133 FERC ¶ 61,227 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

Docket No. RM09-14-000 

Version One Regional Reliability Standard for Transmission Operations 

 

(December 16, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Proposed Rulemaking. 

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

Regulatory Commission (Commission) proposes to approve TOP-007-WECC-1 (System 

Operating Limits) developed by the Western Electric Coordinating Council (WECC) and 

submitted to the Commission for approval by the North American Electric Reliability 

Corporation. The revised regional Reliability Standard would replace the approved 

WECC TOP-STD-007-0. While we propose to approve the regional Reliability Standard, 

as discussed in this Notice of Proposed Rulemaking, TOP-007-WECC-1 raises some 

concerns about which the Commission requests additional information. The Commission 

also proposes to direct WECC to develop certain limited modifications to the regional 

Reliability Standard and the associated violation risk factor and violation severity levels 

as discussed herein. 

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

FEDERAL REGISTER]. 
Docket No. RM09-14-000 ii 

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

accordance with the requirements posted on the Commission’s website 

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-to-PDF format and not in a 

scanned format, at http://www.ferc.gov/docs-filing/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 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: 

Mindi Sauter (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6830 

E. Nick Henery (Technical Information) 

Office of Electric Reliability 

Division of Policy Analysis and Rulemaking 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8636 
Docket No. RM09-14-000 iii 

Danny Johnson (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8892 

SUPPLEMENTARY INFORMATION: 
 

133 FERC ¶ 61,227 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Version One Regional Reliability Standard for 

Transmission Operations 

Docket No. RM09-14-000 

NOTICE OF PROPOSED RULEMAKING 

(December 16, 2010) 

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

 the Commission proposes to 

approve TOP-007-WECC-1 (System Operating Limits) developed by the Western 

Electricity Coordinating Council (WECC) and 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 revised regional Reliability 

Standard, designated by WECC as TOP-007-WECC-1,3

 would replace WECC TOPSTD-007-0. While we propose to approve the regional Reliability Standard, we are 

concerned about certain provisions of TOP-007-WECC-1, about which we request 

additional information in public comment. The Commission also proposes to direct 

 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). 

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.” 
Docket No. RM09-14-000 - 2 - 

WECC to develop certain limited modifications to the regional Reliability Standard and 

the associated violation risk factor and violation severity levels as discussed herein. 

I. Background

A. Mandatory Reliability Standards

2. Section 215 of the FPA requires a Commission-certified Electric Reliability 

Organization (ERO) to develop mandatory and enforceable Reliability Standards, which 

are subject to Commission review and approval. Once approved, the Reliability 

Standards may be enforced by the ERO, subject to Commission oversight, or by the 

Commission independently.4

 

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

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

that region.5

 In Order No. 672, the Commission noted that: 

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

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

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

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

continent-wide Reliability Standard, including a regional difference that 

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

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

difference in the Bulk-Power System. 

When the ERO reviews a regional Reliability Standard that would be applicable on an 

interconnection-wide basis and that has been proposed by a Regional Entity organized on 

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

5

 16 U.S.C. 824o(e)(4). A Regional Entity is an entity that has been approved by 

the Commission to enforce Reliability Standards under delegated authority from the 

ERO. See 16 U.S.C. 824o(a)(7) and (e)(4). 
Docket No. RM09-14-000 - 3 - 

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

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

the public interest.6

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

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

basis.7

B. WECC Regional Reliability Standards

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

NERC and each of eight Regional Entities.8

 In the order, the Commission accepted 

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

Entity, WECC oversees Bulk-Power System reliability in the Western Interconnection. 

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

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

portion of Baja California in Mexico. 

5. In June 2007, the Commission approved eight regional Reliability Standards that 

apply in the Western Interconnection, including WECC TOP-STD-007-0.9

 Currently 

effective WECC TOP-STD-007-0 has the stated purpose of ensuring that the Western 

Interconnection’s operating transfer capability limits requirements are not exceeded. In 

 6

 16 U.S.C. 824o(d)(3). 

7

 16 U.S.C. 824o(d)(2). 

8 North American Electric Reliability Corp., 119 FERC ¶ 61,060 (2007). 

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

2007 Order). 
Docket No. RM09-14-000 - 4 - 

approving the current regional Reliability Standard, the Commission found that it was 

more stringent than the corresponding NERC TOP-007-0. The Commission noted that, 

“[i]n particular, the imposition of a 20-minute limit [maximum for exceeding a stabilitylimited operating transfer capability] is more restrictive than NERC’s TOP-007-0 and is a 

prudent means of limiting the risk of blackouts, consistent with sound engineering 

principles.”10 

6. In the June 2007 Order, the Commission also expressed concern that WECC-TOP007-0 may be inconsistent with NERC IRO-005-1 depending upon the interpretation of 

IRO-005-1.11 Previously, in Order No. 693, the Commission discussed the possibility 

that NERC IRO-005-1 could be interpreted as allowing a system operator to respect 

interconnection reliability operating limits in two different ways.12 In the June 2007 

Order, the Commission noted that the wording of WECC-TOP-007-0 Requirement 

WR1.b, which provides that “[t]he interconnected power system shall remain stable upon 

loss of any one single element without system cascading that could result in the 

successive loss of additional elements,” suggests that WECC expects that stability-

 10 Id. P 104. 

11 Id. P 105-110. 

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

FERC Stats. & Regs. ¶ 31,242, at P 946 (2007), order on reh’g, Order No. 693-A, 

120 FERC ¶ 61,053 (2007). The Commission explained, “IRO-005-1 could be 

interpreted as allowing a system operator to respect IROLs in two possible ways: 

(1) allowing IROL to be exceeded during normal operations, i.e., prior to a contingency, 

provided that corrective actions are taken within 30 minutes or (2) exceeding IROL only 

after a contingency and subsequently returning the system to a secure condition as soon 

as possible, but no longer than 30 minutes. Thus, the system can be one contingency 

away from potential cascading failure if operated under the first interpretation and two 

contingencies away from cascading failure under the second interpretation.” Id. at n.303. 
Docket No. RM09-14-000 - 5 - 

limited system operating limits will be addressed in such a manner that the system is two 

contingencies away from a cascading failure. The Commission noted, however, that 

Measure WM1 of WECC-TOP-007-0 may not be consistent with Requirement WR1.b, 

since it states that “[a]ctual power flow on all transmission paths shall at no time exceed 

the [operating transfer capability] for more than 20 minutes for paths that are stability 

limited, or more than 30 minutes for paths that are thermally limited.”13 The 

Commission further stated that the Measure appears more consistent with the less 

conservative interpretation of the NERC IRO-005-1 and could allow the power system to

be operated one contingency away from a cascading outage. Thus, the Commission 

directed NERC and WECC to: (1) submit a filing within 30 days of the date of the or

explaining whether Requirement WR1.b is consistent with the second interpretation of 

NERC IRO-005-1 (two contingencies away from cascading failure); (2) clarify any 

inconsistency between Requirement WR1.b and corresponding Measure WM1; and (3) 

ensure that the requirements currently set forth in Measures WM1 are set forth in t

Standard’s Requirements and that corresponding Measures simply quantify the 

frequency, duration and magnitude of the violations as determined by th

der 

he 

e 

PSTD-007-0 to address certain shortcomings identified by NERC with regard to such 

matters as format, aligning WECC regional definitions with the NERC Glossary of 

 

Requirements.14 

7. The Commission also directed WECC to develop modifications to WECC-TO

13 North American Electric Reliability Corp., 119 FERC ¶ 61,260 at P 107. 

14 Id. P 108-109. 
Docket No. RM09-14-000 - 6 - 

Terms Used in Reliability Standards, and removing compliance and measure 

references.15

8. In response, NERC submitted a compliance filing (Compliance Filing) on 

July 9, 2007.16 NERC explained that “a WECC reliability coordinator must take 

immediate action, initially through the transmission operators, and then issues directives, 

to return the system to a secure condition as soon as possible after identification of a 

transfer path exceeding its SOL/IROL” in accordance with WECC procedure RC-003-1, 

entitled WECC Reliability Coordinator Monitoring and Directive Procedure.17 NERC 

continued, stating that “WECC operates its system in such a manner that the system is at 

least two contingencies away from a cascading failure.” NERC further explained that, 

there is no inconsistency between IRO-005-1 and WECC-TOP-STD-007-0. 

In order to support Requirement WR1.b in the WECC-TOP-STD-007-0 

regional Reliability Standard, the system cannot be operated such that a 

single contingency will cause cascading of the system. This is implicit in 

the identification of the [operating transfer capability] limit derivation. If, 

however, there is a flow that exceeds the [operating transfer capability] 

limit, the transmission operator must take (proactive) immediate corrective 

action within 20 minutes for stability-limited paths and 30 minutes for 

thermally limited paths to return the system to below the [operating transfer 

capability] limit, thus protecting the system from potential cascading for a 

subsequent contingency.18 

 15 Id. P 55, 110. 

16 North American Electric Reliability Corp., Compliance Filing, Docket 

No. RR07-11-000 (filed July 9, 2007). 

17 Id. at 5. 

18 Id. at 8 
Docket No. RM09-14-000 - 7 - 

Proposed WECC Regional Reliability Standard TOP-007-WECC-1

9. On March 25, 2009, NERC submitted a petition to the Commission seeking 

approval of proposed TOP-007-WECC-1 and requesting the concurrent retirement of the 

currently effective TOP-STD-007-0.19 NERC requests an effective date for the proposed 

regional Reliability Standard of 90 calendar days after receipt of applicable regulatory 

approval. 

10. Proposed TOP-007-WECC-1 would apply to transmission operators for the 

transmission paths in the most current table titled “Major WECC Transfer Paths in the 

Bulk Electric System” (WECC Transfer Path Table) located on the WECC website.20 

NERC states that the primary purpose of the regional Reliability Standard is to ensure 

that actual flows and associated scheduled flows on Major WECC Transfer Paths do not 

exceed system operating limits for more than 30 minutes. 

11. NERC states that the proposed regional Reliability Standard satisfies the factors, 

set forth in Order No. 672, that the Commission considers when determining whether a 

proposed Reliability Standard is just, reasonable, not unduly discriminatory or 

 19 North American Reliability Corp., March 25, 2009 Petition for Approval of 

Proposed Western Electric Coordinating Council Regional Reliability Standard TOP007-WECC-1 (NERC Petition). 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. RM09-14-000 and are available on the ERO’s website, 

www.nerc.com. 

20 See WECC Transfer Path Table, available at: 

www.wecc.biz/Docs/Documents/Table%20Major%20Paths%204-28-08.doc. The 

Transfer Path Table includes a footnote that provides, “[f]or an explanation of terms, 

path numbers, and definition for the paths refer to WECC’s Path Rating Catalog.” 
Docket No. RM09-14-000 - 8 - 

preferential and in the public interest.21 According to NERC, proposed TOP-007-

WECC-1 is clear and unambiguous regarding what is required and who is required to 

comply with the Standard. NERC states that proposed TOP-007-WECC-1 has clear and 

objective measures for compliance and achieves a reliability goal (namely, that operating 

power flows along major paths are within not only interconnection reliability operating 

limits but also system operating limits) effectively and efficiently. NERC also states that 

the requirements proposed in TOP-007-WECC-1 are not covered by a NERC Reliability 

Standard and are intended to be more stringent than or cover areas not covered by the 

continent-wide NERC Reliability Standard TOP-007-0. NERC also notes that its public 

posting of the proposed regional Reliability Standard did not elicit any significant 

technical objection.22 

12. Proposed TOP-007-WECC-01 contains two requirements and one subrequirement, summarized as follows: 

Requirement R1: requires a transmission operator of a major WECC transfer 

path to take immediate action to return actual flows that are in excess of the path’s system 

operating limits to within the system operating limits in no longer than 30 minutes. 

Requirement R2: requires a transmission operator of a major WECC transfer 

path to ensure that the net scheduled interchange across the path does not exceed the 

 21 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, at P 323-337 (2006), order on 

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

22 NERC Petition at 9. 
Docket No. RM09-14-000 - 9 - 

path’s system operating limits, when the transmission operator implements its real-time 

schedules for the next hour. 

Sub-requirement R2.1: requires a transmission operator of a major WECC 

transfer path to adjust the net scheduled interchange across the path within 30 minutes so 

that it does not exceed the path’s new system operating limit value if the system 

operating limit decreases within 20 minutes before the start of the hour. 

13. In the Petition, NERC asserts that the proposed regional Reliability Standard 

covers matters not covered by a NERC Reliability Standard and is more stringent than the 

corresponding continent-wide Reliability Standard, TOP-007-0. NERC explains: 

Whereas, NERC Reliability Standard TOP-007-0 – Reporting SOL and 

IROL Violations Requirement R2 requires the Transmission Operator to 

return its transmission path flows to within Interconnection Reliability 

Operating Limits (“IROLs”) as soon as possible, but no longer than 30 

minutes following a contingency or event, TOP-007-WECC-1 Requirement 

R1 requires the Transmission Operator of the major WECC transfer paths 

to take immediate action to return the actual power flow to within [system 

operating limits] such that at no time shall the power flow exceed the 

[system operating limits] for longer than 30 minutes. There is no NERC 

requirement to return the transmission system to within [system operating 

limits] within a time certain, only a requirement to report to the Reliability 

Coordinator (TOP-007-0 Requirement R1). Depending on the current 

system conditions, the limits for the paths identified in this TOP-007-

WECC-1 standard are [system operating limits]s that would not result in 

cascading outages. TOP-007-WECC-1 specifically applies to the major 

paths in the Western Interconnection regardless of whether the limit is 

defined as an IROL or an [system operating limits]. TOP-007-WECC-1 

Requirement R2 requires the Transmission Operator of the major WECC 

transfer paths to ensure that Net Scheduled Interchange for power flow over 

an interconnection or transmission path does not exceed the path’s [system 

operating limits] when the Transmission Operator implements its real-time 

schedules for the next hour. The requirement for maintaining Net 

Scheduled Interchange within a path’s [system operating limits] is also not 

covered in the NERC Reliability Standards. This requirement is important 

to the Western Interconnection because scheduling transmission paths 
Docket No. RM09-14-000 - 10 - 

beyond their limits could adversely affect actual flows on parallel paths by 

creating unscheduled flow that may jeopardize system reliability.23

14. NERC also provides, as Exhibit C to the NERC Petition, a Record of 

Development of Proposed Reliability Standard. Included in the approximately 100-page 

development record is a “mapping document” prepared by the WECC standards drafting 

team that compares the related provisions of the currently-effective regional Reliability 

Standard to the modified Standard and discusses the “proposed change and impact.”24 

II. Discussion

15. Pursuant to FPA section 215(d)(2), we propose to approve TOP-007-WECC-1 as 

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

indicated above, the proposed TOP-007-WECC-1 appears to cover topics not covered by 

the corresponding NERC Reliability Standard, TOP-007-0, thus meeting a criterion for 

approving a regional difference. Specifically, Requirement R1 would require the 

transmission operator of a major WECC transfer path to take immediate action to return 

the actual power flow to within system operating limits such that at no time shall the 

power flow exceed the system operating limits for longer than 30 minutes. While the 

NERC Reliability Standards do have a requirement to report exceeding system operating 

limits to the reliability coordinator, they do not have a requirement to return the 

transmission system to within system operating limits within a time certain. Likewise, 

proposed Requirement R2 of the regional Reliability Standard would prohibit the 

 23 NERC Petition at 11-12 (footnote omitted). 

24 See NERC Petition, Exhibit C, Comparison of WECC Standard TOP-STD-007-

0 to proposed WECC Standard TOP-007-WECC-1, beginning at page 86 of the NERC 

Petition as it appears in the Commission’s eLibrary pdf document. 
Docket No. RM09-14-000 - 11 - 

transmission operator from having the net scheduled interchange for power flow over an 

interconnection or transmission path above the path’s system operating limit when the 

transmission operator implements its real-time schedules for the next hour, while there 

currently is no such requirement in a NERC Standard. In addition to these stringencies, 

the proposed regional Reliability Standards addresses modifications directed by the 

Commission in the June 2007 Order. For these reasons, the Commission proposes to 

approve TOP-007-WECC-1. 

16. However, below, we ask WECC, the ERO and other interested entities to provide 

further clarification regarding several aspects of the proposed regional Reliability 

Standard. Our intent in seeking comments is to better understand certain aspects of the 

proposed regional Reliability Standard that are not fully explained in the NERC Petition. 

Specifically, we request in comments additional information about the following 

concerns: (1) whether the proposed regional Reliability Standard would allow 

transmission operators to operate the system at a single contingency away from cascading 

failure for up to 30 minutes; (2) the change in the time allowed to respond to a stabilitylimited system operating limit violation from 20 to 30 minutes; (3) the substitution of the 

term “system operating limit” for the term “operating transfer capability”; and 

(4) replacement of the WECC Transfer Path Table attachment to the regional Reliability 

Standard with an internet link. The Commission also proposes to direct WECC to 

develop certain limited modifications to the regional Reliability Standard and the 

associated violation risk factor and violation severity levels as discussed herein. 
Docket No. RM09-14-000 - 12 - 

A. Operating One Contingency Away from a Cascading Outage

17. As discussed above, when approving TOP-STD-007-0, the Commission noted its 

concern that Measure WM1 may be interpreted in a way that is less stringent than the 

NERC IRO-005-1, which, in turn, could allow the system to be operated one contingency 

away from a potential cascading failure.25 NERC explained in its July 2007 Compliance 

Filing that, under Requirement WR1.b of TOP-STD-007-0, transmission operators must 

operate the system in a manner that it is at least two contingencies away from cascading 

at all times during steady state operating conditions.26 

Proposed Regional Reliability Standard

18. Requirement R1 of TOP-007-WECC-1 states, “[w]hen the actual power flow 

exceeds an [system operating limit] for a Transmission path, the Transmission Operators 

shall take immediate action to reduce the actual power flow across the path such that at 

no time shall the power flow for the Transmission path exceed the [system operating 

limit] for more than 30 minutes.” NERC notes that the corresponding NERC Reliability 

Standard, TOP-007-0 does not currently cover this requirement, explaining that NERC 

TOP-007-0 does not require the transmission operators to return the transmission system 

to within system operating limits within a time certain. Therefore, the proposed TOP007-WECC-1 appears to meet a criterion for approving a regional difference. The 

proposed TOP-007-WECC-1 does not include the provision of current Requirement 

WR1, which, in TOP-STD-007-0, requires that “[t]he interconnected power system shall 

 25 North American Electric Reliability Corp., 119 FERC ¶ 61,260 at P 108. 

26 Compliance Filing at 4. 
Docket No. RM09-14-000 - 13 - 

remain stable upon loss of any one single element without system cascading that could 

result in the successive loss of additional elements.” The mapping document included 

within Exhibit C to the Petition explains that the provision was eliminated because 

“inclusion would be redundant with similar criteria in other NERC standards,” such as 

NERC FAC-011 (including Regional Differences 1.1 and 1.2), FAC-014, and TOP-004. 

Commission Concerns

19. A plain reading of the proposed regional Reliability Standard’s Requirement R1 

does not explicitly require a transmission operator to operate the system in a manner that 

is two contingencies from a cascading outage. Specifically, Requirement R1 appears to 

allow the power flow, during steady state conditions, to exceed a stability-limited system 

operating limit for up to 30 minutes, which could mean that the system would be one 

contingency away from a cascading failure for that period of time. Although WECC 

clarified in its July 2007 Compliance Filing that the WECC transmission grid must be 

operated such that no cascading occurs following a single contingency, the proposed 

Reliability Standard does not re-affirm this understanding. Indeed, the proposed regional 

Reliability Standard could be interpreted as affirmatively permitting the power system to 

be operated one contingency away from a cascading outage, which is the same concern 

the Commission raised with respect to the current regional Reliability Standard. Our 

concern is heightened when Requirement R1 is considered in conjunction with the NERC 

TOP-004, Requirement R2, which states that “[e]ach Transmission Operator shall operate 

so that instability, uncontrolled separation, or cascading outages will not occur as a result 

of the most severe single contingency.” Read in this light, the proposed revision to the 
Docket No. RM09-14-000 - 14 - 

language currently contained in Requirement WR1 of TOP-STD-007-0 could result in 

transmission operators having two apparently conflicting sets of operational 

requirements. Specifically, the national Reliability Standard prohibits operating a single 

contingency away from cascading outage while the proposed regional Reliability 

Standard seems to permit such operation. The Commission requests comments on this 

issue. 

B. Change in Response Time From 20 to 30 Minutes 

20. TOP-STD-007-0 provides that transmission operators shall return actual flows to 

within the path’s operating transfer capability ratings in no more than 20 minutes on 

stability-limited paths, and within 30 minutes for thermally-limited paths. When NERC 

filed TOP-STD-007-0 for Commission approval, WECC explained that the 20 minute 

time limit for responding to stability-limited operating transfer capability exceedances 

was based on the lessons learned in the two major disturbances in 1996.27 The 

Commission notes that in the Western Interconnection a significant number of 

transmission paths are voltage or frequency stability limited, in contrast to other regions 

of the Bulk-Power System where transmission paths more often are thermally limited.28 

21. Transmission operators generally need to respond to disturbances that result in a 

 27 See North American Electric Reliability Corp., 119 FERC ¶ 61,260 at P 102. 

28 A stability limit is determined by a voltage or frequency stability constraint, and 

loading the line above this limit for any amount of time could result in instability and 

cascading outages. A thermal limit is determined by how much a line can overheat 

without damaging equipment; lines that are thermally-limited can have short-term 

emergency limits that are higher than the normal line rating, since heating occurs over a 

period of time. 
Docket No. RM09-14-000 - 15 - 

“stability-limited” transmission path overload in a shorter time frame than a disturbance 

that results in a “thermally-limited” transmission path overload because the stabilitylimited risk is more systemic in nature. The requirement to bring the power flow across a 

stability-limited transmission path to within the path’s operating transfer capability rating 

within 20 minutes following a disturbance improves reliability by decreasing the 

likelihood that the Bulk-Power System will be operated a single contingency away from a 

cascading outage, thus preventing adverse reliability impacts, as following a disturbance.

Proposed Regional Reliability Standard 

22. The proposed revised regional Reliability Standard would replace the 20-minute 

limit for returning actual flows on stability-limited paths to within system operating limit 

ratings with a 30-minute limit. In its Petition, NERC indicates that the first draft of the 

proposed regional Reliability Standard included the differing time limits (20/30 minutes) 

to return to within system operating limit, but that comments indicated that the 10 minute 

difference was not based on any technically sound reasoning and would create an 

additional operational step to determine the cause of the limit before taking corrective 

action. The Petition further indicates that, based on these comments, the drafting team 

modified the proposed regional Reliability Standard to have one consistent 30 minute 

limit for returning actual flows to within both thermally and stability-limited system 

operating limits. 

23. In its evaluation of the proposed regional Reliability Standard, NERC’s general 

observation was that proposed TOP-007-WECC-1 was significantly modified from TOPSTD-007-0. Specifically, NERC commented to WECC on the technical modification of 
Docket No. RM09-14-000 - 16 - 

the requirement that the actual power flow on all transmission paths shall at no time 

exceed the operating transfer capability for more than 20 minutes for paths that are 

stability limited or for more than 30 minutes for paths that are thermally limited.29 

NERC stated that it was unclear whether the proposed requirement was more stringent 

than the NERC requirements.30 

 

24. In response to NERC’s evaluation, WECC stated that the currently-effective 

regional Reliability Standard creates confusion because system conditions may change 

the limiting conditions on a path, and this resulted in path operators taking “more drastic 

actions” to respond to a contingency within 20 minutes, which may put the system at 

greater risk. WECC indicated that the standard drafting team determined that changing 

the Standard from a 20 to 30 minute response time is “insignificant in terms of the 

probability of the next contingency occurring.”31 

25. NERC’s Petition states that NERC TOP-007-0 does not contain a requirement that 

transmission operators reduce actual flows to within thermally-limited system operating 

limits within 30 minutes. Thus, according to NERC, the change from 20 to 30 minutes 

does not constitute a lowest common denominator approach, but rather provides clarity 

and eliminates the need to determine the limiting condition when a contingency occurs, 

thereby allowing transmission operators to concentrate on resolving the overload 

condition. 

29 NERC Petition at 27-28. 

30 Id. 

31 Id. at 28. 
Docket No. RM09-14-000 - 17 - 

Commission Concerns

26. The Commission seeks additional information to assess whether increasing the 

time to respond to stability-limited system operating limit violations will affect the 

reliable operation of the Western Interconnection. As the Commission previously has 

noted, we will evaluate such proposed changes, including those that may make a standard 

less stringent, on their merit so long as adequate reliability is maintained.32 In this case, 

the Commission is proposing to approve TOP-007-WECC-1; however, the technical 

information provided in the record to date does not demonstrate to our satisfaction that 

the proposed regional Reliability Standard is sufficient to ensure reliability in the WECC 

region. 

27. Therefore, we request that WECC, NERC and other interested entities provide in 

their comments an explanation and supporting technical data demonstrating that changing 

from a 20 to 30 minute response time is “insignificant in terms of the probability of the 

next contingency occurring.”33 For example, WECC could provide historical outage data 

showing instances where an event caused a stability-limited operating transfer limit to be 

exceeded, the amount of time it took the transmission operator to reduce flows and, if the 

transmission operator did not reduce flows within 20 minutes, whether a second 

contingency occurred after the 20 minutes. WECC also could provide information or 

data demonstrating that the WECC region has added facilities to reduce the number of 

 32 Version One Regional Reliability Standard for Resource and Demand 

Balancing, 133 FERC ¶ 61,063 at P 30 (2010). 

33 NERC Petition at 28. 
Docket No. RM09-14-000 - 18 - 

stability- limited “rated transfer paths;” the WECC region has adopted new operational 

procedures or new protection schemes; or statistical operating data showing that the 20 

minute response time was excessive for the Bulk-Power System in the West. 

28. Additionally, based on the current record provided by NERC, we are not 

persuaded by the explanation that the current Reliability Standard’s bifurcated response 

times cause confusion. We understand that, in practice, a transmission operator in the 

Western Interconnection can use the WECC Path Rating Catalog34 to determine if a rated 

system path is either thermally or stability limited for baseline system configurations 

shown in the Catalog, and will have previously determined operating limitations based on 

previously conducted contingency studies. The “WECC Philosophy of SOL and IROL 

Conditions” states that WECC’s operating philosophy is to only operate in conditions that 

have been studied.35 In fact, during the Reliability Standard development process, one 

commenter stated that: “[t]oday, we can tell if the 20 or 30 minutes applies based on the 

statements in the Path Rating Catalog, which classify each of the Paths as either stability 

limited or thermally limited.”36 

 34 As mentioned previously, the WECC Path Rating Catalog is referenced in a 

footnote in Table 1 of the currently-effective regional Reliability Standard. 

35 WECC Philosophy of SOL & IROL Conditions, available at 

http://www.wecc.biz/committees/StandingCommittees/OC/OPS/Lists/Calendar/Attachme

nts/8/WECC%20Philosophy%20of%20SOL-IROL.pdf. 

36 NERC Petition, Exhibit C at page 50 of the NERC Petition as it appears in the 

Commission’s eLibrary pdf document (Sierra Pacific Resources Transmission comments 

to WECC). 
Docket No. RM09-14-000 - 19 - 

C. System Operating Limit versus Operating Transfer Capability

29. TOP-STD-007-0 has the stated purpose of ensuring that “the Operating Transfer 

Capability limits requirements of the Western Interconnection are not exceeded.” The 

regional Reliability Standard defines operating transfer capability as “the maximum value 

of the most critical system operating parameter(s) which meets: (a) precontingency 

criteria as determined by equipment loading capability and acceptable voltage conditions, 

(b) transient criteria as determined by equipment loading capability and acceptable 

voltage conditions, (c) transient performance criteria, and (d) post-contingency loading 

and voltage criteria.” 

30. The single requirement of TOP-STD-007-0 provides in part: 

Actual power flow and net scheduled power flow over an interconnection 

or transfer path shall be maintained within Operating Transfer Capability 

Limits (“OTC”). The OTC is the maximum amount of actual power that 

can be transferred over direct or parallel transmission elements comprising: 

• An interconnection from one Transmission Operator area to 

another Transmission Operator area; or 

• A transfer path within a Transmission Operator area. 

The net schedule over an interconnection or transfer path within a 

Transmission Operator area shall not exceed the OTC, regardless of the 

prevailing actual power flow on the interconnection or transfer path. 

31. The NERC Glossary defines “System Operating Limit” as “the value (such as 

MW, MVar, Amperes, Frequency or Volts) that satisfies the most limiting of the 

prescribed operating criteria for a specified system configuration to ensure operation 

within acceptable reliability criteria. System Operating Limits are based upon certain 

operating criteria. These include, but are not limited to: 
Docket No. RM09-14-000 - 20 - 

 Facility Ratings (Applicable pre- and post-Contingency equipment or facility 

ratings) 

 Transient Stability Ratings (Applicable pre- and post-Contingency Stability 

Limits) 

 Voltage Stability Ratings (Applicable pre- and post-Contingency Voltage 

Stability) 

 System Voltage Limits (Applicable pre- and post-Contingency Voltage Limits).” 

NERC Petition

32. As mentioned above, proposed TOP-007-WECC-1 has the stated purpose of 

ensuring that “when actual flows on Major WECC Transfer Paths exceed system 

operating limits (SOLs), their associated schedules and actual flows are not exceeded for 

longer than a specified time.” Requirement R1 of the proposed regional Reliability 

Standard requires that, “when the actual power flow exceeds a [system operating limit] 

for a Transmission path, the transmission operator shall take immediate action to reduce 

the actual power flow across the path....” 

33. As noted above, the NERC Petition includes, as Exhibit C, a Record of 

Development of Proposed Reliability Standard, which includes a mapping document 

comparing the current regional Standard to the proposed Standard. The mapping 

document explains the drafting team’s actions and rationale for replacing the term 

“operating transfer capability limit” with the term “system operating limit:” 
Docket No. RM09-14-000 - 21 - 

Removed definition of OTC and replaced OTC with SOL throughout the standard. 

Reasons included: 

1. Consistency with NERC standards, definitions and language. 

2. WECC Operating Committee adopted the document “WECC 

Philosophy of SOL & IROL Conditions” which states that a [sic] WECC 

operates only under SOL conditions. This statement is interpreted as 

declaring that a WECC OTC is an SOL. 

3. Removes ambiguity regarding applicability of other NERC standards.37 

34. The WECC Philosophy of SOL and IROL Conditions, adopted by the WECC 

Operating Committee, states that “the WECC operating philosophy is to operate only in 

conditions that have been studied. Therefore, under these normal operating conditions, 

there are never IROL conditions (only SOL).”38

Commission Concerns

35. NERC states that, in addition to addressing the Commission’s concerns noted in 

the June 2007 Order, “WECC made substantial technical modifications to the proposed 

standard TOP-007-WECC-1 on its own accord.”39 However, NERC does not effectively 

discuss the scope and substance of these substantial technical modifications. Rather, the 

NERC Petition explains that “because WECC followed its approved process in 

developing these modifications NERC continues to rebuttably presume this standard is 

 37 See NERC Petition, Exhibit C, Comparison of WECC Standard TOP-STD-007-

0 to proposed WECC Standard TOP-007-WECC-1, beginning at page 86 of the NERC 

Petition as it appears in the Commission’s eLibrary pdf document. 

38 WECC Philosophy of SOL & IROL Conditions, available at 

http://www.wecc.biz/committees/StandingCommittees/OC/OPS/Lists/Calendar/Attachme

nts/8/WECC%20Philosophy%20of%20SOL-IROL.pdf. 

39 NERC Petition at 8. 
Docket No. RM09-14-000 - 22 - 

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

interest.”40 The NERC Petition does not explain the shift from ensuring that operating 

transfer capability limits are not exceeded to ensuring that system operating limits are not 

exceeded for longer than a specified time. It appears that the mapping document 

discussed above provides the only insight in the record into the shift in focus of the 

proposed regional Reliability Standard from operating transfer capability limits to system 

operating limits. 

36. We have concerns regarding whether it is accurate to equate operating transfer 

capability limits and system operating limits. The term system operating limit is used in 

reference to a rated system path within the Western Interconnection and refers to the 

facility or element that presents the most limiting of the prescribed operating criteria for 

the rated system path. The most limiting facility or element may be either thermally or 

stability limited. The operating transfer capability limit corresponds to the “maximum 

amount of actual power transferred over direct or parallel transmission elements from one 

transmission operator to another transmission operator.” While these two terms relate to 

the same amount of power that may be transferred from one end of the rated system path 

to the other, the terms measure different things. When power flow on the facilities or 

elements that constitute a system operating limit reaches the system operating limit’s 

rating, the amount of power being transmitted across the facilities that constitute the rated 

system path becomes the operating transfer capability. This becomes problematic when 

 40 Id.
Docket No. RM09-14-000 - 23 - 

the most limiting operating criteria, i.e., that creates the system operating limit, is not 

located on the rated system path, but rather is located on a neighboring non-rated system

path facility or element. 

37. Based on the Commission’s understanding that there is a difference in these terms, 

we are concerned that the facilities that make up the system operating limit may not be 

part of those facilities that make up the rated system path, i.e., direct or parallel 

transmission elements comprising: (1) an interconnection from one transmission operator 

area to another transmission operator area; or (2) a transfer path within a transmission 

operator area. When operating transfer capability is replaced by system operating limit, 

this requirement could result in a transmission operator being responsible for monitoring 

the flows on transmission system operating limit facilities that may not be on its “rated 

system path” as shown in the WECC Transfer Path Table and the referenced Path Rating 

Catalog. The Commission is further concerned that this scenario creates the possibility 

that an entity to which the regional Reliability Standard applies would be responsible for 

operating facilities that are not part of the rated path system shown in the WECC Transfer 

Path Table and Catalog. We request comments from NERC, WECC and other interested 

parties regarding these concerns. 

38. Similarly, we seek comment from NERC, WECC and others regarding the manner 

in which a transmission operator would address system operating limit facilities that are 

not part of the rated system path. We also request comments regarding the possibility 

that transmission operators may, under the proposed regional Reliability Standard, be 

responsible for facilities that they do not own and which are not on the rated system path 
Docket No. RM09-14-000 - 24 - 

but comprise the system operating limit. For commenters who believe that this is a 

problem, we also request comments regarding how to resolve this potential dilemma. 

39. Additionally, we are concerned that the use of the term system operating limit 

rather than the term operating transfer capability is inconsistent with the WECC Path 

Rating Catalog and would cause confusion. Historically, WECC has used the term 

operating transfer capability, and not system operating limit, to describe transmission 

limitations. Here, it appears that NERC and WECC are using the two terms 

interchangeably as equivalents. Thus, we request that WECC, NERC and other 

interested entities provide clarification regarding the proper understanding of the two 

terms 

D. Applicability 

40. TOP-STD-007-0 is applicable to transmission owners or operators that maintain 

transmission paths listed in the WECC Transfer Path Table, which is included as 

Attachment A to the Reliability Standard. The attachment identifies 40 major 

transmission paths in the Western Interconnection. 

Proposed Regional Reliability Standard

41. Proposed TOP-WECC-007-1 removes Attachment A and, instead, directs 

transmission owners to the most current WECC Transfer Path Table, which is available 

on the WECC website. The table currently posted on the WECC website identifies the 

same 40 major paths as Attachment A to the approved regional Reliability Standard. 

42. The Petition does not explain why WECC moved the WECC Transfer Path Table 

from an attachment to a reference accessed through the WECC website. However, the 
Docket No. RM09-14-000 - 25 - 

mapping document discussed above states that: “[a]s an attachment to the standard, 

revisions to [the WECC Transfer Path Table] must be made through the standards 

process. By making [the WECC Transfer Path Table] a changing the [sic] referenced 

document in the WECC library, it opens the possibility of the table being changed 

through a WECC process without the need for changing the standard itself (for example, 

by recommendation of the OTCPC and approval by the Board).” In response to a 

stakeholder question during the development process, WECC indicated its belief that, 

under the proposed Standard, WECC Board approval would be required for changes to 

the Table, but NERC and Commission approvals would not be required.41 

 Commission Concerns

43. The Commission is concerned that by referencing the WECC Transfer Path Table 

hosted on the WECC website, the applicability of TOP-007-WECC-1 could change 

without Commission and industry notice and opportunity to respond. Under the 

currently-effective regional Reliability Standard, modifications to the WECC Transfer 

Path Table must be approved by the Commission. Accordingly, the Commission seeks 

comment on how NERC and WECC intend to develop and provide notice of proposed 

changes to the WECC Transfer Path Table. We also seek comment on how NERC and 

WECC will ensure that any resulting changes to the applicability of the Reliability 

Standard will not reduce its effectiveness. The Commission also requests comment 

 41 NERC Petition, Exhibit C, at page 51, 53 of the NERC Petition as it appears in 

the Commission’s eLibrary pdf document (reply to questions from Sierra Pacific 

Resources Transmission and Bonneville Power Administration). 
Docket No. RM09-14-000 - 26 - 

regarding whether the current WECC regional Reliability Standards or related documents 

include the criterion that governs when paths are added or removed from the WECC 

Transfer Path Table and requests further information on the scope and application of the 

criterion. 

44. Additionally, under section 215(d)(5) of the FPA, we propose to direct WECC to 

develop a modification to the Reliability Standard to address our concern. For example, 

WECC could include its criterion for identifying and modifying major transmission paths 

listed in the WECC Transfer Path Table and referenced Path Rating Catalog in the 

Reliability Standard, and make an informational filing with the Commission and NERC 

each time it makes a modification to the table or referenced catalog. Another option 

would be for WECC to file its criterion with the Commission and post revised transfer 

path tables and referenced catalogs on its website before they become effective with 

concurrent notification to NERC and the Commission. Alternatively, WECC could 

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

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

applying the requirements of the regional Reliability Standard in a just and reasonable 

manner. 

E. Violation Risk Factors 

45. As part of its compliance and enforcement program, NERC must assign a “lower,” 

“medium,” or “high” violation risk factor to each requirement of each mandatory 

Reliability Standard to associate a violation of the Requirement with its potential impact 

on the reliability of the Bulk-Power System. In the June 2007 Order approving TOP-
Docket No. RM09-14-000 - 27 - 

STD-007-0, the Commission noted that WECC’s existing sanctions table was 

inconsistent with NERC’s Sanction Guidelines, and directed WECC to develop violation 

risk factors that conform to corresponding NERC Reliability Standards.42 

 Proposed Regional Reliability Standard

46. TOP-007-WECC-1 includes violation risk factors for both of the requirements, 

without a separate violation risk factor for sub-requirement R2.1. 

Commission Concerns

47. TOP-007-WECC-1 and its continent-wide counterpart, NERC TOP-007-0, share 

the same reliability objective: to require transmission operators to take corrective action 

to reduce the amount of power flowing on a transmission path when it exceeds system 

operating limits or interconnection reliability operating limit to below the system 

operating limit or interconnection reliability operating limit and thereby minimize the 

amount of time the Bulk-Power System is operating one contingency away from a 

cascading outage. In its Petition, NERC does not explain why WECC assigned violation 

risk factors to the proposed Reliability Standard that differ from the corresponding 

continent-wide Reliability Standard’s violation risk factors.43 

48. We have noted previously that we expect consistency among violation risk factor 

assignments of Requirements that share the same reliability objective.44 Therefore, the 

Commission seeks comment from NERC and WECC regarding why the proposed 

 42 North American Electric Reliability Corp., 119 FERC ¶ 61,260 at P 54. 

43 See violation risk factors for TOP-007-0. 

44 North American Electric Reliability Corp., 119 FERC ¶ 61,145, at P 16, 25 

(2007). 
Docket No. RM09-14-000 - 28 - 

regional Reliability Standard contains violation risk factors that are not aligned with those 

of the continent-wide Reliability Standard. The Commission proposes to direct WECC to 

modify the assigned violation risk factor for TOP-007-WECC-01, Requirements R1 and 

R2 from “medium” and “low,” respectively, to “high” and requests comment on this 

proposal. 

F. Violation Severity Levels 

49. NERC, in its July 30, 2008 evaluation of WECC’s proposed Reliability Standard, 

noted that the violation severity levels in the proposed Reliability Standard do not 

conform to NERC’s format.45 

Proposed Regional Reliability Standard

50. NERC has adopted a standard violation severity level table format that is used in 

its Reliability Standards, which also should be used in all regional Reliability Standards. 

In its evaluation of the proposed regional Reliability Standard, NERC noted that violation 

severity levels do not conform to the NERC format. The NERC Petition notes that 

WECC agreed to address the formatting issue during the next revision of the regional 

Reliability Standard. 

Commission Proposal

51. The Commission agrees with NERC’s comments, and proposes to direct WECC to 

modify the violation severity levels associated with each requirement and subrequirement of TOP-007-WECC-1, and submit them in the approved table format. 

 45 NERC Petition at 29. 
Docket No. RM09-14-000 - 29 - 

III. Information Collection Statement

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

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

agency.46 The information contained here is also subject to review under section 3507(d) 

of the Paperwork Reduction Act of 1995.47 As stated above, the Commission previously 

approved the regional Reliability Standard that is the subject of the current rulemaking. 

In the event that the Commission, after receiving comments, determines to adopt the 

proposed revisions to the Reliability Standard, they would not substantially change the 

entities’ current reporting burden. Thus, the current proposal would not substantively 

affect the burden estimates relating to the currently effective version of the Reliability 

Standard previously approved.48

53. The proposed TOP-007-WECC-1, which would replace TOP-STD-007-0, does not 

modify or otherwise affect the burden related to the collection of information already in 

place. Thus, the proposed modifications to the current Reliability Standard will neither 

increase the reporting burden nor impose any additional information collection 

requirements. 

54. The Commission does not foresee any additional impact on the reporting burden 

for small businesses, because the proposed modifications do not increase the existing 

burden. However, we will submit this proposed rule to OMB for review. 

 46 5 CFR 1320.11. 

47 44 U.S.C. 3507(d). 

48 North American Electric Reliability Corp., 119 FERC ¶ 61,260 at P 125-131. 
Docket No. RM09-14-000 - 30 - 

Title: Version One Regional Reliability Standard for Transmission Operations. 

Action: Proposed Collection FERC-725E. 

OMB Control No.: 1902-0246. 

Respondents: Businesses or other for-profit institutions; not-for-profit institutions. 

Frequency of Responses: On Occasion. 

Necessity of the Information: This proposed rule proposes to approve the requested 

modifications to a regional Reliability Standard pertaining to System Operating Limits. 

The proposed Reliability Standard is one of the standards that helps ensure the reliable 

operation of the Western Interconnection. 

Internal Review: The Commission has reviewed the proposed Reliability Standard and 

made a determination that its action is necessary to implement section 215 of the FPA. 

These requirements, if accepted, should conform to the Commission’s expectation for 

System Operating Limits as well as procedures within the energy industry. 

55. 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, email: DataClearance@ferc.gov, phone: (202) 502-8663, fax: (202) 273-0873]. 

56. For submitting comments concerning the collection(s) of information and the 

associated burden estimate(s), please send your comments to the Commission and to the 

Office of Management and Budget, Office of Information and Regulatory Affairs, 

Washington, DC 20503 [Attention: Desk Officer for the Federal Energy Regulatory 

Commission, phone: (202) 395-4638, fax: (202) 395-7285]. For security reasons, 
Docket No. RM09-14-000 - 31 - 

comments to OMB should be submitted by e-mail to: oira_submission@omb.eop.gov. 

Comments submitted to OMB should include Docket Number RM09-14 and OMB 

Control Number 1902-0246. 

IV. Environmental Analysis

57. 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.49 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.50 The actions proposed here fall within this categorical exclusion in the 

Commission’s regulations. 

V. Regulatory Flexibility Act Certification

58. The Regulatory Flexibility Act of 1980 (RFA)51 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 

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 

n 

that 

cant 

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

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

Act of 1969, FERC Stats. & Regs., Regulations Preambles 1986-1990 ¶ 30,783 (1987). 

50 18 CFR 380.4(a)(2)(ii). 

51 5 U.S.C. 601-612. 
Docket No. RM09-14-000 - 32 - 

small business.52 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.53 The RFA is 

not implicated by this proposed rule because the modification discussed herein will not 

have a significant economic impact on a substantial number of small entities. Moreover, 

the proposed Reliability Standards reflect a continuation of existing requirements for 

these reliability entities. Accordingly, no regulatory flexibility analysis is required. 

VI. Comment Procedures

59. 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. RM09-14-000, and must include the commenter’s name, the organization 

they represent, if applicable, and their address in their comments. 

60. 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 

 52 13 CFR 121.101 

53 13 CFR 121.201, Sector 22, Utilities & n. 1. 
Docket No. RM09-14-000 - 33 - 

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

filing. 

61. 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. 

62. 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

63. 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 the Commission’s Home Page 

(http://www.ferc.gov) and in the Commission’s Public Reference Room during normal 

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

Washington DC 20426. 

64. From the Commission’s Home Page on the Internet, this information is available 

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

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

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

document in the docket number field. 
Docket No. RM09-14-000 - 34 - 

65. User assistance is available for eLibrary and the Commission’s web site 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 

Electric power; Electric utilities; Reporting and record keeping requirements. 

 By direction of the Commission. 

Kimberly D. Bose, 

Secretary.