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