[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)]
[Proposed Rules]
[Pages 36280-36293]
[FR Doc No: 2015-15433]

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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:<PHONE_NUMBER><EMAIL_ADDRESS>Eugene Blick (Technical Information), Office of Electric Reliability,
Federal Energy Regulatory Commission, 888 First Street NE., Washington,
DC 20426, Telephone:<PHONE_NUMBER><EMAIL_ADDRESS>Darrell G. Piatt (Technical Information), Office of Electric
Reliability, Federal Energy Regulatory Commission, 888 First Street
NE., Washington, DC 20426, Telephone:<PHONE_NUMBER>,
<EMAIL_ADDRESS>
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-

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

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

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

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

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

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

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,

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

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

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

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.

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_ADDRESS>phone:
(202) 502-8663, fax:<PHONE_NUMBER>].
    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_ADDRESS>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

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<PHONE_NUMBER> (toll free at 1-866-208-3676) or email at
<EMAIL_ADDRESS>or the Public Reference Room at (202) 502-
8371, TTY<PHONE_NUMBER>. Email the Public Reference Room at
<EMAIL_ADDRESS>
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