133 FERC ¶ 61,151 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

[Docket No. RM10-15-000] 

Mandatory Reliability Standards for Interconnection Reliability Operating Limits 

(November 18, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Proposed Rulemaking. 

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

Regulatory Commission proposes to approve three new Interconnection Reliability 

Operations and Coordination Reliability Standards and seven revised Reliability 

Standards related to Emergency Preparedness and Operations, Interconnection Reliability 

Operations and Coordination, and Transmission Operations. These proposed Reliability 

Standards were submitted to the Commission for approval 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. The proposed Reliability Standards were designed to prevent instability, 

uncontrolled separation, or cascading outages that adversely impact the reliability of the 

interconnection by ensuring prompt action to prevent or mitigate instances of exceeding 

Interconnection Reliability Operating Limits. The Commission also proposes to approve 

the addition of two new terms to the NERC Glossary of Terms. In addition, pursuant to 
Docket No. RM10-15-000 - 2 - 

section 215(d)(5) of the Federal Power Act, the Commission proposes to direct NERC to 

develop a modification to the proposed term “Real-time Assessment” to address a 

specific concern identified by the Commission. The Commission raises some concerns 

with regard to certain aspects of NERC’s proposals and, based on the responses from 

NERC and industry, may choose to direct certain modifications to the proposed new and 

revised Reliability Standard, as well as the new Glossary Terms, as discussed below. 

DATES: Comments are due [insert date that is 60 days after publication in the

FEDERAL REGISTER].

ADDRESSES: You may submit comments, identified by docket number and in 

accordance with the requirements posted on the Commission’s web site, 

http://www.ferc.gov. Comments may be submitted by any of the following methods: 

 Agency Web Site: Documents created electronically using word 

processing software should be filed in native applications or print-toPDF format, and not in a scanned format, at http://www.ferc.gov/docsfiling/efiling.asp. 

 Mail/Hand Delivery: Commenters unable to file comments 

electronically must mail or hand-deliver an original copy of their 

comments to: Federal Energy Regulatory Commission, Secretary of the 

Commission, 888 First Street, NE, Washington, DC 20426. These 

requirements can be found on the Commission’s website, see, e.g., the 

“Quick Reference Guide for Paper Submissions,” available at 
Docket No. RM10-15-000 - 3 - 

http://www.ferc.gov/docs-filing/efiling.asp or via phone from FERC Online 

Support at (202) 502-6652 or toll-free at 1-866-208-3676. 

FOR FURTHER INFORMATION CONTACT: 

Darrell Piatt (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-6687 

A. Cory Lankford (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-6711 

William Edwards (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-6669 

SUPPLEMENTARY INFORMATION:
UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Mandatory Reliability Standards for Interconnection 

Reliability Operating Limits 

Docket No. RM10-15-000 

NOTICE OF PROPOSED RULEMAKING 

TABLE OF CONTENTS

Paragraph Numbers

I. Background ............................................................................................................................3.

A. Mandatory Reliability Standards......................................................................................3.

B. Order No. 693 Directives .................................................................................................4.

II. Discussion.............................................................................................................................7.

A. System Operating Limits..................................................................................................10.

B. Proposed New Reliability Standards................................................................................22.

1. IRO-008-1.....................................................................................................................22.

2. IRO-009-1.....................................................................................................................30.

3. IRO-010-1a...................................................................................................................33.

C. Proposed Revised Reliability Standards...........................................................................38.

1. EOP-001-1 ....................................................................................................................38.

2. IRO-002-2.....................................................................................................................42.

3. IRO-004-2.....................................................................................................................47.

4. IRO-005-3.....................................................................................................................54.

5. TOP-003-1 ....................................................................................................................58.

6. TOP-005-2 ....................................................................................................................61.

7. TOP-006-2 ....................................................................................................................66.

D. Violation Severity Levels and Violation Risk Factors.....................................................69.

III. Information Collection Statement .......................................................................................77.

IV. Environmental Analysis ......................................................................................................82.

V. Regulatory Flexibility Act Certification...............................................................................83.

VI. Comment Procedures ..........................................................................................................84.

VII. Document Availability.......................................................................................................88.
133 FERC ¶ 61,151 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

North American Electric Reliability Corporation Docket No. RM10-15-000 

NOTICE OF PROPOSED RULEMAKING 

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

 the Federal Energy 

Regulatory Commission (Commission) proposes to approve three new Interconnection 

Reliability Operations and Coordination (IRO) Reliability Standards and seven revised 

Reliability Standards related to Emergency Preparedness and Operations (EOP), IRO, 

and Transmission Operations (TOP). The proposed Reliability Standards were submitted 

to the Commission for approval 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.2

 The 

proposed Reliability Standards were designed to prevent instability, uncontrolled 

separation, or cascading outages that adversely impact the reliability of the 

interconnection by ensuring prompt action to prevent or mitigate instances of exceeding 

interconnection reliability operating limits (IROL). The Commission also proposes to 

 1

 16 U.S.C. 824o. 

2 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g 

& compliance, 117 FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc. v. FERC, 564 F.3d 

1342 (D.C. Cir. 2009). 
Docket No. RM10-15-000 - 2 - 

approve the addition of two new terms to the NERC Glossary of Terms (NERC 

Glossary). In addition, pursuant to section 215(d)(5) of the Federal Power Act, the 

Commission proposes to direct NERC to develop a modification to the proposed term 

“Real-time Assessment” to address a specific concern identified by the Commission. The 

Commission raises some concerns with regard to certain aspects of these proposals and, 

based on the responses from NERC and from industry, may choose to direct certain 

modifications to the proposed new and revised Reliability Standard, as well as the new 

Glossary Terms, as discussed below. 

2. The three new Reliability Standards proposed by NERC are designated as 

IRO-008-1 (Reliability Coordinator Operational Analyses and Real-time Assessments), 

IRO-009-1 (Reliability Coordinator Actions to Operate Within IROLs), and IRO-010-1a3

(Reliability Coordinator Data Specification and Collection). In preparing these new 

Reliability Standards, the standards drafting team determined that it was necessary to 

retire or modify certain requirements from several existing standards. Accordingly, 

 3

 NERC designates the version number of a Reliability Standard as the last digit of 

the Reliability Standard number. Therefore, original Reliability Standards end with “-0” 

and modified version one Reliability Standards end with “-1.” The NERC Board of 

Trustees approved the proposed IRO-010-1 Reliability Standard on October 17, 2008. 

Subsequently, on August 5, 2009, the NERC Board of Trustees approved an 

interpretation to the proposed IRO-010-1 standard. Accordingly, NERC is requesting 

approval of both the proposed standard and the appended interpretation, and NERC has 

designated the proposed standard and appended interpretation as IRO-010-1a. 
Docket No. RM10-15-000 - 3 - 

NERC requests Commission approval of revised Reliability Standards EOP-001-2,4

 

IRO-002-2, IRO-004-2, IRO-005-3, and TOP-006-2. NERC also proposes to add the 

following new terms to the NERC Glossary: “Operational Planning Analysis” and “Realtime Assessment.”5

I. Background

A. Mandatory Reliability Standards

3. 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 are enforced by the ERO, 

subject to Commission oversight, or by the Commission independently. 

 4

 Concurrent with its filing in this Docket, NERC filed a petition in Docket No. 

RM10-16-000 seeking approval of certain Emergency Preparedness and Operations 

Reliability Standards. NERC, Petition for Approval of Three Emergency Preparedness 

and Operations Reliability Standards, Docket No. RM10-16-000 (filed Dec. 31, 2009). 

As part of its filing in RM10-16-000, NERC proposed to retire Requirement R3.4 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. NERC indicated 

in both petitions that it could not anticipate the sequence in which the Commission would 

act and therefore included two sets of proposed amendments to EOP-001-0 in each 

petition. The Commission will clarify upon issuance of Final Rules in each proceeding 

which revised version of EOP-001-0 it is addressing in its determination. 

5

 The proposed new Reliability Standards and other modified Reliability Standards 

are not codified in the CFR and are not attached to the NOPR. They are, however, 

available on the Commission’s eLibrary document retrieval system in Docket No. 

RM10-15-000 and are available on the ERO’s website, www.nerc.com. 
Docket No. RM10-15-000 - 4 - 

B. Order No. 693 Directives

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

107 initial Reliability Standards filed by NERC, including the existing IRO Reliability 

Standards.6

 Under section 215(d)(5) of the FPA, the Commission directed NERC to 

develop modifications to the IRO Reliability Standards to address certain issues 

identified by the Commission. 

5. With respect to IRO-001-1, the Commission directed the ERO to develop 

modifications to eliminate the regional reliability organization as an applicable entity.7

 

The Commission also directed the ERO to modify IRO-002-1 to require a minimum set 

of capabilities that must be made available to the reliability coordinator to ensure that a 

reliability coordinator has the capabilities it needs to perform its functions.8

 With respect 

to IRO-003-2, the Commission directed the ERO to develop a modification to create 

criteria to define the term “critical facilities” in a reliability coordinator’s area and its 

adjacent systems.9

 The Commission also directed the ERO to modify IRO-004-1 to 

require the next-day analysis to identify control actions that can be implemented and 

 6 Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 

FR 16416 (Apr. 4, 2007), FERC Stats. & Regs. ¶ 31,242, order on reh’g, Order No. 

693-A, 120 FERC ¶ 61,053 (2007). 

7

 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 896. 

8 Id. P 908. 

9 Id. P 914. 
Docket No. RM10-15-000 - 5 - 

effective within 30 minutes after a contingency. In addition, the Commission directed the 

ERO to consider adding Measures and Levels of Non-Compliance to Reliability 

Standards IRO-004-1 and IRO-005-1 that are commensurate with the magnitude, 

duration, frequency and causes of the violations and whether these occur during normal 

or contingency conditions.10 

6. The Commission also directed the ERO to conduct a survey on IROL practices 

and actual operating experiences by requiring reliability coordinators to report any 

violations of IROLs, their causes, the date and time, the durations and magnitudes in 

which actual operations exceed IROLs to the ERO on a monthly basis for one year 

beginning two months after the effective date of Order No. 693.11 On October 31, 2008, 

NERC filed the results of its year-long survey with the Commission.12 On February 8, 

2009, NERC supplemented those results in a second filing.13 

 10 Id. P 935. NERC has subsequently replaced Levels of Non-Compliance with 

Violation Severity Levels. See Order on Violation Severity Levels Proposed by the 

Electric Reliability Organization, 123 FERC ¶ 61,284 (Violation Severity Level Order), 

order on reh’g, 125 FERC ¶ 61,212 (2008). 

11 Id. P 951. 

12 NERC, Compliance Filing, Docket No. RM06-16-006 (filed Oct. 31, 2008). 

13 NERC, Compliance Filing, Docket No. RM06-16-006 (filed Feb. 8, 2009). 
Docket No. RM10-15-000 - 6 - 

II. Discussion

7. In a December 31, 2009 filing (NERC Petition),14 NERC requests Commission 

approval of proposed Reliability Standards IRO-008-1, IRO-009-1, and IRO-010-1a. 

NERC contends that these new Reliability Standards would address certain Commission 

directives from Order No. 693. In developing the new IRO Reliability Standards, NERC 

determined that it was necessary to retire or modify certain requirements from several 

existing standards. Accordingly, NERC proposes revised Reliability Standards 

EOP-001-1, IRO-002-2, IRO-004-2, IRO-005-3, TOP-003-1, TOP-005-2, and 

TOP-006-2. NERC also requests approval of new definitions “Operational Planning 

Analysis” and “Real-time Assessment.” 

8. As discussed below, the Commission proposes to approve new Reliability 

Standards IRO-008-1, IRO-009-1, and IRO-010-1a. The Commission also proposes to 

approve revised Reliability Standards EOP-001-1, IRO-002-2, IRO-004-2, IRO-005-3, 

TOP-003-1, TOP-005-2, and TOP-006-2 as well as the two new NERC Glossary terms. 

9. In addition, the Commission seeks comment on specific concerns related to the 

proposed IRO Reliability Standards, as set forth below. 

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

of Proposed New and Revised Reliability Standards for Operating Within Interconnection 

Operating Limits (NERC Petition). 
Docket No. RM10-15-000 - 7 - 

A. System Operating Limits

10. To maintain the reliable operation of the Bulk-Power System, reliability 

coordinators, balancing authorities, and transmission operators must be aware of the 

applicable system operating limits (SOLs) and interconnection reliability operating limits 

(IROLs) on their system. NERC defines SOLs as the value (such as MW, MVar, 

Amperes, Frequency or Volts) that satisfies the most limiting of the prescribed operating 

criteria for a specific system configuration to ensure operation within acceptable 

reliability criteria. These SOLs are based upon certain operating criteria. IROLs are, 

essentially, a subset of SOLs. NERC defines IROLs as the value (such as MW, MVar, 

Amperes, Frequency or Volts) derived from, or a subset of the SOLs, which if exceeded, 

could expose a widespread area of the bulk electric system to instability, uncontrolled 

separation, or cascading outages.15

NERC Proposal

11. The proposed IRO Reliability Standards together with the proposed revisions to 

existing Reliability Standards would divide responsibility for SOLs and IROLs between 

reliability coordinators and transmission operators according to the Functional Model.16 

NERC explains that having two entities with the same primary responsibility is not 

 15 See NERC Glossary, available at

http://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf. 

16 NERC, Reliability Functional Model, version 5, at 30 (Nov. 2009), available at

http://www.nerc.com/files/Functional_Model_V5_Final_2009Dec1.pdf. 
Docket No. RM10-15-000 - 8 - 

supported by the Functional Model. However, NERC notes that the proposed Reliability 

Standards should not imply that the reliability coordinator will not look at its future 

operations with respect to specific SOLs.17 NERC states that the reliability coordinator 

must look at its future operations with respect to specific SOLs to ensure that their 

transmission operators are taking actions at appropriate times, but the primary 

responsibility for SOLs rests with the transmission operators. NERC explains that, under 

the proposed Reliability Standards, the reliability coordinator retains overall visibility of 

all operations within its Wide-Area view, including some SOLs, although the 

transmission operator is primarily responsible for actions related to SOLs.18 NERC states 

that the IRO standards were developed in support of the authority and assignment of tasks 

in the Functional Model.19 NERC explains that under the Functional Model, while 

reliability coordinators will assign their transmission operators tasks associated with 

IROLs, the reliability coordinator has ultimate responsibility for these tasks, and the 

reliability coordinator is sanctioned if these tasks are not performed as required by the 

Reliability Standards.20

 17 NERC Petition at 77. 

18 Id. at 78. 

19 Id. at 7-9. 

20 Id. at 8. 
Docket No. RM10-15-000 - 9 - 

12. NERC explains that, under the Functional Model, the reliability coordinator is the 

functional entity with the highest level of responsibility and authority for real-time 

reliability of the Bulk-Power System. NERC states that the reliability coordinator is 

responsible for identifying the subset of SOLs that are known as IROLs, and may direct 

its transmission operators to take actions associated with IROLs. In assigning a single 

task to a single functional entity, under the Functional Model, the reliability coordinator 

is the sole functional entity responsible for developing IROLs and for actions to 

prevent/mitigate instances of exceeding IROLs. While the transmission operator has no 

“direct” responsibility for developing IROLs, the transmission operator may be assigned 

the task of developing some IROLs, monitoring real-time values against identified 

IROLs, and taking actions to prevent reaching an IROL or to mitigate an instance of 

exceeding an IROL. However, the transmission operator only performs these tasks when 

directed to do so by its reliability coordinator.21 

13. NERC further explains that, in a similar fashion, the Functional Model assigns 

responsibility for SOLs that are not IROLs to the transmission operator. But, NERC 

states, this too is a shared responsibility.22 NERC states that where the Transmission 

 Operator has primary responsibility for developing the SOLs within its transmission 

operator area, the transmission operator may request the assistance of its reliability 

 21 Id.

22 Id. at 9. 
Docket No. RM10-15-000 - 10 - 

coordinator in developing these SOLs. In addition, NERC states that it is the reliability 

coordinator that is held responsible for ensuring that transmission operators develop 

SOLs for its reliability coordinator area in accordance with a methodology developed by 

the reliability coordinator. NERC states that the transmission operator must share its 

SOLs with its reliability coordinator, and the reliability coordinator must share any SOLs 

it develops with its transmission operator. NERC also states that the reliability 

coordinator monitors the status of some, but not all, SOLs. 

14. According to NERC, the reliability coordinator’s visualization capabilities are not 

expected to display all SOLs within the Wide-Area that the reliability coordinator 

monitors because this would mix SOLs that have little impact on reliability with those 

SOLs that are associated with facilities that are important to the Bulk-Power System. 

NERC states that the reliability coordinator’s visualization capabilities are expected to 

display the real-time status of parameters against all IROLs that the reliability coordinator 

monitors and also display the subset of SOLs associated with facilities that are most 

critical to the portions of the Bulk-Power System that are monitored by the reliability 

coordinator. 

15. Under proposed new Reliability Standards, IRO-008-1, IRO-009-1, and 

IRO-010-1a, reliability coordinators must monitor and analyze IROLs within their WideArea to prevent instability, uncontrolled separation, or cascading outages that adversely 

impact the reliability of the interconnection. These Reliability Standards would not 

require the reliability coordinator to monitor and analyze SOLs other than IROLs within 

their reliability coordinator area. Similarly, NERC’s proposed revisions to Reliability 
Docket No. RM10-15-000 - 11 - 

Standards EOP-001-1, IRO-002-2, IRO-004-2, IRO-005-3, TOP-003-1, TOP-005-2, and 

TOP-006-2, inter alia, would remove requirements for the reliability coordinator to 

monitor and analyze SOLs other than IROLs. 

Discussion

16. We believe that it is appropriate to develop requirements for Reliability Standards 

that offer a clear division of responsibilities among reliability coordinators and 

transmission operators. We, therefore, propose to approve NERC’s proposed division of 

responsibility for SOLs and IROLs among reliability coordinators and transmission 

operators. Although we support NERC’s proposal and propose here to approve it with 

only a limited directive regarding one proposed definition, we are also seeking comments 

from NERC and industry to obtain further information and ensure that there will not be 

gaps in the analysis of SOLs by reliability coordinators going forward, particularly those 

SOLs that could become IROLs. NERC acknowledges in its filing that the transmission 

operator must develop and share its SOLs with its reliability coordinator, and the 

reliability coordinator must develop and share any SOLs it develops with its transmission 

operator.23 NERC also states that the reliability coordinator monitors the status of some, 

but not all, SOLs.24 In addition, the Commission is aware that NERC is currently 

working on a project to identify a subset of SOLs, other than IROLs, that a reliability 

 23 Id.

24 Id. 
Docket No. RM10-15-000 - 12 - 

coordinator must continuously monitor and analyze.25 Taken together, NERC’s 

statements and its ongoing project indicate a need for reliability coordinators to continue 

to analyze certain SOLs. We, therefore, seek comment on whether there is a need for 

reliability coordinators to continue to analyze, in addition to continuing to monitor and 

coordinate data on,26 SOLs other than IROLs. 

17. Since the ERO has stated that responsibility for the SOLs is shared between the 

reliability coordinator and their transmission operators, we also believe it may be 

beneficial for the reliability coordinator to have a documented methodology for 

identifying the SOL information it needs to fulfill its responsibilities for monitoring, day 

ahead and real-time assessments, and operational control within the reliability 

coordinator’s area. We seek comment on this matter. 

18. In addition, we request comment from NERC, reliability coordinators, and other 

interested entities on the current practices of reliability coordinators and transmission 

operators with respect to coordinating operational responsibilities for monitoring, day 

ahead and real-time assessments; and operating SOLs and IROLs, the practical division 

of responsibilities for preventing and mitigating SOL and IROL violations, and the 

monitoring capabilities of the reliability coordinator with respect to IROLs as well as 

 25 NERC identifies this as “Project 2007-03: Real-time Operations,” available at 

http://www.nerc.com/filez/standards/Real-time_Operations_Project_2007-03.html. 

26 Existing reliability standards that NERC does not propose to change here 

continue to require reliability coordinators to monitor SOLs. See Reliability Standard 

IRO-002-1 Requirement R6. 
Docket No. RM10-15-000 - 13 - 

SOLs. The Commission further seeks comment as to whether a reliability coordinator 

can provide an accurate assessment of the Bulk-Power System to its transmission 

operators on a Wide-Area basis, without evaluating: (1) the operating environment on 

SOLs that will impact the transmission operators within the reliability coordinator’s 

areas; (2) SOLs that have the potential to become IROLs; and, (3) the existing IROLs 

within the reliability coordinator area. In addition, the Commission seeks comments as to 

whether a transmission operator can provide reliable operating assessments or make 

reliable operating instructions on an SOL that is on the border between two different 

transmission operator’s areas. The Commission also requests comment on whether the 

reliability coordinator should have responsibility to monitor certain SOLs other than 

IROLs, and whether such a responsibility would place an unreasonable burden on 

reliability coordinators. If a reliability coordinator should monitor certain SOLs other 

than IROLs, comments should address in detail how reliability coordinators should 

determine which SOLs to monitor. 

19. The Commission has noted that NERC Standard IRO-006, Transmission Loading 

Relief (TLR), requires the reliability coordinators in the Eastern Interconnection to 

relieve overloads on the facilities modeled in the Interchange Distribution Calculator 

(IDC). IRO-006 requires the reliability coordinator to model the SOLs and IROLs in the 

IDC to perform the TLR procedures. The Commission seeks comments on how the 

reliability coordinators in the Eastern Interconnections selects the SOLs for evaluation by 

the IDC and the extent of any burden this has caused the reliability coordinator. 
Docket No. RM10-15-000 - 14 - 

20. The NERC Functional Model is a reference document developed by NERC that 

outlines functions for each responsible entity in the NERC Reliability Standards.27 

NERC explains in its filing that the NERC Functional Model was developed by first 

identifying all of the operating tasks necessary for reliability, and then assigning each of 

these operating tasks to a single functional entity.28 NERC states that this approach 

results in a clear identification of a single functional entity with responsibility for each 

reliability task. However, NERC also states that in later versions of the Functional 

Model, there are circumstances where the Functional Model assigns some activities to 

more than one planning entity.29 NERC explains that, under the Functional Model, the 

reliability coordinator is responsible for identifying the subset of SOLs known as IROLs 

and that the transmission operator is responsible for other SOLs. But the Functional 

Model assigns a much broader role to the reliability coordinator to maintain the real-time 

operating reliability of the bulk electric system within its area. The Commission seeks 

comments from NERC and the public as to how the current Functional Model represents 

the delineation of assessment and operating responsibilities between the reliability 

coordinator and transmission operator with respect to SOLs and IROLs. 

 27 NERC, Reliability Functional Model, version 5 at 30 (Nov. 2009), available at

http://www.nerc.com/files/Functional_Model_V5_Final_2009Dec1.pdf. NERC 

developed the current version of the Functional Model after it developed the proposed 

Reliability Standards. 

28 NERC Petition at 7. 

29 Id. at 7 n.9. 
Docket No. RM10-15-000 - 15 - 

21. Based on the foregoing, the Commission proposes to approve the proposed new 

and revised Reliability Standards without modification (with the exception of the limited 

directive proposed below), as they appear to be an improvement over the existing 

Reliability Standards with respect to the division of responsibilities between reliability 

coordinators and transmission operators. Our intent in seeking comments from NERC 

and industry in this NOPR is to better understand the proposed division of 

responsibilities, as well as the future modifications to those responsibilities that NERC 

intends to pursue. 

B. Proposed New Reliability Standards

1. IRO-008-1

22. Proposed Reliability Standard IRO-008-1 has the stated purpose of preventing 

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

reliability of the interconnection by ensuring that the Bulk Electric System is assessed 

during the operations horizon. The proposed Reliability Standard applies to reliability 

coordinators. IRO-008-1 requires the reliability coordinator to use analyses and 

assessments as methods of achieving the stated goal. The Reliability Standard requires 

analysis of the reliability coordinator’s Wide-Area30 ahead of time and during real-time. 

 30 The term “Wide-Area” is defined in the NERC Glossary, approved by the 

Commission. As defined, Wide-Area includes not only the reliability coordinator’s Area, 

but also critical flow and status information from adjacent reliability Coordinator areas as 

determined by detailed system studies to allow the calculation of IROLs. See NERC 

Glossary available at

http://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf. 
Docket No. RM10-15-000 - 16 - 

It also requires communication with the entities that need to take specific operational 

actions based on the analyses and assessments. 

23. Reliability Standard IRO-008-1 contains three requirements. Requirement R1 

requires each reliability coordinator to perform an Operational Planning Analysis to 

assess whether the planned operations for the next day within its Wide Area, will exceed 

any of its IROLs during anticipated normal and contingency event conditions. 

Requirement R2 requires the reliability coordinator to perform a Real-Time Assessment 

at least once every 30 minutes to determine if its Wide Area is exceeding any IROLs or is 

expected to exceed any IROLs. Requirement R3 requires a reliability coordinator to 

share the results of an Operational Planning Analysis or Real-Time Assessment that 

indicates the need for specific operational actions to prevent or mitigate an instance of 

exceeding an IROL with those entities that are expected to take those actions. 

24. NERC explains that IRO-008-1, Requirement R1 does not specify any single 

application program that all reliability coordinators must use because the Requirement 

assumes that the reliability coordinator has a suite of applications that it can use to 

conduct its assessment, verified as part of the certification process. NERC notes that 

having the ability to conduct a day-ahead contingency analysis is a requirement for 

reliability coordinator certification. 

25. NERC also requests approval of two new terms that appear in IRO-008-1: 

“Operational Planning Analysis” and “Real-time Assessment.” Operational Planning 

Analysis is defined as: 
Docket No. RM10-15-000 - 17 - 

An analysis of the expected system conditions for the next day’s 

operation. (That analysis may be performed either a day ahead or as 

much as 12 months ahead.) Expected system conditions include 

things such as load forecast(s), generation output levels, and known 

system constraints (transmission facility outages, generator outages, 

equipment limitations, etc.). 

NERC states that the definition was designed to provide greater specificity regarding the 

day-ahead study. NERC explains that the term “unique” used in the currently-effective 

IRO-004-1 causes confusion. NERC states that in the event there are no changes to the 

expected conditions from one day to the next, the reliability coordinator would not be 

forced to conduct a new analysis of the expected system conditions solely to have 

documentation for compliance. 

26. The proposed term “Real-time Assessment” is defined as “[a]n examination of 

existing and expected system conditions, conducted by collecting and reviewing 

immediately available data.” The purpose of the new term is to assure that the reliability 

coordinator is required to conduct a real-time assessment, including situations when the 

reliability coordinator is operating without its primary control facilities, by collecting and 

reviewing available data. NERC explains that the definition of Real-Time Assessment is 

purposefully ambiguous to allow the assessment to be conducted either through the 

energy management system or manually. 

NOPR Proposal

27. We agree with NERC that the proposed Reliability Standard IRO-008-1 would 

prevent instability, uncontrolled separation, or cascading outages that adversely impact 

the reliability of the interconnection by ensuring that the bulk electric system is assessed 
Docket No. RM10-15-000 - 18 - 

during the operations horizon. In addition, the Commission recognizes NERC’s effort to 

create a body of IRO Reliability Standards that clearly define which functional entity has 

the ultimate responsibility for SOLs and IROLs. Accordingly, pursuant to section 

215(d)(2) of the FPA, the Commission proposes to approve Reliability Standards IRO008-1, as just, reasonable, not unduly discriminatory or preferential, and in the public 

interest. To ensure that the proposed changes are supported by the Functional Model, the 

Commission requests comment whether the proposed Reliability Standards, such as 

IRO-008-1, appropriately resolve the division of responsibilities for SOLs and IROLs or 

whether some level of sharing of responsibility needs to exist. 

28. The Commission also proposes to approve the addition of two new definitions to 

the NERC Glossary: “Operational Planning Analysis” and “Real-time Assessment” with 

limited modification, as discussed below. Although the proposed definition of 

Operational Planning Analysis would permit entities to use an analysis of the expected 

system conditions for the next day’s operation that was performed up to twelve months 

earlier, the discretion to use an existing analysis is limited to circumstances where the 

expected system conditions, such as load forecasts, generation output levels, and known 

system constraints are the same for both days. Nevertheless, the Commission requests 

comments from NERC and the public on the prudence of using an Operational Planning 

Analysis up to twelve months old. We request comment on whether this timeframe is 

reasonable or whether the timeframe should be shorter to ensure that the analysis is not 

outdated. In addition, the Commission also seeks comments from NERC and the public 
Docket No. RM10-15-000 - 19 - 

on whether the definition should include measurable criteria needed to determine whether 

it is appropriate to use an existing analysis. 

29. In addition, the Commission seeks comment on the meaning of “immediately 

available data” within the proposed definition of Real-Time Assessment. Requirement 

R6 of proposed Reliability Standard IRO-002-2 would require reliability coordinators to 

have adequate analysis capabilities such as state estimation, pre- and post-contingency 

analysis capabilities (thermal, stability, and voltage), and wide-area overview displays.31 

Thus, it appears that any immediately available data used by the reliability coordinator in 

the development of a Real-time Assessment should be data obtained from one of these 

analysis capabilities. We believe this could be clearer. Accordingly, under section 

215(d)(5) of the FPA, the Commission proposes to direct NERC to modify the definition 

of “Real-time Assessment” to specify that the type of data to be relied upon by a 

reliability coordinator in conducting a Real-time Assessment must be based on adequate 

analysis capabilities such as those referenced in Requirement R6 of IRO-002-2 when the 

tools are available. 

2. IRO-009-1

30. As proposed, Reliability Standard, IRO-009-1 is designed to prevent instability, 

uncontrolled separation, or cascading outages that adversely impact the reliability of the 

 31 As discussed below, NERC proposes to revise IRO-002-1 by removing one 

provision, Requirement R2. Thus, Requirement R6 of proposed IRO-002-2 is the same 

as Requirement R7 of the existing version 1 Reliability Standard. 
Docket No. RM10-15-000 - 20 - 

interconnection by “ensuring prompt action to prevent or mitigate instances of exceeding 

[IROLs].” Proposed Reliability Standard IRO-009-1 applies only to reliability 

coordinators. 

31. For each IROL that the reliability coordinator identifies one or more days in 

advance, the reliability coordinator must, under Requirements R1 and R2, have one or 

more operating processes, procedures, or plans that identify actions it shall take that can 

be implemented in time to prevent exceeding those IROLs and to mitigate the magnitude 

and duration of exceeding that IROL such that the IROL is alleviated within the 

maximum time duration allowed for a violation of an IROL. Reliability Standard 

IRO-009-1 refers to the maximum response period for alleviating an IROL as its “IROL 

Tv.”32 Under Requirements R3 and R4, the reliability coordinator must use those 

operating processes, procedures, or plans to prevent and mitigate IROLs. If reliability 

coordinators cannot agree on the value for an IROL or its IROL Tv, Requirement R5 

would require each reliability coordinator that monitors that facility to use the most 

conservative value. 

 32The NERC Glossary of Terms defines “IROL Tv” as: 

The maximum time that an Interconnection Reliability Operating Limit can be 

violated before the risk to the interconnection or other Reliability Coordinator 

Areas becomes greater than acceptable. Each Interconnection Reliability 

Operating Limit’s Tv shall be less than or equal to 30 minutes. 
Docket No. RM10-15-000 - 21 - 

NOPR Proposal

32. The Commission agrees that having action plans developed and implemented with 

respect to IROLs to prevent instability, uncontrolled separation, or cascading outages that 

adversely impact the reliability of the interconnection increases the likelihood that 

reliability coordinators will take appropriate action. Accordingly, under section 

215(d)(2) of the FPA, the Commission proposes to approve Reliability Standard 

IRO-009-1, as just, reasonable, not unduly discriminatory or preferential, and in the 

public interest. However, as discussed above, the Commission requests comment on the 

extent that reliability coordinators should have action plans developed and implemented 

with respect to other SOLs apart from IROLs and if so, which SOLs. 

3. IRO-010-1a

33. NERC proposes the addition of a new Reliability Standard, IRO-010-1a to the 

current suite of IRO Reliability Standards. IRO-010-1a is designed to prevent instability, 

uncontrolled separation, or cascading outages that adversely impact the reliability of the 

interconnection by mandating that the reliability coordinator have the data it needs to 

monitor and assess the operation of its reliability coordinator Area. 

34. The requirements in the Reliability Standard specify a formal request process for 

the reliability coordinator to explicitly identify the data and information it needs for 

reliability; and require the entities with the data to provide it as requested. The 

Reliability Standard applies to the reliability coordinator and to the other functional 
Docket No. RM10-15-000 - 22 - 

entities that must supply data to the reliability coordinator.33 This includes entities that 

have been identified as owners, users, or operators of the bulk-power system. 

35. Because the interpretation for IRO-010-1 was completed before the filing of IRO010-1, NERC requests Commission approval of IRO-010-1a, which includes the standard 

as interpreted. The WECC Reliability Coordination Subcommittee requested 

clarification on: (1) the type of data to be supplied to the reliability coordinator; 

(2) which entities are ultimately responsible for ensuring data are provided; and (3) what 

actions are expected of the reliability coordinator regarding a “mutually acceptable 

format.” 

36. In response to the questions posed by the WECC Reliability Coordination 

Subcommittee, NERC’s interpretation team clarified that the data to be supplied in 

Requirement R3 applies to the documented specification for data and information 

referenced in Requirement R1. They also explained that the intent of Requirement R3 is 

for each responsible entity to ensure that its data and information (as stated in the 

documented specification in Requirement R1) are provided to the reliability coordinator. 

NERC’s interpretation team stated that another entity may provide that data or 

information to the reliability coordinator on behalf of the responsible entity, but the 

responsibility remains with the responsible entity. Finally, they explained that 

 33 The requirements in the standard are specifically applicable to the following 

functional entities: (1) reliability coordinator; (2) balancing authority; (3) generator 

owner; (4) generator operator; (5) interchange authority; (6) load-serving entity; (7) 

transmission operator; and (8) transmission owner. 
Docket No. RM10-15-000 - 23 - 

Requirement R1.2 mandates that the parties will reach a mutual agreement with respect to 

the format of the data and information. If the parties can not mutually agree on the 

format, it is expected that they will negotiate to reach agreement or enter into dispute 

resolution to resolve the disagreement.34 

NOPR Proposal

37. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard IRO-010-1a, including the proposed interpretation, as just, 

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

However, the Commission notes that the requirements of Reliability Standard 

IRO-010-1a do not require reliability coordinators to specify a list of minimum data 

needed for reliable operation of the Bulk-Power System. The Commission is concerned 

that, without such a minimum list, neighboring reliability coordinators could experience 

problems regarding compatibility and, therefore, common understanding of data. For 

example, if differing data requirements were specified by adjacent reliability 

coordinators, the analysis performed by one could indicate a more severe result from a 

possible contingency and result in conflicting operating procedures for mitigation of risk 

to the Bulk-Power System. Therefore, the Commission requests comments from the 

ERO and industry on whether a minimum list of data is necessary for the effective 

sharing of data between neighboring reliability coordinators and, if so, what data should 

 34 NERC Petition at 108. 
Docket No. RM10-15-000 - 24 - 

be included. The Commission also requests comments from NERC and the industry on 

how compatibility of data between neighboring reliability coordinators can be assured 

absent a list of minimum data as part of this proposed Reliability Standard. 

C. Proposed Revised Reliability Standards

1. EOP-001-1

38. NERC proposes to retire Requirement R2 of Reliability Standard EOP-001-0. To 

implement this revision, NERC proposes a revised Reliability Standard EOP-001-1. The 

purpose of EOP-001-1 is to require each transmission operator and balancing authority to 

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

These plans need to be coordinated with other transmission operators and balancing 

authorities, and the reliability coordinator. Revised Reliability Standard EOP-001-1 

would apply only to balancing authorities and transmission operators. 

39. NERC contends that, upon IRO-009-1 becoming effective, Requirement R2 of 

EOP-001-0 should be retired. Under Requirement R2 transmission operators must have 

an emergency load reduction plan for all identified IROLs. NERC contends that this 

requirement would no longer be appropriate upon IRO-009-1 becoming effective because 

the reliability coordinator, not the transmission operator, is responsible for developing 

plans for mitigating IROLs. Accordingly, NERC requests approval of EOP-001-1, which 

is identical to existing Reliability Standard EOP-001-0 except for the retirement of 

Requirement R2. 

40. NERC contends that the proposed new Requirements R1 and R2 of IRO-009-1 

combined with the revisions in proposed Reliability Standard EOP-001-1 address the 
Docket No. RM10-15-000 - 25 - 

Commission’s directives in Order No. 693 to modify EOP-001-0 to include the reliability 

coordinator as an applicable entity and to require the reliability coordinator to act to 

mitigate IROL violations within 30 minutes.35 In developing IRO-009-1, NERC states 

that the drafting team determined that there are some IROLs that must be resolved in a 

time frame that is shorter than 30 minutes. Accordingly, Requirement R2 of IRO-009-1 

requires that each action plan developed to resolve an IROL must be capable of being 

executed such that the IROL is relieved within its IROL Tv. In addition, Requirement R4 

of IRO-009-1 requires the reliability coordinator to act, without delay, when actual 

system conditions show that there is an instance of exceeding an IROL. 

NOPR Proposal

41. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard EOP-001-1 as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. The Commission also proposes to find that the 

ERO has satisfied the first and second directives from P 566 of Order No. 693. 36 

2. IRO-002-2

42. NERC proposes to retire Requirement R2 of Reliability Standard IRO-002-1. To 

implement this revision, NERC requests Commission approval of revised Reliability 

 35 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 548, 556, 566. 

36 The Commission notes that the third and fourth directives listed in P 566 of 

Order No. 693 remain outstanding. Further, the Commission directed the ERO to 

consider a pilot program for implementing system states. Order No. 693, FERC Stats. & 

Regs. ¶ 31,242 at P 566. 
Docket No. RM10-15-000 - 26 - 

standard IRO-002-2. The purpose of IRO-002-2 is to provide reliability coordinators 

with the information, tools and other capabilities that they need to perform their 

responsibilities. IRO-002-2 would apply only to reliability coordinators. 

43. Requirement R2 of IRO-002-1 requires each reliability coordinator to determine 

the data requirements to support its reliability coordinator tasks and to request such data 

from its transmission operators, balancing authorities, transmission owners, generation 

owners, generation operators, and load-serving entities, or adjacent reliability 

coordinators. NERC explains that proposed Reliability Standard IRO-010-1a (discussed 

above) requires the reliability coordinator to develop and distribute a data specification to 

ensure that entities provide data as needed to support monitoring, analyses, and 

assessments. NERC contends that the proposed requirements are more explicit than the 

associated requirement in Reliability Standard IRO-002-1. 

44. Reliability Standard IRO-002-2 continues to require each reliability coordinator to 

monitor SOLs other than IROLs both within its reliability coordinator area and in 

surrounding reliability coordinator areas. Under Requirement R4 of IRO-002-2, each 

reliability coordinator must have detailed real-time monitoring capability of its reliability 

coordinator area and sufficient monitoring capability of its surrounding reliability 

coordinator areas to ensure that potential or actual SOLs or IROL violations are 

identified. In addition, under Requirement R5, each reliability coordinator must monitor 

bulk electric system elements such as generators, transmission lines, buses, transformers 

and breakers that could result in SOL or IROL violations within its reliability coordinator 

area. 
Docket No. RM10-15-000 - 27 - 

45. In Order No. 693, the Commission directed the ERO to develop a modification to 

IRO-002-1 that requires a minimum set of capabilities that should be made available to 

reliability coordinators. NERC acknowledges that the proposed modification does not 

address this directive. NERC states that this directive is being considered in Project 

2009-02 – Real-time Tools and Analysis Capabilities. 

NOPR Proposal

46. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard IRO-002-2. The Commission proposes to find that the data 

specification requirements of proposed Reliability Standard IRO-001-1a are more explicit 

than the direction provided in Requirement R2 of IRO-002-1. In addition, the 

Commission accepts NERC’s commitment to develop a minimum set of capabilities that 

should be made available to reliability coordinators. 

3. IRO-004-2

47. NERC proposes to revise IRO-004-1 by retiring Requirements R1 through R6. 

To implement these revisions, NERC requests Commission approval of Reliability 

Standard IRO-004-2. The purpose of IRO-004-2 is to require each reliability coordinator 

to conduct next-day reliability analyses for its reliability coordinator area to ensure the 

bulk electric system can be operated reliably in anticipated normal and contingency 

conditions. IRO-004-2 would apply to balancing authorities, transmission operators, and 

transmission service providers. 

48. NERC states that, upon approval of proposed IRO-008-1, Requirement R1 of the 

currently-effective IRO-004-1 should be retired because the requirement only requires a 
Docket No. RM10-15-000 - 28 - 

next-day reliability analysis of its own reliability coordinator area as opposed to its WideArea, which also would include critical flow and status information from adjacent 

reliability coordinator areas to allow the calculation of IROLs. NERC explains that 

because proposed IRO-008-1 requires the reliability coordinator to assess a wider area 

than is currently required by IRO-004-1, the reliability coordinator is required to 

continuously look beyond its own area boundaries and assess a broader portion of the 

interconnected Bulk-Power System. NERC further states that the purpose of conducting 

a day-ahead analysis is not to “ensure” but to “assess” the system and, thus, Requirement 

R1 of currently-effective IRO-004-1 is inaccurate. 

49. NERC also seeks to retire Requirement R2 of IRO-004-1, which requires each 

reliability coordinator to “pay particular attention to parallel flows to ensure one 

reliability coordinator area does not place an unacceptable or undue burden on an 

adjacent reliability coordinator area.”37 NERC states that the phrase “to pay particular 

attention to” is neither clear nor measurable. NERC asserts that the requirements in 

currently-effective IRO-014, IRO-015, and IRO-016 are aimed at ensuring that reliability 

coordinators coordinate their actions with one another and act in the best interest of the 

interconnection as a whole. In addition, NERC explains that, under the Functional 

Model, the transmission operator is responsible for the real-time operation of the 

transmission system with the reliability coordinator providing oversight of the 

 37 Reliability Standard IRO-004-1, Requirement R2. 
Docket No. RM10-15-000 - 29 - 

transmission operator’s actions, directing additional or alternate actions when needed. 

NERC states that the requirements proposed in the new IRO Reliability Standards focus 

specifically on IROLs and are inclusive of any reliability implications due to parallel 

flows. 

50. In support of retiring Requirements R1 and R2 of IRO-004-1, NERC posits that 

under the Functional Model, the reliability coordinator is the functional entity with 

primary responsibility for IROLs and the transmission operator is the functional entity 

with primary responsibility for SOLs. NERC states that, under certain circumstances, the 

transmission operator may request the assistance of its reliability coordinator in 

developing an SOL but the responsibility for addressing the SOL remains with the 

transmission operator.38 NERC explains that, under the Functional Model and 

Requirement R11 of Reliability Standard TOP-002-2, the transmission operator is 

responsible for conducting analyses to identify where there may be instances of 

exceeding SOLs. NERC also states that, under TOP-008-1, the transmission operator is 

responsible for taking actions to either prevent or mitigate instances of exceeding SOLs. 

NERC states that, by contrast, it is the reliability coordinator that is responsible for 

ensuring that IROLs are developed for its reliability coordinator area in accordance with 

a methodology developed by the reliability coordinator. Further, NERC states that the 

transmission operator must share its SOLs with its reliability coordinator, and the 

 38 See Reliability Standard TOP-008-1, requiring transmission operators to take 

action to prevent or mitigate violations of SOLs. 
Docket No. RM10-15-000 - 30 - 

reliability coordinator must share any SOLs it develops with its transmission operator. 

NERC states that the reliability coordinator monitors the status of some, but not all, 

SOLs. 

51. NERC also contends that, upon proposed Reliability Standard IRO-009-1 

becoming effective, Requirements R3 and R6 of currently-effective IRO-004-0 should be 

retired. Under Requirement R3 of IRO-004-0, reliability coordinators must, in 

conjunction with its transmission operators and balancing authorities, develop action 

plans, including for reducing load to return transmission loading to within acceptable 

SOLs or IROLs. NERC states that the use of the phrase, “in conjunction with” is not 

supported by the responsibilities of the reliability coordinator in the Functional Model 

and would be inconsistent with the requirements of proposed Reliability Standard 

IRO-009-1. NERC also states that proposed Requirement R3 of IRO-009-1 includes 

language that is more explicit than the language in Requirement R6 of existing Reliability 

Standard IRO-004-1. 

52. Finally, NERC proposes to retire Requirements R4 and R5 from IRO-004-1. 

Requirement R4 requires each transmission operator, balancing authority, transmission 

owner, generator owner, generator operator, and load-serving entity in the reliability 

coordinator area to provide information required for system studies. NERC proposes to 

retire Requirement R4 because it identifies only a fraction of the reliability-related data 

needed by the reliability coordinator. Requirement R5 requires each reliability 

coordinator to share the results of its system studies with other reliability coordinators 

and transmission operators, balancing authorities, and transmission service providers 
Docket No. RM10-15-000 - 31 - 

within its reliability coordinator area. NERC states that proposed Reliability IRO-010-1a 

offers a suitable replacement for currently-effective Requirements R4 and R5 because 

IRO-010-1a requires reliability coordinators to know, in advance, what data and 

information it needs and what data and information it needs to share with other reliability 

entities. In addition, requirement R3 of proposed Reliability Standard IRO-008-1 would 

require the reliability coordinator to share the results of its analyses with entities within 

its reliability coordinator area. 

NOPR Proposal

53. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard IRO- IRO-004-2, as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. The Commission recognizes NERC’s efforts to 

more clearly define which functional entity has the ultimate responsibility for SOLs and 

IROLs, and to synchronize existing standards with the proposed new IRO Reliability 

Standards. We propose to find that the requirements proposed for retirement from 

IRO-004-1 are appropriately addressed in new Reliability Standards IRO-008-1, 

IRO-009-1, and IRO-010-1a. 

4. IRO-005-3

54. NERC proposes to retire Requirement R2, R3, R5, R16, and R17 of currentlyeffective Reliability Standard IRO-005-2, and to modify Requirements R9, R13, and 

R14. To implement these revisions, NERC requests Commission approval of proposed 

Reliability Standard IRO-005-3. The purpose of proposed Reliability Standard 

IRO-005-3 is to require the reliability coordinator to be continuously aware of conditions 
Docket No. RM10-15-000 - 32 - 

within its reliability coordinator area and include this information in its reliability 

assessments. In addition, the reliability coordinator must monitor the bulk electric system 

parameters that may have significant impacts upon the reliability coordinator area and 

neighboring reliability coordinator areas. IRO-005-3 would apply to reliability 

coordinators, balancing authorities, transmission operators, transmission service 

providers, generator operators, load-serving entities, and purchasing-selling entities. 

55. NERC contends that, upon the new IRO Reliability Standards becoming effective, 

Requirements R2, R3, R5, R16, and R17 of IRO-005-2 should be retired and 

Requirements R9, R13, and R14 should be modified. Except for Requirement R2, all of 

the requirements proposed for retirement set responsibilities for the reliability coordinator 

to be continuously aware of SOLs and IROLs within its reliability coordinator area and to 

identify the cause for each SOL and IROL. Similarly, all of the requirements proposed 

for modification include requirements for the reliability coordinator to address SOLs and 

for the transmission operator to address IROLs. NERC contends that these existing 

requirements should be retired or modified in light of the division of responsibilities 

between reliability coordinators and transmission operators expressed in new Reliability 

Standard IRO-009-1. 

56. Requirement R2 requires the reliability coordinator “to be aware of” all 

interchange transactions that wheel through its reliability coordinator area. NERC 

contends that it is not possible to measure how an entity is “aware of” specific 

information. In addition, NERC states that the e-tag system that has been implemented 

no longer requires the reliability coordinator to collect and relay interchange information 
Docket No. RM10-15-000 - 33 - 

to other entities. If a reliability coordinator needs this information, NERC states that the 

reliability coordinator can add this item to the list of data and information on its data 

specification under proposed Requirement R1 of IRO-010-1a. 

NOPR Proposal

57. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard IRO-005-3, as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. The Commission recognizes NERC’s efforts to 

more clearly define which functional entity has the ultimate responsibility for SOLs and 

IROLs, and to synchronize existing standards with the proposed new IRO Reliability 

Standards. We propose to find that the requirements of IRO-005-2 proposed for 

retirement and modification are appropriately addressed in new Reliability Standards 

IRO-008-1, IRO-009-1, and IRO-010-1a. 

5. TOP-003-1

58. NERC proposes to modify Requirement R1.2 of currently-effective Reliability 

Standard TOP-003-0. To implement this revision, NERC requests approval of proposed 

Reliability Standard TOP-003-1. The purpose of TOP-003-1 is to require balancing 

authorities, transmission operators, and reliability coordinators to plan and coordinate 

scheduled generator and transmission outages that may affect the reliability of 

interconnected operations. TOP-003-1 would apply to generator operators, transmission 

operators, balancing authorities, and reliability coordinators. 

59. NERC explains that Requirement R1.2 of TOP-003-0 includes two distinct 

activities – a requirement for the transmission operator to provide the reliability 
Docket No. RM10-15-000 - 34 - 

coordinator and other entities with daily outage information and a requirement for the 

reliability coordinator to establish outage reporting requirements. NERC contends that 

both elements of Requirement R1.2 are captured in proposed Reliability Standard 

IRO-010-1a. NERC proposes to remove the transmission operator’s obligation to 

provide daily outage information to reliability coordinators and strike the requirement for 

the reliability coordinator to establish outage reporting requirements. 

According to NERC, Requirement R1 of proposed IRO-010-1a requires the reliability 

coordinator to specify what data and information it needs, as well as the frequency and 

format for providing that data and information. NERC states that, because the reliability 

coordinator needs outage data for modeling and analysis, the specification will include 

outage data. Requirement R3 of IRO-010-1a requires entities to provide data and 

information to the reliability coordinator in accordance with the reliability coordinator’s 

specifications. NERC states that if TOP-003-0 Requirement R1.2 is not modified, it will 

be redundant with IRO-010-1a, Requirement R3. 

NOPR Proposal

60. Under section 215(d)(2) of the FPA, we propose to approve Reliability Standard 

TOP-003-1, as just, reasonable, not unduly discriminatory or preferential, and in the 

public interest. We propose to find that the requirements of currently-effective 

Reliability Standard TOP-003-0 that NERC proposed for modification are appropriately 

addressed in new Reliability Standard IRO-010-1a. However, under Requirement R3, it 

is incumbent on the reliability coordinator to request sufficient scheduled outage data. 

The Commission is concerned that IRO-010-1a does not specify outage coordination data 
Docket No. RM10-15-000 - 35 - 

and the reliability coordinator may not receive adequate outage coordination data to 

support the Operational Planning Analysis. Therefore, the Commission seeks comments 

from NERC and the public on whether IRO-010-1a should specify the necessary outage 

coordination data. 

6. TOP-005-2

61. NERC proposes to retire Requirements R1 and R1.1 of currently-effective 

Reliability Standard TOP-005-1 and modify Attachment 1 of the Reliability Standard. 

To implement these revisions, NERC requests approval of proposed Reliability Standard 

TOP-005-2. The purpose of TOP-005-2 is to ensure reliability entities have the operating 

data needed to monitor system conditions within their areas. TOP-005-2 would apply to 

transmission operators, balancing authorities, and purchasing selling entities. 

62. Requirement R1 of TOP-005-1 requires transmission operators to provide the 

reliability coordinator with the data and information that the reliability coordinator needs 

to perform its reliability-related tasks. Requirement R1.1 of TOP-005-1 requires 

reliability coordinators to identify the data requirements, listed in Attachment 1 of 

TOP-005-1, and any additional operating information requirements relating to the 

operation of the Bulk-Power System with its reliability coordinator area. NERC states 

that Requirement R1 implies that the reliability coordinator will limit its use of the data 

and information it collects to operations within its reliability coordinator area. According 

to NERC, this does not support the Functional Model, which requires the reliability 

coordinator to monitor the Wide-Area. NERC states that, under other Reliability 

Standards such as IRO-014-1 and IRO-015-1, each reliability coordinator is expected to 
Docket No. RM10-15-000 - 36 - 

coordinate the activities within its reliability coordinator area with other reliability 

coordinators. 

63. NERC states that, under proposed Reliability Standard IRO-010-1a, each 

reliability coordinator must document what data and information it needs and which 

entities must provide that data. NERC explains that the reliability coordinator needs this 

data to perform reliability assessments and for real-time monitoring. Under the 

Functional Model, the reliability coordinator collects data and information not just from 

transmission operators and balancing authorities, but also from generator operators, loadserving entities, transmission owners, and generator owners. 

64. NERC also proposes conforming revisions to Attachment 1 to TOP-005-2. As 

currently written, Attachment 1 of TOP-005-1 lists the types of data that reliability 

coordinators, balancing authorities, and transmission operators are expected to provide, 

and are expected to share with each other. Consistent with the proposed revisions in 

Reliability Standard TOP-005-2, NERC proposes to remove references to the reliability 

coordinator from Attachment 1. 

NOPR Proposal

65. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard TOP-005-2, as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. The Commission recognizes NERC’s efforts to 

more clearly define the reliability coordinator’s need to know, in advance, what data is 

needed, insure the timely availability of the data; and how that data will be 

communicated to other functional entities. We propose to find that the requirements of 
Docket No. RM10-15-000 - 37 - 

TOP-005-1 that are proposed for retirement are appropriately addressed in new 

Reliability Standard IRO-010-1a. We are concerned, however, about whether the 

proposal adequately ensures the compatibility of data between neighboring reliability 

coordinators. Having compatible data allows for an essential level of interoperability. 

The Commission requests comment from the reliability coordinators and the industry on 

whether a list of minimum “Electric System Reliability Data,” such as shown in 

Attachment 1 of currently-effective Reliability Standard TOP-005-1, is beneficial for 

reliability coordinators to meet the requirements of IRO-008-1 and IRO-009-1. 

7. TOP-006-2

66. NERC proposes to modify Requirement R4 of currently-effective Reliability 

Standard TOP-006-1. To implement this revision, NERC requests approval of proposed 

Reliability Standard TOP-006-2. The purpose of TOP-006-2 is to ensure critical 

reliability parameters are monitored in real-time. Its requirements would be applicable to 

transmission operators, balancing authorities, generator operators, and reliability 

coordinators. 

67. Requirement R4 of TOP-006-1 requires each reliability coordinator, transmission 

operator, and balancing authority to have information, including weather forecasts and 

past load patterns, available to predict the system’s near-term load pattern. NERC 

proposes to modify Requirement R4 by removing the reference to reliability coordinators. 

NERC states that the information identified in existing Requirement R4 of TOP-006-1 is 

not inclusive, and is addressed more globally for the reliability coordinator in 

Requirements R1 and R3 of the proposed new Reliability Standard IRO-010-1a. 
Docket No. RM10-15-000 - 38 - 

Proposed Requirement R1 of IRO-010-1a requires each reliability coordinator to have a 

documented specification for data and information to build and maintain models to 

support real-time monitoring, operational planning analyses, and real-time assessments of 

its reliability coordinator area to prevent instability, uncontrolled separation, and 

cascading outages. Requirement R3 of IRO-010-1a requires each balancing authority, 

generator owner, generator operator, interchange authority, load-serving entity, reliability 

coordinator, transmission operator, and transmission owner to provide data and 

information, as specified, to their reliability coordinator. 

NOPR Proposal

68. Under section 215(d)(2) of the FPA, the Commission proposes to approve 

Reliability Standard TOP-006-2, as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. The Commission recognizes NERC’s efforts to 

more clearly define the reliability coordinator’s need to know, in advance, what load 

forecast data is needed, the supporting data for the load forecast; and how that data will 

communicated to other functional entities. We propose to find that the reliability 

coordinator functions that are removed from Requirement R4 of TOP-006-2 are 

appropriately addressed in Requirements R1 and R3 of new Reliability Standard 

IRO-010-1a. 

D. Violation Severity Levels and Violation Risk Factors

69. In the event of a violation of a Reliability Standard, NERC will establish the initial 

value range for the corresponding base penalty amount. To do so, NERC will assign a 

violation risk factor for each requirement of a Reliability Standard that relates to the 
Docket No. RM10-15-000 - 39 - 

expected or potential impact of a violation of the requirement on the reliability of the 

Bulk-Power System. In addition, NERC will define 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. 

70. 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 

become effective.39 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. 

71. 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. 693.40 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 

 39 Facilities Design, Connections and Maintenance Reliability Standards, Order 

No. 705, 121 FERC ¶ 61,296, at P 137 (2007). 

40 Violation Severity Level Order, 123 FERC ¶ 61,284. 
Docket No. RM10-15-000 - 40 - 

ensure uniformity and consistency among all approved Reliability Standards in the 

determination of penalties;41 (3) violation severity level assignments should be consistent 

with the corresponding requirement; and (4) violation severity level assignments should 

be based on a single violation, not a cumulative number of violations.42 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. 

72. 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 the subject informational filing as a supplement to its 

March 5, 2010 Violation Severity Level Order compliance filing.43

 41 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. 

42 Violation Severity Level Order, 123 FERC ¶ 61,284 at P 17. 

43 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. RM10-15-000 - 41 - 

NERC Proposal

73. NERC proposes a complete set of violation severity levels and violation risk 

factors for proposed new Reliability Standards IRO-008-1, IRO-009-1, and IRO-010-1a. 

In addition, NERC proposes to apply the existing set of violation severity levels and 

violation risk factors assigned to the proposed modified requirements. 

74. NERC states that it developed the violation severity levels for the new IRO 

Reliability Standards before the Commission issued its June 19, 2008 order on violation 

severity levels.44 NERC also notes that the proposed violation severity levels were 

developed before NERC proposed a new methodology for assigning violation severity 

levels and violation risk factors.45 As a result, NERC states that some of the proposed 

violation severity levels do not comport with the Commission’s guidelines on violation 

severity levels and some do not comport with the NERC’s revised guidelines. NERC has 

identified differences and commits to propose revisions to the violation severity levels. 

NOPR Proposal

75. The Commission proposes to accept the proposed violation risk factors and 

violation severity levels presented in NERC’s petition. In addition, we propose to accept 

NERC’s commitment to review the proposed violation risk factors and violation severity 

 44 Id. 

45 NERC, Informational Filing Regarding the Assignment of Violation Risk 

Factors and Violation Severity Levels, Docket Nos. RM08-11-000, RR07-9-000, and 

RR07-10-000, (filed Aug. 10, 2009). 
Docket No. RM10-15-000 - 42 - 

levels to ensure compliance with the Commission’s guidelines. Accordingly, we propose 

to direct NERC to submit a compliance filing within six months of the effective date of 

the final rule in this proceeding that would provide the results of NERC’s review 

including any modifications necessary to comply with the Commission’s guidelines on 

violation risk factors and violation severity levels. 

76. The violation risk factors and violation severity levels for proposed new 

Reliability Standards IRO-008-1, IRO-009-1, and IRO-010-1a, and the proposed 

modified requirements also would be impacted by NERC’s revised guidelines for 

assigning violation severity levels currently pending before the Commission in Docket 

No. RR08-4-005. Subject to Commission action on NERC’s revised guidelines, NERC 

may need to make additional revisions to the proposed violation risk factors and violation 

severity levels. 

III. Information Collection Statement

77. The Office of Management and Budget (OMB) regulations require approval of 

certain information collection requirements imposed by agency rules.46 Upon approval 

of a collection(s) of information, OMB will assign an OMB control number and a

expiration date. Respondents subject to the filing requirements of this rule will not be 

penalized for failing to respond to these collections of information unless the collections 

of information display a valid OMB control number. The Paperwork Reduction Act 

n 

 46 5 C.F.R 1320.11. 
Docket No. RM10-15-000 - 43 - 

(PRA)47 requires each federal agency to seek and obtain OMB approval before 

undertaking a collection of information directed to ten or more persons, or continuing a 

collection for which OMB approval and validity of the control number are about to 

expire.48

78. The Commission is submitting these reporting and recordkeeping requirements to 

OMB for its review and approval under section 3507(d) of the PRA. Comments are 

solicited on the Commission’s need for this information, whether the information will 

have practical utility, the accuracy of provided burden estimates, ways to enhance the 

quality, utility, and clarity of the information to be collected, and any suggested methods 

for minimizing the respondent’s burden, including the use of automated information 

techniques.

79. This NOPR proposes to approve three new Reliability Standards, IRO-008-1, 

IRO-009-1 and IRO-010-1a governing reliability coordinator analyses, operational 

actions and data collection, which standards will replace parts of the currently-effective 

Reliability Standards EOP-001-0, IRO-002-1, IRO-004-1, IRO-005-2, TOP-003-0, 

TOP-005-1 and TOP-006-1 approved by the Commission in Order No. 693. Many of the 

proposed requirements are based requirements in currently-effective Reliability Standards 

and match common industry practice. Thus, this proposed rulemaking does not impose 

 47 44 U.S.C. 3501-20. 

48 44 U.S.C. 3502(3)(A)(i), 44 U.S.C. 3507(a)(3). 
Docket No. RM10-15-000 - 44 - 

entirely new burdens on the effected entities. With the exception of the addition of 

Interchange Authority as an applicable entity in IRO-010-1a, the currently-effective 

standards EOP-001-0, IRO-002-1, IRO-004-1, IRO-005-2, TOP-003-0, TOP-005-1 and 

TOP-006-1 require actions by the same applicable group of entities. IRO-010-1a clarifies 

for balancing authorities, generator owners, generator operators, interchange authorities, 

load-serving entities, reliability coordinators, transmission operators, and transmission 

owners shall provide data and information, as specified, to the reliability coordinator(s) 

with which it has a reliability relationship.49 The requirements of IRO-008-1 and 

IRO-009-a provide clarification from existing requirements, dictating the analysis and 

operational roles of the reliability coordinator. 

80. Public Reporting Burden: Our estimate below regarding the number of 

respondents is based on the NERC compliance registry as of September 28, 2010. 

According to the NERC compliance registry, there are 134 balancing authorities, 824 

generator owners, 773 generator operators, 61 interchange authorities, 541 load-serving 

entities, 26 reliability coordinators, 178 transmission operators, and 332 transmission 

owners that would be involved in providing information. However, under NERC’s 

compliance registration program, entities may be registered for multiple functions, and as 

such there is some duplication of functions regarding the number of registered entities 

that would be required to provide information. Given these parameters, the Commission 

 49 Proposed Reliability Standard IRO-010-1a, Requirement R3 
Docket No. RM10-15-000 - 45 - 

estimates that the Public Reporting burden for the requirements contained in the NOPR is 

as follows: 

Data 

Collection 

No. of 

Respondents 

No. of 

Annual 

Responses 

Hours Per 

Respondent 

Total Annual 

Hours 

FERC-725A 

Reliability 

Coordinators 

distribution of 

data 

specification to 

entities 

26 1* 8 208 

Balancing 

Authorities, 

Generator 

Owners, 

Generator 

Operators, 

Interchange 

Authorities, 

Load-serving 

Entities, 

Reliability 

Coordinators, 

Transmission 

Operators, and 

Transmission 

Owners 

reporting data 

to their 

Reliability 

Coordinator 

1501 1* 8 12,008 

Total 12,216 

*As needed 

 Total Annual hours for Collection: (Reporting + recordkeeping ) = hours. 

Information Collection Costs: The Commission seeks comments on the costs to 

comply with the reporting and recordkeeping burden associated with the proposed 
Docket No. RM10-15-000 - 46 - 

Reliability Standards. It has projected the average annualized cost to be the total annual 

hours 

Recordkeeping = 12,216 hours @ $120/hour = $1,465,920. 

 Total costs = $1,465,920. 

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

 Action: Proposed Collection of Information 

 OMB Control No: 1902-0244 

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

 Frequency of Responses: Annually, or as needed. 

 Necessity of the Information: This proposed rule would approve revised 

Reliability Standards that create new requirements for reliability coordinator 

responsibilities. The proposed Reliability Standards require entities to supply required 

data and information needed by the reliability coordinator. 

 Internal review: The Commission has reviewed the requirements pertaining to the 

proposed Reliability Standards for the Bulk-Power System and determined that the 

proposed requirements are necessary to meet the statutory provisions of the Energy 

Policy Act of 2005. These requirements conform to the Commission’s plan for efficient 

information collection, communication and management within the energy industry. The 

Commission has assured itself, by means of internal review, that there is specific, 

objective support for the burden estimates associated with the information requirements. 

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

contacting: Federal Energy Regulatory Commission, 888 First Street, NE, Washington, 
Docket No. RM10-15-000 - 47 - 

DC 20426 [Attention: Ellen Brown, Office of the Executive Director, Phone: 

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

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

Please reference docket number RM10-15-000 in your submission. 

IV. Environmental Analysis

82. 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.50 The actions proposed here fall within the categorical 

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

procedural, for information gathering, analysis, and dissemination.51 Accordingly, 

neither an environmental impact statement nor environmental assessment is required. 

V. Regulatory Flexibility Act Certification

83. The Regulatory Flexibility Act of 1980 (RFA)52 generally requires a description 

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

 50 Order No. 486, Regulations Implementing the National Environmental Policy 

Act, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. ¶ 30,783 (1987). 

51 18 C.F.R 380.4(a)(5). 

52 5 U.S.C. 601-12. 
Docket No. RM10-15-000 - 48 - 

number of small entities. The requirements of this rule would apply primarily to 

reliability coordinators, which do not fall within the definition of small entities.53 

Moreover, the proposed Reliability Standards reflect a continuation of existing 

requirements for reliability coordinators and other entities to monitor, analyze, prevent, 

and mitigate the occurrence of operating limit violations on the Bulk-Power System. The 

one exception is the proposed new requirements in Reliability Standard IRO-010-1a for 

interchange authorities, which also do not fall within the definition of small entities. 

Based on the foregoing, the Commission certifies that this proposed rule will not have a 

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

flexibility analysis is required. 

VI. Comment Procedures

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

issues proposed in this notice to be adopted, including any related matters or alternative 

proposals that commenters may wish to discuss. Comments are due [insert date that is 60 

days from publication in the FEDERAL REGISTER]. Comments must refer to Docket 

No. RM10-15-000, and must include the commenter's name, the organization they 

represent, if applicable, and their address in their comments. 

 53 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. RM10-15-000 - 49 - 

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

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

most standard word processing formats. Documents created electronically using word 

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

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

filing. 

86. Commenters unable to file comments electronically must mail or hand-deliver an 

original copy of their comments to: Federal Energy Regulatory Commission, Secretary 

of the Commission, 888 First Street, NE, Washington, DC 20426. These requirements 

can be found on the Commission’s website, see, e.g., the “Quick Reference Guide for 

Paper Submissions,” available at http://www.ferc.gov/docs-filing/efiling.asp or via phone 

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

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

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

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

on other commenters. 

VII. Document Availability

88. 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 
Docket No. RM10-15-000 - 50 - 

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

Washington DC 20426. 

89. 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. 

90. 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. 

List of subjects in 18 CFR Part 40

By direction of the Commission. 

( S E A L ) 

Kimberly D. Bose, 

Secretary.