147 FERC ¶ 61,209

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket No. RM14-1-000 Order No. 797]

Reliability Standard for Geomagnetic Disturbance Operations

(Issued June 19, 2014)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final rule.

SUMMARY: Pursuant to section 215 of the Federal Power Act, the Federal Energy 

Regulatory Commission (Commission) approves Reliability Standard EOP-010-1 

(Geomagnetic Disturbance Operations). The North American Electric Reliability 

Corporation, the Commission-certified Electric Reliability Organization, submitted the 

Reliability Standard for Commission approval in response to a Commission directive in 

Order No. 779. Reliability Standard EOP-010-1 is designed to mitigate the effects of 

geomagnetic disturbances on the Bulk-Power System by requiring responsible entities to 

implement Operating Plans and Operating Procedures or Processes. 

EFFECTIVE DATE: This rule will become effective [INSERT DATE 60 days after 

publication in the FEDERAL REGISTER].
Docket No. RM14-1-000 - 2 -

FOR FURTHER INFORMATION CONTACT:

Michael Gandolfo (Technical Information) 

Office of Electric Reliability 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-6817 

Michael.Gandolfo@ferc.gov 

Matthew Vlissides (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

Telephone: (202) 502-8408

Matthew.Vlissides@ferc.gov

SUPPLEMENTARY INFORMATION:
147 FERC ¶ 61,209

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Cheryl A. LaFleur, Acting Chairman;

 Philip D. Moeller, John R. Norris,

 and Tony Clark.

Reliability Standard for Geomagnetic 

Disturbance Operations

Docket No. RM14-1-000

ORDER NO. 797

FINAL RULE

(Issued June 19, 2014)

1. Pursuant to section 215 of the Federal Power Act (FPA),1 the Commission

approves Reliability Standard EOP-010-1 (Geomagnetic Disturbance Operations). The

North American Electric Reliability Corporation (NERC), the Commission-certified 

Electric Reliability Organization (ERO), submitted the Reliability Standard for 

Commission approval in response to a Commission directive in Order No. 779.

2

 The 

Reliability Standard is designed to mitigate the effects of geomagnetic disturbances 

(GMD) on the Bulk-Power System by requiring responsible entities to implement 

Operating Plans and Operating Procedures or Processes. The Commission also approves

the associated violation risk factors and violation severity levels, implementation plan, 

and effective dates proposed by NERC.

 1 16 U.S.C. 824o.

2 Reliability Standards for Geomagnetic Disturbances, Order No. 779, 78 FR 

30,747 (May 23, 2013), 143 FERC ¶ 61,147, reh’g denied, 144 FERC ¶ 61,113 (2013).
Docket No. RM14-1-000 - 2 -

I. Background

A. Section 215 and Mandatory Reliability Standards

2. Section 215 of the FPA requires the Commission to certify an ERO to develop 

mandatory and enforceable Reliability Standards, subject to Commission review and 

approval.3

 Once approved, the Reliability Standards may be enforced in the United 

States by the ERO, subject to Commission oversight, or by the Commission 

independently.4

B. Order No. 779

3. In Order No. 779, the Commission directed NERC, pursuant to FPA section 

215(d)(5), to develop and submit for approval proposed Reliability Standards that address 

the impact of GMDs on the reliable operation of the Bulk-Power System. The 

Commission based its directive on the potentially severe, wide-spread impact on the 

reliable operation of the Bulk-Power System that can be caused by GMD events and the 

absence of existing Reliability Standards to address GMD events.

5

 

4. The Commission directed NERC to implement the directive in two stages. In the 

first stage, the Commission directed NERC to submit, within six months of the effective 

date of Order No. 779, one or more Reliability Standards (First Stage GMD Reliability 

Standards) that require owners and operators of the Bulk-Power System to develop and 

 3 16 U.S.C. 824o.

4 Id. 824o(e). 

5 Order No. 779, 143 FERC ¶ 61,147 at P 3.
Docket No. RM14-1-000 - 3 -

implement operational procedures to mitigate the effects of GMDs consistent with the 

reliable operation of the Bulk-Power System.6

5. In the second stage, the Commission directed NERC to submit, within 18 months 

of the effective date of Order No. 779, one or more Reliability Standards (Second Stage 

GMD Reliability Standards) that require owners and operators of the Bulk-Power System 

to conduct initial and on-going assessments of the potential impact of benchmark GMD

events on Bulk-Power System equipment and the Bulk-Power System as a whole. Order 

No. 779 directed that the Second Stage GMD Reliability Standards must identify 

benchmark GMD events that specify what severity GMD events a responsible entity must 

assess for potential impacts on the Bulk-Power System.7

 Order No. 779 explained that, if 

the assessments identify potential impacts from benchmark GMD events, the Reliability 

Standards should require owners and operators to develop and implement a plan to 

protect against instability, uncontrolled separation, or cascading failures of the BulkPower System, caused by damage to critical or vulnerable Bulk-Power System 

equipment, or otherwise, as a result of a benchmark GMD event. The Commission

directed that the development of this plan could not be limited to considering operational 

procedures or enhanced training alone, but should, subject to the potential impacts of the 

benchmark GMD events identified in the assessments, contain strategies for protecting 

 6 Id. P 2.

7 Id.
Docket No. RM14-1-000 - 4 -

against the potential impact of GMDs based on factors such as the age, condition, 

technical specifications, system configuration, or location of specific equipment.8

 Order 

No. 779 observed that these strategies could, for example, include automatically blocking 

geomagnetically-induced currents (GIC) from entering the Bulk-Power System, 

instituting specification requirements for new equipment, inventory management, 

isolating certain equipment that is not cost effective to retrofit, or a combination thereof.

C. NERC Petition

6. On November 13, 2013, NERC petitioned the Commission to approve Reliability 

Standard EOP-010-1 and its associated violation risk factors and violation severity levels, 

implementation plan, and effective dates. In the petition, NERC states that the Reliability 

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

interest. NERC maintains that the Reliability Standard satisfies the Commission’s 

directive in Order No. 779 corresponding to the development and submission of the First 

Stage GMD Reliability Standards.

7. NERC states that, consistent with Order No. 779 and the NERC Functional Model, 

Reliability Standard EOP-010-1 applies to reliability coordinators and transmission 

operators with a “Transmission Operator Area that includes a power transformer with a 

high side wye-grounded winding with terminal voltage greater than 200 kV.”9

 NERC 

 8 Id. 

9 NERC Petition at 8 (“A power transformer with a ‘high side wye-grounded 

winding’ refers to a power transformer with windings on the high voltage side that are 

(continued...)
Docket No. RM14-1-000 - 5 -

explains that the Reliability Standard has three requirements: (1) Requirement R1 

addresses coordination by reliability coordinators within their areas; (2) Requirement R2 

addresses the dissemination of space weather information by reliability coordinators to 

ensure that entities within a reliability coordinator area have the appropriate information 

necessary to take action and that the same information is available to all entities; and 

(3) Requirement R3 requires transmission operators to develop GMD Operating 

Procedures or Processes.

8. NERC states that Requirement R1 requires each reliability coordinator to develop, 

maintain, and implement a GMD Operating Plan that coordinates the GMD Operating 

Procedures or Operating Processes within its reliability coordinator area.10 NERC 

explains that each reliability coordinator is required to ensure that GMD Operating 

Procedures and Operating Processes in its reliability coordinator area are not in conflict, 

but a reliability coordinator will not review the technical aspects of the GMD Operating 

Procedures and Operating Processes.11 Instead, according to NERC, each transmission 

 

connected in a wye configuration and have a grounded neutral connection.”).

10 Operating Plan, Operating Procedure, and Operating Process are existing terms 

defined in the Glossary of Terms Used in NERC Reliability Standards. See Glossary of 

Terms Used in NERC Reliability Standards (effective November 21, 2013) at 49-50. 

11 NERC explains that “if Company A submitted an Operating Procedure 

proposing to take Line X out of service under specified GMD conditions, and Company 

B submitted an Operating Procedure that relies on Line X remaining in service in the 

event of a GMD – it is the responsibility of the Reliability Coordinator to identify this 

conflict.” NERC Petition at 11-12 (emphasis in original). Beyond identifying a conflict 

and requiring its resolution by Company A and Company B, NERC states that the review 

(continued...)
Docket No. RM14-1-000 - 6 -

operator will be responsible for the technical aspects of its Operating Procedures and 

Operating Processes. NERC further states that Requirement R1 requires each reliability 

coordinator to describe the activities that must be undertaken in order to mitigate the 

effects of a GMD event. NERC explains that, pursuant to Reliability Standard IRO-001-

1.1, each reliability coordinator has decision-making authority to act and to direct actions 

to be taken by transmission operators, balancing authorities, generator operators, 

transmission service providers, load-serving entities, and purchasing-selling entities 

within its reliability coordinator area to preserve the reliability of the bulk electric system.

9. NERC states that Requirement R2 requires each reliability coordinator to 

disseminate space weather information to ensure coordination and consistent awareness 

in its reliability coordinator area. NERC maintains that entrusting this responsibility to 

reliability coordinators is appropriate given the reliability coordinator’s wide-area view. 

NERC also explains that Requirement R2 replaces existing Requirement R3 of 

Reliability Standard IRO-005-3.1a, which currently addresses dissemination of 

information regarding GMD forecasts.12 

10. NERC states that Requirement R3 requires each transmission operator to develop 

GMD Operating Procedures or Operating Processes to address GMD events. NERC 

 

is “not intended to be a review by the Reliability Coordinator of the technical aspects of 

the GMD Operating Procedures or Processes.” Id. at 11.

12 According to NERC, Reliability Standard IRO-005-3.1a will be retired once the 

Commission approves proposed Reliability Standard IRO-005-4, which is currently 

pending before the Commission. NERC Petition at 13.
Docket No. RM14-1-000 - 7 -

explains that Requirement R3 is not prescriptive and allows each transmission operator to 

tailor its Operating Procedures or Operating Processes based on the transmission 

operator’s assessment of entity-specific factors, such as geography, geology, and system

topology. According to NERC, Requirement R3 requires each transmission operator to 

specify: (1) steps or tasks that must be conducted to receive space weather information; 

(2) what actions must be taken under what conditions, and such conditions must be

predetermined; and (3) when and under what conditions the Operating Procedure or 

Operating Process is exited. NERC maintains that Reliability Standard EOP-010-1 does 

not prescribe specific actions that must be taken by responsible entities because “a ‘onesize fits all’ approach to crafting GMD Reliability Standards would fail to recognize the 

important role of locational differences.”13

11. NERC proposes that Reliability Standard EOP-010-1 become effective the “first 

day of the first calendar quarter that is six months after the date that this standard is 

approved by an applicable governmental authority.”14 However, NERC states that 

Requirement R2 of Reliability Standard EOP-010-1, pertaining to reliability coordinator 

dissemination of space weather information, is meant to replace existing Requirement R3 

of Reliability Standard IRO-005-3.1a, which includes similar language. Therefore, to 

avoid duplicative requirements being enforced at the same time, NERC proposes that, if 

 13 NERC Petition at 14.

14 NERC Petition, Exhibit B (Implementation Plan) at 2.
Docket No. RM14-1-000 - 8 -

Reliability Standard EOP-010-1 becomes effective prior to the retirement of Reliability 

Standard IRO-005-3.1a, then Requirement R2 of Reliability Standard EOP-010-1 will not 

become effective until the first day following retirement of Reliability Standard IRO-005-

3.1a.

D. Notice of Proposed Rulemaking

12. On January 16, 2014, the Commission issued a Notice of Proposed Rulemaking 

that proposed to approve Reliability Standard EOP-010-1 as just, reasonable, not unduly 

discriminatory or preferential, and in the public interest based on the Commission’s 

review of NERC’s petition and supporting exhibits.15 The NOPR stated that the 

Reliability Standard satisfies the directive in Order No. 779 that NERC submit one or 

more Reliability Standards that require owners and operators of the Bulk-Power System 

to develop and implement operational procedures to mitigate the effects of GMDs 

consistent with the reliable operation of the Bulk-Power System. The NOPR also stated 

that the Reliability Standard is consistent with the guidance in Order No. 779 that NERC 

develop Reliability Standards that, rather than require specific operational procedures, 

require responsible entities to develop and implement entity-specific operational 

procedures because owners and operators of the Bulk-Power System are most familiar 

with their own equipment and system configurations.16 The NOPR further stated that the 

 15 Reliability Standard for Geomagnetic Disturbance Operations, Notice of 

Proposed Rulemaking, 79 FR 3547 (Jan. 22, 2014), 146 FERC ¶ 61,015 (2014) (NOPR).

16 Id. P 38.
Docket No. RM14-1-000 - 9 -

Reliability Standard requires coordination of operational procedures and processes, 

overseen by a functional entity with a wide-area perspective (i.e., reliability 

coordinators), which is consistent with the guidance in Order No. 779.17 

13. In response to the NOPR, the Commission received 20 sets of comments. We 

address below the issues raised in the comments. The Appendix to this Final Rule lists 

the entities that filed comments in response to the NOPR.

II. Discussion

14. Pursuant to FPA section 215(d)(2), we approve Reliability Standard EOP-010-1 as 

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

the Commission stated in Order No. 779, “operational procedures, while not a complete 

solution, constitute an important first step to addressing the GMD reliability gap because 

they can be implemented relatively quickly ... [and] [o]perational procedures may help 

alleviate abnormal system conditions due to transformer absorption of reactive power 

during GMD events, helping to stabilize system voltage swings, and may potentially 

isolate some equipment from being damaged or misoperated.”18 We determine that 

Reliability Standard EOP-010-1 addresses the directive in Order No. 779 that NERC 

submit one or more Reliability Standards that require owners and operators of the BulkPower System to develop and implement operational procedures to mitigate the effects of 

 17 Id.

18 Order No. 779, 143 FERC ¶ 61,147 at P 36.
Docket No. RM14-1-000 - 10 -

GMDs consistent with the reliable operation of the Bulk-Power System.19 We also 

determine that the Reliability Standard is consistent with the guidance in Order No. 779 

that NERC develop Reliability Standards that, rather than require specific operational 

procedures, require responsible entities to develop and implement entity-specific 

operational procedures because owners and operators of the Bulk-Power System are most 

familiar with their own equipment and system configurations.20 Further, we determine 

that the Reliability Standard requires coordination of operational procedures and 

processes, overseen by a functional entity with a wide-area perspective (i.e., reliability 

coordinators), which is also consistent with the guidance in Order No. 779.21 

15. Several commenters support approval of Reliability Standard EOP-010-1 without 

modification.22 We address below the following issues raised by other commenters: 

(A) the applicability section of Reliability Standard EOP-010-1; (B) effectiveness of 

GMD operational procedures; (C) implementation plan; and (D) other issues. We also 

address below the violation risk factors and violation severity levels associated with 

Reliability Standard EOP-010-1.

 19 Reliability Standard EOP-010-1 only addresses the First Stage GMD Reliability 

Standards directed in Order No. 779. The Reliability Standard does not address the 

Second Stage GMD Reliability Standards, which NERC indicates are under development. 

NERC Petition at 3.

20 Order No. 779, 143 FERC ¶ 61,147 at P 38.

21 Id.

22 See comments submitted by NERC, IRC, EEI, Chamber of Commerce, 

Dominion, AEP, ITC, and ASO. 
Docket No. RM14-1-000 - 11 -

A. Applicability Section of Reliability Standard EOP-010-1

NERC Petition

16. NERC submitted a white paper as part of its petition explaining the technical 

justification for applying Reliability Standard EOP-010-1 only to transmission operators

that operate a power transformer with a high side wye-grounded winding with terminal 

voltage greater than 200 kV in their transmission operator areas.

23 In another white 

paper, NERC explains its proposal regarding the applicability of the Reliability Standard 

to reliability coordinators and transmission operators only.24 The White Paper 

Supporting Functional Entity Applicability explains that the reliability coordinator has 

“responsibility and authority for reliable operation within the Reliability Coordinator 

Area (RCA) ... and includes a wide-area view with situational awareness of neighboring 

RCAs.”25 NERC states that including reliability coordinators as applicable entities 

“provides the necessary coordination for planning and real-time actions.”26 With respect 

to transmission operators, NERC explains that “[l]ike the [reliability coordinator], the 

[transmission operator] has responsibility and authority for the reliable operation of the 

 23 NERC Petition, Exhibit D (White Paper Supporting Network Applicability) at 1.

24 NERC Petition, Exhibit E (White Paper Supporting Functional Entity 

Applicability).

25 Id. at 2.

26 Id.
Docket No. RM14-1-000 - 12 -

transmission system within a specified area.”27 In addition, NERC justifies omitting 

balancing authorities and generator operators from the scope of the Reliability Standard. 

NERC explains that balancing authorities “can be expected to address GMD impacts 

through use of generation ... [but] the [balancing authority] would not initiate actions 

unilaterally during a GMD event and would instead respond to the direction of the 

[transmission operator] and [reliability coordinator].”28 As for generator operators, 

NERC states that some generator operators “would not have the technical basis for taking 

steps [to mitigate GMDs] on [their] own and would instead take steps based on the 

[reliability coordinator’s] or [transmission operator’s] Operating Plans, Processes, or 

Procedures.”29 NERC also notes that generator owners and generator operators will be 

considered for inclusion in the Second Stage GMD Reliability Standards, “which will 

require applicable entities to conduct vulnerability assessment and develop appropriate 

mitigation strategies . . . [and that] [s]uch mitigation strategies could include the 

development of Operating Procedures for applicable [generator owners] and [generator 

operators].”30

 27 Id.

28 Id. at 3-4.

29 Id. at 4.

30 Id.
Docket No. RM14-1-000 - 13 -

NOPR

17. The NOPR stated that the applicability designations in Reliability Standard EOP010-1 are appropriate, based on the justifications set forth in the white papers in Exhibits

D and E of NERC’s petition.

Comments

18. Foundation, SmartSense, AFS, and Baker maintain that Reliability Standard EOP010-1 should be applicable to more entities than transmission operators having a power 

transformer with a high side wye-grounded winding with terminal voltage greater than 

200 kV in the transmission operator area.

19. Foundation states that during the March 1989 solar storm discussed in Order No. 

779, electric utilities reported effects on static VAR compensators and other reactive 

power equipment operating between 100 kV and 200 kV. Foundation notes that such 

equipment is “designed to provide reactive power and to stabilize transmission networks 

during GMD.”31 Foundation states that Reliability Standard EOP-010-1 “would exempt 

Transmission Operators with equipment operating between 100 kV and 200 kV.”32 

Foundation requests that the Commission remand Reliability Standard EOP-010-1 to 

 31 Foundation Comments at 10.

32 Id.
Docket No. RM14-1-000 - 14 -

include “owners and operators of all stabilizing and reactive power equipment operating 

between 100 kV and 200 kV.”33

20. Foundation and SmartSense assert that the 200 kV threshold for transmission 

operators is inconsistent with the Commission-approved definition of bulk electric 

system, which generally includes assets operating at voltages of 100 kV and higher. 

SmartSense asserts that there is evidence that elements of the Bulk-Power System 

operating between 100 kV and 200kV would be substantially affected by a GMD event. 

In support, SmartSense cites to an Oak Ridge National Laboratory GMD Study and an 

article from the Idaho National Laboratory, which SmartSense states tested sub-200 kV 

transformers.34 SmartSense further claims that NERC improperly relied on a cost-benefit 

analysis to exclude networks operating at 200 kV and below.

21. Foundation, AFS, EMP Coalition, Kappenman, and Baker maintain that 

Reliability Standard EOP-010-1 should be applicable to generator operators and/or

balancing authorities. 

 33 Id. at 13.

34 SmartSense Comments at 10-11 (citing Oak Ridge National Laboratory, 

Electromagnetic Pulse: Effects on the U.S. Power Grid: Meta-R-319 at page 4-14 

(January 2010), available at http://www.ornl.gov/sci/ees/etsd/pes/pubs/ferc_Meta-R319.pdf; Idaho National Laboratory, INL Broadens Understanding of Solar Storms

(December 16, 2013), available at

https://inlportal.inl.gov/portal/server.pt/community/newsroom/257/feature_story_details/

1269?featurestory=DA_615269). 
Docket No. RM14-1-000 - 15 -

22. Foundation states that balancing authorities have real-time responsibilities that 

would be essential during a GMD event. Foundation asserts that excluding balancing 

authorities from the applicability section of Reliability Standard EOP-010-1 is 

“operationally unworkable” because it “assumes that the real time responsibilities of 

Balancing Authorities under fast-moving GMD conditions could be assumed by 

Reliability Coordinators.”35 Foundation states that the NOAA Space Weather Prediction 

Center would only provide 15-60 minutes warning of a severe solar storm. Foundation 

asserts that, given the 15-60 minute limitation, there would be insufficient time for 

reliability coordinators to communicate with balancing authorities, transmission 

operators, and generator operators following a solar storm warning because the NERC 

Reliability Standards require three-part communications when engaging in oral, twoparty communications. 

23. Foundation and Kappenman also maintain that Reliability Standard EOP-010-1 

does not address generator step up (GSU) transformers, which they assert are vulnerable 

to GMDs. Foundation contends that generator operators have been installing GIC 

monitors for their GSU transformers and have taken actions to downrate their GSU 

transformers during solar storms. Foundation also notes that the NERC GMD Task Force 

developed an Operating Procedure Template for generator operators.

 35 Foundation Comments at 14.
Docket No. RM14-1-000 - 16 -

Commission Determination

24. We determine that the applicability section of Reliability Standard EOP-010-1 is 

technically justified and consistent with Order No. 779, both in terms of using a 200 kV 

threshold for determining applicable transmission operators and not including balancing 

authorities and generator operators as applicable entities. 

25. We reject the argument that the applicability threshold in Reliability Standard 

EOP-010-1 is inconsistent with the definition of bulk electric system because it excludes 

transmission operators with only 200 kV transformers and below. Instead, we determine 

that the applicability section of Reliability Standard EOP-010-1 complies with the 

directive in Order No. 779 that the First Stage GMD Reliability Standards should 

mitigate the effects of GMDs consistent with the reliable operation of the Bulk-Power 

System.36 The NERC petition and White Paper Supporting Network Applicability 

provide an adequate technical basis to conclude that transformers operating at 200 kV 

and below are likely to have a limited impact on the Bulk-Power System during a GMD 

event. We are not persuaded by the Foundation comments, discussed above, which do 

 36 Order No. 779, 143 FERC ¶ 61,147 at P 29; see also 16 U.S.C. 824o(a)(3) (“The 

term ‘reliability standard’ means a requirement ... to provide for the reliable operation of 

the bulk-power system.”); Mandatory Reliability Standards for the Bulk-Power System, 

Order No. 693, FERC Stats. & Regs. ¶ 31,242, at PP 97-98, order on reh’g, Order No. 

693-A, 120 FERC ¶ 61,053 (2007) (explaining that each Reliability Standard will 

identify the set of users, owners and operators that must comply with that standard and 

“NERC has indicated that in the future it may add to a Reliability Standard limitations on 

applicability based on electric facility characteristics such as generator nameplate 

ratings”). 
Docket No. RM14-1-000 - 17 -

not refute this conclusion, or the materials cited by SmartSense. SmartSense cites a table 

in the Oak Ridge Laboratory GMD Study identifying at-risk transformers operating at 

345 kV, which fall within the applicability criteria.37 Moreover, the Oak Ridge 

Laboratory GMD Study found that significantly higher GIC flows occur at higher 

operating voltages.38

26. The applicability criteria for Reliability Standard EOP-010-1 determine which

transmission operators must comply with the Reliability Standard (i.e., those with a 

power transformer with a high side wye-grounded winding with terminal voltage greater 

than 200 kV in the transmission operator area). While this criterion excludes 

transmission operators operating transformers 200 kV and below, the 200 kV threshold 

does not mean that applicable transmission operators will ignore reactive power supplies 

operating at 200 kV or below on their systems when developing the required GMD 

Operating Procedures or Operating Processes. Reliability Standard EOP-010-1, 

Requirement R3 supports this conclusion because it directs each applicable transmission 

operator to “develop, maintain, and implement a GMD Operating Procedure or Operating 

 37 SmartSense Comments at 10 n.31 (citing Oak Ridge National Laboratory, 

Electromagnetic Pulse: Effects on the U.S. Power Grid: Meta-R-319 at page 4-14).

38 Id. at page 1-15 (“The operating voltage of the transmission network is an 

important factor in determining the level of GIC flow that will occur on each part of the 

U.S. power grid. At the higher operating voltages, there are pronounced trends that: the 

average length of each line increases and the average circuit resistance decreases. These 

trends result in larger GIC flows in the higher voltage portions of the network, given the 

same geo-electric field conditions.”).
Docket No. RM14-1-000 - 18 -

Process to mitigate the effects of GMD events on the reliable operation of its respective 

system.” Accordingly, because Requirement R3 addresses an applicable transmission 

operator’s entire system, the requirement is not limited to transformers operating above 

200 kV for the purposes of developing GMD Operating Procedures or Operating 

Processes by applicable transmission operators.

39 

27. The Idaho National Laboratory article cited by SmartSense stated that a simulated 

solar event affected “a pair of 138kV core form, 2 winding substation transformers, 

which had been in-service at [Idaho National Laboratory] since the 1950s,” through

increased losses and generation of harmonics that resulted in loss of excitation.

40 The 

Idaho National Laboratory article does not contradict NERC’s technical analysis, 

however. NERC does not contend that GMD events will have no effect on networks

operating at 200 kV and below. Rather, the standard drafting team found that 

geomagnetically-induced currents generated on networks operated at 200 kV and below 

would be significantly less than those operated at higher voltages, a finding that is 

 39 See NERC Petition at 14 (“An Operating Procedure or Operating Process is 

maintained when it is kept relevant by taking into consideration system configuration, 

conditions or operating experiences, as needed to accomplish its purpose. Requirement 

R3 ... allows entities to tailor their Operational Procedures or Processes based on the 

responsible entity’s assessment of entity-specific factors, such as geography, geology, 

and system topology.”).

40 Idaho National Laboratory, INL Broadens Understanding of Solar Storms

(December 16, 2013), available at

https://inlportal.inl.gov/portal/server.pt/community/newsroom/257/feature_story_details/

1269?featurestory=DA_615269).
Docket No. RM14-1-000 - 19 -

consistent with the Oak Ridge Laboratory GMD Study. Specifically, NERC’s modeling 

of a portion of the Eastern Interconnection showed only a small change in system impact 

from a GMD event when 115 kV and 161 kV circuits were excluded from the model.

41 

The materials cited in the comments do not rebut NERC’s technical analysis. In sum, we 

determine that there is adequate technical justification for the 200 kV threshold for 

transmission operators.

42

28. We also determine that NERC provided adequate justification not to include 

balancing authorities and generator operators in the applicability section of Reliability 

Standard EOP-010-1. We disagree with Foundation’s assertion that balancing authorities 

should be included in the applicability section because reliability coordinators are 

incapable of communicating quickly with transmission operators, generator operators, 

and balancing authorities due to the three-part communications requirement in Reliability 

Standard COM-002-2. We are not persuaded that GMD events pose unique 

communication problems for reliability coordinators because a reliability coordinator 

may only have 15-60 minutes warning of a severe solar storm. Reliability coordinators 

are responsible for real-time system reliability and often must respond quickly or even 

 41 NERC Petition, Exhibit D (White Paper Supporting Network Applicability) at 8 

(Table A2).

42 As we conclude that NERC provided adequate technical justification for the 200 

kV applicability threshold, there is no reason to address SmartSense’s assertion that 

NERC improperly based the 200 kV threshold on a cost-benefit analysis. 
Docket No. RM14-1-000 - 20 -

immediately to Bulk-Power System events with little or no warning.43 Reliability 

Standard COM-002-2, Requirement R1 recognizes this responsibility by stating that 

“[e]ach Transmission Operator, Balancing Authority, and Generator Operator shall have 

communications (voice and data links) with appropriate Reliability Coordinators, 

Balancing Authorities, and Transmission Operators ... [and] [s]uch communications shall 

be staffed and available for addressing a real-time emergency condition.” 

29. With respect to generator operators, there is no dispute that GSU transformers are 

susceptible to geomagnetically-induced currents. While generator operators are not listed 

as applicable entities in Reliability Standard EOP-010-1, NERC explains that generator 

operators will have to act during a GMD event when directed by a reliability coordinator, 

in accordance with its reliability coordiantor’s GMD Operating Plan, or by a transmission 

operator, in accordance with its transmission operator’s GMD Operating Procedures or 

Operating Processes.

44 We are not persuaded that generator operators should be required 

to act independently under Reliability Standard EOP-010-1. While generator operators

might be, as Foundation asserts, increasingly installing GIC monitoring equipment, there 

is no evidence in the record regarding the proportion of generator operators with GIC 

 43 NERC, Reliability Functional Model Technical Document, Version 5, at 7 

(Approved May 2010), available at

http://www.nerc.com/pa/Stand/Functional%20Model%20Archive%201/FM_Technical_

Document_V5_2009Dec1.pdf.

44 NERC Petition, Exhibit E (White Paper Supporting Functional Entity 

Applicability) at 2-4.
Docket No. RM14-1-000 - 21 -

monitoring capabilities. Accordingly, we agree with NERC that at least some generator 

operators would not have the technical basis to address a GMD event and would instead 

need to rely on reliability coordinators and transmission operators for direction.45 We 

also note that the Geomagnetic Disturbance Operating Procedure Template for generator 

operators developed by the NERC GMD Task Force, which the Foundation’s comments 

reference, conditions some of its suggested actions on the generator operator having 

adequate monitoring systems.46 In sum, we are not persuaded by Foundation’s comments 

and, rather, determine that there is adequate justification in the record for not including 

balancing authorities and generator operators in the applicability section of Reliability 

Standard EOP-010-1.47

 45 Id. at 4.

46 NERC, Geomagnetic Disturbance Operating Procedure Template Generator 

Operator, at 1, available at http://www.nerc.com/docs/pc/gmdtf/Template_GOP.pdf

(“Some actions listed below should only be undertaken if supported by an adequate GIC 

impact study and/or if adequate monitoring systems are available. Otherwise they can 

make matters worse.”).

47 While not basing our determination on NERC’s representation or pre-judging

what NERC ultimately submits in the Second Stage GMD Reliability Standards, we note 

NERC’s statement that the standard drafting team for the Second Stage GMD Reliability 

Standards is considering including generator owners and generator operators in the 

applicability section of that proposed Reliability Standard. NERC Petition, Exhibit E at 

4. 
Docket No. RM14-1-000 - 22 -

B. Effectiveness of GMD Operational Procedures

NERC Petition

30. NERC states, quoting Order No. 779, that “[o]perational procedures may help 

alleviate abnormal system conditions due to transformer absorption of reactive power 

during GMD events, helping to stabilize system voltage swings, and may potentially 

isolate some equipment from being damaged or misoperated.”48 NERC explains that 

Reliability Standard EOP-010-1 “is an important first step in addressing the issue of 

GMDs and can be implemented relatively quickly. While responsible entities will 

develop and implement Operational Procedures or Operational Processes, NERC will 

continue to support those efforts through the GMD Task Force, for example, by 

identifying and sharing Operating Plans, Processes, and Procedures found to be the most 

effective.”49

NOPR

31. The NOPR stated that Reliability Standard EOP-010-1 satisfies the directive in 

Order No. 779 that NERC submit one or more Reliability Standards that require owners 

and operators of the Bulk-Power System to develop and implement operational 

procedures to mitigate the effects of GMDs consistent with the reliable operation of the 

Bulk-Power System. The NOPR also stated that operational procedures, while not a 

 48 NERC Petition at 3 (quoting Order No. 779, 143 FERC ¶ 61,147 at P 36).

49 Id. at 3-4.
Docket No. RM14-1-000 - 23 -

complete solution, constitute an important first step to addressing the GMD reliability 

gap.

Comments

32. SmartSense and Orquin state that GMD operational procedures depend on the

limited ability to predict GMD events. SmartSense states that space weather information 

is the “default trigger” for implementing operating procedures under Reliability Standard 

EOP-010-1 but that space weather forecasts have a high error rate. SmartSense contends 

that relying on space weather forecasts alone will result in false alarms or missed GMD 

event forecasts. SmartSense maintains that real-time or near real-time monitoring data 

should be used in conjunction with space weather forecasts to trigger GMD operational 

procedures.

33. Baker states that operational procedures will be ineffective because: (1) grid

operators will be reluctant to take action during a GMD event (e.g., shed load); (2) the 

warning period for solar storms does not allow enough time for grid operators to take 

action; (3) grid operators will not have enough situational awareness to know how to take 

action during a GMD event; (4) there is no capacity to address GMD events on a national 

scale; (5) operational procedures have been shown to be inadequate in other contexts; (6) 

equipment failure may undermine the grid operators’ ability to respond; (7) GMD events 

will disrupt communication networks used by grid operators; (8) the potential effects of a 

GMD event on the Bulk-Power System are too complex to anticipate; and (9) Regional 

Transmission Organizations and Independent System Operators do not have the authority 

to shut down the grid in neighboring Regions. Foundation states that grid operators will 
Docket No. RM14-1-000 - 24 -

have to act blindly during a GMD event because Reliability Standard EOP-010-1 does 

not require GIC monitoring or mandatory sharing of GIC monitoring data. Foundation 

also states that Reliability Standard EOP-010-1 is ineffective because it does not require 

“quantified contingency planning.” Orquin maintains that operational procedures are of 

limited value and recommends using monitoring equipment and blocking devices at least 

as a back-up measure. 

Commission Determination

34. As the Commission stated in Order No. 779, operational procedures are not a 

complete solution to the risks posed by a GMD event to the Bulk-Power System. Order 

No. 779 directed NERC to develop Reliability Standards that require operational 

procedures because such Reliability Standards could be developed and implemented 

relatively quickly. While we recognize the concerns in the comments of Baker and 

others regarding the efficacy of operational procedures, Order No. 779 weighed those 

concerns in ultimately directing NERC to develop operational procedures in the First 

Stage GMD Reliability Standards and more comprehensive protections in the Second 

Stage GMD Reliability Standards.50 We affirm the determination in Order No. 779 that 

operational procedures constitute “an important first step to addressing the GMD 

reliability gap because they can be implemented relatively quickly ... [and] may help 

 50 In Order No. 779, the Commission noted that some entities have already 

implemented operational procedures that address GMD events. Order No. 779, 143 

FERC ¶ 61,147 at P 37. 
Docket No. RM14-1-000 - 25 -

alleviate abnormal system conditions due to transformer absorption of reactive power

during GMD events, helping to stabilize system voltage swings, and may potentially 

isolate some equipment from being damaged or misoperated.”51

35. With respect to the concerns raised by SmartSense regarding overreliance on 

space weather forecasts to trigger GMD operational procedures, Reliability Standard 

EOP-010-1 does not mandate the use of space weather to trigger the GMD operational 

procedures. While Requirement R2 requires reliability coordinators to disseminate 

current and forecasted space weather conditions to the appropriate functional entities, 

Requirement R3 requires transmission operators to develop Operating Procedures or 

Operating Processes that, at a minimum, include “System Operator actions to be initiated 

based on predetermined conditions.” Those “predetermined conditions” might include 

space weather information or other data, including GIC monitoring data, if available. 

Requirement R3 ultimately leaves it to the transmission operator to define the 

predetermined conditions in its Operating Procedure or Operating Process. Accordingly, 

we disagree that Reliability Standard EOP-010-1 requires that initiation of GMD 

operating procedures be based upon space weather only. 

36. We are not persuaded that the First Stage GMD Reliability Standards should 

require all responsible entities to monitor GICs or mandate sharing GIC monitoring data 

with reliability coordinators, as Foundation contends. As explained above, we directed 

 51 Order No. 779, 143 FERC ¶ 61,147 at P 36.
Docket No. RM14-1-000 - 26 -

NERC to develop only operational procedures in the First Stage GMD Reliability 

Standards, and to develop more comprehensive protections in the Second Stage GMD 

Reliability Standards. The issue of monitoring requirements properly belongs in the 

Second Stage GMD Reliability Standards.52 

37. In terms of real-time sharing of GIC information with reliability coordinators, we 

note that Reliability Standard COM-002-2, Requirement R1.1 states that “[e]ach 

Balancing Authority and Transmission Operator shall notify its Reliability Coordinator, 

and all other potentially affected Balancing Authorities and Transmission Operators 

through predetermined communication paths of any condition that could threaten the 

reliability of its area or when firm load shedding is anticipated.” Accordingly, if a 

transmission operator monitors GIC levels that could threaten the reliability of its area of 

the Bulk-Power System, the transmission operator would have to communicate that 

information to its reliability coordinator.53 With respect to Foundation’s comment that 

Reliability Standard EOP-010-1 should include “quantified contingency planning,” 

Foundation does not explain the meaning of this term. In any case, we note that 

Reliability Standard EOP-010-1, Requirement R3 requires applicable transmission 

 52 We will also consider then the need for the Second Stage GMD Reliability 

Standard’s planning requirements to integrate appropriately with the First Stage GMD 

Reliability Standard’s operating requirements.

53 We do not address here the issue of access to GMD monitoring data for other 

purposes, such as reassessing the benchmark GMD event, since this issue too belongs 

properly in the Second Stage GMD Reliability Standards.
Docket No. RM14-1-000 - 27 -

operators to “develop, maintain, and implement a GMD Operating Procedure or 

Operating Process to mitigate the effects of GMD events on the reliable operation of its 

respective system.” 

C. Implementation Plan and Effective Dates

NERC Petition

38. The NERC petition proposes that Reliability Standard EOP-010-1 become 

effective the “first day of the first calendar quarter that is six months after the date that 

this standard is approved by an applicable governmental authority.”54 However, NERC

states that Requirement R2 of Reliability Standard EOP-010-1, pertaining to reliability 

coordinator dissemination of space weather information, is meant to replace existing 

Requirement R3 of Reliability Standard IRO-005-3.1a, which includes similar language. 

Therefore, to avoid duplicative requirements being enforced at the same time, NERC

proposes that, if Reliability Standard EOP-010-1 becomes effective prior to the 

retirement of Reliability Standard IRO-005-3.1a, then Requirement R2 of Reliability 

Standard EOP-010-1 will not become effective until the first day following retirement of 

Reliability Standard IRO-005-3.1a.

55 According to NERC’s petition, Requirements R1 

 54 NERC Petition, Exhibit B (Implementation Plan) at 2.

55 We agree with NERC that Reliability Standard IRO-005-3.1a, Requirement R3, 

which requires that “[e]ach Reliability Coordinator shall ensure its Transmission 

Operators and Balancing Authorities are aware of Geo-Magnetic Disturbance (GMD) 

forecast information and assist as needed in the development of any required response 

plans,” and Requirement R2 of Reliability Standard EOP-010-1, which requires that 

“[e]ach Reliability Coordinator shall disseminate forecasted and current space weather 

(continued...)
Docket No. RM14-1-000 - 28 -

and R3 of Reliability Standard EOP-010-1 are not affected by the possible retirement of 

IRO-05-3.1a and, thus, will be effective the first day of the first calendar quarter that is 

six months after the date that the Reliability Standard is approved by an applicable 

governmental authority.

56 

NOPR

39. The NOPR proposed to approve NERC’s implementation plan and effective dates 

for Reliability Standard EOP-010-1. 

Comments

40. APS states that a six-month implementation period is not a sufficient amount of 

time to create a new Operating Process or Operating Procedure. APS explains that it will 

 

information to functional entities identified as recipients in the Reliability Coordinator’s 

GMD Operating Plan,” are largely duplicative in that both requirements require the 

dissemination of GMD forecast information, at a minimum, to applicable transmission 

operators.

56NERC Petition, Exhibit B (Implementation Plan) at 2. On April 16, 2013, 

NERC submitted a petition requesting approval of three revised IRO Reliability 

Standards and the retirement or revision of six currently-effective Reliability Standards, 

including IRO-005-3.1a (Docket No. RM13-15-000). On November 21, 2013, the 

Commission issued a Notice of Proposed Rulemaking that, inter alia, proposes to remand 

the proposed IRO Reliability Standards and related retirements and revisions. See

Monitoring System Conditions – Transmission Operations Reliability Standard, 

Transmission Operation Reliability Standards, Interconnection Reliability Operations 

and Coordination Reliability Standards, Notice of Proposed Rulemaking, 78 FR 73,112 

(Dec. 5, 2013), 145 FERC ¶ 61,158 (2013). On January 14, 2014, the Commission 

granted NERC’s motion to defer action, until January 31, 2015, on the rulemaking in 

Docket No. RM13-15-000. Monitoring System Conditions – Transmission Operations 

Reliability Standard, Transmission Operation Reliability Standards, Interconnection 

Reliability Operations and Coordination Reliability Standards, 146 FERC ¶ 61,023 

(2014).
Docket No. RM14-1-000 - 29 -

develop an Operation Process or Operating Procedure after its reliability coordinator 

develops an Operating Plan that identifies the activities designed to mitigate the effects of 

GMD events on the Bulk-Power System. APS states that its Operating Process or 

Operating Procedure will then be reviewed by the reliability coordinator, and that it is 

unrealistic to expect all this to be done in six months. APS proposes allowing the

reliability coordinator six months to develop its Operating Plan and then allowing 

transmission operators a further six months to develop their Operating Processes or 

Operating Procedures.

Commission Determination

41. We determine that a six-month implementation period, as proposed by NERC, 

allows enough time for reliability coordinators and transmission operators to implement 

the requirements of Reliability Standard EOP-010-1. Only APS indicates that a sixmonth period does not afford applicable entities enough time to implement the Reliability 

Standard. No other commenter expresses similar concerns. Further, we see no reason 

why, as APS contends, a transmission operator must wait until its reliability coordinator 

has completed its Operating Plan before the transmission operator begins work on its 

Operating Process or Operating Procedure. Reliability coordinators and transmission 

operators should be able to work largely in parallel and coordinate their efforts to 

implement the requirements of the Reliability Standard. Accordingly, we approve the 

implementation plan and effective dates proposed by NERC. 
Docket No. RM14-1-000 - 30 -

D. Other Issues

42. Commenters express concern that Reliability Standard EOP-010-1 does not 

address electromagnetic pulses (EMPs).57 However, Order No. 779 explicitly stated that 

EMPs were not within the scope of that rulemaking, which led to NERC’s petition here.

58 

Likewise, Reliability Standard EOP-010-1 is responsive to the Commission directive, and 

comments critiquing the Reliability Standard for not addressing EMPs are outside the 

scope of the immediate proceeding. 

43. Other commenters criticize the NERC Board of Trustees’ approval of Reliability 

Standard EOP-010-1 because “no substantive discussion occurred at the November 7 

meeting [at which the NERC Board of Trustees approved the Reliability Standard] and, 

as a result, the public was deprived of its right for due process under Section 215 of the 

Federal Power Act.”59 We find no basis to conclude that the NERC Board of Trustees 

either violated the NERC Rules of Procedure or otherwise acted improperly in approving 

Reliability Standard EOP-010-1. Foundation does not identify any rule or other 

provision that, it claims, the NERC Board of Trustees violated in allegedly failing to 

conduct a “substantive discussion” at the November 7 meeting. Moreover, in considering 

whether to approve Reliability Standard EOP-010-1, the Commission established this 

rulemaking docket to provide the public with an opportunity to comment; thus the public 

 57 See comments submitted by Orquin, EMP, Stolov, and Baker.

58 Order No. 779, 143 FERC ¶ 61,147 at P 14 n.20.

59 Foundation Comments at 45; see also CSP Comments at 1.
Docket No. RM14-1-000 - 31 -

has been afforded adequate due process under FPA section 215. This is in addition to 

opportunities to participate in NERC’s standard development process, by submitting 

comments or otherwise.

44. In response to a comment that Reliability Standard EOP-010-1 could interfere 

with the development of state-level efforts to address GMD events,60 we note that FPA 

section 215(j)(3) provides in relevant part that section 215 does not “preempt any 

authority of any State to take action to ensure the safety, adequacy, and reliability of 

electric service within that State, as long as such action is not inconsistent with any 

reliability standard.” We also observe that Reliability Standard EOP-010-1 does not 

preclude users, owners and operators of the Bulk-Power System from taking additional 

steps that are designed to mitigate the effects of GMD events, provided those additional 

steps are not inconsistent with the Commission-approved Reliability Standards.

E. Violation Risk Factors and Violation Severity Levels

45. Each requirement of proposed Reliability Standard EOP-010-1 includes one 

violation risk factor and has an associated set of at least one violation severity level. The 

ranges of ERO penalties for violations will be based on the sanctions table and supporting 

penalty determination process described in the Commission-approved NERC Sanction 

Guidelines, according to the NERC petition. The NOPR proposed to approve the 

proposed violation risk factors and violation severity levels for the requirements proposed 

 60 Maine Representative Boland Comments at 3.
Docket No. RM14-1-000 - 32 -

in Reliability Standard EOP-010-1as consistent with the Commission’s established 

guidelines.61 The Commission did not receive any comments regarding this aspect of the

NOPR. Accordingly, the Commission approves the violation risk factors and violation 

severity levels for the requirements in Reliability Standard EOP-010-1.

III. Information Collection Statement

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

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

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

expiration date. Respondents subject to the filing requirements of an agency rule will not 

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

collections of information display a valid OMB control number. The Paperwork 

Reduction Act (PRA) requires each federal agency to seek and obtain OMB approval 

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

contained in a rule of general applicability. 

47. The Commission is submitting these reporting requirements to OMB for its review 

and approval under section 3507(d) of the PRA. The Commission solicited comments on 

the need for and the purpose of the information contained in Reliability Standard EOP010-1 and the corresponding burden to implement the Reliability Standard. The 

Commission received comments on specific requirements in the Reliability Standard, 

 61 See North American Electric Reliability Corp., 135 FERC ¶ 61,166 (2011).
Docket No. RM14-1-000 - 33 -

which we address in this Final Rule. However, the Commission did not receive any 

comments on our reporting burden estimates or on the need for and the purpose of the 

information collection requirements.

48. The Commission based its paperwork burden estimates on the NERC compliance 

registry as of November 27, 2013. According to the registry, there are 16 reliability 

coordinators and 183 transmission operators.

49. The Commission estimates an increased burden for each requirement, as explained

in the chart below, for a total estimated burden of $238,800. The Commission based the 

burden estimates on staff experience, knowledge, and expertise:

Burden Estimate for Implementation of Reliability Standard EOP-010-1

Reliability 

Standard 

Number

Type of 

Respondents

Number of 

Respondents

(1)

Number of 

Responses 

per 

Respondent

(2)

Average 

Burden 

Hours 

Per 

Response

(3)

Total 

Annual 

Burden 

Hours

(1)x(2)x(3)

Total 

Annual 

Cost62

EOP-010-

1 (R1)

Reliability 

Coordinator

16 1 20 320 $19,200

($60/hr)

EOP-010-

1 (R3)

Transmission 

Operator

183 1 20 3660 $219,600

($60/hr)

TOTAL 3980 $238,800

 62 The estimated hourly loaded cost (salary plus benefits) for an engineer is 

assumed to be $60/hour, based on salaries as reported by the Bureau of Labor Statistics 

(BLS) (http://bls.gov/oes/current/naics2_22.htm). Loaded costs are BLS rates divided by 

0.703 and rounded to the nearest dollar (http://www.bls.gov/news.release/ecec.nr0.htm). 

While the BLS figures have been updated since the issuance of the NOPR, the new BLS 

figures are not significantly different. For consistency, the Commission continues with 

the same loaded cost figure used in the NOPR.
Docket No. RM14-1-000 - 34 -

50. The above chart does not include Reliability Standard EOP-010-1, Requirement 

R2 because, as NERC states, that requirement replaces IRO-005-3.1a, Requirement R3 

and has no change in overall burden. In addition, while our burden estimate with respect 

to Reliability Standard EOP-010-1, Requirement R3 assumes that all 183 transmission 

operators are subject to that requirement, we note that not all 183 transmission operators 

are likely to be subject to Requirement R3 because that requirement only applies to 

transmission operators with a Transmission Operator Area that includes a power 

transformer with a high side, wye-grounded winding with terminal voltage greater than 

200 kV.

Title: FERC-725S, Mandatory Reliability Standards: Reliability Standard EOP-010-1.

Action: Proposed Collection of Information.

OMB Control No: 1902-0270.

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

Frequency of Responses: One-time and ongoing.

Necessity of the Information: Reliability Standard EOP-010-1 implements the 

Congressional mandate of the Energy Policy Act of 2005 to develop mandatory and 

enforceable Reliability Standards to better ensure the reliability of the nation’s BulkPower System. Specifically, the Reliability Standard ensures that responsible entities 

have Operating Plans and Operating Procedures or Processes in place to mitigate the 

effects of geomagnetic disturbances on the Bulk-Power System. 
Docket No. RM14-1-000 - 35 -

Internal review: The Commission has reviewed Reliability Standard EOP-010-1 and has 

determined that the Reliability Standard is necessary to ensure the reliability and integrity 

of the Nation’s Bulk-Power System. 

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

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

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

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

the requirements of this rule may also be sent to the Office of Information and Regulatory 

Affairs, Office of Management and Budget, Washington, DC 20503 [Attention: Desk 

Officer for the Federal Energy Regulatory Commission]. For security reasons, comments 

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

submitted to OMB should include Docket Number RM14-1-000.

IV. Environmental Analysis

52. 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.63 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

 63 Regulations Implementing the National Environmental Policy Act, Order No. 

486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs., Regulations Preambles 

1986-1990 ¶ 30,783 (1987).
Docket No. RM14-1-000 - 36 -

not substantially change the effect of the regulations being amended.64 The actions here 

fall within this categorical exclusion in the Commission’s regulations. 

V. Regulatory Flexibility Act

53. The Regulatory Flexibility Act of 1980 (RFA)65 generally requires a description 

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

number of small entities.

54. The NOPR compared the NERC compliance registry with data submitted to the 

Energy Information Administration on Form EIA-861, which indicated that perhaps as 

many as 34 small entities were registered as transmission operators and no small entities 

were registered as reliability coordinators. However, the Commission estimated in the 

NOPR that there will be no material change in burden for the 34 transmission operators 

that qualified as small entities because they will likely not be subject to Reliability 

Standard EOP-010-1. Reliability Standard EOP-010-1 applies to transmission operators 

with a Transmission Operator Area that includes a power transformer with a high side,

wye-grounded winding with terminal voltage greater than 200 kV. The NOPR stated that 

transmission operators with Transmission Operator Areas that include a power 

transformer with a high side, wye-grounded winding with terminal voltage greater than 

200 kV are generally large entities serving substantial geographical areas with significant 

 64 18 CFR 380.4(a)(2)(ii).

65 5 U.S.C. 601-612.
Docket No. RM14-1-000 - 37 -

energy output. The Commission did not receive any comments regarding this aspect of 

the NOPR.

55. Since the issuance of the NOPR, the Small Business Administration changed the 

small business size standard applicable to reliability coordinators and transmission 

operators. The Commission currently does not have an estimate of the number of small 

reliability coordinators and transmission operators using the new size standard. 

However, the Commission still estimates that the specific applicability of Reliability 

Standard EOP-010-1 means that generally only large entities will have to meet the new 

requirements.

56. Based on the above, the Commission certifies that Reliability Standard EOP-010-1

will not have a significant impact on a substantial number of small entities. Accordingly, 

no initial regulatory flexibility analysis is required. 

VI. Document Availability

57. 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.

58. 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 
Docket No. RM14-1-000 - 38 -

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

document in the docket number field.

59. User assistance is available for eLibrary and the Commission’s website during 

normal business hours from the Commission’s Online Support at (202) 502-6652 (toll 

free at 1-866-208-3676) or email at ferconlinesupport@ferc.gov, or the Public Reference 

Room at (202) 502-8371, TTY (202) 502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov.

VII. Effective Date and Congressional Notification

60. These regulations are effective [INSERT DATE 60 days after publication in the 

FEDERAL REGISTER]. The Commission has determined, with the concurrence of the 

Administrator of the Office of Information and Regulatory Affairs of OMB, that this rule 

is not a “major rule” as defined in section 351 of the Small Business Regulatory 

Enforcement Fairness Act of 1996. 

By the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.
Docket No. RM14-1-000 - 39 -

Appendix 

Commenters 

Abbreviation Commenter

AEP American Electric Power Service Corporation

AFS Advanced Fusion Systems

APS Arizona Public Service Company

ASO Atomic Safety Organization

Baker George H. Baker

Maine Representative Boland Hon. Andrea M. Boland, Maine State Representative

CSP Center for Security Policy

Dominion Dominion Resources Services, Inc.

EEI Edison Electric Institute

EMP Coalition EMP Coalition

Emprimus Emprimus LLC

Chamber of Commerce Institute for 21st Century Energy, U.S. Chamber of 

Commerce

Foundation Foundation for Resilient Societies

IRC ISO/RTO Council

ITC International Transmission Company

Kappenman John G. Kappenman

NERC North American Electric Reliability Corporation

Orquin Alberto Ramirez Orquin

SmartSenseCom SmartSenseCom, Inc.

Stolov Jerome J. Stolov