133 FERC ¶ 61,161 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

Docket No. RM10-16-000 

System Restoration Reliability Standards 

(November 18, 2010) 

AGENCY: Federal Energy Regulatory Commission 

ACTION: Notice of Proposed Rulemaking 

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

Regulatory Commission (Commission) proposes to approve Reliability Standards EOP001-1 (Emergency Operations Planning), EOP-005-2 (System Restoration from 

Blackstart Resources), and EOP-006-2 (System Restoration Coordination) submitted to 

the Commission by the North American Electric Reliability Corporation, the Electric 

Reliability Organization (ERO) certified by the Commission. In addition, the 

Commission seeks comment from the ERO and other interested parties regarding specific 

concerns. The Commission may determine that, after considering such comments, it is 

appropriate to direct the ERO, under section 215(d)(5) of the FPA, to develop additional 

modifications to proposed EOP-005-2 and EOP-006-2. The proposed Reliability 

Standards require that plans, facilities and personnel are prepared to enable system 

restoration using designated blackstart resources. 
Docket No. RM10-16-000 - 2 -

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

FEDERAL REGISTER]. 

ADDRESSES: You may submit comments, identified by Docket No. RM10-16-000 and 

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

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

● Agency Web Site: Documents created electronically using word processing 

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

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

● Mail/Hand Delivery: Commenters unable to file comments electronically must 

mail or hand deliver 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 web site, 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: 

David O’Connor (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6695 
Docket No. RM10-16-000 - 3 -

Nick Henery (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

888 First Street, NE Washington, DC 20426 

(202) 502-8636 

Terence Burke (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6498 

Jonathan First (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8529 

SUPPLEMENTARY INFORMATION
133 FERC ¶ 61,161 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

System Restoration Reliability Standards Docket No. RM10-16-000 

NOTICE OF PROPOSED RULEMAIKING 

(November 18, 2010) 

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

 the Commission proposes to 

approve three Reliability Standards, EOP-001-1 (Emergency Operations Planning), EOP005-2 (System Restoration from Blackstart Resources), and EOP-006-2 (System 

Restoration Coordination) developed by the North American Electric Reliability 

Corporation (NERC), the Commission-certified Electric Reliability Organization (ERO), 

as well as the definition of the term “Blackstart Resource” to be added to the NERC 

Glossary of Terms. The proposed Reliability Standards were drafted to ensure plans, 

facilities and personnel are prepared to enable system restoration from blackstart 

resources in order that reliability is maintained during system restoration. The 

Commission also seeks comment from the ERO and other interested entities regarding 

the Commission’s specific concerns discussed below. The Commission may determine 

that, after considering such comments, it is appropriate to direct the ERO, under section 

215(d)(5) of the FPA, to develop additional modifications to proposed EOP-005-2 and 

 1

 16 U.S.C. 824o (2006). 
Docket No. RM10-16-000 - 2 -

EOP-006-2. The Commission also proposes to approve the retirement of the currently 

effective Reliability Standards EOP-001-0 (Emergency Operations Planning), EOP-005-1 

(System Restoration Plans), EOP-006-1 (Reliability Coordination – System 

Restoration), and EOP-009-0 (Documentation of Blackstart Generating Unit Test 

Results) as well as the definition of “Blackstart Capability Plan” from the NERC 

Glossary of Terms, which are superseded by the proposed Reliability Standards EOP001-1, EOP-005-2 and EOP-006-2. 

2. “Blackstart” capability refers to the ability of a generating unit or station to start 

operating and delivering electric power without assistance from the electric system. 

Blackstart units are essential to restart generation and restore power to the grid in the 

event of an outage. As discussed below, NERC proposes to define “Blackstart Resource” 

as “a generating unit(s) and its associated set of equipment which has the ability to be 

started without support from the System or is designed to remain energized without 

connection to the remainder of the System, with the ability to energize a bus...” The 

proposed EOP Reliability Standards addressed in this rulemaking were developed by 

NERC to ensure that applicable entities prepare plans, facilities and personnel to enable 

system restoration from blackstart resources in order that reliability is maintained during 

restoration. 

3. In Order No. 693, the Commission determined that it would not take action on 

certain proposed Reliability Standards that require supplemental information from a 

Regional Entity. Such Reliability Standards refer to regional criteria or procedures that 

have not been submitted to the Commission for approval and, as such, are referred to as 
Docket No. RM10-16-000 - 3 -

“fill-in-the-blank” standards.2

 Pending Reliability Standard EOP-007-0 is one such fillin-the-blank standard. The proposed Reliability Standards provide a national approach to 

address the Commission’s concerns regarding pending EOP-007-0, as set forth in Order 

No. 693. Thus, in addition to the retirement of certain currently effective EOP Reliability 

Standards, we also propose to approve NERC’s to withdrawal of pending Reliability 

Standard EOP-007-0. 

I. Background

A. Section 215 of the FPA

4. 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. If approved, the Reliability Standards are enforced by the ERO, 

subject to Commission oversight, or by the Commission independently. 

5. In July 2006, the Commission certified NERC as the ERO.3

 Concurrent with its 

2006 ERO Application, NERC submitted to the Commission a petition seeking approval 

of 107 proposed Reliability Standards, including nine Emergency Preparedness and 

Operations (EOP) Reliability Standards. The EOP group of Reliability Standards 

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

72 Fed. Reg. 16416 at P 297 (Apr. 4, 2007), FERC Stats. & Regs. ¶ 31,242, order on 

reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007). 

3

 North American Electric Reliability Corp., 116 FERC ¶ 61,062 (ERO 

Certification Order), order on reh’g & compliance, 117 FERC ¶ 61,126 (2006), aff’d sub 

nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009). 
Docket No. RM10-16-000 - 4 -

addresses preparations for emergencies, necessary actions during emergencies and system 

restoration and reporting following disturbances. 

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

107 Reliability Standards filed by NERC,4

 including the Reliability Standards: EOP001-0, EOP-005-1, EOP-006-1 and EOP-009-0.5

 The Commission neither approved 

remanded EOP-007-0 because it applied only to regional reliability organizations, but 

Order No. 693 did provide guidance for the ERO’s further consideration of the Reliability 

Standard.

nor 

6

 In addition, under section 215(d)(5) of the FPA, the Commission directed 

NERC to develop modifications to the EOP Reliability Standards to address certain 

issues identified by the Commission. At issue in the immediate proceeding are two new 

EOP standards, EOP-005-2 and EOP-006-2 that would replace the currently effective 

Reliability Standards EOP-005-1, EOP-006-1, and EOP-009-0 and necessitate a 

conforming change in EOP-001-0. 

B. Currently Effective EOP Reliability Standards

1. Reliability Standard EOP-005-1

7. Currently effective Reliability Standard EOP-005-1 requires transmission 

operators, balancing authorities, and reliability coordinators to have a restoration plan, 

test the plan, train operating personnel in the restoration plan and to have the ability to 

 4

 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 304-1899. 

5

 Id. P 542-676. 

6

 Id. P 644. 
Docket No. RM10-16-000 - 5 -

restore the Interconnection using the plans following a blackout. In Order No. 693, the 

Commission directed the ERO to develop, through the Reliability Standard Development 

Process, a modification to EOP-005-1 that (i) identifies time frames for training and 

review of restoration plan requirements to simulate contingencies and prepare operators 

for anticipated and unforeseen events and (ii) gathers data from simulations and drills of 

system restoration on the time taken to restore power to nuclear power plants and report 

that information to the Commission.7

 The Commission also directed the ERO to 

consider various commenters suggestions in future revisions of the Reliability Standard.8

2. Reliability Standard EOP-006-1

8. In Order No. 693, the Commission also approved Reliability Standard EOP-006-1 

addressing reliability coordination and system restoration. The Reliability Standard sets 

requirements for reliability coordinators during system restoration and requires that 

reliability coordinators have a coordinating role in system restoration to ensure reliability 

is maintained during system restoration. Under section 215 of the FPA, the Commission 

directed the ERO to develop a modification to EOP-006-1 to ensure that the reliability 

coordinator is involved in the development and approval of system restoration plans.9

 7

 Id. P 630. 

8

 Id. P 628. 

9

 Id. P 638. 
Docket No. RM10-16-000 - 6 -

3. Reliability Standard EOP-007-0

9. “Pending” Reliability Standard EOP-007-0 deals with establishing, maintaining 

and documenting regional blackstart capability plans. In Order No. 693, the 

Commission did not act on EOP-007-0 because it applies only to regional reliability 

organizations and as such was not acted on pending NERC’s providing additional 

information.10 The Commission directed the ERO to consider various commenters 

suggestions relating to assigning compliance obligations directly to the entities that 

provide the pertinent data instead of to the Regional Entity, placing responsibility for the 

regional blackstart plan with the reliability coordinator rather than the Regional Entity, 

recognizing that nuclear units have no blackstart capability, revising the definition of a 

blackstart unit, and committing arrangements for coordinating blackstart capability to 

contracts.11

4. Reliability Standard EOP-009-0

10. Currently effective Reliability Standard EOP-009-0 deals with implementing and 

documenting testing of blackstart generating units. In Order No. 693, the Commission 

approved EOP-009-0. In addition, the Commission directed the ERO to consider 

suggestions for improvements raised during the comment period. One commenter stated 

 10 Id. P 297 and 644. 

11 Id. P 642–643, 647. 
Docket No. RM10-16-000 - 7 -

the Reliability Standard should provide details on what constitutes a blackstart test and 

another stated NERC should consolidate the Reliability Standard with EOP-007-0.12

II. NERC Petition for Proposed EOP Reliability Standards

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

approval of its proposed definition of the term “Blackstart Resource” and proposed 

Reliability Standards EOP-001-1 (Emergency Operating Plan),13 EOP-005-2 (System 

Restoration from Blackstart Resources) and EOP-006-2 (System Restoration 

Coordination). NERC also seeks to concurrently retire four currently effective Reliability 

Standards: EOP-001-0, EOP-005-1, EOP-006-1, and EOP-009-0 as well as the definition 

of “Blackstart Capability Plan” and withdraw pending Reliability Standard EOP-007-0. 

12. NERC states that the proposed Reliability Standards “represent significant 

revision and improvement from the current set of enforceable standards” and address the 

Commission’s directives in Order No. 693 related to the EOP standards.14 NERC 

 12 Id. P 674, 676. 

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

RM10-15-000 seeking approval of certain Interconnection Reliability Operating Limit 

(IRO) Reliability Standards. As part of its IRO filing, NERC proposed to retire 

Requirement R2 of EOP-001-0. Each petition proposes unique changes to EOP-001-0 

reflecting the distinct issues addressed by the respective Reliability Standards drafting 

teams. NERC indicated in both petitions that it could not anticipate the sequence in 

which the Commission would act and therefore included two sets of proposed 

amendments to EOP-001-0 in each petition. The Commission will clarify upon issuance 

of Final Rules in each proceeding which revised version of EOP-001-0 it is addressing in 

its determination. 

14 NERC Petition at 4. 
Docket No. RM10-16-000 - 8 -

explains that, among other enhancements, “[t]he proposed revisions now clearly delineate 

the responsibilities of the Reliability Coordinator and Transmission Operator in the 

restoration process and restoration planning.”15 NERC describes the proposed Reliability 

Standards as providing “specific requirements for what must be in a restoration plan, how 

and when it needs to be updated and approved, what needs to be provided to operators 

and what training is necessary for personnel involved in restoration processes.”16 NERC 

requests that the Commission approve (1) the proposed Reliability Standards, (2) 

concurrent retirement of the currently effective EOP Reliability Standards, and (3) the 

revisions to the NERC Glossary of Terms. With regard to implementation, NERC 

proposes that the proposed EOP Reliability Standards, new definitions and retirements of 

effective standards be made effective twenty-four months after the first day of the first 

calendar quarter following applicable regulatory approval. Below, we describe each of 

the proposed EOP Reliability Standards. 

A. Blackstart Resource

13. NERC requests approval of the term “Blackstart Resource” and the concurrent 

retirement of the term “Blackstart Capability Plan.” The proposed definition of “ 

Blackstart Resource” is: 

A generating unit(s) and its associated set of equipment which has the 

ability to be started without support from the System or is designed to 

remain energized without connection to the remainder of the System, with 

the ability to energize a bus, meeting the Transmission Operator’s 

 15 Id. 5. 

16 Id.
Docket No. RM10-16-000 - 9 -

restoration plan needs for real and reactive power capability, frequency and 

voltage control, and that has been included in the Transmission Operator’s 

restoration plan. 

The term “Blackstart Capacity Plan” is currently used solely in EOP-007-0 and 

EOP-009-0, both of which NERC intends to replace with proposed Reliability 

Standards EOP-005-2 and EOP-006-2. 

B. Reliability Standard EOP-001-1

14. Proposed Reliability Standard EOP-001-1 contains seven requirements for the 

stated purpose of requiring each transmission operator and balancing authority to 

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

coordinate these plans with other transmission operators, balancing authorities and the 

reliability coordinator.17 It modifies EOP-001-0 by deleting currently effective 

Requirement R3.4, which requires transmission operators and balancing authorities to 

develop, maintain and implement a set of plans for system restoration. According to 

NERC, the deletion is proposed because the new EOP-005-2 and EOP-006-2 incorporate 

and expand upon this requirement. 

C. Reliability Standard EOP-005-2

15. Proposed Reliability Standard EOP-005-2 contains eighteen requirements for the 

stated purpose of ensuring that plans, facilities and personnel are prepared to enable 

system restoration from Blackstart Resources, and to ensure reliability is maintained 

 17 Reliability Standard EOP-001-1, Section A.3. (Purpose). 
Docket No. RM10-16-000 - 10 -

during restoration and priority is placed on restoring the Interconnection.18 The proposed 

Reliability Standard applies to transmission operators, generation operators, and 

transmission owners, and distribution providers identified in the transmission operator’s 

restoration plan. Requirement R1 requires each transmission operator to have a 

reliability coordinator-approved restoration plan utilizing Blackstart Resources and 

details the scope and elements of such a plan. Requirement R2 instructs each 

transmission operator to provide entities that have a role in the restoration plan with a 

description of their roles and tasks. Requirements R3 through R6 address annual plan 

reviews, updating practices, location of plans and plan verification. Following a 

disturbance, Requirements R7 and R8 provide guidance on following the plan or making 

needed adjustments and coordinating when re-synchronizing two systems together. 

Requirement R9 describes testing information the transmission operator must have to 

verify the Blackstart Resources meet required expectations. Requirements R10 to R12 

cover system restoration training requirements for system operators and field switching 

personnel. Blackstart Resource agreements between the transmission operator and 

generator operator or mutually agreed upon procedures or protocols are addressed in 

Requirement R13. Duties of a generator owner with a Blackstart Resource are provided 

in Requirements R14 through R18, which address operating procedures, change 

notification, testing for each Blackstart Resource and training of operating personnel on 

 18 Reliability Standard EOP-005-2, Section A.4. (Purpose). 
Docket No. RM10-16-000 - 11 -

Blackstart Resources. NERC has requested that EOP-005-1 be retired upon the effectiveness 

of EOP-005-2.

D. Reliability Standard EOP-006-2

16. Proposed Reliability Standard EOP-006-2 contains ten requirements for the stated 

purpose of ensuring that the reliability coordinator establishes plans and prepares 

personnel to enable effective coordination of the system restoration process, to maintain 

reliability during restoration and to place priority on restoring the Interconnection.19 

Requirement R1 requires reliability coordinators to have restoration plans that utilize 

Blackstart Resources and specifies the scope and elements of such plans. Requirement 

R2 covers distribution of the reliability coordinator’s restoration plan. Requirements R3 

through R5 provide for review of the reliability coordinator’s restoration plan and the 

plans of each neighboring reliability coordinator and each transmission operator located 

in the reliability coordinator’s area. Any conflicts between reliability coordinators’ plans 

are to be resolved within thirty days, and transmission operators’ plans shall be approved 

or disapproved, with stated reasons, within thirty days. Requirement R6 requires that the 

reliability coordinator must maintain copies of restoration plans in the reliability 

coordinator’s primary and backup control room. Requirements R7 and R8 describe the 

roles of reliability coordinators to coordinate restoration efforts and authorize resynchronizing of “island” areas. Requirements R9 and R10 address training and 

 19 Reliability Standard EOP-006-2, Section A.3. (Purpose). 
Docket No. RM10-16-000 - 12 -

participation in annual drills, exercises and simulations. NERC has requested with 

acceptance of EOP-006-2 that EOP-006-1 be retired. 

III. Discussion

17. We believe that the proposed glossary term “Blackstart Resource” and Reliability 

Standards EOP-001-1, EOP-005-2, and EOP-006-2 comply with the relevant directives 

set forth in Order No. 693. We also believe that the proposed EOP Reliability Standards 

represent an improvement in blackstart restoration requirements, as represented by 

NERC. Accordingly, under section 215(d)(2) of the FPA, the Commission proposes to 

approve the new term and proposed Reliability Standards as just, reasonable, not unduly 

discriminatory or preferential and in the public interest. In addition, the Commission 

seeks comment from the ERO and other interested parties regarding specific concerns 

and may determine, after considering such comments, that it is appropriate to direct the 

ERO, under section 215(d)(5) of the FPA, to develop additional modifications to 

proposed Reliability Standards EOP-005-2 and EOP-006-2. Below, we discuss each 

proposed EOP Reliability Standard and relevant concerns. 

A. EOP-001-1 Emergency Operation Planning

18. The Commission proposes to approve EOP-001-1 as requested by NERC.20

Current Requirement R3.4 of Reliability Standard EOP-001-0 requires each transmission 

operator and balancing authority to develop, maintain and implement system restoration 

 20 The version of EOP-001-1 that the Commission proposes to approve is the 

version contained in Exhibit A in the NERC Petition. 
Docket No. RM10-16-000 - 13 -

plans. The removal of that Requirement from EOP-001-0 is appropriate because NERC 

proposes to address system restoration plans in its new Reliability Standards EOP-005-2 

and EOP-006-2. The Order No. 693 directives applicable to EOP-001-0 were not 

addressed in the NERC Petition since the proposed standards are narrowly focused on 

system restoration that is a part, and not the sole subject, of the EOP standards. We note 

that all of the Order No. 693 directives relating to EOP-001-0 are still applicable to EOP001-1 and will need to be addressed by NERC in another filing.21

B. EOP-005-2 System Restoration from Blackstart Resources

19. The Commission proposes to approve proposed Reliability Standard EOP-005-2. 

The Reliability Standard effectively addresses the Commission’s directive in Order No. 

693 to develop time frames for training and review of restoration plan requirements to 

simulate contingencies and prepare operators for anticipated and unforeseen events. 

Requirements R3 and R4 set forth time frames for review of restoration plans. Frequency 

of testing Blackstart Resources is addressed in Requirement R9, and Requirement R6 

requires each transmission operator to verify every five years through analysis of actual 

events, steady state and dynamic simulations, or testing that its restoration plan 

accomplishes its intended function. Periodic drills and training are the most effective 

method of demonstrating restoration plans are current and appropriate personnel are 

prepared, and proposed Requirements R10, R11 and R17 address training requirements 

 21 See Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 548, 554, 555, 561, 562 

and 566. 
Docket No. RM10-16-000 - 14 -

for system operators, field switching personnel and generator operators with Blackstart 

Resources. 

20. Proposed Requirement R11 of EOP-005-2 provides that applicable entities “shall 

provide a minimum of two hours of System restoration every two calendar years to their 

field switching personnel identified as performing unique tasks associated with the 

Transmission Operator’s restoration plan that are outside of their normal tasks.” NERC’s 

Petition indicates that, in the development process, three stakeholders commented that the 

use of the term “unique tasks” is vague and requested a better definition and examples.22 

The Commission is also concerned that the applicable entities may not understand what 

the term “unique tasks” means, and we request comment on what is intended by that 

term. Also, given that there a variety of means by which the ERO, if necessary, can 

provide greater clarity regarding the term “unique tasks,” we request comment on 

whether guidance should be provided to the transmission operators, transmission owners 

and distribution providers who are responsible for providing training, and if so, how this 

guidance should be provided. In addition, we seek comment as to whether those tasks 

should be identified in each transmission operator’s restoration plan. 

21. Requirement R5 of currently effective EOP-005-1 addresses periodic testing of 

telecommunication facilities needed to implement restoration plans. This requirement, 

however, is not carried over to proposed EOP-005-2. We recognize that currently 

 22 See NERC Petition, Exh. E (Record of Development of Proposed Reliability 

Standards) at 1429, 1500, and 1748 (as identified in the PDF version available on 

eLibrary on the FERC’s Home Page (http://www.ferc.gov)). 
Docket No. RM10-16-000 - 15 -

effective communication Reliability Standard COM-001-1.1 requires that reliability 

coordinators, transmission operators and balancing authorities manage, alarm, test and/or 

actively monitor vital telecommunication facilities, with special attention given to 

emergency facilities and equipment. Consistent with that requirement, the Commission 

proposes to require that the ERO develop a modification to EOP-005-2 that addresses this 

concern, for example, by specifying that such testing of telecommunication facilities be 

identified in the restoration plan and be part of any restoration drill, exercise or 

simulation. By placing the duty to test telecommunications facilities in the restoration 

plan, entities will ensure restoration-specific telecommunications equipment, phone lists 

and protocols are tested by restoration personnel as part of their ongoing restoration 

preparedness. In addition, recommendation 26 of the U.S. – Canada report23 on the 

August 14, 2003 blackout recognizes that effective communication protocols during 

alerts and emergencies are essential to reliability. Consistent with the Blackout Report, 

applicable entities should have standing hotline networks or functional equivalents to 

receive timely and accurate information and should regularly test such communication 

networks. 

22. Given the importance of communication to the restoration process, however, the 

Commission further believes that testing should be done more frequently than during 

annual drills, exercises or simulations (as is contained in the currently effective 

 23 U.S.-Canada Power System Outage Task Force, Final Report on the August 14, 

2003 Blackout in the United States and Canada: Causes and Recommendations at 161 

(April 2004) (Blackout Report), available at

http://www.ferc.gov/industries/electric/indus-act/blackout.asp. 
Docket No. RM10-16-000 - 16 -

Requirement R5 of EOP-005-1). The Commission is concerned that in an emergency 

event, communication devices must be readily available and functioning properly.24 For 

example, wireless devices may be missing or non-functional and emergency contact 

information may be out of date. A relatively unintrusive, periodic test or drill of 

communications may provide greater assurance that communications equipment is 

available for responding in an emergency. The Commission invites comment on this 

issue. 

C. EOP-006-2 System Restoration Coordination

23. Proposed Reliability Standard EOP-006-2, is intended to ensure that plans are 

established and personnel are prepared to enable effective coordination of the system 

restoration process to ensure reliability is maintained during restoration. The 

Commission proposes to approve EOP-006-2 as it addresses the Commission’s directive 

in Order No.693 to ensure the reliability coordinator is involved in the development and 

approval of system restoration plans. 

24. Under proposed Reliability Standard EOP-005-2, Requirement R1.4 requires the 

transmission operator to indentify each Blackstart Resource and its characteristics. 

Currently effective Reliability Standard EOP-007-0 similarly requires the Regional Entity 

to maintain a database of Blackstart Resources, but these requirements have no 

counterpart in EOP-006-2. The Commission is concerned that the absence of a 

counterpart to such a requirement in EOP-006-2 could deny the Reliability Coordinator a 

 

24 Information on the relationship between communications and electricity is available 

from Public Safety & Homeland Security Bureau of the Federal Communications 

Commission. See http://www.fcc.gov/pshs/. 
Docket No. RM10-16-000 - 17 -

potentially useful tool in maintaining reliability. Since the reliability coordinator is 

responsible for overall system awareness, the Commission invites comments as to why 

the current EOP-007-0 requirement was not carried forward into proposed Reliability 

Standard EOP-006-2 and whether it would be beneficial to include a provision in EOP006-2 that would require the reliability coordinator to maintain a database of each 

Blackstart Resource within its area. 

25. While proposed EOP-005-2 Requirement R6 requires each transmission operator 

to verify through analysis of actual events, simulations or testing that its restoration plan 

accomplishes its intended function, there is no similar requirement in proposed EOP-006-

2 regarding the reliability coordinator’s restoration plan. The Commission is concerned 

that the absence of a comparable verification requirement may have a detrimental effect 

on the quality of Reliability Coordinators’ planning. Accordingly we seek comment on 

whether the same or similar requirement (verification through actual events, steady state 

and dynamic simulations or testing) should apply to reliability coordinators. 

26. Pursuant to proposed EOP-006-2 Requirements R5 and R5.1, the reliability 

coordinators must review the restoration plans required of transmission operators by 

EOP-005-2 and must approve or disapprove the plans within 30 days of receipt. We are 

concerned that no clear guidance is provided on how a transmission operator should 

handle a situation where the reliability coordinator disapproves a transmission operator’s 

plan. Although the reliability coordinator is the final authority, should there be a give 

and take with the transmission operator whose restoration plan contains an element that 

the reliability coordinator believes is incompatible with another restoration plan? If 
Docket No. RM10-16-000 - 18 -

neighboring transmission operators have conflicting plans, how will the reliability 

coordinator determine which plan needs to change? We invite comment on how a 

transmission operator should proceed when a transmission operator’s plan is rejected by a 

reliability coordinator. 

D. Withdrawal of EOP-007-0 and Retirement of EOP-009-0

27. The Commission proposes to allow NERC to withdraw pending Reliability 

Standards EOP-007-0 and to retire EOP-009-0 because, as explained by NERC, the 

requirements contained in those standards are now included in proposed Reliability 

Standards EOP-005-2 and EOP-006-2. 

E. Proposed Data Reporting Requirement

28. Given the importance of having effective blackstart and restoration plans and welltrained personnel in place to address system restoration events, the Commission proposes 

that the ERO collect data on the performance of system restoration exercises conducted 

by transmission operators and reliability coordinators. Results from restoration exercises 

are typically maintained as evidence of compliance but generally not shared with other 

entities or available from a single source and thus are not available for others to learn 

from. Accordingly, the collection of this data will assist the ERO and Commission in 

identifying the effectiveness of restoration plans, establishing best practices among 

transmission operators and reliability coordinators, and determining the affects on 

personnel performance. The ERO could, for example, use this information to develop 

and disseminate “lessons learned” regarding black start capability. 
Docket No. RM10-16-000 - 19 -

29. Thus, under section 39.2(d) of the Commission’s regulations, we propose to direct 

the ERO to gather data and establish a database that can be accessed by transmission 

operators, reliability coordinators and the Commission regarding transmission operator 

and reliability coordinator system restoration drills, exercises and simulations. In 

particular, we propose that the database should include: (1) the duration of each drill, 

exercise and/or simulation; (2) the amount of load considered lost at the beginning of the 

drill, exercise and/or simulation; (3) the amount of load restored at the conclusion of the 

event; (4) whether the drill, exercise and/or simulation was table top, walk through 

simulation or computer simulation; (5) which entities participated in the drill, exercise 

and/or simulation; and (6) whether Blackstart Resources were used. Reliability 

coordinators, transmission operators and the ERO will be able to use this data to identify 

the effectiveness of restoration plans and to help identify improvements that may be 

necessary or that could enhance restoration. The Commission seeks comment on the 

proposed data collection including the benefits of the information to be provided in the 

proposed collection, the types of information proposed to be collected, and any potential 

burden of the proposed collection. 

F. Violation Risk Factors/Violation Security Levels

30. To determine a base penalty amount for a violation of a Requirement within a 

Reliability Standard, NERC must first determine an initial range for the base penalty 

amount. To do so, NERC assigns a violation risk factor to each Requirement and subRequirement of a Reliability Standard that relates to the expected or potential impact of a 

violation of the Requirement on the reliability of the Bulk-Power System. The 
Docket No. RM10-16-000 - 20 -

Commission has established guidelines for evaluating the validity of each violation risk 

factor assignment.25

31. NERC also will assign each Requirement and sub-Requirement one of four 

violation severity levels – low, moderate, high, and severe – as measurements for the 

degree to which the Requirement was violated in a specific circumstance. On June 19, 

2008, the Commission issued an order establishing four guidelines for the development 

of violation severity levels.26 

32. With respect to proposed Reliability Standards EOP-005-2 and EOP-006-2, NERC 

proposes to assign violation risk factors only to the main Requirements and did not 

propose violation risk factors for any of the sub-Requirements.27 NERC noted that such 

 25 See North American Electric Reliability Corp., 119 FERC ¶ 61,145, order on 

reh’g, 120 FERC ¶ 61,145, at P 8-13 (2007) (Violation Risk Factor Rehearing Order). 

The guidelines are: (1) consistency with the conclusions of the Blackout Report; (2) 

consistency within a Reliability Standard; (3) consistency among Reliability Standards; 

(4) consistency with NERC’s definition of the violation risk factor level; and (5) 

treatment of requirements that co-mingle more than one obligation. 

26 North American Electric Reliability Corp., 123 FERC ¶ 61,284, at P 20-35 

(Violation Severity Level Order), order on reh’g & compliance, 125 FERC ¶ 61,212 

(2008). The guidelines provide that VSL assignments should: (1) not lower the current 

level of compliance; (2) ensure uniformity and consistency in the determination of 

penalties; (3) be consistent with the corresponding requirement; and (4) be based on a 

single violation. 

27 We note that in Version Two Facilities Design, Connections and Maintenance 

Reliability Standards, Order No. 722, 126 FERC ¶ 61,255, at P 45 (2009), the ERO 

proposed to develop violation risk factors and violation severity levels for Requirements 

but not sub-requirements. The Commission denied the proposal as “premature” and, 

instead, encouraged the ERO to “develop a new and comprehensive approach that would 

better facilitate the assignment of violation severity levels and violation risk factors.” As 

directed, on March 5, 2010, NERC submitted a comprehensive approach that is currently 

pending with the Commission in Docket No. RR08-4-005. 
Docket No. RM10-16-000 - 21 -

practice is consistent with NERC’s August 10, 2009 Informational Filing Regarding the 

Assignment of violation risk factors and violation severity levels.28 With respect to 

proposed Reliability Standard EOP-001-1, NERC proposes to carry forward the violation 

risk factors and violation severity levels currently assigned to the existing Reliability 

Standard EOP-001-0. 

33. On May 5, 2010, NERC incorporated by reference into Docket No. RR08-4-005,29

its August 10, 2009 information filing in which NERC proposes assigning violation risk 

factors and violation severity levels only to the main Requirements in each Reliability 

Standard, and not to the sub-Requirements. Because the violation risk factors and 

violation severity levels for proposed Reliability Standards EOP-001-1, EOP-005-2, and 

EOP-006-2 are affected by the NERC’s pending petition, we propose to defer discussion 

on the proposed violation risk factors and violation severity levels assigned to EOP-001-

1, EOP-005-2, and EOP-006-2 until after we act on NERC’s petition in Docket No. 

RR08-4-005. 

G. Summary

34. We propose to approve proposed Reliability Standards EOP-001-1, EOP-005-2 

and EOP-006-2 as well as the definition of the term “Blackstart Resource” as just, 

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

 28 NERC Petition at 22. 

29 Docket No. RR08-4-005 comprises NERC’s March 5, 2010 Violation Severity 

Level Compliance Filing submitted in response to Order No. 722. See Order No. 722, 

126 FERC ¶ 61,255 at P 45. 
Docket No. RM10-16-000 - 22 -

seek comment from the ERO and other interested entities regarding the Commission’s 

specific concerns discussed above. The Commission may determine after considering 

such comments that it is appropriate to direct the ERO, under section 215(d)(5) of the 

FPA, to develop additional modifications to proposed EOP-005-2 and EOP-006-2. We 

also propose to approve the retirement of the currently effective Reliability Standards 

EOP-001-0, EOP-005-1, EOP-006-1, and EOP-009-0 as well as the definition of 

“Blackstart Capability Plan” which are superseded by the proposed Reliability Standards 

EOP-001-1, EOP-005-2, and EOP-006-2, and we also propose to allow NERC to 

withdraw the pending Reliability Standard EOP-007-0. 

IV. Information Collection Statement 

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

certain information collection requirements imposed by agency rules.30 Upon approval 

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

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

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

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

n 

 

31

requires each federal agency to seek and obtain OMB approval before undertaking a 

30 5 C.F.R. § 1320.11. 

31 44 U.S.C. § 3501-20. 
Docket No. RM10-16-000 - 23 -

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

which OMB approval and validity of the control number are about to expire.32

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

OMB for its review and approval under section 3507(d) of the Paperwork Reduction Act. 

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.

37. This Notice of Proposed Rulemaking (NOPR), proposes to approve three new 

Reliability Standards, EOP-001-1, EOP-005-2 and EOP-006-2 governing system 

restoration from blackstart, which standards will replace currently effective Reliability 

Standards EOP-001-0, EOP-005-1, EOP-006-1, and EOP-009-0 as well as pending 

Reliability Standard EOP-007-0, all of which the Commission addressed in Order No. 

693. Rather than creating entirely new blackstart requirements, the proposed Reliability 

Standards EOP-005-2 and EOP-006-2 instead consolidate and upgrade the overall quality 

of the existing Reliability Standards governing blackstart planning, testing and training 

and ensure enhanced coordination of the Bulk-Power System restoration process. Thus, 

this proposed rulemaking does not impose entirely new burdens on the effected entities. 

For example, the currently effective restoration Reliability Standards require transmission 

 32 44 U.S.C. § 3502(3)(A)(i), 44 U.S.C. § 3507(a)(3). 
Docket No. RM10-16-000 - 24 -

operators to create, maintain and test restoration plans and train personnel in those plans. 

Similarly, reliability coordinators are currently required to a have a role in coordinating 

system restoration and in focusing on restoration of the Interconnection, and generation 

owners and operators are currently required to test and report the results of the start up 

and operation of blackstart generating units. Accordingly, the requirements imposed by 

proposed Reliability Standards EOP-005-2 and EOP-006-2 are more specific but not 

necessarily more expansive than currently effective EOP Reliability Standards addressing 

restoration requirements. However, the Commission’s proposal that the ERO gather and 

report data on the performance of system restoration exercises does enlarge the duties 

placed on the affected entities. 

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

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

According to the registry, there are 26 reliability coordinators and 176 transmission 

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

compliance registration program, entities may be registered for multiple functions, so 

there is some double counting involved in these numbers. Proposed EOP-006-2 requires 

the reliability coordinator to conduct two system restoration drills, exercises or 

simulations per calendar year involving transmission operators and generation operators. 

Depending on the scope of the drill, exercise or simulation, certain transmission operators 

or generation operators may not be required to provide data to the reliability coordinator 

in any given year. Proposed reliability Standard EOP-005-2 requires generator operators 

with Blackstart Resources who have not already done so to document in writing both the 
Docket No. RM10-16-000 - 25 -

terms of their blackstart arrangements with their transmission operator and their 

procedures for energizing a bus. The registry indicates there are 773 generator operators, 

but we estimate of these the requirements will apply to 230. Lastly, EOP-005-2 requires 

transmission owners and distribution providers whose field switching personnel have 

unique tasks under a restoration plan to provide two hours of training every two years. 

The registry shows a net 678 entities that might be required to carry out such training as a 

result of these Reliability Standards. Given these parameters, the Commission estimates 

that the Public Reporting burden for the requirements contained in this NOPR is as 

follows: 

Data 

Collection 

No. of 

Respondents 

No. of 

Annual 

Responses 

Hours Per 

Respondent 

Total Annual 

Hours 

FERC-725A

Reporting: 

8 

Reporting: 

208 

Reliability 

coordinators 

reporting data 

to NERC on 

annual basis 

26 1 

Recordkeeping:

8 

Recordkeeping:

 208 

Compliance: 

116 

Compliance: 

20,416 

Transmission 

operators 

reporting data 

to their 

reliability 

coordinator 

and reducing 

blackstart 

arrangements 

to writing 

176 1 

Recordkeeping: 

16 

Recordkeeping: 

2816 

Generator 

operator 

system 

restoration 

responsibilities 

230 1 80 18,400 
Docket No. RM10-16-000 - 26 -

including 

Testing and 

maintaining 

records 

Transmission 

owner and 

distribution 

provider 

training and 

recordkeeping 

678 1 8 5,424 

Total 47,472 hours 

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

with these requirements and recordkeeping burden associated with the proposed 

Reliability Standards. 

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

hours. 

 Reporting/Compliance = 44,448 hours @ $132/hour = $5,867,136 

 Recordkeeping = 3,024 hours @ $17/hour = $51,408 

 Total Cost = $5,918,544 

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

 Action: Proposed Collection of Information. 

 OMB Control No: 1902-0244 

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

 Frequency of Responses: Annually. 

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

Reliability Standards that modify the existing requirement for system restoration from a 

blackstart. The proposed Reliability Standards require some entities to commit 
Docket No. RM10-16-000 - 27 -

agreements or understandings to writing and/or draft written procedures. Other entities 

may have to produce and maintain training materials. A proposed directive to those 

Reliability Standards would require entities to report annually to the ERO who will in 

turn report to the Commission regarding transmission operator and reliability coordinator 

system restoration drills, exercises and simulations. 

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

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

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

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

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

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

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

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

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

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

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

1902-0244 and the docket number of this proposed rulemaking in your submission. 
Docket No. RM10-16-000 - 28 -

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.33 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.34 Accordingly, 

neither an environmental impact statement nor environmental assessment is required. 

VI. Regulatory Flexibility Act Analysis 

41. The Regulatory Flexibility Act of 1980 (RFA)35 generally requires a description 

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

number of small entities. Many of the entities, i.e., reliability coordinators, transmission 

operators, generation operators, transmission owners and distribution providers identified 

in the transmission operator’s restoration plan, to which the requirements of this rule 

would apply do not fall within the definition of small entities,36 but most transmission 

owners and most distribution providers would be deemed small entities. The proposed 

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

486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. ¶ 30,783 (1987). 

34 18 C.F.R. § 380.4(a)(5). 

35 5 U.S.C. § 601-12. 

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

Small Business Act (SBA), which defines a “small business concern” as a business that is 

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

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

a total electric output of less than four million MWh in the preceding year. 
Docket No. RM10-16-000 - 29 -

Reliability Standards clarify the elements of restoration plans and training requirements 

and give reliability coordinators a greater role in review and approval of plans, but the 

proposed Reliability Standards reflect primarily a continuation of existing system 

restoration requirements currently applicable to reliability coordinators, transmission 

operators and generation operators. 

42. Based on available information regarding NERC’s compliance registry, and our 

best assessment of the application of the proposed Reliability Standards, approximately 

1,110 entities will be responsible for compliance with proposed Reliability Standards 

EOP-005-2 and EOP-006-2, of which approximately 678 are transmission owners and 

distribution providers not already subject to the existing system restoration Reliability 

Standards. Of the 678 transmission owners and distribution providers, only that subset 

whose field switching personnel are identified in the restoration plan as having unique 

tasks will be subject to a new requirement under the proposed standards, i.e., providing 

two hours of system restoration training every two calendar years to such personnel. The 

Commission estimates that this requirement will impose a cost of perhaps $1,056 per year 

on transmission owners and distribution providers, and indeed for some entities there will 

be no additional cost because field personnel are already being trained in restoration tasks 

and therefore should not present significant operating costs. Based on the foregoing, the 

Commission certifies that this proposed Reliability Standard will not have a significant 

impact on a substantial number of small entities. 
Docket No. RM10-16-000 - 30 -

43. Based on this understanding, the Commission certifies that this rule will not have a 

significant economic impact on a substantial number of small entities. Accordingly, no 

regulatory flexibility analysis is required. 

VII. Comment Procedures

44. 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 60 days from 

publication in the FEDERAL REGISTER]. Comments must refer to Docket No. 

RM10-16-000, and must include the commenter’s name, the organization they represent, 

if applicable, and their address in their comments. 

45. Commenters may submit comments, identified by Docket No. RM10-16-000 and 

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

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

● Agency Web Site: Documents created electronically using word processing 

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

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

● Mail/Hand Delivery: Commenters unable to file comments electronically must 

mail or hand deliver 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 web site, 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. 
Docket No. RM10-16-000 - 31 -

46. 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

47. 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. 

48. 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. 

49. User assistance is available for eLibrary and the FERC’s website during normal 

business hours from FERC Online Support at 202-502-6652 (toll free at 1-866-208-

3676) or email at ferconlinesupport@ferc.gov, or the Public Reference Room at (202) 
Docket No. RM10-16-000 - 32 -

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 ) 

Nathaniel J. Davis, Sr., 

Deputy Secretary.