk electric 
system.\33\ The Commission agrees with NERC that clarity and 
consistency are important with respect to establishing and implementing 
operating plans to mitigate SOL and IROL exceedances. However, the 
Commission notes that in its 2015 State of Reliability report, NERC 
states that the Western Interconnection reliability coordinator 
definition of an IROL has additional criteria that may not exist in 
other reliability coordinator areas.\34\ Based on this information, it 
is unclear whether NERC regions apply a consistent approach to 
identifying IROLs. Accordingly, the Commission seeks comment on (1) 
identification of all regional differences or variances in the 
formulation of IROLs, (2) the potential reliability impacts of such 
differences or variations, and (3) the value of providing a uniform 
approach or methodology to defining and identifying IROLs.
---------------------------------------------------------------------------

    \32\ NERC Petition, Exhibit E, ``White Paper on System Operating 
Limit Definition and Exceedance Clarification'' at 1.
    \33\ NERC Glossary of Terms defines Interconnection Reliability 
Operating Limit as ``[a] System Operating Limit that, if violated, 
could lead to instability, uncontrolled separation, or Cascading 
outages that adversely impact the reliability of the Bulk Electric 
System.''
    \34\ NERC 2015 State of Reliability report at 44, available at 
www.nerc.com. See also WECC Reliability Coordination System 
Operating Limits Methodology for the Operations Horizon, Rev. 7.0 
(effective March 3, 2014) at 18 (stating that ``SOLs qualify as 
IROLs when . . . studies indicate that instability, Cascading, or 
uncontrolled separation may occur resulting in uncontrolled 
interruption of load equal to or greater than 1000 MW''), available 
at https://www.wecc.biz/Reliability/PhaseII%20WECC%20RC%20SOL%20Methodology%20FINAL.pdf.
---------------------------------------------------------------------------

 2. Outage Coordination
    52. We believe, too, that NERC has addressed the concerns raised in 
the Remand NOPR with respect to the IRO standards regarding planned 
outage coordination. In the Remand NOPR, the Commission expressed 
concern with NERC's proposal because Reliability Standards IRO-008-1, 
Requirement R3 and IRO-010-1a (subjects of the proposed remand and now 
withdrawn by NERC) did not require the coordination of outages, noting 
that outage coordination is a critical reliability function that should 
be performed by the reliability coordinator.\35\
---------------------------------------------------------------------------

    \35\ Remand NOPR, 145 FERC ] 61,158 at P 90.
---------------------------------------------------------------------------

    53. With respect to proposed Reliability Standard IRO-017-1, 
submitted by NERC for approval in the immediate proceeding, Requirement 
R1 requires each reliability coordinator to develop, implement and 
maintain an outage coordination process for generation and transmission 
outages within its reliability coordinator area. Under Requirement R2, 
each transmission operator and balancing authority, in turn, would 
perform the functions specified in its reliability coordinator's outage 
coordination process. Further, Requirement R3 requires each planning 
coordinator and transmission planner to provide its planning assessment 
to the relevant reliability coordinators and to work together to solve 
any issues or conflicts with planned outages among the applicable 
entities under Requirement R4. Additionally, proposed Reliability 
Standard IRO-014-3, Requirement R1, Part 1.4 requires reliability 
coordinators to include the exchange of planned and unplanned outage 
information to support operational planning analyses and real-time 
assessments in the operating procedures, processes, and plans for 
activities that require coordination with adjacent reliability 
coordinators. Further, the proposed revised definitions of operational 
planning analysis and real-time assessments require that these 
evaluations of system conditions include transmission and generation 
outages. We believe that these proposed standards and revised 
definitions adequately address our concerns with respect to outage 
coordination as outlined in the Remand NOPR.

B. Other Reliability Issues

    54. While proposing to approve the TOP and IRO Reliability 
Standards, the Commission seeks clarifying comments addressing three 
additional issues: (1) Monitoring of non-bulk electric system 
facilities; (2) removal of the load-serving entity as an applicable 
entity for proposed Reliability Standard TOP-001-3; and (3) data 
exchange capabilities. Based on comments and information received on 
these issues, the Commission may issue directives as appropriate.
1. Monitoring of Non-Bulk Electric System Facilities
NERC Petition
    55. NERC explains how the proposed Reliability Standards address 
the recommendations in the 2011 Southwest Outage Blackout Report, in 
particular with respect to Finding 17 concerning the impact of sub-100 
kV facilities on the reliability of the interconnected transmission 
network. Finding 17 states:

    WECC RC and affected TOPs and BAs do not consistently recognize 
the adverse impact sub-100 kV facilities can have on BPS 
reliability. As a result, sub-100 kV facilities might not be 
designated as part of the BES, which can leave entities unable to 
address the reliability impact they can have in the planning and 
operations time horizons. If, prior to September 8, 2011, certain 
sub-100 kV facilities had been designated as part of the BES and, as 
a result, were incorporated into the TOPs' and RC's planning and 
operations studies, or otherwise had been incorporated into these 
studies, cascading outages may have been avoided on the day of the 
event.

    Recommendation 17 states:

    WECC, as the RE, should lead other entities, including TOPs and 
BAs, to ensure that all facilities that can adversely impact BPS 
reliability are either designated as part of the BES or otherwise 
incorporated into planning and operations studies and actively 
monitored and alarmed in [real-time contingency analysis] systems.

    NERC states that proposed Reliability Standard IRO-002-4, 
Requirement R3 addresses monitoring of non-bulk electric system 
facilities by requiring each reliability coordinator to monitor 
facilities and necessary non-bulk electric system facilities in order 
to identify SOL and IROL exceedances within its reliability coordinator 
area.\36\ In addition, NERC states that proposed Reliability Standards 
IRO-010-2,

[[Page 36288]]

Requirement R1.1 and TOP-003-3, Requirement R1.1 address non-bulk 
electric system data by specifically requiring reliability coordinators 
and transmission operators to incorporate any non-bulk-electric system 
data as deemed necessary into their operational planning analyses, 
real-time monitoring, and real-time assessments.\37\
---------------------------------------------------------------------------

    \36\ NERC Petition at 61.
    \37\ Id. at 40.
---------------------------------------------------------------------------

    56. However, NERC explains that the standard drafting team 
concluded it is unnecessary to include non-bulk electric system 
monitoring in proposed Reliability Standard TOP-001-3, Requirement R10 
for the transmission operator, in a similar fashion as proposed 
Reliability Standard IRO-002-4, Requirement R3 for the reliability 
coordinator. Instead, the standard drafting team determined that any 
non-bulk electric system facility elements that are necessary for 
reliable operation of the bulk electric system would be included in the 
bulk electric system through the exception process provided in Appendix 
5C to the NERC Rules of Procedure. NERC states that the exception 
process provides the means for transmission operators and reliability 
coordinators to include elements in the bulk electric system that are 
necessary for the reliable operation of the interconnected transmission 
system but not identified in the bulk electric system definition.\38\
---------------------------------------------------------------------------

    \38\ Id. at 47-48.
---------------------------------------------------------------------------

Commission Proposal
    57. We propose to find that NERC has adequately addressed the 2011 
Southwest Outage Blackout Report recommendation in connection with sub-
100 kV facilities for proposed Reliability Standards IRO-002-4, 
Requirement R3, IRO-010-2, Requirement R1.1 and TOP-003-3, Requirement 
R1.1. In doing so, we rely primarily on the proposed responsibility of 
the reliability coordinator to monitor such facilities to the extent 
necessary.
    58. However, the transmission operator may have a more granular 
perspective than the reliability coordinator of its necessary non-bulk 
electric system facilities to monitor in order to identify SOL and IROL 
exceedances, and it is not clear whether or how the transmission 
operator would communicate any insight it may have to the reliability 
coordinator to ensure monitoring of all necessary facilities. Thus, the 
Commission seeks comment on how NERC will ensure that the reliability 
coordinator will receive information from the transmission operator 
regarding which non-bulk electric system facilities should be 
monitored. Further, as stated above, Recommendation 17 states ``. . . 
to ensure that all facilities that can adversely impact BPS reliability 
are either designated as part of the BES or otherwise incorporated into 
planning and operations studies and actively monitored and alarmed in 
[real-time contingency analysis] systems.'' (emphasis added.) Including 
such non-bulk electric system facilities in the definition of bulk 
electric system through the Rules of Procedure exception process could 
be an option to address any potential gaps for monitoring facilities. 
However, there may be potential efficiencies gained by using a more 
expedited method to include non-bulk electric system that requires 
monitoring. Thus, the Commission seeks comments on whether the 
exception process should be used exclusively in all cases.
    59. Alternatively, we seek comment regarding whether this concern 
should be addressed through a review process of the transmission 
operators' systems to determine if there are important non-bulk-
electric system facilities that require monitoring. For example, 
Commission staff could work with NERC, Regional Entities and applicable 
entities to review their system modeling and perform an analysis to 
identify non-bulk electric system facilities that need monitoring. 
Accordingly, we seek comment from NERC and other interested persons on 
these alternatives.
2. Removal of Load-Serving Entity Function From TOP-001-3
NERC Petition
    60. Proposed Reliability Standard TOP-001-3, Requirement R3 
requires that each balancing authority, generator operator and 
distribution provider shall comply with each operating instruction 
issued by its transmission operator, and proposed Reliability Standard 
TOP-001-3, Requirement R4 requires that each balancing authority, 
generator operator and distribution provider inform its transmission 
operator of its inability to comply with an operating instruction. 
Proposed Reliability Standard TOP-001-3, Requirement R5 requires that 
each transmission operator, generator operator and distribution 
provider shall comply with each operating instruction issued by its 
balancing authority, and proposed Reliability Standard TOP-001-3, 
Requirement R6 requires that each transmission operator, generator 
operator and distribution provider inform its balancing authority of 
its inability to comply with an operating instruction.\39\
---------------------------------------------------------------------------

    \39\ NERC Petition at 22-23.
---------------------------------------------------------------------------

    61. In its petition, NERC states that, during the standard drafting 
process, the load-serving entity function was removed from proposed 
Reliability Standard TOP-001-3, Requirements R3 through R6. NERC 
explains that the removal of the load-serving entity as an applicable 
entity was based on the November 2014 NERC Board of Trustees action to 
remove load-serving entity as a functional entity from NERC's Rules of 
Procedure.\40\ Since that time, the Commission has issued an order in 
Docket No. RR15-4-000 that denied, without prejudice, NERC's proposal 
to remove the load-serving entity as a functional entity under NERC's 
Risk Based Registration petition and directed NERC to submit a 
compliance filing to address this issue.\41\
---------------------------------------------------------------------------

    \40\ NERC Petition, Exhibit K, Consideration of Comments January 
7, 2015, at 2.
    \41\ North American Electric Reliability Corp., 150 FERC ] 
61,213 (2015).
---------------------------------------------------------------------------

    62. On May 12, 2015, NERC supplemented its initial petition with 
additional explanation for the removal of the load-serving entity 
function from proposed Reliability Standard TOP-001-3. NERC explains 
that the proposed standard gives transmission operators and balancing 
authorities the authority to direct the actions of certain other 
functional entities by issuing an operating instruction to maintain 
reliability during real-time operations. According to NERC, load-
serving entities are not included in the list of entities that must 
comply with a transmission operator's or balancing authority's 
operating instructions. NERC contends that the exclusion is justified 
because none of the functions performed by load-serving entities, as 
described in the NERC Functional Model, necessitate that load-serving 
entities be subject to a requirement to comply with such operating 
instructions to ensure that a transmission operator or balancing 
authority can maintain reliability.\42\ NERC adds that a load-serving 
entity does not own or operate bulk electric system facilities or 
equipment or the facilities or equipment used to serve end-use 
customers and its NERC Functional Model tasks are limited in scope. As 
indicated by the NERC Functional Model, the load-serving entity does 
not play a role in shedding load in real-time.
---------------------------------------------------------------------------

    \42\ NERC Supplemental Filing at 6.
---------------------------------------------------------------------------

    63. NERC also explains in its supplemental filing that the standard 
drafting team did not identify any circumstances under which a

[[Page 36289]]

transmission operator or balancing authority would need to issue an 
operating instruction to a load-serving entity to prevent instability, 
uncontrolled separation, or cascading outages. NERC contends that, with 
respect to the load-serving entity's role as a provider of information 
to other functional entities, that role is primarily carried out ahead 
of real-time and would not be the subject of an operating instruction. 
Additionally, NERC states that the load-serving entity's real-time role 
with respect to voluntary load curtailment does not necessitate 
requiring load-serving entities to comply with operating instructions 
issued by a transmission operator or balancing authority. In order to 
maintain reliability in their areas and prevent instability, 
uncontrolled separation, or cascading outages, there may be 
circumstances under which transmission operators and balancing 
authorities need to shed load. NERC states that such action is 
implemented in real-time to address imminent or existing reliability 
issues such as an exceedance of an IROL or SOL, or a voltage problem. 
According to NERC, due to the urgent nature of these circumstances, the 
reliability coordinator, balancing authority, or transmission operator 
may issue operating instructions directly to the distribution provider 
for physical implementation of load shedding (except when this can be 
accomplished directly by the transmission operator).\43\
---------------------------------------------------------------------------

    \43\ NERC Supplemental Filing at 9.
---------------------------------------------------------------------------

Commission Proposal
    64. NERC proposes the removal of the load-serving entity function 
from proposed Reliability Standard, TOP-001-3, Requirements R3 through 
R6, as a recipient of an operating instruction from a transmission 
operator or balancing authority. However, the Commission notes that the 
issuance and compliance of operating instructions under proposed 
Reliability Standard TOP-001-3 is not limited to the real-time 
operations time horizon only.\44\
---------------------------------------------------------------------------

    \44\ NERC TOP/IRO Petition, Exhibit A includes the following 
time horizons for proposed Reliability Standard TOP-001-3, 
Requirements R3 through R6: ``[Time Horizon: Same-Day Operations, 
Real-Time Operations].''
---------------------------------------------------------------------------

    65. Further, if a transmission operator or balancing authority 
would issue an operating instruction to a load-serving entity such as 
to carry out interruptible load curtailments, it is not clear what 
entity would respond to this operating instruction if the load-serving 
entity is removed from proposed TOP-001-3, Requirements R3 through 
R6.\45\
---------------------------------------------------------------------------

    \45\ NERC Glossary of Terms defines Interruptible Load as the 
``[d]emand that the end-use customer makes available to its Load-
Serving Entity via contract or agreement for curtailment.''
---------------------------------------------------------------------------

    66. The Commission notes that NERC is required to make a compliance 
filing in July 2015 in Docket No. RR15-4-000. The Commission's decision 
on that filing will guide any action in this proceeding.
3. Data Exchange Capabilities
NERC Petition
    67. In Order No. 808, the Commission approved Reliability Standards 
COM-001-2 (Communications) and COM-002-4 (Operating Personnel 
Communications Protocols).\46\ In Order No. 808, the Commission 
explained that it had raised concerns in the underlying NOPR proposing 
to approve these COM Reliability Standards (COM NOPR) whether COM-001-2 
addresses ``facilities that directly exchange or transfer data.'' \47\ 
In response to the COM NOPR, NERC and other commenters clarified that 
Reliability Standard COM-001-2, which covers communications capability 
requirements, is not intended to address data exchanges or 
transfers.\48\ As the Commission noted in Order No. 808, NERC 
maintained that Reliability Standard COM-001-2 need not include 
requirements regarding data exchange capability, ``because such 
capability is covered under other existing or proposed standards.'' 
\49\ The Commission did not make any determinations regarding 
facilities used for data exchange capability in Order No. 808 and, 
based on NERC's explanation in its supplemental filing, the Commission 
stated that it would address these issues in this TOP and IRO 
rulemaking proceeding.\50\
---------------------------------------------------------------------------

    \46\ Communications Reliability Standards, Order No. 808, 151 
FERC ] 61,039 (2015).
    \47\ Order No. 808, 151 FERC ] 61,039 at P 54, quoting 
Communications Reliability Standards, Notice of Proposed Rulemaking, 
148 FERC ] 61,210, at P 33 (2014).
    \48\ Id. P 48.
    \49\ Id. See also NERC's Supplemental Comments in Response to 
Notice of Proposed Rulemaking, Communications Reliability Standards, 
Docket No. RM14-13-000 at 3.
    \50\ Order No. 808, 151 FERC ] 61,039 at P 54.
---------------------------------------------------------------------------

    68. In general, it appears that facilities for data exchange 
capabilities are addressed in NERC's proposal. For example, proposed 
Reliability Standard TOP-001-3, Requirements R19 and R20 require some 
form of ``data exchange capabilities'' for the transmission operator 
and balancing authority, respectively. Similarly, proposed Reliability 
Standard IRO-002-4, Requirement R1 requires some form of ``data 
exchange capabilities'' for the reliability coordinator. However, we 
seek additional explanation from NERC regarding how it addresses data 
exchange capabilities in the TOP and IRO Reliability Standards in the 
following areas: (a) Redundancy and diverse routing; and (b) testing of 
the alternate or less frequently used data exchange capability.
(i) Redundancy and Diverse Routing of Data Exchange Capabilities
Background
    69. The terms ``redundant'' and ``diverse routing'' of data 
exchange capabilities appear in Reliability Standard COM-001-1, where 
the reliability coordinator, transmission operator and balancing 
authority are required to have telecommunication facilities that are 
``redundant'' and ``diversely routed'' to maintain Bulk-Power System 
reliability.\51\ NERC added two definitions (Interpersonal 
Communication and Alternative Interpersonal Communication) to 
Reliability Standard COM-001-2 that addressed redundant and diverse 
routing of communications between persons and proposed to eliminate the 
need to use phrases such as ``redundant and diversely routed'' that it 
described as ambiguous.\52\ With respect to the data exchange 
capabilities, NERC stated that several proposed or existing standards 
``provided the necessary mandatory Requirements to ensure proper data 
exchange is occurring.'' \53\ NERC also asserted that four proposed IRO 
and TOP standards ``include specific coverage related to data 
exchange,'' and ``collectively require data exchange capability'' for 
reliability coordinators, transmission operators, balancing 
authorities, generator operators, and distribution providers.\54\
---------------------------------------------------------------------------

    \51\ COM-001-1.1 Standard, Requirement R1 requires that ``[e]ach 
Reliability Coordinator, Transmission Operator and Balancing 
Authority shall provide adequate and reliable telecommunications 
facilities for the exchange of Interconnection and operating 
information:'' and R1.4 requires that ``[w]here applicable, these 
facilities shall be redundant and diversely routed.''
    \52\ NERC COM Petition at 16.
    \53\ NERC COM Petition at 16.
    \54\ NERC Supp. COM Comments at 3. NERC identified these same 
four standards in its Initial Comments, but provides a more detailed 
discussion of the proposed standards and their status in its 
Supplemental Comments.
---------------------------------------------------------------------------

    70. In Order No. 808, the Commission approved NERC's definition of 
the terms Interpersonal Communication and Alternative Interpersonal 
Communication. NERC defines Interpersonal Communication as ``[a]ny 
medium that allows two or more individuals to interact, consult, or

[[Page 36290]]

exchange information.'' NERC defines Alternative Interpersonal 
Communication as ``[a]ny Interpersonal Communication that is able to 
serve as a substitute for, and does not utilize the same infrastructure 
(medium) as, Interpersonal Communication used for day-to-day 
operation.'' \55\ Reliability Standard COM-001-2, Requirements R1 
through R6 require that reliability coordinators, transmission 
operators, and balancing authorities have Interpersonal Communication 
capabilities and Alternative Interpersonal Communication capabilities 
in place with other defined entities (e.g., other interconnected 
transmission operators). In its COM Petition, NERC maintained that the 
defined terms make clear that an entity's communication capability must 
be redundant and that each of the capabilities must not utilize the 
same medium, while eliminating the need to use ambiguous phrases such 
as ``redundant and diversely routed'' (as used in the prior version of 
the standard governing communications capability).\56\
---------------------------------------------------------------------------

    \55\ Order No. 808, 151 FERC ] 61,039, at P 45 n.54.
    \56\ May 14, 2014, NERC COM Petition, Docket No. RM14-13-000 at 
15-16.
---------------------------------------------------------------------------

    71. As noted above, NERC indicated in its response to the COM NOPR 
that Reliability Standard COM-001-2 need not include requirements 
regarding data exchange capability because such capability is or would 
be covered by other existing or proposed standards. Specifically, NERC 
explained that data exchange is addressed by the currently enforceable 
Reliability Standards IRO-010-1a and IRO-014-1. In addition, NERC 
stated that data exchange transfer capabilities are directly addressed 
in proposed Reliability Standard TOP-001-3, as well as in proposed 
Reliability Standard IRO-002-4, Requirement R1. NERC also stated that 
the data itself is covered in proposed Reliability Standard IRO-010-2 
and proposed Reliability Standard TOP-003-3.\57\
---------------------------------------------------------------------------

    \57\ NERC COM Supplemental Comments at 3.
---------------------------------------------------------------------------

NERC Petition
    72. In the petition in this proceeding, NERC states that in 
proposed Reliability Standard TOP-001-3, ``Requirements R19 and R20 
provide that each Transmission Operator (Requirement R19) and Balancing 
Authority (Requirement R20) must have data exchange capabilities with 
the entities from which it needs data in order to maintain reliability 
in its area.'' \58\ NERC states that Requirements R19 and R20 are 
consistent with proposed Reliability Standard IRO-002-4, Requirement 
R1, which provides that each reliability coordinator must have data 
exchange capabilities with its balancing authorities, transmission 
operators, and other entities it deems necessary. Requirements R19 and 
R20 state:
---------------------------------------------------------------------------

    \58\ NERC Petition at 26.

    R19. Each Transmission Operator shall have data exchange 
capabilities with the entities that it has identified that it needs 
data from in order to maintain reliability in its Transmission 
Operator Area.
    R20. Each Balancing Authority shall have data exchange 
capabilities with the entities that it has identified that it needs 
data from in order to maintain reliability in its Balancing 
Authority Area.

    Reliability Standard IRO-002-4 Requirement R1 states:

    R1. Each Reliability Coordinator shall have data exchange 
capabilities with its Balancing Authorities and Transmission 
Operators, and with other entities it deems necessary, for it to 
perform its Operational Planning Analyses, Real-time monitoring, and 
Real-time Assessments.

    In addition, NERC states that IRO-002-4, Requirement R4 requires 
``each Reliability Coordinator must have monitoring systems . . . over 
a redundant infrastructure.'' \59\
---------------------------------------------------------------------------

    \59\ Id. at 31.
---------------------------------------------------------------------------

Commission Proposal
    73. The Commission agrees that proposed Reliability Standard TOP-
001-3, Requirements R19 and R20 require some form of ``data exchange 
capabilities'' for the transmission operator and balancing authority, 
respectively, and that proposed Reliability Standard TOP-003-3 
addresses the operational data itself needed by the transmission 
operator and balancing authority. In addition, the Commission agrees 
that Reliability Standard IRO-002-4, Requirement R1 requires ``data 
exchange capabilities'' for the reliability coordinator and that 
proposed Reliability Standard IRO-010-2 addresses the operational data 
needed by the reliability coordinator. Further, the Commission agrees 
that proposed Reliability Standard IRO-002-4 Requirement R4 requires a 
redundant infrastructure for system monitoring. However, it is not 
clear whether redundancy and diverse routing of data exchange 
capabilities (or an equally effective alternative that eliminates the 
ambiguity of ``redundancy'' and ``diversely routed'') are adequately 
addressed in proposed Reliability Standards TOP-001-3 and IRO-002-4 for 
the reliability coordinator, transmission operator, and balancing 
authority.
    74. Unlike the approach taken with COM-001-2, which requires 
redundancy and use of a diverse medium through the definitions of 
Interpersonal Communication and Alternative Interpersonal 
Communication, proposed Reliability Standards TOP-001-3 and IRO-002-4 
do not appear to address redundancy and diverse routing of data 
exchange capabilities. While Reliability Standard IRO-002-4, 
Requirement R4 requires reliability coordinators to have a redundant 
infrastructure for system monitoring, it is not clear whether this 
requirement addresses redundancy and diverse routing of other forms of 
data exchange capabilities. For example, a redundant infrastructure 
used for system monitoring could be a subset of the total data exchange 
capabilities used by reliability coordinators and not include redundant 
infrastructure for capabilities such as control of equipment or real-
time assessments. The Commission seeks explanation or clarification 
from NERC whether and how the proposed Reliability Standards in the 
immediate proceeding address redundancy and diverse routing or an 
equally effective alternative to redundancy and diverse routing. 
Further, if NERC or others believe that redundancy and diverse routing 
are not addressed, we seek comment on whether there are associated 
reliability risks of the interconnected transmission network for any 
failure of data exchange capabilities that are not redundant and 
diversely routed.
(ii) Testing of the Alternate or Less Frequently Used Data Exchange 
Capability
NERC Petition
    75. Reliability Standard COM-001-2, Requirement R9 (approved in 
Order No. 808) requires each reliability coordinator, transmission 
operator and balancing authority to test its Alternative Interpersonal 
Communication capability at least once each calendar month and to 
initiate action to repair or designate a replacement Alternative 
Interpersonal Communication capability.\60\
---------------------------------------------------------------------------

    \60\ Reliability Standard COM-001-2, Requirement R9 states: 
``[e]ach Reliability Coordinator, Transmission Operator, and 
Balancing Authority shall test its Alternative Interpersonal 
Communication capability at least once each calendar month. If the 
test is unsuccessful, the responsible entity shall initiate action 
to repair or designate a replacement Alternative Interpersonal 
Communication capability within 2 hours.''
---------------------------------------------------------------------------

    76. As noted above, proposed Reliability Standards TOP-001-3, 
Requirements R19 and R20 and IRO-002-4, Requirement R1 address primary

[[Page 36291]]

data exchange capabilities of the transmission operator, balancing 
authority and reliability coordinator, respectively. However, the 
proposed TOP and IRO Reliability Standards do not appear to address 
testing requirements of alternative or less frequently used data 
exchange capabilities.
Commission Proposal
    77. The Commission is concerned that the proposed TOP and IRO 
Reliability Standards do not appear to address testing requirements for 
alternative or less frequently used mediums for data exchange to ensure 
they would properly function in the event that the primary or more 
frequently used data exchange capabilities failed. The Commission seeks 
comment on whether and how the TOP and IRO Reliability Standards 
address the testing of alternative or less frequently used data 
exchange capabilities for the transmission operator, balancing 
authority and reliability coordinator. If NERC or others believe that 
testing requirements for alternative or less frequently used mediums 
for data exchange is not necessary, we seek comment on why it is not 
necessary.

III. Information Collection Statement

    78. The collection of information contained in this Notice of 
Proposed Rulemaking is subject to review by the Office of Management 
and Budget (OMB) regulations under section 3507(d) of the Paperwork 
Reduction Act of 1995 (PRA).\61\ OMB's regulations require approval of 
certain informational collection requirements imposed by agency 
rules.\62\ Upon approval of a collection(s) of information, OMB will 
assign an OMB control number and an expiration date. Respondents 
subject to the filing requirements of a rule will not be penalized for 
failing to respond to these collections of information unless the 
collections of information display a valid OMB control number.
---------------------------------------------------------------------------

    \61\ 44 U.S.C. 3507(d) (2012).
    \62\ 5 CFR 1320.11 (2014).
---------------------------------------------------------------------------

    79. We solicit comments on the need for this information, whether 
the information will have practical utility, the accuracy of the burden 
estimates, ways to enhance the quality, utility, and clarity of the 
information to be collected or retained, and any suggested methods for 
minimizing respondents' burden, including the use of automated 
information techniques. Specifically, the Commission asks that any 
revised burden or cost estimates submitted by commenters be supported 
by sufficient detail to understand how the estimates are generated.
    Public Reporting Burden: The Commission proposes to approve 
revisions to the Transmission Operations and Interconnection 
Reliability Operations and Coordination Reliability Standards. These 
revisions will impose new or revised, or retire requirements for the 
balancing authority, transmission operator, generator operator, 
distribution provider, generator owner, load-serving entity, 
purchasing-selling entity, transmission service provider, interchange 
authority, transmission owner, reliability coordinator, planning 
coordinator, and transmission planner functions. The Commission based 
its paperwork burden estimates on the NERC compliance registry as of 
May 15, 2015. According to the registry, there are 11 reliability 
coordinators, 99 balancing authorities, 450 distribution providers, 839 
generator operators, 80 purchasing-selling entities, 446 load-serving 
entities, 886 generator owners, 320 transmission owners, 24 interchange 
authorities, 75 transmission service providers, 68 planning 
coordinators, 175 transmission planners and 171 transmission operators. 
The estimates are based on the change in burden from the current 
standards to the proposed. Not all entity types would experience an 
increase in burden, which is reflected by absence of those entities 
from the chart below.
    Collectively, the proposed TOP and IRO Reliability Standards along 
with revised definitions provide for certain enhancements over the 
currently-effective TOP and IRO Reliability Standards.\63\ For example, 
the revised definitions of operational planning analysis and real-time 
assessment, which are applicable to multiple proposed TOP and IRO 
Reliability Standards, were enhanced and provide significant additional 
detail over the currently-effective definitions such as including 
inputs that were identified as contributing to past outages on the bulk 
electric system.\64\ As another example, the new proposed Reliability 
Standard IRO-017-1 establishes operational planning requirements for 
each reliability coordinator to implement an outage coordination 
process for its area that address a reliability gap identified in the 
Southwest Outage Blackout Report and in the Remand NOPR.\65\ The 
Commission estimates the annual reporting burden and cost as follows:
---------------------------------------------------------------------------

    \63\ NERC Petition at 10.
    \64\ NERC Petition at 14.
    \65\ NERC Petition at 17.

       RM15-16-000 (Transmission Operations Reliability Standards, Interconnection Reliability Operations and Coordination Reliability Standards)
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                              Annual
                                                             number of                                         Total annual burden
                                          Number of          responses   Total number  Average burden & cost  hours & total annual   Cost per respondent
                                       respondents \66\         per      of responses    per response \67\            cost                   ($)
                                                            respondent
                                    (1)..................           (2)   (1) * (2) =  (4)..................  (3) * (4) = (5).....  (5) / (1)
                                                                                  (3)
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                        FERC-725A
--------------------------------------------------------------------------------------------------------------------------------------------------------
TOP-001-3.........................  196 (TOP & BA).......             1           196  96 hrs. $6,369.......  18,816 hrs.,          96 hrs., $6,369.
                                                                                                               $1,248,441.
TOP-002-4.........................  196 (TOP & BA).......             1           196  284 hrs., $18,843....  55,664 hrs.,          284 hrs., $18,843.
                                                                                                               $3,693,306.
TOP-003-3.........................  196 (TOP & BA).......             1           196  230 hrs., $15,260....  45,080 hrs.,          230 hrs., $15,260.
                                                                                                               $2,991,058.
                                                          ----------------------------                       ----------------------
    Sub-Total for FERC-725A.......  .....................  ............  ............  .....................  123,252 hrs.,         ....................
                                                                                                               $7,932,806.
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                        FERC-725Z
--------------------------------------------------------------------------------------------------------------------------------------------------------
IRO-001-4 \68\....................  177 (RC & TOP).......             1           177  0 hrs. $0............  0 hrs. $0...........  0 hrs. $0.
IRO-002-4.........................  11 (RC)..............             1            11  24 hrs., $1,592......  264 hrs., $17,516...  24 hrs., $1,592.
IRO-008-2.........................  11 (RC)..............             1            11  228 hrs., $15,127....  2,508 hrs., $166,405  228 hrs., $15,127.
IRO-010-2.........................  11 (RC)..............             1            11  36 hrs., $2,388......  396 hrs., $26,274...  36 hrs., $2,388.
IRO-014-3.........................  11 (RC)..............             1            11  12 hrs., $796........  132 hrs., $8,758....  12 hrs., $796.

[[Page 36292]]

 
IRO-017-1.........................  180 (RC, PC, & TP)...             1           180  218 hrs., $14,464....  39,240 hrs.,          218 hrs., $14,464.
                                                                                                               $2,603,574.
                                                          ----------------------------                       ----------------------
    Sub-Total for FERC-725Z.......  .....................  ............  ............  .....................  42,540 hrs.,          ....................
                                                                                                               $2,822,529.00.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Retirement of current standards     457 (RC, TOP, BA,                 1           457  -223 hrs., -$14,796..  -101,911 hrs., -      -223 hrs., -$14,796.
 currently in FERC-725A.             TSP, LSE, PSE, & IA).                                                     $6,761,794.
                                                          ----------------------------                       ----------------------
    Net Total of NOPR in RM15-16..  .....................  ............  ............  .....................  63,881 hrs,
                                                                                                               $3,993,540.
--------------------------------------------------------------------------------------------------------------------------------------------------------

    Title: FERC-725Z, Mandatory Reliability Standards: IRO Reliability 
Standards, and FERC-725A, Mandatory Reliability Standards for the Bulk-
Power System
---------------------------------------------------------------------------

    \66\ The number of respondents is the number of entities for 
which a change in burden from the current standards to the proposed 
exists, not the total number of entities from the current or 
proposed standards that are applicable.\67\ The estimated hourly 
costs (salary plus benefits) are based on Bureau of Labor Statistics 
(BLS) information, as of April 1, 2015, for an electrical engineer 
($66.35/hour). These figures are available at http://bls.gov/oes/current/naics3_221000.htm#17-0000.\68\ IRO-001-4 is a revised 
standard with no increase in burden.
---------------------------------------------------------------------------

    Action: Proposed Changes to Collections.
    OMB Control Nos: 1902-0276 (FERC-725Z); 1902-0244(FERC-725A)
    Respondents: Business or other for-profit and not-for-profit 
institutions.
    Frequency of Responses: On-going.
    80. Necessity of the Information and Internal review: The 
Commission has reviewed the requirements pertaining to the proposed 
Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-
002-4, IRO-008-2, IRO-010-2, IRO-014-3, and IRO-017-1 and made a 
determination that the proposed requirements of these standards are 
necessary to implement section 215 of the FPA. These requirements 
conform to the Commission's plan for efficient information collection, 
communication and management within the energy industry. The Commission 
has assured itself, by means of its internal review, that there is 
specific, objective support for the burden estimates associated with 
the information requirements.
    81. Interested persons may obtain information on the reporting 
requirements by contacting the Federal Energy Regulatory Commission, 
Office of the Executive Director, 888 First Street NE., Washington, DC 
20426 [Attention: Ellen Brown, email: [email protected], phone: 
(202) 502-8663, fax: (202) 273-0873].
    82. Comments concerning the information collections proposed in 
this NOPR and the associated burden estimates, should be sent to the 
Commission in this docket and may also be sent to the Office of 
Management and Budget, Office of Information and Regulatory Affairs 
[Attention: Desk Officer for the Federal Energy Regulatory Commission]. 
For security reasons, comments should be sent by email to OMB at the 
following email address: [email protected]. Please reference 
OMB Control Nos. 1902-0276 (FERC-725Z) and 1902-0244 (FERC-725A)) in 
your submission.

IV. Environmental Analysis

    83. The Commission is required to prepare an Environmental 
Assessment or an Environmental Impact Statement for any action that may 
have a significant adverse effect on the human environment.\69\ The 
Commission has categorically excluded certain actions from this 
requirement as not having a significant effect on the human 
environment. Included in the exclusion are rules that are clarifying, 
corrective, or procedural or that do not substantially change the 
effect of the regulations being amended.\70\ The actions approved 
herein fall within this categorical exclusion in the Commission's 
regulations.
---------------------------------------------------------------------------

    \69\ Regulations Implementing the National Environmental Policy 
Act of 1969, Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. 
& Regs. Preambles 1986-1990 ] 30,783 (1987).
    \70\ 18 CFR 380.4(a)(2)(ii).
---------------------------------------------------------------------------

V. Regulatory Flexibility Act Analysis

    84. The Regulatory Flexibility Act of 1980 (RFA) generally requires 
a description and analysis of Proposed Rules that will have significant 
economic impact on a substantial number of small entities.\71\ The 
Small Business Administration's (SBA) Office of Size Standards develops 
the numerical definition of a small business.\72\ The SBA revised its 
size standard for electric utilities (effective January 22, 2014) to a 
standard based on the number of employees, including affiliates (from a 
standard based on megawatt hours).\73\ Proposed Reliability Standards 
TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-002-4, IRO-008-2, IRO-
010-2, IRO-014-3, and IRO-017-1 are expected to impose an additional 
burden on 196 entities (reliability coordinators, transmission 
operators, balancing authorities, transmission service providers, and 
planning authorities). Comparison of the applicable entities with the 
Commission's small business data indicates that approximately 82 of 
these entities are small entities that will be affected by the proposed 
Reliability Standards.\74\ As discussed above, proposed Reliability 
Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-002-4, IRO-
008-2, IRO-010-2, IRO-014-3, and IRO-017-1 will serve to enhance 
reliability by imposing mandatory requirements for operations planning, 
system monitoring, real-time actions, coordination between

[[Page 36293]]

applicable entities, and operational reliability data. The Commission 
estimates that each of the small entities to whom the proposed 
Reliability Standards TOP-001-3, TOP-002-4, TOP-003-3, IRO-001-4, IRO-
002-4, IRO-008-2, IRO-010-2, IRO-014-3, and IRO-017-1 applies will 
incur costs of approximately $147,364 (annual ongoing) per entity. The 
Commission does not consider the estimated costs to have a significant 
economic impact on a substantial number of small entities. The 
Commission seeks comment on this proposal.
---------------------------------------------------------------------------

    \71\ 5 U.S.C. 601-12.
    \72\ 13 CFR 121.101 (2013).
    \73\ SBA Final Rule on ``Small Business Size Standards: 
Utilities,'' 78 FR 77343 (Dec. 23, 2013).
    \74\ The Small Business Administration sets the threshold for 
what constitutes a small business. Public utilities may fall under 
one of several different categories, each with a size threshold 
based on the company's number of employees, including affiliates, 
the parent company, and subsidiaries. For the analysis in this NOPR, 
we are using a 750 employee threshold for each affected entity to 
conduct a comprehensive analysis.
---------------------------------------------------------------------------

VI. Comment Procedures

    85. The Commission invites interested persons to submit comments on 
the matters and issues proposed in this notice to be adopted, including 
any related matters or alternative proposals that commenters may wish 
to discuss. Comments are due August 24, 2015. Comments must refer to 
Docket No. RM15-16-000, and must include the commenter's name, the 
organization they represent, if applicable, and their address in their 
comments.
    86. The Commission encourages comments to be filed electronically 
via the eFiling link on the Commission's Web site at http://www.ferc.gov. The Commission accepts most standard word processing 
formats. Documents created electronically using word processing 
software should be filed in native applications or print-to-PDF format 
and not in a scanned format. Commenters filing electronically do not 
need to make a paper filing.
    87. Commenters that are not able to file comments electronically 
must send an original of their comments to: Federal Energy Regulatory 
Commission, Secretary of the Commission, 888 First Street NE., 
Washington, DC 20426.
    88. All comments will be placed in the Commission's public files 
and may be viewed, printed, or downloaded remotely as described in the 
Document Availability section below. Commenters on this proposal are 
not required to serve copies of their comments on other commenters.

VII. Document Availability

    89. In addition to publishing the full text of this document in the 
Federal Register, the Commission provides all interested persons an 
opportunity to view and/or print the contents of this document via the 
Internet through the Commission's Home Page (http://www.ferc.gov) and 
in the Commission's Public Reference Room during normal business hours 
(8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street NE., Room 2A, 
Washington, DC 20426.
    90. From the Commission's Home Page on the Internet, this 
information is available on eLibrary. The full text of this document is 
available on eLibrary in PDF and Microsoft Word format for viewing, 
printing, and/or downloading. To access this document in eLibrary, type 
the docket number of this document, excluding the last three digits, in 
the docket number field.
    91. User assistance is available for eLibrary and the Commission's 
Web site during normal business hours from the Commission's Online 
Support at 202-502-6652 (toll free at 1-866-208-3676) or email at 
[email protected], or the Public Reference Room at (202) 502-
8371, TTY (202) 502-8659. Email the Public Reference Room at 
[email protected].

List of Subjects in 18 CFR Part 40 Reliability standards.

    By direction of the Commission.

    Dated: June 18, 2015.
Kimberly D. Bose,
Secretary.
[FR Doc. 2015-15433 Filed 6-23-15; 8:45 am]
 BILLING CODE 6717-01-P