135 FERC ¶ 61,061 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

[Docket No. RM09-9-000; Order No. 751] 

Version One Regional Reliability Standards for Facilities Design, Connections, and 

Maintenance; Protection and Control; and Voltage and Reactive 

(Issued April 21, 2011) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Final Rule. 

SUMMARY: Under section 215 of the Federal Power Act, the Commission hereby 

approves four revised regional Reliability Standards developed by the Western Electricity 

Coordinating Council and approved by the North American Electric Reliability 

Corporation, which the Commission has certified as the Electric Reliability Organization 

responsible for developing and enforcing mandatory Reliability Standards. These 

regional Reliability Standards have been designated by the Western Electricity 

Coordinating Council as FAC-501-WECC-1 – Transmission Maintenance, PRC-004-

WECC-1 – Protection System and Remedial Action Scheme Misoperation, VAR-002-

WECC-1 – Automatic Voltage Regulators, and VAR-501-WECC-1 – Power System 

Stabilizer. Reliability Standard FAC-501-WECC-1 addresses transmission maintenance 

for specified transmission paths in the Western Interconnection. Reliability Standard 

PRC-004-WECC-1 addresses the analysis of misoperations that occur on transmission 
Docket No. RM09-9-000 

and generation protection systems and remedial action schemes in the Western 

Interconnection. Reliability Standard VAR-002-WECC-1 is meant to ensure that 

automatic voltage regulators remain in service on synchronous generators and condensers 

in the Western Interconnection. Reliability Standard VAR-501-WECC-1 is meant to 

ensure that power system stabilizers remain in service on synchronous generators in the 

Western Interconnection. In addition, the Commission approves five new regional 

definitions applicable within the Western Interconnection. 

EFFECTIVE DATE: This rule will become effective [insert date that is 60 days after 

publication in the FEDERAL REGISTER] 

FOR FURTHER INFORMATION CONTACT: 

Nick Henery (Technical Information) 

Office of Electric Reliability 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8636 

Scott Sells (Technical Information) 

Office of Electric Reliability 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6664 

A. Cory Lankford (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6711 
Docket No. RM09-9-000 

SUPPLEMENTARY INFORMATION:
UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Version One Regional Reliability Standards for 

Facilities Design, Connections, and Maintenance; 

Protection and Control; and Voltage and Reactive 

Docket No. RM09-9-000 

ORDER NO. 751 

TABLE OF CONTENTS

Paragraph Numbers

 I. Background ..........................................................................................................................2.

 A. Mandatory Reliability Standards....................................................................................2.

 B. Western Electricity Coordinating Council .....................................................................5.

 C. Proposed Regional Reliability Standards.......................................................................7.

 II. Discussion............................................................................................................................11.

 A. FAC-501-WECC-1 Transmission Maintenance ............................................................14.

 1. WECC Transfer Path Table.......................................................................................19.

 2. System Operating Limits ...........................................................................................25.

 3. Summary....................................................................................................................33.

 B. PRC-004-WECC-1.........................................................................................................34.

 1. WECC Transfer Path Table and WECC Remedial Action Schemes Table..............40.

 2. Summary....................................................................................................................51.

 C. VAR-002-WECC-1 ........................................................................................................52.

 1. Automatic Voltage Regulator In-Service Requirement ............................................57.

 2. Exclusion of Synchronous Generators that Operate Less than Five Percent of 

 All Hours During a Calendar Quarter........................................................................68.

 3. Automatic Voltage Regulator Replacement..............................................................73.

 4. Automatic Voltage Regulator Performance ..............................................................78.

 5. Summary....................................................................................................................85.

 D. VAR-501-WECC-1........................................................................................................86.

 1. Power System Stabilizer In-Service Requirement .....................................................88.

 2. Exclusion of Synchronous Generators that Operate for Less than Five Percent 

 of All Hours During a Calendar Quarter ....................................................................96.

 3. Power System Stabilizer Replacement.......................................................................100.
Docket No. RM09-9-000 ii 

 4. Power System Stabilizer Performance ....................................................................105.

 5. Reporting Burden.....................................................................................................112.

 6. Summary..................................................................................................................117.

 E. NERC VAR-002-1.1b ..................................................................................................118.

 F. Violation Risk Factors and Violation Severity Levels ................................................122.

 III. Information Collection Statement ......................................................................................134.

 IV. Environmental Analysis .....................................................................................................139.

 V. Regulatory Flexibility Act..................................................................................................140.

 VI. Document Availability .......................................................................................................144.

VII. Effective Date and Congressional Notification .................................................................147.
 

135 FERC ¶ 61,061 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Before Commissioners: Jon Wellinghoff, Chairman; 

 Marc Spitzer, Philip D. Moeller, 

 John R. Norris, and Cheryl A. LaFleur. 

Version One Regional Reliability Standards for 

Facilities Design, Connections, and Maintenance; 

Protection and Control; and Voltage and Reactive 

Docket No. RM09-9-000 

ORDER NO. 751 

FINAL RULE 

(Issued April 21, 2011) 

 

1. Under section 215 of the Federal Power Act (FPA),1

 the Commission hereby 

approves four revised regional Reliability Standards developed by the Western Electricity 

Coordinating Council (WECC) and approved by the North American Electric Reliability 

Corporation (NERC), which the Commission has certified as the Electric Reliability 

Organization (ERO) responsible for developing and enforcing mandatory Reliability 

Standards. These regional Reliability Standards have been designated by WECC as 

FAC-501-WECC-1 – Transmission Maintenance, PRC-004-WECC-1 – Protection 

System and Remedial Action Scheme Misoperation, VAR-002-WECC-1 – Automatic 

1

 16 U.S.C. 824o (2006). 
Docket No. RM09-9-000 - 2 - 

Voltage Regulators, and VAR-501-WECC-1 – Power System Stabilizer. Reliability 

Standard FAC-501-WECC-1 addresses transmission maintenance for specified 

transmission paths in the Western Interconnection. Reliability Standard PRC-004-

WECC-1 addresses the analysis of misoperations that occur on transmission and 

generation protection systems and remedial action schemes in the Western 

Interconnection. Reliability Standard VAR-002-WECC-1 is meant to ensure that 

automatic voltage regulators remain in service on synchronous generators and condensers 

in the Western Interconnection. Reliability Standard VAR-501-WECC-1 is meant to 

ensure that power system stabilizers remain in service on synchronous generators in the 

Western Interconnection. In addition, the Commission approves five new regional 

definitions applicable within the Western Interconnection. 

I. Background

A. Mandatory Reliability Standards

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

mandatory and enforceable Reliability Standards, which are subject to Commission 

review and approval. Once approved, the Reliability Standards may be enforced by the 

ERO, subject to Commission oversight, or by the Commission independently.2

 

 2

 16 U.S.C. 824o(e)(3). 
Docket No. RM09-9-000 - 3 - 

 

3. Reliability Standards that the ERO proposes to the Commission may include 

Reliability Standards that are proposed to the ERO by a Regional Entity to be effective in 

that region.3

 A Regional Entity is an entity that has been approved by the Commission to 

enforce Reliability Standards under delegated authority from the ERO.4

 When the ERO 

reviews a regional Reliability Standard that would be applicable on an Interconnectionwide basis and that has been proposed by a Regional Entity organized on an 

Interconnection-wide basis, the ERO must rebuttably presume that the regional 

Reliability Standard is just, reasonable, not unduly discriminatory or preferential, and in 

the public interest.5

 In turn, the Commission must give “due weight” to the technical 

expertise of the ERO and of a Regional Entity organized on an Interconnection-wide 

basis.6

3

 16 U.S.C. 824o(e)(4). 

4

 16 U.S.C. 824o(a)(7) and (e)(4). 

5

 18 CFR 39.5 (2010). 

6

 16 U.S.C. 824o(d)(2). 
Docket No. RM09-9-000 - 4 - 

4. In Order No. 672, the Commission urged uniformity of Reliability Standards, but 

recognized a potential need for regional differences.7

 Accordingly, the Commission 

stated that: 

As a general matter, we will accept the following two types of regional 

differences, provided they are otherwise just, reasonable, not unduly 

discriminatory or preferential and in the public interest, as required under 

the statute: (1) a regional difference that is more stringent than the 

continent-wide Reliability Standard, including a regional difference that 

addresses matters that the continent-wide Reliability Standard does not; and 

(2) a regional Reliability Standard that is necessitated by a physical 

difference in the Bulk-Power System.8

 

B. Western Electricity Coordinating Council

5. On April 19, 2007, the Commission accepted delegation agreements between 

NERC and each of eight Regional Entities.9

 In its order, the Commission accepted 

 7 Rules Concerning Certification of the Electric Reliability Organization; 

Procedures for the Establishment, Approval, and Enforcement of Electric Reliability 

Standards, Order No. 672, 71 FR 8662 (Feb. 17, 2006), FERC Stats. & Regs. ¶ 31,204, 

at P 290, order on reh’g, Order No. 672-A, 71 FR 19814 (Apr. 18, 2006), FERC Stats. 

& Regs. ¶ 31,212 (2006). 

8 Id. P 291. 

9 North American Electric Reliability Corp., 119 FERC ¶ 61,060, at P 432 (2007). 
Docket No. RM09-9-000 - 5 - 

 

WECC as a Regional Entity organized on an Interconnection-wide basis. As a Regional 

Entity, WECC oversees transmission system reliability in the Western Interconnection. 

The WECC region encompasses nearly 1.8 million square miles, including 14 western 

U.S. states, the Canadian provinces of Alberta and British Columbia, and the northern 

portion of Baja California in Mexico. 

6. In June 2007, the Commission approved eight regional Reliability Standards for 

WECC including the currently-effective WECC PRC-STD-001-1, PRC-STD-003-1, 

PRC-STD-005-1, VAR-STD-002a-1 and VAR-STD-002b-1.10 The Commission directed 

WECC to develop certain modifications to WECC PRC-STD-001-1, PRC-STD-003-1, 

PRC-STD-005-1, VAR-STD-002a-1 and VAR-STD-002b-1, as identified by NERC in its 

filing letter for the current standards.11 For example, the Commission determined that: 

(1) regional definitions should conform to definitions set forth in the NERC Glossary of 

Terms Used in Reliability Standards (NERC Glossary), unless a specific deviation has 

been justified; and, (2) documents that are referenced in the Reliability Standard should 

be attached to the Reliability Standard. The Commission also found that it is important 

that regional Reliability Standards and NERC Reliability Standards achieve a reasonable 

10 North American Electric Reliability Corp., 119 FERC ¶ 61,260 (2007). 

11 Id.
Docket No. RM09-9-000 - 6 - 

level of consistency in their structure so that there is a common understanding of the 

elements. 

C. Proposed Regional Reliability Standards

7. On March 25, 2009, NERC submitted a petition (NERC Petition) to the 

Commission seeking approval of four WECC regional Reliability Standards.12 The four 

proposed WECC regional Reliability Standards are designated as FAC-501-WECC-1, 

PRC-004-WECC-1, VAR-002-WECC-1 and VAR-501-WECC-1.13 In its petition, 

NERC explains that the four proposed regional Reliability Standards are meant to replace 

certain currently-effective regional Reliability Standards: 

 FAC-501-WECC-1 is intended to replace the current approved WECC PRC-STD005-1; 

 PRC-004-WECC-1 is intended to replace WECC PRC-STD-001-1 and WECC 

PRC-STD-003-1; 

 VAR-002-WECC-1 is intended to replace WECC VAR-STD-002a-1; and 

 VAR-501-WECC-1 is intended to replace WECC VAR-STD-002b-1. 

 12 See 18 CFR 39.5(a) (requiring the ERO to submit regional Reliability Standards 

on behalf of a Regional Entity). 

13 The proposed regional Reliability Standards are not attached to the Final Rule. 

They are, however, available on the Commission’s eLibrary document retrieval system in 

Docket No. RM09-9-000 and are posted on the ERO’s web site, available at: 

http://www.nerc.com. 
Docket No. RM09-9-000 - 7 - 

 

NERC states that the NERC board of trustees approved the proposed regional Reliability 

Standards on October 29, 2008, on the condition that WECC address certain 

shortcomings raised during the comment periods in the next revision of the Reliability 

Standards. 

8. NERC requests an effective date for FAC-501-WECC-1, VAR-002-WECC-1 and 

VAR-501-WECC-1 of the first day of the first quarter after Commission approval. For 

PRC-004-WECC-1, NERC requests an effective date of the first day of the second 

quarter after approval by the Commission. 

9. On December 17, 2010, the Commission issued a Notice of Proposal Rulemaking 

(NOPR) in which it proposed to approve the four revised regional Reliability Standards. 

In addition, under section 215(d)(5) of the FPA, the Commission proposed to direct 

WECC, working through its standards development process, to develop modifications to 

these regional Reliability Standards.14

10. As indicated in Appendix A, fourteen entities filed comments in response to the 

NOPR. 

14 Version One Regional Reliability Standards for Facilities Design, Connections, 

and Maintenance; Protection and Control; and Voltage and Reactive, Notice of Proposed 

Rulemaking, 75 FR 80,397 (Dec.22, 2010), FERC Stats. & Regs. ¶ 32,667 (2010). 
Docket No. RM09-9-000 - 8 - 

II. Discussion

11. As discussed below, we approve Reliability Standards FAC-501-WECC-1, PRC004-WECC-1, VAR-002-WECC-1, and VAR-501-WECC-1 as just, reasonable, not 

unduly discriminatory or preferential, and in the public interest. We find that the revised 

WECC Reliability Standards are more stringent than the corresponding NERC Reliability 

Standards either because they address issues not covered in the requirements of the 

corresponding NERC Reliability Standards or because they offer more detailed 

requirements than the corresponding NERC Reliability Standards. For these same 

reasons, we find that the requirements of these revised regional Reliability Standards are 

not redundant of the requirements of the corresponding NERC Reliability Standards. 

Moreover, we find that these revised WECC Reliability Standards are sufficient to 

maintain the reliability of the Bulk-Power System in the Western Interconnection. 

12. We also find that the revised regional Reliability Standards offer several 

improvements over the currently-effective regional Reliability Standards. Consistent 

with the Commission’s directives in its June 2008 order, the revised regional Reliability 

Standards replace the former sanctions table with violation risk factors and violation 

severity levels. The revised regional Reliability Standards also remove compliancerelated information and elements from the requirements. 

13. In addition, we direct WECC to address a concern pertaining to the applicability of 

FAC-501-WECC-1 and PRC-004-WECC-1, which reference tables of major 
Docket No. RM09-9-000 - 9 - 

transmission paths and remedial action schemes posted on the WECC website. We also 

adopt our NOPR to direct NERC to remove the WECC regional definition of Disturbance 

from the NERC Glossary to ensure consistency between the regional and NERC defined 

terms. 

A. FAC-501-WECC-1 Transmission Maintenance

NERC Petition

14. In its petition, NERC explained that proposed FAC-501-WECC-1 is intended to 

replace approved WECC PRC-STD-005-1. The proposed regional Reliability Standard 

would apply to transmission owners that maintain transmission paths listed in the table 

titled “Major WECC Transfer Paths in the Bulk Electric System” (WECC Transfer Path 

Table), which is no longer an attachment to the Reliability Standard but is maintained on 

the WECC website. Proposed FAC-501-WECC-1 contains three main provisions. 

Requirement R1 provides that each transmission owner must have a transmission 

maintenance and inspection plan, and each transmission owner must annually review and 

update as required its transmission maintenance and inspection plan. Requirement R2 

states that each transmission owner must include specified maintenance categories15

when developing its transmission maintenance and inspection plan. Requirement R3 

 15 The maintenance categories to be included in the transmission maintenance and 

inspection plan are included in Attachment 1 of FAC-501-WECC-1 – “Transmission 

Line and Station Maintenance Details.” 
Docket No. RM09-9-000 - 10 - 

states that each transmission owner must implement and follow its transmission 

maintenance and inspection plan. 

15. In its petition, NERC recommended approval of FAC-501-WECC-1, stating that 

the proposed regional Reliability Standard addresses matters that the NERC Reliability 

Standard does not. Specifically, according to NERC, FAC-501-WECC-1 requires, for 

specified transmission paths, a highly detailed maintenance and inspection plan for all 

transmission and substation equipment components, beyond the relay and communication 

system maintenance and testing required by the corresponding NERC Reliability 

Standard.16

NOPR Proposal

16. In the NOPR, the Commission proposed to approve FAC-501-WECC-1 as just, 

reasonable, not unduly discriminatory or preferential, and in the public interest. The 

Commission stated that, as explained by NERC, proposed FAC-501-WECC-1 appears to 

be more stringent, by virtue of its requirement for a highly detailed maintenance and 

inspection plan, compared to the corresponding NERC Reliability Standard. 

17. The Commission pointed out that, in approving the currently-effective WECC 

PRC-STD-005-1, the Commission directed WECC to make certain modifications to the 

regional Reliability Standard. The Commission stated that the proposed regional 

 16 NERC Petition at 11, 14. 
Docket No. RM09-9-000 - 11 - 

Reliability Standard appeared to address these directives by no longer referencing any 

WECC forms, and removing text regarding the Compliance Monitoring Period. The 

Commission also pointed out that the proposed regional Reliability Standard no longer 

refers to a regional definition of Disturbance, which conflicted with the definition of 

Disturbance in the NERC Glossary. Since the term is not included in any of the proposed 

regional Reliability Standards, the Commission proposed to direct NERC to remove this 

regional definition from the NERC Glossary of Terms upon Commission approval of 

FAC-501-WECC-1. The proposed regional Reliability Standard also removes the 

sanctions table and includes violation risk factors, violation severity levels, measures and 

time horizons, as directed by the Commission. The Commission proposed to find that the 

proposed removal of the sanctions table and inclusion of violation risk factors, violation 

severity levels, measures and time horizons, appeared generally consistent with the 

Commission’s directives, and signify meaningful improvement. Accordingly, the 

Commission proposed to approve FAC-501-WECC-1 and NERC’s petition to retire 

currently-effective WECC PRC-STD-005-1. 

18. The Commission also sought comment on two issues regarding FAC-501-WECC1: (1) the use of the WECC Transfer Path Table and (2) the use of the term “system 

operating limit,” as discussed below. 
Docket No. RM09-9-000 - 12 - 

1. WECC Transfer Path Table

19. Regional Reliability Standard FAC-501-WECC-1 applies to transmission owners 

that maintain transmission paths listed in the most current WECC Transfer Path Table 

provided on WECC’s website. The table currently posted on WECC’s website identifies 

the same 40 major paths as the table attached to the currently-effective regional 

Reliability Standard, WECC PRC-STD-005-1. 

NOPR Proposal

20. In the NOPR, the Commission expressed concern that, by referencing the WECC 

Transfer Path Table posted on the WECC website, the applicability of FAC-501-WECC1 could change without review and approval by NERC and the Commission. The 

Commission explained that the possibility for the applicability of the Reliability Standard 

to change at any time could create confusion for entities that need to comply as well as 

any compliance or enforcement staff trying to determine which entities are responsible 

for complying with the Reliability Standard. Accordingly, the Commission proposed to 

direct WECC to develop a modification to FAC-501-WECC-1 to address this concern. 

21. The Commission offered examples of how WECC might address the 

Commission’s concern. First, the Commission suggested that WECC could include its 

criterion for identifying and modifying major transmission paths listed in the WECC 

Transfer Path Table and make an informational filing each time it makes a modification 

to the table. A second option the Commission proposed was that WECC file its criterion 
Docket No. RM09-9-000 - 13 - 

with the Commission and post revised transfer path tables and associated catalogs on its 

website before they become effective with concurrent notification to NERC and the 

Commission. Alternatively, the Commission suggested that the Regional Entity could 

include the WECC Transfer Path Table as an attachment to the modified Reliability 

Standard. In this way, the Commission would be able to verify that the Regional Entity is 

applying the requirements of FAC-501-WECC-1 in a just and reasonable manner. 

Comments

22. WECC, as well as Bonneville, PacifiCorp, and SDG&E, support the 

Commission’s proposal to require WECC to provide greater certainty regarding the 

applicability of FAC-501-WECC-1 based on the WECC Transfer Path Table. WECC 

supports the Commission’s second approach and suggests that the Commission direct 

WECC to file its criterion for identifying and modifying major transmission paths listed 

in the tables. Moreover, WECC commits to publicly post any revisions to the table on 

the WECC website with concurrent notification to the Commission, NERC, and industry. 

WECC explains that posting the WECC Transfer Path Table to the website is preferred 

because the current WECC Regional Reliability Standards development process and 

subsequent NERC and FERC approval processes do not result in timely updates to the 

table. 

23. Likewise, Bonneville, PacifiCorp, and SDG&E support the Commission’s 

proposal to require WECC to develop and file criterion to clarify how major transmission 
Docket No. RM09-9-000 - 14 - 

paths are included in or excluded from the WECC Transfer Path Table. Bonneville 

believes that filing such criterion would provide transparency for transmission owners 

that are affected by changes to the table. PacifiCorp comments that WECC should not be 

required to include the criterion or the WECC Transfer Path Table as an attachment to the 

Reliability Standard because it would require a modification to the standard and, thus, 

added delay, every time WECC proposed a change to the criteria or the table. By 

contrast, the Bureau of Reclamation recommends that the Commission approve the 

proposed Reliability Standard and direct WECC to append the current WECC Transfer 

Path Table. 

Commission Determination

24. Consistent with our NOPR proposal and WECC’s comments the Commission 

directs WECC to file, within 60 days from the issuance of this Final Rule, its criterion for 

identifying and modifying major transmission paths listed in the WECC Transfer Path 

Table. Moreover, the Commission accepts WECC’s commitment to publicly post any 

revisions to the WECC Transfer Path Table on the WECC website with concurrent 

notification to the Commission, NERC, and industry. We believe that this process 

balances the interests of WECC in developing timely revisions to the WECC Transfer 

Path Table with the need for adequate transparency for transmission owners that are 

affected by changes to the WECC Transfer Path Table. 
Docket No. RM09-9-000 - 15 - 

2. System Operating Limits

25. WECC proposes to replace references to Operating Transfer Capability limits in 

WECC PRC-STD-001-1 with System Operating Limits in FAC-501-WECC-1. 

Currently, WECC determines transfer capability based on a “rated system path” 

methodology and the WECC Transfer Path Table and associated catalog identify the 

facilities that make up each rated system path. Unlike a System Operating Limit, 

WECC’s definition of Operating Transfer Capability limits is restricted to direct or 

parallel transmission elements between or within specific transmission operators. 

Moreover, the rating of a System Operating Limit, which is based on an operating 

criterion that is either thermally (based on facility ratings) or stability-based (based on 

transient stability, voltage stability, or system voltage limits), is the first element to 

calculate in order to determine the Operating Transfer Capability limit rating. 

NOPR Proposal

26. In the NOPR, the Commission expressed concern that the terms Operating 

Transfer Capability limit and System Operating Limit were not interchangeable. 

Specifically, the Commission expressed concern that the introduction of the NERC 

Glossary definition of System Operating Limit in Requirement R1 of the proposed 

regional Reliability Standard could create confusion regarding which transmission 

owners are required to maintain a transmission maintenance and inspection plan. The 

Commission expressed further concern that, by using the term System Operating Limit, 
Docket No. RM09-9-000 - 16 - 

Requirement R1 could apply to more transmission facilities than identified in the WECC 

Transfer Path Table and associated catalog. 

Comments

27. WECC, supported by SDG&E, urges the Commission to approve FAC-501-

WECC-1 as filed. NERC and several other commenters support the Commission’s 

proposal to approve FAC-501-WECC-1.17 WECC agrees that there are slight differences 

between the definitions of Operating Transfer Capability limits and System Operating 

Limits but contends that the intent and the effect is the same and the applicability is clear. 

WECC explains that both limits are calculated using the same methodologies and result 

in the same values. WECC further explains that it made this change to address the 

Commission’s concerns related to the proliferation of regional terms. Moreover, WECC 

states that, beginning with the 2008-2009 winter System Operating Limit seasonal study 

report and continuing to the present, WECC has defined the limits calculated as System 

Operating Limits. WECC states that it uses these seasonal studies to formulate the 

correct System Operating Limits for transmission paths in the West. 

28. SDG&E and TANC support the use of System Operating Limits instead of 

Operating Transfer Capability limits. SDG&E comments that the methodology for 

determining System Operating Limits is the same as for Operating Transfer Capability 

 17 E.g. Bonneville, Reclamation, PacifiCorp. 
Docket No. RM09-9-000 - 17 - 

limits and that there is no confusion related to the use of System Operating Limit in 

Requirement R1. TANC comments that an interpretation of Requirement R1 that 

requires transmission owners of major paths to be responsible for maintaining and 

inspecting transmission facilities owned by other entities whose facilities may be 

necessary to maintain System Operating Limits associated with the major path would be 

infeasible, overly burdensome on the individual owners of the major paths and 

inconsistent with the spirit of the proposed regional Reliability Standard as written. 

TANC suggests that using the term Operating Transfer Capability limit as a substitute for 

System Operating Limit may resolve any confusion, as could a modification clarifying 

that each major path transmission owner’s responsibility is to inspect and maintain its 

own facilities. 

29. Bonneville and PacifiCorp also support the use of the term System Operating 

Limit instead of the term Operating Transfer Capability because both terms result in the 

same requirement that maintenance be performed to ensure that each path is capable of 

operating up to the path’s limit. Nevertheless, Bonneville and PacifiCorp comment that 

Requirement R1 is unclear as to which facilities are covered and who is responsible for 

the maintenance of those facilities. Bonneville contends that the transmission owner 

should be responsible only for the facilities it owns, and the standard should make this 

clear. PacifiCorp suggests that Requirement R1 should be modified to reflect that 

transmission owners should have a transmission maintenance and inspection plan 
Docket No. RM09-9-000 - 18 - 

detailing their requirements “that apply to all transmission facilities identified by the 

Transmission Operator of the transmission path as necessary” for System Operating 

Limits associated with each of the transmission paths identified in the WECC Transfer 

Path Table. 

30. By contrast, in light of the concerns raised by the Commission in the NOPR, 

CDWR asks the Commission to consider maintaining current Reliability Standard PRCSTD-005-1. 

Commission Determination

31. The Commission finds that the Regional Entity has adequately explained its 

intended use of System Operating Limits as a replacement for Operating Transfer 

Capability limits. As WECC and others have described, transmission owners within the 

Western Interconnection will continue to identify capability limits associated with their 

own paths listed in the WECC Transfer Path Table using the same methodology as they 

have used under the currently-effective WECC PRC-STD-001-1. We accept the 

substitution of terms based on WECC’s explanation that all it has done is to replace 

references to Operating Transfer Capability limits with System Operating Limits in order 

to address the Commission’s concern regarding the proliferation of regional terms. 

32. In response to our concern that use of the term System Operating Limit could 

expand the applicability of FAC-501-WECC-1 to transmission facilities that are not listed 

in the WECC Transfer Path Table, we accept WECC’s explanation that the applicability 
Docket No. RM09-9-000 - 19 - 

of the Reliability Standard is clear. Consistent with comments filed by Bonneville and 

PacifiCorp, we find that it would be unreasonable to interpret FAC-501-WECC-1 as 

requiring transmission owners to be responsible for maintaining and inspecting 

transmission facilities related to System Operating Limits on paths that they do not own. 

Nevertheless, we believe that this could be clearer in the language of Requirement R1. 

Accordingly, we recommend that WECC consider the comments of Bonneville, 

PacifiCorp and TANC when it develops future modifications to FAC-501-WECC-1. 

3. Summary

33. We adopt our NOPR proposal and approve FAC-501-WECC-1 as just, reasonable, 

not unduly discriminatory or preferential and in the public interest. We find that the 

revised regional Reliability Standard is more stringent than the corresponding NERC 

Reliability Standard, PRC-005-1, by virtue of its requirement for a highly detailed 

maintenance and inspection plan for all transmission and substation equipment 

components associated with transmission paths identified in the WECC Transfer Path 

Table. 

B. PRC-004-WECC-1

NERC Petition

34. Regional Reliability Standard PRC-004-WECC-1 is intended to replace two 

currently-effective WECC Reliability Standards, PRC-STD-001-1 and PRC-STD-003-1. 

In its petition, NERC explained that PRC-004-WECC-1 is more stringent than the 
Docket No. RM09-9-000 - 20 - 

 

currently-effective corresponding NERC Reliability Standards because the former 

requires that all transmission and generation protection system and remedial action 

scheme misoperations on major WECC transfer paths be analyzed and mitigated within a 

specific timeframe. In contrast, corresponding NERC Reliability Standard PRC-003-1 

requires Regional Entities to establish procedures for review, analysis, reporting, and 

mitigation of transmission and generation protection system misoperations, but it does 

not specifically address the owners of the transmission and generation facilities. NERC 

also explained that NERC Reliability Standard PRC-004-1 has requirements for 

protection system misoperations, but does not provide for the additional requirements 

included in PRC-004-WECC-1.18

35. Regional Reliability Standard PRC-004-WECC-1 contains three provisions. 

Requirement R1 provides that “System Operators and System Protection Personnel” of 

transmission owners and generator owners must analyze all protection system and 

remedial action scheme operations. Requirements R1.1 and R1.2 identify time limits for 

the review and analysis of transmission element tripping, remedial action scheme 

18 See NERC Petition at 11, 19-20. In Order No. 693, the Commission found that 

PRC-003-1 was a fill-in-the-blank Reliability Standard in part because its requirements 

apply to the Regional Reliability Organizations, now called Regional Entities, which the 

Commission was not persuaded NERC can enforce a Regional Entity’s compliance with 

a Reliability Standard. Mandatory Reliability Standards for the Bulk-Power System, 

Order No. 693, FERC Stats. & Regs., Regulations Preambles 2006-2007 ¶ 31,242, at 

P 1460-1461, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007). 
Docket No. RM09-9-000 - 21 - 

operations and protection systems. Requirement R2 identifies actions required by 

transmission owners and generator owners for each protection system or remedial action 

scheme misoperation, including identifying timelines for removing the equipment that 

failed from service. Requirement R3 states that transmission owners and generator 

owners must submit an incident report for each misoperation or repair of equipment that 

misoperated. 

36. Both the currently-effective and proposed regional Reliability Standards apply to 

transmission owners and transmission operators. However, PRC-004-WECC-1 also 

applies to generator owners that own facilities listed in the the table titled “Major WECC 

Remedial Action Schemes” (WECC Remedial Action Schemes Table), which is available 

on WECC’s website.19 In addition, WECC proposes four new regional definitions for 

Functionally Equivalent Protection System, Functionally Equivalent Remedial Action 

Scheme, Security-Based Misoperation and Dependability Based Misoperation. 

NOPR Proposal

37. The Commission proposed to approve PRC-004-WECC-1 as just, reasonable, not 

unduly discriminatory or preferential, and in the public interest.20 The Commission also 

 19 See proposed regional Reliability Standard PRC-004-WECC-1, Section 4 

(Applicability). 

20 NOPR, FERC Stats. & Regs. ¶ 32,667 at P 32. 
Docket No. RM09-9-000 - 22 - 

proposed to approve NERC’s petition to withdraw currently-effective WECC PRC-STD001-1 and WECC PRC-STD-003-1. The Commission explained that PRC-004-WECC-1 

appears more stringent than the corresponding NERC PRC-004-1. Moreover, PRC-004-

WECC-1 addresses Commission directives to develop modifications to the currentlyeffective regional Reliability Standards. 

38. The Commission noted that, in approving the currently-effective WECC PRCSTD-001-1 and WECC PRC-STD-003-1, the Commission directed WECC to make 

certain modifications in developing replacement Reliability Standards. To address these 

directives, WECC no longer references any WECC forms and the text regarding the 

compliance monitoring period has been removed from the proposed Standard. In 

addition, the revised regional Reliability Standard does not reference the regional 

definition of Disturbance, which did not match the NERC definition of Disturbance in the 

NERC Glossary. The revised regional Reliability Standard also removes the definition of 

Business Day. Since these terms are not included in any of the existing or proposed 

regional Reliability Standards, the Commission proposed to direct NERC to remove these 

regional definitions from the NERC Glossary upon approval of PRC-004-WECC-1. The 

revised regional Reliability Standard also removes the sanctions table and includes 

violation risk factors, violation severity levels, measures and time horizons. The 

Commission commended WECC for addressing these directives. 
Docket No. RM09-9-000 - 23 - 

39. The Commission sought comment on two issues concerning PRC-004-WECC-1: 

(1) the use of the WECC Transfer Path Table and the WECC Remedial Action Schemes 

Table to define applicability and (2) the need for the four new regional definitions to be 

added to the NERC Glossary of Terms. 

1. WECC Transfer Path Table and WECC Remedial Action 

Schemes Table

40. Similar to regional Reliability Standard FAC-501-WECC-1, discussed above, the 

applicability of Reliability Standard PRC-004-WECC-1 is dependent upon references to 

the WECC Transfer Path Table and the WECC Remedial Action Schemes Table, which 

WECC posts on its website. The NOPR raised the same applicability concerns as 

discussed above in the context of FAC-501-WECC-1. In turn, WECC offered to file the 

criteria for identifying paths and remedial action schemes associated with these tables. 

Commission Determination

41. Consistent with our NOPR proposal and WECC’s comments the Commission 

directs WECC to file, within 60 days from the issuance of this Final Rule, its criteria for 

identifying and modifying major transmission paths listed in the WECC Transfer Path 

Table and major remedial actions schemes listed in the WECC Remedial Action Schemes 

Table. Moreover, the Commission accepts WECC’s commitment to publicly post any 

revisions to the WECC Transfer Path Table, WECC Remedial Action Schemes Table, 

and the associated catalogs on the WECC website with concurrent notification to the 

Commission, NERC, and industry. We believe that this process balances the interests of 
Docket No. RM09-9-000 - 24 - 

WECC in developing timely revisions to the WECC Transfer Path Table with the need 

for adequate transparency for transmission owners that are affected by changes to the 

WECC Transfer Path Table and the WECC Remedial Action Schemes Table. Regional 

Definitions Associated With PRC-004-WECC-1 

NERC Petition

42. The revised regional Reliability Standard includes four new regional definitions 

meant to apply only in WECC. Two of the proposed definitions (Functionally Equivalent 

Protection System and Functionally Equivalent Remedial Action Scheme) have added 

“functionally equivalent” to terms that already exist in the NERC Glossary.21 In addition, 

WECC has developed two regional definitions for the term Misoperation, as it is defined 

in the NERC Glossary. NERC explains that the terms Security-Based Misoperations and 

Dependability-Based Misoperations are meant to address: (1) incorrect operation of a 

protection system (Security-Based Misoperation); and (2) absence of a protection system 

to operate (Dependability-Based Misoperation). 

NOPR Proposal

43. In the NOPR, the Commission expressed concern about the unnecessary 

proliferation of glossary terms and whether the proposed WECC definitions were 

 21 See NERC Glossary definitions for Protection System and Remedial Action 

Scheme. 
Docket No. RM09-9-000 - 25 - 

 

unnecessary variations of terms already defined in the NERC Glossary.22 With regard to 

the definitions of Functionally Equivalent Protection System and Functionally Equivalent 

Remedial Action Scheme, the Commission expressed concern that the new definitions do 

not add any further clarity to the NERC Glossary terms. Accordingly, we sought an 

explanation from WECC and other interested commenters regarding whether these new 

terms are more inclusive than the corresponding NERC Glossary definitions and, if so, 

how. 

44. The Commission also noted that WECC proposes to define Functionally 

Equivalent Protection System as “[a] Protection System that provides performance as 

follows: Each Protection System can detect the same faults within the zone of protection 

...”23 The Commission expressed concern that the meaning of the phrase “detect the 

same faults” was unclear in this definition. Accordingly, we sought comment on the 

meaning of the phrase “the same faults” within the definition. 

45. With regard to the bifurcation of the term Misoperation, the Commission 

expressed concern that the two new regional definitions may be confusing because at 

least some of the requirements for each type of misoperation appear to overlap. 

22 NERC Glossary of Terms used in Reliability Standards, available at: 

http://www.nerc.com/files/Glossary of Terms 2011Mar15.pdf. 

23 See Proposed Reliability Standard PRC-004-WECC-1, proposed definition of 

Functionally Equivalent Protection System. 
Docket No. RM09-9-000 - 26 - 

Accordingly, we sought an explanation from WECC and other interested commenters 

regarding why these two new regional terms are necessary or desirable within the context 

of the proposed regional Reliability Standard, and how they will enhance reliability. 

Comments

46. WECC, supported by SDG&E, contends that the addition of the terms 

Functionally Equivalent Protection System and Functionally Equivalent Remedial Action 

Scheme adds clarity because they apply only to a subset of protection systems and 

remedial action schemes and are thus less inclusive than the corresponding NERC 

Glossary definition. WECC explains that a Functionally Equivalent Protection System or 

Functionally Equivalent Remedial Action Scheme is a protection system or remedial 

action scheme that provides redundancy to the specific protection system or remedial 

action scheme that failed. WECC further explains that a Functionally Equivalent 

Protection System or Remedial Action Scheme is not identical to the one that 

misoperated but rather provides redundancy over the same part of the Interconnection as 

the remedial action scheme or protection system that misoperated. Finally, WECC 

explains that the phrase “detect the same faults” is intended to take on its plain meaning, 

i.e., that both protection systems (the primary and the functionally equivalent protection 

system) can detect and protect against the same problem on the system.24 

 24 See WECC Comments at page 11. 
Docket No. RM09-9-000 - 27 - 

47. Bonneville and PacifiCorp generally agree that the terms Functionally Equivalent 

Protection System and Functionally Equivalent Remedial Action Scheme are useful 

because they describe a protection system or remedial action scheme that is able to 

provide the necessary functionality of a protection system or remedial action scheme 

without the loss of any necessary dependability for the system. PacifiCorp further 

suggests that the Commission direct NERC to consider the development of a continentwide definition of Functionally Equivalent Protection System and Functionally 

Equivalent Remedial Action Scheme. 

48. WECC, supported by SDG&E, Bonneville, and PacifiCorp, contends that 

definitions of Security-Based Misoperation and Dependability-Based Misoperation 

should be retained because they provide clarity in the implementation of PRC-004-

WECC-1. WECC states that these two definitions were developed recognizing that 

misoperations can be grouped into two types, incorrect operation and failure to operate. 

WECC explains that a Dependability-Based Misoperation occurs during a system fault, 

and its impact to the bulk electric system is minimal if other functionally equivalent 

redundancies exist to eliminate, or at least minimize, any impact from any single 

misoperation. By contrast, a Security-Based Misoperation isolates an element from the 

bulk electric system unnecessarily either when another protection system is already 

responding to contingency conditions or when noise in a communication system trips an 

element even though no fault occurred. WECC comments that PRC-004-WECC-1 
Docket No. RM09-9-000 - 28 - 

therefore requires different actions based on which category of misoperation has 

occurred. 

Commission Determination

49. In view of the comments supporting these regional definitions, the Commission 

accepts the four new defined terms to be applicable only in the Western Interconnection. 

However, similar to our policy set forth in Order No. 672 that favors the development of 

uniform Reliability Standards,25 the Commission believes NERC, as a rule, should 

develop definitions that apply uniformly across the different Interconnections and strive 

to minimize the use of regional definitions and terminology. 

50. We will not direct NERC to consider PacifiCorp’s suggestion that the Commission 

direct NERC to consider the development of a continent-wide definition of functionally 

equivalent protection system and functionally equivalent remedial action scheme. We 

note that NERC has an ongoing project that could address this issue.26 We encourage 

 25 Order No. 672, FERC Stats. & Regs. ¶ 31,204 at P 290 (“The Commission 

believes that uniformity of Reliability Standards should be the goal and the practice, the 

rule rather than the exception. Greater uniformity will encourage best practices, thereby 

enhancing reliability and benefiting consumers and the economy”). 

26 NERC Project 2009-07 Reliability of Protection Systems, available at: 

http://www.nerc.com/filez/standards/Project2009-

07_Reliability_of_Protection_Systems.html. 
Docket No. RM09-9-000 - 29 - 

NERC to consider the comments of PacifiCorp in this proceeding during the development 

of Project 2009-07 and encourage PacifiCorp to participate in this NERC project. 

2. Summary

51. The Commission adopts its NOPR proposal to approve PRC-004-WECC-1 as just, 

reasonable, not unduly discriminatory or preferential, and in the public interest. As 

discussed above, we direct WECC to file its criteria for identifying and modifying major 

transmission paths listed in the WECC Transfer Path Table and major remedial action 

schemes listed in the WECC Remedial Action Schemes Table. We also accept WECC’s 

explanation regarding its need for the four new regional definitions to be added to the 

NERC Glossary of Terms. 

C. VAR-002-WECC-1

52. Regional Reliability Standard VAR-002-WECC-1 applies to generator operators 

and transmission operators that operate synchronous condensers. Requirement R1 

provides that each generator operator and transmission operator shall have automatic 

voltage regulators in service and in automatic voltage control mode for synchronous 

generators and synchronous condensers during 98 percent of all operating hours unless 

exempted by the transmission operator. Sub-requirements R1.1 through R1.10 detail the 

type of exemptions that the transmission operator may grant to the generator operator to 

excuse the generator from operating the automatic voltage regulator in automatic voltage 

control mode. Requirement R2 states that each generator operator and transmission 
Docket No. RM09-9-000 - 30 - 

operator must have documentation identifying the number of hours excluded for each 

sub-requirement R1.1 through R1.10. 

53. Consistent with the Commission directives, the revised regional Reliability 

Standard replaces the former sanctions table with violation risk factors, violation severity 

levels, measures and time horizons.27 WECC also proposes a new glossary term, 

Commercial Operation, applicable only in the Western Interconnection. 

NERC Petition

54. The NERC Petition requested Commission approval of VAR-002-WECC-1. In 

addition, the Petition explained that, during the standards development process, NERC 

expressed concern regarding two aspects of the regional Reliability Standard, and that 

WECC responded in writing to NERC’s concerns. First, with regard to Requirement R1 

of VAR-002-WECC-1, WECC explained that the requirement to keep automatic voltage 

regulators in service and in automatic voltage control mode during 98 percent of all 

operating hours is a translation of the limits set in the levels of non-compliance associated 

with the current regional Reliability Standard. 28 In addition, WECC explained that the 

 27 See North America Electric Reliability Corp., 119 FERC ¶ 61,260 at P 117. 

28 The levels of non-compliance assigned to the currently-effective regional 

Reliability Standard specify that there shall be a level 1 non-compliance if automatic 

voltage regulators are in service less than 98 percent but at least 96 percent or more of all 

hours during which the synchronous generating unit is on line for each calendar quarter. 
Docket No. RM09-9-000 - 31 - 

two percent allowance provides more time to start up generating facilities when the 

automatic voltage regulators are not yet in voltage control mode and allows for 

evaluation when a generator operator responds to an unforeseen event.29 

55. Second, NERC expressed concern regarding sub-requirement R1.1, which 

includes an exemption for units operating less than five percent of all hours during a 

calendar quarter, because the provision “excludes the hours attributed to the synchronous 

generator or condenser that operates for less than five percent of all hours during any 

calendar quarter.”30 WECC responded by explaining that (1) this exemption is a 

carryover from the currently effective regional Reliability Standard and (2) the 

five percent exclusion permits the continued practice of allowing the operation of peaking 

units without penalty for having an out-of-service automatic voltage regulator per the 

manufacturer’s recommendations.31 

NOPR Proposal

56. The Commission proposed to approve VAR-002-WECC-1 as just, reasonable, not 

unduly discriminatory or preferential, and in the public interest. Further, the Commission 

proposed the concurrent retirement of currently-effective WECC VAR-STD-002a-1. The 

 29 NERC Petition at 34-35. 

30 Id. at 34-35. 

31 Id. at 35. 
Docket No. RM09-9-000 - 32 - 

Commission proposed to find that VAR-002-WECC-1 is more stringent than the 

corresponding NERC Reliability Standard. In addition, the Commission sought comment 

on several issues concerning VAR-002-WECC-1 including: (1) the automatic voltage 

regulator in-service requirement, (2) the exclusion of synchronous generators that operate 

less than five percent of all hours during a calendar quarter, (3) the replacement period 

for automatic voltage regulators, and (4) automatic voltage regulator performance. 

1. Automatic Voltage Regulator In-Service Requirement

57. Requirement R1 of regional Reliability Standard VAR-002-WECC-1 provides that 

“Generator Operators and Transmission Operators shall have [automatic voltage 

regulators] in service and in automatic voltage control mode 98 [percent] of all operating 

hours for synchronous generators or synchronous condensers.”32 Requirement R1 then 

identifies ten circumstances in which a generator operator or transmission operator is 

excused from this requirement. 

NOPR Proposal

58. In the NOPR, the Commission proposed to find that, by specifying the 

circumstances in which a generator operator or transmission operator is excused from 

operating with automatic voltage regulator in-service and in automatic voltage control 

mode, Requirement R1 is more stringent than the requirement in NERC VAR-002-1.1b. 

 32 Regional Reliability Standard VAR-002-WECC-1, Requirement R1. 
Docket No. RM09-9-000 - 33 - 

Nevertheless, the Commission expressed its concern that, where installed, automatic 

voltage regulators should be in-service at all times except in circumstances when the 

generator is operating at an output level that is not within the design parameters of the 

automatic voltage regulator or when operations of the automatic voltage regulator would 

result in instability. Accordingly, we sought comment on whether the Commission 

should direct WECC to develop a modification to the proposed regional Reliability 

Standard to address our concern. The Commission offered, for example, that WECC 

could develop a modification replacing the blanket two percent exemption with a list of 

specific exemptions that would accommodate generating units that are starting up or 

responding to unforeseen events and are operating outside of applicable facility ratings. 

Comments

59. WECC, supported by CDWR, urges the Commission to approve VAR-002-

WECC-1 with its exemption from using automatic voltage regulators during two percent 

of all operating hours. WECC contends that this exemption is not new and is included in 

WECC VAR-STD-002a-1, which addresses automatic voltage regulators. WECC 

explains that the current regional Reliability Standards includes levels of non-compliance 

that assess no penalty for generator operators that operate with their automatic voltage 

regulators in service at least 98 percent of the time. WECC contends that moving this 

exemption from the levels of non-compliance to the revised requirement was necessary to 
Docket No. RM09-9-000 - 34 - 

 

meet the Commission’s violation severity level guideline 3, which states that violation 

severity levels “should not appear to redefine or undermine the requirement.”33

60. WECC further contends that a directive reducing the two percent exemption will 

not increase the reliable performance of the Western Interconnection. WECC explains 

that the exemption is reasonable and a best business practice developed to enhance and 

protect reliability. WECC further explains that generator operators need the flexibility to 

take their automatic voltage regulator out of service when an operator is not comfortable 

with the performance of the automatic voltage regulator. WECC contends that requiring 

automatic voltage regulators to be in service 100 percent of all operating hours would be 

an onerous requirement that may, in fact, create a perverse incentive for generator 

operators to take their generation off-line rather than risk non-compliance with a more 

stringent requirement. Furthermore, WECC contends that the Commission’s suggestion 

that WECC develop a list of specific exemptions is untenable. WECC explains that it is 

difficult to define all of the reasons why it may be necessary to take an automatic voltage 

regulator out of service unless the exclusions were written more broadly. WECC also 

contends that when a generator operator is responding to alarms, it may not have 

sufficient time to determine if the situation complies with a list of exemptions. 

33 WECC Comments at 15, citing North American Electric Reliability Corp., 123 

FERC ¶ 61,284, at P 32 (2008) (Violation Severity Level Order). 
Docket No. RM09-9-000 - 35 - 

61. Although EPSA states that it supports the requirement that equipment such as 

automatic voltage regulators and power system stabilizers be available for a high 

percentage of the time a generator is in-service, EPSA urges the Commission to not 

mandate 100 percent availability for such ancillary equipment. EPSA contends that 

requiring equipment on generators to be available 100 percent of the time would not 

improve the reliability of the bulk electric system and would remove valuable generation 

from the grid, possibly due to what might be merely a minor problem associated with the 

ancillary equipment. 

62. The Bureau of Reclamation comments that the NOPR and revised regional 

Reliability Standard do not use consistent terminology when referring to the operation of 

the automatic voltage regulator. The Bureau of Reclamation explains that the use of the 

terms “[automatic voltage regulator] in service” and “[automatic voltage regulator] in 

automatic voltage control mode” is misleading making it hard to determine the basis for 

compliance. The Bureau of Reclamation states that, in discussing this issue with 

members of the drafting team, the intent was to capture the hours the excitation system 

was in automatic voltage regulator mode but the language of the standard is unclear. 

The Bureau of Reclamation suggests that Requirement R1 of VAR-002-WECC-1 should 

state: “Generator Operators and Transmission Operators shall have the excitation system 

in [automatic voltage regulator] mode 98% of all operating hours for synchronous 

generators or synchronous condensers.” 
Docket No. RM09-9-000 - 36 - 

63. Mariner comments that there is an inadequacy in VAR-002-WECC-1. Mariner 

states that a voltage schedule is needed to appropriately program the automatic voltage 

regulator to operate in automatic voltage control mode. However, the continent-wide 

Reliability Standard VAR-001-1 allows transmission owners to provide either a voltage 

schedule or a reactive power schedule to the generator operators. Mariner comments that 

a reactive power schedule does not provide a generator operator with enough information 

to appropriately program the automatic voltage regulator to operate in automatic voltage 

control mode as required, such that the reactive power output must continuously be 

monitored and manually adjusted throughout the day, thereby defeating the purpose of 

the “automatic” voltage regulator. Mariner further states that operating with these 

continuous manual adjustments to maintain a constant reactive power output could 

actually harm the reliability of the system. Accordingly, Mariner recommends that the 

Commission remand regional Reliability Standard VAR-002-WECC-1. 

Commission Determination

64. We recognize that the stated exemption from operating automatic voltage 

regulators during two percent of all operating hours is included in the levels of noncompliance associated with the currently-effective WECC VAR-STD-002a-1. We find 

that, by moving the exemption from the levels of non-compliance to the revised 

requirement, the revision is consistent with the Commission’s guidelines on violation 
Docket No. RM09-9-000 - 37 - 

 

severity levels.34 We also accept that requiring an exhaustive list of exemptions could 

result in overly broad exemptions that could allow generator operators to operate without 

automatic voltage regulators for more than two percent of all operating hours. If this 

were to occur, reliability could be diminished. 

65. The Commission understands that the purpose of the two percent exemption is to 

allow the generator operator to remove the automatic voltage regulator from service when 

the generator operator determines that automatic voltage regulator operation would 

jeopardize the generator or reliability of the Bulk-Power System. All hours included in 

the two percent exemption must be consistent with the purpose of the revised Regional 

Reliability Standard, which is to ensure the reliability of the Bulk-Power System within 

the Western Interconnection by ensuring that automatic voltage regulators on 

synchronous generators and condensers are kept in service and controlling voltage.35 We 

(continued...) 

34 See Violation Severity Level Order, 123 FERC ¶ 61,284 at P 32; see also North 

American Electric Reliability Corp., 119 FERC ¶ 61,260 at P 109 (directing that a 

substantive compliance responsibility be set forth in the Requirement of a Reliability 

Standard); Order No. 693, FERC Stats. & Regs., Regulations Preambles 2006-2007 

¶ 31,242 at P 253 (stating “while Measures and Levels of Non-Compliance provide 

useful guidance to the industry, compliance will in all cases be measured by determining 

whether a party met or failed to meet the Requirement given the specific facts and 

circumstances of its use, ownership or operation of the Bulk-Power System”). 

35 NERC states that WECC explained "the two percent allowance provides for 

time to start up generating facilities ... It also allows for evaluation when the Generator 

Operators respond to unforeseen events." NERC Petition at 34. In addition, WECC 

states “Generator Operators need the flexibility to take either their [automatic voltage 
Docket No. RM09-9-000 - 38 - 

 

will not direct WECC to modify the two percent exemption for automatic voltage 

regulator operation. 

66. In response to the comments filed by the Bureau of Reclamation, we agree that 

there is a difference between the automatic voltage regulator being “in service” and the 

automatic voltage regulator being “in automatic voltage control mode.” As the Bureau of 

Reclamation explained, modern excitation systems can include several control function 

modes, one of which is automatic voltage regulator mode. If the excitation controller is 

operating in automatic voltage regulator mode, then the generator is operating in 

automatic voltage control mode. If the excitation controller is operating in another mode, 

the generator is not operating in automatic voltage control mode. Accordingly, we 

believe that VAR-002-WECC-1 makes this distinction clear by requiring synchronous 

generators and synchronous condensers to have the automatic voltage regulator in service 

and in automatic voltage control mode. 

regulator] or [power system stabilizer] out of service when an operator is not comfortable 

with the performance of the [automatic voltage regulator] or [power system stabilizer]. ... 

Furthermore, when a Generator Operator is responding to alarms, there is not sufficient 

time to determine if the situation complies with the Standard’s exclusions. Giving the 

Generator Operator the time to evaluate the situation impacting the performance of an 

[automatic voltage regulator] or [power system stabilizer], rather than taking the 

generator out of service, provides for situational awareness and enhances reliability.” 

WECC Comments at 15-16. 
Docket No. RM09-9-000 - 39 - 

67. With regard to Mariner’s concern, we note that WECC has an ongoing project to 

address this issue.36 We encourage WECC to consider the comments of Mariner in this 

proceeding during the development of its Project WECC-0046 and encourage Mariner to 

participate. 

2. Exclusion of Synchronous Generators that Operate Less than 

Five Percent of All Hours During a Calendar Quarter

68. Requirement R1.1 of regional Reliability Standard VAR-002-WECC-1 allows 

exclusion of any synchronous generator or synchronous condenser that “operates for less 

than five percent of all hours during any calendar quarter” from operating with automatic 

voltage regulator in service and in automatic voltage control mode. During the 

Reliability Standard development process of the revised regional Reliability Standard, 

NERC expressed concern regarding the exclusion of these hours.37 WECC explained 

that the “exclusion below the five percent threshold during a calendar quarter permits 

continued practice of allowing the operation of peaking units without penalty for having 

an out-of-service [automatic voltage regulator] per the manufacturer recommendations” 

since “[p]eaking units often operate, for short periods, at low megawatt levels (below 

the 

 36 WECC Project WECC-0046 – VAR-001-WECC-1 Voltage and Reactive 

Control can be followed at: 

http://www.wecc.biz/Standards/Development/Pages/default.aspx. 

37 NERC Petition at 34-35. 
Docket No. RM09-9-000 - 40 - 

where manufacture[r]s recommend placing the [automatic voltage regulators] inservice).” 38 

NOPR Proposal

69. In the NOPR, the Commission observed that it appears that WECC developed the 

five percent threshold provision to account for out-of-service automatic voltage 

regulators per the manufacturer recommendations regarding automatic voltage regulator 

design limitations. The Commission expressed concern, however, that the provision is 

written more broadly than necessary. The Commission stated that it appears inefficient to 

allow an exemption for any synchronous generator or synchronous condenser that 

“operates for less than five percent of all hours during any calendar quarter” in order to 

address concerns about operation limits based on manufacture recommendations, and that 

such an exemption could potentially exempt other generator operators and transmission 

operators. Thus, the Commission sought comment on whether it should direct WECC to 

develop a modification through its Reliability Standards development process that 

addresses this concern. The Commission suggested that one reasonable solution would 

be to develop a replacement requirement that directly addresses the need for an 

exemption for peaking units operating automatic voltage regulators when necessary to 

 38 Id. at 35. 
Docket No. RM09-9-000 - 41 - 

satisfy manufacturer recommendations regarding the operation of an automatic voltage 

regulator. 

Comments

70. WECC, supported by SDG&E, comments that the five percent exemption is not 

new and is included in the applicability sections of WECC VAR-STD-002a-1 and VARSTD-002b-1. WECC contends that the retention of this exclusion in VAR-002-WECC-1 

will not diminish the reliability of the bulk electric system in the Western 

Interconnection. WECC further contends that it would not be cost-effective for some 

older generators that are used for short periods to replace, repair, or upgrade their 

automatic voltage regulator. WECC contends that it is more likely that these generators 

would be retired rather than make such repairs and, thus, they would no longer be 

available during peak periods. Thus, WECC argues, removing the five percent 

exemption could have a negative impact on reliability. 

71. EPSA supports an exemption from requiring ancillary equipment such as 

automatic voltage regulators on facilities that are online five percent or less of the time 

each year if the unit is not required to meet system operating limits or interconnection 

reliability operating limits. 

Commission Determination

72. The Commission recognizes that an exclusion for synchronous generators or 

synchronous condensers that operate for less than five percent of all hours during a 
Docket No. RM09-9-000 - 42 - 

calendar quarter from compliance with the requirement to have an automatic voltage 

regulator in service and in automatic voltage control mode exists as part of the 

“applicability” provision of currently-effective WECC VAR-STD-002a-1. We also 

understand that it may not be cost-effective for some older generators that are used only 

for short periods of time to replace, repair, or upgrade their automatic voltage regulator. 

The Commission, therefore, accepts this exclusion on the basis of WECC’s explanation 

that the retention of this exclusion will not diminish the reliability of the bulk electric 

system in the Western Interconnection. Even with the additional stringency of the 

regional Reliability Standard, generator operators must still comply with the requirements 

of NERC VAR-002-1.1b, which requires generators with automatic voltage regulators to 

operate each generator in the automatic voltage control mode unless the generator 

operator has notified the transmission operator. 

3. Automatic Voltage Regulator Replacement

73. Sub-requirement R1.6 of VAR-002-WECC-1 lengthens the automatic voltage 

regulator replacement timeline due to component failure from 15 months to 24 months 

“to accommodate design and procurement especially for nuclear units.”39 NERC 

supported the extension of the outage time frame for the automatic voltage regulators. 

 39 NERC Petition at Exhibit C, “Consideration of Comments for VAR-002-

WECC-1 – Automatic Voltage Regulator Comments were due January 2, 2008.” 
Docket No. RM09-9-000 - 43 - 

NOPR Proposal

74. The Commission, giving due weight to WECC and NERC, proposed to accept the 

Reliability Standard with this revision. Nevertheless, the Commission expressed concern 

that allowing an additional nine months of non-operation of an automatic voltage 

regulator is not necessary for many, if not most, units. The Commission commented that 

the additional replacement time could lead to a decrease in generation that can react in 

automatic voltage regulator mode. In the event of a contingency, this decrease in 

generation could have an impact on bulk electric system reliability. The Commission 

suggested that it may be appropriate for the Commission to direct WECC to develop a 

modification to this provision to address our concern. As an example, the Commission 

suggested that WECC could allow fifteen months for replacement with an opportunity to 

seek an extension up to nine months where justified. Alternatively, WECC could retain a 

fifteen month replacement period for non-nuclear generator units, and a twenty-four 

month replacement period for nuclear generator units. The Commission sought comment 

regarding the historical replacement period for nuclear and non-nuclear units, and the 

appropriateness of the Commission proposal. 

Comments

75. WECC comments that it has gained considerable knowledge on this subject since 

its previous standard was approved by the Commission. WECC states that drafting team 

members reviewed replacement experiences for a number of different types of generators 
Docket No. RM09-9-000 - 44 - 

and concluded that a 15 month replacement requirement was extremely tight. In 

addition, WECC states that because many automatic voltage regulators date back to the 

early 1970s or earlier, extensive refinements must be made to the design of the automatic 

voltage regulator and the excitation system to integrate an old analog system with a new 

digital system. WECC also points out that strict procurement regulations, contracting 

requirements, the limited number of suppliers, delivery, and installation time all make a 

15 month deadline infeasible. WECC further contends that the number of units that are 

operating without an automatic voltage regulator in service at the same time due to 

component failure is typically very limited. Thus, WECC argues, the additional time 

allowed for replacement would have very little to no impact on the overall reliability of 

the bulk electric system. 

76. EPSA also contends that 15 months is an insufficient period in which to require a 

generator to replace an automatic voltage regulator because of the length of the 

procurement period and the importance of fulfilling compliance requirements with 

respect to the replacement equipment. Accordingly, EPSA contends that the 24 month 

period represents an improvement that should be adopted by the Commission. SDG&E 

agrees that the replacement period should be extended to 24 months based on industry 

experience with these generator components. 
Docket No. RM09-9-000 - 45 - 

Commission Determination

77. We recognize, as WECC points out, that replacing an old automatic voltage 

regulator may require significant refinements to the design of the automatic voltage 

regulator and the excitation system to integrate a new digital system with an existing 

analog system, thereby requiring additional time. We also recognize that, as WECC and 

EPSA explain, procurement periods for new automatic voltage regulators might require 

more than 15 months. Although we did not receive any specific details regarding 

historical automatic voltage regulator replacement timeframes, WECC states that the 

drafting team members reviewed replacement experiences for a number of different types 

of generators and concluded the 15-month replacement requirement was “extremely 

tight.”40 Based on these explanations, we approve the regional Reliability Standard with 

the modified provision, Requirement R1.6, which allows up to 24 months for replacing 

an excitation system due to component failure. 

4. Automatic Voltage Regulator Performance

78. The current regional Reliability Standard provides that “[a]ll synchronous 

generators with automatic voltage control equipment shall normally be operated in 

voltage control mode and set to respond effectively to voltage deviations.” The revised 

Reliability Standard VAR-002-WECC-1 removes this requirement. 

 40 WECC Comments at 18. 
Docket No. RM09-9-000 - 46 - 

NOPR Proposal

79. The Commission noted that the NERC Petition does not provide any explanation 

for, or potential impact of, removing the provision. Accordingly, the Commission sought 

further comment on the impact of removing this provision from the currently-effective 

WECC regional Reliability Standard. The Commission expressed concern that, by 

removing the requirement for automatic voltage regulators to respond effectively to 

voltage deviations, the proposed regional Reliability Standard would not require entities 

to assess the performance of the automatic voltage regulators to ensure they are 

appropriately responding to voltage deviations to support reliability of the Bulk-Power 

System. 

Comments

80. WECC comments that it removed the requirement for generators with automatic 

control equipment to operate in automatic voltage control mode because NERC 

Reliability Standard VAR-002-1.1b already requires generator operators to operate each 

generator connected to the interconnected transmission system in the automatic voltage 

control mode unless the generator operator has notified the transmission operator. Thus, 

WECC contends, exclusion of this requirement from VAR-002-WECC-1 will have no 

impact on the reliability of the bulk electric system because generators must still comply 

with the requirements of NERC Reliability Standard VAR-002-1.1b. WECC further 

contends that including this requirement in the revised regional Reliability Standard 
Docket No. RM09-9-000 - 47 - 

would unnecessarily expose entities in the West to the possibility of non-compliance with 

the same requirement in two different Reliability Standards. 

81. The Bureau of Reclamation also contends that it is unnecessary to maintain a 

requirement for automatic voltage regulators to respond to voltage deviations. The 

Bureau of Reclamation explains that the requirement to ensure proper tuning and 

performance of automatic voltage regulators is covered under the MOD series of 

Reliability Standards, specifically MOD-012-1 and MOD-013-1. 

Commission Determination

82. As WECC points out, Requirement R1 of NERC Reliability Standard VAR-002-

1.1b requires generator operators to “operate each generator connected to the 

interconnected transmission system in the automatic voltage control mode (automatic 

voltage regulator in service and controlling voltage).” WECC explains that it understood 

the currently-effective regional requirement for all synchronous generators with 

automatic voltage control equipment to be normally operating in voltage control mode 

and set to respond effectively to voltage deviations to be duplicative of Requirement R1 

of NERC Reliability Standard VAR-002-1.1b. The Commission believes that, if a 

generator operator with an installed automatic voltage regulator complies with the NERC 

requirement to have the generator in automatic voltage control mode, generators should 

be set to respond effectively to voltage deviations. Thus, we find that there will be no 

impact to the reliability of the bulk electric system if this provision is removed from the 
Docket No. RM09-9-000 - 48 - 

 

regional Reliability Standard because the requirement remains enforceable under NERC 

Reliability Standard VAR-002-1.1.b. 

83. The Commission disagrees with the Bureau of Reclamation’s comment that NERC 

Reliability Standards MOD-012-0 and MOD-013-1 address requirements for ensuring 

proper tuning and performance of automatic voltage regulators.41 The Commission 

agrees that the requirements in MOD-012-0 require entities to provide dynamic system 

modeling and simulation data, including data regarding “excitation systems, voltage 

regulators, turbine-governor systems, power system stabilizers, and other associated 

generation equipment” to the Regional Entities and NERC for use in reliability analysis 

of the interconnected transmission system.42 These Reliability Standards do not require 

proper performance and tuning of an automatic voltage regulator, but the data required by 

NERC Reliability Standard MOD-012-0 could help identify improper performance of an 

automatic voltage regulator when employed in certain reliability analyses. 

41 Order No. 693 approved Reliability Standard MOD-012-0 as mandatory and 

enforceable. However, Order No. 693 deemed MOD-013-0 as a fill-in-the-blank 

Reliability Standard in part because its requirements apply to the Regional Reliability 

Organizations, now called Regional Entities, which the Commission was not persuaded 

NERC can enforce a Regional Entity’s compliance with a Reliability Standard. See

Order No. 693, FERC Stats. & Regs., Pregulations Preambles ¶ 31,242 at P 301. 

42 Reliability Standard MOD-013-1, Requirement R1.2.
Docket No. RM09-9-000 - 49 - 

84. Accordingly, in view of WECC’s comments that NERC Reliability Standard 

VAR-002-1.1b subjects WECC generators to the requirement for generators to be 

normally operated “in voltage control mode and set to respond effectively to voltage 

deviations,” and that a similar regional Reliability Standard requirement would be 

duplicative, we will not direct any modifications to VAR-002-WECC-1. 

5. Summary

85. For the reasons discussed above, the Commission adopts its NOPR proposal to 

approve VAR-002-WECC-1 as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. The Commission also approves NERC’s petition 

to retire currently-effective WECC-VAR-STD-002a-1. Based on the comments received 

from WECC and other entities, we will not, at this time, direct any modifications to 

Reliability Standard VAR-002-WECC-1. 

D. VAR-501-WECC-1

86. Regional Reliability Standard VAR-501-WECC-1 contains two requirements that 

are intended to ensure that power system stabilizers on synchronous generators are kept 

in service. Requirement R1 provides that each generator operator with a synchronous 

generator equipped with a power system stabilizer must have the power system stabilizer 

in service during 98 percent of all operating hours. NERC explains that a power system 

stabilizer is part of the excitation control system of a generator used to increase power 

transfer levels by improving power system dynamic performance. Sub-requirements 
Docket No. RM09-9-000 - 50 - 

R1.1 through R1.12 set forth exceptions to the operating requirement in Requirement R1. 

Requirement R2 states that each generator operator must have documentation identifying 

the number of hours excluded for each sub-requirement R1.1 through R1.12. 

NOPR Proposal

87. In the NOPR, the Commission proposed to approve VAR-501-WECC-1 as just, 

reasonable, not unduly discriminatory or preferential, and in the public interest. The 

Commission also proposed to approve NERC’s proposed retirement of currentlyeffective WECC VAR-STD-002b-1. Nevertheless, the Commission sought comment on 

certain provisions of VAR-501-WECC-1 including: (1) the power system stabilizer inservice requirement, (2) the exclusion of synchronous generators that operate for less 

than five percent of all hours during a calendar quarter, (3) the replacement period for 

power system stabilizers, and (4) power system stabilizer performance. 

1. Power System Stabilizer In-Service Requirement

88. Requirement R1 of VAR-501-WECC-1 provides that “Generator Operators shall 

have [power system stabilizers] in service 98 [percent] of all operating hours for 

synchronous generators equipped with [power system stabilizers].”43 Requirement R1 

also sets forth twelve circumstances in which a generator operator is excused from this 

requirement. 

 43 Proposed regional Reliability Standard VAR-501-WECC-1, Requirement R1. 
Docket No. RM09-9-000 - 51 - 

NOPR Proposal

89. In the NOPR, the Commission observed that by specifying the circumstances in 

which a generator operator is excused from keeping its power system stabilizer in service, 

the proposed requirement appears to be more stringent than the currently-effective 

requirement in NERC Reliability Standard VAR-002-1.1b, which requires only that a 

generator operator notify its transmission operator when there is a change in status of its 

power system stabilizer. Nevertheless, the Commission commented that, where installed, 

power system stabilizers should be in-service at all times, equipment and facility ratings 

permitting, unless exempted by the transmission operator. 

90. Similar to its concerns with automatic voltage regulators addressed in VAR-002-

WECC-1, the Commission stated that an exemption to an in-service requirement might 

be appropriate to accommodate generating facilities when they are starting up or 

operating outside of their facility ratings. The Commission expressed concern, however, 

that the proposed regional Reliability Standard provides no limitation as to when 

generating units may use the two percent exemption. Accordingly, we sought comment 

on whether the Commission should direct WECC to develop a modification to the 

proposed regional Reliability Standard that would address our concern. The Commission 

suggested, as an example, that WECC could develop a modification to replace the 

blanket two percent exemption with a more specific list of exemptions that would 
Docket No. RM09-9-000 - 52 - 

accommodate generating units that are starting up or are operating outside of applicable 

facility ratings. 

Comments

91. WECC, supported by CDWR, urges the Commission to approve VAR-501-

WECC-1 with its exemption for using power system stabilizers two percent of all 

operating hours. WECC comments that VAR-501-WECC-1 addresses an issue that is not 

covered by any NERC Reliability Standard. In addition, WECC contends that this 

exemption is not new and is included in WECC VAR-STD-002b-1, which addresses 

power system stabilizer operation. WECC explains that the current regional Reliability 

Standard includes levels of non-compliance that assess no penalty for generator operators 

that operate with their power system stabilizers in service at least 98 percent of the time. 

WECC contends that moving this exemption from the levels of non-compliance to the 

revised requirement was necessary to meet the Commission’s violation severity level 

guideline 3, which states that violation severity levels “should not appear to redefine or 

undermine the requirement.”44

92. WECC further contends that a directive reducing the two percent exemption will 

not increase the reliable performance of the Western Interconnection. WECC explains 

 44 WECC Comments at 15, citing Violation Severity Level Order, 123 FERC 

¶ 61,284 at P 32. 
Docket No. RM09-9-000 - 53 - 

that the exemption is reasonable and a best business practice developed to enhance and 

protect reliability. WECC further explains that generator operators need the flexibility to 

take their power system stabilizers out of service when an operator is not comfortable 

with the performance of the power system stabilizer. WECC contends that requiring 

power system stabilizers to be in service 100 percent of all operating hours would be an 

onerous requirement that may, in fact, create a perverse incentive for generator operators 

to take their generation off-line rather than risk non-compliance with a more stringent 

requirement. Furthermore, WECC contends that the Commission’s suggestion that 

WECC develop a list of specific exemptions is untenable. WECC explains that it is 

difficult to define all of the reasons where it may be necessary to take a power system 

stabilizer out of service. WECC also contends that when a generator operator is 

responding to alarms, it may not have sufficient time to determine if the situation 

complies with a list of exemptions. 

93. The Bureau of Reclamation points out that three of the twelve exceptions for the 

in-service requirement concern the power output level of the generator: Requirement 

R1.4 concerns when the unit is operating in synchronous condenser mode; Requirement 

R1.5 concerns when the unit is generating less power than the design limit for effective 

power system stabilizer operation; and Requirement R1.6 concerns when the unit is 

passing through a range of output that is a known “rough zone.” The Bureau of 

Reclamation comments that for most hydro generators the power system stabilizer is 
Docket No. RM09-9-000 - 54 - 

always in-service but control of power system stabilizers is performed by the power 

system stabilizer controller, automatically engaging or bypassing the power system 

stabilizer when output reaches a certain level. The Bureau of Reclamation contends that, 

as hydro generators are commonly used for regulation and peaking, these generators 

could be passing through the power system stabilizer pre-programmed levels several 

times a day. The Bureau of Reclamation recommends that the Commission remand 

VAR-501-WECC-1. 

Commission Determination

94. We accept the explanation of WECC and other supporting comments on this 

matter. We recognize that the stated exemption from operating power system stabilizers 

two percent of all operating hours is included in the levels of non-compliance associated 

with the currently-effective WECC VAR-STD-002b-1. Further, we find that, by moving 

the stated exemption from the levels of non-compliance measures to the revised 

requirement, the revision is consistent with the Commission’s guidelines on violation 

severity levels and with our determinations in Order No. 693.45 We also accept that 

 

(continued...) 

45 See Violation Severity Level Order, 123 FERC ¶ 61,284 at P 32; see also North 

American Electric Reliability Corp., 119 FERC ¶ 61,260 at 109 (directing that a 

substantive compliance responsibility be set forth in the Requirement of a Reliability 

Standard); Order No. 693, FERC Stats. & Regs., Regulations Preambles 2006-2007 

¶ 31,242 at P 253 (stating “while Measures and Levels of Non-Compliance provide 

useful guidance to the industry, compliance will in all cases be measured by determining 
Docket No. RM09-9-000 - 55 - 

requiring an exhaustive list of exemptions could result in overly broad exemptions that 

could allow generator operators to operate without power system stabilizers for more than 

two percent of all operating hours. If this were to occur, reliability could be diminished. 

95. The Commission understands that the purpose of the two percent exemption is to 

allow the generator operator with an installed power system stabilizer to remove the 

power system stabilizer from service when the generator operator determines that power 

system stabilizer operation would jeopardize the generator or reliability of the BulkPower System. All hours included in the two percent exemption must be consistent with 

the purpose of the revised regional Reliability Standard, which is to ensure the reliability 

of the Bulk-Power System within the Western Interconnection by ensuring that power 

system stabilizers on synchronous generators are kept in service and controlling 

voltage.46 We will not direct WECC to modify the two percent exemption for power 

system stabilizer operation. 

2. Exclusion of Synchronous Generators that Operate for Less 

than Five Percent of All Hours During a Calendar Quarter

96. Requirement R1.1 of regional Reliability Standard VAR-501-WECC-1 allows 

exclusion of any synchronous generator that operates for less than five percent of all 

 

 whether a party met or failed to meet the Requirement given the specific facts and 

circumstances of its use, ownership or operation of the Bulk-Power System”). 

46 See supra note 35. 
Docket No. RM09-9-000 - 56 - 

hours during any calendar quarter from the requirement that it operate with power system 

stabilizers in service. In its petition, NERC explained that, during the Reliability 

Standard development process of the regional Reliability Standard, NERC expressed 

concern regarding the exclusion of these hours.47 WECC responded by explaining that 

the “exclusion below the five percent threshold during a calendar quarter permits the 

continued practice of allowing the operation of peaking units without penalty for having 

an out-of-service power system stabilizer per the manufacturer recommendations” since 

“[p]eaking units often operate, for short periods, at low megawatt levels (below where 

manufacture[r]s recommend placing the [power system stabilizer] in-service).” 48 

NOPR Proposal

97. In the NOPR, the Commission noted that it appears that WECC developed the five 

percent threshold to account for out-of-service power system stabilizer per manufacturer 

recommendations. We sought comment on whether the proposed provision is written 

more broadly than necessary. Based on the comments received, the Commission stated 

that it might propose to direct WECC to develop a modification through its Reliability 

Standards development process that addresses this concern. The Commission suggested 

that one reasonable solution would be to develop a replacement requirement that directly 

 47 NERC Petition at 40. 

48 Id. 
Docket No. RM09-9-000 - 57 - 

addresses the need for an exemption for peaking units that may not operate with power 

system stabilizers to satisfy manufacturer recommendations. 

Comments

98. WECC, supported by SDG&E and EPSA, comments that the five percent 

exemption is not new and is included in the applicability sections of WECC VAR-STD002a-1 and VAR-STD-002b-1. WECC contends that the retention of this exclusion in 

the VAR-501-WECC-1 will not diminish the reliability of the bulk electric system in the 

Western Interconnection. WECC further contends that it would not be cost-effective for 

some older generators that are used for short periods to replace, repair, or upgrade their 

power system stabilizers. WECC contends that it is more likely that these generators 

would be retired rather than make such repairs and, thus, they would no longer be 

available during peak periods. Thus, WECC contends, removing the five percent 

exemption could have a negative impact on reliability. 

Commission Determination

99. We recognize that a stated exclusion for synchronous generators that operate for 

less than five percent of all hours during a calendar quarter from compliance with the 

requirement to have a power system stabilizer in service exists in the applicability section 

of the currently-effective WECC VAR-STD-002b-1. We also understand that it may not 

be cost-effective for some older generators that are used only for short periods of time to 

replace, repair, or upgrade their power system stabilizers. We, therefore, agree that this 
Docket No. RM09-9-000 - 58 - 

exclusion will not diminish the reliability of the bulk electric system in the Western 

Interconnection. We believe that the requirement is acceptable because there is no 

corresponding NERC requirement for power system stabilizers and, thus, the revised 

standard is more stringent than the requirements of the NERC Reliability Standards. 

Accordingly, we are satisfied with WECC’s explanation on this matter. 

3. Power System Stabilizer Replacement

100. Proposed sub-requirement R1.10 lengthens the power system stabilizer 

replacement timeline due to component failure from 15 months to 24 months “to 

accommodate design and procurement especially for nuclear units.”49 

NOPR Proposal

101. The Commission proposed to accept this requirement even though WECC 

provided limited evidence in the record to support the extension of the outage time frame 

for power system stabilizers from 15 months to 24 months. However, since the rationale 

provided for the increased replacement period is based on the needs of nuclear power 

generators, the Commission expressed concern whether the additional nine months are 

necessary for many, if not most, units. The Commission explained that the additional 

replacement time could lead to a decrease in generation units operating with power 

 49 NERC Petition at Exhibit C, “Consideration of Comments for VAR-501-

WECC-1 – Power System Stabilizer Comments were due January 2, 2008.” 
Docket No. RM09-9-000 - 59 - 

system stabilizers. The Commission commented that, in the event of a contingency, 

such a decrease could have an impact on bulk electric system reliability. Accordingly, 

the Commission sought comment regarding the historical replacement period for nuclear 

and non-nuclear units, and the appropriateness of the Commission proposal. 

Comments

102. WECC comments that it has gained considerable knowledge on this subject since 

the Commission approved the currently-effective regional Reliability Standard in 2007. 

WECC states that drafting team members reviewed replacement experiences for a 

number of different types of generators and concluded that a 15 month replacement 

requirement was extremely tight. In addition, WECC states that because many power 

system stabilizers date back to the early 1970s or earlier, extensive refinements must be 

made to the design of the power system stabilizer and the excitation system to integrate 

an old analog system with a new digital system. WECC also points out that strict 

procurement regulations, contracting requirements, the limited number of suppliers, 

delivery, and installation time all make a 15 month deadline infeasible. WECC further 

contends that the number of units that are operating without a power system stabilizer in 

service at the same time due to component failure is typically very limited. Thus, WECC 

argues, there would be very little, if any, impact on bulk electric system reliability that 

would result from an increase in the outage time frame to 24 months. 
Docket No. RM09-9-000 - 60 - 

103. EPSA comments that 15 months is an insufficient period in which to require a 

generator to replace a power system stabilizer because of the length of the procurement 

period and the importance of fulfilling compliance requirements with respect to the 

replacement equipment. Accordingly, EPSA advocates that the 24-month period 

represents an improvement that should be adopted by the Commission. SDG&E agrees 

that the replacement period should be extended to 24 months based on industry 

experience with these generator components. 

Commission Determination

104. We recognize, as WECC points out, that replacing an old power system stabilizer 

may require significant refinements to the design of the power system stabilizer and the 

excitation system to integrate a new digital system with an existing analog system, 

thereby requiring additional time. We also recognize that, as WECC and EPSA explain, 

procurement periods for new power system stabilizers might require more than 

15 months. Although we did not receive any specific details regarding historical power 

system stabilizer replacement timeframes, WECC states that the drafting team members 

reviewed replacement experiences for a number of different types of generators and 

concluded the 15-month replacement requirement was “extremely tight.”50 Based on 

these explanations, we approve the regional Reliability Standard with the modified 

 50 WECC Comments at 18. 
Docket No. RM09-9-000 - 61 - 

provision, Requirement R1.6, which allows up to 24 months for replacing a power system 

stabilizer and excitation system due to component failure. 

4. Power System Stabilizer Performance

105. The current regional Reliability Standard requires all generators with power 

system stabilizers to be properly tuned in accordance with the WECC requirements. 51 

The proposed regional Reliability Standard removes the tuning requirement without 

explanation or analysis of the potential impact of removing the provision. 

NOPR Proposal

106. In the NOPR, the Commission expressed its belief that, if a power system 

stabilizer is in-service, it must be properly tuned to enhance system damping and 

maintain system stability. The Commission, therefore, sought further explanation from 

WECC and NERC, and public comment, on the impact of removing the tuning 

requirement. 

Comments

107. WECC states that the Commission is correct that a properly-tuned power system 

stabilizer is necessary to enhance system damping. WECC contends, however, that a 

power system stabilizer tuning requirement is not necessary because, in order for a 

 51 Id. Requirement WR1 of the currently-effective regional Reliability Standard 

provides: “Power System Stabilizers on generators shall be kept in service at all times, 

unless one of the exemptions listed in Section C (Measures) applies, and shall be properly 

tuned in accordance with WECC requirements.” 
Docket No. RM09-9-000 - 62 - 

generator operator to meet the in-service requirements of VAR-501-WECC-1 without 

experiencing inappropriate system oscillations, that generator operator typically must 

have a properly tuned power system stabilizer. WECC adds that VAR-501-WECC-1 is a 

performance, not a tuning standard, which is why WECC’s standards development 

drafting team excluded this requirement from the revised regional Reliability Standard. 

108. Moreover, WECC contends that power system stabilizer tuning should not be 

added to VAR-501-WECC-1 because tuning is highly site and unit specific, making it 

difficult to enforce a “proper tuning” requirement. WECC further contends that 

identifying whether or not a power system stabilizer or excitation system is properly 

tuned is very dependent upon the professional opinion of the expert performing the 

tuning. WECC also points out that older analog power system stabilizers are being 

replaced with newer digital versions, which do not require any further adjustments unless 

changes are made to the system configuration. Moreover, WECC contends that because 

the new digital power system stabilizers, unlike the older analog versions, do not drift, 

the periodic testing requirement which sought to address drift by requiring a five-year 

tuning power system stabilizer testing program is no longer necessary. 

109. EPSA comments that a generator operator can purchase, install and tune power 

system stabilizer equipment but regional entities may have the tools to measure proper 

tuning. EPSA contends that an out-of-tune power system stabilizer could be identified 

faster using analyses performed by the transmission operator or regional entity than the 
Docket No. RM09-9-000 - 63 - 

owner of the power system stabilizer could identify by routinely checking power system 

stabilizer tuning parameters. Moreover, EPSA comments, new power system stabilizers 

are digital, so less component drift takes place than in older power system stabilizers that 

would need to be checked periodically. EPSA predicts that it may not be long before 

new power system stabilizers are self-learning and self-tuning. 

110. In contrast, PacifiCorp suggests modifying the proposed regional Reliability 

Standard to include language that the power system stabilizer shall be tuned in 

accordance with WECC requirements, without prescribing any intervals. PacifiCorp 

further suggests that carrying over this requirement from the current standard would 

ensure any power system stabilizer will be properly tuned. 

Commission Determination

111. Although a properly-tuned power system stabilizer is necessary to enhance system 

damping, we accept the exclusion of the current tuning requirement based on WECC’s 

explanation that, in order for a generator operator with an installed power system 

stabilizer to meet the in-service requirements of VAR-501-WECC-1, the power system 

stabilizer must be properly tuned to prevent experiencing inappropriate system 

oscillations. A tuning requirement would require removal of the power system stabilizer 

from service, which may cause the generator operator to be non-compliant with the 

performance requirements of VAR-501-WECC-1. Accordingly, we will not direct any 

modifications to VAR-501-WECC-1 regarding a power system stabilizer tuning 
Docket No. RM09-9-000 - 64 - 

requirement. If, in the future, WECC develops a requirement for power system stabilizer 

tuning, we urge WECC to consider the comments submitted by PacifiCorp to include 

such a tuning requirement. 

5. Reporting Burden

NOPR Proposal

112. In the NOPR, the Commission noted that the revised WECC Reliability Standards 

do not modify or otherwise affect the burdens related to the collection of information 

already in place. Thus, the Commission preliminarily concluded that the revised WECC 

Reliability Standards will neither increase the reporting burden nor impose any additional 

information collection requirements. 

Comments

113. Melissa Kurtz, USACE NWW, USACE Portland, USACE Seattle contend that, 

contrary to the Commission’s burden estimate in the NOPR, compliance with VAR-501-

WECC-1 will impose an additional burden on entities that must now track when a power 

system stabilizer is off. These commenters state that the power system stabilizer is 

largely handled by the generator exciter, which is programmed to activate and deactivate 

the power system stabilizer depending on generator loading conditions. They explain 

that the exciter automatically turns the power system stabilizer off when the unit is 

passing through a rough zone, when the unit is generating less power than its design limit 

for effective power system stabilizer operation, or when the unit is condensing. They 
Docket No. RM09-9-000 - 65 - 

contend that VAR-501-WECC-1 will require tracking the status of the power system 

stabilizer that is turning on and off automatically along with the reason it is turned off. 

They also explain that a power system stabilizer is a piece of remote equipment that sits 

on the powerhouse floor and is not conveniently located for observation. Thus, they 

argue that the required tracking is not reasonable and will not add to system reliability 

because it uses scarce resources to track the information. Further, commenters state that 

tracking this information would require hardware and software modifications by staff. 

They suggest that evidence of compliance through system settings is more beneficial than 

micromanaging the results of a machine. 

114. The Bureau of Reclamation states that it has no process to track the minutes that 

the power system stabilizer is in a bypass condition and to develop such a process, as 

would be required under Requirement R2 of VAR-501-WECC-1, would be very 

burdensome. The Bureau of Reclamation further comments that tracking such a transient 

condition does not add to the reliability of the bulk electric system. Finally, the Bureau 

of Reclamation points out that the current regional Reliability Standard does not include a 

requirement to track and document the time the power system stabilizer controller places 

the power system stabilizer in bypass condition. 

Commission Determination

115. The Commission finds that VAR-501-WECC-1 does not impose any new 

reporting requirements. Under Requirement R3.1 of NERC Reliability Standard VAR-
Docket No. RM09-9-000 - 66 - 

 

002-1.1b a generator operator must notify its transmission operator as soon as practical 

but no later than 30 minutes after a “status or capability change on any generator 

Reactive Power resource, including the status of each automatic voltage regulator and 

power system stabilizer and the expected duration of the change in status or capability.”52

Thus, generator operators already must monitor and report changes in status of their 

power system stabilizers. 

116. We believe that the documentation requirement for exempt outages of power 

system stabilizers under Requirement R2 of VAR-501-WECC-1 is consistent with the 

existing reporting requirement under Requirement R3.1 of NERC VAR-002-1.1b. If a 

generator operator must already notify its transmission operator of a change in status of 

each power system stabilizer, it should not create an added burden to document those 

changes. Thus, we do not expect implementation of VAR-501-WECC-1 to result in an 

increased reporting burden to generator operators. If, however, generator operators in the 

Western Interconnection continue to be concerned about their compliance with either of 

these Reliability Standards, we believe that such a concern is best addressed through the 

compliance programs at either WECC or NERC. 

52 NERC Reliability Standard VAR-002-1.1b, Requirement R3.1. 
Docket No. RM09-9-000 - 67 - 

6. Summary

117. The Commission adopts its NOPR proposal to approve VAR-501-WECC-1 as 

just, reasonable, not unduly discriminatory or preferential, and in the public interest. We 

accept WECC’s explanations for the issues raised in the NOPR. Accordingly, we will 

not, at this time, direct WECC to develop any modifications to VAR-501-WECC-1. We 

also dismiss arguments raised by Melissa Kurtz, USACE NWW, USACE Portland, and 

USACE Seattle that the revised regional Reliability Standard creates an undue reporting 

burden. 

E. NERC VAR-002-1.1b

118. In the NOPR, the Commission sought comment as to whether it should direct 

NERC to develop a modification to VAR-002-1.1b to clarify that, if a generator has an 

automatic voltage regulator or power system stabilizer installed, it must be in-service at 

all times, equipment and facility ratings permitting, unless exempted by the transmission 

operator. 

119. The Commission noted that NERC Reliability Standard does not address power 

system stabilizer tuning. The Commission stated that a properly tuned power system 

stabilizer is necessary to enhance system damping. If a power system stabilizer is 

installed, periodic review of the power system stabilizer tuning is a significant component 

of maintaining system stability to ensure that system changes have not impacted the 

performance of the power system stabilizer in supporting system stability. Accordingly, 
Docket No. RM09-9-000 - 68 - 

the Commission sought comment on whether it should propose to direct NERC to 

develop a continent-wide Reliability Standard to address this concern. The Commission 

added that any resulting proposal to direct the development of modifications to the NERC 

Reliability Standards would be addressed in a separate proceeding. 

Comments

120. NERC comments that it has not performed the technical analysis necessary to 

determine whether it is necessary for Bulk-Power System reliability to develop a tuning 

requirement for power system stabilizers. If the Commission receives comments that 

would compel it to direct NERC to develop such a requirement, NERC asks that the 

Commission allow NERC enough flexibility so that it can appropriately prioritize the 

directive. 

Commission Determination

121. The Commission will not, at this time, commence a new proceeding to propose a 

directive to NERC to develop a requirement on power system stabilizer tuning. We 

recognize that the need for a requirement on power system stabilizer tuning is reduced as 

generator operators install new digital power system stabilizers, which are less prone to 

drifting and should not require adjustment unless changes are made to system 

configurations. Nevertheless, we may revisit this proposal as more practical experience 

with the new digital technology progresses. 
Docket No. RM09-9-000 - 69 - 

F. Violation Risk Factors and Violation Severity Levels 

122. In the event of a violation of a Reliability Standard, consistent with NERC 

practices, WECC establishes the initial value range for the corresponding base penalty 

amount. To do so, WECC assigns a violation risk factor for each requirement of a 

Reliability Standard that relates to the expected or potential impact of a violation of the 

requirement on the reliability of the Bulk-Power System. In addition, WECC defines up 

to four violation severity levels – Lower, Moderate, High, and Severe – as measurements 

for the degree to which the requirement was violated in a specific circumstance. 

123. Violation risk factors and violation severity levels are not part of the Reliability 

Standard and, thus, are appropriately treated as an appendix to NERC’s Rules of 

Procedure.53 Revisions of violation severity levels do not modify the Reliability 

Standard. Accordingly, NERC and the regional entities are not required to comport with 

the Reliability Standards development provisions of section 215 of the FPA when 

revising a violation risk factor or violation severity level assignment.54 

124. In Order No. 705, the Commission approved 63 of NERC’s 72 proposed violation 

risk factors for the version one FAC Reliability Standards and directed NERC to file 

violation severity level assignments before the version one FAC Reliability Standards 

 53 Violation Severity Level Order, 123 FERC ¶ 61,284 at P 15. 

54 See North American Electric Reliability Corporation, 120 FERC ¶ 61,145 at 

P 16. 
Docket No. RM09-9-000 - 70 - 

 

become effective.55 Subsequently, NERC developed violation severity levels for each 

requirement of the Commission-approved FAC Reliability Standards, as measurements 

for the degree to which the requirement was violated in a specific circumstance. 

125. On June 19, 2008, the Commission issued its Violation Severity Level Order 

approving the violation severity level assignments filed by NERC for the 83 Reliability 

Standards approved in Order No. 693.56 In that order, the Commission offered four 

guidelines for evaluating the validity of violation severity levels, and ordered a number of 

reports and further compliance filing to bring the remainder of NERC’s violation severity 

levels into conformance with the Commission’s guidelines. The four guidelines are: 

(1) violation severity level assignments should not have the unintended consequence of 

lowering the current level of compliance; (2) violation severity level assignments should 

ensure uniformity and consistency among all approved Reliability Standards in the 

determination of penalties;57 (3) violation severity level assignments should be consistent 

with the corresponding requirement; and (4) violation severity level assignments should 

55 Facilities Design, Connections and Maintenance Reliability Standards, Order 

No. 705, 121 FERC ¶ 61,296, at P 137 (2007). 

56 Violation Severity Level Order, 123 FERC ¶ 61,284. 

57 Guideline 2 contains two sub-parts: (a) the single violation severity level 

assignment category for binary requirements should be consistent and (b) violation 

severity levels assignments should not contain ambiguous language. 
Docket No. RM09-9-000 - 71 - 

 

be based on a single violation, not a cumulative number of violations.58 The Commission 

found that these guidelines will provide a consistent and objective means for assessing, 

inter alia, the consistency, fairness and potential consequences of violation severity level 

assignments. The Commission noted that these guidelines were not intended to replace 

NERC’s own guidance classifications but, rather, to provide an additional level of 

analysis to determine the validity of violation severity level assignments. 

126. On August 10, 2009, NERC submitted an informational filing setting forth a 

summary of revised guidelines that NERC intends to use in determining the assignment 

of violation risk factors and violation severity levels for Reliability Standards. NERC 

states that these revised guidelines were consistent with Commission’s guidelines. On 

May 5, 2010, NERC submitted an informational filing as a supplement to its pending 

March 5, 2010 Violation Severity Level Order compliance filing.59 In that May 5, 2010 

filing, NERC proposes to assign a violation severity level only to each main requirement. 

Thus, a violation of any number of sub-requirements would trigger only a single violation 

of the main requirement. This proposed “roll-up” methodology is currently pending 

before the Commission in Docket No. RR08-4-005. 

58 Violation Severity Level Order, 123 FERC ¶ 61,284 at P 17. 

59 North American Reliability Corporation, Filing of the North American Electric 

Reliability Corporation regarding the Assignment of Violation Risk Factors and Violation 

Severity Levels, Docket No. RR08-4-005 (filed May 5, 2010). 
Docket No. RM09-9-000 - 72 - 

WECC Proposal

127. As discussed above, WECC has developed violation risk factors and violation 

severity levels for each of these revised regional Reliability Standards. WECC states that 

it developed these violation risk factors and violation severity levels in response to 

comments from NERC and the Commission that it should replace its existing sanctions 

tables. In addition, NERC states in its petition that WECC has agreed to conform the 

format of the violation severity levels to that of the NERC Reliability Standards in 

revisions to the four regional Reliability Standards. 

Commission Determination

128. The Commission approves the violation risk factors and violation severity levels 

assigned to FAC-501-WECC-1, PRC-004-WECC-1, VAR-002-WECC-1, and VAR-501-

WECC-1. We note, however, that there appear to be some missing violation risk factors 

and severity levels. Even with these potential gaps, however, the requirements of the 

WECC Reliability Standards approved in this Final Rule shall be enforceable upon their 

implementation. 

129. In FAC-501-WECC-1, the Lower violation severity level applies when the 

transmission maintenance and inspection plan does not include facilities for one of the 

paths in the WECC Transfer Path Table, but the transmission owners are performing 

maintenance and inspection for those facilities. The Moderate violation severity level 

applies when the transmission maintenance and inspection plan does not include facilities 
Docket No. RM09-9-000 - 73 - 

for two of the paths in the WECC Transfer Path Table, and the transmission owners are 

not performing maintenance and inspection for those facilities. Based on these two 

violation severity level assignments, it is ambiguous which violation severity level would 

apply if the transmission maintenance and inspection plan does not include facilities for 

one of the paths in the WECC Transfer Path Table, and the transmission owners are not 

performing maintenance and inspection for those facilities. 

130. In PRC-004-WECC-1, the violation severity levels for Requirement R2.3 do not 

define any potential violations for the transmission owner even though both Requirement 

2.3 and sub-Requirement 2.3.1 apply to the transmission owner, a situation that could be 

viewed as violating violation severity level guideline 3. Also in PRC-004-WECC-1, 

violation risk factors have not been assigned for Requirements R2, R2.4 and R2.4.1. If 

WECC believes that it would be inappropriate to assign violation risk factors to these 

requirements, it should submit an explanation. 

131. In VAR-002-WECC-1, Requirement R1 requires the automatic voltage regulators 

to be “in service and in automatic voltage control mode” but the violation severity levels 

for Requirement R1 specify only that the automatic voltage regulator must be “in 

service,” which could be viewed as violating violation severity level guideline 3. Also, 

the violation severity levels for VAR-002-WECC-1, Requirement R1 lower the level of 

compliance from the levels of non-compliance associated with the currently-effective 

VAR-STD-002a-1. VAR-STD-002a-1 includes four levels of non-compliance (Level 1, 
Docket No. RM09-9-000 - 74 - 

Level 2, Level 3, and Level 4) which have been translated into the four violation severity 

levels (Lower, Moderate, High, and Severe). The four levels of non-compliance are 

defined by the automatic voltage regulator in service hours being: (Level 1) less than 

98 percent but at least 96 percent; (Level 2) less than 96 percent but at least 94 percent; 

(Level 3) less than 94 percent but at least 92 percent; and (Level 4) less than 92 percent. 

The violation severity levels assigned to Requirement R1 of VAR-002-WECC-1 are 

defined by the automatic voltage regulator in service hours being: (Lower) less than 

98 percent but at least 90 percent; (Moderate) less than 90 percent but at least 80 percent; 

(Higher) less than 80 percent but at least 70 percent; and (Severe) less than 70 percent. 

This change appears to violate violation severity level guideline 1. In addition, WECC 

has determined that High and Severe violation severity levels are not applicable to 

Requirement R2 of VAR-002-WECC-1. 

132. In VAR-501-WECC-1, the violation severity levels for Requirement R1 lower the 

level of compliance from the levels of non-compliance associated with the currentlyeffective VAR-STD-002a-1. VAR-STD-002b-1 includes four levels of non-compliance 

(Level 1, Level 2, Level 3, and Level 4) which have been translated into the four 

violation severity levels (Lower, Moderate, High, and Severe). The four levels of noncompliance are defined by the power system stabilizer in service hours being: (Level 1) 

less than 98 percent but at least 96 percent; (Level 2) less than 96 percent but at least 

94 percent; (Level 3) less than 94 percent but at least 92 percent; and (Level 4) less than 
Docket No. RM09-9-000 - 75 - 

 

92 percent. The proposed violation severity levels are defined by the power system

stabilizer in service hours being: (Lower) less than 98 percent but at least 90 percent; 

(Moderate) less than 90 percent but at least 80 percent; (Higher) less than 80 percent but 

at least 70 percent; and (Severe) less than 70 percent. This change appears to violate 

violation severity level guideline 1. For Requirement R2, only lower and moderate 

violation severity levels were defined. 

133. Consistent with our concerns outlined above, we direct WECC to consider 

modifications to the violation risk factors and violation severity levels assigned to these 

four regional Reliability Standards. Accordingly, we direct WECC to submit revisions to 

or explanations justifying these violation risk factors and violation severity levels within 

60 days from the issuance of this order. Consistent with NERC practice, these violation 

risk factors and violation severity levels should be in table format. Interested parties will 

have an opportunity to comment on this filing. In addition, the Commission supports 

WECC’s agreement to conform the violation severity levels format to that of the NERC 

Reliability Standards related to FAC-501-WECC-1, VAR-002-WECC-1 and VAR-501-

WECC-1 in future revisions to the regional Reliability Standards.60 Accordingly, we 

expect WECC to make future revisions to these and other violation risk factors and 

60 NERC Petition at 18, 35 and 40. 
Docket No. RM09-9-000 - 76 - 

violation severity level assignments consistent with any changes in NERC and 

Commission guidelines. 

III. Information Collection Statement

134. The information collection requirements in this Final Rule are identified under the 

Commission data collection FERC-725E, “Mandatory Reliability Standards for the 

Western Electricity Coordinating Council.” The information collection requirements are 

being submitted to the Office of Management and Budget (OMB) for review under 

section 3507(d) of the Paperwork Reduction Act of 1995.61 OMB’s regulations to 

approve certain information collection requirements imposed by agency rule.62

135. The four new regional Reliability Standards (FAC-501-WECC-1, PRC-004-

WECC-1, VAR-002-WECC-1, and VAR-501-WECC-1) replace existing regional 

Reliability Standards PRC-STD-001-1, PRC-STD-003-1, PRC-STD-005-1, VAR-STD002a-1, and VAR-STD-002b-1, which were approved by the Commission in its June 

2007 Order.63 In addition, the new regional Reliability Standards introduce five new 

regional definitions for the NERC Glossary: Functionally Equivalent Protection System, 

Functionally Equivalent Remedial Action Scheme, Security-Based Misoperations, 

 61 44 U.S.C. 3507(d). 

62 5 CFR 1320.11 

63 North American Electric Reliability Corp. 119 FERC ¶ 61,260. 
Docket No. RM09-9-000 - 77 - 

Dependability-Based Misoperations, and Commercial Operation. We find that the 

requirements of these revised regional Reliability Standards may result in minor changes 

in burden to applicable entities but, overall, these requirements will not substantially add 

to or increase burden to entities that must already comply with the existing regional 

Reliability Standards and the corresponding NERC Reliability Standards. 

136. There are, however, two differences with respect to the applicability of the new 

versus the existing regional Reliability Standards. First, existing regional Reliability 

Standard WECC PRC-STD-005-1 is applicable to transmission owners or operators that 

maintain transmission paths indicated in the WECC Transfer Path Table. By contrast, 

new Reliability Standard FAC-501-WECC-1 is applicable only to transmission owners 

that maintain transmission paths indicated in the WECC Transfer Path Table. Thus, 

transmission operators no longer must comply with these regional requirements. Second, 

existing regional Reliability Standard WECC VAR-STD-002a-1 is applicable only to 

generator operators of synchronous generators whereas new regional Reliability Standard 

VAR-002-WECC-1 is applicable to both generator operators and transmission operators 

of synchronous condensers. Thus, Reliability Standard VAR-002-WECC-1 creates a new 

burden for transmission operators of synchronous condensers, which we evaluate below. 

137. Public Reporting Burden: Our estimate below regarding the number of 

respondents is based on the WECC compliance registry as of December 2, 2010. 

According to WECC’s compliance registry, as of that date there are 52 transmission 
Docket No. RM09-9-000 - 78 - 

operators. As discussed above, new WECC Reliability Standard FAC-501-WECC-1 

removes as an applicable entity transmission operators that maintain transmission paths 

listed in the WECC Transfer Path Table. In addition, new Reliability Standard VAR002-WECC-1 adds as applicable entities a subset of transmission operators that operate 

synchronous condensers. Although these requirements apply to a subset of transmission 

operators, it is unclear which transmission operators should be included and so we base 

our burden estimate on the total number of transmission operators. Given these 

parameters, the Commission estimates the savings related with the removal of 

transmission operators from FAC-501-WECC-1 and the added public reporting burden 

for transmission operators that must comply with Reliability Standard VAR-002-WECC1 is as follows: 

FERC-725E 

Data 

Collection 

No. of 

Respondents 

(A) 

No. of 

Annual 

Responses 

(B) 

Hours Per 

Respondent 

(C) 

Total Annual 

Hours 

(A X B X C) 

Recordkeeping 

for 

transmission 

operators 

complying 

with PRCSTD-005-1 

52 1 10 (520) (savings) 

Reporting for 

transmission 

operators 

52 4 10 2,080 
Docket No. RM09-9-000 - 79 - 

complying 

with VAR002-WECC-1 

Recordkeeping 

for 

transmission 

operators 

complying 

with VAR002-WECC-1 

52 4 1 208 

Total Estimated Annual Hours for Collection: (Reporting/Compliance + recordkeeping) 

= 1,768 hours. 

Reporting/Compliance = 2,080 @ $120/hour = $249,600 

Recordkeeping = (312) hours @ $28/hour = ($8,736) (savings) 

Total Cost = $240,864 

Title: FERC-725E, Mandatory Reliability Standards for the Western Electricity 

Coordinating Council. 

Action: Proposed Revision to FERC-725E. 

OMB Control No.: 1902-0244 

Respondents: Businesses or other for-profit institutions; not-for-profit institutions. 

Frequency of Responses: On Occasion. 

Necessity of the Information: This Final Rule approves four regional Reliability 

Standards that pertain to facilities design, connections, and maintenance; protection and 

control; and voltage and reactive. This Final Rule also approves the addition of five new 

terms to the NERC Glossary of Terms. This Final Rule finds the Reliability Standards 
Docket No. RM09-9-000 - 80 - 

and related definitions just, reasonable, not unduly discriminatory or preferential, and in 

the public interest. 

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

contacting: Federal Energy Regulatory Commission, Attn: Ellen Brown, Office of the 

Executive Director, 888 First Street NE, Washington, DC 20426, Email: 

DataClearance@ferc.gov, Tel: (202) 502-8663, Fax: (202) 273-0873. Comments on the 

requirements of this Final 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 OMB Control Number 1902-0244, RIN 1902-AE17, and the docket 

number of this Final Rule in your submission. 

IV. Environmental Analysis

139. 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.64 The Commission has categorically excluded certain 

actions from this requirement as not having a significant effect on the human 

 64 Order No. 486, Regulations Implementing the National Environmental Policy 

Act, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs., Regulations Preambles 1986-

1990 ¶ 30,783 (1987). 
Docket No. RM09-9-000 - 81 - 

l exclusion 

l, for 

environment. The actions directed in this Final Rule fall within the categorica

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

information gathering, analysis, and dissemination. 65 Accordingly, neither an 

environmental impact statement nor an environmental assessment is required. 

V. Regulatory Flexibility Act

140. The Regulatory Flexibility Act of 1980 (RFA)66 generally requires a description 

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

number of small entities. The requirements of the Reliability Standards approved in this 

Final Rule would apply primarily to transmission owners of major transmission paths and 

remedial action schemes within the Western Interconnection, generator owners of major 

remedial action schemes within the Western Interconnection, transmission operators that 

operate major transmission paths or remedial action schemes in the Western 

Interconnection, and generator and transmission operators that operate synchronous 

generators and condensers within the Western Interconnection that are connected to the 

bulk electric system. Many of these entities do not fall within the definition of small 

entities but some transmission owners, generator owners, transmission operators and 

 65 18 CFR 380.4(a)(5). 

66 5 U.S.C. 601-612. 
Docket No. RM09-9-000 - 82 - 

 

generator operators would be deemed small entities.67 The new regional Reliability 

Standards reflect a continuation of existing requirements currently applicable to these 

entities. 

141. There are only two modifications to the applicable entities for this group of 

regional Reliability Standards. Proposed FAC-501-WECC-1 no longer applies to 

transmission operators. Proposed VAR-002-WECC-1 has added applicability to 

transmission operators, but only the subset that operate synchronous condensers that are 

connected to the bulk electric system. 

142. Based on available information regarding NERC’s compliance registry, and our 

best assessment of the application of the proposed regional Reliability Standards, 

approximately 275 unique entities will be responsible for compliance with the proposed 

regional Reliability Standards, of which 52 are transmission operators. Of the 

52 transmission operators, only a subset that operate synchronous condensers connected 

to the bulk electric system will be subject to the proposed VAR-002-WECC-1, i.e., 

required to have automatic voltage regulators in service and in automatic voltage control 

mode 98 percent of operating hours on synchronous condensers, and document the hours 

67 The RFA definition of “small entity” refers to the definition provided in the 

Small Business Act (SBA), which defines a “small business concern” as a business that is 

independently owned and operated and that is not dominant in its field of operation. See

15 U.S.C. 632. According to the SBA, a small electric utility is defined as one that has a 

total electric output of less than four million MWh in the preceding year. 
Docket No. RM09-9-000 - 83 - 

that are excluded from automatic voltage regulator operation. The Commission estimates 

that this requirement will impose a cost of $4,912 on transmission operators that operate 

synchronous condensers connected to the bulk electric system. We believe that this 

figure should not represent a significant portion of operating costs. 

143. Based on the foregoing, the Commission certifies that this Final Rule will not have 

a significant impact on a substantial number of small entities. Accordingly, no regulatory 

flexibility analysis is required. 

VI. Document Availability

144. 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. 

145. 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. 
Docket No. RM09-9-000 - 84 - 

146. 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 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. 

VII. Effective Date and Congressional Notification

147. This Final Rule shall become effective [insert date 60 days from 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. 

148. The effective date of the Final Rule is separate from the implementation date of 

the Reliability Standards approved herein. According to a schedule developed by 

WECC, FAC-501-WECC-1, VAR-002-WECC-1 and VAR-501-WECC-1 shall become 

effective as of the first day of the first quarter after Commission approval. In addition, 

PRC-004-WECC-1 shall become effective as of the first day of the second quarter after 

approval by the Commission. 

Thus, if the Final Rule is published in the Federal Register on or before May 2, 2011, the 

Final Rule would become effective in 60 days, FAC-501-WECC-1, VAR-002-WECC-1 

and VAR-501-WECC-1 would be implemented beginning July 1, 2011, and PRC -004-
Docket No. RM09-9-000 - 85 - 

WECC-1 would be implemented beginning October 1, 2011. If, however, the Final Rule 

is published in the Federal Register after May 2, 2011, the Final Rule would become 

effective in 60 days, FAC-501-WECC-1, VAR-002-WECC-1 and VAR-501-WECC-1 

would be implemented beginning October 1, 2011, and PRC-004-WECC-1 would be 

implemented beginning January 1, 2012. 

List of subjects in 18 CFR Part 40

Electric power, Electric utilities, Reporting and recordkeeping requirements 

By the Commission. 

( S E A L ) 

Nathaniel J. Davis, Sr., 

Deputy Secretary. 

 
Appendix A

List of Commenters

Name Abbreviation

Bonneville Power Administration Bonneville 

U.S. Bureau of Reclamation Bureau of Reclamation 

California Department of Water Resources State 

Water Project 

CDWR 

Electric Power Supply Association EPSA 

Mariner Consulting Services, Inc. Mariner 

Melissa Kurtz 

North American Electric Reliability Corp. NERC 

PacifiCorp PacifiCorp 

San Diego Gas & Electric Co. SDG&E 

Transmission Agency of Northern California TANC 

U.S. Army Corps of Engineers NNW USACE NNW 

U.S. Army Corps of Engineers Portland USACE Portland 

U.S. Army Corps of Engineers Seattle USACE Seattle 

Western Electricity Coordinating Council WECC