UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket No. RM16-20-000; Order No. 837

Remedial Action Schemes Reliability Standard

(Issued September 20, 2017)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final rule.

SUMMARY: The Federal Energy Regulatory Commission approves Reliability 

Standard PRC-012-2 (Remedial Action Schemes) submitted by the North American 

Electric Reliability Corporation. The purpose of Reliability Standard PRC-012-2 is 

to ensure that remedial action schemes do not introduce unintentional or unacceptable 

reliability risks to the bulk electric system.

EFFECTIVE DATE: This rule will become effective [60 days after publication in the 

FEDERAL REGISTER].

FOR FURTHER INFORMATION CONTACT:

Syed Ahmad (Technical Information)

Office of Electric Reliability

Division of Reliability Standards and Security

888 First Street, NE

Washington, DC 20426

Telephone: (202) 502-8718

Syed.Ahmad@ferc.gov
Docket No. RM16

-20-000 - 2 -

Alan Rukin (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

Telephone: (202) 502-8502

Alan.Rukin@ferc.gov

SUPPLEMENTARY INFORMATION:
160 FERC ¶ 61,071

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Neil Chatterjee, Chairman;

 Cheryl A. LaFleur, and Robert F. Powelson.

 

Remedial Action Schemes Reliability Standard Docket No. RM16-20-000

ORDER NO. 837

FINAL RULE

(Issued September 20, 2017)

1. Pursuant to section 215 of the Federal Power Act (FPA), the Federal Energy 

Regulatory Commission (Commission) approves Reliability Standard PRC-012-2 

(Remedial Action Schemes).

1

 The North American Electric Reliability Corporation 

(NERC), the Commission-certified Electric Reliability Organization (ERO), submitted 

Reliability Standard PRC-012-2 for approval. The purpose of Reliability Standard 

PRC-012-2 is to ensure that remedial action schemes do not introduce unintentional or 

unacceptable reliability risks to the bulk electric system. In addition, the Commission 

approves the associated violation risk factors and violation severity levels, 

implementation plan, and effective date proposed by NERC. The Commission also 

approves the retirement of currently-effective Reliability Standards PRC-015-1 and

 1 16 U.S.C. 824o.
Docket No. RM16-20-000 - 2 -

PRC-016-1 as well as NERC’s request to withdraw proposed Reliability Standards 

PRC-012-1, PRC-013-1, and PRC-014-1, which are now pending before the 

Commission.

I. Background

A. Section 215 and Mandatory Reliability Standards

2. Section 215 of the FPA requires a Commission-certified ERO to develop 

mandatory and enforceable Reliability Standards, subject to Commission review and 

approval.2

 Once approved, the Reliability Standards may be enforced by the ERO

subject to Commission oversight or by the Commission independently.3

 In 2006, the

Commission certified NERC as the ERO pursuant to section 215 of the FPA.

4

B. Order No. 693

3. On March 16, 2007, the Commission issued Order No. 693, approving 83 of the 

107 Reliability Standards filed by NERC, including Reliability Standards PRC-015-1 

(Remedial Action Scheme Data and Documentation) and PRC-016-1 (Remedial Action

 2 Id. 824o(c), (d).

3 Id. 824o(e).

4 North American Electric Reliability Corp., 116 FERC ¶ 61,062 (ERO 

Certification Order), order on reh’g and compliance, 117 FERC ¶ 61,126 (2006), 

order on compliance, 118 FERC ¶ 61,190, order on reh’g, 119 FERC ¶ 61,046 

(2007), aff’d sub nom. Alcoa Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).
Docket No. RM16-20-000 - 3 -

Scheme Misoperation).5

 Reliability Standard PRC-015-1 requires transmission owners, 

generator owners, and distribution providers to maintain a listing; retain evidence of 

review; and provide documentation of existing, new or functionally modified special 

protection systems.6

 Reliability Standard PRC-016-1 requires transmission owners, 

generator owners, and distribution providers to provide the regional reliability 

organization with documentation, analyses and corrective action plans for misoperation 

of special protection systems.7

4. In Order No. 693, the Commission determined that then-proposed Reliability 

Standard PRC-012-0 was a “fill-in-the-blank” Reliability Standard because, while it 

would require regional reliability organizations to ensure that all special protection 

systems are properly designed, meet performance requirements, and are coordinated with 

other protection systems, NERC had not submitted any regional review procedures with 

the proposed Reliability Standard.8

 Similarly, the Commission determined that proposed 

Reliability Standard PRC-013-0 was a “fill-in-the-blank” Reliability Standard because, 

 5 Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 

FERC Stats. & Regs. ¶ 31,242, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 

(2007).

6 Id. PP 1529-1533.

7 Id. PP 1534-1540.

8 Id. PP 1517-18, 1520. The Commission used the term “fill-in-the-blank” 

standards to refer to proposed Reliability Standards that required the regional reliability 

organizations to develop at a later date criteria for use by users, owners or operators

within each region. Id. P 297.
Docket No. RM16-20-000 - 4 -

although it was intended to ensure that all special protection systems are properly 

designed, meet performance requirements, and are coordinated with other protection 

systems by requiring the regional reliability organization to maintain a database of 

information on special protection systems, NERC had not filed any regional procedures 

for maintaining the databases.9

 Further, the Commission determined that proposed 

Reliability Standard PRC-014-0 was a “fill-in-the-blank” Reliability Standard because, 

while it was proposed to ensure that special protection systems are properly designed, 

meet performance requirements, and are coordinated with other protection systems by 

requiring the regional reliability organization to assess and document the operation, 

coordination, and compliance with NERC Reliability Standards and effectiveness of 

special protection systems at least once every five years, NERC had not submitted 

any regional procedures for this assessment and documentation.10 The Commission 

stated that it would not approve or remand proposed Reliability Standards PRC-012-0, 

PRC-013-0 or PRC-014-0 until NERC submitted the additional necessary information 

to the Commission.11

 9 Id. PP 1521, 1522, 1524.

10 Id. PP 1525, 1526, 1528.

11 Id. PP 1520, 1524, 1528.
Docket No. RM16-20-000 - 5 -

C. Remedial Action Schemes

5. On June 23, 2016, the Commission approved NERC’s revision to the NERC

Glossary of Terms Used in NERC Reliability Standards (NERC Glossary) that redefines 

special protection system to have the same definition as remedial action scheme, effective 

April 1, 2017.12 The NERC Glossary defines remedial action scheme to mean:

A scheme designed to detect predetermined System conditions 

and automatically take corrective actions that may include, but 

are not limited to, adjusting or tripping generation (MW and 

Mvar), tripping load, or reconfiguring a System(s). [Remedial 

Action Schemes (RAS)] accomplish objectives such as:

• Meet requirements identified in the NERC Reliability 

Standards;

• Maintain Bulk Electric System (BES) stability;

• Maintain acceptable BES voltages;

• Maintain acceptable BES power flows;

• Limit the impact of Cascading or extreme events.13

The revised remedial action scheme definition also identifies fourteen items that do not 

individually constitute a remedial action scheme.

 12 N. Am. Elec. Reliability Corp., Docket No. RD16-5-000 (June 23, 2016) 

(delegated letter order); NERC Glossary, http://www.nerc.com/files/glossary_of_terms.p

df.

13 NERC Glossary, http://www.nerc.com/files/glossary_of_terms.pdf; see also 

Revisions to Emergency Operations Reliability Standards; Revisions to Undervoltage 

Load Shedding Reliability Standards; Revisions to the Definition of “Remedial Action 

Scheme” and Related Reliability Standards, Order No. 818, 153 FERC ¶ 61,228, 

at PP 24, 31 (2015).
Docket No. RM16-20-000 - 6 -

D. NERC Petition and Reliability Standard PRC-012-2

6. On August 5, 2016, NERC submitted a petition seeking Commission approval of 

proposed Reliability Standard PRC-012-2.14 NERC contended that Reliability Standard 

PRC-012-2 is just, reasonable, not unduly discriminatory or preferential, and in the public 

interest.15 NERC explained that the intent of Reliability Standard PRC-012-2 is to 

supersede “pending” Reliability Standards PRC-012-1, PRC-013-1, and PRC-014-1 and 

to retire and replace currently-effective Reliability Standards PRC-015-1 and 

PRC-016-1.16 NERC stated that Reliability Standard PRC-012-2 represents substantial 

improvements over these Reliability Standards because it streamlines and consolidates 

existing requirements; corrects the applicability of previously unapproved Reliability 

Standards; and implements a continent-wide remedial action scheme review program.17

7. NERC stated that, in the United States, Reliability Standard PRC-012-2 will apply 

to reliability coordinators, planning coordinators, and remedial action scheme-entities. 

 14 Reliability Standard PRC-012-2 is not attached to this Final Rule. The 

Reliability Standard is available on the Commission’s eLibrary document retrieval 

system in Docket No. RM16-20-000 and is posted on NERC’s website, 

http://www.nerc.com.

15 NERC Petition at 2.

16 NERC noted that it submitted “for completeness” revised versions of Reliability 

Standards PRC-012-1, PRC-013-1, and PRC-014-1 in its petition to revise the definition 

of remedial action scheme, but NERC did not request Commission approval of the 

revised Reliability Standards in that proceeding. Id. at 1 n.5.

17 Id. at 12-13. 
Docket No. RM16-20-000 - 7 -

Reliability Standard PRC-012-2 defines remedial action scheme-entities to include each

transmission owner, generation owner, or distribution provider that owns all or part of a 

remedial action scheme.

8. NERC stated that Reliability Standard PRC-012-2 includes nine requirements that 

combine all existing (both effective and “pending”) Reliability Standards mentioned 

above into a single, consolidated, continent-wide Reliability Standard to address all

aspects of remedial action schemes.

18 NERC explained that all of the requirements in 

Reliability Standard PRC-012-1 except R2 are now covered in Requirements R1, R2, R3, 

R4, R5, R6, and R8 of Reliability Standard PRC-012-2.19 NERC maintained that 

Reliability Standard PRC-012-1, Requirement R2 is “administrative in nature and does 

not contribute to reliability.”20 NERC also stated that it established Reliability Standard 

PRC-012-2, Requirement R9 to replace the mandate in Reliability Standard PRC-013-1 

that responsible entities maintain a remedial action scheme database with pertinent 

technical information for each remedial action scheme.

21 NERC explained that 

Reliability Standard PRC-012-2, Requirements R4 and R6 cover the review and the 

 18 Id. at 3. 

19 Id. at 40.

20 Id. at 41.

21 Id. at 42.
Docket No. RM16-20-000 - 8 -

mandate to take corrective action required by Reliability Standard PRC-014-1.22 NERC 

stated that it integrated the performance requirements in Reliability Standard PRC-015-1 

into Reliability Standard PRC-012-2, Requirements R1, R2, and R3.23 NERC also 

asserted that it integrated the performance requirements in Reliability Standard 

PRC-016-1 into Reliability Standard PRC-012-2, Requirements R5, R6, and R7.24

9. NERC explained how the nine Requirements in Reliability Standard PRC- 012-2 

work together and with other Reliability Standards. According to NERC, Requirements 

R1, R2, and R3, together, establish a process for the reliability coordinator to review new 

or modified remedial action schemes.25 The reliability coordinator must complete the 

review before an entity places a new or functionally modified remedial action scheme

into service.

10. Requirement R4 requires the planning coordinator to perform a periodic 

evaluation of each remedial action scheme within its planning area, at least once every 

five years.26 The evaluation must determine, inter alia, whether each remedial action 

scheme: (1) mitigates the system conditions or contingencies for which it was designed; 

 22 Id.at 43. 

23 Id. at 43-44.

24 Id. at 44-45.

25 Id. at 15-18.

26 Id. at 18-22.
Docket No. RM16-20-000 - 9 -

and (2) avoids adverse interactions with other remedial action scheme and protection 

systems. Requirement R4, Part 4.1.3 footnote 1 defines a certain subset of remedial 

action schemes as “limited impact.” Requirement R4, Part 4.1.3 footnote 1 states: 

“A RAS designated as limited impact cannot, by inadvertent operation or failure to 

operate, cause or contribute to BES Cascading, uncontrolled separation, angular 

instability, voltage instability, voltage collapse, or unacceptably damped oscillations.”27 

Further, Requirement R4, Parts 4.1.3, 4.1.4, and 4.1.5 provide certain exceptions to 

“limited impact” remedial action schemes. For example, Part 4.1.5 states that:

Except for limited impact RAS, a single component failure in 

the RAS, when the RAS is intended to operate does not prevent 

the BES from meeting the same performance requirements 

(defined in Reliability Standard TPL-001-4 or its successor) as 

those required for the events and conditions for which the RAS 

is designed.28

NERC explained that Requirement R4 “does not supersede or modify [planning 

coordinator] responsibilities under Reliability Standard TPL-001-4.”29 NERC continued

that even though Part 4.1.5 exempts “limited impact” remedial action schemes from 

certain aspects of Reliability Standard PRC-012-2, Requirement R4 does not exempt 

 27 Id. at 19 & n.44.

28 Id. at 19.

29 Id. at 28.
Docket No. RM16-20-000 - 10 -

“limited impact” remedial actions schemes from meeting each of the performance 

requirements in Reliability Standard TPL-001-4.30

11. NERC stated that prior to development of Reliability Standard PRC-012-2, 

two NERC Regions, the Northeast Power Coordinating Council (NPCC) and the Western 

Electric Coordinating Council (WECC), used their own remedial action scheme

classification regimes to identify remedial action schemes that would meet criteria similar 

to those for remedial action schemes described as “limited impact” in Reliability 

Standard PRC-012-2.31 NERC continued that the standard drafting team identified the 

Local Area Protection Scheme (LAPS) classification in WECC and the Type III 

classification in NPCC as consistent with the “limited impact” designation.32 According 

to NERC, remedial action schemes implemented prior to the effective date of Reliability 

Standard PRC-012-2 that have gone through the regional review processes of WECC or 

NPCC and that are classified as either a LAPS by WECC or a Type III by NPCC would 

be considered a “limited impact” remedial action scheme for purposes of Reliability 

Standard PRC-012-2.33

 30 Id. at 28-29.

31 Id. at 25.

32 Id.at 25-26.

33 Id. at 26. 
Docket No. RM16-20-000 - 11 -

12. Requirements R5, R6, and R7 pertain to the analysis of each remedial action 

scheme operation or misoperation.34 A remedial action scheme-entity must perform an 

analysis of each remedial action scheme operation or misoperation and provide the results 

to the reviewing reliability coordinator. Further, the remedial action scheme-entity must 

develop and submit a corrective action plan to the reviewing reliability coordinator after 

learning of a deficiency with its remedial action scheme, implement the corrective action 

plan, and update it as necessary. Requirement R8 requires periodic testing of remedial 

action scheme performance: every six years for normal remedial action schemes and 

every 12 years for “limited impact” remedial action schemes.

35 Requirement R9 requires

the reliability coordinator to annually update its remedial action scheme database.36

13. NERC proposed an implementation plan that includes an effective date for 

Reliability Standard PRC-012-2 that is the first day of the first calendar quarter that is 

thirty-six months after the date that the Commission approves the Reliability Standard. 

Concurrent with the effective date, the implementation plan calls for the retirement of 

currently-effective Reliability Standards PRC-015-1 and PRC-016-1 and withdrawal of 

“pending” Reliability Standards PRC-012-1, PRC-013-1, and PRC-014-1.

 34 Id. at 29-34. 

35 Id. at 34-36. 

36 Id. at 36-38. 
Docket No. RM16-20-000 - 12 -

E. Notice of Proposed Rulemaking

14. On January 19, 2017, the Commission issued a Notice of Proposed Rulemaking 

proposing to approve Reliability Standard PRC-012-2.37 The NOPR also proposed to 

clarify that, consistent with NERC’s representation in its petition, Reliability Standard 

PRC-012-2 will not modify or supersede any system performance obligations under 

Reliability Standard TPL-001-4.38 In addition, the NOPR proposed to approve the 

associated violation risk factors and violation severity levels, implementation plan, and 

effective date proposed by NERC.39 The NOPR further proposed to approve the 

withdrawal of “pending” Reliability Standards PRC-012-1, PRC-013-1, and PRC-014-1 

and retirement of currently-effective Reliability Standards PRC-015-1 and PRC-016-1, as 

proposed by NERC.40

15. In response to the NOPR, entities filed seven sets of comments. We address 

below the issues raised in the NOPR and comments. The Appendix to this Final Rule 

lists the entities that filed comments in response to the NOPR.

 37 Remedial Action Schemes Reliability Standard, Notice of Proposed Rulemaking, 

82 FR 9702 (Jan. 19, 2017), 158 FERC ¶ 61,042 (2017) (NOPR).

38 NOPR, 158 FERC ¶ 61,042 at P 16.

39 Id. P 14.

40 Id.
Docket No. RM16-20-000 - 13 -

II. Discussion

16. Pursuant to section 215(d)(2) of the FPA, we hereby approve Reliability Standard 

PRC-012-2.41 Reliability Standard PRC-012-2 promotes efficiency and clarity by 

addressing all aspects of remedial action schemes in a single, continent-wide Reliability 

Standard. Reliability Standard PRC-012-2 enhances reliability by assigning specific 

remedial action scheme responsibilities to appropriate functional entities. Further, 

Reliability Standard PRC-012-2 improves reliability by establishing a centralized process

to review new or modified remedial action schemes prior to implementation, by requiring

periodic evaluations, tests, and operational analyses of each remedial action scheme, and 

by requiring an annual update of an area-wide remedial action scheme database. We 

determine that Reliability Standard PRC-012-2 satisfies the relevant directives in Order 

No. 693 for the ERO to provide additional information regarding review procedures for 

remedial action schemes (then called special protection systems) and to establish 

continent-wide uniformity.42

17. We also approve the associated violation risk factors and violation severity levels, 

implementation plan, and effective date proposed by NERC. In addition, we approve, 

upon the effective date of Reliability Standard PRC-012-2, the withdrawal of pending 

Reliability Standards PRC-012-1, PRC-013-1, and PRC-014-1 and the retirement of 

 41 16 U.S.C. 824o(d)(2).

42 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at PP 297-298, 1517-1520.
Docket No. RM16-20-000 - 14 -

currently-effective Reliability Standards PRC-015-1 and PRC-016-1 due to their 

consolidation with proposed Reliability Standard PRC-012-2.

A. Impact of Reliability Standard PRC-012-2 on Compliance with

Reliability Standard TPL-001-4

NOPR

18. The NOPR sought comments on its proposal to clarify that Reliability Standard 

PRC-012-2 will not modify or supersede any system performance obligation under 

Reliability Standard TPL-001-4. The NOPR also sought comments on the processes 

used to ensure LAPS or Type III remedial action schemes’ compliance with Reliability 

Standard TPL-001-4 prior to the effective date of Reliability Standard PRC-012-2.

Comments

19. NERC, Joint ISOs, and the EEI support the Commission’s proposal to approve 

Reliability Standard PRC-012-2 with a clarification that it does not modify or supersede 

any system performance obligations under Reliability Standard TPL-001-4.43 NERC 

states that Reliability Standard PRC-012-2 merely adds design, implementation, and 

review requirements ensuring that remedial action schemes enhance reliability and do 

not introduce unintentional or unacceptable reliability risks.44 NERC and Joint ISOs

state that Reliability Standard PRC-012-2 does not supersede or modify the system 

performance requirements of Reliability Standard TPL-001-4 because responsible 

 43 NERC Comments at 4; Joint ISO Comments at 2; EEI Comments at 4.

44 NERC Comments at 5.
Docket No. RM16-20-000 - 15 -

entities must still assume that all remedial action schemes operate correctly, guaranteeing 

a non-consequential load loss by less than 75 MW.45 Joint ISOs believe that no 

clarification to Reliability Standard PRC-012-2 is necessary; but if the Commission 

determines that some clarification is necessary, the Commission may confirm that under 

Reliability Standard TPL-001-4, responsible entities can assume that all remedial action 

schemes operate as designed.46 EEI states that while it is unlikely that the exceptions 

in Reliability Standard PRC-012-2 would be interpreted by industry as exempting any 

of the performance requirements in Reliability Standard TPL-001-4, EEI is supportive 

of the proposed clarification since such clarification would remove any ambiguity.47

20. NESCOE contends that, absent confirmation that Reliability Standard TPL-001-4 

allows responsible entities to assume that all remedial action schemes operate properly, a 

clarification that Reliability Standard PRC-012-2 does not modify or supersede any 

system performance obligations under Reliability Standard TPL-001-4 may be 

misinterpreted by entities, requiring actions that would increase material costs without 

 45 Id. at 5; Joint ISO Comments at 2.

46 Joint ISO Comments at 2.

47 EEI Comments at 4.
Docket No. RM16-20-000 - 16 -

benefit.48 NESCO states that reliability gains must be measured against the risk and cost 

associated with any standard.49

21. NERC states that LAPS in WECC and Type III remedial actions schemes in 

NPCC must be compliant with Reliability Standard TPL-001-4 before and after the 

effective date of proposed Reliability Standard PRC-012-2.50 According to NERC, 

Reliability Standard TPL-001-4 does not distinguish between different types of remedial 

action schemes or exempt LAPS or Type III remedial action schemes from any of the 

performance requirements.51 NERC and Joint ISOs state that additional regional controls 

that maintain remedial action scheme compliance with the performance requirements of 

Reliability Standard TPL-001-4 are in place.

52

22. EEI questions the relevancy of asking the industry to comment on WECC LAPS 

or NPCC Type III remedial action schemes reclassification as “limited impact” remedial 

action schemes.53 EEI contends that once the Commission approves Reliability Standard 

 48 NESCO Comments at 2.

49 Id.

50 NERC Comments at 5.

51 Id. at 6.

52 Id.; Joint ISO Comments at 3.

53 EEI Comments at 5.
Docket No. RM16-20-000 - 17 -

PRC-012-2, WECC and NPCC must be compliant regardless. EEI believes that insights 

into processes ensuring compliance with Reliability Standard PRC-012-2 are irrelevant.54

Commission Determination

23. We adopt our NOPR proposal and clarify that Reliability Standard PRC-012-2 

does not modify or supersede any system performance obligations under Reliability 

Standard TPL-001-4. We agree with and, thus, adopt NERC’s explanation:

Nothing in proposed Reliability Standard PRC-012-2 or the 

designation of a RAS as “limited impact” exempts an entity 

from meeting its performance requirements under [Reliability 

Standard] TPL-001-4, including the requirement that NonConsequential Load Loss may not exceed 75 MW for certain 

Category P1, P2, or P3 contingencies, as provided in Table 1 

and footnote 12 of TPL-001-4.

In performing the assessments required pursuant to 

Reliability Standard TPL-001-4, an entity must consider all 

RAS, whether designated as “limited impact” or not. While 

Reliability Standard TPL-001-4, Requirement R2, Part 2.7.1 

recognizes that entities may use a RAS as a method for meeting 

the performance obligations of Table 1, TPL-001-4 does not 

distinguish between different types of RAS. As such, entities 

must satisfy the performance requirements of TPL-001-4 

considering the actions of “limited impact” RAS and nonlimited impact RAS alike.55

 54 Id.

55 NERC Comments at 5. In response to the requests by Joint ISOs and NESCOE 

for confirmation that Reliability Standard TPL-001-4 allows responsible entities to 

assume that all remedial action schemes operate properly, the Commission declines to 

interpret Reliability Standard TPL-001-4 in this proceeding. However, this Final Rule 

approving Reliability Standard PRC-012-2 in no way modifies the requirements of 

Reliability Standard TPL-001-4 or the compliance obligations associated with Reliability 

Standard TPL-001-4.
Docket No. RM16-20-000 - 18 -

This clarification should help entities avoid confusion regarding compliance obligations 

when implementing PRC-012-2.

24. In addition, we accept NERC’s assurance that LAPS in WECC and Type III 

remedial actions schemes in NPCC must be compliant with Reliability Standard 

TPL-001-4 before and after the effective date of proposed Reliability Standard 

PRC-012-2.56

B. Definition of “Limited Impact” Remedial Action Schemes

NOPR

25. The NOPR sought comment on whether NERC should define the term “limited 

impact” remedial action schemes in the NERC Glossary.

Comments

26. NERC, Joint ISOs, and EEI contend that NERC should not define the term 

“limited impact” remedial action scheme in the NERC Glossary.57 NERC states that it 

typically develops terms in the NERC Glossary for one of two reasons: “(1) to establish 

a single meaning for a term or concept used across several different Reliability Standards 

or multiple times within a single Reliability Standard, or (2) to provide for a more 

 56 We note that WECC’s and NPCC’s remedial action scheme criteria and 

associated regional terms found in the “Technical Justification” section of Reliability 

Standard PRC-012-2 were not submitted for approval by NERC and as such are not 

part of this proceeding.

57 NERC Comments at 8; Joint ISO Comments at 3; EEI at 5.
Docket No. RM16-20-000 - 19 -

readable standard by creating a shorthand reference to avoid unnecessary repetition.”58 

NERC contends that neither reason exists for “limited impact” remedial action 

schemes.59

27. NERC and EEI maintain that remedial action schemes vary widely in complexity 

and impact on the bulk electric system.60 NERC and EEI explain that NERC should not 

define “limited impact” remedial action schemes because not all remedial action schemes 

impact the bulk electric system similarly and the diversity of remedial action schemes 

makes it difficult to establish a common definition for North America.61

28. NERC, Joint ISOs, and EEI assert that other comprehensive lists may establish a 

baseline definition for “limited impact” remedial action schemes.

62 Joint ISOs note that 

the performance criteria described in Reliability Standard PRC-012-2, Requirement 4.1.3, 

footnote 1 provide an adequate level of guidance.63 MISO contends that NERC need not 

define “limited impact” remedial action scheme in the NERC Glossary.

64

 58 NERC Comments at 8.

59 Id.

60 NERC Comments at 9; EEI Comments at 5.

61 Id.

62 NERC Comments at 9; Joint ISO Comments at 3; EEI Comments at 6.

63 Joint ISO Comments at 3-4.

64 MISO Comments at 6.
Docket No. RM16-20-000 - 20 -

29. Bonneville and ITC contend that NERC should define the term “limited impact” 

remedial action schemes in the NERC Glossary.65 Bonneville states that the footnote in 

Reliability Standard PRC-012-2 only reiterates the substantive requirements of “limited 

impact” remedial action schemes under Requirement R4.3.1 and does not clarify how 

“limited impact” remedial action schemes differ from normal remedial action schemes.

66

Bonneville proposes the following definition for “limited impact” remedial action 

schemes:

A remedial action scheme whose operation or misoperation 

only affects the local area defined by the RAS-entity that owns 

all of part of the remedial action scheme and does not affect the 

BES of any adjacent Transmission Owners, Transmission 

Operators, Generation Owners, or Generation Operators.67

ITC also states that the Commission should issue a directive to NERC to define “limited 

impact” remedial action schemes in the NERC Glossary.68 ITC states that doing so 

avoids confusion while ensuring consistency, facilitates the use of the term in other 

Reliability Standards, and enhances the overall usefulness of the NERC Glossary.69

 65 Bonneville Comments at 2; ITC Comments at 1.

66 Bonneville Comments at 2.

67 Id.

68 ITC Comments at 1.

69 Id. at 2.
Docket No. RM16-20-000 - 21 -

Commission Determination

30. We determine not to require NERC to define “limited impact” remedial action 

schemes in the NERC Glossary. We agree with NERC, Joint ISOs, and EEI that a 

definition of “limited impact” remedial action schemes is unnecessary at this time given 

the diversity among the different types, functions, and placements of remedial action 

schemes across North America. In addition, only Reliability Standard PRC-012-2 uses 

the term “limited impact” remedial action schemes, thus eliminating one of the principal 

reasons for normally including terms in the NERC Glossary (i.e., to establish a single 

meaning for a term or concept used across several different Reliability Standards). 

Should this situation change, the Commission may reconsider this determination.

C. Other Issues

Comments

31. MISO contends that the Commission should not approve Reliability Standard 

PRC-012-2 as proposed.70 MISO contends that oversight of remedial action schemes 

would be difficult for reliability coordinators and planning coordinators when remedial 

action schemes span multiple footprints.71 MISO also contends that Reliability Standard 

PRC-012-2 creates a geographical variation in transmission system characteristics which 

result in uneven distribution of coordination burden and duplicative work on remedial 

 70 MISO Comments at 2.

71 Id.
Docket No. RM16-20-000 - 22 -

action schemes.72 MISO contends that the planning assessment performance 

requirements in Reliability Standard PRC-012-2 are better placed in Reliability Standard 

TPL-001-4 to avoid redundancies.

73 Finally, MISO proposes a five-year evaluation of 

remedial action schemes, which includes a renewal requirement to benefit efficient 

operations.74

32. Bonneville contends that Reliability Standard PRC-012-2, Requirement R2 gives 

reliability coordinators too much time to complete reviews of remedial action schemes.75 

Bonneville states that Reliability Standard PRC-012-2, Requirement R2 provides

reliability coordinators four calendar months to review a remedial action scheme.76 

Bonneville states that in the Western Interconnection, these reviews are currently 

completed in two weeks. Bonneville continues that Reliability Standard PRC-012-2 

allows an additional fourteen weeks for review, which would prevent Bonneville from 

completing remedial action scheme projects in a timely manner.77 Bonneville proposes 

 72 Id. at 3.

73 Id. at 4-5.

74 Id. 6-7.

75 Bonneville Comments at 2.

76 Id.

77 Id. at 3.
Docket No. RM16-20-000 - 23 -

that Reliability Standard PRC-012-2, Requirement R2 should require reliability 

coordinators to complete their reviews within four weeks.78

Commission Determination

33. MISO’s opposition to Reliability Standard PRC-012-2 is largely based on 

perceived “inefficiencies” created by the Reliability Standard because it allegedly lacks 

regional coordination between reliability coordinators and planning coordinators and 

because of “redundancies” between PRC-012-2 and Reliability Standard TPL-001-4. 

We are not persuaded that MISO’s concerns justify remanding Reliability Standard 

PRC-012-2. As discussed above, we determine that the Reliability Standard PRC-012-2 

satisfies section 215(d)(2) of the FPA in that it is just, reasonable, not unduly 

discriminatory or preferential, and in the public interest. MISO accepts that Reliability 

Standard PRC-012-2 “shifts responsibility from the eight Regional Reliability 

Organizations (RROs) to Reliability Coordinators and Planning Coordinators” and MISO 

“agrees that the Reliability Coordinators and Planning Coordinators are best positioned to 

perform review and evaluation tasks associated with RAS.”79 We also note that other 

commenters, including Joint ISOs, do not share MISO’s concerns and support approval 

of Reliability Standard PRC-012-2 as drafted.

80 To the extent that MISO continues to 

 78 Id.

79 MISO Comments at 2.

80 Joint ISOs Comments at 1.
Docket No. RM16-20-000 - 24 -

believe that improvements should be made to Reliability Standard PRC-012-2, MISO 

may pursue any modifications through the NERC standards development process.81

34. We are not persuaded by Bonneville’s comments regarding the period that 

reliability coordinators have to review remedial action schemes. NERC stated that 

Reliability Standard PRC-012-2, Requirement R2 establishes a comprehensive, consistent 

review process that includes a detailed checklist that reliability coordinators must use to 

identify design and implementation aspects of the remedial action schemes that are 

critical to an effective framework.82 NERC also stated that allowing four months to 

complete this detailed review is consistent with industry practice, provides adequate time 

for a complete review, and includes additional flexibility for unique or unforeseen 

circumstances.83 While four calendar months may be longer than what is typical in the 

Western Interconnection, we determine that NERC’s proposal is reasonable because it 

provides a single, consistent, continent-wide timeframe for reviews. Moreover, as 

 81 With respect to MISO’s proposal that each remedial action scheme be renewed 

every five years, NERC explained that Reliability Standard PRC-012-2, Requirement R4 

provides for periodic remedial action scheme evaluations (i.e., at least every five years) 

by planning coordinators that will result in one of three determinations: (1) affirmation 

that the existing remedial action scheme is effective; (2) identification of changes needed 

to the existing remedial action scheme; or (3) justification for remedial action scheme 

retirement. NERC Petition at 21. Provided that the remedial action scheme is 

determined to be effective, is made effective, or retired, we see no reliability reason to 

direct inclusion of an additional renewal sub-requirement.

82 NERC Petition at 17.

83 Id.
Docket No. RM16-20-000 - 25 -

Bonneville recognizes, Reliability Standard PRC-012-2, Requirement R2 permits entities 

to use a mutually agreed upon schedule instead of the four-month default timeline 

provided for in Requirement R2. Accordingly, Bonneville’s request is denied on this 

issue.

III. Information Collection Statement

35. The collection of information addressed in this final rule is subject to review by 

the Office of Management and Budget (OMB) under section 3507(d) of the Paperwork 

Reduction Act of 1995.84 OMB’s regulations require approval of certain information 

collection requirements imposed by agency rules.85 Upon approval of a collection(s) 

of information, OMB will assign an OMB control number and an expiration date. 

Respondents subject to the filing requirements of a rule will not be penalized for failing 

to respond to these collections of information unless the collections of information 

display a valid OMB control number.

36. Public Reporting Burden: The number of respondents below is based on 

an examination of the NERC compliance registry for reliability coordinators, planning 

coordinators, transmission owners, generation owners, and distribution providers and 

an estimation of how many entities from that registry will be affected by the proposed 

Reliability Standard. At the time of Commission review of Reliability Standard 

PRC-012-2, 15 reliability coordinators, 71 planning coordinators, 328 transmission 

 84 44 U.S.C. 3507(d).

85 5 CFR 1320.11.
Docket No. RM16-20-000 - 26 -

owners, 930 generation owners, and 367 distribution providers in the United States were 

registered in the NERC compliance registry. However, under NERC’s compliance 

registration program, entities may be registered for multiple functions, so these numbers 

incorporate some double counting. The Commission notes that many generation sites 

share a common generation owner.

37. Reliability Standards PRC-015-1 and PRC-016-1 are in the Reliability Standards 

approved in FERC-725A, (OMB Control No. 1902-0244). Reliability Standards PRC015-1 and PRC-016-1 will be retired when Reliability Standard PRC-012-2 becomes 

effective, which will reduce the burden in FERC-725A.86

38. Reliability Standard PRC-012-2 sets forth Requirements for remedial action 

schemes to ensure that remedial action schemes do not introduce unintentional or 

unacceptable reliability risks to the bulk electric system and are coordinated to provide 

the service to the system as intended. Reliability Standard PRC-012-2 improves upon the 

existing Reliability Standards because it removes ambiguity in NERC’s original “fill-inthe-blank” Reliability Standards by assigning responsibility to appropriate functional 

entities. Reliability Standard PRC-012-2 also streamlines and consolidates the remedial 

action scheme Reliability Standards into one clear, effective Reliability Standard under 

Information Collection FERC-725G.

 86 The Commission is being conservative and not subtracting hours at this time 

from FERC-725A.
Docket No. RM16-20-000 - 27 -

39. The following table illustrates the estimated burden to be applied to FERC-725G

information collection.87

FERC-725G in RM16-20-000 (Mandatory Reliability Standards: Reliability Standard PRC-012-2) 

Requirement 

and 

Respondent 

Category for 

PRC-012-2

Number of 

Respondents

(1)

Number of 

Responses per 

Respondent

(2)

Total Number 

of Responses 

(1)*(2)=(3)

Average 

Burden Hours 

& Cost per 

Response88

(4)

Annual Burden 

Hours & Total 

Annual Cost 

(3)*(4)=(5)

R1. Each 

RAS-entity 

(TO, GO, DP)

1,595 1 1,595

(Eng.) 24 hrs. 

($1,543); (R.K.) 

12 hrs. ($453) 

57,420 hrs. (38,280

Eng., 19,140 R.K.); 

$3,183,556

($2,461,021 Eng., 

$722,535 R.K.)

R2. Each 

Reliability 

Coordinator

15 1 15

(Eng.) 16 hrs. 

($1,029); (R.K.) 

4 hrs. ($151)

300 hrs. (240 Eng., 60 

R.K.); $17,695 

($15,430 Eng., $2,265

R.K.)

R4. Each 

Planning 

Coordinator

71 1 71

(Eng.) 16 hrs. 

($1,029); (R.K.) 

4 hrs. ($151)

1,420 hrs. (1,136

Eng., 284 R.K.); 

$85,754 ($73,033

Eng., $10,721 R.K.)

R5, R6, R7, 

and R8. Each 

RAS-entity 

(TO, GO, DP)

1,595 1 1,595

(Eng.) 24 hrs. 

($1,543); (R.K.) 

12 hrs. ($453)

57,420 hrs. (38,280

Eng., 19,140 R.K.); 

$3,183,556

($2,461,021 Eng., 

$722,535 R.K.)

R9. Each 

Reliability 

Coordinator

15 1 15

(Eng.) 10 hrs. 

($653); (R.K.) 4 

hrs. ($151)

210 hrs. (150 Eng., 60

R.K.); $11,909

($9,644 Eng., $2,265

R.K.)

TOTAL

3,291

116,770 hrs. (78,086

Eng., 38,684 R.K.); 

$6,480,470 

($5,020,149 Eng.;

$1,460,321 R.K.)

 87 In the burden table, engineering is abbreviated as “Eng.” and record keeping is

abbreviated as “R.K.”

88 The estimates for cost per response are derived using the following formula: 

Burden Hours per Response * $/hour = Cost per Response. The $64.29/hour figure for 

an engineer and the $37.75/hour figure for a record clerk are based on the average salary 

plus benefits data from the Bureau of Labor Statistics.
Docket No. RM16-20-000 - 28 -

Title: FERC-725A (Mandatory Reliability Standards); FERC-725G (Mandatory 

Reliability Standards: PRC-012-2)

Action: Revision to existing collections.

OMB Control No: 1902-0244 (FERC-725A); 1902-0252 (FERC-725G)

Respondents: Business or other for profit, and not for profit institutions.

Frequency of Responses: Annually

Necessity of the Information: Reliability Standard PRC-012-2 sets forth Requirements 

for remedial action schemes to ensure that remedial action schemes do not introduce 

unintentional or unacceptable reliability risks to the bulk electric system and are 

coordinated to provide the service to the system as intended.

Internal review: The Commission has assured itself, by means of its internal review, 

that there is specific, objective support for the burden estimates associated with the

information requirements.

40. Interested persons may obtain information on the reporting requirements by 

contacting the Federal Energy Regulatory Commission, Office of the Executive Director, 

888 First Street, NE, Washington, DC 20426 [Attention: Ellen Brown, e-mail: 

DataClearance@ferc.gov, phone: (202) 502-8663, fax: (202) 273-0873].

41. Comments concerning the information collection in this Final Rule and the 

associated burden estimates should be sent to the Office of Management and Budget, 

Office of Information and Regulatory Affairs [Attention: Desk Officer for the Federal 

Energy Regulatory Commission]. For security reasons, comments should be sent by 

e-mail to OMB at the following e-mail address: oira_submission@omb.eop.gov. Please 
Docket No. RM16-20-000 - 29 -

reference FERC-725A and FERC-725G and the docket number of this Final Rule, 

Docket No. RM16-20-000, in your submission.

IV. Environmental Analysis

42. 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.89 The action proposed here falls within the categorical 

exclusion in the Commission’s regulations for rules that are clarifying, corrective or 

procedural, for information gathering, analysis, and dissemination.90

V. Regulatory Flexibility Act

43. The Regulatory Flexibility Act of 1980 (RFA) generally requires a description and 

analysis of proposed rules that will have significant economic impact on a substantial 

number of small entities.91

44. In the NOPR, the Commission proposed that Reliability Standard PRC-012-2 will 

apply to approximately 1681 entities in the United States.

92 The Commission did not 

receive any comments on the impact on small entities. Comparison of the applicable 

entities with the Commission’s small business data indicates that approximately 1,025 are 

 89 Regulations Implementing the National Environmental Policy Act of 1969, 

Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. Preambles 1986-

1990 ¶ 30,783 (1987).

90 18 CFR 380.4(a)(2)(ii).

91 5 U.S.C. 601-612.

92 NOPR, 158 FERC ¶ 61,042 at P 26.
Docket No. RM16-20-000 - 30 -

small entities or 61 percent of the respondents affected by proposed Reliability Standard 

PRC-012-2.

93 The Commission estimates for these small entities, Reliability Standard 

PRC-012-2 may need to be evaluated and documented every five years with a cost of 

$6,322 for each evaluation. The Commission views this as a minimal economic impact 

for each entity. Accordingly, the Commission certifies that Reliability Standard 

PRC-012-2 will not have a significant economic impact on a substantial number of small 

entities.

VI. Document Availability

45. In addition to publishing the full text of this document in the Federal Register, 

the Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through the Commission’s Home Page 

(http://www.ferc.gov) and in the Commission’s Public Reference Room during normal 

business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington DC 20426.

46. 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 

 93 The Small Business Administration sets the threshold for what constitutes a 

small business. Public utilities may fall under one of several different categories, each 

with a size threshold based on the company’s number of employees, including affiliates, 

the parent company, and subsidiaries. For the analysis in this rulemaking, we apply a 

500 employee threshold for each affected entity. Each entity is classified as Electric Bulk 

Power Transmission and Control (NAICS code 221121).
Docket No. RM16-20-000 - 31 -

document in eLibrary, type the docket number excluding the last three digits of this 

document in the docket number field.

47. User assistance is available for eLibrary and the Commission’s website during 

normal business hours from FERC Online Support at 202-502-6652 (toll free at 1-866-

208-3676) or e-mail at ferconlinesupport@ferc.gov, or the Public Reference Room at 

(202) 502-8371, TTY (202)502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov.

VII. Effective Date and Congressional Notification

48. The final rule is effective [INSERT DATE 60 days from publication in 

FEDERAL REGISTER]. The Commission has determined, with the concurrence of the 

Administrator of the Office of Information and Regulatory Affairs of OMB, that this rule 

is not a “major rule” as defined in section 351 of the Small Business Regulatory 

Enforcement Fairness Act of 1996. This final rule is being submitted to the Senate, 

House, and Government Accountability Office.

By the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.
Docket No. RM16-20-000 - 32 -

Appendix

Bonneville Power Administration (Bonneville)

Edison Electric Institute (EEI)

International Transmission Company d/b/a ITC Transmission, Michigan Electric 

Transmission Company, LLC, ITC Midwest LLC and ITC Great Plains, LLC (together, 

ITC)

Midcontinent Independent System Operator, Inc. (MISO)

New England States Committee on Electricity (NESCOE)

New York Independent System Operator, Independent Electricity System Operator, ISO 

New England, Inc. and Electric Reliability Council of Texas, Inc. (together, Joint ISOs)

North American Electric Reliability Corporation (NERC)