130 FERC ¶ 61,033 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

[Docket No. RM10-9-000] 

Transmission Loading Relief Reliability Standard and Curtailment Priorities 

(Issued January 21, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Inquiry 

SUMMARY: The Commission requests comment on the interplay between Reliability 

Standard IRO-006-4 (Reliability Coordination – Transmission Loading Relief) and the 

curtailment priorities set forth in the Commission’s pro forma open access transmission 

tariff, particularly sections 13.6 and 14.7. 

DATES: Comments are due 60 days after publication in the FEDERAL REGISTER

ADDRESSES: You may submit comments, identified by docket number by any of the 

following methods: 

 Agency Web Site: http://www.ferc.gov. Documents created electronically using 

word processing software should be filed in native applications or print-to-PDF 

format and not in a scanned format. 

 Mail/Hand Delivery: Commenters unable to file comments electronically must 

mail or hand deliver an original and 14 copies of their comments to: Federal 

Energy Regulatory Commission, Office of the Secretary, 888 First Street, NE, 

Washington, DC 20426. 

Instructions: For detailed instructions on submitting comments and additional 
Docket No. RM10-09-000 - 2 - 

information on the rulemaking process, see the Comment Procedures Section of this 

document. 

FOR FURTHER INFORMATION CONTACT: 

Ruta Kalvaitis Skučas 

Federal Energy Regulatory Commission, Office of the General Counsel 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6647 

ruta.skucas@ferc.gov 

Thomas Dautel 

Federal Energy Regulatory Commission, Office of Energy Policy & Innovation 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6196 

thomas.dautel@ferc.gov

Thanh Loung 

Federal Energy Regulatory Commission, Office of Electric Reliability 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6080 

thanh.luong@ferc,gov 

SUPPLEMENTARY INFORMATION:
UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Before Commissioners: Jon Wellinghoff, Chairman; 

 Marc Spitzer, Philip D. Moeller, 

 and John R. Norris. 

Transmission Loading Relief Reliability 

Standard and Curtailment Priorities 

Docket No. RM10-9-000 

NOTICE OF INQUIRY 

(Issued January 21, 2010) 

1. In this Notice of Inquiry (NOI), the Commission requests comments from industry 

and stakeholders regarding the interplay between Reliability Standard IRO-006-4 

(Reliability Coordination – Transmission Loading Relief) and curtailment priorities in 

Commission-approved Open Access Transmission Tariffs (OATT). The Commission 

seeks further information, comments and data on whether Reliability Standard IRO-006-4 

directs a reliability coordinator to curtail a firm interchange transaction crossing over a 

constrained flowgate prior to curtailing a non-firm native network load transaction across 

the same flowgate. 

I. Background

2. On December 21, 2007, the North American Electric Reliability Corporation 

(NERC), the Commission-certified electric reliability organization (ERO), submitted for 

Commission approval modifications to Reliability Standard IRO-006-3, known as the 

transmission loading relief (TLR) procedure.1

 As discussed in greater detail below, 

 

(continued)

1

 Reliability Standard IRO-006-4 modifies Reliability Standard IRO-006-3, which 
Docket No. RM10-9-000 - 2 - 

Reliability Standard IRO-006-4 provides Interconnection-wide transmission loading 

relief procedures that can be used to prevent or manage potential or actual system 

operating limit or interconnection reliability operating limit violations.2

 

3. As discussed below, the NRG Companies filed comments on Reliability Standard 

IRO-006-4, asserting that the proposed modified Reliability Standard is not consistent 

with the requirements of the Commission-approved pro forma OATT. They asserted 

that, due to flaws in the Interchange Distribution Calculator,3

 firm transactions may be 

curtailed prior to non-firm transactions, resulting in an OATT violation. They also 

argued that the Interchange Distribution Calculator is flawed for several reasons, 

including that it does not take native load transactions into account when determining 

which transactions should be curtailed to relieve congestion. The Constellation Energy 

Commodities Group, Inc. filed comments in support of the NRG Companies’ comments, 

 

the Commission approved in Order No. 693. Mandatory Reliability Standards for the 

Bulk-Power System, Order No. 693, FERC Stats. & Regs. ¶ 31,242, order on reh’g, 

Order No. 693-A, 120 FERC ¶ 61,053 (2007). 

2

 A System Operating Limit or SOL is the value (such as MW, MVar, amperes, 

frequency or volts) that satisfies the most limiting of the prescribed operating criteria for 

a specified system configuration to ensure operation within acceptable reliability criteria. 

NERC Glossary of Terms Used in Reliability Standards at 19, available at

http://www.nerc.com/files/Glossary_12Feb08.pdf (NERC Glossary). An Interconnection 

Reliability Operating Limit or IROL is a system operating limit that, if violated, could 

lead to instability, uncontrolled separation, or cascading outages that adversely impact the 

reliability of the Bulk-Power System. Id. at 10. 

3

 The Interchange Distribution Calculator is a mechanism used by the reliability 

coordinators in the Eastern Interconnection to calculate the distribution of interchange 

transactions over specific flowgates. It includes a database of all interchange transactions 

and a matrix of the distribution factors for the Eastern Interconnection. Id. at 9. 
Docket No. RM10-9-000 - 3 - 

arguing that the use of the Interchange Distribution Calculator has resulted in unjust and 

discriminatory curtailments, particularly firm transactions before non-firm transactions. 

4. On July 21, 2008, the Commission issued Order No. 713, which, inter alia, 

directed NERC to submit a filing explaining one aspect of the TLR procedure before such 

procedure could be approved.4

 Following NERC’s response, on March 19, 2009, the 

Commission approved Reliability Standard IRO-006-4 in Order No. 713-A. In addition, 

the Commission directed NERC to develop modifications to IRO-006-4, pursuant to 

section 215(d)(5) of the Federal Power Act (FPA).5

 In response to comments regarding 

competitive concerns and the application of the Interchange Distribution Calculator, the 

Commission concluded: 

The above comments on suggested improvements to the [transmission 

loading relief] procedure are beyond the scope of this proceeding, which 

pertains to the separation of business practices from the ERO’s 

[transmission loading relief] procedure and implementation of the 

Commission’s directives set forth in Order No. 693. We note, however, 

that the ERO indicated in its December 21, 2007 filing that it has a threephase plan to improve the [transmission loading relief] procedures, and the 

 4

 Modification of Interchange and Transmission Loading Relief Reliability 

Standards; and Electric Reliability Organization Interpretation of Specific Requirements 

of Four Reliability Standards, Order No. 713, 124 FERC ¶ 61,071 (2008), order on reh’g, 

Order No. 713-A, 126 FERC ¶ 61,252 (2009), order on reh’g, Order No. 713-B, 130 

FERC ¶ 61,032 (2010). The Commission sought clarification of whether the removal and 

transfer to NAESB of business-related requirements formerly contained in Reliability 

Standard IRO-006-3 would impact bulk-power system reliability, an issue unrelated to 

the current proceeding. Order No. 713, 124 FERC ¶ 61,071 at P 50. 

5

 16 U.S.C. 824o(d)(5) (2006). The modifications relate to the use of the term 

“alone” in Requirement R1.1 and changes to the Violation Risk Factors for Requirements 

R1 through R4 to “high,” and are not related to the issues discussed in this NOI. Order 

No. 713-A, 126 FERC ¶ 61,252 at P 36, 59. 
Docket No. RM10-9-000 - 4 - 

third phase will consist of “a complete redrafting to incorporate 

enhancement and changes beyond the separation of reliability and 

business practice issues.” Therefore, the phase three proceeding would 

provide a proper forum for commenters to raise their concerns. The 

Commission believes that NRG and other commenters raise valid issues 

and urges the commenters to raise—and expects the ERO to consider—

these matters in an appropriate proceeding. We also note that NERC 

states it is currently updating the [Interchange Distribution Calculator] to 

more accurately determine the impacts of native load and network 

service.6

 

5. In a request for rehearing of Order No. 713-A, the NRG Companies, the Electric 

Power Supply Association, and Constellation Energy Commodities Group (Rehearing 

Parties) challenged the Reliability Standard on several grounds.7

 First, they assert that 

Reliability Standard IRO-006-4 violates the curtailment priorities established in Order 

Nos. 8888

 and 8909 and the pro forma OATT approved by the Commission in those 

proceedings, because the standard favors native network load transactions over 

 6

 Order No. 713-A, 126 FERC ¶ 61,252 at P 21 (footnotes omitted). 

7

 Request for Rehearing and Clarification of the NRG Companies, the Electric 

Power Supply Association and Constellation Energy Commodities Group, Docket 

No. RM08-7-002 (Apr. 20, 2009) (Request for Rehearing). 

8

 Promoting Wholesale Competition Through Open Access Non-Discriminatory 

Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities 

and Transmitting Utilities, Order No. 888, FERC Stats. & Regs. ¶ 31,036 (1996), order 

on reh’g, Order No. 888-A, FERC Stats. & Regs. ¶ 31,048, order on reh’g, Order 

No. 888-B, 81 FERC ¶ 61,248 (1997), order on reh’g, Order No. 888-C, 82 FERC 

¶ 61,046 (1998), aff’d in relevant part sub nom. Transmission Access Policy Study Group 

v. FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New York v. FERC, 535 U.S. 1 

(2002). 

9

 Preventing Undue Discrimination and Preference in Transmission Service, Order 

No. 890, FERC Stats. & Regs. ¶ 31,241, order on reh’g, Order No. 890-A, FERC Stats. & 

Regs. ¶ 31,261 (2007), order on reh’g, Order No. 890-B, 123 FERC ¶ 61,299 (2008),

order on reh’g, Order No. 890-C, 126 FERC ¶ 61,228 (2009). 
Docket No. RM10-9-000 - 5 - 

interchange transactions with respect to curtailment priority, and allows the curtailment 

of firm transactions before non-firm transactions. 

6. The Rehearing Parties assert that, under sections 13.6 and 14.7 of the 

Commission’s pro forma OATT, non-firm transmission services must be curtailed before 

firm transmission services, and firm point-to-point and network integration transmission 

service customers have an equal priority with the transmission provider’s use of the 

system to deliver Network Resources to its native load. They maintain that, because of 

its reliance on the flawed Interchange Distribution Calculator, Reliability Standard IRO006-4 would direct a reliability coordinator10 to curtail a firm interchange transaction 

crossing over a constrained flowgate prior to curtailing a non-firm native network load 

transaction across the same flowgate. The Rehearing Parties also assert that the 

Commission has recognized such flaws in the Interchange Distribution Calculator and 

has directed NERC to address them.11 

 10 The NERC Glossary defines a reliability coordinator as: “The entity that is the 

highest level of authority who is responsible for the reliable operation of the Bulk Electric 

System, has the Wide Area view of the Bulk Electric System, and has the operating tools, 

processes and procedures, including the authority to prevent or mitigate emergency 

operating situations in both next-day analysis and real-time operations. The Reliability 

Coordinator has the purview that is broad enough to enable the calculation of 

Interconnection Reliability Operating Limits, which may be based on the operating 

parameters of transmission systems beyond any Transmission Operator’s vision.” NERC 

Glossary at 16. 

11 Request for Rehearing at 8 n.12, citing North American Electric Reliability 

Council, 85 FERC ¶ 61,353 (1998). 
Docket No. RM10-9-000 - 6 - 

II. Discussion

A. OATT Requirements

7. Curtailment priorities are largely set forth in two sections of the Commission’s pro 

forma OATT. Section 13.6 of the Commission’s pro forma OATT, entitled Curtailment 

of Firm Transmission Service, provides that: 

Curtailments will be made on a non-discriminatory basis to the 

transaction(s) that effectively relieve the constraint. Transmission 

Provider may elect to implement such Curtailments pursuant to the 

Transmission Loading Relief procedures specified in Attachment J. If 

multiple transactions require Curtailment, to the extent practicable and 

consistent with Good Utility Practice, the Transmission Provider will 

curtail service to Network Customers and Transmission Customers taking 

Firm Point-To-Point Transmission Service on a basis comparable to the 

curtailment of service to the Transmission Provider's Native Load 

Customers. All Curtailments will be made on a non-discriminatory basis, 

however, Non-Firm Point-To-Point Transmission Service shall be 

subordinate to Firm Transmission Service. . . . [T]he Transmission 

Provider reserves the right to Curtail, in whole or in part, any Firm 

Transmission Service provided under the Tariff when, in the Transmission 

Provider's sole discretion, an emergency or other unforeseen condition 

impairs or degrades the reliability of its Transmission System. . . . .12

8. Section 14.7 of the Commission’s pro forma OATT, entitled Curtailment or 

Interruption of Service, provides that: 

The Transmission Provider reserves the right to Curtail, in whole or in 

part, Non-Firm Point-To-Point Transmission Service provided under the 

Tariff for reliability reasons . . . . Transmission Provider may elect to 

implement such Curtailments pursuant to the Transmission Loading Relief 

procedures specified in Attachment J. The Transmission Provider reserves 

the right to Interrupt, in whole or in part, Non-Firm Point-To-Point 

Transmission Service provided under the Tariff for economic reasons in 

order to accommodate (1) a request for Firm Transmission Service, (2) a 

 12 Order No. 890-B, 123 FERC ¶ 61,299, Pro Forma OATT 13.6 (emphasis 

added). 
Docket No. RM10-9-000 - 7 - 

request for Non-Firm Point-To-Point Transmission Service of greater 

duration, (3) a request for Non-Firm Point-To-Point Transmission Service 

of equal duration with a higher price, (4) transmission service for Network 

Customers from non-designated resources, or (5) transmission service for 

Firm Point-to-Point Transmission Service during conditional curtailment 

periods . . . . Where required, Curtailments or Interruptions will be made 

on a non-discriminatory basis to the transaction(s) that effectively relieve 

the constraint, however, Non-Firm Point-To-Point Transmission Service 

shall be subordinate to Firm Transmission Service. . . . Transmission 

service for Network Customers from resources other than designated 

Network Resources will have a higher priority than any Non-Firm PointTo-Point Transmission Service under the Tariff.13 

9. As indicated by the above-quoted text, the pro forma OATT provides that when 

curtailments are necessary, non-firm service shall be subordinate to firm service. 

B. Reliability Standard IRO-006-4

10. Reliability Standard IRO-006-4, which is applicable to balancing authorities, 

reliability coordinators and transmission operators, establishes transmission loading relief 

procedures: 

The purpose of this standard is to provide Interconnection-wide 

transmission loading relief procedures that can be used to prevent or 

manage potential or actual [system operating limit] and [interconnection 

reliability operating limit] violations to maintain reliability of the Bulk 

Electric System. 

11. The Reliability Standard contains five requirements. Requirement R1 obligates a 

reliability coordinator experiencing a potential or actual system operating limit or 

interconnection reliability operating limit violation within its reliability coordinator area 

to select one or more procedures to mitigate potential or actual transmission overloads. 

 13 Order No. 890-B, 123 FERC ¶ 61,299, Pro Forma OATT 14.7 (emphasis 

added). 
Docket No. RM10-9-000 - 8 - 

Pursuant to the Commission’s direction in Order No. 693,14 sub-requirement R1.1 

specifically notes: 

The [transmission loading relief] procedure alone is an inappropriate and 

ineffective tool to mitigate an [interconnection reliability operating limit] 

violation due to the time required to implement the procedure. Other 

acceptable and more effective procedures to mitigate actual 

[interconnection reliability operating limit] violations include: 

reconfiguration, redispatch, or load shedding. 

12. Requirement R2 mandates that the reliability coordinator only use local 

transmission loading relief or congestion management procedures to which the 

transmission operator experiencing the potential or actual system operating limit or 

interconnection reliability operating limit is a party. Requirement R3 establishes that a 

reliability coordinator with a transmission loading relief obligation from an 

interconnection-wide procedure follow the curtailments as directed by the 

interconnection-wide procedure. It also requires that a reliability coordinator desiring to 

use a local procedure as a substitute for curtailments as directed by the interconnectionwide procedure must obtain prior approval from the ERO. Requirement R4 mandates 

that each reliability coordinator comply with interconnection-wide procedures, once they 

are implemented, to curtail transactions that cross interconnection boundaries. 

Requirement R5 directs balancing authorities and reliability coordinators to comply with 

applicable interchange-related Reliability Standards during the implementation of 

transmission loading relief procedures. 

 14 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 577. 
Docket No. RM10-9-000 - 9 - 

13. NERC has established 7 TLR levels.15 At Level 1, the reliability coordinator 

notifies of a potential system operating limit or interconnection reliability operating limit 

violation. At Level 2, the reliability coordinator holds interchange transactions at current 

levels to prevent operating limit violations. At Level 3, the reliability coordinator 

reallocates transmission by curtailing non-firm interchange transactions to allow higherpriority transactions to continue, and/or curtails non-firm interchange transactions to 

prevent further operating limit violations. At Level 4, the reliability coordinator 

reconfigures the transmission system to allow firm transactions to continue. At Level 5, 

the reliability coordinator curtails firm interchange transactions, either to allow certain 

other firm transactions to continue or to mitigate any further operating limit violations. 

At Level 6, the reliability coordinator implements emergency procedures. At Level 0, the 

TLR has concluded. 

14. As previously noted, the Interchange Distribution Calculator is a mechanism used 

by the reliability coordinators in the Eastern Interconnection to calculate the distribution 

of interchange transactions over specific flowgates. It includes a database of all 

interchange transactions and a matrix of the distribution factors for the Eastern 

Interconnection.16 

 15 Transmission Loading Relief Procedures, TLR Levels, available at

http://www.nerc.com/page.php?cid=5|67|205. 

16 NERC Glossary at 9. 
Docket No. RM10-9-000 - 10 - 

C. Concerns Regarding Reliability Standard IRO-006-4

15. In Docket No. RM08-7-000, both the NRG Companies and the Rehearing Parties 

raised concerns regarding Reliability Standard IRO-006-4. In comments filed in response 

to the Commission’s Notice of Proposed Rulemaking regarding Reliability Standard 

IRO-006-4, the NRG Companies argued that certain flaws in the Interchange Distribution 

Calculator result in violations of sections 13.6 and 14.7 of the Commission’s pro forma

OATT. First, NRG Companies asserted that there are flaws in the Interchange 

Distribution Calculator, which allows certain types of transactions to avoid curtailment.17 

NRG Companies explained that, for example, the Interchange Distribution Calculator 

does not take into account internal non-firm transactions, defined as those with a source 

and sink in the same Balancing Area, and will curtail firm transactions before these 

internal non-firm transactions. As a result, NRG Companies assert that interchange 

transactions bear a disproportionate share of the system’s reliability obligations. Further, 

NRG Companies argue, the Interchange Distribution Calculator does not distinguish 

between firm and non-firm native load transmission services, assuming that all internal 

transactions are firm and assigning firm curtailment priorities to them.18 

16. Following issuance of Order No. 713-A, the Rehearing Parties sought rehearing, 

asserting that Reliability Standard IRO-006-4 is not just and reasonable because it results 

 17 Comments of the NRG Companies at 8, 16-17, Docket No. RM08-7-000 

(Oct. 10, 2008) (NRG Comments). 

18 NRG Comments at 4. 
Docket No. RM10-9-000 - 11 - 

in OATT violations and discriminates in favor of native load transactions made by a load 

serving entity over similar transactions entered into by an otherwise similarly-situated 

transmission-dependent utility or merchant generator. The Rehearing Parties cite to 

NRG’s comments in the underlying proceeding that point to problems with the 

Interchange Distribution Calculator, upon which the Reliability Standard relies to 

determine curtailments.19 They assert that sections 13.6 and 14.7 of the Commission’s 

pro forma OATT require that non-firm transmission services be curtailed before firm 

transmission services, and state that firm point-to-point and network integration 

transmission service customers have an equal priority with the transmission provider’s 

use of the system to deliver network resources to its native load.20 

17. According to the Rehearing Parties, because of its reliance on the flawed 

Interchange Distribution Calculator, which does not take internal native load transactions 

into account, Reliability Standard IRO-006-4 would direct a reliability coordinator to 

curtail a firm interchange transaction crossing over a constrained flowgate prior to 

curtailing a non-firm native network load transaction across the same flowgate. The 

Rehearing Parties assert that this is a violation of the OATT’s curtailment priorities and 

constitutes undue discrimination in favor of native load transactions. According to the 

 19 Request for Rehearing at 7, citing NRG Comments at 12-16. 

20 Id. 
Docket No. RM10-9-000 - 12 - 

Rehearing Parties, earlier reforms to the transmission loading relief procedures and the 

Interchange Distribution Calculator have not remedied these flaws.21 

D. Commission Questions

18. In an order issued concurrently with this NOI, the Commission denies the 

Rehearing Parties’ request for rehearing of Order No. 713-A as outside of the scope of 

the proceeding in Docket No. RM08-7-002.22 However, the Commission believes that 

commenters have raised issues regarding Reliability Standard IRO-006-4 that merit 

further inquiry. Although we have reviewed the comments filed by NRG Companies and 

the Request for Rehearing in Docket No. RM08-7, we seek broader input from industry 

before determining how to proceed. 

19. Therefore, the Commission seeks public comment on whether the current 

application of the transmission loading relief procedures and Reliability Standard IRO006-4 are inconsistent with OATT curtailment priorities and, if so, recommended 

corrective actions.23 In addition, the Commission seeks public comment on the following 

questions: 

 21 Request for Rehearing at 8, citing North Am. Electric Reliability Council, 

85 FERC ¶ 61,353 (1998), order on reh’g, 87 FERC ¶ 61,161 (1999). 

22 Modification of Interchange and Transmission Loading Relief Reliability 

Standards; and Electric Reliability Organization Interpretation of Specific Requirements 

of Four Reliability Standards, Order No. 713-B, 130 FERC ¶ 61,032 (2010). 

23 This proceeding will not address issues related to the Curtailment Threshold 

previously approved by the Commission. North Am. Electric Reliability Council, 

87 FERC ¶ 61,160 (1999), reh’g denied, 96 FERC ¶ 61,079 (2001). 
Docket No. RM10-9-000 - 13 - 

(a) Whether Reliability Standard IRO-006-4, as implemented by various 

transmission providers, reliability coordinators and balancing authorities, 

results in firm service being made subordinate to non-firm service? 

(b) How do Transmission Providers currently implement OATT sections 13.6 and 

14.7? Specifically, discuss whether Transmission Providers rely solely on the 

Interchange Distribution Calculator in determining which transactions to 

curtail, or whether they also take into account non-firm transactions internal to 

the Balancing Authority which are currently not reflected in the Interchange 

Distribution Calculator. 

(c) If the Interchange Distribution Calculator results in firm service being made 

subordinate to non-firm service, would including transactions internal to a 

Balancing Authority help resolve the problem? If so, what parties would be 

impacted? If there are affected parties, please provide examples of what the 

impacts on those parties would be. 

(d) If the Interchange Distribution Calculator results in firm service being made 

subordinate to non-firm service, would modifing it to calculate the Transfer 

Distribution Factors (TDF) for transactions within a Balancing Authority 

solve the identified issue of firm transactions being curtailed before non-firm 

transactions within a Balancing Authority? 

(e) What is the role and responsibility of the transmission provider, reliability 

coordinator and balancing authority, in the TLR procedures and curtailment? 

(f) As noted above, a Level 5 TLR is called to allow certain firm transactions to 

continue or to mitigate further operating limit violations and a Level 6 TLR is 

called to implement emergency procedures. Are commenters aware of Level 

5 or Level 6 TLR procedures being called for reasons other than to allow 

certain other firm transactions to continue or to mitigate any further operating 

limit violations? 

(g) If this is an issue, does it occur in non-RTO/ISO regions, within ISO/RTO 

footprints, or both? 

20. The Commission also seeks an update from the ERO regarding its efforts to make 

improvements to the Interchange Distribution Calculator.24 

 

(continued)

24 We understand that the ERO previously estimated that resolving problems in the 

Interchange Distribution Calculator would take approximately 2 to 5 years; however, 
Docket No. RM10-9-000 - 14 - 

III. Comment Procedures

21. The Commission invites interested persons to submit comments on the matters and 

issues proposed in this NOI, including any related matters or alternative proposals that 

commenters may wish to discuss. Comments are due 60 days from publication in the 

FEDERAL REGISTER. Comments must refer to Docket No. RM10-9-000, and must 

include the commenter's name, the organization they represent, if applicable, and their 

address in their comments. 

22. The Commission encourages comments to be filed electronically via the eFiling 

link on the Commission's web site at http://www.ferc.gov. The Commission accepts 

most standard word processing formats. Documents created electronically using word 

processing software should be filed in native applications or print-to-PDF format and not 

in a scanned format. Commenters filing electronically do not need to make a paper 

filing. 

23. Commenters that are not able to file comments electronically must send an 

original and 14 copies of their comments to: Federal Energy Regulatory Commission, 

Office of the Secretary, 888 First Street NE, Washington, DC 20426. 

24. All comments will be placed in the Commission's public files and may be viewed, 

printed, or downloaded remotely as described in the Document Availability section 

 

more than a year has passed since that estimate. Compliance Filing of the North 

American Electric Reliability Corporation In Response to Paragraph 50 of Order 

No. 713 at 10, Docket No. RM08-7-001 (Sept. 11, 2008). 
Docket No. RM10-9-000 - 15 - 

below. Commenters on this proposal are not required to serve copies of their comments 

on other commenters. 

IV. Document Availability

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

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

contents of this document via the Internet through FERC's Home Page 

(http://www.ferc.gov) and in FERC's Public Reference Room during normal business 

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

Washington DC 20426. 

26. From FERC's Home Page on the Internet, this information is available on 

eLibrary. The full text of this document is available on eLibrary in PDF and Microsoft 

Word format for viewing, printing, and/or downloading. To access this document in 

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

docket number field. 

27. User assistance is available for eLibrary and the FERC’s website during normal 

business hours from FERC Online Support at 202-502-6652 (toll free at 1-866-208-3676) 

or e-mail at ferconlinesupport@ferc.gov, or the Public Reference Room at (202) 502- 

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

public.referenceroom@ferc.gov. 
Docket No. RM10-9-000 - 16 - 

By the Commission. Commissioner Norris voting present. 

( S E A L ) 

Kimberly D. Bose, 

Secretary.