134 FERC ¶ 61,215 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

[Docket No. RM10-16-000; Order No. 749] 

System Restoration Reliability Standards 

(Issued March 17, 2011) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Final Rule. 

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

three Emergency Operations and Preparedness (EOP) Reliability Standards, EOP-001-1 

(Emergency Operations Planning), EOP-005-2 (System Restoration from Blackstart 

Resources), and EOP-006-2 (System Restoration Coordination) as well as the definition 

of the term “Blackstart Resource” submitted to the Commission for approval by the 

North American Electric Reliability Corporation (NERC), the Electric Reliability 

Organization certified by the Commission. The approved Reliability Standards require 

transmission operators, generation operators, and certain transmission owners and 

distribution providers to ensure that plans, facilities and personnel are prepared to enable 

system restoration from Blackstart Resources and require reliability coordinators to 

establish plans and prepare personnel to enable effective coordination of the system 

restoration process. The Commission also approves the NERC’s proposal to retire four 
Docket No. RM-10-16-000 - 2 - 

existing EOP Reliability Standards and a definition that are replaced by the Standards and 

definition approved in this Final Rule. 

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

FEDERAL REGISTER]. 

FOR FURTHER INFORMATION CONTACT: 

Terence Burke (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6498 

David O’Connor (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6695 

SUPPLEMENTARY INFORMATION: 
134 FERC ¶ 61,215 

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. 

System Restoration Reliability Standards Docket No. RM10-16-000 

ORDER NO. 749 

FINAL RULE 

(Issued March 17, 2011) 

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

 the Commission approves 

three Emergency Operations and Preparedness (EOP) Reliability Standards, EOP-001-1 

(Emergency Operations Planning), EOP-005-2 (System Restoration from Blackstart 

Resources), and EOP-006-2 (System Restoration Coordination) as well as the definition 

of the term “Blackstart Resource” submitted to the Commission for approval by the 

North American Electric Reliability Corporation (NERC), the Electric Reliability 

Organization (ERO) certified by the Commission. The approved Reliability Standards 

require transmission operators, generation operators, and certain transmission owners and 

distribution providers to ensure that plans, facilities, and personnel are prepared to enable 

system restoration from Blackstart Resources and require reliability coordinators to 

establish plans and prepare personnel to enable effective coordination of the system 

 1

 16 U.S.C. 824o. 
Docket No. RM10-16-000 - 2 - 

restoration process. The Commission also approves NERC’s proposal to retire four 

existing EOP Reliability Standards and the defined term “Blackstart Capability Plan” 

concurrent with the effectiveness of the Standards and the term Blackstart Resource 

approved in this Final Rule. In those jurisdictions where regulatory approval is required, 

Reliability Standard EOP-001-1 will not become effective until the first day of the first 

calendar quarter three months after regulatory approval is obtained, and EOP-005-2 and 

EOP-006-2 approved in this Final Rule will not become effective until 24 months after 

the first day of the first quarter after applicable regulatory approval. 

2. “Blackstart” capability refers to the ability of a generating unit or station to start 

operating and delivering electric power without assistance from the electric system. 

Blackstart units are essential to restart generation and restore power to the grid in the 

event of an outage. As discussed below, NERC proposes to define “Blackstart Resource” 

as “a generating unit(s) and its associated set of equipment which has the ability to be 

started without support from the System or is designed to remain energized without 

connection to the remainder of the System, with the ability to energize a bus....” 

3. In Order No. 693, the Commission determined that it would not take action on 

certain proposed Reliability Standards that required supplemental information from a 

Regional Entity. Such Reliability Standards refer to regional criteria or procedures that 

had not been submitted to the Commission for approval and, as such, are referred to as 
Docket No. RM10-16-000 - 3 - 

“fill-in-the-blank” standards.2

 Pending Reliability Standard EOP-007-0 is one such 

fill-in-the-blank standard. The Reliability Standards approved herein provide a 

standardized, national approach to address the Commission’s concerns regarding pending 

EOP-007-0, as set forth in Order No. 693. Thus, in addition to the retirement of certain 

currently effective EOP Reliability Standards, we also approve the withdrawal of pending 

Reliability Standard EOP-007-0. 

I. Background

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

the 107 Reliability Standards filed by NERC,3

 including the Reliability Standards: 

EOP-001-0, EOP-005-1, EOP-006-1, and EOP-009-0.4

 The Commission neither 

approved nor remanded EOP-007-0 because it applied only to regional reliability 

organizations, but Order No. 693 did provide guidance for the ERO’s further 

consideration of the Reliability Standard.5

 In addition, under section 215(d)(5) of the 

FPA, the Commission directed NERC to develop modifications to the EOP Reliability 

Standards to address certain issues identified by the Commission. At issue in the 

immediate proceeding are two new EOP standards, EOP-005-2 and EOP-006-2 that 

 2

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

72 FR 16416 (Apr. 4, 2007), FERC Stats. & Regs. ¶ 31,242, at P 297, order on reh’g, 

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

3

 Id. P 304-1899. 

4

 Id. P 542-676. 

5

 Id. P 644. 
Docket No. RM10-16-000 - 4 - 

would replace the currently effective Reliability Standards EOP-005-1, EOP-006-1, 

and EOP-009-0, pending Standard EOP-007-0, and necessitate a conforming change in 

EOP-001-0. 

A. Currently Effective EOP Reliability Standards

Reliability Standard EOP-005-1

5. Currently effective Reliability Standard EOP-005-1 requires transmission 

operators, balancing authorities, and reliability coordinators to have a restoration plan, 

test the plan, train operating personnel in the restoration plan, and have the ability to 

restore the Interconnection using the plans following a blackout. In Order No. 693, the 

Commission directed the ERO to develop, through the Reliability Standard development 

process, a modification to EOP-005-1 that identifies time frames for training and review 

of restoration plan requirements to simulate contingencies and prepare operators for 

anticipated and unforeseen events.6

 The Commission also directed the ERO to consider 

various commenters’ suggestions in future revisions of the Reliability Standard.7

Reliability Standard EOP-006-1

6. In Order No. 693, the Commission also approved Reliability Standard EOP-006-1 

addressing reliability coordination and system restoration. The Reliability Standard sets 

requirements for reliability coordinators during system restoration and requires that they 

have a coordinating role to ensure reliability is maintained during system restoration. 

 6

 Id. P 630. 

7

 Id. P 628. 
Docket No. RM10-16-000 - 5 - 

Under section 215 of the FPA, the Commission directed the ERO to develop a 

modification to EOP-006-1 to ensure that the reliability coordinator is involved in the 

development and approval of system restoration plans.8

Pending Reliability Standard EOP-007-0

7. Pending Reliability Standard EOP-007-0 deals with establishing, maintaining and 

documenting regional blackstart capability plans. In Order No. 693, the Commission did 

not act on EOP-007-0 pending NERC’s providing additional information.9

 The 

Commission, however, directed the ERO to consider various commenters’ suggestions 

relating to assigning compliance obligations directly to the entities that provide the 

pertinent data rather than to the Regional Entity, placing responsibility for the regional 

blackstart plan with the reliability coordinator, recognizing that nuclear units have no 

blackstart capability, revising the definition of a blackstart unit, and committing 

arrangements for coordinating blackstart capability to contracts.10

Reliability Standard EOP-009-0

8. Currently effective Reliability Standard EOP-009-0 deals with implementing and 

documenting testing of blackstart generating units. In Order No. 693, the Commission 

directed the ERO to consider suggestions for improvements raised during the comment 

period. One commenter stated the Reliability Standard should provide details on what 

 8

 Id. P 638. 

9

 Id. P 297, 644. 

10 Id. P 642–643, 647. 
Docket No. RM10-16-000 - 6 - 

constitutes a blackstart test and another stated that NERC should consolidate the 

Reliability Standard with EOP-007-0.11

B. NERC Petition

9. In a December 31, 2009 filing (NERC Petition),12 NERC requests Commission 

approval of its proposed definition of the term “Blackstart Resource” and proposed 

Reliability Standards EOP-001-1 (Emergency Operating Planning),13 EOP-005-2 

(System Restoration from Blackstart Resources), and EOP-006-2 (System Res

Coordination). NERC also seeks to concurrently retire four currently effective Reliability 

Standards: EOP-001-0, EOP-005-1, EOP-006-1, and EOP-009-0 as well as the definition 

of “Blackstart Capability Plan” and withdraw pending Reliability Standard EOP-007-0. 

toration 

 11 Id. P 674, 676. 

12 North American Electric Reliability Corp., Dec. 31, 2009 Petition for Approval 

of Three Emergency Preparedness and Operations Reliability Standards and One New 

Glossary Term and for Retirement of Five Existing Reliability Standards and One 

Glossary Term. The three Reliability standards are included as Exhibit A to NERC’s 

Petition. In addition, under18 CFR 40.3 of the Commission’s regulations, all 

Commission-approved Reliability Standards are available on NERC’s website at 

http://www.nerc.com/page.php?cid=2|20. See 18 CFR 40.3. 

13 Concurrent with its filing in this Docket, NERC filed a petition in Docket 

No. RM10-15-000 seeking approval of certain Interconnection Reliability Operations 

and Coordination (IRO) Reliability Standards. As part of its IRO filing, NERC proposed 

to retire Requirement R2 of EOP-001-0. Each petition proposes unique changes to 

EOP-001-0 reflecting the distinct issues addressed by the respective Reliability Standards 

drafting teams. In this Final Rule, the Commission is addressing Version 2 of EOP-001 

contained in Exhibit B of the NERC Petition which reflects both the IRO and the EOP 

proposed changes. 
Docket No. RM10-16-000 - 7 - 

10. NERC states that the proposed Reliability Standards “represent significant 

revision and improvement from the current set of enforceable standards” and address the 

Commission’s directives in Order No. 693 related to the EOP standards.14 NERC 

explains that, among other enhancements, “[t]he proposed revisions now clearly delineate 

the responsibilities of the Reliability Coordinator and Transmission Operator in the 

restoration process and restoration planning.”15 NERC describes the proposed Reliability 

Standards as providing “specific requirements for what must be in a restoration plan, how 

and when it needs to be updated and approved, what needs to be provided to operators 

and what training is necessary for personnel involved in restoration processes.”16 

Proposed Definition of Blackstart Resource

11. NERC requests approval of the term “Blackstart Resource” and the concurrent 

retirement of the term “Blackstart Capability Plan.” The proposed definition of 

“Blackstart Resource” is: 

A generating unit(s) and its associated set of equipment which has the 

ability to be started without support from the System or is designed to 

remain energized without connection to the remainder of the System, with 

the ability to energize a bus, meeting the Transmission Operator’s 

restoration plan needs for real and reactive power capability, frequency and 

 14 NERC Petition at 4. 

15 Id. at 5. 

16 Id.
Docket No. RM10-16-000 - 8 - 

voltage control, and that has been included in the Transmission Operator’s 

restoration plan. 

The term “Blackstart Capacity Plan” is currently used solely in EOP-007-0 and 

EOP-009-0, both of which are replaced with proposed Reliability Standards EOP-005-2 

and EOP-006-2. 

Proposed Reliability Standard EOP-001-1

12. Proposed Reliability Standard EOP-001-1 contains seven requirements for the 

stated purpose of requiring each transmission operator and balancing authority to 

develop, maintain, and implement a set of plans to mitigate operating emergencies and to 

coordinate these plans with other transmission operators, balancing authorities, and the 

reliability coordinator.17 It modifies EOP-001-0 by deleting Requirement R3.4, which 

requires transmission operators and balancing authorities to develop, maintain and 

implement restoration plans, because proposed Reliability Standards EOP-005-2 and 

EOP-006-2 incorporate and expand upon this Requirement. 

Proposed Reliability Standard EOP-005-2

13. Proposed Reliability Standard EOP-005-2 contains eighteen requirements for the 

stated purpose of ensuring that plans, facilities, and personnel are prepared to enable 

system restoration from Blackstart Resources, and to ensure reliability is maintained 

during restoration and priority is placed on restoring the Interconnection.18 The proposed 

 17 Reliability Standard EOP-001-1, Section A.3. (Purpose). 

18 Reliability Standard EOP-005-2, Section A.4. (Purpose). 
Docket No. RM10-16-000 - 9 - 

Reliability Standard applies to transmission operators, generation operators, and 

transmission owners and distribution providers identified in the transmission operator’s 

restoration plan. Requirement R1 requires each transmission operator to have a 

reliability coordinator-approved restoration plan utilizing Blackstart Resources and 

details the scope and elements of such a plan. Requirement R2 instructs each 

transmission operator to provide entities that have a role in the restoration plan with a 

description of their roles and tasks. Requirements R3 through R6 address annual plan 

reviews, updating practices, location of plans and plan verification. Following a 

disturbance, Requirements R7 and R8 provide guidance on following the plan or making 

needed adjustments and coordinating when re-synchronizing two systems together. 

Requirement R9 describes testing information the transmission operator must have to 

verify the Blackstart Resources meet required expectations. Requirements R10 through 

R12 cover system restoration training requirements for system operators and field 

switching personnel. Blackstart Resource agreements between the transmission operator 

and generator operator, or mutually agreed upon procedures or protocols are addressed in 

Requirement R13. Duties of a generator owner with a Blackstart Resource are provided 

in Requirements R14 through R18, which address operating procedures, change 

notification, testing for each Blackstart Resource and training of operating personnel on 

Blackstart Resources. Proposed Reliability Standard EOP-005-2 is intended to supersede 

all of currently effective Reliability Standard EOP-005-1. 
Docket No. RM10-16-000 - 10 - 

Proposed Reliability Standard EOP-006-2

14. Proposed Reliability Standard EOP-006-2 contains ten requirements with the 

stated purpose of ensuring that the reliability coordinator establishes plans and prepares 

personnel to enable effective coordination of the system restoration process, to maintain 

reliability during restoration, and to place priority on restoring the Interconnection.19 

Requirement R1 requires reliability coordinators to have restoration plans that utilize 

Blackstart Resources and specifies the scope and elements of such plans. Requirement 

R2 covers distribution of the reliability coordinator’s restoration plan. Requirements R3 

through R5 provide for review of the reliability coordinator’s restoration plan and the 

plans of each neighboring reliability coordinator and each transmission operator located 

in the reliability coordinator’s area. Any conflicts between neighboring reliability 

coordinators’ plans are to be resolved within thirty days, and transmission operators’ 

plans shall be approved or disapproved, with stated reasons, within thirty days of receipt 

by the reliability coordinator. Requirement R6 requires that the reliability coordinator 

must maintain copies of restoration plans in its primary and backup control rooms. 

Requirements R7 and R8 describe the roles of reliability coordinators to coordinate 

restoration efforts and authorize re-synchronization of “island” areas. Requirements R9 

and R10 address training and participation in annual drills, exercises and simulations. 

Proposed Reliability Standard EOP-006-2 is intended to supersede all of currently 

effective Reliability Standard EOP-006-1. 

 19 Reliability Standard EOP-006-2, Section A.3. (Purpose). 
Docket No. RM10-16-000 - 11 - 

C. Notice of Proposed Rulemaking

15. On November 17, 2010, the Commission issued its Notice of Proposed 

Rulemaking (NOPR) proposing to approve the three proposed EOP Reliability Standards, 

EOP-001-1, EOP-005-2, and EOP-006-2 and defined term Blackstart Resource (and the 

retirement of the four superseded standards, EOP-001-0, EOP-005-1, EOP-006-1, and 

EOP-009-0, the definition of “Blackstart Capability Plan,” and the ERO’s withdrawal of 

EOP-007-0).20 With respect to proposed Reliability Standard EOP-005-2, the NOPR 

proposed to direct NERC to modify the Standard to address the Commission’s concern 

regarding the periodic testing of telecommunication facilities needed to implement 

restoration plans. In addition, the Commission sought comment on: (i) what is 

intended by the term “unique tasks” as used in the context of proposed Requirement R11 

of EOP-005-2; (ii) whether guidance should be provided regarding the term, and if so, 

how it should be provided; and (iii) whether those tasks should be indentified in each 

transmission operator’s restoration plan. With respect to proposed Reliability Standard 

EOP-006-2, the NOPR sought comment as to why the Standard does not require 

reliability coordinators to maintain a database of Blackstart Resources as is required of 

Regional Entities under currently effective EOP-007-0 and whether such a requirement 

would be beneficial. The NOPR also sought comment on: (i) whether reliability 

coordinators should be required to verify their restoration planning through actual events, 

 20 System Restoration Reliability Standards, Notice of Proposed Rulemaking, 

75 FR 71625 (Nov. 24, 2010), FERC Stats. & Regs. ¶ 32,666 (2010). 
Docket No. RM10-16-000 - 12 - 

steady state and dynamic simulations or testing; and (ii) how a transmission operator 

should proceed when its restoration plan is rejected by a reliability coordinator. Lastly, 

the NOPR proposed that the ERO collect data on the performance of system restoration 

exercises conducted by transmission operators and reliability coordinators to assist the 

ERO and Commission in identifying the effectiveness of restoration plans, establishing 

best practices, and determining the affects on personnel performance. 

16. In response to the NOPR, comments were filed by nine interested parties.21 These 

comments assisted us in the evaluation of the NERC’s proposal. In the discussion below, 

we address the issues raised by these comments.

II. Discussion

A. Approval of Proposed Reliability Standards

17. In the NOPR, the Commission proposed to approve the three EOP Reliability 

Standards and the glossary term filed by NERC in this proceeding. None of the nine 

interested parties filing comments to the NOPR objects to such an approval. For the 

reasons described below, the Commission adopts the NOPR proposal and approves 

Reliability Standards EOP-001-1, EOP-005-2, and EOP-006-2 as well as the proposed 

glossary term “Blackstart Resource” as just, reasonable, not unduly discriminatory or 

 21 NERC, The Edison Electric Institute (EEI), American Public Power 

Association (APPA), the ISO/RTO Council (IRC), Pacificorp, City of Santa Clara, 

California (Santa Clara), Bonneville Power Administration (BPA), and NorthWestern 

Corporation (NorthWestern) filed comments. Wisconsin Electric Power Company filed 

supporting EEI’s comments. 
Docket No. RM10-16-000 - 13 - 

preferential, and in the public interest.22 EOP-005-2 and EOP-006-2 clarify the 

responsibilities of the reliability coordinator and transmission operator in the restoration 

process and restoration planning and address the Commission’s directives in Order 

No. 693 related to the EOP Standards. By enhancing the rigor of the restoration planning 

process, the Reliability Standards represent an improvement from the current Standards 

and will improve the reliability of the Bulk-Power System. The Commission is not 

directing any modifications to the three new Reliability Standards. Nevertheless, as 

discussed below, commenters raised several issues for consideration, at the time these 

standards are next revisited, which we believe could improve these new Reliability 

Standards. The Commission also approves NERC retiring the four currently effective 

Reliability Standards, EOP-001-0, EOP-005-1, EOP-006-1, and EOP-009-0 as well as the 

definition of “Blackstart Capability Plan” and withdrawing pending Reliability 

Standard EOP-007-0 concurrent with the effectiveness of the EOP-001-1, EOP-005-2, 

and EOP-006-2 and the definition of the term “Blackstart Resource.” 

B. Vagueness of Term “Unique Tasks”

18. Requirement R11 of EOP-005-2 requires that a minimum of two hours of system 

restoration training be provided every two years to field switching personnel performing 

“unique tasks” associated with the transmission operator’s restoration plan. In the 

NOPR, the Commission expressed concern that the applicable entities may not 

understand what the term “unique tasks” means. We requested comment on what is 

 22 16 U.S.C. 824o(d)(2). 
Docket No. RM10-16-000 - 14 - 

intended by that term and on whether guidance should be provided to the transmission 

operators, transmission owners, and distribution providers who are responsible for 

providing training. In addition, the NOPR sought comment as to whether the unique 

tasks should be identified in each transmission operator’s restoration plan. 

Comment

19. NERC comments that the term “unique tasks” is not intended to have any meaning 

beyond the dictionary definition of the words. Everyday tasks of field switching 

personnel are not considered unique, but tasks not included in the person’s normal duties 

(e.g., operation of a synchroscope) would be considered unique. NERC and APPA do 

not perceive a reliability benefit in requiring identification of unique tasks in restoration 

plans. NERC acknowledges that it could promote the development of guidance to aid 

entities in complying with Requirement R11. 

20. EEI comments that while it would be difficult to define “unique tasks” in a manner 

that could be broadly applied to affected entities, the standards drafting team believed 

that the term was clearly understood as a practical matter. Companies should be afforded 

discretion to determine how the term is defined within their restoration plans, but, to the 

extent that compliance issues arise, EEI would encourage NERC to consider developing 

compliance guidance as needed. IRC also believes the term is generally understood by 

the applicable entities and that it is appropriate for each transmission operator’s 

restoration plan to identify the particular tasks for which training is required. 
Docket No. RM10-16-000 - 15 - 

21. APPA states that the diversity of entities and their specific approaches to system 

restoration prevented the standard drafting team from developing guidance on the term 

but agrees that registered entities could benefit from a best practices document that 

provides examples of unique tasks. 

22. Santa Clara comments that a one-size-fits-all definition would not be helpful, and 

the affected entities should define unique tasks on a case-by-case basis. It agrees that 

unique tasks should be included within the transmission operator’s restoration plan. 

Pacificorp comments that training should be provided to field switching personnel 

performing any restoration tasks associated with implementing the transmission 

operator’s restoration plan. Addressing each sub-Requirement of Requirement R1 would 

provide an appropriate framework for a system restoration training program. Pacificorp 

and NorthWestern oppose additional guidance or requirements in the Standard. BPA, on 

the other hand, is unsure what is intended by the term “unique tasks” and supports a 

specific definition to avoid any ambiguity. 

Commission Determination

23. Based on NERC’s comment that the term “unique tasks” is to be understood in 

accordance with the normal meaning of the words and the majority of the commenters’ 

assertions that the variety of approaches to system restoration precludes greater 

specificity, we find that the term conveys as much precision as circumstances allow. To 

the extent that it would be helpful to the affected entities to specify in a transmission 
Docket No. RM10-16-000 - 16 - 

operator’s restoration plan which tasks are deemed unique, the entities are encouraged to 

do so, but the Commission does not require such specificity at this time. 

24. Both EEI and APPA recognize potential benefit in the development of further 

guidance as to the term “unique tasks,” and BPA is uncertain as to the meaning of the 

term and consequently unsure as to how to demonstrate compliance with its training 

obligation. NERC, in its comments about the term, states that it “could promote the 

development of a guideline to aid registered entities in complying with Requirement 

R11.”23 The Commission notes that this Reliability Standard will not become effective 

for at least 24 months, during which time ambiguities in language or differences of 

opinion among affected entities may be resolved in practical ways. Once the Standard is 

effective, if industry determines that ambiguity with the term arises, it would be 

appropriate for NERC to consider its proposal to develop a guideline to aid entities in 

their compliance obligations. 

C. Telecommunication Facility Testing

25. Requirement R5 of Reliability Standard EOP-005-1 provides for periodic testing 

of telecommunication facilities needed to implement restoration plans, but this 

Requirement has no counterpart in EOP-005-2. In the NOPR, the Commission proposed 

requiring the ERO to develop a modification to EOP-005-2 to address the Commission’s 

concern that entities involved in system restoration ensure restoration-specific 

telecommunications equipment, phone lists, and protocols are tested as part of ongoing 

 23 NERC at 4–5. 
Docket No. RM10-16-000 - 17 - 

restoration preparedness. The Commission further stated its concern that, in light of the 

importance of communication to the restoration process, testing should be done more 

frequently than during annual drills, exercises or simulations as is required under 

Reliability Standard EOP-005-1. 

Comments

26. Each of the commenters opposes adding a telecommunications requirement to 

EOP-005-2 on the basis that such a requirement would be redundant given 

Communications Reliability Standard COM-001-1.1, which requires testing of routine 

communication facilities on an on-going basis. Several comments noted that duplicative 

requirements can lead to potential confusion. 

Commission Determination

27. Reliability Standard COM-001-1 does not apply to generation operators or 

distribution providers.24 Further, we do not accept that each entity whose 

telecommunications facilities will be needed during the system restoration process is 

currently subject to COM-001-1.1 Requirement R2 which provides that “[e]ach 

Reliability Coordinator, Transmission Operator and Balancing Authority shall manage, 

alarm, test and/or actively monitor vital telecommunications facilities. Special attention 

shall be given to emergency telecommunications facilities and equipment not used for 

routine communications.” 

 24 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 478-493. 
Docket No. RM10-16-000 - 18 - 

28. NERC notes in its comments that the Reliability Coordination Standard Drafting 

Team is currently working on Project 2006-06 to develop a set of revisions to Reliability 

Standard COM-001-1.1 to tighten requirements relating to communication capabilities. 

The Commission believes the objectives of this project in managing, alarming, testing 

and/or actively monitoring vital primary and emergency telecommunication facilities will 

close this gap in the Reliability Standard after it is completed and approved. 

Accordingly, consistent with NERC’s comments on its current project and concerns not 

to create redundancy in development of Reliability Standards, NERC should close the 

gap in the applicability of the draft COM-001-2 so it addresses generation operators and 

distribution providers. 

D. Emergency Operations Planning

29. Reliability Standard EOP-005-2 requires each transmission operator to identify 

each blackstart resource and its characteristics, but this requirement has no counterpart 

for reliability coordinators in EOP-006-2. The Commission expressed concern and 

invited comment in the NOPR on whether the absence of a required list of its Blackstart 

Resources could deny the reliability coordinator a potentially useful tool in maintaining 

reliability. 

Comments

30. NERC notes that the transmission operator, not the reliability coordinator, 

maintains direct contact with the blackstart resources, and reliability coordinators have 

sufficient authority to request information needed to identify blackstart resources should 
Docket No. RM10-16-000 - 19 - 

such information be required. NERC, EEI, IRC, and APPA do not believe a requirement 

to maintain a database of blackstart resources would improve reliability. Santa Clara, 

however, requests that the Commission direct NERC to revise Requirement R2 of 

Reliability Standard EOP-005-2 to specify that transmission operators provide copies of 

their restoration plans to those entities included in the plan within 60 days of the plan’s 

approval by the appropriate reliability coordinator to ensure that resources identified in 

the plan are capable of complying with the plan. 

Commission Determination

31. Since a reliability coordinator obtains copies of all its constituent transmission 

operators’ restoration plans and has the ability to obtain information regarding the 

identity and characteristics of blackstart resources from its transmission operators, we 

agree there is no reliability need for it to maintain a duplicative database. With regard to 

Santa Clara’s request, we believe that the determination whether resources in a 

restoration plan are capable of complying with the plan is made during the transmission 

operator’s development of its plan as required by Requirement R1, not once the plan is 

approved by the reliability coordinator. For this reason, we do not see a need to direct the 

modification to Requirement R2 that Santa Clara requests. 

E. System Restoration Coordination

32. Reliability Standard EOP-005-2 requires each transmission operator to verify that 

its restoration plan achieves its intended function. There is no similar requirement in 

EOP-006-2 regarding the reliability coordinator’s restoration plan. The Commission 
Docket No. RM10-16-000 - 20 - 

sought comment on whether the same or a similar requirement should apply to reliability 

coordinators. In addition, the Standard also requires reliability coordinators to approve, 

or disapprove with written reasons, the restoration plans of each of their constituent 

transmission operators. The Commission invited comment as to how a transmission 

operator should proceed when its restoration plan is rejected by a reliability coordinator. 

Comments

33. NERC, EEI, and IRC comment that a reliability coordinator’s restoration plan is 

essentially a compilation of the restoration plans of its constituent transmission operators. 

Given that EOP-005-2 requires transmission operators to verify their restoration plans 

and that EOP-006-2 requires reliability coordinators to conduct system restoration drills 

with their constituent transmission operators and generation owners, requiring further 

verification of the same plans by the reliability coordinator would be duplicative and not 

provide additional reliability benefit. 

34. With respect to how a transmission operator should proceed when its reliability 

coordinator rejects its restoration plan, NERC states that when a restoration plan is 

rejected by a reliability coordinator, the reliability coordinator is required to supply one 

or more reasons for its rejection, and the transmission operator should then be able to 

re-submit a revised plan. NERC does not believe it is necessary to document this process 

in additional requirements since the dialogue between the two entities is no different than 

the routine coordination that normally occurs between the transmission operator and its 
Docket No. RM10-16-000 - 21 - 

reliability coordinator. EEI, APPA, and IRC agree that there is no need for additional 

procedures to be spelled out. 

35. IRC, BPA, and Santa Clara all comment that the reliability coordinator should be 

the final authority to resolve conflicts. Santa Clara nevertheless states that if the 

transmission operator and reliability coordinator cannot resolve their differences because 

the transmission operator believes compliance with the reliability coordinator’s decision 

is infeasible, the transmission operator should be allowed to appeal either to the Regional 

Entity or, in the case of the Western Interconnect, the dispute should be brought to 

NERC. 

36. EEI observes that the two-year implementation period for these Standards will 

likely provide sufficient time to resolve any differences in order for a reliability 

coordinator to approve a transmission operator’s initial restoration plan. Any subsequent 

rejection of a revised restoration plan will not result in a reliability gap since the initial 

plan will remain in place. EEI further notes that any rejection of a restoration plan by a 

reliability coordinator will necessarily be based on generic reliability engineering criteria 

readily understood by the transmission operator. Pacificorp, on the other hand, notes that 

the requirement that the reliability coordinator give stated reasons for any disapproval of 

a submitted restoration plan does not ensure the reasons will specify the circumstances 

under which a transmission operator should revise its plan. Pacificorp states that a 

reliability coordinator must have formal criteria for reviewing, approving and 

disapproving restoration plans and standard procedures for those plans to be revised and 
Docket No. RM10-16-000 - 22 - 

resubmitted for review. Pacificorp also suggest a modification to Requirement R5 to 

provide that a transmission operator’s submitted restoration plan shall be deemed 

approved if the reliability coordinator fails to approve or disapprove the plan within the 

required 30 days. 

Commission Determination

37. We accept the commenters’ position that requiring verification of the reliability 

coordinators’ restoration plan through a requirement in EOP-006-2 would be largely 

duplicative. As commenters point out, Reliability Standard EOP-006-2 requires 

reliability coordinators to conduct system restoration drills including their constituent 

transmission operators and generation owners. Such drills, exercises or simulations, 

together with the verifications carried out by the transmission operators of their 

restoration plans and approval of their plans by the reliability coordinators under 

EOP-005-2, serve as verification of the reliability coordinators’ plans and as such,should 

serve to identify difficulties in a reliability coordinator’s restoration plan. 

38. We agree with EEI that the basis on which a reliability coordinator rejects a 

restoration plan will necessarily be based on generic engineering criteria easily 

understood by the transmission operator. We also agree with those commenters who 

reaffirm that the ultimate arbiter of coordination and compatibility of transmission 

operators’ restoration plans is the reliability coordinator. For these reasons, we do not see 

a need to direct modifications as Pacificorp and Santa Clara suggest that could 

circumvent the reliability coordinator’s authority concerning the approval or disapproval 
Docket No. RM10-16-000 - 23 - 

of a restoration plan. However, we agree with Pacificorp that Reliability Standard 

EOP-006-2, which establishes requirements to enable coordinated system restoration and 

ensure reliability is maintained during system restoration, is not the appropriate place to 

include any specific criteria or procedures for the review and revision of transmission 

operators’ restoration plans. We recognize that documenting such criteria and procedures 

may have utility in facilitating the settlement of disagreements when a reliability 

coordinator rejects a transmission operator’s restoration plan. Nonetheless, we leave it to 

the ERO Reliability Standard development process to determine whether the merit is 

sufficient to compel the development of such criteria or procedures. 

F. Data Reporting 

39. Given the importance of effective blackstart and restoration plans and well-trained 

personnel, the NOPR proposed that the ERO collect data on the performance of system 

restoration exercises and make such data available to transmission operators, reliability 

coordinators and the Commission. This data could then be used to identify the 

effectiveness of restoration plans and help identify improvements to enhance restoration. 

The Commission sought comment on the proposed data collection. 

Comments

40. NERC notes that formal debriefings are held after each required drill and is 

unclear whether there would be any additional reliability benefit arising from the data 

collection contemplated in the NOPR. EEI proposes that companies should be allowed to 

gather experience on the new requirements before undertaking data collection efforts and 
Docket No. RM10-16-000 - 24 - 

points out that the North American Transmission Forum (NATF) would be an appropriate 

venue for discussions on the efficacy of various training experiences. BPA and 

NorthWestern also cite NATF as an appropriate venue to share best practices. BPA 

views its restoration information as extremely sensitive and perceives risk that such 

information could fall into the wrong hands. 

41. NERC, EEI, APPA, Pacificorp, and NorthWestern question the reliability benefit 

of creating such a database compared to the burden it would impose on the industry. 

NERC asks whether developing such a database would direct industry resources where 

they can best serve reliability. IRC does not see the value of the proposed data gathering, 

but notes section 1600 – Requests for Data or Information of NERC’s Rules of 

Procedure25 could be an appropriate means of collecting data without creating an ongoing 

requirement. 

Commission Determination

42. The Commission agrees with NERC that the formal debriefing of system 

restoration drills, exercises and simulations can capture lessons learned and identify best 

practices. But lessons learned in such debriefings are not necessarily communicated to 

all who might benefit from them. In addition, the Commission understands that NATF 

may be an appropriate forum to discuss industry activity and best practices, but we 

continue to believe that there would be a reliability benefit in the ERO aggregating and 

 25 North American Electric Reliability Corporation, Rules of Procedure 85-87 

(2011), available at http://www.nerc.com/files/NERC_Rules_of_Procedure_ 

EFFECTIVE_ 20110101.pdf. 
Docket No. RM10-16-000 - 25 - 

disseminating lessons learned derived from restoration drills, exercises and simulations. 

Nevertheless, we will allow the industry to develop some experience with the new 

Reliability Standards and then review whether or not to pursue this matter under section 

39.2(d) of the Commission’s regulations and the use of Requests for Data or Information 

under section 1600 of NERC’s Rules of Procedure or through some other means. 

G. Violation Risk Factors/Violation Severity Levels

43. In the NOPR, the Commission proposed deferring action on the proposed 

violation risk factors (VRF) and violation severity levels (VSL) for the proposed 

Reliability Standards until the Commission acts on NERC’s pending petition in Docket 

No. RR08-4-005, in which NERC proposes a “roll-up” approach for VRF and VSL 

assignments by which NERC would only assign VRF and VSL to the main requirements 

and not to sub-Requirements.26 Subsequent to the NOPR, on December 1, 2010, NERC 

made a compliance filing to the Commission in Docket No. RR08-04-006 submitting 

new VSL to supersede those presented in the NERC Petition. 

Commission Determination

44. No comments were received regarding this matter. Accordingly, the Commission 

will defer discussion on the proposed violation risk factors and violation severity levels 

 26 Docket No. RR08-4-005 comprises NERC’s March 5, 2010 Violation Severity 

Level Compliance Filing submitted in response to Order No. 722 and an August 10, 2009 

informational filing in which NERC proposes assigning VRF and VSL only to the main 

Requirements in each Reliability Standard and not to the sub-requirements. 
Docket No. RM10-16-000 - 26 - 

assigned to EOP-005-2 and EOP-006-2 until after the Commission issues a final order 

acting on NERC’s petition in Docket No. RR08-4-005 and Docket No. RR08-4-006. 

III. Information Collection Statement

45. The following collections of information contained in this Reliability Standard 

have been submitted to the Office of Management and Budget (OMB) for review under 

section 3507(d) of the Paperwork Reduction Act of 1955.27 OMB’s regulations require 

OMB to approve certain information collection requirements imposed by agency rule.28

46. The Commission solicited comments on the need for and the purpose of the 

information contained in these three Emergency Operations and Performance Reliability 

Standards and the corresponding burden to implement them. The commission received 

comments on its proposed data reporting requirement regarding the performance of 

system restoration exercises which we address in this Final Rule. The Commission has 

not directed any modifications to the Requirements in the three Reliability Standards 

being approved. As a result of this Final Rule the annual burden will increase by an 

estimated 47,472 hours. This is a reduction from the burden estimates provided in the 

NOPR, with respect to reporting data to NERC; however, we have not similarly reduced 

the estimated time expended by reliability coordinators on recordkeeping in order to 

better reflect their enhanced involvement in the planning process. 

 27 44 U.S.C. 3507 (d). 

28 5 CFR 1320.11. 
Docket No. RM10-16-000 - 27 - 

47. Burden Estimate: The estimated burden and for the requirements in this Final 

Rule follow: 

FERC-725A 

Data 

Collection 

No. of 

Respondents 

(A) 

No. of 

Annual 

Responses 

Per 

Respondent 

(B) 

Hours Per 

Respondent 

Per Response 

(C) 

Total Annual 

Hours 

(A X B X C) 

Reliability 

Coordinators 

data retention 

26 2 Recordkeeping 

8 

Recordkeeping 

416 

Compliance: 

116 

Compliance: 

20,416 

Transmission 

operators 

reporting data 

to their 

reliability 

coordinator 

and reducing 

blackstart 

arrangements 

to writing 

176 1 

Recordkeeping: 

16 

Recordkeeping: 

2816 

Generator 

operator 

system 

restoration 

responsibilities 

including 

testing and 

maintaining 

records 

230 1 80 18,400 

Transmission 

owner and 

distribution 

provider 

training and 

recordkeeping 

678 1 8 5,424 

Total 47,472 hours 
Docket No. RM10-16-000 - 28 - 

 Total Estimated Annual Hours for Collection: (Reporting/Compliance + 

recordkeeping) = 47,472 hours. 

 Reporting/Compliance = 44,240 hours @ $132/hour = $5,839,680 

 Recordkeeping = 3232 hours @ $17/hour = $54,944 

 Total Cost = $5,894,624 

 Title: Mandatory Reliability Standards for the Bulk-Power System 

 Action: FERC 725A, Proposed Modification to FERC-725A. 

 OMB Control No: 1902-0244 

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

 Frequency of Responses: On occasion. 

 Necessity of the Information: This Final Rule would approve revised Reliability 

Standards that modify the existing requirement for system restoration from a blackstart. 

The proposed Reliability Standards require some entities to commit agreements or 

understandings to writing and/or to draft written procedures, and retain records. Other 

entities may have to produce and maintain training materials. 

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

contacting: Federal Energy Regulatory Commission, 888 First Street, NE, Washington, 

DC 20426 [Attention: Ellen Brown, Office of the Executive Director, e-mail: 

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

the requirements of this order 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 
Docket No. RM10-16-000 - 29 - 

reasons, comments should be sent by e-mail to OMB at oira_submission@omb.eop.gov. 

Please reference OMB Control Number 1902-0244 and the docket number of this 

rulemaking in your submission. 

IV. Environmental Analysis

49. 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.29 The action taken in the Final Rule fall within the 

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

corrective or procedural, for information gathering, analysis, and dissemination.30 

Accordingly, neither an environmental impact statement nor an environmental 

assessment is required. 

V. Regulatory Flexibility Act

50. The Regulatory Flexibility Act of 1980 (RFA)31 generally requires a description 

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

number of small entities. The RFA mandates consideration of regulatory alternatives that 

accomplish the stated objectives of a proposed rule and that minimize any significant 

economic impact on a substantial number of small entities. The Small Business 

 29 Regulations Implementing the National Environmental Policy Act, Order 

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

1986-1990 ¶ 30,783 (1987). 

30 18 CFR 380.4(a)(5). 

31 5 U.S.C. 601-12. 
Docket No. RM10-16-000 - 30 - 

 

Administration’s (SBA) Office of Size Standards develops the numerical definition of a 

small business.32 The SBA has established a size standard for electric utilities, stating 

that a firm is small if, including its affiliates, it is primarily engaged in the transmission, 

generation and/or distribution of electric energy for sale and its total electric output for 

the preceding twelve months did not exceed four million megawatt hours.33

51. Many of the entities to which the requirements of this rule would apply do not fall 

within the definition of small entities, but most transmission owners, and most 

distribution providers would be deemed small entities. The proposed Reliability 

Standards clarify the elements of restoration plans and training requirements and give 

reliability coordinators a greater role in review and approval of plans, but the proposed 

Reliability Standards reflect primarily a continuation of existing system restoration

requirements currently applicable to reliability coordinators, transmission operators and 

generation operators. 

52. Based on available information regarding NERC’s compliance registry, and our 

best assessment of the application of the proposed Reliability Standards, approximately 

1,110 entities will be responsible for compliance with proposed Reliability Standards 

EOP-005-2 and EOP-006-2, of which approximately 678 are transmission owners and 

distribution providers not already subject to the existing system restoration Reliability 

Standards. Of the 678 transmission owners and distribution providers, only that subset 

32 13 CFR 121.101. 

33 13 CFR 121.201, Sector 22, Utilities & n. 1. 
Docket No. RM10-16-000 - 31 - 

whose field switching personnel are identified in the restoration plan as having unique 

tasks will be subject to a new requirement under the proposed standards, i.e., providing 

two hours of system restoration training every two calendar years to such personnel. The 

Commission estimates that this requirement will impose a cost of perhaps $1,056 per year 

on transmission owners and distribution providers, (and indeed for some entities there 

will be only de minimis additional cost because field personnel are already being trained 

in restoration tasks) and therefore should not present significant operating costs. 

53. Based on this understanding, the Commission certifies that this rule will not have a 

significant economic impact on a substantial number of small entities. Accordingly, no 

regulatory flexibility analysis is required. 

VI. Document Availability

54. 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. 

55. 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. RM10-16-000 - 32 - 

56. 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

57. These regulations are effective [insert date 60 days from publication in 

FEDERAL REGISTER]. The Commission notes that although the determinations made 

in this Final Rule are effective [insert date that is 60 days from publication in the 

FEDERAL REGISTER], in those jurisdictions where regulatory approval is required, 

Reliability Standard EOP-001-1 will not become effective until the first day of the first 

calendar quarter three months after regulatory approval is obtained, and EOP-005-2 and 

EOP-006-2 approved in this Final Rule will not become effective until 24 months after 

the first day of the first quarter after applicable regulatory approval. The Commission 

has determined, with the concurrence of the Administrator of the Office of Information 

and Regulatory Affairs of OMB, that this rule is not a “major rule” as defined in 

section 351 of the Small Business Regulatory Enforcement Fairness Act of 1996. 

By the Commission. 

( S E A L ) 

Kimberly D. Bose, 

Secretary.