133 FERC ¶ 61,074 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 C.F.R. Part 40 

Docket No. RM09-19-000 

Western Electric Coordinating Council 

Qualified Transfer Path Unscheduled Flow Relief Regional Reliability Standard 

(October 21, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Proposed Rulemaking. 

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

Regulatory Commission (Commission) proposes to approve regional Reliability Standard 

IRO-006-WECC-1 (Qualified Transfer Path Unscheduled Flow Relief) submitted to the 

Commission for approval by the North American Electric Reliability Corporation. While 

we propose to approve the regional Reliability Standard, as discussed in this Notice of 

Proposed Rulemaking, IRO-006-WECC-1 raises some concerns about which the 

Commission requests additional information. Depending upon the responses received, in 

the Final Rule the Commission may, as a separate action under section 215(d)(5) of the 

FPA, direct the Western Electricity Coordinating Council to develop modifications to the 

regional Reliability Standard to address the issues identified. 

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

FEDERAL REGISTER]. 
Docket No. RM09-19-000 - 2 - 

ADDRESSES: Interested persons may submit comments, identified by Docket 

No. RM09-19-000, by any of the following methods: 

 Agency Web Site: http://www.ferc.gov. Documents created electronically using 

word processing software should be filed in native applications or print-to-PDF 

format and not in a scanned format. 

 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 

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 ¶ 61,074 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Western Electric Coordinating Council 

Qualified Transfer Path Unscheduled Flow Relief 

Regional Reliability Standard 

Docket No. RM09-19-000 

NOTICE OF PROPOSED RULEMAKING 

(October 21, 2010) 

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

 the Commission proposes to 

approve regional Reliability Standard IRO-006-WECC-1 (Qualified Transfer Path 

Unscheduled Flow Relief) submitted to the Commission for approval by the North 

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

Reliability Organization (ERO). While we propose to approve the regional Reliability 

Standard, as discussed in this Notice of Proposed Rulemaking, IRO-006-WECC-1 raises 

some concerns about which the Commission requests additional information. Depending 

upon the responses received, the Commission may, in the Final Rule, direct the Western 

Electricity Coordinating Council (WECC) to develop modifications to the regional 

Reliability Standard to address the issues identified. 

 

1

 16 U.S.C. 824o. 
Docket No. RM09-19-000 - 2 - 

I. Background 

A. Section 215 of the FPA and NERC Reliability Standard IRO-006

2. Section 215 of the FPA requires a Commission-certified ERO to develop 

mandatory and enforceable Reliability Standards, which are subject to Commission 

review and approval.2

 Approved Reliability Standards are enforced by the ERO, subject 

to Commission oversight, or by the Commission independently. 

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

Reliability Standards proposed by NERC, including Reliability Standard IRO-006-3, 

titled “Reliability Coordination – Transmission Loading Relief.”3

 In addition, the 

Commission directed the ERO to develop modifications to IRO-006-3 and other 

approved Reliability Standards to address specific issues identified by the Commission, 

pursuant to section 215(d)(5) of the FPA. 

4. NERC Reliability Standard IRO-006-3 establishes a Transmission Loading Relief 

(TLR) process for use in the Eastern Interconnection to alleviate loadings on the system 

by curtailing or changing transactions based on their priorities and according to different 

levels of TLR procedures. Requirement R2.2 provides that “the equivalent 

 2

 The Commission certified NERC as the ERO in July 2006. North American 

Electric Reliability Corp., 116 FERC ¶ 61,062 (ERO Certification Order), order on reh’g 

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

F.3d 1342 (D.C. Cir. 2009). 

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

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

(2007). 
Docket No. RM09-19-000 - 3 - 

Interconnection-wide transmission loading relief procedure for use in the Western 

Interconnection is the WECC Unscheduled Flow Mitigation Plan.” This document 

provides detailed instructions for addressing unscheduled flows, e.g., parallel path flows, 

based on the topography and configuration of the Bulk-Power System in the Western 

Interconnection. The Unscheduled Flow Mitigation Plan identifies nine “steps” to 

address unscheduled flows. In the first three steps, the Mitigation Plan relies on phase 

angle regulators, series capacitors, and back-to-back DC lines to mitigate contingencies 

without curtailing transactions. Steps four and above involve curtailment of transactions. 

5. On March 19, 2009, the Commission approved IRO-006-4, which modified the 

prior version of the Reliability Standard and addressed the Commission’s directives from 

Order No. 693.4

 The Commission subsequently accepted an erratum to that Reliability 

Standard that corrected the reference in Requirement R1.2 to the Unscheduled Flow 

Mitigation Plan (Mitigation Plan).5

 4 Modification of Interchange and Transmission Loading Relief Reliability 

Standards; and Electric Reliability Organization Interpretation of Specific Requirements 

of Four Reliability Standards, Order No. 713-A, 126 FERC ¶ 61,252 (2009).

5 North American Electric Reliability Corp., Docket No. RD09-9-000 (Dec. 10, 

2009) (unpublished letter order). Note that Reliability Standard IRO-006-4.1, 

Requirement R1.2 refers to the “WECC Unscheduled Flow Reduction Procedure,” which 

is Attachment 1 to the Mitigation Plan, the term we use herein. 
Docket No. RM09-19-000 - 4 - 

B. WECC Delegation Agreement and WECC Regional Reliability 

Standard IRO-STD-006-0

6. On April 19, 2007, the Commission approved delegation agreements between 

NERC and each of the eight Regional Entities, including WECC.6

 Pursuant to such 

agreements, the ERO delegated responsibility to the Regional Entities to enforce the 

mandatory, Commission-approved Reliability Standards. In addition, the Commission 

approved, as part of each delegation agreement, a Regional Entity process for developing 

regional Reliability Standards. In the Delegation Agreement Order, the Commission 

accepted WECC as a Regional Entity organized on an Interconnection-wide basis and 

accepted WECC’s Standards Development Manual, which sets forth the process for 

development of WECC’s Reliability Standards.7

 

7. On June 8, 2007, the Commission approved eight WECC regional Reliability 

Standards that apply in the Western Interconnection, including IRO-STD-006-0.8

 The 

regional Reliability Standard applies to transmission operators, load-serving entities and 

balancing authorities within the Western Interconnection. Currently effective IRO-STD006-0 addresses the mitigation of transmission overloads due to unscheduled line flow on 

specified paths. Specifically, Requirement R1 of IRO-STD-006-0 states that: 

 6 See North American Electric Reliability Corp., 119 FERC ¶ 61,060, order on 

reh’g, 120 FERC ¶ 61,260 (2007) (Delegation Agreement Order). 

7 Id. P 469-470. 

8 North American Electric Reliability Corp., 119 FERC ¶ 61,260 (June 8, 2007 

Order). 
Docket No. RM09-19-000 - 5 - 

WECC’s Unscheduled Flow Mitigation Plan (Plan) ... specifies that 

members shall comply with requests from (Qualified) Transfer Path 

Operators to take actions that will reduce unscheduled flow on the 

Qualified Path in accordance with the table entitled “WECC Unscheduled 

Flow Procedure Summary of Curtailment Actions,” which is located in 

Attachment 1 of the Plan.9

The regional Reliability Standard then provides excerpts from the plan that describe 

actions entities must take to address unscheduled flow. 

8. The June 8, 2007 Order directed WECC to develop certain modifications to the 

eight WECC Reliability Standards to address issues identified by the Commission. With 

respect to IRO-STD-006-0, the Commission directed WECC to clarify the term 

“receiver” used in the Reliability Standard. The Commission also directed WECC to 

address concerns raised by a commenter regarding WECC’s inclusion of load-serving 

entities, which may be unable to meet the Reliability Standard’s requirements, in the 

applicability section of the Reliability Standard.10 The Commission directed WECC to 

remove a Sanctions Table (identifying a maximum penalty of $10,000 per violation) that 

is inconsistent with the NERC Sanctions Guidelines. The Commission also directed 

WECC to address NERC’s concerns regarding formatting, use of standard terms, and the 

need for greater specificity in the actions that a responsible entity must take. 

 9

 Regional Reliability Standard IRO-STD-006-0, available at 

http://www.wecc.biz/Standards/Approved%20Standards/IRO-STD-006-0.pdf. 

10 June 8, 2007 Order, 119 FERC ¶ 61,260 at P 70-71. 
Docket No. RM09-19-000 - 6 - 

II. Petition for Proposed Regional Reliability Standard IRO-006-WECC-1 

A. Proposed Regional Reliability Standard

9. In a June 17, 2009 filing, NERC requests Commission approval of proposed 

regional Reliability Standard IRO-006-WECC-1, which was developed in response to the 

Commission’s directives in the June 8, 2007 Order, to replace the currently effective 

regional Standard.11 NERC states that the purpose of IRO-006-WECC-1 is to mitigate 

transmission overloads due to unscheduled flow on Qualified Transfer Paths. Under the 

Reliability Standard, reliability coordinators are responsible for initiating schedule 

curtailments and balancing authorities are responsible for implementing the curtailments. 

Specifically, proposed regional Reliability Standard IRO-006-WECC-1 contains the 

following two Requirements: 

R.1. Upon receiving a request of Step 4 or greater (see Attachment 1-

IRO-006-WECC-1) from the Transmission Operator of a Qualified 

Transfer Path, the Reliability Coordinator shall approve (actively or 

passively) or deny that request within five minutes. 

R.2. The Balancing Authorities shall approve curtailment requests to the 

schedules as submitted, implement alternative actions, or a combination 

there of that collectively meets the Relief Requirement. 

An attachment to IRO-006-WECC-1 summarizes the nine steps and related actions to 

address unscheduled flows. 

 11 North American Electric Reliability Corp., June 17, 2009 Petition for Approval 

of Proposed Western Electricity Coordinating Council Regional Reliability Standard 

IRO-006-WECC-1 (NERC Petition). 
Docket No. RM09-19-000 - 7 - 

10. NERC states that the revised regional Reliability Standard addresses the 

Commission’s prior concerns by removing load-serving entities as an applicable entity, 

no longer referring to receivers, and addressing formatting changes required by NERC 

and the Commission’s June 8, 2007 Order. Further, NERC states the proposed 

Reliability Standard is justified on the basis that the regional Reliability Standard’s 

requirements are more stringent than those contained in the associated NERC Reliability 

Standard IRO-006-4. NERC explains that the NERC Reliability Standard IRO-006-4 

requires a reliability coordinator experiencing a potential or actual System Operating 

Limit (SOL) or Interconnection Reliability Operating Limit (IROL) violation to take 

appropriate actions to relieve transmission loading using local or Interconnection-wide 

procedures. According to NERC, Requirement R1 of the proposed regional Reliability 

Standard IRO-006-WECC-1 goes beyond the NERC requirements by establishing a 

process to reduce schedules that prevents potential overloads during the next operating 

hour. In addition, the proposed Reliability Standard requires each reliability coordinator 

to approve or deny a request submitted by a Qualified Transfer Path transmission 

operator within five minutes. Requirement R2 of the proposed regional Reliability 

Standard requires each balancing authority to approve curtailment requests to the 

schedules as submitted, implement alternative actions, or a combination thereof, which 

collectively meet the relief requirement. 

B. Concerns Raised by NERC Regarding the WECC Proposal

11. In the Petition, NERC explains that, when WECC submitted IRO-006-WECC-1 

for NERC’s review, NERC was concerned that the proposed Standard no longer contains 
Docket No. RM09-19-000 - 8 - 

requirements that are more stringent than the continent-wide NERC Reliability Standard 

IRO-006-4, which was the main justification for consideration of IRO-006-

WECC-1 as the regional Reliability Standard.12 NERC states that, at the direction of the 

NERC Board of Trustees, NERC staff met several times with WECC staff to discuss its 

concerns with the proposed regional Reliability Standard. 

1. Pre-Curtailment Actions

12. In its Petition, NERC expressed several concerns. First, NERC was concerned 

that the proposed Standard only includes the curtailment portion of the Mitigation Plan. 

In contrast, the current regional Reliability Standard IRO-STD-006-0 references WECC’s 

Mitigation Plan, which contains directions in steps one through three to reduce flows 

through use of phase-angle regulators, series capacitors, and back-to-back DC lines 

before transaction curtailment. 

13. According to the NERC Petition, WECC explained that the proposed regional 

Reliability Standard contains the curtailment portion of the Mitigation Plan “because the 

remaining items contain procedural requirements explaining ‘how,’ not ‘what.’”13 

WECC explained to NERC that two WECC regional Reliability Standards work together. 

Proposed IRO-006-WECC-1 prevents overloads during the next hour by requiring 

applicable entities to reduce schedules and adjust generation patterns. In addition, 

 12 Id 26-27. 

13Id. at 30. 
Docket No. RM09-19-000 - 9 - 

regional Reliability Standard TOP-007-WECC-1 (System Operating Limits), contains 

instructions for mitigation of an actual, real-time overload.14 According to WECC, these 

regional Reliability Standards, combined, ensure that the transmission operator will 

utilize the phase-angle regulators, series capacitors, and back-to-back DC lines before 

transaction curtailment. 

14. In addition, NERC provided additional supplemental information in Exhibit C of 

its Petition regarding how WECC envisions the implementation of proposed regional 

Reliability Standard IRO-006-WECC-1. Exhibit C contains the complete development 

record of proposed regional Reliability Standard IRO-006-WECC-1 and includes 

WECC’s undated response to NERC’s concerns regarding the interaction between TOP007-WECC-1 and IRO-006-WECC-1.15 

15. Specifically, NERC raised a concern that “IRO-006-WECC-1 removed a 

requirement for the Transmission Operator (TOP) to request relief through the WECC 

Qualified Path Unscheduled Flow Relief Procedure when a qualified transfer path 

exceeded or was close to exceeding a System Operating Limit (SOL).” In response, 

WECC stated that “the requirements of another WECC regional reliability standard, 

TOP-STD-007-0 (interim approved Tier 1 standard), as well as the WECC proposed 

 14 NERC’s petition for approval of regional Reliability Standard 

TOP-007-WECC-1 is currently pending before the Commission in Docket No. 

RM09-14-000. 

15 The document is titled, “Interaction between TOP-007-WECC-1 and 

IRO-006-WECC-1.” 
Docket No. RM09-19-000 - 10 - 

replacement regional reliability standard TOP-007-WECC-1, require the TOP to take 

actions to ensure that SOLs are not exceeded.”16 

16. WECC further explained that TOP-WECC-007-1 requires Transmission Operators 

to keep path flows and schedules at or below SOLs for 40 identified paths. WECC stated 

that “TOPs, in coordination with the Reliability Coordinators, may select from several 

methods” to reduce flows, and provide several examples, such as on path schedule 

curtailments, adjust controllable devices (e.g., phase shifters, series capacitors), use of 

the WECC Mitigation Plan if the path experiencing the loading is a qualified path, or 

local procedures, as well as other examples. WECC further explained that the “key 

point” with respect to qualified paths, “is that it is TOP-007-WECC-1, not IRO-006-

 16 Exhibit C to NERC Petition, Interaction between TOP-007-WECC-1 and 

IRO-006-WECC-1 at 1. 

Requirement WR1 of the currently applicable regional Reliability Standard, 

TOP-STD-007-0 provides, in part, that “Actual power flow and net scheduled power flow 

over an interconnection or transfer path shall be maintained within Operating Transfer 

Capability Limits.” The NERC Glossary defines Operating Transfer Capability Limit 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) postcontingency loading and voltage criteria.” 

Proposed regional Reliability Standard TOP-007-WECC-1, Requirement R1 

provides that “When the actual power flow exceeds an SOL 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 SOL for more than 30 minutes.” 
Docket No. RM09-19-000 - 11 - 

WECC-1, that requires the TOP to take actions to reduce flows to within SOLs.”17 In 

situations where the Transmission Operator has taken action to reduce the flows on 

qualified paths, but the flows remain near or exceeding the SOL, “IRO-006-

WECC-1 requires curtailment of Contributing Schedules or provision of comparable 

relief through other means, as identified in the Unscheduled Flow Reduction Procedure [a 

portion of the Mitigation Plan].”18 WECC further notes that “implementation of the 

[Mitigation Plan] is one of the options available to the TOP to prevent potential violations 

of TOP-007-WECC-1. If the TOP is able to take other actions to keep actual flows 

within SOLs, the TOP may not need or desire to utilize the [Mitigation Plan]. ... 

However, if the TOP chooses the [Mitigation Plan] as one of the alternatives to manage 

flows, the requirements of IRO-006-WECC-1 make it mandatory for entities with 

Contributing Schedules to curtail these schedules, upon approval by the [reliability 

coordinator], to provide the necessary relief.”19 WECC summarizes the interaction 

between the two regional standards, stating that “IRO-006-WECC-1 provides entities 

with the necessary motivation to curtail off-path schedules and adjust generation to 

 17 Exhibit C to Petition, Interaction between TOP-007-WECC-1 and 

IRO-006-WECC-1 at 2. 

18 Id. at 2-3. 

19 Id. at 3. 
Docket No. RM09-19-000 - 12 - 

prevent and/or reduce qualified path overloads, thus facilitating compliance with TOP007-WECC-1.”20

2. Role of Reliability Coordinator 

17. NERC’s second concern with the proposed regional Standard was with regard to 

the role of the reliability coordinator. According to the NERC Petition, NERC staff 

requested clarification regarding the role of the reliability coordinator in initiating 

curtailments. In the proposed Reliability Standard, IRO-006-WECC-1, the reliability 

coordinator is only obligated to respond to a transmission operator’s curtailment request. 

However, there is no mention in either the proposed Standard IRO-006-WECC-1 or 

TOP-007-WECC-1 that the entity with the wide-area view, the reliability coordinator, 

can initiate curtailment requests if needed for reliability. Nor do they indicate what 

recourse the transmission operator has if the reliability coordinator denies the request for 

curtailment. WECC confirmed that the reliability coordinator does not initiate 

curtailments but, rather, approves the transmission operator’s request for curtailment. 

Requirement R1 of proposed IRO-006-WECC-1 requires the reliability coordinator to 

approve or deny the request, which is accomplished using the OATI webSAS tool.21 

 20 Id. at 4. 

21 The webSAS (Security Analysis System) is a proprietary internet based 

application that is used by WECC to analyze, initiate, communicate, and provide 

compliance reports for implementation of the Unscheduled Flow Reduction Procedure. It 

is available by subscription through the vendor to provide notification of Unscheduled 

Flow Events, calculate and display required relief, and provide a rapid method of 

transaction curtailments. 
Docket No. RM09-19-000 - 13 - 

Unless the reliability coordinator denies the request for reliability reasons, the webSAS 

tool, through preprogrammed algorithms, identifies the off-path schedules to curtail and 

submits those curtailments to the entities identified on the tags. WECC also confirmed 

that the reliability coordinator has the wide-area view and, when a transmission operator 

requests curtailment of off-path schedules, the reliability coordinator may deny the 

request for reliability reasons. In that situation, the transmission operator, in coordination 

with the reliability coordinator, would then follow one of the other WECC or local 

procedures for reducing path flow. 

18. NERC states that, as a result of WECC’s clarification, the NERC Board of 

Trustees approved proposed IRO-006-WECC-1 on February 10, 2009. 

III. Discussion

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

Standard IRO-006-WECC-1, as just, reasonable, not unduly discriminatory or 

preferential, and in the public interest. In addition, we ask WECC, the ERO, and other 

interested entities to provide further clarification regarding several aspects of the 

proposed regional Reliability Standard. Depending on the responses to our concerns, we 

may determine that it is appropriate to direct WECC to develop modifications to the 

proposed regional Reliability Standard under section 215(d)(5) of the FPA. 

20. It is the Commission’s view that the proposed regional Reliability Standard 

adequately addresses a number of the directives identified in the June 8, 2007 Order and 

represents improvement to the standard. For example, it appears that IRO-006-WECC-1 

adequately addresses our concern regarding use of the term “receiver” by removing the 
Docket No. RM09-19-000 - 14 - 

term, and thereby eliminating potential confusion that could result from the undefined 

term. The proposed regional Reliability Standard also provides additional clarity by 

removing load-serving entities from the applicability section of the standard. This is 

beneficial since, as noted by NERC and WECC, load-serving entities may be unable to 

meet the Reliability Standard’s requirements with regard to curtailment procedures. 

Further, unlike the currently effective regional Reliability Standard, IRO-006-WECC-1 

would include reliability coordinators as an applicable entity and would address their role 

in curtailment procedures. 

21. As indicated by NERC, proposed IRO-006-WECC-1 appears to go beyond the 

corresponding NERC Reliability Standard by requiring a reliability coordinator to 

approve or deny a request submitted by a transmission operator within five minutes. 

22. The WECC Reliability Standard also addresses formatting concerns, including the 

use of standard terms, conformance with NERC’s Violation Severity Level and Violation 

Risk Factor matrix, and the elimination of a WECC sanction table (with a maximum 

penalty of $10,000) and “Excuse of Performance” section in the currently effective 

WECC standard that significantly differ from NERC’s Sanction Guidelines. In addition, 

IRO-006-WECC-1 ensures that the requirements are part of the regional Reliability 

Standard rather than embedded in a filing. For these reasons, we propose to approve the 

proposed WECC Reliability Standard. 

Commission Concerns

23. However, in addressing the Commission’s directives, such as the removal of loadserving entities and the term “receivers,” it appears that WECC has raised some other 
Docket No. RM09-19-000 - 15 - 

concerns that create possible conflicts or inconsistencies between proposed IRO-006-

WECC-1 and NERC’s currently effective IRO-006-4, as discussed below. In modifying 

the regional Reliability Standard, WECC has eliminated the reference to the Mitigation 

Plan, included in both the NERC standard, IRO-006-4, and the currently effective WECC 

standard. As mentioned above, the Mitigation Plan includes nine steps to address 

unscheduled flows; steps four and above requiring varying levels of curtailments of 

transactions. Requirement R1 of proposed IRO-006-WECC-1 provides that “[u]pon 

receiving a request of Step 4 or greater ... from the Transmission Operator of a Qualified 

Transfer Path, the Reliability Coordinator shall approve ... or deny that request within 

five minutes,” however, steps one through three are no longer referenced in IRO-006-

WECC-1 or in the related regional Standard TOP-007-WECC-1. 

24. On the other hand, NERC Reliability Standard IRO-006-4 continues to 

specifically reference the Mitigation Plan with regard to transmission loading relief in the 

Western Interconnection. However, the Mitigation Plan has not been updated to include 

the requirement that the reliability coordinator act on a request for relief within five 

minutes, an improvement contained in WECC’s proposed IRO-006-WECC-1. Likewise, 

the Mitigation Plan continues to reference and require action by “receivers,” while that 

term is removed from the proposed WECC regional Reliability Standard, in conformance 

with the Commission’s directive in the June 8, 2007 Order. 

25. Because of these dichotomies between the proposed regional Reliability Standard 

and the corresponding NERC Standard, we have several areas of concern regarding how 

the proposed regional Standard would work in practice to ensure Reliable Operation in 
Docket No. RM09-19-000 - 16 - 

the Western Interconnection. Specifically, we are concerned with: (1) how entities will 

know whether to follow the national or regional Standard in a given situation; (2) 

WECC’s and NERC’s reliance on TOP-007-WECC-1 to ensure that entities manage 

power flows using steps one through three of the Mitigation Plan prior to requesting 

curtailments; (3) how the webSAS tool will work with respect to the national and 

regional Standard; and (4) the potential reliability impact of reliability coordinators’ 

inability to request curtailments. 

26. With regard to our first concern, it is our understanding that in responding to 

unscheduled flows on qualified paths, entities would initially follow the requirements of 

the current regional TOP-007 Reliability Standard (whichever version is in effect), which 

would allow the option of using steps one through three of the Mitigation Plan. Although 

the requirement in the current regional Reliability Standard TOP-STD-007-0 does not 

specifically require Transmission Operators to perform steps one through three of the 

Mitigation Plan, it requires Transmission Operators to maintain flow within Operating 

Transfer Capability Limits, which gives the Transmission Operator the authority to take 

whatever actions necessary to return within its Operating Transfer Capability Limit or 

SOL (depending on the version of the Standard). Specifically, as described above, the 

approved regional Reliability Standard TOP-STD-007-0 does not allow for operation 

exceeding an Operating Transfer Capability Limit for longer than a specified period of 

time. Additionally, without prejudging the proposal pending before us in Docket No. 

RM09-9-000, we note that proposed regional Standard TOP-WECC-007-0 does not allow 

for operation exceeding an SOL for longer than a specified period of time and also 
Docket No. RM09-19-000 - 17 - 

requires a transmission operator to take immediate action to reduce such flows. Thus, as 

WECC explained with respect to the proposed TOP-007-WECC-1, one of the 

Transmission Operator’s options for ensuring that flows are maintained within Operating 

Transfer Capability Limits is to utilize steps one through three. Both of these regional 

Reliability Standards give the transmission operator authority to use various means to 

ensure that the system is returned to within an SOL or IROL, including utilizing the 

options listed within steps one through three of the Mitigation Plan if deemed 

appropriate. If those steps prove ineffective, it is our understanding that a transmission 

operator may choose, if the path qualifies, to request curtailments, which would require 

reliability coordinators and balancing authorities to follow steps four through nine of the 

proposed regional Standard, IRO-006-WECC-1. Because of this, we are unclear how the 

NERC IRO-006-4 national Reliability Standard would interact with the regional 

Reliability Standards, or if the national and regional Standards are duplicative. 

Accordingly, we request comment from NERC, WECC, and other interested entities 

regarding the interaction between the differing requirements contained in the regional 

versus national Reliability Standard. We also seek comment on which of the Standards’ 

requirements take precedence and how NERC envisions ensuring compliance and 

consistent enforcement with regard to the Standards. 

27. In a related vein, NERC indicates that proposed IRO-006-WECC-1 is more 

stringent than NERC Reliability Standard IRO-006 and “goes beyond the NERC 
Docket No. RM09-19-000 - 18 - 

Requirements by establishing a process to reduce schedules that prevent potential 

overloads during the next operating hour.”22 However, it is not clear to the Commission 

why that same benefit is not contained in the Mitigation Plan, which is referenced in the 

corresponding NERC Reliability Standard. The Commission seeks comment on this 

matter. 

28. Our second concern is that, as noted above, the portion of the Mitigation Plan that 

the Commission relied upon in determining that the current regional Reliability Standard 

IRO-STD-006-0 is more stringent than the NERC Standard was contained within the 

procedures for steps one through three (i.e., use of phase-angle regulators, series 

capacitors, and back-to-back DC lines to mitigate unscheduled flows before transaction 

curtailment), which is no longer referenced in proposed IRO-006-WECC-1. The NERC 

Petition states that another WECC regional Reliability Standard, TOP-STD-007-0 or 

TOP-007-WECC-1 (whichever is in effect), works in conjunction with IRO-006-WECC1 to ensure these functions are performed. However, TOP-STD-007-0 requires 

transmission operators to ensure that power flows are maintained within Operating 

Transfer Capability Limits, but does not explicitly state that they must perform steps one 

through three of the Mitigation Plan. Similarly, without prejudging the pending proposal, 

it appears that TOP-007-WECC-1 generally requires entities to take action to reduce the 

actual flow to within SOL levels in within set time limits, but does not explicitly require 

 22 NERC Petition at 11. 
Docket No. RM09-19-000 - 19 - 

action based on the specific options set forth in steps one through three of the Mitigation 

Plan. NERC and WECC posit that TOP-007-WECC-1 focuses on the “what” and not the 

“how.” Nonetheless, the Commission is concerned whether WECC’s reliance on TOPSTD-007-0 or TOP-007-WECC-1 (whichever is in effect) is an adequate replacement for 

the currently required pre-curtailment actions set forth and currently required in steps one 

through three of the Mitigation Plan. We request further explanation from NERC and 

WECC on this issue. Depending upon the response and comments, the Commission may 

determine it is appropriate to direct NERC and WECC to include references in IRO-006-

WECC-1 to the specific actions set forth in steps one through three of the Mitigation 

Plan. 

29. Third, as discussed above, NERC’s Petition explains that the webSAS tool uses 

preprogrammed algorithms to calculate curtailments and, unless the reliability 

coordinator actively denies the request, webSAS approves the curtailment within five 

minutes.23 We request additional information regarding how the webSAS program 

works in relation to WECC’s proposed IRO-006-WECC-1, as well as NERC’s curr

effective IRO-006-4, which is incorporated by reference in the Mitigation Plan. For 

example, we ask that comments address how the webSAS program incorporates the 

process outlined in the Mitigation Plan. We also seek comment regarding how 

differences between the process detailed in the Mitigation Plan, which remains 

ently 

 23 NERC Petition at 28-29. 
Docket No. RM09-19-000 - 20 - 

incorporated by reference in NERC’s IRO-006-4, and the webSAS programming could 

create conflicts with respect to enforcement. 

30. Fourth, the Commission is concerned about the possibility that automatic approval 

through the webSAS tool may occur without reliability coordinator review, as well as 

reliability coordinators’ inability to request curtailments, and the resultant affect on 

reliability. Since, as the NERC Petition indicated, reliability coordinators are the only 

entities with the wide-area view, it is the Commission’s view that it is appropriate that 

reliability coordinators, as the entity with the highest level of authority to ensure reliable 

operation of the Bulk-Power System24, have the ability to act to ensure reliability if 

necessary. For example, this is consistent with a reliability coordinator’s ability to 

initiate relief procedures without first receiving a request from a transmission operator as 

established in NERC Reliability StandardIRO-001-125 and IRO-006-4.26 We request 

comment on these concerns. 

31. While we believe IRO-006-WECC-1 generally is acceptable and responsive to the 

directives in the June 8, 2007 Order, because of the issues noted above, we observe that 

 24 See NERC Glossary definition of “reliability coordinator.” 

25 Reliability Standard IRO-001-1, Requirement R3, provides that the reliability 

coordinator “shall have clear decision-making authority to act and direct actions ... to 

preserve the integrity and reliability of the Bulk Electric System.” 

26 Reliability Standard IRO-006-4, Requirement R1 provides that a reliability 

coordinator experiencing a potential or actual system operating limit or interconnection 

reliability operator limit “shall, with its authority and at its discretion, select one or more 

procedures to provide transmission loading relief.” 
Docket No. RM09-19-000 - 21 - 

maintaining both a regional difference in the national Reliability Standard and a regional 

Reliability Standard addressing unscheduled flows may be unnecessary and confusing. 

We believe it might be more efficient and appropriate to incorporate all the WECC rules 

and procedures with respect to unscheduled flow mitigation in a single document. Thus, 

the Commission requests comments regarding whether it should direct WECC to either 

(1) revise the Mitigation Plan referenced by IRO-006-4 to incorporate all the WECC 

rules and procedures, thus eliminating the need for the regional Reliability Standard; or 

(2) incorporate all the WECC rules and procedures into IRO-006-WECC-1 and TOP007-WECC-1 while eliminating the regional difference contained in NERC IRO-006-4.. 

Summary

32. We propose to approve proposed regional Reliability Standard IRO-006-WECC-1 

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

We also seek comment from the ERO, WECC, and other interested entities regarding the 

Commission’s specific concerns discussed above. The Commission may determine in the 

Final Rule, after considering such comments, that it is appropriate to direct WECC to 

develop additional modifications to IRO-006-WECC-1 and/or to update the Mitigation 

Plan. 
Docket No. RM09-19-000 - 22 - 

IV. Information Collection Statement 

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

certain information collection requirements imposed by agency rules.27 Upon approval 

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

expiration date. Respondents subject to the filing requirements of this proposed 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)

n 

 

28 requires each federal agency to seek and obtain OMB approval 

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

imposed by agency rules.29

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

and approval under section 3507(d) of the PRA. Comments are solicited on the 

Commission’s need for this information, whether the information will have practical 

utility, the accuracy of provided burden estimates, ways to enhance the quality, utility, 

and clarity of the information to be collected, and any suggested methods for minimizing 

the respondent’s burden, including the use of automated information techniques.

27 5 CFR 1320.11. 

28 44 U.S.C. 3501-20. 

29 44 U.S.C. 3502(3)(A)(i), 44 U.S.C. 3507(a)(3), 5 CFR 1320.11. The FERC725E reporting requirements originally were approved by OMB on 10/10/2007. 
Docket No. RM09-19-000 - 23 - 

35. This Notice of Proposed Rulemaking proposes to approve a new regional 

Reliability Standard, IRO-006-WECC-1, which will replace currently effective regional 

Reliability Standard IRO-STD-006-0 approved by the Commission on June 8, 2007.30 

Rather than creating entirely new requirements, the proposed regional Reliability 

Standard instead modifies and improves the existing regional Reliability Standard 

governing qualified transfer path unscheduled flow relief. Thus, this proposed 

rulemaking imposes a minimal additional burden on the affected entities. 

36. The proposed Reliability Standard does not require responsible entities to file 

information with the Commission. However, it does require responsible entities to 

develop, provide, and maintain certain information for a specified period of time, subject 

to inspection by WECC. Specifically, the proposed Reliability Standard requires the 

reliability coordinator and balancing authorities to document and maintain information 

regarding actions taken in response to requests to mitigate unscheduled flow. We believe 

our approval of WECC regional Reliability Standard IRO-006-WECC-1 will result in a 

minimal increase in reporting burdens as compared to current practices in WECC. 

37. Commission approval of proposed regional Reliability Standard 

IRO-006-WECC-1 would make the standard mandatory and enforceable. Therefore, the 

Commission will submit this proposed rule to OMB for review and approval of the 

reporting and recordkeeping requirements. 

 30 North American Electric Reliability Corp., 119 FERC ¶ 61,260. 
Docket No. RM09-19-000 - 24 - 

Title: FERC 725E, Mandatory Reliability Standards for the Western Electric 

Coordinating Council’ 

Action: Proposed modification to FERC-725-E 

OMB Control No: 1902-0246 

Respondents: Balancing Authorities and Reliability Coordinator in the Western 

Electricity Coordinating Council (WECC). 

Frequency of Responses: On Occasion. 

Necessity of the Information: This proposed rule would approve a revised Reliability 

Standard modifying the existing requirement for entities to respond to requests for 

curtailment. The proposed Reliability Standard requires entities to maintain 

documentation evidencing their response to such requests. 

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

regional Reliability Standard IRO-006-WECC-1 and believes it to be just, reasonable, 

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

conform to the Commission’s plan for efficient information collection, communication 

and management within the energy industry. The Commission has assured itself, by 

means of internal review, that there is specific, objective support for the burden 

estimates associated with the information requirements. 
Docket No. RM09-19-000 - 25 - 

Burden Estimate: The burden for the requirements in this proposed rule follow: 

Data Collection 

FERC-725E 

No. of 

Respondents 

No. of 

Responses 

Hours Per 

Response 

Total Annual 

Hours 

35 Balancing 

Authorities and 1 

Reliability 

CoordinatorReporting 

Requirement 

36 1 1 36 

35 Balancing 

Authorities and 1 

Reliability 

CoordinatorRecordkeeping 

Requirement 

36 1 1 36 

Total 72 

38. Total Annual hours for Collection: 36 reporting +36 recordkeeping = 72 hours. 

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

with these requirements. It has projected the average annualized cost to be $5760, as 

shown below: 

Reporting = 36 hours @ $120/hour = $4320 

Recordkeeping = 36 hours @ $40/hour = $1440 

Total Costs = Reporting ($4320) + Recordkeeping ($1440) = $5760 

39. 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, Phone: (202) 502-

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

requirements of the proposed 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 
Docket No. RM09-19-000 - 26 - 

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

Please reference OMB Control Number 1902-0246 and the docket number of this 

proposed rulemaking in your submission. 

V. Environmental Analysis

40. 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.31 The actions proposed here fall within the categorical 

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

procedural, for information gathering, analysis, and dissemination.32 Accordingly, 

neither an environmental impact statement nor environmental assessment is required. 

VI. Regulatory Flexibility Act Analysis 

41. The Regulatory Flexibility Act of 1980 (RFA)33 generally requires a description 

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

number of small entities. Most of the entities (i.e., reliability coordinators and balancing 

authorities) to which the requirements of this Rule would apply do not fall within the 

definition of small entities.34 The Commission estimates that only 2-4 of the 35 

 

(continued...) 

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

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

32 18 CFR 380.4(a)(5). 

33 5 U.S.C. 601-12. 

34 The RFA definition of “small entity” refers to the definition provided in the 

Small Business Act (SBA), which defines a “small business concern” as a business that is 
Docket No. RM09-19-000 - 27 - 

balancing authorities (or a maximum of 11.4%) are small. The proposed Reliability 

Standard reflects a modification of existing requirements. Based on the foregoing, the 

Commission certifies that this Rule will not have a significant impact on a substantial 

number of small entities. Accordingly, no regulatory flexibility analysis is required. 

VII. Comment Procedures

42. 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. RM09-19-000, and must include the commenter’s name, the organization they 

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

43. The Commission encourages comments to be filed electronically via the eFiling 

link on the Commission’s web site at http://www.ferc.gov. The Commission accepts 

most standard word processing formats. Documents created electronically using word 

processing software should be filed in native applications or print-to-PDF format and not 

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

filing. 

 

independently owned and operated and that is not dominant in its field of operation. See

15 U.S.C. 632. According to the SBA, a small electric utility is defined as one that has a 

total electric output of less than four million MWh in the preceding year. 
Docket No. RM09-19-000 - 28 - 

44. Commenters that are not able to file comments electronically must send an 

original copy of their comments to: Federal Energy Regulatory Commission, Secretary 

of the Commission, 888 First Street NE, Washington, DC 20426. 

45. 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. 

VIII. Document Availability

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

Commission provides all interested persons an opportunity to view and/or print the 

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

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

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

Washington, DC 20426. 

47. From FERC’s Home Page on the Internet, this information is available on 

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

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

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

docket number field. 
Docket No. RM09-19-000 - 29 - 

48. User assistance is available for eLibrary and the FERC’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. 

By direction of the Commission. 

( S E A L ) 

Kimberly D. Bose, 

Secretary.