163 FERC ¶ 61,184

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket No. RM16-22-000; Order No. 847]

Coordination of Protection Systems for Performance During Faults and Specific Training 

for Personnel Reliability Standards

(Issued June 7, 2018)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final rule.

SUMMARY: The Federal Energy Regulatory Commission (Commission) approves 

Reliability Standards PRC-027-1 (Coordination of Protection Systems for Performance 

During Faults) and PER-006-1 (Specific Training for Personnel) submitted by the North 

American Electric Reliability Corporation (NERC). 

EFFECTIVE DATE: This rule will become effective [60 days after publication in the 

FEDERAL REGISTER].

FOR FURTHER INFORMATION CONTACT:

Juan Villar (Technical Information)

Office of Electric Reliability

Division of Reliability Standards and Security

888 First Street, NE

Washington, DC 20426

Telephone: (772) 678-6496

Juan.Villar@ferc.gov

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Docket No. RM16-22-000 ii

Alan Rukin (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

Telephone: (202) 502-8502

Alan.Rukin@ferc.gov

SUPPLEMENTARY INFORMATION:

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163 FERC ¶ 61,184

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Kevin J. McIntyre, Chairman;

 Cheryl A. LaFleur, Neil Chatterjee,

 Robert F. Powelson, and Richard Glick.

Coordination of Protection Systems for Performance 

During Faults and Specific Training for Personnel 

Reliability Standards

 Docket No. RM16-22-000

ORDER NO. 847

FINAL RULE

(Issued June 7, 2018)

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

approves Reliability Standards PRC-027-1 (Coordination of Protection Systems for 

Performance During Faults) and PER-006-1 (Specific Training for Personnel).1

 The 

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

Electric Reliability Organization (ERO), submitted Reliability Standards PRC-027-1 and 

PER-006-1 for approval. As discussed below, we determine that Reliability Standard 

PRC-027-1, which is designed to maintain the coordination of protection systems 

installed to detect and isolate faults on bulk electric system elements, such that those 

protection systems operate in the intended sequence during faults, and PER-006-1, which 

 1 16 U.S.C. 824o (2012).

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is intended to ensure that personnel are trained on specific topics essential to reliability to 

perform or support real-time operations of the bulk electric system, improve upon the 

currently-effective Reliability Standards. In addition, based on the record before us, 

we do not adopt the NOPR proposal to direct NERC to modify Reliability Standard 

PRC-027-1 to require an initial protection system coordination study to ensure that 

applicable entities will perform (or have performed), as a baseline, a study demonstrating 

proper coordination of its protection systems.

2. The Commission also approves the associated violation risk factors, violation 

severity levels, implementation plans, and effective dates proposed by NERC for 

Reliability Standards PRC-027-1 and PER-006-1. The Commission further approves the 

retirement of currently-effective Reliability Standard PRC-001-1.1(ii) (System Protection 

Coordination) as proposed by NERC. Finally, the Commission approves new and revised 

definitions submitted by NERC for incorporation in the NERC Glossary for the following 

terms: (1) “protection system coordination study;” (2) “operational planning analysis;” 

and (3) “real-time assessment.”2

I. Background

A. Section 215 and Mandatory Reliability Standards

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

mandatory and enforceable Reliability Standards, subject to Commission review and 

 2 NERC Glossary of Terms Used in NERC Reliability Standards (NERC 

Glossary).

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approval.3

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

subject to Commission oversight or by the Commission independently.4

 In 2006, the 

Commission certified NERC as the ERO pursuant to section 215 of the FPA.5

B. Order No. 693

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

107 Reliability Standards filed by NERC, including Reliability Standard PRC-001-1.6

 

In addition, the Commission directed NERC to develop modifications to Reliability 

Standard PRC-001-1 that:

(1) correct the references for Requirements, and [sic] 

(2) include a requirement that upon the detection of failures in 

relays or protection system elements on the Bulk-Power 

System that threaten reliable operation, relevant transmission 

operators must be informed promptly, but within a specified 

period of time that is developed in the Reliability Standards 

development process, whereas generator operators must also 

promptly inform their transmission operators; and (3) clarifies 

that, after being informed of failures in relays or protection 

system elements that threaten reliability of the Bulk-Power 

System, transmission operators must carry out corrective 

control actions, i.e., return a system to a stable state that 

 3 Id. 824o(c), (d).

4 Id. 824o(e).

5 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g 

and compliance, 117 FERC ¶ 61,126 (2006), order on compliance, 118 FERC ¶ 61,190, 

order on reh’g, 119 FERC ¶ 61,046 (2007), aff’d sub nom. Alcoa Inc. v. FERC, 564 F.3d 

1342 (D.C. Cir. 2009).

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

FERC Stats. & Regs. ¶ 31,242 at PP 1433-1449, order on reh’g, Order No. 693-A, 

120 FERC ¶ 61,053 (2007).

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respects system requirements as soon as possible and no 

longer than 30 minutes after they receive notice of the 

failure.7

C. NERC Petition and Reliability Standards PRC-027-1 and PER-006-1

5. On September 2, 2016, NERC submitted a petition seeking Commission approval 

of Reliability Standards PRC-027-1 and PER-006-1.8

 NERC stated that the Reliability 

Standards, new and revised NERC Glossary terms, and the retirement of Reliability 

Standard PRC-001-1.1(ii) satisfy the Commission’s criteria in Order No. 672 and are just, 

reasonable, not unduly discriminatory or preferential, and in the public interest.9

 NERC 

explained that the intent of the submitted Reliability Standards and changes to the NERC 

Glossary are to maintain the coordination of protection systems installed to detect and 

isolate faults on bulk electric system elements and require registered entities to provide 

training to their relevant personnel on protection systems and remedial action schemes. 

NERC asserted that the submitted Reliability Standards are an improvement over 

currently-effective Reliability Standard PRC-001-1.1(ii) and will ensure that appropriate 

personnel are trained on protection systems and that protection systems are appropriately 

studied, coordinated, and monitored.

 7 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1449.

8 Reliability Standards PRC-027-1 and PER-006-1 are not attached to this Final 

Rule. The Reliability Standards are available on the Commission’s eLibrary document 

retrieval system in Docket No. RM16-22-000 and are posted on the NERC website, 

http://www.nerc.com.

9 NERC Petition at 10.

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1. Reliability Standard PER-006-1

6. NERC stated that Reliability Standard PER-006-1 requires generator operators to 

use a systematic approach to develop and implement training for dispatch personnel at 

centrally-located dispatch centers.10 NERC explained that Reliability Standard 

PER-006-1 will also cover plant personnel who are responsible for real-time control of a 

generator. NERC maintained that it is appropriate to train plant personnel in the 

functionality of protection systems and remedial action schemes. NERC observed that 

Reliability Standard PER-006-1 replaces the phrase “purpose and limitations” used 

in Reliability Standard PRC-001-1(ii) with the phrase “operational functionality” to 

clearly identify the objective of the training.11 NERC also noted that Reliability Standard 

PER-006-1 replaces the phrase “applied in its area” in Reliability Standard 

PRC-001-1.1(ii) with the phrase “that affect the output of the generating facility(ies) 

it operates” to properly tailor the scope of the required training. NERC noted that 

Reliability Standard PER-006-1 does not specify a periodicity for the required training.

2. Reliability Standard PRC-027-1

7. NERC asserted that Reliability Standard PRC-027-1:

provides a clear set of Requirements that obligate entities to 

(1) implement a process for establishing and coordinating 

new or revised Protection System settings, and 

(2) periodically study Protection System settings that could be 

affected by incremental changes in Fault current to ensure the 

 10 Id. at 13. 

11 Id. at 15.

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Protection Systems continue to operate in their intended 

sequence.

12

According to NERC, Reliability Standard PRC-027-1, Requirement R1 mandates that 

each transmission owner, generator owner, and distribution provider establish a process 

for developing new and revised protection system settings for bulk electric system 

elements.13

8. NERC stated that Reliability Standard PRC-027-1, Requirement R2 mandates that 

every six years, applicable entities must either: (1) perform a protection system 

coordination study to determine whether the protection systems continue to operate in the 

intended sequence during faults; (2) compare present fault current values to an 

established fault current baseline and, only if the comparison identifies a 15 percent or 

greater deviation in fault current values (either three phase or phase to ground) at a bus to 

which the bulk electric system is connected, perform a protection system coordination 

study; or (3) use a combination of Options 1 and 2.14

9. NERC explained that Reliability Standard PRC-027-1, Requirement R3 will 

require applicable entities to use the process established under Reliability Standard 

PRC-027-1, Requirement R1 for the development of any new or revised protection 

system settings.

 12 Id. at 26.

13 Id. at 27.

14 Id. at 26.

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3. Retirement of Reliability Standard PRC-001-1.1(ii)

10. NERC stated that Reliability Standard PRC-001-1.1(ii) includes six requirements 

that are either addressed by Reliability Standards approved by the Commission or by 

Reliability Standards PER-006-1and PRC-027-1. Specifically, NERC explained that 

Reliability Standard PRC-001-1.1(ii), Requirement R1 has been partially replaced by 

Reliability Standards PER-003-1 and PER-005-2. NERC continued that Reliability 

Standard PER-006-1 and the revised definitions of operational planning analysis and 

real-time assessment will replace the remaining portions of Reliability Standard PRC001-1.1(ii), Requirement R1. NERC asserted that Reliability Standard PRC-001-1.1(ii), 

Requirement R2 has been addressed by Reliability Standards IRO-001-4, IRO-008‐2, 

IRO‐010‐2, TOP‐001‐3, and TOP‐003‐3, which the Commission approved in Order 

No. 817.15 NERC stated that Reliability Standard PRC-027-1 will replace Reliability 

Standard PRC-001-1.1(ii), Requirements R3 and R4. NERC also explained that

Reliability Standard PRC-001-1.1(ii), Requirement R5 has been replaced with several 

Reliability Standards developed after Reliability Standard PRC-001-1(ii) became 

effective.16 NERC further stated that Reliability Standard PRC-001-1.1(ii), Requirement 

R6 has been replaced with Reliability Standards TOP-001-3 and TOP-003-3.

 15 Id. at 5 (citing Transmission Operations Reliability Standards and 

Interconnection Reliability Operations and Coordination Reliability Standards, Order 

No. 817, 153 FERC ¶ 61,178 (2015)).

16 Id. at 6.

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D. Notice of Proposed Rulemaking

11. On November 16, 2017, the Commission issued a Notice of Proposed Rulemaking 

proposing to approve Reliability Standards PRC-027-1 and PER-006-1.17 The NOPR 

proposed to determine that Reliability Standards PRC-027-1 and PER-006-1 improve 

upon the currently-effective Reliability Standards. However, the NOPR observed that 

Reliability Standard PRC-027-1, Requirement R2, Option 2 does not appear to ensure 

coordination of all bulk electric system elements with protection system functions 

because it does not require an initial protection system coordination study. Accordingly, 

the NOPR also proposed to direct NERC, pursuant to section 215(d)(5) of the FPA, to 

submit modifications to Reliability Standard PRC-027-1 within 12 months of the 

effective date of this Final Rule to require an initial protection system coordination study 

to ensure that applicable entities will perform (or have performed), as a baseline, a study 

demonstrating proper coordination of its protection systems.18

12. In addition, the NOPR proposed to approve the associated violation risk factors 

and violation severity levels, implementation plan, and effective date proposed by 

 17 Coordination of Protection Systems for Performance During Faults and Specific 

Training for Personnel Reliability Standards, Notice of Proposed Rulemaking, 82 FR 

55,535 (Nov. 22, 2017), 161 FERC ¶ 61,159, at P 12 (2017) (NOPR). The NOPR was 

erroneously published a second time in the Federal Register on November 28, 2017, 

which changed the comment date to January 29, 2018. 82 FR 56,759 (Nov. 30, 2017); 

82 FR 56,186 (Nov. 28, 2017).

18 NOPR, 161 FERC ¶ 61,159 at PP 14, 24.

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NERC.19 The NOPR also proposed to approve the revised definitions for inclusion in the 

NERC Glossary.20 Further, the NOPR proposed to approve the retirement of Reliability 

Standard PRC-001-1.1(ii), as requested by NERC.21

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

address below the issues raised in the NOPR and comments. The Appendix to this Final 

Rule lists the entities that filed comments in response to the NOPR.

II. Discussion

14. Pursuant to section 215(d)(2) of the FPA, we approve Reliability Standards 

PER-006-1 and PRC-027-1 as just, reasonable, not unduly discriminatory or preferential, 

and in the public interest, as both Reliability Standards improve on currently-effective 

Reliability Standard PRC-001-1.1(ii) in important ways.22 As discussed below, we do

not adopt the NOPR proposal to direct NERC to modify Reliability Standard PRC-027-1 

to require coordination of all bulk electric system elements with protection system 

functions.

15. Reliability Standard PRC-027-1 improves on currently-effective Reliability 

Standard PRC-001-1.1(ii) by: (1) modifying the applicability section to include the 

appropriate functional entity types with the responsibilities, resources, and skill sets to 

 19 Id. P 13.

20 Id.

21 Id.

22 16 U.S.C. 824o(d)(2).

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conduct the studies required to coordinate protection systems, and (2) listing the 

protection system functions on all bulk electric system elements that require coordination. 

Reliability Standard PER-006-1, along with existing formal training requirements in the 

Personnel Performance, Training, and Qualifications (PER) group of Reliability 

Standards, also improves upon Reliability Standard PRC-001-1.1(ii), Requirement R1 by 

ensuring that the necessary personnel are familiar with and understand the purpose and 

limitations of protection systems schemes while providing more precise and auditable 

requirements.

16. In addition, we approve NERC’s associated violation risk factors, violation 

severity levels, implementation plans, and effective dates. We also approve the revised 

definitions for inclusion in the NERC Glossary. Further, we approve the retirement of 

Reliability Standard PRC-001-1.1(ii), as requested by NERC.

Initial Protection System Coordination Study

NOPR

17. The NOPR proposed to direct that NERC develop modifications to Reliability 

Standard PRC-027-1 to ensure coordination of all bulk electric system elements with 

protection system functions by requiring that applicable entities perform an initial 

protection coordination study under Requirement R2, Option 2.

Comments

18. NERC does not support the proposed directive because it believes that the 

proposed directive is unduly burdensome and unsupported by the materials cited in the 

NOPR. NERC contends that while the “proposed directive could potentially help reduce 

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misoperations caused by coordination issues . . . [it] would also impose a significant 

burden on industry . . . requiring a substantial expenditure of resources.”23 NERC also 

states that it “expects that many entities will choose to do a full Protection System 

Coordination Study . . . for their more impactful [bulk electric system] Elements” and 

that “it is highly likely that the overwhelming majority of entities have already conducted 

coordination studies for their Protection Systems.”24 While NERC agrees with the goal 

of reducing protection system misoperation rates on the bulk electric system, it contends 

that recent misoperation rates demonstrate that mis-coordination of existing protection 

systems “does not present a widespread risk to [bulk electric system] reliability that 

would necessitate the expenditure of resources required to conduct full Protection System 

Coordination Studies for every [bulk electric system] element with a Protection 

System.”25

19. In addition, NERC and other commenters contend that the materials cited in the 

NOPR do not support the proposal to modify Reliability Standard PRC-027-1.26 NERC, 

EEI and Tri-State contend that the Arizona Southern California September 8, 2011 

Outage Report is unsupportive because it addresses mis-coordination of remedial action 

 23 NERC Comments at 4.

24 Id. at 5-6.

25 Id. at 6.

26 See generally NERC Comments; EEI Comments; Tri-State Comments; Entergy 

Comments; ITC Comments.

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schemes and not protection systems.27 NERC and Tri-State assert that the NERC System 

Protection Control Task Force Report addressed issues specific to generation 

transmission interfaces and did not apply broadly to all bulk electric system elements 

with protection systems.28 NERC and Tri-State also contend that the 2009 letter from the 

NERC President to the NERC board of Trustees and stakeholders is no longer relevant 

because mis-coordination issues are now responsible for a smaller percentage of events 

and that mis-coordination has not recently caused any significant system disturbances.29 

NERC and Tri-State claim that Reliability Standard PRC-004 now requires applicable 

entities to mitigate the effects of misoperations by implementing a corrective action plan 

that has reduced misoperations.30

20. Further, while NERC agrees with the 2013 Misoperations Report that reducing 

misoperations, including mis-coordination events, is an important priority for bulk 

electric system reliability, NERC contends that the report does not indicate that requiring 

protection system coordination studies for all applicable elements, as proposed in the 

NOPR, is the only or optimal way to reduce mis-coordination events.31 EEI also 

contends that the 2013 Misoperations Report shows that human error and lack of training 

 27 NERC Comments at 7; EEI Comments at 7; Tri-State Comments at 7-8.

28 NERC Comments at 7-8; Tri-State Comments at 8-9.

29 NERC Comments at 8; Tri-State Comments at 9-10.

30 NERC Comments at 8; Tri-State Comments at 9.

31 NERC Comments at 9.

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are responsible for a significant portion of misoperations.32

21. NERC, EEI, and Tri-State explain that the 2014 incident identified in the “lessons 

learned” document on “Generation Relaying – Underfrequency Protection Coordination” 

was unrelated to protection system coordination.33

22. Finally, NERC states that while the 2016 State of Reliability Report highlights the 

continued need to reduce misoperations, the report does not indicate that there is a need 

to require entities to perform a protection system coordination study for every bulk 

electric system element with a protection system.34 NERC also contends that the 2017 

State of Reliability Report observes a continuing decline in misoperation rates, but that

misoperations are a priority for NERC.35 NERC states that the misoperations rate within 

the Texas Reliability Entity Region observed in the 2016 State of Reliability Report was 

mitigated by the time NERC issued the 2017 State of Reliability Report.36 NERC claims 

that this reduction in misoperation events is evidence that requiring entities to perform 

protection system coordination studies is unnecessary because the entities will address 

the misoperation events without specific requirements in Reliability Standards.37

 32 EEI Comments at 7.

33 NERC Comments at 10; EEI Comments at 8; Tri-State Comments at 10.

34 NERC Comments at 10.

35 Id. at 9.

36 NERC Comments at 11; see also Entergy Comments at 8.

37 NERC Comments at 11.

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23. Other commenters do not support the proposal to direct NERC to develop 

modifications to Reliability Standard PRC-027-1 because they generally contend that the 

proposed directive is not necessary and would impose a burden without a proportional 

reliability benefit.38 Hydro One estimates that it will need approximately 30,000 hours of 

work to perform an initial protection system coordination study.39 Tri-State estimates 

that it would take an engineer at least twenty hours to perform a protection system 

coordination study at each of its approximately 700 terminals.40 Tri-State estimates that 

the actual cost to all applicable entities could be more than $120 million.41 PG&E 

estimates a cost to industry “greatly in excess of $100 million” and asserts that the 

proposed directive would require PG&E to perform coordination studies for 95 percent of 

the PG&E bulk electric system at a cost of $3.5 million in engineering labor.42

24. Entergy requests that the Commission find that NERC’s approach for requiring 

protection system coordination studies achieves the Reliability Standard’s “reliability 

 38 APPA/TAPS Comments at 3; EEI Comments at 3; El Paso Electric Comments 

at 4; Entergy Comments at 4; Hydro One Comments at 1-2; ITC Comments at 3; LPPC

Comments at 2; NPPD Comments at 1; NRECA/ELCON Comments at 5; Oncor 

Comments at 1; PG&E Comments at 2; SCE&G Comments at 1; Tri-State Comments 

at 4.

39 Hydro One Comments at 1.

40 Id. at 13.

41 Id.

42 PG&E Comments at 3.

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goals effectively and efficiently.”43 Entergy opines that, by adopting NERC’s proposal 

without modification, the Commission appropriately would give “due weight” to the 

technical expertise of the ERO. Entergy asserts that NERC properly supported 

Requirement R2 by setting forth evidence of the frequency of coordination events over a 

four-year period, which shows that only 11 percent of misoperation events (17 events out 

of 151) and only 2.9 percent of total events (17 out of 574) involved Protection System 

coordination issues. Further, Entergy claims that, in proposing the Reliability Standard, 

NERC was aware of the possibility that some bulk electric system elements may never 

undergo a Protection System Coordination Study and that “NERC does not afford this 

possibility the same risk as the Commission.”44 According to Entergy, “NERC has 

properly balanced the implementation costs and reliability benefits of the proposed 

PRC-027-1 Reliability Standard and determined that Option 2 is sufficient to ensure 

reliability” and the Commission should defer to NERC’s expertise, or otherwise provide 

more support to justify a deviation from NERC’s proposal.

25. In addition, some commenters expressed concern that applicable entities may not 

have maintained sufficient documentation to substantiate prior protection system 

coordination studies and, as result, entities would have to perform new protection system 

coordination studies purely for compliance purposes.45

 43 Entergy Comments at 5.

44 Id. at 9-10.

45 ITC Comments at 4; Entergy Comments at 1; NPPD Comments at 1; PG&E 

(continued ...)

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26. As an alternative to the proposed directive, NERC and other commenters suggest 

that Reliability Standard PRC-027-1 be modified so that it requires an applicable entity to 

conduct an initial baseline protection system coordination study on a certain subset of its 

bulk electric system elements (i.e., based on a higher voltage or higher risk protection 

systems).46 NERC and other commenters also request that the Commission permit 

NERC to allow more than 6 years to complete the initial baseline protection system 

coordination studies (i.e., 10 or 12 years) if the Commission directs NERC to modify 

Reliability Standard PRC-027-1.47 EEI recommends that if the Commission continues to 

have concerns about Reliability Standard PRC-027-1, Requirement R2, Option 2, as an 

alternative to the proposed directive, a final rule should direct NERC “to assess the 

 

Comments at 3.

46 NERC Comments at 11-12; El Paso Electric Comments at 2; Entergy Comments 

at 12; NRECA/ELCON Comments at 6-7.

47 NERC Comments at 12; El Paso Electric Comments at 2-3; Entergy Comments 

at 12-13; NRECA/ELCON Comments at 6-7. Separately, El Paso Electric contends that 

the six-year cycle proposed by NERC in Reliability Standard PRC-027-1, Requirement 

R2 is too short and directs resources away from “other activities that have a greater 

likelihood of improving reliability outcomes in a demonstrable way.” El Paso Electric 

Comments at 2. We disagree. NERC recognized the potential burden imposed by 

Requirement R2 and determined that six years “balance[d] the resources required to 

perform Protection System Coordination Studies and the potential reliability impacts 

created by incremental changes of Fault current over time.” NERC Petition at 40. 

Moreover, during the standard drafting process, some commenters indicated that 

six years was too long an interval. See, e.g., NERC Petition, Exhibit G (Summary of 

Development History and Record of Development) at 1479 of pdf (ReliabilityFirst 

recommending a 24-month period to conduct protection system coordination study), 

2169 of pdf (Texas RE stating that six years is too long of a time period between studies 

of fault currents).

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effectiveness of Option 2 after the implementation of the proposed Reliability Standard 

and if necessary make technical recommendations to improve the efficiency and 

effectiveness as appropriate.”48

27. Idaho Power supports the proposed directive.49 Idaho Power supports eliminating 

Reliability Standard PRC-027-1, Requirement R2, Option 2 because it contends that 

Option 1 is a more robust option explaining that it is “preferable because it is more likely 

to address miscoordinations.”50

Commission Determination

28. Based on the record before us, we do not adopt the directive proposed in 

the NOPR. The record in this proceeding supports the NOPR’s conclusion that 

mis-coordination of protection systems may pose a potential reliability risk and, as 

currently drafted, Reliability Standard PRC-027-1, Requirement R2, Option 2 permits 

applicable entities to forego protection system coordination studies under certain 

circumstances.51 However, we are persuaded by the statements from NERC and other 

 48 EEI Comments at 6.

49 Idaho Power Comments at 1-2.

50 Id. at 2.

51 See, e.g., NERC Comments at 6 (“NERC and the standard drafting team 

concluded that Protection System coordination did not present a prevalent enough risk to 

the reliable operation of the [bulk electric system] to warrant imposing the burden of 

requiring applicable entities to perform a full Protection System Coordination Study for 

every [bulk electric system] Element with a Protection System.”); Entergy Comments 

at 9 (“In proposing the Reliability Standard, NERC was aware of the possibility that 

some bulk electric system elements may never undergo a Protection System Coordination 

(continued ...)

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commenters that applicable entities generally perform, or will choose to perform for their 

significant facilities, protection system coordination studies even in the absence of a 

Reliability Standard requirement.52 We also recognize the concern raised by commenters 

regarding the burden of compliance. Specifically, we recognize the concern that were the 

NOPR directive adopted, applicable entities could be required to re-run protection system 

coordination studies for the sole purpose of generating compliance documentation, even 

if such entities already performed protection system coordination studies that remain 

valid but lack documentation to substantiate compliance. Accordingly, pursuant to 

215(d)(2) of the FPA, we approve Reliability Standard PRC-027-1 and do not direct 

modifications to the Reliability Standard.53

III. Information Collection Statement

29. The collections of information addressed in this Final Rule are subject to review 

by the Office of Management and Budget (OMB) under section 3507(d) of the 

Paperwork Reduction Act of 1995.54 OMB’s regulations require approval of certain 

information collection requirements imposed by agency rules.55 Upon approval of a 

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

 

Study.”).

52 See, e.g., NERC Comments at 5; NPPD Comments at 1; Tri-State Comments 

at 10; ITC Comments at 4.

53 16 U.S.C. 824o(d)(2).

54 44 U.S.C. 3507(d) (2012).

55 5 CFR 1320.11 (2017).

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date. Respondents subject to the filing requirements of a 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.

30. The Commission solicited public comments in the NOPR on the need for this 

information, whether the information will have practical utility, the accuracy of the 

burden estimates, ways to enhance the quality, utility, and clarity of the information to be 

collected or retained, and any suggested methods for minimizing respondents’ burden, 

including the use of automated information techniques. The Commission did not receive 

comments regarding the burden estimates for the Reliability Standards approved herein 

(i.e., Reliability Standards PRC-027-1 and PER-006-1).56

31. The information collection requirements in this Final Rule in Docket 

No. RM16-22-000 are associated with FERC-725A, FERC-725G, and FERC-725Y, 

as discussed below.57

 56 As discussed above, several commenters addressed the potential burden of a 

new version of Reliability Standard PRC-027-1 modified, pursuant to the Commission’s 

directive, to require initial protection system coordination studies. See, e.g., Tri-State 

Comments at 12. However, those comments are not relevant to the burden estimates 

contained in this Final Rule because, herein, the Commission only approves Reliability 

Standards PRC-027-1 and PER-006-1. 

57 In the NOPR in Docket No. RM16-22-000, some of the reporting requirements 

were included under FERC-725G6 (OMB Control No. 1902-0300), a temporary place 

holder, because FERC-725G was pending review at OMB in an unrelated action. As 

indicated below, those reporting requirements are now included under FERC-725G 

(OMB Control No. 1902-0252). When the NOPR in Docket No. RM16-22-000 was 

issued, another unrelated item affecting FERC-725A was pending OMB review. Burden 

estimates were provided in order to solicit public comments, but the burden reduction 

to FERC-725A was not submitted to OMB at that time. The burden reduction to 

(continued ...)

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32. Public Reporting Burden: The number of respondents below is based on an 

examination of the NERC compliance registry on December 1, 2017, for transmission 

owners, generator owners, generator operators, and distribution providers within the 

United States and an estimate of how many such entities from that registry will be 

affected by the Reliability Standards in this Final Rule for adoption and implementation. 

As of December 1, 2017, 337 transmission owners, 971 generator owners, 944 generator 

operators, and 419 distribution providers in the United States were registered in the 

NERC compliance registry. However, under NERC’s compliance registration program, 

entities may be registered for multiple functions, so these numbers incorporate some 

double counting. We note that many generation sites share a common generator owner or 

generator operator. The following table provides the estimated annual burden and cost 

related to information collection requirements in this Final Rule.58

 

FERC-725A for this Final Rule will be submitted to OMB for review.

58 TO=transmission owner; TOP=transmission operator; GO=generator owner; 

GOP=generator operator; DP=distribution provider; and BA=balancing authority.

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Changes due to the Final Rule in Docket No. RM16-22-000 

Responde

nt 

Category 

and 

Requirem

ent59

Number of 

Responden

ts

(1)

Annual 

Number of 

Responses 

per 

Responden

t

(2)

Total 

Number of 

Annual 

Responses 

(1)*(2)=(3)

Average 

Burden 

Hours & 

Cost per 

Response60

(4)

Annual 

Burden Hours 

& Total 

Annual Cost 

(rounded)61

(3)*(4)=(5)

FERC-725G (Reliability Standard PRC-027-1)62

TO; 

Reporting 

Reqs. R1, 

R2, & R3 337 1 337

60 hrs.;

$3,941.40

20,220 hrs.;

$1,328,252

TO; 

Recordkee

ping Reqs. 337 1 337

40 hrs.;

$1,565.60

13,480 hrs.;

$527,607

 59 For each Reliability Standard, the Measure shows the acceptable evidence for 

the associated Reporting Requirement, and the Compliance section details the related 

Recordkeeping Requirement.

60 The estimates for cost per hour are based on May 2016 wage figures from the 

Bureau of Labor Statistics (BLS, https://www.bls.gov/oes/current/naics2_22.htm)

and BLS benefits information from March 20, 2018 (for December 2017, 

https://www.bls.gov/news.release/ecec.nr0.htm). The estimated hourly cost, for wages 

plus benefits, are: (a) $68.12/hour, for electrical engineer, Occupation Code 17-2071, 

and (b) $39.14/hour, for information and record clerk, Occupation Code 43-4199.

The hourly cost for an electrical engineer is used for the reporting requirements; 

the hourly cost for a record clerk is used for the recordkeeping requirements.

61 For display purposes, the cost figures in column 5 have been rounded.

62 Some of the reporting requirements are required at least every six calendar 

years. In this table, the Commission assumes that respondents might work on some of 

their elements each year; the annual burden estimate shown is one sixth of the burden 

associated with one complete six-year cycle. For example, for each transmission owner: 

(a) the annual reporting burden associated with Requirements R1, R2, and R3 is shown as 

60 hours per year, and (b) the burden for the six-year cycle would be six times that, or a 

total of 360 hours.

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GO; 

Reporting 

Reqs. R1, 

R2, & R3 971 1 971

10 hrs.;

$656.90

9,710 hrs.;

$637,830

GO; 

Recordkee

ping Reqs. 971 1 971

10 hrs.;

$391.40

9,710 hrs.;

$380,049

DP; 

Reporting 

Reqs R1, 

R2, & R3 419 1 419

10 hrs.;

$656.90

4,190 hrs.;

$275,241

DP; 

Recordkee

ping Reqs. 419 1 419

10 hrs.;

$391.40

4,190 hrs.;

$163,997

Sub-Total 

for 

Reporting 

Reqs. for 

FERC725G

34,120 hrs.;

$2,241,323

Sub-Total 

for 

Recordkee

ping Reqs. 

for FERC725G

27,380 hrs.;

$1,072,653

Total 

Increase 

for FERC725G

61,500 hrs.;

$3,313,976

FERC-725Y (Reliability Standard PER-006-1)63

GOP; 

Reporting 

Req. R1 944 1 944

5 hrs.;

$328.45

4,720 hrs.;

$310,057

 63 In order to provide improved information on the Reliability Standard and 

associated burden, FERC-725Y (rather than FERC-725A) will cover the burden required 

by PER-006-1.

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GOP; 

Recordkee

ping Req. 944 1 944

10 hrs.;

$391.40

9,440 hrs.;

$369,482

Total 

Increase 

for FERC725Y

14,160 hrs.;

$679,539

Reductions to FERC-725A (retirement of Reliability Standard PRC-001-1.1)64

GOP; 

Reporting 

Req. 944 1 944

40 hrs.;

$2,627.60

37,760 hrs.;

$2,480,454

GOP; 

Recordkee

ping Req. 944 1 944

50 hrs.;

$1,957.00

47,200 hrs.;

$1,847,408

TOP; 

Reporting 

Req. 176 1 176

60 hrs.;

$3,941.40

10,560 hrs.;

$693,686

TOP; 

Recordkee

ping Req. 176 1 176

70 hrs.;

$2,739.80

12,320 hrs.;

$482,205

BA; 

Reporting 

Req. 99 1 99

32 hrs.;

$2,102.08

3,168 hrs.;

$208,106

BA; 

Recordkee

ping Req. 99 1 99

20 hrs.;

$782.80

1,980 hrs.;

$77,497

Reduction 

Sub-Total 

Reporting 

Reqs. for 

FERC725A

51,484 hrs.;

$3,382,246

 64 The estimates for average annual burden hours per response are based on figures 

in Order No. 693. Order No. 693, FERC Stats. & Regs. ¶ 31,242, at PP 1906-1907. The 

numbers of respondents and estimated hourly costs are based on current figures.

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Reduction 

Sub-Total 

Recordkee

ping Reqs. 

for FERC725A

61,500 hrs.;

$2,407,110

Reduction

Sub-Total 

for FERC725A

112,984 hrs.;

$5,789,356

(reduction)

NET 

TOTAL 

REDUCTI

ON FOR 

CHANGE

S IN 

RM16-22-

000

37,324 hrs.;

$1,795,841

(reduction)

Titles: FERC-725A (Mandatory Reliability Standards for the Bulk-Power System), 

FERC-725G (Reliability Standards for the Bulk Power System: PRC Reliability 

Standards) and FERC-725Y (Mandatory Reliability Standards: Operations Personnel 

Training).

Action: Revisions to existing collections.

OMB Control Nos.: 1902-0244 (FERC-725A); 1902-0252 (FERC-725G) and 1902-0279 

(FERC-725Y).

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

Frequency of Responses: Annual recordkeeping and reporting requirements, with some 

reporting requirements being at least once every six years.

Necessity of the Information: Reliability Standards PRC-027-1 and PER-006-1 set forth 

requirements for coordination of protection systems and personnel training on specific 

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topics essential to reliability. The Commission approves Reliability Standards 

PRC-027-1 and PER-006-1, which will replace Commission-approved Reliability 

Standard PRC-001-1.1(ii). Reliability Standards PRC-027-1 and PER-006-1 improve 

upon existing Reliability Standard PRC-001-1.1(ii) because the Reliability Standards 

assign responsibilities to entities with more appropriate resources and skill sets to conduct 

studies required to coordinate protection systems. The approved Reliability Standards 

also provide additional clarity to applicable entities.

Internal review: The Commission has assured itself, by means of its internal review, that 

there is specific, objective support for the burden estimates associated with the 

information requirements.

IV. Environmental Analysis

33. 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.65 The action proposed here falls within the categorical 

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

procedural, for information gathering, analysis, and dissemination.66

V. Regulatory Flexibility Act

34. The Regulatory Flexibility Act of 1980 (RFA) generally requires a description and 

 65 Regulations Implementing the National Environmental Policy Act of 1969, 

Order No. 486, FERC Stats. & Regs. ¶ 30,783 (1987) (cross-referenced at 41 FERC 

¶ 61,284).

66 18 CFR 380.4(a)(2)(ii) (2017).

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

of small entities.67 The Small Business Administration (SBA) defines which utilities are 

small businesses based on the number of employees that a utility and its affiliates 

employ.68

35. Reliability Standard PRC-027-1 (included in FERC-725G) will apply to 

approximately 1,727 entities (337 transmission owners, 971 generator owners, and 

419 distribution providers) in the United States.69 Pursuant to SBA regulations, the small 

business threshold for Electric Bulk Power Transmission and Control is 500 employees. 

For generator owners, the small generator threshold ranges from 250 to 750 employees 

(depending on the fuel source). For Electric Power Distribution, the small business 

threshold is 1,000 employees. We estimate that the annual cost for each entity will be 

$1,048 for each generator owner and distribution provider and $5,507 for each 

transmission owner.

36. Reliability Standard PER-006-1 (included in FERC-725Y) will apply to 

approximately 944 generator operators in the United States. Pursuant to SBA regulations 

the small business threshold for generator operators ranges from 250 to 750 employees 

(depending on the fuel source). We estimate that the annual cost for each generator 

 67 5 U.S.C. 601-612 (2012).

68 13 CFR 121.201, Subsector 221 (2017).

69 Many respondents serve multiple roles in the NERC compliance registry, so 

there is likely double counting in the estimates.

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operator will be $719.

37. The retirement of Reliability Standard PRC-001-1.1(ii) (included in FERC-725A) 

will decrease the annual estimated cost for 944 generator operators by $4,585 each, for 

176 transmission operators by $6,681 each, and for 99 balancing authorities by $2,885 

each. For the generator operators affected by this retirement and approval of Reliability 

Standard PER-006-1, the net annual effect would be a decrease of $3,866 each.

38. We estimate the net annual cost of this Final Rule would vary, by type of entity, 

from an annual decrease of $6,681 (for each transmission operator) to an annual increase

of $5,507 (for each transmission owner). We view this as a minimal economic impact for 

each entity. Accordingly, we certify that this Final Rule will not have a significant 

economic impact on a substantial number of small entities.

VI. Document Availability

39. 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.

40. 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 

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docket number field.

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

business hours from FERC Online Support at 202-502-6652 (toll free at 1-866-208-3676) 

or email at ferconlinesupport@ferc.gov, or the Public Reference Room at 202-502-8371, 

TTY 202-502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov.

VII. Effective Date and Congressional Notification

42. The Final Rule is effective [INSERT DATE 60 days from publication in 

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

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

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

Enforcement Fairness Act of 1996. This Final Rule is being submitted to the Senate, 

House, and Government Accountability Office.

By the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.

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Appendix

List of Commenters

APPA/TAPS American Public Power Association and 

Transmission Access Policy Study Group

EEI Edison Electric Institute

El Paso Electric El Paso Electric Company

Entergy Entergy Services, Inc.

Hydro One Hydro One Networks Inc.

Idaho Power Idaho Power Company

ITC International Transmission Company d/b/a ITC 

Transmission, Michigan Electric Transmission 

Company, LLC, ITC Midwest LLC and ITC Great 

Plains, LLC

LPPC Large Public Power Council

NPPD Nebraska Public Power District

NERC North American Electric Reliability Corporation

NRECA/ELCON National Rural Electric Cooperative Association and 

the Electricity Consumers Resource Council

Oncor Oncor Electric Delivery

PG&E Pacific Gas and Electric Company

SCE&G South Carolina Electric and Gas Company

Tri-State Tri-State Generation and Transmission Association, 

Inc.

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Document Content(s)

RM16-22-000.DOCX......................................................1-31

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