143 FERC ¶ 61,147

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket No. RM12-22-000; Order No. 779]

Reliability Standards for Geomagnetic Disturbances

(Issued May 16, 2013)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final Rule.

SUMMARY: Under section 215 of the Federal Power Act, the Federal Energy 

Regulatory Commission (Commission) directs the North American Electric Reliability 

Corporation (NERC), the Commission-certified Electric Reliability Organization, to 

submit to the Commission for approval proposed Reliability Standards that address the 

impact of geomagnetic disturbances (GMD) on the reliable operation of the Bulk-Power 

System. The Commission directs NERC to implement the directive in two stages. In the 

first stage, NERC must submit, within six months of the effective date of this Final Rule, 

one or more Reliability Standards that require owners and operators of the Bulk-Power 

System to develop and implement operational procedures to mitigate the effects of GMDs 

consistent with the reliable operation of the Bulk-Power System. In the second stage, 

NERC must submit, within 18 months of the effective date of this Final Rule, one or 

more Reliability Standards that require owners and operators of the Bulk-Power System 

to conduct initial and on-going assessments of the potential impact of benchmark GMD
Docket No. RM12-22-000 - 2 -

events on Bulk-Power System equipment and the Bulk-Power System as a whole. The 

Second Stage GMD Reliability Standards must identify benchmark GMD events that 

specify what severity GMD events a responsible entity must assess for potential impacts 

on the Bulk-Power System. If the assessments identify potential impacts from 

benchmark GMD events, the Reliability Standards should require owners and operators 

to develop and implement a plan to protect against instability, uncontrolled separation, or 

cascading failures of the Bulk-Power System, caused by damage to critical or vulnerable 

Bulk-Power System equipment, or otherwise, as a result of a benchmark GMD event. 

The development of this plan cannot be limited to considering operational procedures or 

enhanced training alone, but will, subject to the potential impacts of the benchmark GMD 

events identified in the assessments, contain strategies for protecting against the potential 

impact of GMDs based on factors such as the age, condition, technical specifications, 

system configuration, or location of specific equipment. These strategies could, for 

example, include automatically blocking geomagnetically induced currents from entering 

the Bulk-Power System, instituting specification requirements for new equipment, 

inventory management, isolating certain equipment that is not cost effective to retrofit, or 

a combination thereof.

EFFECTIVE DATE: This rule will become effective [INSERT DATE 60 days after 

publication in the FEDERAL REGISTER].
Docket No. RM12-22-000 - 3 -

FOR FURTHER INFORMATION CONTACT:

Regis Binder (Technical Information)

Office of Electric Reliability

Division of Reliability Standards and Security

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(301) 665-1601

Regis.Binder@ferc.gov

Matthew Vlissides (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-8408

Matthew.Vlissides@ferc.gov

SUPPLEMENTARY INFORMATION:
143 FERC ¶ 61,147

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Jon Wellinghoff, Chairman;

 Philip D. Moeller, John R. Norris,

Cheryl A. LaFleur, and Tony Clark.

Reliability Standards for Geomagnetic Disturbances Docket No. RM12-22-000

Order No. 779

FINAL RULE

(Issued May 16, 2013)

1. Pursuant to section 215(d)(5) of the Federal Power Act (FPA),1 the Commission 

directs the North American Electric Reliability Corporation (NERC), the Commissioncertified Electric Reliability Organization (ERO), to submit for approval Reliability 

Standards (GMD Reliability Standards) that address the risks posed by geomagnetic 

disturbances (GMD) to the reliable operation of the Bulk-Power System. 

2. The Commission directs NERC to implement the directive in two stages. In the 

first stage, NERC must submit, within six months of the effective date of this Final Rule, 

one or more Reliability Standards that require owners and operators of the Bulk-Power 

System to develop and implement operational procedures to mitigate the effects of GMDs 

consistent with the reliable operation of the Bulk-Power System. In the second stage, 

 1 16 U.S.C. 824o(d)(5) (2006).
Docket No. RM12-22-000 - 2 -

NERC must submit, within 18 months of the effective date of this Final Rule, one or 

more Reliability Standards that require owners and operators of the Bulk-Power System 

to conduct initial and on-going assessments of the potential impact of benchmark GMD

events on Bulk-Power System equipment and the Bulk-Power System as a whole. The 

Second Stage GMD Reliability Standards must identify “benchmark GMD events” that 

specify what severity GMD events a responsible entity must assess for potential impacts 

on the Bulk-Power System. The benchmark GMD events must be technically justified 

because the benchmark GMD events will define the scope of the Second Stage GMD 

Reliability Standards (i.e., responsible entities should not be required to assess GMD 

events more severe than the benchmark GMD events). If the assessments identify 

potential impacts from benchmark GMD events, the Reliability Standards should require 

owners and operators to develop and implement a plan to protect against instability, 

uncontrolled separation, or cascading failures of the Bulk-Power System, caused by 

damage to critical or vulnerable Bulk-Power System equipment, or otherwise, as a result 

of a benchmark GMD event. The plan cannot be limited to considering operational 

procedures or enhanced training alone. Rather, the plan must, subject to the potential

impacts of the benchmark GMD events identified in the assessments, contain strategies 

for protecting against the potential impact of GMDs based on factors such as the age, 

condition, technical specifications, system configuration, or location of specific 

equipment. These strategies could, for example, include automatically blocking 

geomagnetically induced currents (GICs) from entering the Bulk-Power System, 

instituting specification requirements for new equipment, inventory management, 
Docket No. RM12-22-000 - 3 -

isolating certain equipment that is not cost effective to retrofit, or a combination thereof. 

The Reliability Standards should include Requirements whose goal is to prevent 

instability, uncontrolled separation, or cascading failures of the Bulk-Power System when 

confronted with a benchmark GMD event. Given that the scientific understanding of 

GMDs is still evolving, we recognize that Reliability Standards cannot be expected to 

protect against all GMD-induced outages.

3. We take this action based on the potentially severe, wide-spread impact on the 

reliable operation of the Bulk-Power System that can be caused by GMD events and the 

absence of existing Reliability Standards to address GMD events. We are not directing 

the ERO to include any specific Requirements in the GMD Reliability Standards nor are 

we pre-judging what the ERO eventually submits for approval. Instead, in this Final 

Rule, we identify issues that should be considered in the NERC standards development 

process. We expect NERC to explain how the proposed GMD Reliability Standards 

address these issues when the Reliability Standards are submitted for Commission 

approval.

I. Background

A. Section 215 and Mandatory Reliability Standards

4. Section 215 of the FPA requires the Commission to certify an ERO to develop 

mandatory and enforceable Reliability Standards, subject to Commission review and 
Docket No. RM12-22-000 - 4 -

approval.2

 Once approved, the Reliability Standards may be enforced in the United 

States by the ERO, subject to Commission oversight, or by the Commission 

independently.

5. Pursuant to FPA section 215(d)(5), 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.3

 

B. Geomagnetic Disturbances

6. A GMD, caused by solar events, results in distortions to the earth’s magnetic field, 

can be of varying intensity, and has in the past impacted the operation of pipelines, 

communications systems, and electric power systems.4

 The interaction of the earth’s 

magnetic field and solar events can cause low frequency GICs to flow along the surface 

of the earth and in the oceans. Reliability issues arise when GICs enter the Bulk-Power 

System from the earth. Because many Bulk-Power System transformers are grounded, 

the GIC appears as electrical current to the Bulk-Power System and flows through the 

 2 16 U.S.C. 824o (2006).

3 16 U.S.C. 824o(d)(5); 18 CFR 39.5(f) (2012).

4 Oak Ridge National Laboratory, Electric Utility Industry Experience with 

Geomagnetic Disturbances at xiii (1991), available at http://www.ornl.gov/~webworks/

cpr/v823/rpt/51089.pdf.
Docket No. RM12-22-000 - 5 -

ground connection and conductors, such as transformers and transmission lines.5

 GICs

can cause “half-cycle saturation” of high-voltage Bulk-Power System transformers, 

which can lead to increased consumption of reactive power and creation of disruptive 

harmonics that can cause the sudden collapse of the Bulk-Power System.6

 Further, halfcycle saturation from GICs can potentially damage Bulk-Power System transformers 

because of overheating.7

C. Studies of GMD Events on the Bulk-Power System

7. The impact of GMDs on the Bulk-Power System has been evaluated in several 

government-sponsored studies and NERC reports. The EMP Commission issued reports 

assessing the threat to the United States from Electromagnetic Pulse (EMP) attack in 

2004 and 2008, which also addressed the effects of geomagnetic storms on the electric 

power infrastructure.8

 The National Research Council of the National Academies issued 

 5 North American Electric Reliability Corp., 2012 Special Reliability Assessment 

Interim Report: Effects of Geomagnetic Disturbances on the Bulk Power System at ii

(February 2012) (NERC Interim GMD Report), available at 

http://www.nerc.com/files/2012GMD.pdf.

6 Id. at iii-iv.

7 Id.

8 These reports are accessible at the Commission to Assess the Threat to the 

United States from Electromagnetic Pulse (EMP) Attack website at 

http://www.empcommission.org/.
Docket No. RM12-22-000 - 6 -

a report addressing the impact of severe space weather events in 2008.9

 The Oak Ridge

National Laboratory issued a series of reports on the effects of electromagnetic pulses on 

the Bulk-Power System in January 2010.10 NERC issued the HILF Report on highimpact, low-frequency risks to the Bulk-Power System in June 2010.11 

8. In November 2010, NERC endorsed the creation of a GMD Task Force to 

“develop a technical white paper describing the evaluation of scenarios of potential GMD 

impacts, identifying key bulk power system parameters under those scenario conditions, 

and evaluating potential reliability implications of these incidents.”12 The NERC GMD 

Task Force was formed in early 2011.13 In February 2012, the NERC GMD Task Force 

issued the NERC Interim GMD Report evaluating the effects of GMDs on the BulkPower System. 

 9 National Research Council of the National Academies, Severe Space Weather 

Events—Understanding Societal and Economic Impacts: A Workshop Report at 4 (2008) 

(NAS Workshop Report), available at http://www.nap.edu/catalog/12507.html.

10 Oak Ridge National Laboratory, FERC EMP-GIC Metatech Reports 319-324

(January 2010) (collectively, Oak Ridge Study), available at http://www.ornl.gov/sci/ees/

etsd/pes/ferc_emp_gic.shtml.

11 The HILF Report was prepared by NERC, Department of Energy, and a steering 

committee comprised of industry and risk experts and was approved by the NERC Board 

of Trustees on May 17, 2010. North American Electric Reliability Corp., High-Impact, 

Low-Frequency Event Risk to the North American Bulk Power System, at 2 (June 2010) 

(HILF Report), available at http://www.nerc.com/files/HILF.pdf). 

12 NERC, Board of Trustees Minutes, Exhibit J, at 1 (Nov. 4, 2010), available at

http://www.nerc.com/docs/docs/bot/BOT-1110m-open-complete.pdf.

13 NERC Comments at 2 n.4.
Docket No. RM12-22-000 - 7 -

9. The Commission held a Technical Conference on April 30, 2012 to discuss the 

risks posed by GMDs to the reliable operation of the Bulk-Power System.14 Several 

panelists indicated at the Technical Conference that severe GMD events could potentially 

compromise the reliable operation of the Bulk-Power System, with some noting as an 

example the GMD-induced disruption of the Hydro-Québec grid in 1989.15 Some 

commenters, however, expressed concern with developing Reliability Standards to 

address GMD events at this time.16 

D. Notice of Proposed Rulemaking

10. On October 18, 2012, the Commission issued a Notice of Proposed Rulemaking 

(NOPR) pursuant to FPA section 215(d) proposing to direct that NERC submit to the 

Commission for approval proposed Reliability Standards that address the risks posed by 

 14 Written statements presented at the Technical Conference, post-Technical 

Conference comments, and Technical Conference transcript are accessible through the 

Commission’s eLibrary document retrieval system in Docket No. AD12-13-000.

15 NOPR, 141 FERC ¶ 61,045 at P 3 (citing Statement of Scott Pugh, U.S. 

Department of Homeland Security at 2 (citing 1989 Hydro-Québec blackout); Statement 

of Frank Koza, PJM Interconnection, L.L.C. at 1 (“The combination of half-cycle 

transformer saturation and increased reactive power consumption can lead to voltage 

collapse and blackouts if not properly managed.”); Statement of John Kappenman at 8 

(“The bulk power system is the nation’s most important critical infrastructure and unlike 

other threats, a severe geomagnetic storms [sic] can impose a near simultaneous 

nationwide crippling threat to this vital infrastructure.”); Statement of Gerry Cauley, 

NERC at 1 (“Previous examples, such as the 1989 event in Hydro Québec demonstrate 

that severe solar storms represent a serious risk that can challenge the reliability of the 

bulk power system.”)).

16 See, e.g., Statement of Steven Naumann, EEI at 5 (“Until [system-wide] studies 

are completed, it is premature to determine whether NERC should advance development 

of mandatory requirements to address GMD related-issues.”).
Docket No. RM12-22-000 - 8 -

GMDs to the reliable operation of the Bulk-Power System.17 The NOPR stated that the 

proposal was based on government-sponsored studies and NERC studies indicating that 

GMD events can have an adverse, wide-area impact on the reliable operation of the BulkPower System.18 The NOPR stated that GMD vulnerabilities are not adequately 

addressed in the Reliability Standards and that this constitutes a reliability gap because 

GMD events can cause the Bulk-Power System to collapse suddenly and can potentially 

damage equipment on the Bulk-Power System. 

11. The NOPR proposed to direct NERC to develop GMD Reliability Standards in 

two stages. Regarding the first stage, NERC would submit one or more proposed 

Reliability Standards that require owners and operators of the Bulk-Power System to 

develop and implement operational procedures to mitigate the effects of GMDs 

consistent with the reliable operation of the Bulk-Power System. The NOPR proposed

that NERC would submit these First Stage GMD Reliability Standards within 90 days of 

the effective date of a final rule in this proceeding. The NOPR, while not proposing to 

direct a specific implementation plan, encouraged a 90-day implementation period 

following Commission approval of the First Stage GMD Reliability Standards. 

 17 Reliability Standards for Geomagnetic Disturbances, Notice of Proposed 

Rulemaking, 77 FR 64,935 (Oct. 24, 2012), 141 FERC ¶ 61,045 (2012) (NOPR).

18 NOPR, 141 FERC ¶ 61,045 at P 2 (citing NERC Interim GMD Report at 85;

HILF Report at 68; Oak Ridge Study).
Docket No. RM12-22-000 - 9 -

12. The NOPR proposed to accept aspects of the “Initial Actions” plan set forth in 

NERC’s May 21, 2012 post-Technical Conference comments, in which NERC stated that 

it would “identify facilities most at-risk from severe geomagnetic disturbance” and 

“conduct wide-area geomagnetic disturbance vulnerability assessment.”19 In the NOPR, 

the Commission stated that it agreed with NERC that critical Bulk-Power System 

facilities should be evaluated for GMD vulnerability and, as part of the “Initial Actions,” 

special attention should be given to Bulk-Power System facilities that provide service to 

critical and priority loads. The NOPR proposed that NERC would conduct these “Initial 

Actions” simultaneously with the development of the First Stage GMD Reliability 

Standards. 

13. Regarding the second stage, the NOPR proposed that, within six months of the 

effective date of a final rule in this proceeding, NERC would file one or more proposed 

Reliability Standards that require owners and operators of the Bulk-Power System to 

conduct initial and on-going assessments of the potential impact of GMDs on BulkPower System equipment and the Bulk-Power System as a whole. The NOPR stated that, 

based on those assessments, the Reliability Standards would require owners and operators 

to develop and implement a plan so that instability, uncontrolled separation, or cascading 

failures of the Bulk-Power System, caused by damage to critical or vulnerable BulkPower System equipment, or otherwise, will not occur as a result of a GMD. The NOPR 

 19 NERC May 21, 2012 Comments at 8-9.
Docket No. RM12-22-000 - 10 -

stated that the plan could not be limited to operational procedures or enhanced training 

alone, but should, subject to the needs identified in the assessments, contain strategies for 

protecting against the potential impact of GMDs based on factors such as the age, 

condition, technical specifications, or location of specific equipment. The NOPR further 

stated that these strategies could include automatically blocking GICs from entering the 

Bulk-Power System, instituting specification requirements for new equipment, inventory 

management, and isolating certain equipment that is not cost effective to retrofit. 

Without proposing a specific implementation period, the NOPR stated that the Second 

Stage GMD Reliability Standards would likely need to be implemented in phases, 

focusing first on the most critical Bulk-Power System assets.

14. In response to the NOPR, interested entities filed 62 comments. We address 

below the issues raised in the comments.20 The Appendix to this Final Rule lists the 

entities that filed comments to the NOPR.21

 20 Some comments raised issues not addressed in the NOPR, including cost 

recovery for compliance with the GMD Reliability Standards; the risks posed to the 

Bulk-Power System by electromagnetic pulses; the organization and conduct of the 

NERC GMD Task Force; terrorism; and cybersecurity. Issues outside the scope of the 

NOPR are not addressed in this Final Rule. However, nothing precludes entities from 

seeking cost recovery if needed.

21 A document submitted by the Nuclear Regulatory Commission (NRC) was 

erroneously included in the Commission’s eLibrary system in this rulemaking docket and 

was subsequently removed. The NRC document did not influence the determinations in 

this Final Rule.
Docket No. RM12-22-000 - 11 -

II. Discussion

15. As discussed below, the Commission finds that the existing Reliability Standards 

do not adequately address the risks posed by GMDs to the reliable operation of the BulkPower System. In its NOPR comments, NERC states that “[a]s a high-impact, lowfrequency event, GMDs pose a unique threat to Bulk-Power System reliability, and 

NERC is committed to working with stakeholders and the Commission to address these 

challenges consistent with its responsibilities as the ERO.”22 Accordingly, pursuant to 

section 215(d)(5) of the FPA, the Commission directs the ERO to develop and submit for 

approval Reliability Standards that address the potentially severe, wide-spread impact of 

GMD events on the reliable operation of the Bulk-Power System.23 

16. We issue this directive recognizing, as we did in the NOPR, that there is an 

ongoing debate as to the likely effect of GMDs on the reliable operation of the BulkPower System. As discussed below, the NOPR comments reflect these differing views, 

with some comments supporting the NERC Interim GMD Report’s conclusion that the 

worst-case GMD scenario is “voltage instability and subsequent voltage collapse,”24

while other comments endorse the Oak Ridge Study’s conclusion that a severe GMD 

 22 NERC Comments at 3.

23 We do not necessarily require NERC to develop and submit entirely new 

Reliability Standards. NERC could develop and submit revisions to existing Reliability 

Standards. In addition, as stated in the NOPR, facilities and equipment falling outside of 

our jurisdiction would not be subject to the proposed GMD Reliability Standards. 

NOPR, 141 FERC ¶ 61,045 at P 27 n.49.

24 NERC Interim GMD Report at 69.
Docket No. RM12-22-000 - 12 -

event could put Bulk-Power System transformers at risk for failure or permanent 

damage.25 As we stated in the NOPR, and affirm here, “[w]hile the conclusions of these 

reports differ significantly, our proposed action is warranted by even the lesser 

consequence of a projected widespread blackout without long-term, significant damage to 

the Bulk-Power System. Taking steps to prevent such blackouts is consistent with 

maintaining the reliable operation of the Bulk-Power System.”26 

17. In directing the ERO to submit Reliability Standards that address the potential 

impact of GMD events on the reliable operation of the Bulk-Power System, we are not 

directing NERC to include specific Requirements or otherwise pre-judging what the ERO 

eventually proposes. In addition, we are not directing the ERO to develop GMD 

Reliability Standards that are “one-size-fits-all,” a concern expressed in the comments.27 

Instead, in this final rule we identify issues that should be considered in the NERC 

standards development process. We expect NERC to develop GMD Reliability 

 25 Oak Ridge National Laboratory, Electromagnetic Pulse: Effects on the U.S. 

Power Grid: Meta-R-319 at page 1-14, Tables 4-1, 4-2, 4-3 (discussing at-risk 

transformers) (January 2010) (Oak Ridge Study 319 Report), available at

http://www.ornl.gov/sci/ees/etsd/pes/pubs/ferc_Meta-R-319.pdf.

26 NOPR, 141 FERC ¶ 61,045 at P 5 (citing 16 U.S.C. 824o(a)(4)).

27 See, e.g., NERC Comments at 4; EIS Comments at 3; Bonneville Comments at 

3; NV Energy Comments at 4. Rather than adopt a “one-size-fits-all” approach, the 

NOPR stated that the Oak Ridge Study identified several variables that determine the 

severity of GMD events, including: (1) location and strength of the underlying solar 

event; (2) ground conductivity in the affected locations (i.e., the geology of the location); 

(3) orientation of the transmission lines; (4) length of transmission lines; and (5) grid 

construction. NOPR at P 14 (citing Oak Ridge Study 319 Report at page 2-5).
Docket No. RM12-22-000 - 13 -

Standards that address these issues and, when these Reliability Standards are submitted to 

the Commission for approval, to explain in the accompanying petition how the issues are 

addressed in the proposed GMD Reliability Standards.28

18. Because of concerns raised in the comments regarding the proposed schedule for 

developing and submitting the GMD Reliability Standards, we adjust the schedule in the 

NOPR to allow more time. Accordingly, we set a six-month deadline from the effective 

date of this Final Rule for NERC to submit the First Stage GMD Reliability Standards 

and suggest a six-month implementation period for the First Stage GMD Reliability 

Standards following Commission approval. We set an 18-month deadline from the 

effective date of this Final Rule for NERC to submit the Second Stage GMD Reliability 

Standards, and direct NERC to propose an implementation period.

19. Below we address the comments regarding: (1) the Commission’s authority to 

direct the ERO to develop and submit GMD Reliability Standards under FPA 

section 215(d)(5); (2) the content of the First Stage GMD Reliability Standards and the 

schedule for submitting and implementing the Reliability Standards; (3) the “Initial 

Actions” GMD vulnerability assessments; and (4) the content of the Second Stage GMD 

Reliability Standards and the schedule for submitting and implementing those Reliability 

Standards.

 28 In its comments, NERC encourages the Commission to permit Commission staff 

to actively participate in the NERC standards development process. NERC Comments 

at 8. Consistent with the Commission’s current practice, Commission staff will 

participate as an observer in the development of the GMD Reliability Standards.
Docket No. RM12-22-000 - 14 -

A. Commission Authority to Direct the ERO to Develop GMD Reliability 

Standards under FPA Section 215(d)(5)

NOPR

20. The NOPR stated that GMD vulnerabilities are not adequately addressed in the 

existing Reliability Standards.29 The NOPR stated that this constitutes a reliability gap 

because GMD events can cause the Bulk-Power System to collapse suddenly and can 

potentially damage the Bulk-Power System.30 In order to carry out section 215 of the 

FPA, the NOPR proposed to direct NERC to develop and submit for approval Reliability 

Standards that address the potentially severe, wide-spread impact of GMD events on the 

reliable operation of the Bulk-Power System.

Comments

21. NERC states that it “supports the Commission’s exercise of its authority pursuant 

to Section 215(d)(5) in the NOPR and the due weight given to NERC’s technical 

expertise with respect to the content of the proposed Reliability Standards. The NOPR 

explicitly does not propose to require NERC or owners or operators of the Bulk-Power 

System to adopt any particular operational procedures or a particular solution in the 

 29 NOPR, 141 FERC ¶ 61,045 at P 4 (citing NERC Reliability Standard IRO-005-

3a (Reliability Coordination — Current Day Operations), Requirement R3, as the only 

existing Requirement that discusses GMDs). 

30 NOPR, 141 FERC ¶ 61,045 at PP 4-5. 
Docket No. RM12-22-000 - 15 -

second stage Reliability Standards to address GMDs. NERC submits that this approach 

is consistent with Section 215(d)(2) of the Federal Power Act.”31

22. ELCON states that the NOPR does not establish why the GMD Reliability 

Standards are “appropriate to carry out [section 215],” as required under FPA 

section 215(d)(5).32 ELCON states that the “NOPR does not give sufficient recognition 

to the key unresolved technical issues, including the lack of consensus about the nature 

and potential impacts of GMD events and the absence of tools for modeling or addressing 

the effects of geomagnetic induced currents.”33 Accordingly, ELCON states that “a final 

rule would not be supportable as an exercise of the Commission’s authority under 

Section 215(d)(5).”34 The Trade Associations state that “[w]hile FERC has authority 

under Section 215(d)(5) to direct the ERO to develop a mandatory standard on a specific 

matter, the specific matter that is the subject of this NOPR, GIC levels caused by strong 

GMD events, does not have a strong scientific or technical consensus upon which to 

develop standards.”35 NARUC states that the NOPR “does not provide sufficient cost 

 31 NERC Comments at 7.

32 16 U.S.C. 824o(d)(5) (“The Commission, upon its own motion or complaint 

may order the Electric Reliability Organization 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 this section.”).

33 ELCON Comments at 4-5.

34 Id. at 5.

35 Trade Associations Comments at 25.
Docket No. RM12-22-000 - 16 -

benefit or technical evidence to justify a directive to NERC to set GMD Reliability 

Standards at this time.”36 Other commenters, without explicitly addressing the 

Commission’s authority to direct the ERO to develop GMD Reliability Standards, state 

that there is an insufficient technical basis for the NERC standards development 

process.37

Commission Determination

23. The Commission finds that the directives in this Final Rule are a valid exercise of 

the Commission’s authority under FPA section 215(d)(5). The plain language of the 

statute authorizes the Commission to order the development of a Reliability Standard that 

“addresses a specific matter if the Commission considers such a new or modified 

reliability standard appropriate to carry out this section.”38 

24. We determine that addressing the specific matter of GMDs and their impact on the 

reliable operation of the Bulk-Power System is appropriate to carry out FPA section 215. 

As the NOPR stated, while there is an ongoing debate as to how a severe GMD event will 

most likely impact the Bulk-Power System, there is a general consensus that GMD events 

 36 NARUC Comments at 3.

37 See, e.g., Duke Comments at 2-4; CenterPoint Comments at 3.

38 16 U.S.C. 824o(d)(5). 
Docket No. RM12-22-000 - 17 -

can cause wide-spread blackouts due to voltage instability and subsequent voltage 

collapse, thus disrupting the reliable operation of the Bulk-Power System.

39 

25. FPA section 215 defines “reliability standard” as a “requirement ... to provide for 

reliable operation of the bulk-power system.”40 FPA section 215 defines “reliable 

operation” to mean “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.”41 Because there is a general consensus that GMD events can cause “voltage 

instability and subsequent voltage collapse,” thus affecting the reliable operation of the 

Bulk-Power System, the Commission finds that GMDs are valid subject matter for

Reliability Standards development. In addition, as the Trade Associations’ comments 

 39 See, e.g., Trade Associations Comments at 51 (“The 1989 Hydro Quebec 

Blackout, is often used in the ORNL/Metatech Report to assert that wide spread collapse 

and permanent equipment damage is a likely outcome of a severe GMD event. Although 

the Trade Associations agree that both are potential risks of a severe GMD event, the 

Trade Association find the conclusions of the GMD Task Force, which states that ‘the 

most likely worst-case system impacts from a severe GMD event and corresponding GIC 

flow is voltage instability caused by a significant loss of reactive power support,’ to be 

more credible and based on the scientific facts.”); PJM Comments at 3 (“[T]here is no 

question that severe space weather has the potential to create serious problems for the 

Bulk-Power System.”); ITC Comments at 2 (“ITC believes that the risk to the bulk power 

system from GMD is a significant concern that should be addressed.”).

40 16 U.S.C. 824o(a)(3).

41 Id. at 824o(a)(4).
Docket No. RM12-22-000 - 18 -

acknowledge, the Reliability Standards currently do not expressly require responsible

entities to mitigate the risks posed by GMDs to the Bulk-Power System.42 Therefore, we 

believe that it is appropriate to direct NERC to submit new or modified Reliability 

Standards that address GMDs pursuant to FPA section 215(d)(5).

26. We reject the assertion that a lack of technical or scientific consensus regarding 

some issues associated with GMDs deprives the Commission of the statutory authority to 

order the development of revised or new Reliability Standards. While the Commission 

must have a reasonable basis for its actions, section 215(d)(5) does not require the 

Commission to certify the existence of a consensus before it can require the ERO to 

develop a Reliability Standard. Instead, the statute specifically vests the Commission 

with the discretion to determine when a new Reliability Standard is necessary.43 In any 

event, the lack of consensus in this case pertains to the most likely impact of a severe 

GMD event and the appropriate measures to take in mitigation. There is general 

 42 Trade Associations Comments at 25 (“[T]he Trade Associations acknowledge 

that NERC Reliability Standards do not expressly require steps for mitigating the effects 

of GMD events.”).

43 16 U.S.C. 824o(d)(5); see also Transmission Relay Loadability Reliability 

Standard, 134 FERC ¶ 61,127, at P 25 (2011) (explaining that under section 215(d)(5) 

“the Commission, and not just the ERO, has the responsibility and authority to identify 

'specific matters' that it considers appropriate to carry out section 215. Section 215 

establishes a paradigm by which both the Commission and the ERO are responsible for 

identifying reliability gaps—the ERO through its Reliability Standards development 

process, where it can independently identify areas of concern and develop Standards to 

address them; and the Commission through its review of proposed Reliability Standards 

and authority to direct modifications or new Standards that address specific issues 

necessary to effectuate the purposes of section 215.”).
Docket No. RM12-22-000 - 19 -

agreement that GMD events can cause wide-spread blackouts due to voltage instability 

and subsequent voltage collapse, thus disrupting the reliable operation of the Bulk-Power 

System.44 In fact, such blackouts have occurred.45 Requiring Reliability Standards to 

protect against these risks is well within the Commission’s authority. Moreover, the 

NERC standards development process will be the vehicle for working through the 

technical complexities associated with addressing the risks of GMD events on the BulkPower System.46 This is consistent with the NERC Standards Process Manual, which 

states that the NERC standards development process is designed to “build and document 

consensus for each Reliability Standard, both with regard to the need and justification for 

the Reliability Standard and the content of the Reliability Standard.”47

27. Some comments contend that the NOPR proposed to direct NERC to develop 

GMD Reliability Standards containing overly prescriptive Requirements in too short an 

 44 See supra n.39.

45 See NERC Interim GMD Report at i (citing 1989 Hydro-Québec blackout).

46 The NERC GMD Task Force has already developed operational procedure 

templates for certain functional entities. See NERC GMD Task Force Geomagnetic 

Disturbance Operating Procedure Template: Transmission Operator, available at 

http://www.nerc.com/docs/pc/gmdtf/Template _TOP.pdf; NERC GMD Task Force 

Geomagnetic Disturbance Operating Procedure Template: Generator Operator, available 

at http://www.nerc.com/docs/pc/gmdtf/Template_GOP.pdf. We expect that the NERC 

standards development process will consider the NERC GMD Task Force’s work as a 

resource.

47 NERC Rules of Procedure, Appendix 3A (Standards Process Manual) (Effective 

January 31, 2012) at 4.
Docket No. RM12-22-000 - 20 -

amount of time.48 Moreover, those comments state that the NOPR relied on underlying 

studies that, the comments assert, are flawed or unreliable.

49 However, as NERC 

recognizes in its NOPR comments, the NOPR explicitly stated that it was not directing 

the ERO to include any specific Requirements or otherwise pre-judging what the ERO 

eventually submits for approval.50 In this Final Rule, we direct the ERO to consider 

issues in the NERC standards development process, but we do not direct the content of 

the Reliability Standards or pre-judge what NERC ultimately proposes. As for the timing 

of the submission and implementation of the GMD Reliability Standards, we address that 

concern by modifying the schedule in the NOPR to give NERC more time to develop and 

submit the Reliability Standards. With respect to the commenters’ criticism of the studies 

cited in the NOPR, we recognize the divergent views.

51 However, as stated above, our

directive to develop GMD Reliability Standards is justified even under the conclusion in 

 48 See, e.g., ELCON Comments at 7-14; CenterPoint Comments at 2.

49 See, e.g., Trade Associations Comments at 19.

50 NOPR, 141 FERC ¶ 61,045 at P 17.

51 While some commenters criticize the Oak Ridge Study’s conclusions regarding 

the possible damaging effects of GMDs to Bulk-Power System components, the NOPR 

stated that the NERC-approved HILF Report also found that “[t]ransformers experience 

excessive levels of internal heating brought on by stray flux when GICs cause the 

transformer's magnetic core to saturate, forcing magnetic flux to flow outside the normal 

core steel magnetic circuit. Previous well documented cases have noted heating failures 

that caused melting and burn-through of large-amperage copper windings and leads in 

these transformers (Figure 9).” NOPR, 141 FERC ¶ 61,045 at 13 n.33 (citing HILF 

Report at 70).
Docket No. RM12-22-000 - 21 -

the NERC GMD Interim Report, with which the Trade Associations “strongly agree,” 

that a GMD event could result in “voltage instability and subsequent voltage collapse.”52

28. Finally, while we disagree that FPA section 215(d)(5) (the specific subsection we 

rely on in this proceeding) requires a particular cost-benefit showing in order to direct the 

development of revised or new Reliability Standards, the Commission is cognizant of the 

potential costs of GMD Reliability Standards. As we explain and clarify in this final rule, 

the Commission is not directing the content of the GMD Reliability Standards that must 

be submitted, and with respect to the Second Stage GMD Reliability Standards, is not 

mandating the use of any particular technologies (such as automatic blocking) to address 

the potential impact of benchmark GMD events. We expect that NERC and industry will 

consider the costs and benefits of particular mitigation measures as NERC develops the 

technically-justified Second Stage GMD Reliability Standards.

B. First Stage GMD Reliability Standards 

29. As discussed below, the Commission directs that, within six months of the 

effective date of this Final Rule, NERC submit for approval one or more Reliability 

Standards that require owners and operators of the Bulk-Power System to develop and 

implement operational procedures to mitigate the effects of GMDs consistent with the 

reliable operation of the Bulk-Power System. We address below the comments regarding 

 52 NERC Interim GMD Report at 69; Trade Associations Comments at 17-18.
Docket No. RM12-22-000 - 22 -

the content of the First Stage GMD Reliability Standards and the schedule for submitting 

and implementing the First Stage GMD Reliability Standards. 

1. Content of First Stage GMD Reliability Standards

NOPR

30. The NOPR proposed to direct NERC to submit one or more Reliability Standards 

requiring owners and operators of the Bulk-Power System to develop and implement 

operational procedures to mitigate the effects of GMDs consistent with the reliable 

operation of the Bulk-Power System. The NOPR stated that the proposed Reliability 

Standards should not necessarily specify what operational procedures must be adopted, 

but the ERO should give owners and operators of the Bulk-Power System guidance as to 

what procedures have been or are expected to be effective in mitigating the effects of 

GMDs consistent with the reliable operation of the Bulk-Power System. The NOPR also 

stated that the proposed Reliability Standards should address the coordination of 

operational procedures among responsible entities across regions. The NOPR further 

stated that, because there is potential for equipment damage resulting from a GMD event, 

the proposed Reliability Standards should also address operational procedures for 

restoring GMD-impacted portions of the Bulk-Power System that take into account the 

potential for equipment that is damaged or out-of-service for an extended period of time. 

The NOPR also proposed that, following implementation, NERC would provide periodic 

reports assessing the effectiveness of operational procedures in mitigating the effects of 

GMD events and periodically review the required operational procedures and recommend 

to owners and operators that they incorporate lessons-learned and new research findings.
Docket No. RM12-22-000 - 23 -

Comments

31. NERC and several commenters generally support the development of Reliability 

Standards requiring owners and operators to develop and implement operational 

procedures to address GMDs.53 Some commenters state that certain entities have already 

implemented operational procedures to address GMDs, and some commenters stress the 

importance of combining operational procedures with monitoring and situational 

awareness.54 Other commenters express concern with relying on operational procedures 

alone to address GMDs.55 

32. NERC states that it supports the development of operational procedures because 

“[t]raining and education programs on the nature of the threat [of GMDs] will allow 

Bulk-Power System Operators to more rapidly identify areas for improvement and take 

actions when necessary.”56 NERC states, however, that its ability to assess and report on 

the effectiveness of operational procedures is constrained because of the limitations with 

monitoring and forecasting GMD events. NERC states that, if the Commission requires 

NERC to submit periodic reports, as proposed in the NOPR, the reports should be 

 53 See, e.g., NERC Comments at 9; Joint ISOs/RTOs Comments at 4; PJM

Comments at 3; APS Comments at 3; Exelon Comments at 4; Bonneville Comments at 3;

ITC Comments at 6; PPL Companies Comments at 2; Pa PUC Comments at 3; SCE 

Comments at 3-4; and IESO Comments at 6.

54 See, e.g., IESO Comments at 6; Exelon Comments 4-5.

55 See, e.g., Comments of Congressman Franks at 1-2; IESO Comments at 8-9;

and EIS Comments at 5.

56 NERC Comments at 9.
Docket No. RM12-22-000 - 24 -

submitted no more frequently than annually and, in part to conserve ERO resources, that 

the reporting obligation should expire upon implementation of the Second Stage GMD 

Reliability Standards. NERC also states that the emergence of new forecasting 

capabilities is vital to improving early warning and understanding of potential GMD 

effects and will directly impact the development of operational procedures. NERC states 

that relying on the “K-Index,”57 which NERC describes as the most familiar means of 

characterizing the severity of geomagnetic storms, is problematic because of the 

associated “uncertainties and inaccuracies.” NERC states that the K-Index “cannot be 

used as an automatic triggering event for specific required actions because operational 

procedures need flexibility to account for actual operating conditions and the ability to 

adjust accordingly.”58

33. Commenters that oppose Reliability Standards requiring the development and 

implementation of operational procedures state that Reliability Standards are premature 

because the science of GMDs is not fully understood and more study is needed before 

Reliability Standards can be developed.59 Accordingly, commenters state that the NERC 

 57 “K index” is defined as “a 3-hourly quasi-logarithmic local index of 

geomagnetic activity relative to an assumed quiet-day curve for the recording site. Range 

is from 0 (quiet) to 9 (severely disturbed).” Space Weather Prediction Center, Glossary 

of Solar-Terrestrial Terms, available at http://www.swpc.noaa.gov/info/glossary.html#k.

58 NERC Comments at 11.

59 See, e.g., Trade Associations Comments at 4-5; NARUC Comments at 5-6;

ELCON Comments at 2; SPP Parties Comments at 3; CenterPoint Comments at 5;

Dominion Comments at 4; Duke Comments at 2-3; and KCP&L Comments at 2.
Docket No. RM12-22-000 - 25 -

GMD Task Force should be allowed to finish its work, which includes evaluating the 

need for GMD Reliability Standards, before the Commission directs NERC to develop 

Reliability Standards. Commenters also state that requiring operational procedures 

prematurely (e.g., before responsible entities have conducted GMD vulnerability 

assessments) may harm reliability because operational procedures can have unintended 

consequences that adversely affect the Bulk-Power System.60 

34. Some commenters opposed to requiring operational procedures state that they 

could support the use of operational procedures under certain conditions. The Trade 

Associations state that they could support requiring operational procedures if the 

Commission determines that they are necessary.61 Dominion states that it could support, 

as an interim step, having NERC gather current industry practices regarding GMD 

operational procedures and issue a best practices operating guideline within 90 days.62 

SPP Parties state that the Commission should encourage NERC to issue, before the next 

 60 CenterPoint Comments at 7.

61 Trade Associations Comments at 5-6 (“If the Commission finds it must direct 

NERC to develop a standard or standards to address the impact of GMDs on the [BulkPower System], the Trade Associations support the Commission’s stage one proposal to 

require NERC to file one or more standards which would require grid owners and 

operators to develop and implement operations procedures that would mitigate GMD 

effects.”).

62 Dominion Comments at 4.
Docket No. RM12-22-000 - 26 -

solar peak in June 2013, a “reliability guideline” to assist owners and operators of BulkPower System facilities to address GMD threats to the Bulk-Power System.63

35. Commenters generally agree that operational procedures, if required, should be 

developed by responsible entities and not by NERC, although some commenters state 

that NERC could develop best practices to assist responsible entities.64 Commenters state 

that the Reliability Standards should not have Requirements that treat responsible entities 

the same (“one-size-fits-all”) because responsible entities, due to geography, geology or 

other variables, may be more or less likely to experience the effects of GMDs. 

Commenters state that the operational procedures should be developed by responsible

entities based on factors such as the entity’s geographic location and the structural makeup of the entity’s Bulk-Power System components. Commenters also state that 

operational procedures should not have the unintended effect of adversely impacting the 

Bulk-Power System. Commenters further state that the Reliability Standards should be 

 63 SPP Parties Comments at 4. As discussed below, the NERC GMD Task Force 

provided guidance to registered entities in the NERC Interim GMD Report by identifying 

possible operational procedures in response to GMD events. NERC Interim GMD 

Report at 80-81. In addition, NERC issued an Industry Advisory Alert on May 10, 2011 

entitled “Preparing for Geo-Magnetic Disturbances.” NERC, Industry Advisory: 

Preparing for Geo-Magnetic Disturbance (May 10, 2011), available at http://www.nerc.

com/fileUploads/File/Events%20Analysis/A-2011-05-10-01_GMD_FINAL.pdf.

64 NERC Comments at 6; AEP Comments at 4-5; ELCON Comments at 13; SPP 

Parties Comments at 5; IESO Comments at 11; Consumers Comments at 4; and Duke 

Comments at 5.
Docket No. RM12-22-000 - 27 -

clear as to which functional entities are responsible for compliance and that the 

assignment of responsibilities should be consistent with NERC’s functional model.

Commission Determination

36. The Commission directs NERC to submit, within six months of the effective date 

of this Final Rule, one or more Reliability Standards requiring owners and operators of 

the Bulk-Power System to develop and implement operational procedures to mitigate the 

effects of GMDs consistent with the reliable operation of the Bulk-Power System. As we 

stated in the NOPR, “operational procedures, while not a complete solution, constitute[] 

an important first step to addressing the GMD reliability gap because they can be 

implemented relatively quickly.”65 Operational procedures may help alleviate abnormal 

system conditions due to transformer absorption of reactive power during GMD events, 

helping to stabilize system voltage swings, and may potentially isolate some equipment 

from being damaged or misoperated. 

37. It is not premature for NERC to begin developing Reliability Standards requiring 

owners and operators of the Bulk-Power System to develop and implement operational 

procedures. The comments reflect that some entities have implemented operational 

 65 NOPR, 141 FERC ¶ 61,045 at P 18 n.38 (citing NERC Interim GMD Report 

at 79 (“Operating procedures are the quickest way to put in place actions that can 

mitigate the adverse effects of GIC on system reliability ... Both system operating and 

transmission owner organizations need to have appropriate procedures and training in 

place.”)).
Docket No. RM12-22-000 - 28 -

procedures to mitigate the impacts of GMDs.66 In addition, the NERC Interim GMD 

Report identifies examples of operational procedures to mitigate GMD events including: 

reduction of equipment loading (e.g., by starting off-line generation), unloading the 

reactive load of operating generation, reductions of system voltage, and system and/or 

equipment isolation through reconfiguration of the transmission system.67 In addition, 

the NERC GMD Task Force has developed operational procedure templates for certain 

functional entities. Given the work of the NERC GMD Task Force and recognizing that 

some operational procedures are already in place, we conclude that it is not premature for 

NERC to develop Reliability Standards that require operational procedures.

38. The Commission is not directing NERC to develop Reliability Standards that 

include specific operational procedures. Instead, as proposed in the NOPR, the 

Reliability Standards should include a mechanism that requires responsible entities to

develop and implement operational procedures because owners and operators of the 

Bulk-Power System are most familiar with their own equipment and system 

configurations. In addition, we do not expect that owners and operators of the BulkPower System will necessarily develop and implement the same operational procedures. 

Instead, the Reliability Standards, rather than include “one-size-fits-all” Requirements,

should allow responsible entities to tailor their operational procedures based on the 

 66 See, e.g., IESO Comments at 5; Exelon Comments at 5; CEA Comments at 6-7; 

Dominion Comments at 5; Trade Associations Comments at 26.

67 NERC Interim GMD Report at 80-81.
Docket No. RM12-22-000 - 29 -

responsible entity’s assessment of entity-specific factors, such as geography, geology, 

and system topology, identified in the Reliability Standards. In addition, as we stated in 

the NOPR, the coordination of operational procedures across regions is an important 

issue that should be considered in the NERC standards development process.68 The 

coordination of operational procedures across regions and data sharing might be overseen 

by planning coordinators or another functional entity with a wide-area perspective.69 The 

NERC standards development process, as stated in the NOPR, should also consider 

operational procedures for restoring GMD-impacted portions of the Bulk-Power System 

that take into account the potential for damaged equipment that could be de-rated or outof-service for an extended period of time.

39. While responsible entities will develop and implement operational procedures, 

NERC can support their efforts, for example, by identifying and sharing operational 

procedures found to be the most effective. NERC should also periodically survey the 

responsible entities’ operational procedures, offer recommendations based on lessonslearned and new research findings, and re-evaluate whether modification to the 

Reliability Standards is warranted. Based on these surveys, NERC should produce 

 68 NOPR, 141 FERC ¶ 61,045 at 20 (citing NERC Interim GMD Report at 79 

(“The [operating] procedures of these organizations need to be coordinated with each 

other and with their neighboring organizations.”)). 

69 In NERC’s May 21, 2012 post-Technical Conference comments, NERC stated 

that planning coordinators will conduct the wide-area analyses as part of the “Initial 

Actions” assessments, discussed below. NERC May 21, 2012 Comments at 9. LADWP 

proposes that reliability coordinators coordinate these efforts. LADWP Comments at 5.
Docket No. RM12-22-000 - 30 -

periodic reports assessing the effectiveness of operational procedures. We take no 

position in this Final Rule on the content, frequency, or duration of such surveys, 

recommendations, or reports because we believe that those issues, in the first instance, 

should be addressed as part of the NERC standards development process.

40. We take no position in this Final Rule with respect to NERC’s concerns regarding 

overreliance on the K-Index to trigger operational procedures. Technical issues regarding 

the development and implementation of operational procedures should be, in the first 

instance, considered in the NERC standards development process. Likewise, we take no 

position in this Final Rule on which functional entities should be responsible under the 

Reliability Standards because we believe that those issues, in the first instance, should be 

addressed as part of the NERC standards development process.

2. Schedule for Submitting and Implementing First Stage GMD 

Reliability Standards 

NOPR

41. The NOPR proposed that NERC submit the First Stage GMD Reliability 

Standards to the Commission for approval within 90 days of the effective date of a final 

rule in this proceeding. The NOPR also proposed a suggested 90-day implementation 

period following Commission approval of the First Stage GMD Reliability Standards. 

Comments

42. NERC states that “[w]hile the implementation plan proposed for the completion of 

the first stage Reliability Standards is aggressive, NERC is committed to meeting 
Docket No. RM12-22-000 - 31 -

whatever implementation targets are established by the Commission.”70 Other 

commenters support adoption of the proposed 90-day filing deadline for the First Stage 

GMD Reliability Standards.71

43. Other commenters state that the proposed 90-day deadline for filing the First Stage 

GMD Reliability Standards does not allow enough time to develop a Reliability Standard 

using the NERC standards development process.72 ITC proposes a six-month deadline 

for developing and submitting the First Stage GMD Reliability Standards and a sixmonth implementation period following Commission approval. LADWP suggests an 

eight-month deadline for submitting the First Stage GMD Reliability Standards and a sixmonth implementation period. Joint ISOs/RTOs propose a one-year deadline for 

developing and submitting the First Stage GMD Reliability Standards, with the 

Commission directing NERC to develop an implementation schedule once NERC has a 

better idea of the degree of coordination that will be needed between the different 

functional entities. CenterPoint states that “two years of study and review are needed to 

develop GMD Reliability Standards” and proposes “a region-based phased 

implementation schedule.”73 Exelon recommends having the ERO propose a filing 

 70 NERC Comments at 9.

71 See, e.g., SENS Comments at 4; Foundation Comments at 19.

72 See, e.g., ITC Comments at 3; LADWP Comments at 8-9; Joint ISOs/RTOs 

Comments at 14; Consumers Energy Comments at 2-3; AEP Comments at 4.

73 CenterPoint Comments at 16-17.
Docket No. RM12-22-000 - 32 -

deadline.

74 The Trade Associations recommend that the Commission not suggest an 

implementation period, but the Trade Associations state that it is their preliminary view 

that operational procedures could be implemented in six months.75

Commission Determination

44. We support the prompt development of mandatory and enforceable Reliability 

Standards that require owners and operators to implement operational procedures to 

afford some level of protection to the Bulk-Power System against GMD events. In its 

comments, NERC commits to meeting the 90-day deadline proposed in the NOPR. 

However, based on the concerns raised in other comments, we modify the schedule in the 

NOPR and direct NERC to submit proposed First Stage GMD Reliability Standards 

within six months of the effective date of this Final Rule. 

45. While a six-month deadline may not be as long as some commenters propose, it 

strikes a balance by affording NERC a reasonable amount of time to develop the 

Reliability Standards and having Reliability Standards in place in the near term. As we 

stated in the NOPR, the Commission expects that NERC and owners and operators of the 

Bulk-Power System will draw on industry’s experience with existing operational 

procedures to expedite the NERC standards development process. This should help 

 74 Exelon Comments at 14.

75 Trade Associations Comments at 22.
Docket No. RM12-22-000 - 33 -

establish the First Stage GMD Reliability Standards quickly to afford some level of 

protection to the Bulk-Power System against GMD events.

46. With respect to the suggested 90-day implementation period proposed in the 

NOPR, we modify the proposal and suggest a six-month implementation period. Given 

our expectation that the Reliability Standards proposed by NERC will require responsible

entities to develop and implement operational procedures and to coordinate such efforts, 

it is appropriate to afford more time for implementation. We take no position in this 

Final R ule on the details of the implementation plan. The details of the implementation 

plan should be addressed, in the first instance, in the NERC standards development 

process.

C. “Initial Actions” GMD Vulnerability Assessments

NOPR

47. The NOPR proposed to accept aspects of the “Initial Actions” detailed in NERC’s 

May 21, 2012 post-Technical Conference comments. The NOPR stated that NERC 

proposed to “identify facilities most at-risk from severe geomagnetic disturbance” and 

“conduct wide-area geomagnetic disturbance vulnerability assessment.”76 The NOPR 

agreed with NERC that critical Bulk-Power System facilities should be evaluated for 

GMD vulnerability and, as part of the “Initial Actions,” that special attention should be 

 76 NERC May 21, 2012 Comments at 8-9.
Docket No. RM12-22-000 - 34 -

given to Bulk-Power System facilities that provide service to critical and priority loads.77 

The NOPR proposed that NERC would conduct these “Initial Actions” in parallel with 

the development and implementation of the First Stage GMD Reliability Standards. 

Comments

48. NERC states that it agrees that an assessment is necessary to identify and classify 

the at-risk population of transformers, and NERC clarifies that asset owners will conduct 

the “Initial Actions” assessments. The Trade Associations agree that owners and 

operators of the Bulk-Power System should perform individual assessments, while 

planning authorities should perform system-wide assessments.

49. The Trade Associations support identification of at-risk facilities but caution that 

the assessment will require new tools, including improved modeling of GICs; 

improvements in area and regional power flow modeling; and benchmarking of models 

against actual GICs. Bonneville also states that, while an assessment needs to be done, 

the tools and models required to perform such an assessment currently do not exist. 

Bonneville anticipates the availability of “adequate tools for use in developing limited 

assessments of risk indexed against the magnitude of GIC flow through individual 

 77 NOPR, 141 FERC ¶ 61,045 at P 22 (citing NERC, Severe Impact Resilience: 

Considerations and Recommendations at 26 (Accepted by NERC Board of Trustees on 

May 9, 2012), available at 

http://www.nerc.com/docs/oc/sirtf/SIRTF_Final_May_9_2012-Board_Accepted.pdf.).
Docket No. RM12-22-000 - 35 -

transformers and possibly even reactive demand under GIC condition by the end 

of 2013.”78

50. Duke states that the “Initial Actions” assessments should identify critical BulkPower System facilities but that “[e]xpanding the effort to include identification and 

protection for all critical and priority loads is too extensive an activity to be completed 

simultaneously with the first stage GMD Reliability Standards.”79 Exelon states that the 

NOPR defines critical facilities in a confusing manner because the NOPR references 

“critical and priority” loads, which Exelon states generally relate to the distribution 

system and not to specific Bulk-Power System facilities. Exelon states that NERC has 

set out a methodology for determining what equipment it considers critical and a 

methodology to identify “at-risk” equipment based on peer-reviewed research. Exelon 

recommends that NERC and responsible entities rely on their technical expertise to 

define what is critical equipment. Exelon also states that the time frames in the NOPR 

for completing the “Initial Actions” assessments is unrealistic because Exelon believes 

that the NOPR proposed to require completion of the assessments 90 days after the 

Commission approves the First Stage GMD Reliability Standards.80 CenterPoint states 

 78 Bonneville Comments at 5.

79 Duke Comments at 5-6.

80 Exelon Comments at 7 n.20.
Docket No. RM12-22-000 - 36 -

that vulnerability assessments should be made on a “regional basis” with the regions most 

vulnerable to GMDs assessed first.

Commission Determination

51. The Commission accepts the proposal in NERC’s May 21, 2012 post-Technical 

Conference comments and directs NERC to “identify facilities most at-risk from severe 

geomagnetic disturbance” and “conduct wide-area geomagnetic disturbance vulnerability 

assessment” as well as give special attention to those Bulk-Power System facilities that 

provide service to critical and priority loads.81 As noted in NERC’s comments, owners 

and operators of the Bulk-Power System, as opposed to NERC, will perform the 

assessments and special attention will be given to evaluating critical transformers (e.g., 

step-up transformers at large generating facilities).82 We agree with the Trade 

Associations that system-wide assessments could be conducted by planning authorities, 

 81 NERC Comments at 8-9 (“As the first step in identifying the risk of 

geomagnetic disturbance to the bulk power system, NERC intends to complete a systemwide vulnerability assessment ... special attention will be given to the evaluation of 

critical transformers, such as generator step-up units at large generating facilities ... a 

high level review will be conducted to identify and classify the at-risk population based 

on existing peer-reviewed research. This assessment will be based on a high level 

screening approach that will include transformer design, condition, geology and 

geomagnetic location.”).

82 The NERC Rules of Procedure permit NERC to seek such information from 

registered entities. NERC Rules of Procedures, Section 1601 (effective January 31, 

2012) (“Within the United States, NERC and Regional Entities may request data or 

information that is necessary to meet their obligations under Section 215 of the Federal 

Power Act, as authorized by Section 39.2(d) of the Commission’s regulations, 18 C.F.R. 

§ 39.2(d).”).
Docket No. RM12-22-000 - 37 -

or another functional entity with a wide-area perspective, in coordination with owners 

and operators of the Bulk-Power System.

83 NERC should oversee these efforts and 

provide responsible entities with a methodology for identifying “at-risk” Bulk-Power 

System components and “critical and priority loads” that need to be analyzed in the 

“Initial Actions.”

52. Some commenters state that tools do not exist for conducting the “Initial Actions” 

assessments. As a result, the commenters assert that the schedule for completing the 

“Initial Actions” assessments is unrealistic because the commenters believe that the 

NOPR proposed to require the completion of such assessments by the filing date or 

implementation date of the First Stage GMD Reliability Standards. We clarify that the 

“Initial Actions” assessments do no need to be completed by the filing date or 

implementation date of the First Stage GMD Reliability Standards. The NOPR only 

proposed that the “Initial Actions” assessments should begin immediately (i.e., 

simultaneous with the development of the First Stage GMD Reliability Standards). Thus,

the “Initial Actions” assessments provide a head start for analyzing the most at-risk and 

critical facilities before the Second Stage GMD Reliability Standards become effective 

and could be used to assist in performing the GMD vulnerability assessments required in

the Second Stage GMD Reliability Standards. Further, to the extent that owners and 

 83 The accuracy of wide-area assessments will depend on the data provided by 

owners and operators of the Bulk-Power System.
Docket No. RM12-22-000 - 38 -

operators of the Bulk-Power System have already begun to identify facilities most at-risk 

from severe GMD events, those assessments should help to inform the “Initial Actions”

assessments required by this final rule.

53. In NERC’s May 21, 2012 post Technical Conference comments, NERC stated that 

all of its proposed “Initial Actions” would take 18-24 months to complete.84 The 

June 2012 GMD Task Force Phase 2 Scope and Project Plan estimated that “improve[d] 

tools for industry planners to develop GMD mitigation strategies” would be completed 

within 12-36 months, depending on the task, and “improve[d] tools for system operators 

to manage GMD impacts” would be completed within 12-24 months.85 Adjusting the 

deadline for submission of the Second Stage GMD Reliability Standards to 18 months

allows time to identify facilities most at-risk from severe geomagnetic disturbance and to 

conduct wide-area geomagnetic disturbance vulnerability assessment, with special 

attention being given to those Bulk-Power System facilities that provide service to critical 

and priority loads, before the effective date of the Second Stage GMD Reliability 

Standards.86

 84 NERC May 21, 2012 Comments at 8.

85 NERC, GMD Task Force Phase 2 Scope and Project Plan (June 2012), available 

at http://www.nerc.com/docs/pc/gmdtf/GMD_Phase_2_Project_Plan_APPROVED.pdf.

86 The rulemaking following submission of the Second Stage GMD Reliability 

Standards 18 months from the effective date of this Final Rule is likely to take several 

months, and a multi-phased implementation period is likely to follow the effective date of 

a final rule approving the Second Stage GMD Reliability Standards. 
Docket No. RM12-22-000 - 39 -

D. Second Stage GMD Reliability Standards

54. As discussed below, the Commission adopts the NOPR proposal, with 

modifications, to direct NERC to submit Second Stage GMD Reliability Standards. We 

direct NERC to submit for approval, one or more Reliability Standards that require

owners and operators of the Bulk-Power System to conduct initial and on-going 

assessments of the potential impact of benchmark GMD events on Bulk-Power System 

equipment and the Bulk-Power System as a whole. The Second Stage GMD Reliability 

Standard must identify what severity GMD events (i.e., benchmark GMD events) that 

responsible entities will have to assess for potential impacts on the Bulk-Power System. 

If the assessments identify potential impacts from benchmark GMD events, owners and 

operators must develop and implement a plan to protect against instability, uncontrolled 

separation, or cascading failures of the Bulk-Power System, caused by damage to critical 

or vulnerable Bulk-Power System equipment, or otherwise, as a result of a benchmark

GMD event. Owners and operators of the Bulk-Power System cannot limit their plans to 

considering operational procedures or enhanced training alone, but must, subject to the 

vulnerabilities identified in the assessments, contain strategies for protecting against the 

potential impact of the benchmark GMD events based on factors such as the age, 

condition, technical specifications, system configuration, or location of specific 

equipment. These strategies could, for example, include automatically blocking GICs

from entering the Bulk-Power System, instituting specification requirements for new 

equipment, inventory management, and isolating certain equipment that is not cost 
Docket No. RM12-22-000 - 40 -

effective to retrofit, or a combination thereof. These Reliability Standards should be 

submitted within 18 months of the effective date of this Final Rule.

55. In the discussion below, we address the comments on the GMD vulnerability

assessments, the plans for addressing identified vulnerabilities, and the schedule for 

submitting and implementing the Second Stage GMD Reliability Standards.

1. GMD Vulnerability Assessments

NOPR

56. The NOPR proposed to direct NERC to file one or more Reliability Standards that 

require owners and operators of the Bulk-Power System to conduct initial and on-going 

assessments of the potential impact of GMDs on Bulk-Power System equipment and the 

Bulk-Power System as a whole. The NOPR stated that the Reliability Standards would 

require owners and operators to develop and implement plans based on the needs 

identified in the assessments.

57. The NOPR proposed to direct the ERO to consider the following parameters as it 

develops the Second Stage GMD Reliability Standards. 

58. First, the Commission proposed that the Reliability Standards should contain 

uniform evaluation criteria for owners and operators to follow when conducting their 

assessments. 

59. Second, the NOPR stated that the assessments should, through studies and 

simulations, evaluate the primary and secondary effects of GICs on Bulk-Power System 
Docket No. RM12-22-000 - 41 -

transformers, including the effects of GICs originating from and passing to other 

regions.87 

60. Third, the NOPR asserted that the assessments should evaluate the effects of GICs 

on other Bulk-Power System equipment, system operations, and system stability, 

including the anticipated loss of critical or vulnerable devices or elements resulting from 

GIC-related issues.88

61. Fourth, in conjunction with assessments by owners and operators of their own 

Bulk-Power System components, the Commission stated that wide-area or Regional 

assessments of GIC impacts should be performed. The NOPR noted that a severe GMD 

event can cause simultaneous stresses at multiple locations on the Bulk-Power System, 

potentially resulting in a multiple-outage event.89 In predicting GIC flows, it is necessary 

to take into consideration the network topology as an integrated whole (i.e., on a widearea basis).90 

 87 The NOPR described damage to Bulk-Power System components as a primary 

effect of GICs and production of harmonics that are not present during normal BulkPower System operation and increased transformer absorption of reactive power as 

secondary effects of GICs. NOPR, 141 FERC ¶ 61,045 at P 13.

88 The Oak Ridge Study assessment included GMD modeling, simulation and 

review of storm impacts, power grid GIC flows and reactive power demands, transformer 

heating and risk of potential damage to transformers. See generally Oak Ridge Study 319 

Report. 

89 Oak Ridge Study 319 Report at pages A1-1, A1-2. 

90 Id. at page 1-17.
Docket No. RM12-22-000 - 42 -

62. Fifth, the NOPR proposed that the assessments should be periodically updated, 

taking into account new facilities, modifications to existing facilities, and new 

information, including new research on GMDs, to determine whether there are resulting 

changes in GMD impacts that require modifications to Bulk-Power System mitigation 

schemes.

Comments

63. NERC and several commenters generally support requiring GMD vulnerability 

assessments.91 NERC states that it supports the NOPR’s approach of requiring owners 

and operators of the Bulk-Power System to conduct vulnerability assessments to 

determine how critical or vulnerable Bulk-Power System components react to simulated 

GICs of varying intensities. NERC also states that it appreciates the NOPR’s recognition 

of the need to incorporate new information and research given that the science of GMDs 

is still evolving.

64. Many commenters that oppose the Second Stage GMD Reliability Standards at 

this time state that available methods of performing vulnerability assessments are crude 

and unrefined.92 For example, the Trade Associations state that using existing tools 

“would be asking industry to make assessments ... and apply solutions at a point when 

these tools are incapable of doing so without creating risks to reliability that could be 

 91 See, e.g., NERC Comments at 14 Joint ISOs/RTOs Comments at 19; PJM 

Comments at 3; Pa PUC Comments at 3-4; AEP Comments at 2.

92 See, e.g., Trade Associations Comments at 30; Exelon Comments at 8.
Docket No. RM12-22-000 - 43 -

greater than any known risk resulting from a severe GMD event.”93 Commenters state 

that assessments should only be required after the necessary tools and methodologies 

have been developed and validated and the NERC GMD Task Force has completed its 

work.

65. Some commenters state that requiring all owners and operators to base their 

vulnerability assessments on uniform evaluation criteria would not be realistic due to the 

widely varying geology and geomagnetic latitudes within which the Bulk-Power System 

is planned and operated. 

66. Some commenters state that the Commission should specify the severity of the 

GMD to assess and plan, although the commenters do not agree on a specific severity.

94 

ITC states that it “believes that there should be a clear engineering benchmark for 

transmission owner and operators to plan for GMD in a prudent fashion (e.g., a 1 in 

100 year GMD event).”95 EIS states that, because the science of GMDs is inexact, an 

event twice as large as the largest expected GMD should be used as a safety margin.96 

Other commenters state that establishing a benchmark GMD event is problematic 

because there is no consensus storm scenario.

 93 Trade Associations Comments at 4.

94 See, e.g., CEA Comments at 4-5; ITC Comments at 4.

95 ITC Comments at 4.

96 EIS Comments at 4.
Docket No. RM12-22-000 - 44 -

Commission Determination

67. We direct NERC, within 18 months of the effective date of this final rule, to 

submit for approval one or more Reliability Standards that require owners and operators 

of the Bulk-Power System to conduct initial and on-going vulnerability assessments of 

the potential impact of benchmark GMD events on Bulk-Power System equipment and 

the Bulk-Power System as a whole. We agree with commenters that the Second Stage

GMD Reliability Standards should specify what severity GMD events (i.e., benchmark 

GMD events) responsible entities must assess for potential impacts on the Bulk-Power 

System. However, the Commission declines to specify the severity of the storm or 

otherwise define the characteristics of these benchmark GMD events in this Final Rule. 

Rather, NERC, through its standards development process, should identify the

benchmark GMD events that responsible entities would have to assess.97 Each 

responsible entity under the Second Stage GMD Reliability Standards would then be 

required to assess its vulnerability to the benchmark GMD events consistent with the 

five assessment parameters identified in the NOPR and adopted in this Final Rule.

98 The 

NERC standards development process should consider tasking planning coordinators, or 

 97 Similar work is already being done in Phase 2 of the NERC GMD Task Force 

Plan. The GMD Task Force Phase 2 Scope and Project Plan states that the NERC GMD 

Task Force will “refine and improve a set of defined reference storms (most severe 

occurrence in a 100-year time horizon) and support ongoing research to identify the 

maximum theoretical GMD.” GMD Task Force Phase 2 Scope and Project Plan at 5.

98 NOPR, 141 FERC ¶ 61,045 at PP 28-32.
Docket No. RM12-22-000 - 45 -

another functional entity with a wide-area perspective, to coordinate assessments across 

Regions under the Second Stage GMD Reliability Standards to ensure consistency and 

regional effectiveness.

68. The comments that oppose requiring assessments stress that there is a substantial 

amount of work being done by the NERC GMD Task Force and industry to develop and 

validate tools, models, and data to perform the vulnerability assessments. We recognize 

that the tools for assessing GMD vulnerabilities are not fully mature. To address this 

concern, NERC should consider developing Reliability Standards that can incorporate 

improvements in the scientific understanding of GMDs. When developing the Second 

Stage GMD Reliability Standards implementation schedule, NERC should consider the 

availability of validated tools, models, and data necessary to comply with the 

Requirements.

69. Some tools currently exist and others are expected to be available when the 

Second Stage GMD Reliability Standards become effective. For example, NERC states 

in its comments that, while only one component of developing a comprehensive 

understanding of the effects of GMDs on the Bulk-Power System, NERC and the Electric 

Power Research Institute have developed a vulnerability assessment tool that calculates 

expected GIC levels and has released the tool in an open-source code.99 In addition, 

 99 NERC Comments at 13. As noted at the April 30, 2012 Technical Conference, 

John Kappenman stated that his investigations are based on mathematical models 

regarding the impacts of GMDs on the Bulk-Power System. See, e.g., April 30, 2012 

Prepared Testimony of John G. Kappenman at 1. 
Docket No. RM12-22-000 - 46 -

NERC stated in its May 12, 2012 post-Technical Conference comments that NERC 

expects to complete several “Mid-Term Actions” within 12 to 36 months relating to the 

development of GMD assessment tools. These “Mid-Term Actions” include: (1) 

refining probabilistic geomagnetic disturbance storm scenarios; (2) performing 

comprehensive tests of transformers to GIC; (3) increasing GIC monitoring locations 

across North America; and (4) developing analytical tools for system planners and 

operators to reliably manage geomagnetic disturbance impacts.100 The 18-month

deadline to submit the Second Stage GMD Reliability Standards (i.e., early-2015) falls 

within NERC’s 12 to 36 month window for completion of the “Mid-Term Actions.” 

Moreover, it is likely that the implementation date of the Second Stage GMD Reliability 

Standards will be after the completion of the “Mid-Term Actions.” As a result, 

responsible entities will likely have additional tools available to conduct GMD 

vulnerability assessments once the Second Stage GMD Reliability Standards become 

effective. In any event, as we explain above, NERC should consider the availability of 

validated tools, models, and data as it develops an implementation schedule for the 

Second Stage GMD Reliability Standards.

70. In response to commenters who note that entities may have different 

vulnerabilities to GMD events based on their geographic location and geology, we 

emphasize that the vulnerability assessments in the Second Stage GMD Reliability 

 100 NERC May 12, 2012 Comments at 10-12.
Docket No. RM12-22-000 - 47 -

Standards should not assume that all owners and operators of the Bulk-Power System are 

the same. However, we disagree with commenters that it is not realistic to base 

vulnerability assessments on uniform evaluation criteria.101 We clarify that the NOPR 

did not intend to require responsible entities to use uniform values when assessing their 

GMD vulnerabilities. Instead, the vulnerability assessments would be based on uniform 

criteria (e.g., geographic location and geology) but the values for such criteria would be 

entity-specific. 

71. In drafting the Second Stage GMD Reliability Standards, NERC should identify 

what severity GMD events (i.e., benchmark GMD events) responsible entities will have 

to assess, and NERC should technically support its choice. The benchmark GMD events 

should be based on factors that may include, but are not limited to, varying severity of the 

GMD (i.e., the rate of change in the GMDs magnetic fields), duration, geographic

footprint of the GMD, how the GMD’s intensity varies with latitude, system 

configuration, and the orientation of the magnetic fields produced by the GMD.102 We 

recognize that there is currently no consensus on benchmark GMD events, and the 

Commission does not identify specific benchmark GMD events for NERC to adopt. 

 101 NOPR, 141 FERC ¶ 61,045 at P 27.

102 NERC Interim GMD Report at 82 (“The first step is to develop a handful of 

scenarios and the associated probability of each (e.g., severe storm – once in 100 years; 

serious storm once in 10 years).”). The Commission recognizes that this is not an 

exhaustive list and additional factors may be added as new information becomes 

available. 
Docket No. RM12-22-000 - 48 -

Instead, this issue should be considered in the NERC standards development process so 

that any benchmark GMD events proposed by NERC have a strong technical basis.

2. Plans to Address Identified GMD Vulnerabilities

NOPR

72. The NOPR proposed to direct the ERO to develop Reliability Standards that 

require owners and operators of the Bulk-Power System to develop and implement a 

plan, based on the results of the GMD vulnerability assessments, so that instability, 

uncontrolled separation, or cascading failures of the Bulk-Power System, caused by 

damage to critical or vulnerable Bulk-Power System equipment, or otherwise, will not 

occur as a result of a GMD. The NOPR did not propose to require a particular solution in 

the Second Stage GMD Reliability Standards to address identified vulnerabilities. 

However, the NOPR stated that it expected that some assessments will demonstrate that 

automatic blocking is necessary in some instances. 

73. The NOPR stated that automatic blocking measures address the two major 

concerns with relying exclusively on operational procedures to mitigate GMDs (i.e., the 

short period of time to react to a GMD event and operational procedures may not prevent 

damage to Bulk-Power System equipment). The NOPR stated that automatic blocking 

can prevent the flow of GICs through power transformers and the Bulk-Power System.103 

The NOPR further stated that eliminating GICs in transformers prevents transformer core 

 103 NOPR, 141 FERC ¶ 61,045 at P 34 (citing NERC Interim GMD Report at 73).
Docket No. RM12-22-000 - 49 -

saturation and, thus, mitigates or prevents the effects of GMDs on the Bulk-Power 

System (i.e., transformer overheating, reactive power absorption, and harmonic 

generation). The NOPR did not propose to direct the ERO to require a particular 

automatic blocking technology, where blocking is deemed necessary. Instead, the 

Commission proposed to direct the ERO to identify in the Reliability Standards what 

would constitute appropriate automatic blocking measures. In defining what is an 

appropriate blocking measure, the NOPR stated that the ERO should address: (1) its 

feasibility and effectiveness; and (2) its ability to operate without adversely impacting the 

reliable operation of the Bulk-Power System. The NOPR also proposed that the 

Reliability Standards should include a means by which the ERO can verify that selected 

blocking measures are appropriate. 

74. The NOPR stated that, while not a means for blocking GICs, another possible 

option is to improve the “withstand” capability of Bulk-Power System components, 

which refers to a component’s ability to withstand stresses imposed by GICs before 

suffering damage.

104 The NOPR stated that the ERO should consider whether the 

reliability goals of the proposed Reliability Standards can be achieved by a combination 

of automatic protection measures, including, for example, some combination of 

automatic blocking and improved “withstand” capability.

 104 NOPR, 141 FERC ¶ 61,045 at P 36 (citing NERC Interim GMD Report at 67).
Docket No. RM12-22-000 - 50 -

Comments

75. NERC states that the Second Stage GMD Reliability Standards should be 

technology-neutral and should not require dedicated blocking devices or other specific 

equipment. NERC further states that it is currently unable to verify whether a specific 

blocking device is appropriate. 

76. A majority of commenters state that blocking devices need further study and that 

the Commission should clarify that the Second Stage GMD Reliability Standards will not 

require responsible entities to install blocking devices or require installation of any 

particular type of mitigation.105 Bonneville, for example, states that the “capability to 

perform studies that include transformer thermal models needed for developing 

appropriate mitigation plans and blocking strategies will likely not be available for use 

until the end of the 2014 at the earliest.”106 Commenters also express concern with the 

statement in the NOPR that plans for addressing GMD vulnerabilities cannot be limited 

to operational procedures or enhanced training alone because the commenters understand 

this language to require the installation of automatic blocking devices. PJM requests that 

the Reliability Standards explicitly state that equipment owners, not system operators, are 

the responsible entities.107 

 105 See, e.g., Trade Associations Comments at 32; Joint ISOs/RTOs Comments at 

18; Bonneville Comments at 7; Exelon Comments at 11-12.

106 Bonneville Comments at 6.

107 PJM Comments at 4-5.
Docket No. RM12-22-000 - 51 -

77. Some commenters state that the Second Stage GMD Reliability Standard should 

not require responsible entities to implement a plan that prevents cascading failures but 

instead support a Reliability Standard that allows NERC to determine the appropriate mix 

between prevention and timely restoration of the Bulk-Power System. Commenters also 

express concern with the language in the NOPR that, under the Second Stage GMD 

Reliability Standards, responsible entities would be required to “develop and implement a 

plan so that instability, uncontrolled separation, or cascading failures of the Bulk-Power 

System, caused by damage to critical or vulnerable Bulk-Power System equipment, or 

otherwise, will not occur as a result of a GMD.” Commenters state that such a standard 

imposes strict liability on responsible entities and is inconsistent with the unpredictable 

and uncontrolled nature of GMD events.

78. Other commenters express support for hardening elements of the Bulk-Power 

System as an option to protect against GMD events.108 Some of these commenters state 

that operational procedures alone do not prevent the flow of GICs through Bulk-Power 

System elements; instead, operational procedures are intended to prevent the Bulk-Power 

System from collapsing, which exposes equipment to GICs for longer periods. EIS states 

that a combination of operational procedures and hardware is needed to protect the BulkPower System. Foundation states that relying on operational procedures alone, based on 

warnings from space weather observations, renders the Advanced Composition Explorer 

 108 See, e.g., Pa PUC Comments at 4; Bonneville Comments at 7.
Docket No. RM12-22-000 - 52 -

satellite, which gives details about an approaching GMD, a single point of failure in 

protecting the Bulk-Power System. Commenters also state that the benefits afforded by 

operational procedures are unpredictable because the state of the Bulk-Power System 

(e.g., load, available generation, unplanned equipment outages) at the time of a GMD 

event cannot be known in advance.

Commission Determination

79. We direct NERC, within 18 months of the effective date of this Final Rule, to 

submit for approval one or more Reliability Standards that, assuming the assessments 

identify potential impacts from a benchmark GMD event, require owners and operators 

of the Bulk-Power System to develop and implement a plan to protect against instability, 

uncontrolled separation, or cascading failures of the Bulk-Power System, caused by 

damage to critical or vulnerable Bulk-Power System equipment, or otherwise, as a result 

of a benchmark GMD event. Owners and operators of the Bulk-Power System cannot 

limit their plans to considering operational procedures or enhanced training, but must, 

subject to the vulnerabilities identified in the assessments, contain strategies for 

protecting against the potential impact of any benchmark GMD event based on factors 

such as the age, condition, technical specifications, system configuration, or location of 

specific equipment. These strategies could, for example, include automatically blocking 

GICs from entering the Bulk-Power System, instituting specification requirements for 

new equipment, inventory management, and isolating certain equipment that is not cost 

effective to retrofit, or a combination thereof.
Docket No. RM12-22-000 - 53 -

80. A major concern raised in the comments is that the NOPR proposed to require 

responsible entities to utilize automatic blocking devices. However, the NOPR explicitly 

stated that it did not propose to require a particular solution in the Second Stage GMD 

Reliability Standards to address GMD vulnerabilities. The NOPR only stated that it 

expected that some assessments will demonstrate that automatic blocking is necessary in 

some instances. While the NOPR proposed to provide guidance with respect to the use 

and evaluation of automatic blocking devices, the NOPR did not propose to require the 

use of automatic blocking devices.

81. In this Final Rule, we do not direct the ERO to develop Reliability Standards that 

require the use of automatic blocking devices or any specific technology. We agree with 

NERC that the Reliability Standards should be technology-neutral.109 Instead, the 

Second Stage GMD Reliability Standards should require owners and operators of the 

Bulk-Power System to develop and implement a plan to protect against instability, 

uncontrolled separation, or cascading failures of the Bulk-Power System, caused by 

damage to critical or vulnerable Bulk-Power System equipment, or otherwise, as a result 

of a benchmark GMD event. In the NOPR, we identified a non-exhaustive list of 

possible automatic measures for doing so, including automatically blocking GICs from 

entering the Bulk-Power System, instituting specification requirements for new 

 109 NERC Comments at 4.
Docket No. RM12-22-000 - 54 -

equipment, inventory management, and isolating certain equipment that is not cost 

effective to retrofit. 

82. As with the First Stage GMD Reliability Standards, the responsible entities should 

perform vulnerability assessments of their own systems and develop the plans for 

mitigating any identified vulnerabilities. We take no position in this Final Rule on which 

functional entities should be responsible for compliance under the Second Stage GMD 

Reliability Standards. However, the NERC standards development process should 

consider tasking planning coordinators, or another functional entity with a wide-area 

perspective, to coordinate mitigation plans across Regions under the Second Stage GMD 

Reliability Standards to ensure consistency and regional effectiveness. We clarify that if 

a responsible entity performs the required GMD vulnerability assessments and finds no 

potential GMD impacts, no plan is required under the Second Stage GMD Reliability 

Standards.110 

83. The NOPR stated that if a responsible entity identifies GMD vulnerabilities, then 

the plan cannot be limited to operational procedures or enhanced training alone. Some 

commenters interpreted this to mean that a responsible entity could never rely on 

operational procedures alone. We clarify that if the GMD vulnerability assessments in 

the Second Stage GMD Reliability Standards identify potential GMD impacts, while the 

development of the required mitigation plan cannot be limited to considering operational 

 110 NOPR, 141 FERC ¶ 61,045 at P 16 n.37.
Docket No. RM12-22-000 - 55 -

procedures or enhanced training alone, operational procedures and enhanced training may 

be sufficient if that is verified by the vulnerability assessments. 

84. The Second Stage GMD Reliability Standards should not impose “strict liability” 

on responsible entities for failure to ensure the reliable operation of the Bulk-Power 

System in the face of a GMD event of unforeseen severity, as some commenters fear. 

The NOPR proposed to require owners and operators to develop and implement a plan so 

that instability, uncontrolled separation, or cascading failures of the Bulk-Power System, 

caused by damage to critical or vulnerable Bulk-Power System equipment, or otherwise, 

will not occur as a result of a GMD.

111 While this language is taken directly from the 

definition of “reliable operation” in FPA section 215(a)(4), and similar language is found 

in the Requirements of other Reliability Standards, we clarify that owners and operators 

should be required to develop and implement a plan to protect against instability, 

uncontrolled separation, or cascading failures of the Bulk-Power System, caused by 

damage to critical or vulnerable Bulk-Power System equipment, or otherwise, as a result 

of a benchmark GMD event. The goal of the NERC standards development process 

should be to propose Reliability Standards that ensure the reliable operation of the Bulk-

 111 16 U.S.C. 824o(a)(4) (“The term ‘reliable operation’ means 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.”).
Docket No. RM12-22-000 - 56 -

Power System in response to identified benchmark GMD events.

112 Identifying robust 

and technically justified benchmark GMD events in the Reliability Standards, that the 

Bulk-Power System is required to withstand (i.e., continue “reliable operation”), 

addresses the concern that responsible entities might otherwise be required to prevent

instability, uncontrolled separation, or cascading failures of the Bulk-Power System when 

confronted with GMD events of unforeseen severity. In addition, the Reliability 

Standards should include Requirements whose goal is to prevent instability, uncontrolled 

separation, or cascading failures of the Bulk-Power System when confronted with a 

benchmark GMD event. Given that the scientific understanding of GMDs is still 

evolving, we recognize that Reliability Standards cannot be expected to protect against 

all GMD-induced outages.

85. In the NOPR, we proposed to direct the ERO to identify what would constitute 

appropriate automatic blocking measures. The NOPR stated that, in defining what is an 

appropriate blocking measure, the ERO should address: (1) feasibility and effectiveness; 

and (2) ability to operate without adversely impacting the reliable operation of the BulkPower System. The comments reflect that certain entities have implemented automatic 

blocking measures, but the comments also reflect concerns with the unintended effects of 

automatic blocking measures and the uncertainties surrounding automatic blocking 

 112 See, e.g., Reliability Standard TOP-004-2, Requirement R2 (“Each 

Transmission Operator shall operate so that instability, uncontrolled separation, or 

cascading outages will not occur as a result of the most severe single contingency.”).
Docket No. RM12-22-000 - 57 -

measures.

113 We do not require the use of automatic blocking measures in the Second 

Stage GMD Reliability Standards. However, given that some responsible entities have or 

may choose automatic blocking measures, the NERC standards development process 

should consider how to verify that selected blocking measures are effective and 

consistent with the reliable operation of the Bulk-Power System.

86. The NOPR stated that another possible mitigation option is to improve the 

“withstand” capability of Bulk-Power System components. The NOPR stated that the 

“withstand” capability refers to a component’s ability to withstand stresses imposed by 

GICs before suffering damage. While responsible entities will decide how to mitigate 

GMD vulnerabilities on their systems, the NERC standards development process should 

consider how the reliability goals of the proposed Reliability Standards can be achieved 

by a combination of automatic measures including, for example, some combination of 

blocking, improved “withstand” capability, instituting specification requirements for new 

equipment, inventory management, and isolating certain equipment that is not cost 

effective to retrofit. As with the First Stage GMD Reliability Standards, NERC can 

identify and disseminate to responsible entities the measures or the combination of 

measures adequate to maintain the reliable operation of the Bulk-Power System against 

the potential GMD impacts identified in the assessments.

 113 CEA Comments at 10; Bonneville Comments at 7; Dominion Comments at 7; 

CenterPoint Comments at 12-13; Exelon Comments at 11-12.
Docket No. RM12-22-000 - 58 -

3. Schedule for Submitting and Implementing Second Stage GMD 

Reliability Standards

NOPR

87. The NOPR proposed a six-month deadline to submit the Second Stage GMD 

Reliability Standards to the Commission. However, the NOPR did not propose to direct 

or suggest an implementation schedule for the Second Stage GMD Reliability Standards. 

Instead, the NOPR stated that the Reliability Standards would likely require an extended, 

multi-phase implementation period given the time needed to conduct the required 

assessments and the time and cost of installing any required automatic protection 

measures. The NOPR stated that it would be appropriate for the Second Stage GMD 

Reliability Standards to include an implementation schedule that requires owners and 

operators of the Bulk-Power System to prioritize implementation so that components 

considered vital to the reliable operation of the Bulk-Power System are protected in the 

earliest phase of the implementation plan. 

Comments

88. NERC states that “[w]hile the implementation proposed for the completion of the 

second stage Reliability Standards is aggressive, NERC is committed to meeting 

whatever implementation targets are established by the Commission in the final rule.”114 

 114 NERC Comments at 13.
Docket No. RM12-22-000 - 59 -

Other commenters support adoption of the proposed six-month filing deadline for the 

Second Stage GMD Reliability Standards.115

89. Some commenters, including those supporting the Second Stage GMD Reliability 

Standards, express concern with the six-month deadline proposed in the NOPR because 

six months does not allow enough time to address the complex issues raised by the 

proposed Reliability Standards.116 Joint ISOs/RTOs propose a one-year development and 

filing deadline.117 Idaho Power proposes an 18-month deadline for submitting the 

Reliability Standards and a three-year, multi-phased implementation period.

118 Exelon 

recommends that NERC should propose a filing deadline.119

90. Commenters opposing the Second Stage GMD Reliability Standards state that the 

development of Second Stage GMD Reliability Standards should be delayed given the 

need for further research into GMDs and the continuing work of the NERC GMD Task 

Force.

Commission Determination

91. In its comments, NERC commits to meeting the six-month submission deadline 

proposed in the NOPR. However, based on the concerns raised in the comments, we

 115 See, e.g., Foundation Comments at 19.

116 See, e.g., LADWP Comments at 5; Joint ISOs/RTOs Comments 24-25.

117 Joint ISOs/RTOs Comments at 24.

118 Idaho Power Comments at 2.

119 Exelon Comments at 14.
Docket No. RM12-22-000 - 60 -

modify the schedule in the NOPR and direct NERC to submit the proposed Second Stage 

GMD Reliability Standards within 18 months of the effective date of this Final Rule. 

While NERC should propose an implementation plan, we do not direct or suggest a 

specific implementation plan. As stated in the NOPR, in a proposed implementation 

plan, we expect that NERC will consider a multi-phased approach that requires owners 

and operators of the Bulk-Power System to prioritize implementation so that components 

considered vital to the reliable operation of the Bulk-Power System are protected first. 

We also expect, as discussed above, that the implementation plan will take into account 

the availability of validated tools, models, and data that are necessary for responsible 

entities to perform the required GMD vulnerability assessments. 

III. Information Collection Statement

92. The Office of Management and Budget (OMB) regulations require approval of 

certain information collection requirements imposed by agency rules. 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 an agency 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. The Paperwork 

Reduction Act (PRA) requires each federal agency to seek and obtain OMB approval 

before undertaking a collection of information directed to ten or more persons, or 

contained in a rule of general applicability. 

93. The Commission is submitting these reporting requirements to OMB for its review 

and approval under section 3507(d) of the PRA. The Commission solicited comments on 
Docket No. RM12-22-000 - 61 -

the Commission’s need for this information, whether the information will have practical 

utility, ways to enhance the quality, utility, and clarity of the information to be collected, 

and any suggested methods for minimizing the respondent’s burden, including the use of 

automated information techniques. The Commission received no comments on the 

burden and cost information contained in the NOPR. 

94. The Public Reporting Burden and cost related to the proposed rule in Docket 

RM12-22-000 are covered by, and already included in, the existing FERC-725, 

Certification of Electric Reliability Organization; Procedures for Electric Reliability 

(OMB Control No. 1902-0225). FERC-725 includes the ERO’s overall responsibility 

for developing Reliability Standards, such as the Reliability Standards for Geomagnetic 

Disturbances. 

95. Internal review: The Commission has reviewed the proposed changes and has 

determined that the changes are necessary to ensure the reliability and integrity of the 

Nation’s Bulk-Power System. 

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

contacting: Federal Energy Regulatory Commission, 888 First Street, NE, Washington, 

DC 20426 [Attention: Ellen Brown, Office of the Executive Director, e-mail: 

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

the requirements of this rule may also be sent to the Office of Information and Regulatory 

Affairs, Office of Management and Budget, Washington, DC 20503 [Attention: Desk 

Officer for the Federal Energy Regulatory Commission]. For security reasons, comments 

should be sent by e-mail to OMB at oira_submission@omb.eop.gov. Please reference 
Docket No. RM12-22-000 - 62 -

OMB Control No. 1902-0225, FERC-725 and the docket number of this proposed 

rulemaking in your submission.

IV. Environmental Analysis

97. 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.120 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.121 The actions proposed here fall within this categorical exclusion in the 

Commission’s regulations.122 

 120 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).

121 18 CFR 380.4(a)(2)(ii).

122 Only one commenter, SENS, addressed the NOPR’s Environmental Analysis 

proposal. SENS requested that the Commission “include an environmental impact 

assessment of GMD-induced power outage on the approximately 104 nuclear power 

plants in the United States if the proposed rules are not enacted.” SENS Comments at 5 

(emphasis in original). The request in this comment is moot in light of the Commission’s 

directive in this Final Rule that the ERO develop and submit for approval proposed GMD 

Reliability Standards.
Docket No. RM12-22-000 - 63 -

V. Regulatory Flexibility Act

98. The Regulatory Flexibility Act of 1980 (RFA)123 generally requires a description 

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

number of small entities. The RFA mandates consideration of regulatory alternatives that 

accomplish the stated objectives of a proposed rule and that minimize any significant 

economic impact on a substantial number of small entities. The Small Business 

Administration’s (SBA) Office of Size Standards develops the numerical definition of a 

small business.124 The SBA has established a size standard for electric utilities, stating 

that a firm is small if, including its affiliates, it is primarily engaged in the transmission, 

generation and/or distribution of electric energy for sale and its total electric output for 

the preceding twelve months did not exceed four million megawatt hours.125

99. The NOPR stated that, by proposing only to direct NERC, the Commissioncertified ERO, to develop GMD Reliability Standards, the proposal would not have a 

significant or substantial impact on entities other than NERC. The NOPR stated that the 

ERO develops and files with the Commission for approval Reliability Standards affecting 

the Bulk-Power System, which represents: (a) a total electricity demand of 830 gigawatts 

(830,000 megawatts) and (b) more than $1 trillion worth of assets. Therefore, the NOPR 

certified that the proposal will not have a significant economic impact on a substantial 

 123 5 U.S.C. 601-612.

124 13 CFR 121.101.

125 13 CFR 121.201, Sector 22, Utilities & n.1.
Docket No. RM12-22-000 - 64 -

number of small entities. The NOPR further stated that any Reliability Standards 

proposed by NERC in compliance with this rulemaking will be considered by the 

Commission in future proceedings and that, 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.

100. The Commission received one comment addressing the Regulatory Flexibility Act 

certification in the NOPR.

Comments

101. APPA, NRECA, and TAPS state that the GMD Reliability Standards could result 

in significant adverse regulatory impacts on many small utilities. APPA, NRECA and 

TAPS state that, while it might be premature for the Commission to engage in a full RFA 

analysis at this stage, putting off an RFA analysis will make it more difficult to perform 

an analysis in the future. APPA, NRECA and TAPS state that the Commission should at 

least gather the necessary facts in the comment phase of this rulemaking so that it can 

develop a record on the universe of small entities that could be affected by NERC 

Reliability Standards addressing GMDs and possible ways to mitigate any adverse 

impacts of such Reliability Standards. APPA, NRECA and TAPS encourage the 

Commission to host a “technical conference, convene[] a panel of small utility 

representatives, or undertake some other comparable outreach effort to solicit information 
Docket No. RM12-22-000 - 65 -

from the small entities that may be affected by the contemplated GMD reliability 

standards.” 126

Commission Determination

102. The Commission certifies that this final rule will not have a significant economic 

impact on a substantial number of small entities. We affirm the reasoning in the NOPR 

that, in only directing the ERO to develop and submit for approval GMD Reliability 

Standards, this Final Rule only applies to NERC, which, as discussed above, is not a 

small entity. APPA, NRECA and TAPS concede that it would be premature to conduct a 

full Regulatory Flexibility Analysis at this time, but they state that it could be more 

difficult to conduct such an analysis in the future. We disagree because the Commission 

cannot assess the economic impact on small entities of the GMD Reliability Standards at 

this time since they have not been developed or submitted for approval by NERC. Such 

an analysis, at this time, would be purely speculative. As we stated in the NOPR, the 

GMD Reliability Standards proposed by NERC in compliance with this Final Rule will 

be considered by the Commission in future rulemakings. As part of those rulemakings, 

the Commission will make determinations pertaining to the Regulatory Flexibility Act 

based on the content of the Reliability Standards proposed by NERC. While the 

Commission declines to conduct the types of outreach suggested by APPA, NRECA, and 

TAPS at this time, APPA, NRECA and TAPS should participate in the standards 

 126 APPA, NRECA, and TAPS Comments at 6.
Docket No. RM12-22-000 - 66 -

development process as NERC develops the Reliability Standards required by this Final 

Rule to ensure that their views are taken into account. In addition, the Commission 

welcomes any informal discussions on these issues as NERC develops the Reliability 

Standards required by this final rule.

VI. 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) and in the Commission's Public Reference Room during normal 

business hours (8:30 am to 5:00 pm Eastern time) at 888 First Street, NE, Room 2A, 

Washington DC 20426.

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 (202) 502-6652 (toll 

free at 1-866-208-3676) or email 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.
Docket No. RM12-22-000 - 67 -

VII. Effective Date and Congressional Notification

106. These regulations are effective [60 days after publication in the 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.

By the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.
Docket No. RM12-22-000 - 68 -

Appendix

Commenters

Abbreviation Commenter

Alcoa Alcoa Inc. and Alcoa Power Generating Inc. 

AFS Advanced Fusion Systems

AEP American Electric Power Service Corporation

APS Arizona Public Service Company

Ayers Cynthia E. Ayers

George Baker George H. Baker III, Ph. D

Joel Baker Joel E. Baker

Bequette William Bequette

Bowen Dwane M. Bowen

Boyd David A. Boyd

Bonneville Bonneville Power Administration

CEA Canadian Electricity Association

CenterPoint CenterPoint Energy Houston Electric, LLC

Clinic Samuelson-Glushko Technology Law and Policy Clinic, 

University of Colorado Law School

Congressman Franks Congressman Trent Franks

Consumers Energy Consumers Energy Company

Dominion Dominion Resources Services, Inc.

Duke Duke Energy Corporation

EEI Edison Electric Institute

EIS Electric Infrastructure Security Council

ELCON Electricity Consumers Resource Council

Emprimus Emprimus LLC

EPSA Electric Power Supply Association

Exelon Exelon Corporation

Foundation Foundation for Resilient Societies

FPL Florida Power & Light Company

Frauman Roger Frauman

Greenhill John Greenhill

Idaho Power Idaho Power Company

IESO Independent Electricity Operator and Hydro One Networks, 

Inc.

ITC International Transmission Company

Joint ISOs/RTOs Alberta Electric System Operator, California Independent 

System Operator, Electric Reliability Council of Texas, 

Independent Electricity System Operator of Ontario, Inc., ISO 

New England Inc., Midwest Independent Transmission 

System Operator, Inc., New York Independent System 
Docket No. RM12-22-000 - 69 -

Operator, Inc., and Southwest Power Pool (SPP)

Johnson Amanda Johnson

Kappenman John Kappenman, Storm Analysis Consultants

KCP&L Kansas City Power & Light Company and KCP&L Greater 

Missouri Operations Company

Koenig Roger L. Koenig, Michigan State University

Kristen Steven F. Kristen

LADWP City of Los Angeles Department of Water and Power

Leggett Nickolaus Leggett

Lloyd’s Lloyd’s

Lund John Curtis Lund

Manto Charles L. Manto

Mitsubishi Electric Mitsubishi Electric Power Products, Inc.

NARUC National Association of Regulatory Utility Commissioners

NERC North American Electric Reliability Corporation

NV Energy Nevada Power Company and Sierra Pacific Power Company

Pa PUC Pennsylvania Public Utility Commission

Phoenix Phoenix Electric Corp.

PJM PJM Interconnection, L.L.C.

PPL Companies Louisville Gas and Electric Company and Kentucky Utilities 

Company, Lower Mount Bethel Energy, LLC, PPL Brunner 

Island, LLC, PPL Electric Utilities Corporation, PPL 

EnergyPlus, LLC, PPL Ironwood, LLC, PPL Martins Creek, 

LLC, PPL Montana, LLC, PPL Montour, LLC, and PPL 

Susquehanna LLC

Orquin Alberto Ramirez Orquin, PhD

Ruckriegle Heidi Ruckriegle

SCE Southern California Edison

SDG&E San Diego Gas & Electric

SENS Stored Energy Systems LLC

SmartSenseCom SmartSenseCom, Inc.

SPP Parties AEP, City of Coffeyville, Kansas, City of Independence, 

Missouri, Oklahoma Municipal Power Authority, SPP, 

Southwester Power Administration, Westar Energy, Inc., and 

Western Farmers Electric Cooperative

Stolov Jerome J. Stolov

TAPS Transmission Access Policy Study Group

Trade Associations American Public Power Association (APPA), Edison Electric 

Institute, Large Public Power Council, National Rural Electric 

Cooperative Association (NRECA)

Wallenmeyer William Wallenmeyer