136 FERC ¶ 61,186 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

[Docket No. RM10-6-000; Order No. 754] 

Interpretation of Transmission Planning Reliability Standard 

(Issued September 15, 2011) 

AGENCY: Federal Energy Regulatory Commission 

ACTION: Final Rule. 

SUMMARY: On November 17, 2009, the North American Electric Reliability 

Corporation (NERC) submitted a petition requesting approval of NERC’s interpretation 

of Requirement R1.3.10 of Commission-approved transmission planning Reliability 

Standard TPL-002-0 (System Performance Following Loss of a Single Bulk Electric 

System Element). In a March 2010 Notice of Proposed Rulemaking (NOPR), the 

Commission proposed to reject NERC’s proposed interpretation, and instead proposed an 

alternative interpretation of Requirement R1.3.10 of Reliability Standard TPL-002-0. As 

a result of the comments received in response to the proposal, the Commission declines 

to adopt the NOPR proposal and approves NERC’s proposed interpretation. In addition, 

as proposed by several commenters, the Commission directs NERC and Commission 

staff to initiate a process to identify any reliability issues, as discussed below. 

EFFECTIVE DATE: This rule will become effective 30 days after publication in the 

FEDERAL REGISTER. 

FOR FURTHER INFORMATION CONTACT: 
Docket No. RM10-6-000 - 2 - 

Ron LeComte (Legal Information) 

Office of General Counsel 

888 First Street, NE 

Washington, DC 20426 

ron.lecomte@ferc.gov 

Eugene Blick (Technical Information) 

Office of Electric Reliability 

888 First Street, NE 

Washington, DC 20426 

eugene.blick@ferc.gov 

Lauren Rosenblatt (Legal Information) 

Office of Enforcement 

888 First Street, NE 

Washington, DC 20426 

lauren.rosenblatt@ferc.gov 

SUPPLEMENTARY INFORMATION

:
136 FERC ¶ 61,186 

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. 

Interpretation of Transmission Planning Reliability 

 Standard 

Docket No. RM10-6-000 

ORDER NO. 754 

FINAL RULE 

(Issued September 15, 2011) 

1. On November 17, 2009, the North American Electric Reliability Corporation 

(NERC) submitted a petition requesting approval of NERC’s interpretation of 

Requirement R1.3.10 of Commission-approved transmission planning Reliability 

Standard TPL-002-0 (System Performance Following Loss of a Single Bulk Electric 

System Element). In a March 2010 Notice of Proposed Rulemaking (NOPR),1

 the 

Commission proposed to reject NERC’s proposed interpretation, and instead proposed an 

alternative interpretation of Requirement R1.3.10 of Reliability Standard TPL-002-0. As 

a result of the comments received in response to the proposal, the Commission declines 

to adopt the NOPR proposal and approves NERC’s proposed interpretation of 

Requirement R1.3.10 of Reliability Standard TPL-002-0. In addition, as proposed by 

 1 Interpretation of Transmission Planning Reliability Standards, 75 FR 14386 

(March 25, 2010), FERC Stats. & Regs. ¶ 32,655 (2010). 
Docket No. RM10-6-000 - 2 - 

several commenters, the Commission directs NERC and Commission staff to initiate a 

process to identify any reliability issues, as discussed below. 

I. Background

2. Section 215 of the Federal Power Act (FPA) requires a Commission-certified 

Electric Reliability Organization (ERO) to develop mandatory and enforceable 

Reliability Standards, which are subject to Commission review and approval.2

 

Specifically, the Commission may approve, by rule or order, a proposed Reliability 

Standard or modification to a Reliability Standard if it determines that the Standard is 

just, reasonable, not unduly discriminatory or preferential, and in the public interest.3

 

Once approved, the Reliability Standards may be enforced by the ERO, subject to 

Commission oversight, or by the Commission independently.4

3. Pursuant to section 215 of the FPA, the Commission established a process to select 

and certify an ERO,5

 and subsequently certified NERC.6 On April 4, 2006, NERC 

 2

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

3 Id. 824o(d)(2). 

4 Id. 824o(e)(3). 

5 Rules Concerning Certification of the Electric Reliability Organization; and 

Procedures for the Establishment, Approval and Enforcement of Electric Reliability 

Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, order on reh’g, Order 

No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006). 

6 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. RM10-6-000 - 3 - 

 

submitted to the Commission a petition seeking approval of 107 proposed Reliability 

Standards. On March 16, 2007, the Commission issued a final rule, Order No. 693,7

approving 83 of the 107 Reliability Standards, including transmission planning 

Reliability Standards TPL-001-0 through TPL-004-0. In addition, pursuant to section 

215(d)(5) of the FPA,8

 the Commission directed NERC to develop modifications to 56 of 

the 83 approved Reliability Standards, including TPL-002-0.9

4. NERC’s Rules of Procedure provide that a person that is “directly and materially 

affected” by Bulk-Power System reliability may request an interpretation of a Reliability 

Standard.10 In response, the ERO will assemble a team with relevant expertise to address 

the requested interpretation and also form a ballot pool. NERC’s Rules of Procedure 

provide that, within 45 days, the team will draft an interpretation of the reliability 

standard and submit it to the ballot pool. If approved by the ballot pool and subsequently 

by the NERC Board of Trustees, the interpretation is appended to the Reliability Standard 

and filed with the applicable regulatory authorities for approval. 

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

FERC Stats. & Regs. ¶ 31,242, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 

(2007). 

8

 16 U.S.C. 824o(d)(5). 

9

 Order No. 693, FERC Stats & Regs. ¶ 31,242 at P 1797. 

10 NERC Rules of Procedure, Appendix 3A, Reliability Standards Development 

Procedure, Version 6.1, at 27-29 (2010). 
Docket No. RM10-6-000 - 4 - 

II. Transmission Planning Reliability Standards

5. Each of the TPL Reliability Standards, TPL-001-0 through TPL-004-0, requires 

the planning authorities and transmission planners (planner) to provide a “valid 

assessment” that would “ensure that reliable systems are developed that meet specified 

performance requirements” both in the near-term (years one through five) and in the 

longer-term (years six through ten, or as needed). For each of these TPL Reliability 

Standards, entities must adequately assess a range of operating conditions on their 

systems and plan to meet certain performance criteria that the TPL Reliability Standards 

specify for each of four classes of contingencies.11 The principles that planners must 

apply to the design of the assessment and of the supporting studies are set forth in the 

Requirements of the specific TPL Reliability Standard. 

6. Table I, which is incorporated into each of the TPL Reliability Standards, sets 

forth the different types of contingencies that planners must study in conjunction with 

critical system conditions. The performance that must be met before and after 

experiencing those contingencies is also defined in the Table I, including reliably meeting 

all projected customer demand and firm transfers for Category B contingencies. 

 11 Reliability Standards TPL-001-0 through TPL-004-0 each includes the same 

Table I, titled “Transmission System Standards – Normal and Emergency Conditions,” 

which identifies the classes of contingencies as Category A through Category D. 

Reliability Standard TPL-002-0 addresses Category B contingencies. 
Docket No. RM10-6-000 - 5 - 

 

7. Requirement R1 of Reliability Standard TPL-002-0 states: 

R1. The Planning Authority and Transmission Planner shall each 

demonstrate through a valid assessment that its portion of the 

interconnected transmission system is planned such that the Network 

can be operated to supply projected customer demands and projected 

Firm (non-recallable reserved) Transmission Services, at all demand 

levels over the range of forecast system demands, under the 

contingency conditions as defined in Category B.[12] To be valid, 

the Planning Authority and Transmission Planner assessments shall: 

.... 

8. Requirement R1 proceeds with sub-Requirements R1.1 through R1.5, which 

provide the criteria that must be met to qualify the assessment directed by Requirement 

R1 as valid. In particular, Requirement R1.3 mandates that the assessment shall 

[b]e supported by a current or past study and/or system simulation 

testing that addresses each of the following categories, showing 

system performance following Category B. The specific elements 

selected (from each of the following categories) for inclusion in 

these studies and simulations shall be acceptable to the associated 

Regional Reliability Organization(s). 

12 Category B contingencies are defined in Table I of the Reliability Standard. 
Docket No. RM10-6-000 - 6 - 

Further, Requirement R1.3.10 requires the planner to 

[i]nclude the effects of existing and planned protection systems, 

including any backup or redundant systems. 

III. NERC Proposed Interpretation

9. In the NERC Petition, NERC explained that it received a request from PacifiCorp 

for an interpretation of Reliability Standard TPL-002-0, Requirement R1.3.10, addressing 

three specific questions. The PacifiCorp questions and NERC interpretations were as 

follows: 

Question 1: Does TPL-002-0 R1.3.10 require that all elements that 

are expected to be removed from service through normal operation 

of the protection systems be removed in simulations? 

Response 1: TPL-002-0 requires that System studies or simulations 

be made to assess the impact of single Contingency operation with 

Normal Clearing. TPL-002-0, R1.3.10 does require that all elements 

expected to be removed from service through normal operations of 

the Protection Systems be removed in simulations. 

Question 2: Is a Category B disturbance limited to faults with 

[N]ormal [C]learing where the protection system operates as 

designed in the time expected with proper functioning of the 

protection system(s) or do Category B disturbances extend to 

protection system misoperations and failures? 
Docket No. RM10-6-000 - 7 - 

Response 2: This standard does not require an assessment of the 

Transmission System performance due to a Protection System 

failure or Protection System misoperation. Protection System failure 

or Protection System misoperation is addressed in TPL-003-0 — 

System Performance following Loss of Two or More Bulk Electric 

System Elements (Category C) and TPL-004-0 — System 

Performance Following Extreme Events Resulting in the Loss of 

Two or More Bulk Electric System (BES) Elements (Category D). 

Question 3: Does TPL-002-0, R1.3.10 require that planning for 

Category B [C]ontingencies assume a [C]ontingency that results in 

something other than a [N]ormal [C]learing event even though the 

TPL-002-0 Table I - Category B matrix uses the phrase "SLG or 3-

Phase Fault, with Normal Clearing?” 

Response 3: TPL-002-0, R1.3.10 does not require simulating 

anything other than Normal Clearing when assessing the impact of a 

Single Line Ground (SLG) or 3-Phase (3Ø) Fault on the 

performance of the Transmission System.13

 13 NERC Petition at 10. In support for its request for an interpretation, PacifiCorp 

states that “[i]f TPL-002-0, R1.3.10 requires that planning for Category B Contingencies 

must assume failure or misoperation of all existing and planned protection systems, 

protection system failures previously identified as Category C [] Contingencies or 

Category D [] Contingencies would now become Category B Contingencies ....” Id. at 

Appendix A at 1-2. 
Docket No. RM10-6-000 - 8 - 

10. In support of its request for approval, NERC stated that the proposed interpretation 

directly supports the reliability purpose of TPL-002-0 because it clarifies what is required 

for the “System simulations” cited in the main requirement without expanding the reach 

of the standard.14 NERC maintained that the proposed interpretation clearly identifies 

what needs to be done – that all elements expected to be removed from service through 

normal operation of the protection system must be removed in simulations and that only 

normal clearing is required in the simulations. NERC stated that the proposed 

interpretation clearly distinguishes that misoperations and failures of the protection 

system are not part of Reliability Standard TPL-002-0, but are addressed in other 

standards. NERC stated that the interpretation will result in ensuring that an adequate 

level of reliability for the Bulk-Power System will be achieved and maintained by 

providing clarity and certainty in support of the objective. 

IV. Commission NOPR

11. The Commission proposed to reject NERC’s proposed interpretation and proposed 

an alternative interpretation. The Commission’s proposed interpretation would have 

required modeling of the non-operation of non-redundant primary protection systems to 

be in compliance with Requirement R1.3.10 of Reliability Standard TPL-002-0. In the 

NOPR, the Commission stated that a planner would perform an assessment of its portion 

of the interconnected transmission system through computer modeling and simulations, 

 14 Id. at 11. 
Docket No. RM10-6-000 - 9 - 

in which the planner first creates base cases. Using these base cases as a starting point, 

the planner then assesses the performance of the system and tests the base cases by 

subjecting them to various Category B Contingencies outlined in Table I with normal 

clearing. The Commission’s proposed interpretation would have found that Requirement 

R1.3.10 of TPL-002-0 requires planners to study, in their system assessments, the nonoperation of non-redundant primary protection systems in order to ascertain whether and 

how reliance on the as-designed backup or redundant protection systems affects 

reliability.15 

12. The Commission proposed that its interpretation of R1.3.10 of Reliability Standard 

TPL-002-0 would apply prospectively from the effective date of any Final Rule and no 

entity will be subject to financial penalties for having operated in a manner inconsistent 

with this proposed interpretation prior to the effective date of any Final Rule. 

V. Comments

13. Twenty-seven entities provided comments on the Commission’s proposed 

interpretation.16 Almost uniformly, comments support NERC’s proposed 

interpretation.17 In general, commenters18 state that the non-operation of a primary 

 15 Interpretation of Transmission Planning Reliability Standards, FERC Stats. & 

Regs. ¶

e, 

 others 

(continued...) 

 32,655, at P 15 (2010). 

16 A list of commenters is provided in Appendix 1. 

17 Commenters including NERC, Trade Associations (Edison Electric Institut

American Public Power Association, National Rural Electric Cooperative Association, 

Electric Power Supply Association, Transmission Access Policy Study Group, and 

Canadian Electricity Association), Florida Reliability Coordinating Council and
Docket No. RM10-6-000 - 10 - 

-

only 

er 

uld 

yed 

 

protection system is not studied under TPL-002-0, but rather under TPL-003-0 and TPL

004-0 as an unplanned event with delayed clearing.19 Commenters contend that 

planned protection system outages (maintenance outages) should be addressed und

TPL-002-0.20 In addition, commenters assert that the Commission’s interpretation wo

require the installation of fully redundant protection systems at an estimated cost of $24 

billion and require significant construction efforts spanning 10 to 20 years.21 

Commenters contend that TPL-002-0 relates to Normal Clearing and not Dela

Clearing in which a protection system failure has occurred or fails to operate. 

indicate support for NERC’s interpretation of Requirement R1.3.10 of TPL-002-0. In 

contrast, the International Transmission Companies (ITC) commented that the 

Commission’s proposal “establishes an additional level of good utility practice” and “is a 

reasonable and rational approach to evaluate system consequences, under Requirement 

R1.3.10 of TPL-002-0, regarding element outages and clearing times associated with 

non-operation of the primary protection system.” However, given the corrective actions 

that would be required to comply with the Commission’s proposal, ITC requests that the 

Commission allow an appropriate amount of time for compliance. 

18 See, e.g., NERC comments at 7-8; Trade Association Comments at 19-23. 

19 Planned outages are modeled as one of the base case conditions (categories) and 

studied to achieve the performance requirements of Category B (single contingencies), 

Table I. Protection system failures are addressed by performance requirements of 

Category C (two or more contingencies) and misoperations are addressed by Category D 

(extreme events). 

20 Requirement R.1.3.12 of TPL-002-0 requires the planner to consider the 

planned (including maintenance) outage of protection systems at demand levels for which 

such outages are performed. 

21 See Trade Associations comments at 31-34. 
Docket No. RM10-6-000 - 11 - 

14. NERC explains that the pre-2007 voluntary transmission planning standard was 

broken into four mandatory Version 0 Standards linked by the performance categories of 

Table I. Thus, according to NERC, some continuity was lost and, as a result, subrequirements such as Requirement R1.3.10 that appear in TPL-002-0 through TPL-004-0 

have very limited applicability in the context of TPL-002-0. NERC explains that 

Requirement R1.3.10 of TPL-002-0 is a valid requirement for judging system 

performance, but only in those cases where the system is being studied to determine its 

ability to perform when a given primary protection system or one of its components is out 

of service for maintenance (Requirement R1.3.12). 

A. Supplemental Comments

15. The Trade Associations submitted supplemental comments, with additional 

comments in support filed by NERC. The Trade Associations reiterate their request that 

the Commission approve, without change, NERC’s proposed interpretation of Reliability 

Standard TPL-002-0 Requirement R1.3.10. The Trade Associations also state that, based 

on outreach meetings with Commission staff, there may be a system protection issue that 

merits further exploration by technical experts. Thus, the Trade Associations suggest that 

the Commission take the following two actions. First, instruct Commission Reliability 

Staff to meet with NERC and its appropriate subject matter experts to: (a) explore Staff’s 

concerns and identify whether there is a further system protection issue warranting 

additional actions, and (b) if so, define the issue’s scope and assess its importance. The 

Trade Associations state such exchange of views among technical experts would be 

intended to facilitate the subject matter experts’ ability to recommend appropriate actions 
Docket No. RM10-6-000 - 12 - 

within NERC. Second, direct NERC to submit an informational filing within six months 

to explain its view as to whether there is a further system protection issue that needs to be 

addressed and if so, what forum and process should be used to address that issue and 

what priority it should be accorded relative to other reliability initiatives planned by 

NERC.22

16. NERC supports the Trade Associations’ proposal to give NERC, Commission 

staff, and technical experts the opportunity to further examine whether there may be a 

potential system protection issue that needs to be addressed. NERC states that it would 

make an informational filing with the Commission regarding whether there is a further 

system protection issue that needs to be addressed and if so, what forum and process 

should be used to address that issue and what priority it should be accorded relative to 

other reliability initiatives planned by NERC. 

17. NERC requests that the Commission approve the proposed interpretation of 

Reliability Standard TPL-002-0 Requirement R1.3.10, as filed. 

VI. Discussion

18. In the NOPR, the Commission proposed to find that Reliability Standard TPL002-0, Requirement R1.3.10 requires the study of the non-operation of non-redundant 

primary protection systems. Based on the comments received, the Commission accepts 

NERC’s interpretation of TPL-002-0, Requirement R1.3.10, that finds that the 

 22 Trade Associations Supplemental Comments at 3 (footnote omitted). 
Docket No. RM10-6-000 - 13 - 

requirement does not require the study of non-operation of non-redundant primary 

protection systems. Because we find NERC’s proposed interpretation to be just and 

reasonable, we, therefore, decline to adopt the NOPR proposal. 

19. We agree with the Trade Associations that there may be a system protection issue 

that merits further exploration by technical experts. The comments received in response 

to the Commission’s NOPR and Commission staff outreach discussions indicate that 

there may have been a misunderstanding that the Commission’s proposed interpretation 

would have established a full redundancy requirement for all primary protection systems. 

The Commission clarifies that it did not intend to require full redundancy. Rather, the 

Commission believes that there is an issue concerning the study of the non-operation of 

non-redundant primary protection systems; e.g., the study of a single point of failure on 

protection systems. The Commission agrees with commenters that this issue does not 

have to be addressed in TPL-002-0, Requirement R1.3.10. 

20. Accordingly, consistent with the supplemental comments of the Trade 

Associations, we direct Commission staff to meet with NERC and its appropriate subject 

matter experts to explore this reliability concern, including where it can best be 

addressed, and identify any additional actions necessary to address the matter. Further, 

we direct NERC to make an informational filing within six months of the date of the 

issuance of this Final Rule explaining whether there is a further system protection issue 

that needs to be addressed and, if so, what forum and process should be used to address 
Docket No. RM10-6-000 - 14 - 

that issue and what priority it should be accorded relative to other reliability initiatives 

planned by NERC.23

VII. Information Collection Statement

21. The Office of Management and Budget (OMB) regulations require that OMB 

approve certain reporting and recordkeeping (collections of information) imposed by an 

agency.

24 The information contained here is also subject to review under section 3507(d) 

of the Paperwork Reduction Act of 1995.25 

22. As stated above, the Commission previously approved, in Order No. 693, the 

Reliability Standard that is the subject of the current Final Rule. This Final Rule accepts 

an interpretation of the currently approved Reliability Standard and does not change this 

standard. The interpretation of the current Reliability Standard at issue in this final rule is 

not expected to change the reporting burden or the information collection requirements. 

The informational filing required of NERC is part of currently active collection FERC725 and does not require additional approval by OMB.26 

23. We will submit this final rule to OMB for informational purposes only. 

 23 This filing requirement has been approved by the Office of Management and 

Budget under FERC-725, OMB Control No. 1902-0225. This filing does not change the 

existing burden or reporting requirements imposed on NERC under FERC-725. 

24 5 CFR 1320.11. 

25 44 U.S.C. 3507(d). 

26 See supra n.23. 
Docket No. RM10-6-000 - 15 - 

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

contacting the following: Federal Energy Regulatory Commission, 888 First Street, 

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

e-mail: data.clearance@ferc.gov, phone: (202) 502-8663, or fax: (202) 273-0873]. 

VIII. Environmental Analysis

25. 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.27 The Commission has categorically excluded certain 

actions from this requirement as not having a significant effect on the human 

environment. Included in the exclusion are rules that are clarifying, corrective, or 

procedural or that do not substantially change the effect of the regulations being 

amended.28 The actions proposed herein fall within this categorical exclusion in the 

Commission’s regulations. 

IX. Regulatory Flexibility Act

26. The Regulatory Flexibility Act of 1980 (RFA) generally requires a descriptio

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 

29 n 

that 

 27 Regulations Implementing the National Environmental Policy Act of 1969, 

Order No. 486, FERC Stats. & Regs. ¶ 30,783 (1987). 

28 18 CFR 380.4(a)(2)(ii). 

29 5 U.S.C. 601-612. 
Docket No. RM10-6-000 - 16 - 

cant 

 is 

bility 

l not have a 

a substantial number of small entities. 

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

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

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

small business. 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. The RFA

not implicated by this Final Rule because the interpretation accepted herein does not 

modify the existing burden or reporting requirements. With no changes to the Relia

Standard as approved, the Commission certifies that this Final Rule wil

30

31

significant economic impact on 

X. Document Availability

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

Commission provides all interested persons an opportunity to view and/

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

(

, the 

or print the 

siness 

.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington DC 20426. 

 

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

hours (8:30 a.m. to 5:00 p

30 13 CFR 121.201. 

31 Id. n.1. 
Docket No. RM10-6-000 - 17 - 

28. 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. 

29. 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. 

XI. Effective Date and Congressional Notification

30. This final rule is effective 30 days from publication in Federal Register. The 

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

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

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

List of subjects in 18 CFR Part 40 

Applicability 

Mandatory Reliability Standards 

Availability of Reliability Standards 

By the Commission. 

( S E A L ) 

 

Kimberly D. Bose, 

Secretary. 
Docket No. RM10-6-000 - 18 - 

 

Appendix 1 

List of Commenters 

American Transmission Company LLC 

Avista Corporation 

Black Hills Power, Inc. 

Bonneville Power Administration 

Constellation Energy Group, Inc.32

Department of Interior, Office of Environmental Policy and Compliance 

Entergy Services, Inc. 

Exelon Corporation 

Florida Reliability Coordinating Council 

Independent Electricity System Operator and Hydro One Networks 

International Transmission Company33

ISO/RTO Council 

Kansas City Power & Light Company, KCP&L Greater Missouri Operations Company 

Manitoba Hydro 

Modesto Irrigation District 

National Grid 

New England States Committee on Electricity 

North American Electric Reliability Corporation 

Pacific Gas and Electric Company 

Public Power Council34

32 Baltimore Gas & Electric Company, Constellation Energy Commodities Group, 

Inc., Constellation Energy Control and Dispatch, LLC, Constellation NewEnergy, Inc., 

and Constellation Power Source Generation, Inc., and Constellation Energy Nuclear 

Group, LLC. 

33 ITCTransmission, Michigan Electric Transmission Company, LLC, ITC 

Midwest LLC, and ITC Great Plains, LLC. 

34 Public Power Council includes Washington Rural Electric Cooperative 

Association, Idaho Consumer-Owned Utilities Association, Oregon PUD Association, 

Northwest Public Power Association, Oregon Rural Electric Cooperative Association, 

PNGC Power, Western Public Agencies Group, Western Montana Electric G&T 

Cooperative, Inc., Oregon Municipal Electric Utilities Association, Washington PUD 

Association, Northwest Requirements Utilities. 
Docket No. RM10-6-000 - 19 - 

 

List of Commenters Continued 

Reliability First Corporation 

San Diego Gas & Electric Company 

Southern Company Services, Inc.35

Trade Associations36 

Tampa Electric Company 

Virginia Electric and Power Company, doing business as Dominion Virginia Power 

Wisconsin Electric Power Company 

35 Alabama Power Company, Georgia Power Company, Gulf Power Company, 

and Mississippi Power Company. 

36 The Trade Association includes the Edison Electric Institute, the American 

Public Power Association, Canadian Electricity Association, the National Rural Electric 

Cooperative Association, the Transmission Access Policy Study Group, and the Electric 

Power Supply Association.