[Federal Register Volume 87, Number 122 (Monday, June 27, 2022)]
[Proposed Rules]
[Pages 38020-38044]
[FR Doc No: 2022-13471]

=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

18 CFR Part 40

[Docket No. RM22-10-000]

Transmission System Planning Performance Requirements for Extreme
Weather

AGENCY: Federal Energy Regulatory Commission, Department of Energy.

ACTION: Notice of proposed rulemaking.

-----------------------------------------------------------------------

SUMMARY: The Federal Energy Regulatory Commission proposes to direct
that the North American Electric Reliability Corporation, the
Commission-certified Electric Reliability Organization, submit to the
Commission modifications to Reliability Standard TPL-001-5.1
(Transmission System Planning Performance Requirements) within one year
of the effective date of a final rule in this proceeding to address
reliability concerns pertaining to transmission system planning for
extreme heat and cold weather events that impact the reliable
operations of the Bulk-Power

System. Specifically, we propose to direct NERC to develop
modifications to Reliability Standard TPL-001-5.1 to require:
development of benchmark planning cases based on information such as
major prior extreme heat and cold weather events or future
meteorological projections; planning for extreme heat and cold events
using steady state and transient stability analyses expanded to cover a
range of extreme weather scenarios including the expected resource
mix's availability during extreme weather conditions, and including the
broad area impacts of extreme weather; and corrective action plans that
include mitigation for any instances where performance requirements for
extreme heat and cold events are not met.

DATES: Comments are due August 26, 2022.

ADDRESSES: Comments, identified by docket number, may be filed in the
following ways. Electronic filing through https://www.ferc.gov, is
preferred.
     Electronic Filing: Documents must be filed in acceptable
native applications and print-to-PDF, but not in scanned or picture
format.
     For those unable to file electronically, comments may be
filed by U.S. Postal Service mail or by hand (including courier)
delivery.
    [cir] Mail via U.S. Postal Service only: Addressed to: Federal
Energy Regulatory Commission, Office of the Secretary, 888 First Street
NE, Washington, DC 20426.
    [cir] For delivery via any other carrier (including courier):
Deliver to: Federal Energy Regulatory Commission, Office of the
Secretary, 12225 Wilkins Avenue, Rockville, MD 20852.

FOR FURTHER INFORMATION CONTACT:
Mahmood Mirheydar (Technical Information), Office of Electric
Reliability, Federal Energy Regulatory Commission, 888 First Street NE,
Washington, DC 20426,<PHONE_NUMBER>, [email protected]
Milena Yordanova (Legal Information), Office of the General Counsel,
Federal Energy Regulatory Commission, 888 First Street NE, Washington,
DC 20426,<PHONE_NUMBER>, [email protected]

SUPPLEMENTARY INFORMATION:

Table of Contents

                                                              Paragraph
                                                                 Nos.

I. Introduction............................................            1
II. Background.............................................            8
    A. Legal Authority.....................................            8
    B. Climate Change, Extreme Weather, and Electric System           10
     Reliability Technical Conference......................
    C. Overview of Technical Conference Comments...........           13
    D. Cold Weather Reliability Standards..................           18
    E. Reliability Standard TPL-001-4 (Transmission System            20
     Planning Performance Requirements)....................
III. The Need for Reform...................................           24
    A. Recent Events Show Changes in Weather Patterns                 24
     Resulting in More Extreme Heat and Cold Weather Events
    B. NERC Reliability Standards Do Not Require Planning             37
     To Minimize the Increasing Reliability Risks
     Associated With Anticipated Extreme Heat and Cold
     Weather Events........................................
IV. Proposed Directives....................................           47
    A. Develop Benchmark Planning Cases Based on Major                50
     Prior Extreme Heat and Cold Weather Events............
    B. Transmission System Planning for Extreme Heat and              57
     Cold Weather Events...................................
        1. Steady State and Transient Stability Analyses...           58
        2. Transmission Planning Studies of Wide-Area                 64
         Events............................................
        3. Study Concurrent Generator and Transmission                68
         Outages...........................................
        4. Sensitivity Analysis............................           73
        5. Modifications to the Traditional Planning                  75
         Approach..........................................
        6. Coordination Among Planning Coordinators and               80
         Transmission Planners and Sharing of Study Results
    C. Implement a Corrective Action Plan If Performance              83
     Standards Are Not Met.................................
    D. Other Extreme Weather-Related Events and Issues.....           90
V. Information Collection Statement........................           94
VI. Environmental Assessment...............................           96
VII. Regulatory Flexibility Act Certification..............           97
VIII. Comment Procedures...................................          100
IX. Document Availability..................................          103

I. Introduction

    1. Pursuant to section 215(d)(5) of the Federal Power Act (FPA),\1\
the Commission proposes to direct that the North American Electric
Reliability Corporation (NERC), the Commission-certified Electric
Reliability Organization (ERO), submit modifications to Reliability
Standard TPL-001-5.1 (Transmission System Planning Performance
Requirements) \2\ that address concerns pertaining to transmission
system planning for extreme heat or cold weather events that impact the
reliable operation \3\ of the Bulk-Power System.\4\
---------------------------------------------------------------------------

    \1\ 16 U.S.C 824o(d)(5).
    \2\ Transmission Planning Reliability Standard TPL-001-5, Order
No. 867, 85 FR 8155 (Feb. 13, 2020), 170 FERC ] 61,030, at P 1
(2020) (approving the proposed Reliability Standard TPL-001-5 and
associated implementation plan). N. Am. Elec. Reliability Corp.,
Docket No. RD20-8-000 (June 10, 2020) (delegated order) (approving
Reliability Standard TPL-001-5.1). This NOPR refers to Reliability
Standard TPL-001-5.1 to reflect that the currently effective version
4 of the Reliability Standard will be soon replaced by version 5.1
and any modifications proposed in the NOPR will apply only to TPL-
001-5.1.
    \3\ The FPA defines ``Reliable Operation'' as ``operating the
elements of the Bulk-Power System within equipment and electric
system thermal, voltage, and stability limits so that instability,
uncontrolled separation, or cascading failures of such system will
not occur as a result of a sudden disturbance, including a
cybersecurity incident, or unanticipated failure of system
elements.'' 16 U.S.C. 824o(a)(4).
    \4\ The Bulk-Power System is defined in the FPA as ``facilities
and control systems necessary for operating an interconnected
electric energy transmission network (or any portion thereof), and
electric energy from generating facilities needed to maintain
transmission system reliability. The term does not include
facilities used in the local distribution of electric energy.'' Id.
824o(a)(1).

---------------------------------------------------------------------------

    2. We take this action to address planning challenges associated
with extreme heat and cold weather events, particularly those that
occur during periods when the Bulk-Power System must meet unexpectedly
high demand.\5\ Extreme heat and cold weather events are occurring with
greater frequency, and are projected to occur with even greater
frequency in the future.\6\ As such, the impact of concurrent failures
of Bulk-Power System generators and transmission equipment and the
potential for cascading outages \7\ that may be caused by extreme heat
and cold events should be studied and corrective actions should be
identified and implemented.
---------------------------------------------------------------------------

    \5\ Technical Conference June 1-2, 2021, Climate Change, Extreme
Weather, and Electric System Reliability, Docket No. AD21-13-000
(June 1-2, 2021), June 1, 2021 Tr. 26: 3-7 (Derek Stenclik, Founding
Partner, Telos Energy, Inc.), 31:7-8 (Judy Chang, Undersecretary of
Energy, Massachusetts).
    \6\ Environmental Protection Agency, Climate Change Indicators:
Weather and Climate (May 12, 2021) (EPA Climate Change Indicators),
https://www.epa.gov/climate-indicators/weather-climate (showing an
upward trend in extreme heat and cold weather events).
    \7\ NERC Glossary of Terms Used in Reliability Standards
(Updated March 29, 2022) (NERC Glossary). NERC defines ``cascading''
as, ``The uncontrolled successive loss of System Elements triggered
by an incident at any location. Cascading results in widespread
electric service interruption that cannot be restrained from
sequentially spreading beyond an area predetermined by studies.''
---------------------------------------------------------------------------

    3. At the Commission's June 1-2, 2021 technical conference on
Climate Change, Extreme Weather, and Electric System Reliability, there
was consensus among panelists that planners cannot simply project
historical weather patterns forward to effectively forecast the future,
since climate change has made the use of historical weather
observations no longer representative of future conditions.\8\ For
example, extreme heat in summer in regions like the Pacific northwest
and extreme cold in winter in regions like Texas has increased demand
for electricity at times when historically demand has been low and such
events will likely continue to present challenges in the future.\9\
Therefore, transmission planners and planning coordinators need to
reflect these new realities into their planning processes.\10\
---------------------------------------------------------------------------

    \8\ June 1, 2021 Tr. 30:2-3 (Chang), 31:12-18 (Lisa Barton,
Executive Vice President/Chief Operating Officer, American Electric
Power).
    \9\ June 1, 2021 Tr. 31:1-6 (Chang); June 2, 2021 Tr. 72:8-10
(Amanda Frazier, Senior Vice President of Regulatory Policy, Vista
Corp.); 9:1-5 (Wesley Yeomans, Vice President of Operations, New
York Independent System Operator, Inc. (NYISO)) (noting that in New
York the majority of the extreme conditions were cold weather
related but that there can be heat waves in New York City, and more
heat waves are expected).
    \10\ June 1, 2021 Tr. 35:1-6 (Chang). See also US News,
Blackouts in US Northwest Due to Heat Wave, Deaths Reported (June
29, 2021), https://www.usnews.com/news/business/articles/2021-06-29/rolling-blackouts-for-parts-of-us-northwest-amid-heat-wave; Judah
Cohen et al., Linking Arctic Variability and Change With Extreme
Winter Weather in the United States, 373 Sci. 1116, 1120 (2021),
https://www.science.org/doi/10.1126/science.abi9167 (a study
connecting the 2021 extreme cold weather event in Texas and the
South-central United States to global warming-induced weather
anomalies that are likely to continue to produce severe winter storm
events).
---------------------------------------------------------------------------

    4. Since 2011, the country has experienced at least seven major
extreme heat and cold weather events,\11\ all of which put stress on
the Bulk-Power System, and resulted in some degree of load shed, and in
some cases nearly caused system collapse and uncontrolled blackouts,
which were only avoided via the actions of system operators. Of these,
the four most severe occurred in 2011, 2013, 2018, and 2021. The
extreme weather conditions in the February 2011 Southwest Cold Weather
Event resulted in the acumulative loss of approximately thirty thousand
megawatts of generation resources, causing the Electric Reliability
Council of Texas (ERCOT) to shed load to prevent widespread,
uncontrolled blackouts throughout the entire ERCOT Interconnection. The
September Midwest and Mid-Atlantic 2013 Heatwave Event lasted over
three days and at its peak required a 5,791 MW reduction in load. The
PJM Interconnection, L.L.C. (PJM) analysis during the event indicated a
need for pre-contingency load shed to avoid post-contingency voltage
collapse and a potential cascading outage.\12\ During the January 2018
South Central Cold Weather Event in the Midwest, had the grid operator
lost the single largest contingency of 1,163 MW, there could have been
firm load shedding to maintain system stability. In February of 2021,
the extensive cold in the South Central and Texas regions required a
combined total of 23,418 MW of firm load shed to maintain Bulk-Power
System reliability; it was the largest controlled load shedding event
in U.S. history. During this 2021 Cold Weather Event, had frequency in
Texas remained under its lowest point on February 15, 2021 for an
additional five minutes, approximately 17,000 MW of additional
generation would have tripped, potentially blacking out the entire
ERCOT Interconnection. ERCOT shed firm load in order to maintain
frequency to prevent a collapse of the system.\13\
---------------------------------------------------------------------------

    \11\ This NOPR references the following seven extreme heat and
cold weather events experienced since 2011: (1) February 2011
Southwest Cold Weather Event; (2) September Midwest and Mid-Atlantic
2013 Heatwave Event; (3) January 2014 Polar Vortex Cold Weather
Event; (4) January 2018 South Central Cold Weather Event; (5) August
2020 California Heatwave Event; (6) 2021 Cold Weather Event; (7)
June 2021 the Pacific Northwest Heatwave Event. The naming of the
events is based on the title of the associated reliability report
for each event cited below.
    \12\ PJM, Technical Analysis of Operational Events and Market
Impacts during the September 2013 Heat Wave, at 13 (Dec. 23, 2013),
https://www.yumpu.com/en/document/read/40807126/20131223-technical-analysis-of-operational-events-and-market-impacts-during-the-september-2013-heat-wave.
    \13\ FERC, NERC, Regional Entity Staff Report, The February 2021
Cold Weather Outages in Texas, and the South-Central United States,
at 133 (Nov. 2021) (2021 Cold Weather Event Report).
---------------------------------------------------------------------------

    5. Given the reliability risks associated with extreme heat and
cold weather events, including the potential for widespread blackouts,
we believe it would be appropriate for planning of the transmission
system to account for extreme heat and cold weather events' potential
impact over wide geographical areas, and to consider the changing
resource mix and associated planning assumptions. Reliability Standard
TPL-001-4, the currently effective transmission system planning
standard, was developed to establish transmission system planning
performance requirements that ensure that the Bulk-Power System
operates reliably over a broad spectrum of system conditions and
following a wide range of probable contingencies. Reliability Standard
TPL-001-4, and its successor, TPL-001-5.1, includes provisions for
transmission planners and planning coordinators to study system
performance under extreme events based on their experience. However,
the current standards do not specifically require that a performance
analysis be conducted for extreme heat and cold weather, despite the
fact that such events have demonstrated a potential harm to reliable
operations of the Bulk-Power System, thus leaving a gap in system
planning.
    6. To address this reliability gap, we propose to direct NERC to
develop modifications to Reliability Standard TPL-001-5.1 to require:
(1) development of benchmark planning cases based on information such
as major prior extreme heat and cold weather events or future
meteorological projections; (2) planning for extreme heat and cold
events using steady state and transient stability analyses expanded to
cover a range of extreme weather scenarios including the expected
resource mix's availability during extreme heat and cold weather
conditions, and including the broad area impacts of extreme heat and
cold

weather; and (3) corrective action plans that include mitigation for
any instances where performance requirements for extreme heat and cold
events are not met. In proposing to direct NERC to modify Reliability
Standard TPL-001-5.1, we are not proposing specific requirements.
Instead, we identify concerns that we believe should be addressed. NERC
may propose to develop new or modified Reliability Standards that
address our concerns in an equally efficient and effective manner.
However, NERC's proposal should explain how it addresses the
Commission's concerns.\14\
---------------------------------------------------------------------------

    \14\ See e.g., Mandatory Reliability Standards for the Bulk-
Power Sys., Order No. 693, 72 FR 16416 (Apr. 4, 2007), 118 FERC ]
61,218, at PP 186, 297, order on reh'g, Order No. 693-A, 120 FERC ]
61,053 (2007) (``where the Final Rule identifies a concern and
offers a specific approach to address the concern, we will consider
an equivalent alternative approach provided that the ERO
demonstrates that the alternative will address the Commission's
underlying concern or goal as efficiently and effectively as the
Commission's proposal''); Reliability Standards for Physical Sec.
Measures, 146 FERC ] 61,166, at P 13 (2014).
---------------------------------------------------------------------------

    7. We further propose to direct NERC to submit modifications to
Reliability Standard TPL-001-5.1 within one year of the effective date
of a final rule in this proceeding with compliance obligations for all
proposed new or modified Reliability Standards beginning no later than
12 months from the date of Commission approval of the modified
Reliability Standard. Finally, we invite comments on whether to also
direct NERC to address in Reliability Standard TPL-001-5.1 other
extreme weather-related events.

II. Background

A. Legal Authority

    8. Section 215 of the FPA requires a Commission-certified ERO to
develop mandatory and enforceable Reliability Standards, subject to
Commission review and approval. Reliability Standards may be enforced
by the ERO, subject to Commission oversight, or by the Commission
independently.\15\ Pursuant to section 215 of the FPA, the Commission
established a process to select and certify an ERO,\16\ and
subsequently certified NERC.\17\
---------------------------------------------------------------------------

    \15\ 16 U.S.C. 824o(e).
    \16\ Rules Concerning Certification of the Elec. Reliability
Org. & Procedures for the Establishment, Approval, & Enf't. of Elec.
Reliability Standards, Order No. 672, 71 FR 8662 (Feb. 17, 2006),
114 FERC ] 61,104, order on reh'g, Order No. 672-A, 71 FR 19814
(Apr. 18, 2006), 114 FERC ] 61,328 (2006).
    \17\ N. Am. Elec. Reliability Corp., 116 FERC ] 61,062, order on
reh'g and compliance, 117 FERC ] 61,126 (2006), aff'd sub nom.
Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).
---------------------------------------------------------------------------

    9. Pursuant to section 215(d)(5) of the FPA, the Commission has the
authority, upon its own motion or upon complaint, to order the ERO to
submit to the Commission a proposed Reliability Standard or a
modification to a Reliability Standard that addresses a specific matter
if the Commission considers such a new or modified Reliability Standard
appropriate to carry out section 215 of the FPA.\18\ Further, pursuant
to Sec.  39.5(g) of the Commission's regulations, the Commission may
order a deadline by which the ERO must submit a proposed or modified
Reliability Standard, when ordering the ERO to submit to the Commission
a proposed Reliability Standard that addresses a specific matter.\19\
---------------------------------------------------------------------------

    \18\ 16 U.S.C. 824o(d)(5).
    \19\ 18 CFR 39.5(g) (2021).
---------------------------------------------------------------------------

B. Climate Change, Extreme Weather, and Electric System Reliability
Technical Conference

    10. On March 5, 2021, the Commission announced that staff would
hold a technical conference to discuss issues surrounding the threat to
electric system reliability posed by climate change and extreme weather
events.\20\ The Commission sought to understand, among other things,
whether further action from the Commission is needed to help achieve an
electric system that can withstand, respond to, and recover from
extreme weather events.\21\ On March 15, 2021, the Commission invited
comments on a range of issues related to Bulk-Power System reliability,
including how extreme weather events (e.g., hurricanes, extreme heat,
extreme cold, drought, storms), have impacted the electric system and
whether these events would require changes to the way generation,
transmission, substation, or other facilities are designed, built,
sited, and operated.\22\ The Commission also inquired whether there are
opportunities to improve the NERC Reliability Standards to address
vulnerabilities to Bulk-Power System reliability due to climate change
or extreme weather events in the areas of transmission planning, Bulk-
Power System operations, Bulk-Power System maintenance, and emergency
operations.\23\
---------------------------------------------------------------------------

    \20\ Climate Change, Extreme Weather, and Electric System
Reliability, Notice of Technical Conference, Docket No. AD21-13-000,
at 1 (Mar. 5, 2021).
    \21\ Id. at 2.
    \22\ Supplemental Notice of Technical Conference, Docket No.
AD21-13-000, at 1, 3 (Mar. 15, 2021).
    \23\ Id. at 5.
---------------------------------------------------------------------------

    11. On June 1 and 2, 2021, the Commission convened a staff-led
technical conference on Climate Change, Extreme Weather, and Electric
System Reliability focused on: (1) ways in which planning practices
might evolve to achieve outcomes that reflect consumer needs for
reliable electricity in the face of patterns of climate change and
extreme weather events that diverge from historical trends; (2) best
practices throughout the industry for assessing the risks posed by
climate change and extreme weather and developing cost-effective
mitigation; (3) ways in which existing operating practices may
necessitate updated techniques and approaches in light of increasing
instances of extreme weather and longer-term threats posed by climate
change; (4) best practices for the recovery period following an extreme
weather event; and (5) the role that coordination and cooperation
across jurisdictions could play in planning, operations, and recovery
practices to address climate change and extreme weather events.\24\
---------------------------------------------------------------------------

    \24\ Supplemental Notice of Technical Conference, Docket No.
AD21-13-000, at 1, 3 (May 27, 2021) (attaching agenda).
---------------------------------------------------------------------------

    12. Following the conference, the Commission invited comments on
specific topics discussed at the conference, such as the possibility
of: incorporating probabilistic methods into local transmission
planning and/or regional transmission planning; coordinating transfers
across the seams between Regional Transmission Organizations; the
possibility of modifying transmission planning requirements established
under Reliability Standard TPL-001 to better assess and mitigate the
risk of extreme weather events and associated common mode failures;
additional changes to the NERC Reliability Standards to address the
risk of extreme weather events; and among other topics, whether target
levels of interregional transfer capacity could help facilitate more
effective development of interregional transmission projects to help
ensure reliability and resilience during extreme weather events.\25\
---------------------------------------------------------------------------

    \25\ Notice Inviting Post-Technical Conference Comments, Docket
No. AD21-13-000, at 3, 5 (Aug. 11, 2021).
---------------------------------------------------------------------------

C. Overview of Technical Conference Comments

    13. Commenters submitted more than 50 sets of pre-conference and 20
post-conference comments on a wide range of issues, including the types
of extreme weather events experienced,\26\ and the range of mitigating
measures that could be taken to address the specific risks of climate
change in various regions of the country. Commenters expressed

concerns that the impacts of climate change are anticipated to affect
the electric system in multiple, compounding, and synergistic ways.\27\
Generally, industry experts agreed that extreme weather events are
likely to become more severe and frequent in the future,\28\ and
acknowledged the challenges associated with planning for extreme
events, including shifting scheduled maintenance, canceling or
recalling transmission and generation assets from scheduled maintenance
to meet demand under unexpected circumstances.\29\
---------------------------------------------------------------------------

    \26\ See, e.g., California Independent System Operator
Corporation (CAISO) Pre-Conference Comments at 3.
    \27\ Environmental Defense Fund and Columbia Law School's Sabin
Center for Climate Change Law Pre-Conference Comments at 4.
    \28\ CAISO Pre-Conference Comments at 1-3; California Public
Utilities Commission Pre-Conference Comments at 4; Oregon Public
Utilities Commission Pre-Conference Comments at 2-3; NYISO Pre-
Conference Comments at 4.
    \29\ June 2, 2021, Tr. at 21-23 (Wesley Yeomans, Vice President
of Operations, NYISO).
---------------------------------------------------------------------------

    14. Some commenters discussed potential changes to the NERC
Reliability Standards to address planning and operational preparedness
for energy adequacy risks,\30\ contingencies related to extreme weather
events, and wide-area transmission planning and development
challenges,\31\ among others. In addition, participants advocated for
planning that reflects the new climate-change driven conditions, as the
expected impacts of climate change ``need to be baked into the rest of
your planning and development activities.'' \32\
---------------------------------------------------------------------------

    \30\ ISO-New England Inc. Pre-Conference Comments at 10.
    \31\ Midcontinent Independent System Operator (MISO) Pre-
Conference Comments at 4-5, 14-17.
    \32\ June 1, 2021 Tr. 136:18-21 (Neil Millar, Vice President,
Transmission Planning & Infrastructure Development, CAISO).
---------------------------------------------------------------------------

    15. Pacific Gas and Electric Company states that Reliability
Standard TPL-001-4 already requires transmission planners to evaluate
extreme events, but could benefit from providing further clarity on the
events to consider, as well as the extent to which investments can be
made to the grid to mitigate the identified issues for the given event
evaluated.\33\
---------------------------------------------------------------------------

    \33\ Pacific Gas and Electric Company Pre-Conference Comments at
19-20.
---------------------------------------------------------------------------

    16. Post-conference comments also addressed more directly the
potential reliability gaps in the existing set of Reliability
Standards, including Reliability Standard TPL-001-4. For example, MISO
argues that while current Commission-approved Reliability Standards
provide for the assessment of the impacts of extreme events that may
include climate-driven weather events, they do not include requirements
to mitigate consequences from such events.\34\ Similarly, PJM states
that Reliability Standard TPL-001-4 should be modified to specifically
account for extreme weather events by mandating regional extreme
weather design standards for transmission and generation operating
criteria.\35\ CAISO also states that Reliability Standard TPL-001 may
not serve as the best means to assess the threat and risk of extreme
weather events.\36\
---------------------------------------------------------------------------

    \34\ MISO Post-Conference Comments at 20.
    \35\ PJM Post-Conference Comments at 21.
    \36\ CAISO Post-Conference Comments at 10.
---------------------------------------------------------------------------

    17. NERC agrees that with proper planning, including consideration
not only of historic temperature averages but also consideration of
conditions during extreme weather events and the linkage between
critical infrastructures, the risks associated with extreme weather and
the changing resource mix can be mitigated.\37\ NERC agrees that
enhancements to the Reliability Standards could be beneficial. Some
examples of potential enhancements include requiring reliability
coordinators, balancing authorities, or planning coordinators to
determine the temperature to which plants in their respective areas
must weatherize; requiring reliability coordinators or balancing
authorities to develop seasonal emergency energy management plans, to
address conditions such as wildfires, extreme hot and cold
temperatures, and severe storms (i.e., hurricanes); requiring
reliability coordinators to develop a rolling three week emergency
energy management plan; and requiring balancing authorities to prepare
a seasonal energy management plan based on regional extreme weather
scenarios identified in NERC's seasonal assessments.\38\
---------------------------------------------------------------------------

    \37\ NERC Pre-Conference Comments at 6.
    \38\ Id. at 15-16; NERC Post-Conference Comments at 5-7
(explaining that additional modifications to the Reliability
Standards may be appropriate as the resource mix is transformed to
one that is more sensitive to severe weather conditions, as some
types of severe weather events or conditions could result in the
loss of a substantial amount of resources due to fuel concerns).
---------------------------------------------------------------------------

D. Cold Weather Reliability Standards

    18. NERC and the Commission have begun to address the effects of
extreme cold weather on generating units, specifically focusing on
improved performance of generating units during cold weather
conditions. On August 24, 2021, the Commission approved revised
Reliability Standards to address some of the reliability risks posed by
extreme cold weather.\39\ Effective April 2023, those Reliability
Standards will, inter alia, require generators to implement plans for
cold weather preparedness and require the balancing authority,
transmission operator, and reliability coordinator to plan and operate
the grid reliably during cold weather conditions by requiring the
exchange of certain information related to the generator's capability
to operate under such conditions.\40\
---------------------------------------------------------------------------

    \39\ N. Am. Elec. Reliability Corp., 176 FERC ] 61,119 (2021).
The Commission approved proposed Reliability Standards EOP-011-2
(Emergency Preparedness and Operations); IRO-010-4 (Reliability
Coordinator Data Specification and Collection); and TOP-003-5
(Operational Reliability Data) (collectively, the Cold Weather
Reliability Standards).
    \40\ Id. P 3.
---------------------------------------------------------------------------

    19. The proposed improvements to transmission planning discussed in
this NOPR and the requirements in the Cold Weather Reliability
Standards both work together to mitigate the reliability impact of
extreme weather events, such as the 2021 Cold Weather Event in Texas
and South-Central United States. To ensure reliability, transmission
planning should be considered in the context of generators' performance
and availability during extreme heat and cold events.

E. Reliability Standard TPL-001-4 (Transmission System Planning
Performance Requirements)

    20. Transmission system planning refers to the evaluation of future
transmission system performance and creation of corrective action plans
that includes mitigation for extreme heat and cold events to remedy
identified deficiencies.\41\ The planning horizon associated with
transmission system planning covers near term (one to five years),
long-term (six to 10 years), and beyond.\42\
---------------------------------------------------------------------------

    \41\ NERC Glossary defines ``Planning Assessment'' as
``documented evaluation of future Transmission System performance
and Corrective Action Plans to remedy identified deficiencies.''
    \42\ Id.
---------------------------------------------------------------------------

    21. Reliability Standard TPL-001-4, applicable to planning
coordinators and transmission planners, establishes minimum
transmission system planning performance requirements within the
identified planning horizon to plan a Bulk-Power System that will
operate reliably over a broad spectrum of system conditions and follow
a wide range of probable contingencies.\43\ Under Reliability Standard
TPL-001-4, and Reliability Standard TPL-001-5.1, Requirement R2, each
transmission planner and planning coordinator must prepare an annual
planning assessment of its portion of the Bulk-Power System based on
current or qualified past studies, document its assumptions, and
document the summarized results of the

steady state analyses, short circuit analyses, and stability
analyses.\44\ This planning assessment is required for both near-term
and long-term transmission planning horizons.\45\
---------------------------------------------------------------------------

    \43\ Reliability Standard TPL-001-4, Purpose.
    \44\ Reliability Standard TPL-001-4/5.1, Requirement 2. Further,
steady-state analyses are a snapshot in time where load and system
conditions (e.g., generators, lines, facilities) are modeled as
constant (not as changing over time). The analysis will either solve
or diverge (not solved). See IEEE, Transactions on Power Systems,
Vol. 19, No. 2, (May 2004) (power system stability is the ability of
an electric power system, for a given initial operating condition,
to regain a state of operating equilibrium after being subjected to
a physical disturbance, with most system variables bounded so that
practically the entire system remains intact); see also, Kundur,
Prabha, Power System Stability and Control, McGraw Hill, at 26
(1994).
    \45\ See Reliability Standard TPL-001-4, Requirement 2.1 (Near-
Term Transmission Planning Horizon) and Requirement R.2.2 (Long-Term
Transmission Planning Horizon).
---------------------------------------------------------------------------

    22. Requirements R3 and R4 of Reliability Standard TPL-001-4
require in part that planning coordinators and transmission planners
conduct steady state and stability analyses of pre-specified extreme
events and evaluate possible actions designed to reduce the likelihood
or mitigate the consequences and adverse impacts of the event(s), if
the analysis concludes that the pre-selected extreme events cause
cascading outages.
    23. Table 1 of Reliability Standard TPL-001-4 includes a list of
examples of planning events for which specific studies may be required,
generally, based on the entity's own evaluation that such an event
could occur within its operating area. Section 3.a of Table-1, Steady
State & Stability Performance Extreme Events, states that steady state
analysis should be conducted for wide-area events affecting the
transmission system based on system configuration and how it can be
affected by events such as wildfires and severe weather (e.g.,
hurricanes and tornadoes). In addition, section 3.b serves as a catch-
all provision, stating that steady state analysis should be performed
for ``other events based upon operating experience that may result in
wide-area disturbances.''

III. The Need for Reform

A. Recent Events Show Changes in Weather Patterns Resulting in More
Extreme Heat and Cold Weather Events

    24. Recent extreme weather-related events that spread across large
portions of the country over the past decade demonstrate the challenges
to transmission planning from extreme heat and cold weather patterns.
Since 2011, the country has experienced at least seven major extreme
heat and cold weather events; of these, four neared system collapse
(2011, 2013, 2018, and 2021 extreme cold weather events) if the
operators had not acted to shed load. The remaining three events (2014,
2020, 2021 extreme heat weather events) resulted in generation loss and
varying degrees of load shedding.
    25. These extreme heat and cold events demonstrate a risk to
reliable operation of the Bulk-Power System. Below we discuss in detail
how recent extreme cold and heat events have demonstrated such risks,
including resource availability, limitations of the transmission system
locally and over a wide area, and limitations of interregional transfer
capabilities.
    26. From February 1 to February 4, 2011, the southwest region of
the United States experienced unusually cold and windy weather,
referred to as the February 2011 Southwest Cold Weather Event. Low
temperatures during the period were in the teens for five consecutive
mornings and there were many sustained hours of below freezing
temperatures throughout Texas and New Mexico. Low temperatures in
Albuquerque, New Mexico ranged from 7 degrees Fahrenheit to minus seven
degrees Fahrenheit over the period, compared to a normal range of 51 to
26 degrees Fahrenheit. Temperatures in Dallas, Texas ranged from 19
degrees to 14 degrees Fahrenheit, compared to a normal range of 60 to
mid-to-upper 30s degrees Fahrenheit. Many cities in the region did not
see temperatures above freezing until February 4, 2011. In addition,
sustained high winds of over 20 mph produced severe wind chill factors.
The extreme weather conditions resulted in the loss of a significant
number of generators which occurred almost simultaneously, causing
ERCOT to shed load to prevent widespread, uncontrolled blackouts
throughout the entire ERCOT Interconnection.\46\ As a result,
approximately 4.4 million electric customers were affected over the
course of the event.\47\
---------------------------------------------------------------------------

    \46\ FERC and NERC Staff Report, Outages and Curtailments During
the Southwest Cold Weather Event of February 1-5, 2011, at 7 (Aug.
2011), https://www.ferc.gov/sites/default/files/2020-05/ReportontheSouthwestColdWeatherEventfromFebruary2011Report.pdf. Load
shedding may be used to reduce an overload condition (such as when
thermal limits on a transmission line are exceeded), to recover from
an under-frequency condition, or to return voltage to a normal
level.
    \47\ Id. at 1.
---------------------------------------------------------------------------

    27. Two years later, the Midwest and mid-Atlantic experienced
unseasonably hot weather from September 9 through September 11, 2013,
which led to emergency conditions in the PJM service area. During this
period, temperatures ranged from the upper 80s into the 90s Fahrenheit,
which in some areas like Cleveland translated into conditions of over
20 degrees above normal.\48\ As a result, demand for electricity
reached an all-time high for September within PJM's footprint.
Transmission owners tend to schedule maintenance outages during the
fall and spring, increasing the risk of system stress during periods of
weather-related high energy demand, such as occurred in September 2013.
PJM implemented controlled outages in a few constrained areas to
prevent uncontrolled blackouts over larger areas that could have
affected many more customers.\49\ In preparation for another day of
unseasonably high use of electricity, on September 11, PJM called for
voluntary demand response \50\ across much of its service area,
resulting in a 6,048 MW reduction in electricity demand, the largest
amount of demand response PJM had ever received. During the entire
event PJM shed 157 MW of load affecting approximately 45,000
customers.\51\
---------------------------------------------------------------------------

    \48\ PJM, Technical Analysis of Operational Events and Market
Impacts during the September 2013 Heat Wave, at 7, Figure 1, RTO
Temperatures (Dec. 23, 2013) (PJM Heat Wave Analysis), https://www.yumpu.com/en/document/read/40807126/20131223-technical-analysis-of-operational-events-and-market-impacts-during-the-september-2013-heat-wave.
    \49\ Id. at 4.
    \50\ Under demand response programs, retail customers volunteer
and are paid to reduce their electricity use when requested.
    \51\ PJM Heat Wave Analysis at 5.
---------------------------------------------------------------------------

    28. Another extreme event occurred the following year, in early
January 2014, when the Midwest, south central, and east coast regions
of the country experienced an extreme cold weather event known as the
polar vortex, referred to as the January 2014 Polar Vortex Cold Weather
Event, where extreme cold resulted in temperatures 20 to 30 degrees
Fahrenheit below normal.\52\ Some areas faced days that were 35 degrees
Fahrenheit or more below their normal temperatures. These extreme
temperatures resulted in record high electrical demand on January 6 and
again on January 7, 2014. During the January 2014 Polar Vortex Cold
Weather Event, the cold weather increased demand for natural gas, which
caused a significant amount of gas-fired generation to become
unavailable due to unavailability of the non-firm gas purchases they
relied on. The cold weather and issues from fuel combined for over
35,000 MW of generator outages during the height of the polar vortex

weather conditions.\53\ By employing communication tools, interruptible
load, demand-side management tools, and voltage reduction, balancing
authorities and load serving entities were mostly able to maintain
their operating reserve margins and serve firm load and only one
balancing authority was required to shed 300 MW of firm load. Many
outages, including a number of those in the southeastern United States,
were the result of temperatures that fell below a plant's design
basis.\54\
---------------------------------------------------------------------------

    \52\ NERC, Polar Vortex Review (Sept. 2014) (Polar Vortex
Review), https://www.nerc.com/pa/rrm/January%202014%20Polar%20Vortex%20Review/Polar_Vortex_Review_29_Sept_2014_Final.pdf.
    \53\ Id. at 4.
    \54\ Id. at iii.
---------------------------------------------------------------------------

    29. Further, in mid-January 2018, a large area of the south-central
region of the United States saw unusually cold weather, with
temperatures dropping from about five degrees Fahrenheit to as much as
27 degrees Fahrenheit below the normal daily minimums. Texas,
Louisiana, Arkansas, Oklahoma, Mississippi, Missouri, and other
neighboring states were all affected by the extreme cold weather, which
lasted from January 12 to January 19, 2018, known as the January 2018
South Central Cold Weather Event.\55\ The reliability coordinators in
MISO did not anticipate the numerous mitigation measures they would
need to take to maintain Bulk-Power System reliability at the peak of
the event (January 17, 2018), including transmission loading relief,
transmission reconfiguration, and the need to be prepared to shed firm
load in the event of an additional contingency in MISO South of 1,163
MW.\56\ Although the system remained stable on January 17, 2018, this
event represented a near miss of cascading outages.
---------------------------------------------------------------------------

    \55\ FERC and NERC Staff Report, The South Central United States
Cold Weather Bulk Electric System Event of January 17, 2018, at 6-8
(July 2019) (2018 Cold Weather Event Report), https://www.nerc.com/pa/rrm/ea/Documents/South_Central_Cold_Weather_Event_FERC-NERC-Report_20190718.pdf.
    \56\ Id. at 12.
---------------------------------------------------------------------------

    30. Two years later, the western United States suffered another
intense and prolonged heatwave affecting many areas across the Western
Interconnection during a five-day period from August 14 through August
19, 2020 (August 2020 California Heatwave Event). With temperatures
between 15- and 30-degrees Fahrenheit above normal, many areas in the
western parts of the country broke daily heat records. Some areas in
the southwest posted record temperatures: Phoenix, Arizona reached a
record 115 degrees Fahrenheit. Even cities located further north had
similar temperature spikes, with Portland, Oregon, registering 102
degrees Fahrenheit. Because of these high temperatures, electricity
demand in the Western Interconnection reached a record high on August
18, 2020.\57\ On August 14 and 15, CAISO shed firm load to maintain the
operating reserves needed to maintain the reliability and security of
the Bulk-Power System. Several other entities reported being one
contingency away from needing to shed load as well.\58\
---------------------------------------------------------------------------

    \57\ Western Electricity Coordinating Council, August 2020
Heatwave Event Analysis Report, at 1-2 (Mar. 19, 2021) (2020 Heat
Event Report), https://www.wecc.org/Reliability/August%202020%20Heatwave%20Event%20Report.pdf.
    \58\ Id. at 1.
---------------------------------------------------------------------------

    31. More recently, in February 2021, Texas and the South-Central
United States experienced the 2021 Cold Weather Event, the fourth cold-
weather-related event in the last ten years to jeopardize Bulk-Power
System reliability. Temperatures began to drop below freezing in Texas
and the Southwest Power Pool, Inc. (SPP) region on February 8, 2021,
but temperatures dropped even lower during the week of February 14,
reaching their nadir on February 15 and 16, 2021. Daily low
temperatures for February 15th were as much as 40 to 50 degrees lower
than average daily minimum temperatures for that day. In addition to
the arctic air, the cold front brought periods of freezing
precipitation and snow to large parts of Texas and the South Central
region, starting February 10, and extending into the week of February
14, 2021.\59\
---------------------------------------------------------------------------

    \59\ 2021 Cold Weather Event Report at 9, 12-13.
---------------------------------------------------------------------------

    32. This was the most devastating cold-weather-related event in the
last 10 years to impact Bulk-Power System reliability, with a combined
23,418 MW of manual firm load shed, the largest controlled firm load
shed event in U.S. history.\60\ The unplanned generation outages that
escalated during the event, 65,622 MW, were more than four times as
large as the previous largest event, in 2011 (14,702 MW).\61\ ERCOT
faced the greatest challenge due to the magnitude of unplanned
generating unit outages in its area, coupled with its limited ability
to import power to help offset generation shortfalls. Notably, the
entire ERCOT Interconnection has a maximum total import limitation of
only 1,220 MW, which limited ERCOT's ability to import electricity to
meet demand.\62\ In Texas alone, this event resulted in more than 4.5
million people losing power, cost the Texas economy between $80 to $130
billion, and caused at least 210 deaths.\63\ Had frequency in Texas
remained under its lowest point for an additional five minutes during
the peak of the event, approximately 17,000 MW of additional generation
would have tripped, potentially blacking out the entire ERCOT
Interconnection. In contrast to ERCOT, some regions, such as MISO and
SPP, had the ability to import power from the east, where weather
conditions were less severe, to make up for a large portion of their
generation shortfalls during the event. For example, PJM was exporting
an unprecedented amount of electricity into MISO and SPP, reaching over
15,700 MW of interregional transfers on February 15, 2021.\64\
---------------------------------------------------------------------------

    \60\ Id. at 9.
    \61\ Id.
    \62\ Id. at 127 n.197.
    \63\ Id. at 10.
    \64\ PJM Post-Conference Comments at 17-18; 2021 Cold Weather
Event Report at 229 n. 355. Interregional transfer capability allows
an entity in one region with available energy to assist one or more
entities in another region that is experiencing an energy shortfall
due to the extreme weather event.
---------------------------------------------------------------------------

    33. Finally, in June 2021 the Pacific Northwest experienced another
record-breaking heat wave, referred to as June 2021 the Pacific
Northwest Heatwave. During the event, Seattle set an all-time record
high temperature of 104 degrees Fahrenheit on June 27, 2021, while
Portland had two back-to-back all-time records, on June 26 and 27,
2021, where temperatures reached 108- and 112-degrees Fahrenheit,
respectively.\65\ While such events are still rare in today's climate,
researchers believe such events are likely to become more common in the
future.\66\
---------------------------------------------------------------------------

    \65\ Climate Signals, Northwest Pacific Heat Wave June 2021
(Oct. 2021), https://www.climatesignals.org/events/northwest-pacific-heat-wave-june-2021#/more.
    \66\ Sjoukje Y. Philip, Sarah F. Kew et al., Rapid attribution
analysis of the extraordinary heatwave on the Pacific Coast of the
US and Canada (June 2021), at 199, https://www.worldweatherattribution.org/wp-content/uploads/NW-US-extreme-heat-2021-scientific-report-WWA.pdf.
---------------------------------------------------------------------------

    34. While these wide-area extreme events may not occur every year,
their frequency and magnitude are expected to increase. NOAA's data and
analyses show an increasing trend in extreme heat and cold events,\67\
and the U.S. Environmental Protection Agency climate change indicators
also show upward trends in heatwave frequency, duration, and
intensity.\68\ NOAA states that climate change is also driving more
compound events, which are multiple extreme events occurring
simultaneously or successively, such as concurrent heat waves and
droughts,

and more extreme heat conditions in cities.\69\
---------------------------------------------------------------------------

    \67\ NOAA website, Climate Data Online (NOAA website, Climate
Data Online), https://www.ncdc.noaa.gov/cdo-web/.
    \68\ EPA Climate Change Indicators.
    \69\ NOAA website, Climate Data Online.
---------------------------------------------------------------------------

    35. With respect to extreme cold, NOAA explains that accelerated
arctic warming is likely contributing to the increasing frequency of
Arctic polar vortex-stretching events that deliver extreme cold to the
United States and Canada, including the winter 2021 Texas cold
wave.\70\ NOAA climate data indicates that the occurrence of
significant cold weather events is trending higher nationwide.\71\
---------------------------------------------------------------------------

    \70\ NOAA, Climate Program Office, Research Links Extreme Cold
Weather in the United States to Arctic Warming, https://cpo.noaa.gov/Interagency-Programs/NIHHIS/ArtMID/6409/ArticleID/2369/Research-Links-Extreme-Cold-Weather-in-the-United-States-to-Arctic-Warming?msclkid=f9ad03bcc7c911ecba22ebf3e1ead5d9.
    \71\ NOAA website, Climate Data Online.
---------------------------------------------------------------------------

    36. As discussed, the recent extreme heat and cold events have had
a significant impact on the reliability of the Bulk-Power System.
However, the potential impact of widespread extreme heat and cold
events on the reliability of the Bulk-Power System can be modeled and
studied in advance as part of near-term and long-term transmission
system planning. Transmission planners could use the studies to develop
transmission system operational strategies or corrective action plans
with mitigation that could be deployed prior to and in preparation for
extreme heat and cold events. Examples of such corrective action plans
include planning for additional contingency reserves or implementing
new energy efficiency programs to decrease load,\72\ planning for
additional interregional transfer capability, transmission switching/
reconfiguration, or adjusting transmission and generation maintenance
outages based on longer-lead forecasts. Therefore, given the urgency of
addressing the negative impact of extreme weather on the reliability of
the Bulk-Power System, the proposed directives to NERC in this NOPR aim
to improve system planning specifically for extreme heat and cold
weather events.
---------------------------------------------------------------------------

    \72\ Contingency reserves would only contribute to a corrective
action plan to the extent that they are expected to perform during
the applicable modeled extreme weather event(s) and thereby
contribute to meeting the applicable performance criteria.
Accordingly, if for instance, extreme cold is anticipated to cause
fuel unavailability for the applicable area, a corrective action
plan would need to account for such limitations.
---------------------------------------------------------------------------

B. NERC Reliability Standards Do Not Require Planning To Minimize the
Increasing Reliability Risks Associated With Anticipated Extreme Heat
and Cold Weather Events

    37. The currently effective Reliability Standard TPL-001-4 and the
to-be-effective TPL-001-5.1, Requirements R3 and R4 require steady
state and stability analyses to be performed for extreme events
``listed in Table 1 that are expected to produce more severe system
impacts.'' Table 1, Steady State & Stability Performance Extreme
Events, under the Steady State analysis, sections 3.a.iii and 3.a.iv
lists wildfires and severe weather (e.g., hurricanes and tornadoes) as
potential events that could be studied. However, neither Requirements
R3 or R4, nor the associated Table 1 specifically require steady state
analyses for extreme heat and cold conditions to be completed as part
of the transmission planner's or planning coordinator's planning
assessment. Finally, Table 1, provisions 2.f (stability) and 3.b
(steady state), require the responsible entities to study events based
on operating experience that may result in a wide-area disturbance, but
they do not specify the study of extreme heat or cold conditions.
    38. System planning measures alone will not eliminate the
reliability risk associated with extreme heat and cold events. However,
system planning will limit the impact of such events and reduce the
risk to the reliability of the Bulk-Power System, which prior events
demonstrate is significant.
    39. The country experienced wide-spread cold weather events in
2011, 2014, 2018, and 2021. With the exception of the January 2018
South Central Cold Weather Event, planned and unplanned generating unit
outages caused energy emergencies and triggered the need for firm load
shed. As evidenced by the last cold weather event in 2021, where
generation loss and loss of load were the most extreme, it becomes
increasingly more important to consider changes in transmission
planning. Although during the January 2018 South Central Cold Weather
Event the system remained stable, the 2018 Cold Weather Event Report
addressing this specific event recommended that MISO and other
reliability coordinators perform voltage stability analyses when under
similarly constrained conditions, benchmark planning and operations
models against actual events that strained the system, perform periodic
impact studies to identify which elements in the adjacent reliability
coordinators' systems have the most impact on their own systems, and
perform drills with entities involved in load shedding to prepare to
execute load-shedding for maintaining reserves while at the same time
alleviating severe transmission conditions.\73\
---------------------------------------------------------------------------

    \73\ 2018 Cold Weather Event Report at 12-13.
---------------------------------------------------------------------------

    40. Having the necessary data and performing modeling in advance of
extreme cold temperatures could allow transmission planners and
operators to assess the potential impact of an event to identify
corrective actions that could be taken well in advance of the event.
Such action could include ensuring generators have winterized their
equipment, scheduling fewer planned outages of generating units and
transmission lines, and endeavoring to maintain transmission ties
intact to: (1) permit maximum transfers to an area experiencing a
deficiency in generation; (2) minimize the possibility of cascading
outages; and (3) assist in restoring operation to normal.\74\ While
these corrective action plans may not fully mitigate the potential
impact of these events, they could minimize the impact and reduce
system restoration time.
---------------------------------------------------------------------------

    \74\ ERCOT, Nodal Operating Guide, at 137 (Jan. 1, 2022),
https://www.ercot.com/files/docs/2021/12/21/Nodal%20Operating%20Guide.pdf.
---------------------------------------------------------------------------

    41. Past experience can inform how steady state and stability
analyses should model transmission and generator outages, including
availability of wind, natural gas, and other resources sensitive to
extreme cold conditions. For example, the February 2021 cold weather-
related outages in Texas and the south-central United States caused
4,125 outages/derates of generating units (i.e., approximately 456 GW
during event in total event area). Of the total generation losses, 59%
were gas-fired generating units due to fuel issues \75\ and a pipeline
equipment failure, and 27% were wind generation due to blade icing.\76\
---------------------------------------------------------------------------

    \75\ Fuel issues included 87% natural gas fuel supply issues
(decreased natural gas production, terms and conditions of natural
gas commodity and transportation contracts, low pipeline pressure
and other issues) and 13% other fuel issues.
    \76\ 2021 Cold Weather Event Report at 163.
---------------------------------------------------------------------------

    42. While heat events have different planning challenges, they also
present a serious risk to the Bulk-Power System and often require
operators to shed load to maintain system stability. The recent extreme
heat events resulted in a variety of reliability issues such as
controlled rolling blackouts and transmission congestion. During the
August 2020 California Heatwave Event, wind production was low during
the evenings, and solar generation was declining during the peak demand
hours, leading to reserve shortages.

Similar to Texas, California relies on wind and solar generation to
meet normal peak day demand, but wind and solar generation were largely
unavailable. Steady state and stability analyses of study cases modeled
to reflect past extreme conditions as well as modeling of availability
of generation resources during extreme heat conditions in the planning
process could have better prepared the transmission operators for such
conditions.
    43. Past extreme heat and cold events discussed above demonstrate
the importance of assessing resource and reserve requirements under
extreme heat and cold weather conditions. Developing and using extreme
heat and cold weather scenarios in planning analyses will help to
identify the potential risks that extreme events may pose to the Bulk-
Power System. Based on the risks identified, appropriate mitigations or
corrective action plans such as requiring additional reserves and
transfer capability can be developed and deployed to address the risks
and specify what should be planned for the longer term to ensure the
availability of electricity in real time.
    44. NERC recognizes that extreme events present a reliability risk
and there are opportunities to improve the transmission planning
processes. Following the 2021 extreme cold weather event, NERC issued a
level 2 NERC Alert to industry on cold weather preparations for extreme
weather events with five recommendations to assist reliability
coordinators, balancing authorities, transmission operators, and
generator owners in preparing for the winter season. NERC's level 2
Alerts recommend but do not mandate registered entities to take
specific actions.\77\ The Alert recommended seasonal operating plans
for the upcoming winter season, which would include plans to utilize
additional transmission capacity, consideration of the import
capability of the system and resource availability constraints on
external systems, and load forecasting practices that consider extreme
events, among other recommendations.\78\ The NERC Alert did not include
any recommendations concerning long-term transmission planning.
---------------------------------------------------------------------------

    \77\ NERC, About Alerts, https://www.nerc.com/pa/rrm/bpsa/Pages/About-Alerts.aspx.
    \78\ NERC, Alert R-2021-08-18-01 Extreme Cold Weather Events
(Aug. 18, 2021), https://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/NERC%20Alert%20R-2021-08-18-01%20Extreme%20Cold%20Weather%20Events.pdf.
---------------------------------------------------------------------------

    45. In addition, in 2021 NERC formed the Energy Reliability
Assessment Task Force (ERATF) to assess risks associated with unassured
energy supplies, including the inconsistent output from variable
renewable energy resources, fuel location, and volatility in forecasted
load, which can result in insufficient amounts of energy on the system
to serve electrical demand.\79\ The ERATF uses resource adequacy models
to address energy availability concerns related to the operations
planning horizon (i.e., one day to one year) and near-term planning
horizon (i.e., one to five years).\80\ In December of 2021, the ERATF
prepared a draft Standard Authorization Request (SAR) and based on the
comments to the SAR, two SARs were created: a planning SAR and an
operations/operations planning SAR, aiming to create or modify NERC
Reliability Standards across the operations/operational planning time
horizon and the planning time horizon. To discuss this latest update
with industry members, NERC held an informational Webinar on May 19,
2022, and the two SARs were scheduled for committee consideration on
June 8, 2022.\81\
---------------------------------------------------------------------------

    \79\ NERC, Energy Reliability Assessment Task Force website,
(ERAFT website), https://www.nerc.com/comm/RSTC/Pages/
ERATF.aspx#:~:text=%E2%80%8B%E2%80%8B%E2%80%8B%E2%80%8B%E2%80%8B,insu
fficient%20amounts%20of%20energy%20on.
    \80\ NERC Post-Technical Conference Comments at 7.
    \81\ NERC, Informational Webinar: Industry Webinar Energy
Reliability Assessment Task Force Update on the Revised SARs (May
19, 2022), https://www.nerc.com/pa/RAPA/Lists/RAPA/DispForm.aspx?ID=480; NERC, Reliability and Security Technical
Committee Meeting Agenda, SAR Draft.
---------------------------------------------------------------------------

    46. While these ongoing efforts by NERC and industry members are
intended to improve system reliability, they do not directly address
the gap in transmission planning related to extreme heat and cold
weather. NERC acknowledges that heat and cold events have effects on
the grid but at this time has not determined that modifications to TPL-
001-5.1 are needed to address extreme weather events.\82\
---------------------------------------------------------------------------

    \82\ NERC, 2021 ERO Reliability Risk Priorities Report, Risk
Profile 2, at 26 (July 2021), https://www.nerc.com/comm/RISC/Documents/RISC%20ERO%20Priorities%20Report_Final_RISC_Approved_July_8_2021_Board_Submitted_Copy.pdf; see also NERC Post-Conference Comments at 5
(referencing Reliability Standard TPL-001-4, NERC states that
``[w]ith respect to extreme weather more generally, NERC staff will
continue to examine the Reliability Standards to determine if other
modifications are needed.'').
---------------------------------------------------------------------------

IV. Proposed Directives

    47. We preliminarily find that a reliability gap exists in
Reliability Standard TPL-001-5.1 with respect to a lack of a long-term
planning requirement for extreme heat and cold weather events.
Accordingly, pursuant to section 215(d)(5) of the FPA, we propose to
direct that NERC develop modifications to Reliability Standard TPL-001-
5.1 to require: (1) development of benchmark planning cases based on
information such as major prior extreme heat and cold weather events or
future meteorological projections; \83\ (2) planning for extreme heat
and cold events using steady state and transient stability analyses
expanded to consider a range of extreme heat and cold weather scenarios
(i.e., sensitivities to be applied to the benchmark base case(s)),
including the expected resource mix's availability during extreme heat
and cold weather conditions, and including the broad area impacts of
extreme heat and cold weather; and (3) corrective action plans that
include mitigation for any instances where performance requirements for
extreme heat and cold events are not met. We further elaborate on the
substance of these proposed directives below. In proposing to direct
NERC to develop modifications to Reliability Standard TPL-001-5.1, we
are not proposing specific requirements; we are identifying concerns
that we believe should be addressed. NERC may propose to develop new or
modified Reliability Standards that address these concerns in an
equally efficient and effective manner as the requirements proposed in
this paragraph; however, NERC must explain how its proposal addresses
the Commission's concerns.\84\
---------------------------------------------------------------------------

    \83\ For instance, a benchmark event could be constructed based
on data from a major prior extreme heat or cold event, with
adjustments if necessary to account for the fact that future
meteorological projections may estimate that similar events in the
future are likely to be more extreme.
    \84\ Order No. 693, 118 FERC ] 61,218 at P 186; Reliability
Standards for Physical Sec. Measures, 146 FERC ] 61,166 at P 13.
---------------------------------------------------------------------------

    48. We further propose to direct NERC to submit modifications to
Reliability Standard TPL-001-5.1 within one year of the effective date
of a final rule in this proceeding with compliance obligations for all
proposed new or modified Reliability Standards beginning no later than
12 months from the date of Commission approval of the modified
Reliability Standard. Finally, we invite comments on whether to also
direct NERC to address in Reliability Standard TPL-001-5.1 other
extreme weather-related events.
    49. Below we provide additional context for these three proposed
directives and describe reliability concerns and potential options for

consideration that we believe would address these concerns.

A. Develop Benchmark Planning Cases Based on Major Prior Extreme Heat
and Cold Weather Events

    50. As part of its revisions to Reliability Standard TPL-001-5.1,
we are proposing to direct that NERC develop requirements that address
the types of extreme heat and cold scenarios the responsible entities
are required to study. Reliability Standard TPL-001-5.1 does not
require any specific approach to studying extreme heat and cold events
and we are concerned that, without specific requirements describing the
types of heat and cold scenarios that entities must study, the standard
may not provide a significant improvement upon the status quo.
    51. To accomplish this, the modified Reliability Standard developed
by NERC should include benchmark events that responsible entities must
study, as well as guidelines regarding which range of sensitivities
must be applied to these benchmark event scenarios. Such benchmark
events should be based on prior events (e.g., February 2011 Southwest
Cold Weather Event, January 2014 Polar Vortex Cold Weather Event) and/
or constructed based on meteorological projections, as described above.
In addition to providing valuable case study information to be applied
to possible comparable future events, these events will also serve as a
basis for effectively using assets and resources. Once developed, the
results of the benchmark events studies could be applied to determine
the limitations of the transmission system locally and over a wide-
area, and to understand resource availability and potential firm load
shedding requirements under stressed conditions.
    52. While extreme weather risks may vary from region to region and
change over time, it is important that transmission planners and
planning coordinators likely to be impacted by the same types of
extreme weather events use consistent benchmark events. In determining
an appropriate benchmark event, NERC should consider approaches to
provide a uniform framework while still recognizing regional
differences. For example, NERC could define benchmark events around a
projected frequency (e.g., 1-in-50-year event) or probability
distribution (95th percentile event),
    53. We propose to provide NERC with flexibility in defining one or
more appropriate benchmark events. For example, one approach could be
for NERC to develop the common benchmark event or events through the
standards development process and include the relevant parameters of
the benchmark event or events in the modified reliability standard.
Another approach could be to include in the modified standard the
primary features of the benchmark event or events (e.g., the expected
occurrence such as one-in-50 years) while designating another set of
entities, such as the Regional Entities, reliability coordinators, or
even NERC itself, as responsible for periodically updating key aspects
of the benchmark events based on the most up-to-date data. Such a
method for developing benchmark events and scenarios could establish a
common design basis across the industry while still recognizing
regional differences in climate and weather patterns. We seek comment
on whether, and to what extent, it may be appropriate to allow
designated entities to periodically update key aspects of the benchmark
events.
    54. As discussed further below, establishing one or more benchmark
events should form the basis for sensitivity analysis, which provide
better visibility into the actual system conditions during extreme heat
and cold. For example, sensitivity analysis could include analysis of
simultaneously varying generation dispatch (e.g., wind, solar, natural
gas, and other fuel generation availability), system transfers, and
load, which have been observed during prior extreme heat and cold
events.
    55. In addition to establishing requirements that address the
extreme heat and cold scenarios that responsible entities are required
to study, NERC could also establish measures of system performance
(stability, voltage, thermal limits, etc.) to determine whether the
responsible entities must implement a corrective action plan.
Performance requirements are a corollary to study requirements--without
clear performance requirements, the obligations on responsible entities
to mitigate issues with system performance may be unclear. Moreover,
performance requirements are an integral part of the existing
Reliability Standard TPL-001-5.1.\85\ Accordingly, NERC should
incorporate performance requirements for extreme heat and cold
conditions when modifying TPL-001-5.1.
---------------------------------------------------------------------------

    \85\ See Reliability Standard TPL-001-5.1 (Transmission System
Planning Performance Requirements), Requirements R1 through R8.
---------------------------------------------------------------------------

    56. In establishing any proposed performance requirements, NERC
should seek to prevent system instability, uncontrolled separation, and
cascading outages. While load shedding could still occur during extreme
heat and cold events to prevent instability, uncontrolled separation,
and cascading, it should be minimized as much as possible. Developing
benchmark events and associated corrective actions to be deployed prior
to and during the event, would result in better system performance in
real time.

B. Transmission System Planning for Extreme Heat and Cold Weather
Events

    57. As discussed above, we propose to direct that NERC develop
modifications to Reliability Standard TPL-001-5.1 to require planning
for extreme heat and cold events using steady state and transient
stability analyses expanded to consider a range of extreme heat and
cold weather scenarios including the expected resource mix's
availability during extreme heat and cold weather conditions, and
including the broad area impacts of extreme heat and cold weather. In
this section, we discuss six topics which NERC would be required to
address in a modified Reliability Standard pursuant to the proposed
directive: (1) steady state and transient stability analysis; (2)
transmission planning studies of wide area issues; (3) concurrent
generator and transmission outages; (4) sensitivity analysis; (5)
consideration of modifications to the traditional planning approach;
and (6) coordination among planning coordinators and transmission
planners and sharing of results. We note that a range of methods/
approaches could satisfy the Commission's directive with regard to
issues (3) through (6). NERC would retain flexibility with regard to
how to address these topics, so long as it incorporates them into its
proposed solution. To better inform our directive to NERC in the final
rule, we invite comments on these matters.
1. Steady State and Transient Stability Analyses
    58. To maintain and improve the reliability of the Bulk-Power
System, it is important to conduct both steady state and stability
analyses for extreme heat and cold events as part of transmission
planning studies. As discussed above, steady state and stability
analyses of study cases modeled to reflect past and forecasted extreme
heat and cold conditions would better prepare transmission operators
for such conditions. Further, this approach is consistent with
Reliability Standard TPL-001-5.1, which requires both steady state and
stability analyses for extreme events identified in Table 1 of the
Standard. Performing these studies in the long-term planning horizon
time frame (i.e., five to 10 years) will provide an adequate lead time
for entities to

develop and implement corrective action plans to reduce the likelihood
or mitigate the consequences and adverse impacts of such events.
    59. A steady-state analysis or assessment is based on a snapshot in
time where bulk-electric system facilities such as generators,
transmission lines, transformers, etc. are modeled as fixed and load is
modeled as a constant. The steady state analysis assesses the ability
of the system to deliver electricity to load within the ratings and
constraints of generators and transmission lines. It also includes a
contingency analysis to predict electrical system conditions when
elements are removed from the base case.\86\
---------------------------------------------------------------------------

    \86\ NERC, Compliance Implementation Guidance Real-time
Assessment Quality of Analysis, at 3 (May 2019), https://www.nerc.com/pa/comp/guidance/EROEndorsedImplementationGuidance/TOP-010-1(i)%2520R3%2520and%2520IRO-018-1(i)%2520R2%2520-
%2520RTA%2520Quality%2520of%2520Analysis%2520(OC).pdf.
---------------------------------------------------------------------------

    60. Transient stability or dynamic studies add to the steady state
analyses simulate the time-varying characteristics of the system during
a disturbance that occurs during an extreme heat or cold weather event.
They are time-domain analyses that assess angular stability, voltage
stability, and frequency excursions.\87\ Transient angular stability is
the ability of interconnected synchronous machines of a power system to
remain in synchronism after being subjected to a disturbance (i.e.,
fault, sudden loss of load, and generation tripping).\88\ Transient
voltage stability refers to the ability of a power system to maintain
steady voltages at all buses in the system after being subjected to a
disturbance.\89\
---------------------------------------------------------------------------

    \87\ Indian Institute of Technology Patna, Power System Dynamics
and Control, at 1, (Power System Dynamics), https://www.iitp.ac.in/
~siva/2022/ee549/Introduction_Power_System_Stability.pdf.
    \88\ Id. at 3.
    \89\ Id. at 15.
---------------------------------------------------------------------------

    61. While we recognize dynamic studies can be more resource
intensive to perform, we believe that the consideration of both types
of studies is important to understand the potential impacts of extreme
heat and cold weather events. We believe the consideration of dynamic
studies is particularly important given the changing resource mix and
the need to understand the dynamic behavior of both traditional
generators as well as variable energy resources (VER) (mainly wind and
photovoltaic solar).
    62. To that end, we seek comments on whether planning coordinators
and transmission planners should include contingencies based on their
planning area and perform both steady state and transient stability
(dynamic) analyses using extreme heat and cold cases. We are inviting
comments on the following topics regarding planning for extreme heat
and cold weather conditions: (1) the set of contingencies planning
coordinators and transmission planners must consider; (2) required
analyses to ensure system stability, frequency excursion and angular
deviations caused as a result of near simultaneous outages or common
mode failures of VERs; and (3) the role of demand response under such
scenarios.
    63. Finally, we emphasize the continued importance of ensuring that
entities responsible for performing assessments under TPL-001-5.1 are
able to obtain the necessary data. Currently, the data for steady-
state, dynamic, and short circuit modeling can be obtained pursuant to
Reliability Standard MOD-32-1, Requirement 1 (Data for Power System
Modeling and Analysis), which is referenced in Reliability Standard
TPL-001-5.1. Specifically, Reliability Standard MOD-32-1 allows
planning coordinators and transmission planners to request data from
the generator owners and transmission owners, which are obligated to
provide the specified data.\90\ Consistent with the existing standards,
we believe it is important for NERC to ensure that registered entities
responsible for performing studies of extreme weather are able to
access the data necessary to complete such studies. Accordingly, we
seek comment on whether the existing Reliability Standards are
sufficient to ensure that responsible entities performing studies of
extreme heat and cold weather conditions have the necessary data, or
whether the Commission should direct additional changes pursuant to FPA
215(d)(5) to address that issue.
---------------------------------------------------------------------------

    \90\ Reliability Standard MOD-032-1, Requirements R1 and R2.
---------------------------------------------------------------------------

2. Transmission Planning Studies of Wide-Area Events
    64. As discussed above, our proposed directive would include
modifications to TPL-001-5.1 to require transmission planning studies
that consider the broad area impacts of extreme heat and cold weather.
The effects of extreme weather events on the reliable operation of the
Bulk-Power System can be widespread, potentially causing simultaneous
loss of generation and increased transmission constraints within and
across regions. The studies required by TPL-001-5.1, however, have
traditionally focused on local planning and typically do not address
the issues caused by wide-area extreme heat and cold weather events on
a regional or interconnection scale.\91\
---------------------------------------------------------------------------

    \91\ June 1, 2021 Tr. 153: 2-9. (Frederick Heinle, Assistant
People's Counsel, Office of the People's Counsel for the District of
Columbia).
---------------------------------------------------------------------------

    65. Reliability Standard TPL-001-5.1 does not contemplate the
consideration of impacts from wide-area events \92\ that may impact
multiple planning coordinators simultaneously; in contrast, TPL-001-5.1
only requires identifying and evaluating selected wide-area events
resulting from conditions such as loss of a large gas pipeline into a
region or multiple regions that have significant gas-fired generation,
and does not specify studying potential issues resulting from extreme
heat and cold.\93\
---------------------------------------------------------------------------

    \92\ Reliability Standard TPL-001-5.1, Table 1, Steady State &
Stability Performance Extreme Events, uses the term ``wide area
events'' to refer to such things as loss of two generating stations
resulting from conditions including severe weather or wildfires,
distinguishing such events from ``local area events'' affecting the
transmission system, which may involve the isolated loss of a
transmission tower, substation, or generating station.
    \93\ Reliability Standard TPL-001-5.1, Table 1, Steady State &
Stability Performance Extreme Events, Section 3(a)(i).
---------------------------------------------------------------------------

    66. Failure to study the wide-area impact of extreme heat or
extreme cold weather conditions when an entity conducts transmission
planning, could result in reliability issues that simultaneously affect
multiple regions to remain undetected in the long-term planning
horizon. This, in turn, could lead to otherwise avoidable situations
where the system is one contingency away from voltage collapse and
uncontrolled blackouts.
    67. Based on prior events, we preliminarily find that it is
appropriate that the study criteria for extreme heat and cold events
include a consideration of wide-area conditions affecting neighboring
regions and their impact on one planning area's ability to rely on the
resources of another region during the weather event. To identify
opportunities for improved wide-area planning studies and coordination,
we seek comment on: (1) whether wide-area planning studies should be
defined geographically or electrically; (2) which entities should
oversee and coordinate the wide-area planning models and studies (e.g.,
reliability coordinators, regional planning groups); (3) which entities
should have responsibility to address the results of the studies, and
how they should communicate those results among transmission planners;
and (4) how to develop corrective action plans that mitigate issues
that require corrective action by, and coordination among, multiple
transmission owners.

3. Study Concurrent Generator and Transmission Outages
    68. Concurrent outages occur nearly simultaneously in different
planning areas due to the same extreme weather events, such as the
unplanned generator outages associated with the major extreme heat and
cold events discussed above. Generation resources that are sensitive to
severe weather conditions may cease operation during extreme heat and
cold events, thus contributing to wide-area concurrent outages. In
addition, the performance of power transformers, transmission lines,
and other equipment degrades under extreme heat and may have to come
out of service. Extreme heat could lead to significant derating,
reduced lifetime, and even possible failures of power transformers,
while extreme cold could lead to at least temporary facility
transmission outages.\94\
---------------------------------------------------------------------------

    \94\ MIT News, Preventing the Next Blackout (Dec. 5, 2017),
https://news.mit.edu/2017/mit-study-climate-change-effects-large-transformers-1205; see also IEEE Standard C57.91-2011, Table 2; IEEE
Standard C57.91-2011, Table 3; 2021 Cold Weather Event Report at 95.
---------------------------------------------------------------------------

    69. Therefore, modeling the loss of these generators and
transmission equipment during extreme heat and cold weather events
would allow planners to determine the effects of potential concurrent
transmission and generator outages and study the feasibility (i.e.,
availability and deliverability) of external generation resources that
could possibly be imported to serve load during such events, thereby
minimizing the potential impact of extreme heat and cold events on
customers.\95\ Modeling concurrent generator and transmission outages
would also allow planners to better identify appropriate solutions to
be incorporated into corrective action plans.
---------------------------------------------------------------------------

    \95\ The Cold Weather Reliability Standards referenced supra
take effect in April 2023, and are expected to improve generating
unit performance and help alleviate some of the unsustainable levels
of generation outages seen during extreme events. Improved
transmission planning alone cannot overcome the challenges
associated with generator outages during extreme events. Therefore,
both the Cold Weather Reliability Standards and this proposal to
improve transmission planning are necessary for the Bulk Power
System to perform reliably in the face of future extreme weather
events.
---------------------------------------------------------------------------

    70. Extreme cold effects on generators vary by generator type,
cooling systems, and fuel sources.\96\ Transmission planners commonly
assume that the failures of individual generators are independent. This
understanding, however, is inconsistent with documented historical
events, that show multiple coincident outages due to the same cause.
For instance, the 2021 extreme cold event demonstrated the limitations
of such an assumption. Between February 8 and February 20, 2021,
approximately 44% of generator outages were caused by freezing issues,
31% by fuel issues related to extreme cold weather, and another 21%
were caused by mechanical/electrical failures related to cold
weather.\97\ Meanwhile, wind turbine generators were the second largest
share of individual generating units after gas-fired generators that
suffered freezing issues in the southern part of SPP and Texas, as
temperatures dropped well below zero degrees Fahrenheit.\98\
Transmission facilities were also affected in the short-term, as
transmission operators managed to return them into service.\99\
Likewise, the 2018 Cold Weather Event Report revealed that there is a
high correlation between generator outages and cold temperatures,
indicating that as temperatures decrease, unplanned generator outages
and derates increase.\100\
---------------------------------------------------------------------------

    \96\ Polar Vortex Review at 12.
    \97\ 2021 Cold Weather Event Report at 15-16.
    \98\ Id. at 75.
    \99\ Id. at 95.
    \100\ 2018 Cold Weather Event Report at 80.
---------------------------------------------------------------------------

    71. Similarly, extreme heat impacts on generators vary by generator
type, and the common implication is a reduction in the overall
generation capacity throughout the wide area affected by the heat
event.\101\ Generally, extreme heat poses more of a threat to the
functioning of a solar panel than extreme cold. As temperatures
increase above 77 degrees Fahrenheit, which is a standard test
condition, solar panels generate less voltage and become less
efficient,\102\ producing less power for a given amount of solar energy
depending on the solar panel temperature coefficient.\103\ For example,
during the 2020 heat event in California, wind and solar generation
were largely unavailable.\104\ While extreme cold temperatures on clear
days would not negatively impact energy output. Also, solar panels are
built to be waterproof to protect the electronic components against
heavy rain and to withstand hailstorms. However, snow,\105\ ice
accumulation, or cloud cover that commonly accompany extreme cold
weather could prevent the panels from receiving as much sunlight, which
would limit their power production and efficiency.
---------------------------------------------------------------------------

    \101\ Department of Energy, U.S. Energy Sector Vulnerabilities
to Climate Change and Extreme Weather, Department of Energy, at 19-
22 (July 11, 2013), https://www.energy.gov/sites/default/files/2013/07/f2/20130716-Energy%20Sector%20Vulnerabilities%20Report.pdf
(listing the impacts of increased ambient air temperature on the
various types of generators).
    \102\ IEEEXplore, International Conference on Current Trends in
Computer, Electrical, Electronics and Communication (ICCTCEEC-2017),
Effect of Temperature on Performance of Solar Panels--Analysis,
https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=8455109.
    \103\ Temperature coefficient describes the percentage of power
output that is lost by a specific solar panel as the temperature
rises above 77 degrees Fahrenheit.
    \104\ 2020 Heat Event Report at 11.
    \105\ A recent study by Sandia National Labs identified snow
events as causing the largest performance reductions at solar
facilities. See Nicole D. Jackson & Thushara Gunda, Evaluation of
Extreme Weather Impacts on Utility-Scale Photovoltaic Plant
Performance in the United States, 302, Applied Energy, 1:7 (2021),
https://www.researchgate.net/publication/353944206_Evaluation_of_extreme_weather_impacts_on_utility-scale_photovoltaic_plant_performance_in_the_United_States.
---------------------------------------------------------------------------

    72. Requiring transmission planners and planning coordinators to
study concurrent generator and transmission failures under extreme heat
and cold events is one way to address the reliability gap. Accounting
for concurrent outages in planning studies would provide a more
realistic assessment of system conditions (i.e., updated conditions
based on historic benchmarked performance) during potential extreme
heat and cold events and will help better assess the probability of
potential occurrences of cascading outages, uncontrolled separation, or
instability. Transmission planners and planning coordinators could also
model the derating and possible loss of wind and solar generators, as
well as natural gas generators sensitive to extreme heat and cold
conditions. To identify the scope of these planning studies, we are
seeking comments on: (1) the assumptions (e.g., weather forecast, load
forecast, transmission voltage levels, generator types, multi-day low
wind, solar event, etc.) used in modeling of concurrent outages due to
extreme heat and cold weather events; (2) what assumptions should be
included when performing modeling and planning for generators sensitive
to extreme heat and cold; (3) how the impact of loss of generators
sensitive to extreme heat and cold should be factored into long-term
planning; (4) the extent of neighboring systems' or planning areas'
outages that should be modeled in transmission planning studies; and
(5) whether a certain threshold of penetration of wind, solar
generation, and natural gas generators should trigger additional
analyses.
4. Sensitivity Analysis
    73. As part of its revisions to TPL-001-5.1, NERC should establish
a requirement for sensitivity analysis for

transmission planners and planning coordinators to consider system
models and sensitivity cases when assessing extreme heat and extreme
cold weather. A sensitivity case is a variation from the base case that
helps a transmission planner to determine if the results are sensitive
to changes in the inputs. Reliability Standard TPL-001-5.1, Requirement
R2.1.4 requires that sensitivity power flow cases be used to
demonstrate the impact of changes to the basic assumptions used in the
models for system peak load or system off-peak load. These changes
include, among other things, conditions that vary with temperature;
specifically, load, generation, and system transfers.\106\ While
requiring the variation of one of the specified conditions to
demonstrate a measurable change, it does not require the simultaneous
variation of load, generation and transfers necessary to model
conditions that reflect extreme heat or cold weather conditions, thus
potentially causing major reliability issues (i.e., widespread outages,
cascading, etc.) to remain overlooked and undetected in the planning
horizon. To model the effect of extreme heat or cold weather, demand
probability scenario cases (90/10, 80/20, 50/50),\107\ generators that
are affected by these events (i.e., wind tripping off, solar dropping
off, gas plants not operational due to gas restrictions/freeze-offs,
etc.), and transfer levels need to be defined and modeled in
sensitivity analyses.
---------------------------------------------------------------------------

    \106\ To effectively model the Bulk-Power System, transmission
planners need make assumptions that create scenarios that are valid,
realistic, and defendable. See North American Transmission Forum,
TPL-001-4 Reference Document, at 8-9 (Aug. 2, 2021), https://www.natf.net/docs/natf/documents/resources/planning-and-modeling/natf-tpl-001-4-reference-document.pdf. Specifically, appropriate
assumptions and corresponding model adjustments need to be made
regarding load (demand), generation (particularly that of
renewables), and transfers (power flows between regions or zones).
See National Renewable Energy Laboratory, Report: The Evolving Role
of Extreme Weather Events in the U.S. Power System with High Levels
of Variable Renewable Energy (Dec. 2021), https://www.nrel.gov/docs/fy22osti/78394.pdf.
    \107\ Demand scenario cases are given designations based on the
percent probability the actual system's peak demand for the period
under study will be above or below certain level. For example, for a
90/10 case, the system demand is modeled at a level that there is a
90% probability the actual system demand will be below that level
and a 10% probability that the actual system demand will be above
that level. Other designations follow similarly using different
percentages.
---------------------------------------------------------------------------

    74. Therefore, we seek comment on: (1) requiring transmission
planners and planning coordinators to assess reliability in the
planning horizon for sensitivity cases in which multiple inputs, e.g.,
load and generator failures, change simultaneously during extreme heat
and cold events; and (2) the range of factors and the number of
sensitivity cases that should be considered to ensure reliable
planning.
5. Modifications to the Traditional Planning Approach
    75. In modifying TPL-001-5.1, we propose to direct NERC to consider
planning methods and techniques that diverge from past Reliability
Standard requirements.\108\ Reliability Standard TPL-001-5.1 is based
on a deterministic approach, which uses planned contingencies and
definite performance criteria to study system response to various
conditions. This approach yields accurate planning when the power
supply is highly dispatchable, weather is predictable, and near-record
peak demand is reached only a few days a year.\109\ However, the
current planning approach applied in Reliability Standard TPL-001-5.1
likely is not sufficient to accurately characterize the reliability
risk from extreme heat and cold weather given the high degree of
uncertainty inherent in predicting severe weather and its impact on
generation resources, transmission, and load.
---------------------------------------------------------------------------

    \108\ We are not making a proposed finding at this time that
modifications to the traditional planning approach are necessary to
properly plan for extreme weather. Nonetheless, there is sufficient
concern such that we believe NERC should consider alternative
approaches when developing a new or modified Reliability Standard in
response to a final rule in this proceeding.
    \109\ June 1, 2021 Tr. 31 (Barton).
---------------------------------------------------------------------------

    76. An alternative to the deterministic approach is to use
probabilistic approaches in transmission planning. Probabilistic
transmission planning captures random uncertainties in power system
planning, including those in load forecasting, generator performance,
and failures of system equipment. The probabilistic method is not
intended to replace the deterministic criterion but adds one more
dimension to enhance the transmission planning process.\110\
---------------------------------------------------------------------------

    \110\ IEEE Explore, Probabilistic Planning of Transmission
Systems: Why, How and an Actual Example, at 1 (July 2008), https://ieeexplore.ieee.org/document/4596093.
---------------------------------------------------------------------------

    77. NERC has recognized the need to incorporate probabilistic
approaches into planning activities. For example, NERC's Probabilistic
Assessment Working Group develops probabilistic analysis that
contributes to NERC's Long-Term Reliability Assessment every other
year. NERC is also investigating the development of probabilistic
methods to study resource adequacy, energy sufficiency, and
transmission adequacy for reliable delivery in composite reliability
studies as well as to develop enhanced reliability metrics.\111\
---------------------------------------------------------------------------

    \111\ NERC Post-Technical Conference Comments 3.
---------------------------------------------------------------------------

    78. Therefore, to ensure reliable planning and operations in
response to extreme heat and cold events, we believe that a new or
modified approach may be beneficial to capture these events during the
planning process. The new approach could include elements of both
deterministic and probabilistic approaches to assess reliability
outcomes. For example, the January 2018 South Central Cold Weather
Event in the South Central part of the country was a near-miss where
MISO would have been required to perform firm load shed if its next-
worst contingency occurred (i.e., outage of 1,163 MW generation in MISO
South). The load shed would have been needed to alleviate low voltages
at many locations that would have been significantly below their limits
due to the failure of almost 200 generating units. Including scenarios
in the planning process in which generator failures are
probabilistically evaluated could result in a planning approach better
prepared to ensure reliable outcomes compared to the existing planning
requirements under Reliability Standard TPL-001-5.1.
    79. One option to modify the existing planning approach would be to
expand the required deterministic studies to include probabilistically
developed scenarios. Therefore, we seek comments on industry's
experience and opinion on combining or layering probabilistic and
deterministic approaches when planning for extreme heat and cold
weather conditions in the context of Reliability Standard TPL-001-5.1.
Specifically, we seek comments on the use of the proposed hybrid
planning approach and: (1) the assumptions from the deterministic and
probabilistic approaches that should be applied to study extreme heat
and cold weather events; (2) the potential planning challenges from
combining the two planning approaches; (3) the costs associated with
adjustments to the currently applied deterministic approach; (4) the
implementation period necessary for proposed changes; and (5) the
reliability benefits that could result.
6. Coordination Among Planning Coordinators and Transmission Planners
and Sharing of Study Results
    80. Reliability Standard TPL-001-5.1 cross-refences Reliability
Standard MOD-032-1 (Data for Power System Modeling and Analysis), which
establishes consistent modeling data requirements and reporting
procedures

for development of planning horizon cases necessary to support analysis
of the reliability of the interconnected transmission system.
Reliability Standard MOD-032-1 ensures adequate means of data
collection for transmission planning. It requires each balancing
authority, generator owner, load serving entity, resource planner,
transmission owner, and transmission service provider to provide
steady-state, dynamic, and short circuit modeling data to its
transmission planner(s) and planning coordinator(s). The modeling data
is then shared pursuant to the data requirements and reporting
procedures developed by the transmission planner and planning
coordinator as set forth in Reliability Standard TPL-001-5.1,
Requirement R1.
    81. While balancing authorities and other entities must share
system information and study results with their transmission and
planning coordinator pursuant to Reliability Standards MOD-032-1 and
TPL-001-5.1 as described above, there is no required sharing of such
information--or required coordination--among planning coordinators and
transmission planners with transmission operators, transmission owners,
and generator owners, thus limiting the benefits of additional
modeling. Sharing system information and study results and enhancing
coordination among these entities for extreme heat and cold weather
events could result in more representative planning models by better:
(1) integrating and including operations concerns (e.g., lessons
learned from past issues including corrective actions and projected
outcomes from these actions, evolving issues concerning extreme heat/
cold) in planning models; and (2) conveying reliability concerns from
planning studies (e.g., potential widespread cascading, islanding,
significant loss of load, blackout, etc.) as they pertain to extreme
heat or cold.
    82. Therefore, as part of its revisions, NERC should require system
information and study results sharing, and coordination among planning
coordinators and transmission planners with transmission operators,
transmission owners, and generator owners for extreme heat and cold
weather events. To better understand the benefits of the suggested
actions, we are inviting comments on: (1) the parameters and timing of
coordination and sharing; (2) specific protocols that may need to be
established for efficient coordination practices; and (3) potential
impediments to the proposed coordination efforts.

C. Implement a Corrective Action Plan If Performance Standards Are Not
Met

    83. Pursuant to FPA 215(d)(5), we propose to direct NERC to modify
Reliability Standard TPL-001-5.1 to require corrective action plans
that include mitigation for any instances where performance
requirements for extreme heat and cold events are not met. Under the
currently effective Reliability Standard TPL-001-4, planning
coordinators and transmission planners are required to evaluate
possible actions to reduce the likelihood or mitigate the consequences
of extreme events but are not obligated to develop corrective action
plans. Specifically, if such events are found to cause cascading
outages, they need only be evaluated for possible actions designed to
reduce their likelihood or mitigate their consequences and adverse
impacts.\112\ Accordingly, because of their potential severity, we
believe that extreme heat and cold weather events should require
evaluation and the development and implementation of corrective action
plans to help protect against system instability, uncontrolled
separation, or cascading failures as a result of a sudden disturbance
or unanticipated failure of system elements.
---------------------------------------------------------------------------

    \112\ Reliability Standard TPL-001-4, Requirements R3.3.5 and
R4.4.5 require computer simulation analyses of extreme events listed
in Table 1 of the standard (some listed are examples and are not
definitive), and if the analysis concludes there is Cascading caused
by the occurrence of extreme events, an evaluation of possible
actions designed to reduce the likelihood or mitigate the
consequences and adverse impacts of the event(s) shall be conducted.
---------------------------------------------------------------------------

    84. Consistent with the existing requirements of TPL-001-5.1, we
believe it is appropriate to provide responsible entities with the
flexibility to determine the best actions to include in their
corrective action plan to remedy any identified deficiencies in
performance. Examples of actions that could be included in a corrective
action plan are planning for additional contingency reserves or
implementing new energy efficiency programs to decrease load,
increasing intra- and inter-regional transfer capabilities,
transmission switching, or adjusting transmission and generation
maintenance outages based on longer-lead forecasts. Well planned
mitigation and corrective actions that account for some of these
contingencies will minimize loss of load and improve resilience during
extreme heat and cold weather events.
    85. In particular, increases in interregional transfer capability
could be considered as one option to address potential reliability
issues during extreme weather events. Such transfer capability would
allow an entity in one region with available energy to assist one or
more entities in another region that is experiencing an energy
shortfall due to the extreme weather event. Increasing interregional
transfer capability may be a particularly robust option for planning
entities attempting to mitigate the risks associated with concurrent
generator outages over a wide area.\113\
---------------------------------------------------------------------------

    \113\ In this NOPR we refer to interregional transfer capability
strictly in the context of improving the reliability of the Bulk-
Power System through improved transmission system planning and
associated modifications to NERC's Reliability Standards. As such,
our proposals here are distinct from the requirements for
interregional coordination and cost allocation for public utility
transmission providers. See Transmission Planning and Cost
Allocation by Transmission Owning and Operating Public Utilities,
Order No. 1000, 76 FR 49842 (Aug. 11, 2011), 136 FERC ] 61,051
(2011), order on reh'g, Order No. 1000-A, 77 FR 32184 (May 31,
2012), 139 FERC ] 61,132, order on reh'g and clarification, Order
No. 1000-B, 77 FR 64890 (Oct. 24, 2012), 141 FERC ] 61,044 (2012),
aff'd sub nom. S.C. Pub. Serv. Auth. v. FERC, 762 F.3d 41 (D.C. Cir.
2014).
---------------------------------------------------------------------------

    86. Recent events have shown that interregional transfer capability
can be critical to maintaining reliability during extreme weather
events. For example, during the 2021 Cold Weather Event in Texas and
the South Central United States, SPP and MISO imported power from other
balancing authorities to make up for their increasing load levels and
generation shortfalls, because the eastern part of the Eastern
Interconnection did not have the same arctic weather conditions.
Specifically, MISO was able to import large amounts of power from
neighbors to the east (e.g., PJM), and SPP was able to transfer some of
that power through MISO into its region. Those east-to-west transfers
into MISO peaked at nearly 13,000 MW.\114\ PJM had additional energy
available to be transferred but could not facilitate the transfer due
to internal congestion in neighboring systems.\115\
---------------------------------------------------------------------------

    \114\ 2021 Cold Weather Event Report at 15.
    \115\ PJM Post-Conference Comments at 19-20.
---------------------------------------------------------------------------

    87. Recent events have also shown that the loss of interregional
transfer capability can have significant implications for system
reliability during extreme weather events. For instance, during the
August 2020 California Heatwave Event, there was a reduction in the
transfer capability through the Northwest AC Intertie by as much as
1,250 MW due to another extreme weather event that occurred earlier in
2020 which damaged transmission facilities in the northwest part of the
Western Interconnection. The transfer capability of the intertie
linking

Canadian and U.S. power systems was also reduced by up to 750 MW due to
other planned maintenance outages, further limiting the ability to
transfer energy from the north to the load centers in the south.\116\
---------------------------------------------------------------------------

    \116\ 2020 Heat Event Report at 6.
---------------------------------------------------------------------------

    88. Thus, we believe that there may be potential benefits in better
incorporating interregional transfer capability into corrective action
plans, where warranted and encourage NERC to consider establishing
requirements that appropriately recognize the value of interregional
transfer capability.
    89. To ensure corrective action plans are developed and implemented
in a timely fashion, we invite comments on the timeframe for developing
such corrective action plans and sharing of the corrective actions with
other interconnected planning entities.

D. Other Extreme Weather-Related Events and Issues

    90. While the focus of this NOPR is on extreme heat and cold
weather events, we recognize that long-term drought, particularly when
occurring in conjunction with high temperatures, could also pose a
serious risk to Bulk-Power System reliability over a wide geographical
area.\117\ In particular, we are concerned that drought may cause or
contribute to conditions that affect reliable operation of transmission
systems such as transmission outages, reduced plant efficiency, and
reduced generation capacity.
---------------------------------------------------------------------------

    \117\ DOE, Impacts of Long-term Drought on Power Systems in the
U.S. Southwest, at 5, https://www.energy.gov/sites/prod/files/Impacts%20of%20Long-term%20Drought%20on%20Power%20Systems%20in%20the%20US%20Southwest%20%E2%80%93%20July%202012.pdf.
---------------------------------------------------------------------------

    91. Some examples of recorded events of reduced power production
from drought were seen in the Midwest in 2007 forcing nuclear and coal-
fired plants to shut down and curtail operations and along the
Mississippi River in 2006, which affected nuclear plants in Illinois
and Minnesota.\118\ According to a study conducted by NOAA's drought
task force, climate change has intensified the drought conditions
gripping the Southwestern United States, the region's most severe on
record, with precipitation at the lowest 20-month level documented
since 1895.\119\ The study indicates that the drought that emerged in
early 2020 in California, Nevada and the ``Four Corners'' states of
Arizona, Utah, Colorado and New Mexico has led to unprecedented water
shortages in reservoirs across the region, while exacerbating
devastating western wildfires over the past two years.\120\
---------------------------------------------------------------------------

    \118\ Id. at 6.
    \119\ NOAA, Assessment Report the 2020-2021 Southwestern U.S.
Drought, at 6, https://cpo.noaa.gov/MAPP/DTF4SWReport.
    \120\ Reuters, Southwest U.S. Drought, Worst in a Century,
Linked by NOAA to Climate Change (Sept. 21, 2021), https://
www.reuters.com/business/environment/southwest-us-drought-worst-
century-linked-by-noaa-climate-change-2021-09-21/
#:~:text=The%20drought%20emerged%20in%20early,two%20years%2C%20the%20
report%20noted.
---------------------------------------------------------------------------

    In addition, NERC's 2022 Summer Reliability Assessment concludes
that in 2022 drought threatens wide areas of North America, mainly in
the western United States and Texas, resulting in challenges to area
electricity supplies.\121\
---------------------------------------------------------------------------

    \121\ NERC, 2022 Summer Reliability Assessment, at 5 (May 2022),
https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/
NERC_SRA_2022.pdf.
---------------------------------------------------------------------------

    92. Therefore, we seek comments on whether drought should be
included along with extreme heat and cold weather events within the
scope of Reliability Standard TPL-001-5.1 system planning requirements.
These comments will assist the Commission in determining whether the
final rule should direct that NERC further modify Reliability Standard
TPL-001-5.1 to require transmission planners to conduct transmission
planning assessments of the effects of drought conditions on
transmission system operations.
    93. Finally, we invite comments on whether other extreme weather
events with significant impact on the reliability of the Bulk-Power
System (e.g., tornadoes, hurricanes) could also be considered and
modeled in the future to improve system performance during these
events.

V. Information Collection Statement

    94. The information collection requirements contained in this
Notice of Proposed Rulemaking are subject to review by the Office of
Management and Budget (OMB) under section 3507(d) of the Paperwork
Reduction Act of 1995.\122\ OMB's regulations require approval of
certain information collection requirements imposed by agency
rules.\123\ Upon approval of a collection of information, OMB will
assign an OMB control number and expiration date. Respondents subject
to the filing requirements of this rule will not be penalized for
failing to respond to this collection of information unless the
collection of information displays a valid OMB control number.
---------------------------------------------------------------------------

    \122\ 44 U.S.C. 3507(d).
    \123\ 5 CFR 1320.11.
---------------------------------------------------------------------------

    95. The proposal to direct NERC modify existing Reliability
Standard TPL-001 (Transmission System Planning Performance
Requirements), is covered by, and already included in, the existing
OMB-approved information collection FERC-725 (Certification of Electric
Reliability Organization; Procedures for Electric Reliability
Standards; OMB Control No. 1902-0225),under Reliability Standards
Development.\124\ The reporting requirements in FERC-725 include the
ERO's overall responsibility for developing Reliability Standards, such
as the TPL-001 Reliability, which is designed to ensure the BES will
operate reliably over a broad spectrum of system conditions and
following a wide range of probable contingencies.\125\ The Commission
will submit to OMB a request for a non-substantive revision of FERC-725
in connection with this NOPR.
---------------------------------------------------------------------------

    \124\ Reliability Standards Development as described in FERC-725
covers standards development initiated by NERC, the Regional
Entities, and industry, as well as standards the Commission may
direct NERC to develop or modify.
    \125\ Reliability Standard TPL-001-4, Purpose.
---------------------------------------------------------------------------

VI. Environmental Assessment

    96. 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.\126\ 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.\127\ The actions proposed here
fall within this categorical exclusion in the Commission's regulations.
---------------------------------------------------------------------------

    \126\ Regulations Implementing the National Environmental Policy
Act of 1969, Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats.
& Regs., ] 30,783 (1987) (cross-referenced at 41 FERC ] 61,284).
    \127\ 18 CFR 380.4(a)(2)(ii) (2021).
---------------------------------------------------------------------------

VII. Regulatory Flexibility Act Certification

    97. The Regulatory Flexibility Act of 1980 (RFA) \128\ generally
requires a description and analysis of proposed rules that will have
significant economic impact on a substantial number of small entities.
---------------------------------------------------------------------------

    \128\ 5 U.S.C. 601-612.
---------------------------------------------------------------------------

    98. We are proposing only to direct NERC, the Commission-certified
ERO, to develop modified Reliability Standards that require enhanced
long-term system transmission planning designed to prepare for extreme
heat and cold

weather conditions.\129\ Therefore, this Notice of Proposed Rulemaking
will not have a significant or substantial impact on entities other
than NERC. Consequently, the Commission certifies that this Notice of
Proposed Rulemaking will not have a significant economic impact on a
substantial number of small entities.
---------------------------------------------------------------------------

    \129\ Cf. Cyber Sec. Incident Reporting Reliability Standards,
Notice of Proposed Rulemaking, 82 FR 61499 (Dec. 28, 2017), 161 FERC
] 61,291 (2017) (proposing to direct NERC to develop and submit
modifications to the NERC Reliability Standards to improve mandatory
reporting of Cyber Security Incidents, including incidents that
might facilitate subsequent efforts to harm the reliable operation
of the BES); Internal Network Sec. Monitoring for High and Medium
Impact Bulk Elec. Sys. Cyber Sys., 178 FERC ] 61,038 (2020)
(proposing to direct NERC to new or modified Reliability Standards
that require internal network security monitoring within a trusted
Critical Infrastructure Protection networked environment for high
and medium impact Bulk Electric System Cyber Systems).
---------------------------------------------------------------------------

    99. Any Reliability Standards proposed by NERC in compliance with
this rulemaking will be considered by the Commission in future
proceedings. As part of any future proceedings, the Commission will
make determinations pertaining to the Regulatory Flexibility Act based
on the content of the Reliability Standards proposed by NERC.

VIII. Comment Procedures

    100. 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 26, 2022. Comments must
refer to Docket No. RM22-3-000, and must include the commenter's name,
the organization they represent, if applicable, and address in their
comments. 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.
    101. The Commission encourages comments to be filed electronically
via the eFiling link on the Commission's website at http://www.ferc.gov. The Commission accepts most standard word processing
formats. Documents created electronically using word processing
software must 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.
    102. Commenters that are not able to file comments electronically
may file an original of their comment by USPS mail or by courier-or
other delivery services. For submission sent via USPS only, filings
should be mailed to: Federal Energy Regulatory Commission, Office of
the Secretary, 888 First Street NE, Washington, DC 20426. Submission of
filings other than by USPS should be delivered to: Federal Energy
Regulatory Commission, 12225 Wilkins Avenue, Rockville, MD 20852.

IX. Document Availability

    103. 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). At
this time, the Commission has suspended access to the Commission's
Public Reference Room due to the President's March 13, 2020
proclamation declaring a National Emergency concerning the Novel
Coronavirus Disease (COVID-19).
    104. 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 excluding the last three digits of this document in
the docket number field.
    105. User assistance is available for eLibrary and the Commission's
website during normal business hours from the Commission's Online
Support at<PHONE_NUMBER> (toll free at 1-866-208-3676) or email at
[email protected], or the Public Reference Room at (202) 502-
8371, TTY<PHONE_NUMBER>. Email the Public Reference Room at
[email protected].
    By direction of the Commission. Commissioner Danly is concurring
with a separate statement attached. Commissioner Clements is concurring
with a separate statement attached. Commissioner Phillips is concurring
with a separate statement attached.

    Issued: June 16, 2022.
Debbie-Anne A. Reese,
Deputy Secretary.
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Transmission System Planning Performance Requirements for Extreme
Weather
Docket No. RM22-10-000
(Issued June 16, 2022)
    DANLY, Commissioner, concurring:
    1. I concur in today's notice of proposed rulemaking directing the
North American Electric Reliability Corporation (NERC) to submit
modifications to Reliability Standard TPL-001-5.1 to address
reliability concerns related to transmission system planning.\130\ It
will take over two years, at a minimum, from this notice of proposed
rulemaking (NOPR) to the ultimate implementation of any such changes.
Reliability Standard development is neither swift nor agile, and this
NOPR will not, indeed cannot, timely address the projected risk of
widespread blackouts this summer,\131\ nor can they be in place quickly
enough to address future summer and winter reliability challenges over
the next couple of years. Yet, I agree it is an important (albeit
small) step to establish mandatory and enforceable compliance
obligations to promote proactive planning for weather-related events.
---------------------------------------------------------------------------

    \130\ Transmission Sys. Planning Performance Requirements for
Extreme Weather, 179 FERC ] 61,195 (2022).
    \131\ Chairman Glick says that I am ``prone to hyperbole'' when
I warn that blackouts are the likely outcome of the majority's
misguided policies to prop up renewables at the expense of
competitive markets and existing fossil resources. Rich Heidorn Jr.,
Summer Forecasts Spark Warnings of `Reliability Crisis' at FERC, RTO
Insider (May 19, 2022), https://www.rtoinsider.com/articles/30170-summer-forecasts-spark-warnings-reliability-crisis-ferc. Chairman
Glick appears to be confusing ``hyperbole'' with ``reality.''
California and Texas have already experienced blackouts. Over two-
thirds of the nation faces ``elevated [reliability] risk'' this
summer. Ethan Howland, FERC commissioners respond to elevated power
outage risks across two-thirds of US, Utility Dive (May 20, 2022),
https://www.utilitydive.com/news/ferc-nerc-power-outage-risks-summer-drought/624111/ (``At its monthly meeting Thursday, Federal
Energy Regulatory Commission members dissected the North American
Electric Reliability Corp.'s warning that roughly two-thirds of the
United States faces [sic] heightened risks of power outages this
summer.'').
---------------------------------------------------------------------------

    2. The NOPR makes use of, indeed bases our action upon, an ever-
growing narrative: reliability challenges arise primarily from weather-
related events.\132\ But even if one were to grant that certain parts
of the United States were experiencing statistically unusual weather
when compared to historical baselines, that has absolutely nothing to
do with whether the markets and regulated utilities are procuring