170 FERC ¶ 61,030

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket No. RM19-10-000]

Transmission Planning Reliability Standard TPL-001-5

(Issued January 23, 2020)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final rule.

SUMMARY: The Federal Energy Regulatory Commission (Commission) approves 

Reliability Standard TPL-001-5 (Transmission System Planning Performance 

Requirements), submitted by the North American Electric Reliability Corporation 

(NERC), the Commission-certified Electric Reliability Organization. 

EFFECTIVE DATE: This rule will become effective [INSERT DATE sixty (60) days 

after date of publication in the FEDERAL REGISTER].
Docket No. RM19

-10-000 ii

FOR FURTHER INFORMATION CONTACT:

Eugene Blick (Technical Information)

Office of Electric Reliability

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426 (301) 665-1759

eugene.blick@ferc.gov

Leigh Anne Faugust (Legal Information)

Office of the General Counsel Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6396

leigh.faugust@ferc.gov

SUPPLEMENTARY INFORMATION:
170 FERC ¶ 61,030

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Neil Chatterjee, Chairman;

 Richard Glick and Bernard L. McNamee.

 

Transmission Planning Reliability Standard TPL-001-5 Docket No. RM19-10-000

ORDER NO. 867

FINAL RULE

(Issued January 23, 2020)

Pursuant to section 215(d)(2) of the Federal Power Act (FPA), the Commission 

approves Reliability Standard TPL-001-5 (Transmission System Planning Performance 

Requirements).1

 The North American Electric Reliability Corporation (NERC), the 

Commission-certified Electric Reliability Organization (ERO), submitted Reliability 

Standard TPL-001-5 for Commission approval in response to directives in Order 

No. 786.

2

 As discussed in this final rule, we determine that Reliability Standard 

TPL-001-5 improves upon currently-effective Reliability Standard TPL-001-4 by 

addressing: (1) the study of single points of failure of protection systems; and 

(2) planned maintenance outages and stability analysis for spare equipment strategies. 

 1 16 U.S.C. 824o(d)(2).

2 Transmission Planning Reliability Standards, Order No. 786, 145 FERC 

¶ 61,051 (2013).
Docket No. RM19-10-000 - 2 -

The improvements in Reliability Standard TPL-001-5 are responsive to the 

directives in Order No. 786 regarding planned maintenance outages and stability analysis 

for spare equipment strategies.

3

 Reliability Standard TPL-001-5 is responsive in that it

requires each planning coordinator and transmission planner to perform an annual 

planning assessment of its portion of the bulk electric system considering a number of 

system conditions and contingencies with a risk-based approach. The improvements in 

Reliability Standard TPL-001-5 are also responsive to the concerns identified in Order 

No. 754 regarding the study of a single point of failure on protection systems.4

 

Reliability Standard TPL-001-5 contains revisions to the planning events (Category P5) 

and extreme events (Stability 2.a-h) identified in Table 1 (Steady State and Stability 

Performance Planning Events and Steady State and Stability Performance Extreme 

Events), as well as the associated footnote 13, to provide for a more comprehensive 

study of the potential impacts of protection system single points of failure.

For more common scenarios (i.e., planning events), the planning entity must 

develop a corrective action plan if it determines through studies that its system would 

experience performance issues.5 For less common scenarios that could result in 

 3 Order No. 786, 145 FERC ¶ 61,051, at PP 40, 89.

4 Interpretation of Transmission Planning Reliability Standard, Order No. 754, 

136 FERC ¶ 61,186, at P 19 (2011).

5 NERC defines “Corrective Action Plan” as, “A list of actions and an associated 

timetable for implementation to remedy a specific problem.” Glossary of Terms Used in 

NERC Reliability Standards (May 13, 2019) (NERC Glossary).
Docket No. RM19-10-000 - 3 -

potentially severe impacts such as cascading (i.e., extreme events), the planning entity 

must conduct a comprehensive analysis to understand both the potential impacts on 

its system and the types of actions that could reduce or mitigate those impacts.6

Reliability Standard TPL-001-5 is also responsive to Order No. 786 by modifying 

the requirements for stability analysis to require an entity to assess the impact of the 

possible unavailability of long lead time equipment, consistent with the entity’s spare 

equipment strategy. Accordingly, pursuant to section 215(d)(2) of the FPA, the 

Commission approves Reliability Standard TPL-001-5 as just, reasonable, not unduly 

discriminatory or preferential, and in the public interest.

In the Notice of Proposed Rulemaking (NOPR), the Commission proposed to 

direct NERC, pursuant to section 215(d)(5) of the FPA, to modify the Reliability 

Standard to require corrective action plans for protection system single points of failure

in combination with a three-phase fault if planning studies indicate potential cascading.7

 

As discussed below, we determine not to adopt the proposed directive. 

 6 NERC defines “Cascading” as, “The uncontrolled successive loss of System 

Elements triggered by an incident at any location. Cascading results in widespread 

electric service interruption that cannot be restrained from sequentially spreading beyond 

an area predetermined by studies.” NERC Glossary.

7 16 U.S.C. 824o(d)(5); Transmission Planning Reliability Standard TPL-001-5, 

Notice of Proposed Rulemaking, 84 FR 30,639 (Jun. 27, 2019), 167 FERC ¶ 61,249, at 

P 5 (2019) (NOPR).
Docket No. RM19-10-000 - 4 -

I. Background

A. Section 215 and Mandatory Reliability Standards

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

mandatory and enforceable Reliability Standards, subject to Commission review and 

approval. Once approved, the Reliability Standards may be enforced in the United States 

by the ERO, subject to Commission oversight, or by the Commission independently.8

 

Pursuant to section 215 of the FPA, the Commission established a process to select and 

certify an ERO,9 and subsequently certified NERC.10

B. Industry Advisory

On March 30, 2009, NERC issued an advisory report notifying industry that 

failure of a single component of a protection system caused three significant system 

disturbances in the previous five years.11 In the Industry Advisory, NERC stated that 

“[p]rotection system component failures may render a protective scheme inoperative, 

 8 Id. 824o(e).

9 Rules Concerning Certification of the Electric Reliability Organization; and 

Procedures for the Establishment, Approval, and Enforcement of Electric Reliability 

Standards, Order No. 672, 114 FERC ¶ 61,104, order on reh’g, Order No. 672-A, 

114 FERC ¶ 61,328 (2006).

10 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on 

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

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

11 Industry Advisory, Protection System Single Point of Failure (March 30, 2009), 

https://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/2009%20Advisories/A-2009-03-30-

01.pdf (Industry Advisory).
Docket No. RM19-10-000 - 5 -

which could result in N-1 transmission system contingencies evolving into more severe 

or even extreme events.”12 NERC advised registered transmission owners, generator

owners, and distribution providers “to address single points of failure on their protection 

systems, when identified in routine system evaluations, to prevent N-1 transmission 

system contingencies from evolving into more severe events or even extreme events.”13 

NERC also advised industry to begin preparing an estimate of the resource commitment 

required to review, re-engineer, and develop a workable outage and construction schedule 

to address single points of failure.

C. Order No. 754

On November 17, 2009, NERC submitted a petition requesting approval of 

NERC’s interpretation of Reliability Standard TPL-002-2, Requirement R1.3.10. In the 

resulting Order No. 754, the Commission determined that “there may be a system 

protection issue that merits further exploration by technical experts” and that there is “an 

issue concerning the study of the non‐operation of non‐redundant primary protection 

systems; e.g., the study of a single point of failure on protection systems.”14 To address 

this concern, the Commission directed “Commission staff to meet with NERC and its 

appropriate subject matter experts to explore the reliability concern, including where it 

 12 Id. at 2.

13 Id. at 1.

14 Order No. 754, 136 FERC ¶ 61,186, at P 19 (2011).
Docket No. RM19-10-000 - 6 -

can best be addressed, and identify any additional actions necessary to address the 

matter.”15 The Commission also directed NERC “to make an informational 

filing . . . explaining whether there is a further system protection issue that needs to be 

addressed and, if so, what forum and process should be used to address that issue and 

what priority it should be accorded relative to other reliability initiatives planned by 

NERC.”16

Commission staff then hosted a technical conference in October 2011 on single 

points of failure, which resulted in four consensus points and the following problem 

statement: “[t]he group perceives a reliability concern regarding the comprehensive 

assessment of potential protection system failures by registered entities. The group 

agrees on the need to study if a [reliability] gap exists regarding the study and resolution 

of a single point of failure on protection systems.”17 One outcome of the 2011 technical 

conference, as described in the 2012 Informational Filing, was that the NERC Board of 

Trustees approved the issuance of a data request to aid in assessing whether single points 

of failure in protection systems pose a reliability concern.

18 

 15 Id. P 20.

16 Id.

17 NERC, Order No. 754 Single Point of Failure Technical Meeting Notes at 8 

(October 24-25, 2011). 

18 2012 NERC Informational Filing at 7 (stating that the data request “is based on 

an approach that utilizes . . . a three-phase (3Ø) fault and assesses simulated system 

performance against performance measures”).
Docket No. RM19-10-000 - 7 -

Over the next two years, NERC collected data from transmission planners that it 

used to assess protection system single points of failure. This assessment examined in 

detail the protection systems related to nearly 4,000 buses. The findings were presented 

in a September 2015 report that concluded that single points of failure on protection 

systems posed a reliability risk that warranted further action.19 After considering 

alternatives, the 2015 Report recommended that NERC modify Reliability Standard 

TPL‐001‐4 to maximize reliability of protection system performance and align with 

the directives in Order No. 754. In particular, the 2015 Report recommended that 

three-phase faults involving protection system failures be assessed as an extreme 

event in Reliability Standard TPL-001-4. As an extreme event under Reliability Standard 

TPL-001-4, Part 4.5, an entity is required to evaluate, but not implement, possible actions 

designed to mitigate cascading.20 Notably however, the report did not recommend 

elevating three-phase faults with a protection system failure to a planning event under 

Part 2.7, which requires a corrective action plan when analysis indicates an inability to 

meet performance requirements. The report explained that the “[p]robability of threephase fault with a protection system failure is low enough that it does not warrant a 

planning event.”21

 19 NERC, Order No. 754 Assessment of Protection System Single Points of Failure 

Based on the Section 1600 Data Request, at 11 (September 2015) (2015 Report).

20 Id.

21 Id. at 9.
Docket No. RM19-10-000 - 8 -

D. Order No. 786

In Order No. 786, the Commission approved the currently-effective version 

of the transmission system planning standard, Reliability Standard TPL-001-4, and

issued several directives to NERC. First, the Commission expressed concern that 

the six (6) month outage duration threshold in Reliability Standard TPL-001-4, 

Requirement R1 could exclude planned maintenance outages of significant facilities from 

future planning assessments.22 The Commission determined that planned maintenance 

outages of less than six (6) months in duration may result in relevant impacts during one 

or both of the seasonal off-peak periods, and that prudent transmission planning should 

consider maintenance outages at those load levels when planned outages are performed to 

allow for a single element to be taken out of service for maintenance without 

compromising the ability of the system to meet demand without loss of load. The 

Commission further determined that a properly planned transmission system should 

ensure the known, planned removal of facilities (i.e., generation, transmission, or 

protection system facilities) for maintenance purposes without the loss of 

nonconsequential load or detrimental impacts to system reliability such as cascading, 

voltage instability, or uncontrolled islanding. The Commission directed NERC to modify 

the Reliability Standards to address these concerns. 

 22 Order No. 786, 145 FERC ¶ 61,051 at PP 40-45.
Docket No. RM19-10-000 - 9 -

Second, while stating that NERC had met the Commission’s Order No. 693 

directive to include a spare equipment strategy for steady state analysis in Reliability 

Standard TPL-001-4, the Commission determined that a spare equipment strategy for 

stability analysis was not addressed in the standard.23 The Commission stated that a 

similar spare equipment strategy for stability analysis should exist that requires studies 

to be performed for no or single contingency categories24 with the conditions that the 

system is expected to experience during the possible unavailability of the long lead time 

equipment. Rather than direct a change at that time, however, the Commission directed 

NERC to consider the issue during the next review cycle of Reliability Standard 

TPL-001-4.25

E. NERC Petition and Reliability Standard TPL-001-5 

On December 7, 2018, NERC submitted Reliability Standard TPL-001-5 for 

Commission approval.26 NERC maintains that Reliability Standard TPL-001-5 addresses 

the Order No. 786 directives. With regard to protection system single points of failure, 

 23 Id. PP 85, 88-89 (citing Mandatory Reliability Standards for the Bulk-Power 

System, Order No. 693, 118 FERC ¶ 61,218, at P 1786, order on reh’g, Order No. 693-A, 

120 FERC ¶ 61,053 (2007)).

24 See Reliability Standard TPL-001-4, Table 1 – Steady State & Stability 

Performance Planning Events, Categories P0, P1, and P2.

25 Order No. 786, 145 FERC ¶ 61,051 at PP 88-89.

26 Reliability Standard TPL-001-5 is available on the Commission’s eLibrary 

document retrieval system in Docket No. RM19-10-000 and on the NERC website, 

www.nerc.com.
Docket No. RM19-10-000 - 10 -

NERC indicates that Table 1 of Reliability Standard TPL-001-5 describes system 

performance requirements for a range of potential system contingencies required to be 

evaluated by the planner.27 Table 1 includes three parts: (1) Steady State & Stability 

Performance Planning Events; (2) Steady State & Stability Performance Extreme Events;

and (3) Steady State & Stability Performance Footnotes. Table 1 describes system 

performance requirements for a range of potential system contingencies required to be 

evaluated by the planner. The table categorizes the events as either “planning events” or 

“extreme events.” The table lists seven contingency planning events (P1 through P7) that 

require steady-state and stability analysis as well as five extreme event contingencies: 

three for steady-state and two for stability. 

According to NERC, Reliability Standard TPL-001-5 includes certain 

modifications to better ensure that planning entities are performing a more complete 

analysis of potential protection system single points of failure issues on their systems and 

taking appropriate action to address these concerns. NERC explains that Reliability 

Standard TPL-001-5 contains revisions to both the Table 1 planning event (Category P5) 

and extreme events (Stability 2.a-h) and the associated footnote 13 to provide for 

 27 Reliability Standard TPL-001-5 includes an expanded list of protection system 

components for single points of failure studies. The selected list of components account 

for: (1) those failed non-redundant components of a protection system that may impact 

one or more protection systems; (2) the duration that faults remain energized until 

delayed fault clearing; and (3) the additional system equipment removed from service 

following fault clearing depending on the specific failed non-redundant component of a 

protection system. NERC Petition at 16.
Docket No. RM19-10-000 - 11 -

more comprehensive study of the potential impacts of protection system single points 

of failure. 

NERC states that where the study of a protection system single point of failure for 

a single-line-to-ground fault (i.e., a Category P5 event) identifies cascading, a corrective 

action plan is required.28 NERC considers this a relatively commonplace scenario, and 

NERC explains that an entity would be required to develop a corrective action plan if it 

determines that its system would be unable to meet the performance requirements of 

Table 1 for the Category P5 event. 

In contrast, the revisions treat a protection system single point of failure in 

combination with a three-phase fault as an extreme event that does not require a 

corrective action plan. NERC asserts that the three-phase fault scenario is much less 

common than the single-line-to-ground fault scenario. According to NERC, like the 

other extreme events in Reliability Standard TPL-001-5, the three-phase fault scenario, 

while rare, could result in more significant impacts to an entity’s system.29 Under this 

approach, if an entity determines that its system will experience cascading as a result of a 

three-phase fault scenario, the entity would evaluate possible actions designed to reduce 

 28 Reliability Standard TPL-001-5, Table 1 (Steady State and Stability 

Performance Planning Events), Category P5 requires the study of a single-line-to-ground 

faulted element (e.g., generator, transmission circuit or transformer) along with a failure 

to operate of a non-redundant component of the protection system (i.e., a single point of 

failure) protecting the faulted element.

29 Order No. 693, 118 FERC ¶ 61,218 at P 1826 (describing extreme events as

“events resulting in loss of two or more elements or cascading”).
Docket No. RM19-10-000 - 12 -

the likelihood or mitigate the consequences of the event; however, a corrective action 

plan would not be required.

NERC explains that the likelihood of a three-phase fault event occurring and 

resulting in the most severe impacts would be small based on an historical analysis of 

NERC data on protection system misoperation. NERC states that it reviewed over 

12,000 protection system misoperation in its Misoperation Information Data Analysis 

System database reported since 2011, of which only 28 involved three-phase faults. Of 

those, NERC states that 10 involved breakers that failed to operate, and the remaining 

18 involved breakers that were slow to operate.30 NERC contends that a failure to 

operate may indicate an instance of a protection system single point of failure. While the 

potential for severe impacts from such events remains, NERC asserts that none of the 

10 failure to trip scenarios reported since 2011 resulted in events that reached the 

threshold for reporting under Reliability Standard EOP-004 (Event Reporting).31 With 

regard to the Order No. 786 directives, NERC maintains that Reliability Standard 

TPL-001-5 provides for a more complete consideration of factors for selecting which 

known outages will be included in near-term transmission planning horizon studies. 

 30 NERC Petition at 26, n.55.

31 Reliability Standard EOP-004-3 (Event Reporting), Attachment 1: Reportable 

Events, contains a list of thresholds for reporting certain events to NERC. Examples of 

reporting thresholds include: loss of firm load for 15 minutes or more if 300 MW or 

greater for entities with a previous year’s demand of at least 3,000 MW, or 200 MW or 

greater for all other entities.
Docket No. RM19-10-000 - 13 -

F. Notice of Proposed Rulemaking

On June 20, 2019, the Commission issued a NOPR that proposed to approve 

Reliability Standard TPL-001-5 as the Reliability Standard largely addresses the 

directives in Order No. 786. The NOPR also proposed to direct NERC, pursuant to 

section 215(d)(5) of the FPA, to modify the Reliability Standard to require corrective 

action plans for protection system single points of failure in combination with a threephase fault if planning studies indicate potential cascading.32 The NOPR stated that 

NERC had not adequately justified categorizing protection system single points of failure 

in combination with a three-phase fault as an extreme event that only requires study, but 

not a corrective action plan, when there is the potential for cascading. The NOPR also

expressed concern with NERC’s assessment that such events do not necessitate corrective 

action plans because of their rarity. The NOPR proposed to direct NERC to submit the 

modified Reliability Standard for approval within twelve (12) months from the effective 

date of a final rule. 

In addition to inviting comment on the proposed directive, the NOPR sought 

comment on: (1) how many corrective action plans are expected for protection system

single points of failure in combination with a three-phase fault if a study indicates

cascading, so the Commission could better understand the potential for increased costs 

and other implementation issues; and (2) the Commission’s proposal to direct NERC 

address the directive within twelve (12) months of the effective date of the final rule.

 32 NOPR, 167 FERC ¶ 61,249 at P 1.
Docket No. RM19-10-000 - 14 -

The Commission received ten sets of NOPR comments. We address below the 

issues raised in the NOPR and the comments submitted in response. The Appendix to 

this final rule lists the entities that filed comments.

II. Discussion

Pursuant to section 215(d)(2) of the FPA, the Commission approves Reliability 

Standard TPL-001-5 as just, reasonable, not unduly discriminatory or preferential, and in 

the public interest. We conclude that Reliability Standard TPL-001-5 is an improvement 

over currently-effective Reliability Standard TPL-001-4 and will improve Bulk-Power 

System reliability by requiring enhanced transmission system planning regarding the 

study of protection system single points of failure in combination with a single-line-toground fault, as discussed in Order No. 754. The Commission also approves the 

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

The Commission determines that Reliability Standard TPL-001-5 satisfies the

Order No. 786 directives regarding planned maintenance outages and stability analysis 

for spare equipment strategies. First, Reliability Standard TPL-001-5 provides for a more 

complete consideration of factors for selecting which known outages will be included in 

near-term transmission planning horizon studies. The modifications in Reliability 

Standard TPL-001-5 also address the Commission’s concern that the exclusion of known 

outages of less than six (6) months in currently-effective Reliability Standard TPL-001-4 

could result in outages of significant facilities not being studied. Second, Reliability 

Standard TPL-001-5 modifies requirements for stability analysis to require an entity to 

assess the impact of the possible unavailability of long lead time equipment, consistent 
Docket No. RM19-10-000 - 15 -

with the entity’s spare equipment strategy. For these reasons, the Commission approves 

Reliability Standard TPL-001-5

In addition, the Commission determines not to direct NERC to develop and submit

modifications to the Reliability Standards to require corrective action plans to address 

protection system single points of failure in combination with a three-phase fault if 

planning studies indicate potential cascading. We are persuaded by NERC and other 

commenters of the improbability of single points of failure in combination with threephase faults resulting in cascading outages.33 Our determination is also supported by the 

2015 Report’s assessment that the probability of an adverse system impact from a threephase fault accompanied by a protection system failure is low enough that it does not 

warrant being a planning event (i.e., requiring a corrective action plan). Although the 

Commission previously noted that there is an average of approximately one three-phase 

fault event every three (3) months since 2011, only ten indicated instances of a protection 

system single point of failure, which we agree is a rare occurrence. Given the NERC

standard drafting team’s assessment of the improbability of single points of failure in 

combination with three-phase faults resulting in cascading outages, we determine that it 

is reasonable to address such occurrences as extreme events only requiring analysis and 

evaluation of possible mitigating actions designed to reduce adverse impacts.

 33 See, e.g., NERC Petition 25-26, NERC Comments at 5, Trade Associations 

Comments at 5-6.
Docket No. RM19-10-000 - 16 -

Further, we do not adopt BPA’s recommendation, as an alternative to the NOPR 

directive, for NERC to conduct a two-year pilot to determine whether the types of actions 

that could reduce or mitigate the impacts of single point of failure events are a costeffective means of ensuring reliability.34 As discussed above, we conclude that the

record reflects the infrequent nature of single points of failure in combination with threephase faults resulting in cascading outages and therefore justifies our determination not to 

adopt the NOPR directive.

Other Issues Raised in NOPR Comments

MISO’s comments include recommendations apart from the issues discussed 

above. First, MISO recommends revising Reliability Standard TPL-001-5 to address the 

need for planned outage flexibility in the planning horizon. MISO contends that since 

very few planned outages are scheduled in the planning horizon, the Reliability Standard 

omits consideration of planned (i.e. known) outages in the planning assessment. MISO 

states that Reliability Standard TPL-001-5 does not define the term “known” outages. 

MISO believes that the industry stakeholders will primarily interpret the term “known” to 

require that only scheduled outages be included in transmission planning models. MISO 

maintains that because the eventual occurrence of a future planned outage is certain to 

occur, such planned outages should be considered “known” for purposes of applying 

Reliability Standards to the transmission planning process. 

 34 BPA Comments at 2-3.
Docket No. RM19-10-000 - 17 -

Second, MISO recommends adding instrument transformers (i.e., current 

transformers and voltage transformers) to Reliability Standard TPL-001-5, Table 1, 

Footnote 13 to define protection system non-redundancies. MISO observes that 

instrument transformers are components listed in the NERC definition of protection 

system and, according to NERC, represent valid single points of failure. 

Commission Determination

The Commission agrees with MISO that “because the eventual occurrence of a 

future planned outage is certain to occur, such planned outages should be considered 

‘known’ for purposes of applying Reliability Standards to the transmission planning 

process.”35 As MISO observes, the Commission stated in Order No. 786 that a “properly 

planned transmission system should ensure the known, planned removal of facilities (i.e., 

generation, transmission or protection system facilities) for maintenance purposes 

without the loss of non-consequential load or detrimental impacts to system reliability 

such as cascading, voltage instability or uncontrolled islanding.”36 Moreover, the 

Commission indicated in Order No. 786 that known planned facility outages (i.e. 

generation, transmission or protection system facilities) should be addressed so long as 

their “planned start times and durations may be anticipated as occurring for some period 

of time during the planning time horizon.”37 Given these statements, we are not 

 35 MISO Comments at 5.

36 Order No. 786, 45 FERC ¶ 61,051 at P 41.

37 Id. P 44.
Docket No. RM19-10-000 - 18 -

convinced that registered entities will interpret “known” in Reliability Standard 

TPL-001-5 to mean scheduled, as MISO contends. Accordingly, we decline to adopt 

MISO’s recommendation to modify the Reliability Standard.

The Commission also declines to direct NERC to include instrument transformer 

(i.e., current transformers and voltage transformers) failure as a single component failure 

in Reliability Standard TPL-001-5, Footnote 13. The standard drafting team explained in 

the Technical Rationale document for Reliability Standard TPL-001-5 that the “[System 

Protection and Control Subcommittee and System Modeling and Analysis Subcommittee] 

report described voltage or current sensing devices [i.e., current transformers and voltage 

transformers] as having a lower level of risk of failure to trip due to robustness and 

likelihood to actually cause tripping upon failure. Therefore, these components of a

Protection System are omitted from Footnote 13.”38 While it contends that “ignoring 

instrument transformers ... is contrary to good utility practice,” MISO acknowledges that 

“instrument transformers are generally more robust than the other components of a 

protection system.”39 Based on this record, the Commission declines to adopt MISO’s 

recommendation.

 38 NERC Petition, Exhibit F (Technical Rationale) at 5.

39 MISO Comments at 12.
Docket No. RM19-10-000 - 19 -

III. Information Collection Statement

The Paperwork Reduction Act (PRA)40 requires each federal agency to seek and 

obtain the Office of Management and Budget’s (OMB) approval before undertaking a 

collection of information (including reporting, record keeping, and public disclosure 

requirements) directed to ten or more persons or contained in a rule of general 

applicability. OMB regulations require approval of certain information collection 

requirements imposed by rules (including deletion, revision, or implementation of new 

requirements).41 Upon approval of a collection of information, OMB will assign an 

OMB control number and expiration date. Respondents subject to the filing requirements 

of this rule will not be penalized for failing to respond to the collection of information 

unless the collection of information displays a valid OMB Control Number. 

The Commission is submitting these reporting and recordkeeping requirements to 

OMB for its review and approval under section 3507(d) of the PRA. The Commission 

solicits comments on the Commission’s 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.

 40 44 U.S.C. 3501-21.

41 5 CFR 1320.
Docket No. RM19-10-000 - 20 -

Burden Estimate42: The estimated burden43 and cost44 for the requirements 

contained in this final rule follows:

FERC-725N, Modifications Due to Final Rule in Docket No. RM19-10-000 

Areas of 

Modification

Number of 

Respondents45

(1)

Annual 

Number of 

Responses 

per 

Respondent

(2)

Total 

Number 

of 

Responses 

(1)*(2)=(3)

Average Burden & 

Cost Per Response

(4)

Total Annual 

Burden Hours 

& Total Annual 

Cost

(3)*(4)=(5)

Single Point of 

Failure (onetime)

214 (PC/TP) 1 214

16 hrs. (reporting: 12 

hrs.; recordkeeping: 4 

hrs.);

$880

3,424 hrs. &

$188,320.

(reporting, 

2,568 hrs. & 

$141,240, & 

recordkeeping, 

856 hrs., 

$47,080)

 42 “Burden” is the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. 

For further explanation of what is included in the information collection burden, refer to 

5 CFR § 1320.3.

43 The estimated burden is a one-time burden estimate in addition to the already 

approved burden estimate in Reliability Standard TPL-001-4.

44 Hourly costs are based on the Bureau of Labor Statistics (BLS) figures for May 

2018 (Sector 22, Utilities) for wages (https://www.bls.gov/oes/current/naics2_22.htm) 

and benefits (https://www.bls.gov/news.release/ecec.nr0.htm). We estimate that Office 

and Administrative Support (Occupation code: 43-0000) would perform the functions 

associated with recordkeeping requirements, at an average hourly cost (for wages and 

benefits) of $42.11. We estimate the functions associated with reporting requirements 

would be performed by an Electrical Engineer (Occupation code: 17-2051) at an average 

hourly cost (including wages and benefits) of $68.17. These occupational categories’ 

wage figures are averaged and weighted equally as follows: ($42.11 hour + $68.17 hour) 

÷ 2 = $55.14/hour. The resulting wage figure is rounded to $55.00/hour for use in 

calculating wage figures in the final rule in Docket No. RM19-10-000.

45 The number of respondents is based on the NERC Registry on November 21, 

2019, which showed 8 entities registered as planning coordinators (PCs), 139 entities 

registered as transmission planners (TPs), and 67 entities registered as both PCs and TPs.
Docket No. RM19-10-000 - 21 -

Spare 

Equipment 

Strategy (onetime) 214 (PC/TP) 1 214

4 hrs. (reporting: 2 

hrs.; recordkeeping: 2 

hrs.);

$220

856 hrs. &

$47,080

(reporting, 

428 hrs. & 

$23,540; 

recordkeeping, 

428 hrs. & 

$23,540) 

Plan 

Maintenance 

Outage (onetime) 214 (PC/TP) 1 214

16 hrs. (reporting: 12 

hrs.; recordkeeping: 4 

hrs.)

$880

3,424 hrs. &

$188,320

(reporting, 

2,568 hrs. & 

$141,240; 

recordkeeping, 

856 hrs. & 

$47,080)

Sub-Total for 

Reporting 

Requirements

5,564 hrs.; 

$306,020

Sub-Total for 

Recordkeeping 

Requirements

2,140 hrs.; 

$117,700

TOTAL 642 7,704 hrs.;

$423,720

This final rule will not significantly change existing burdens on an ongoing basis. 

The Commission estimates a one-time burden increase for Year 1 only because Year 1 

represents a one-time task not repeated in subsequent years. 

Title: FERC-725N, Mandatory Reliability Standards: Transmission Planning 

(TPL) Reliability Standards 

Action: Revision to FERC-725N information collection.

OMB Control No.: 1902-0264.

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

Frequency of Responses: One Time 
Docket No. RM19-10-000 - 22 -

Necessity of the Information: This final rule approves the requested modifications to a 

Reliability Standard pertaining to transmission planning. As discussed above, the 

Commission approves Reliability Standard TPL-001-5 pursuant to FPA section 215(d)(2) 

because it improves upon the currently-effective Reliability Standard TPL-001-4. 

Internal Review: The Commission has reviewed Reliability Standard TPL-001-5 and 

determined that its action is necessary to implement section 215 of the FPA. 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.

Interested persons may obtain information on the reporting requirements by 

contacting the following: Federal Energy Regulatory Commission, 888 First Street, 

NE Washington, DC 20426 [Attention: Ellen Brown, Office of the Executive Director, 

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

Submit comments concerning the collection of information and the associated burden 

estimate to the Commission in this docket, and to the Office of Management and Budget, 

Office of Information and Regulatory Affairs, 725 17th Street NW, Washington, DC 

20503, [Attention: Desk Officer for the Federal Energy Regulatory Commission]. For 

security reasons, comments to OMB should be submitted by e-mail to: 

oira_submission@omb.eop.gov. Comments submitted to OMB should include FERC725N and OMB Control No. 1902-0264.

IV. Environmental Analysis

The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 
Docket No. RM19-10-000 - 23 -

on the human environment.46 The Commission has categorically excluded certain actions 

from this requirement as not having a significant effect on the human environment. 

Included in the exclusion are rules that are clarifying, corrective, or procedural or that do 

not substantially change the effect of the regulations being amended.47 The actions 

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

V. Regulatory Flexibility Act Analysis 

The Regulatory Flexibility Act of 1980 (RFA)48 generally requires a description 

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

number of small entities.49 The Small Business Administration’s (SBA) Office of Size 

Standards develops the numerical definition of a small business.50 The SBA revised its 

size standard for electric utilities (effective January 22, 2014) to a standard based on the 

number of employees, including affiliates (from the prior standard based on megawatt 

hour sales).51

 46 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).

47 18 CFR 380.4(a)(2)(ii).

48 5 U.S.C. 601-612.

49 Id.

50 13 CFR 121.101.

51 Id. 121.201.
Docket No. RM19-10-000 - 24 -

Reliability Standard TPL-001-5 is expected to impose an additional burden on 

214 entities52 (PCs and TPs). Of the 214 affected entities discussed above, we estimate 

that approximately 10 percent of the affected entities are small entities. We estimate that 

each of the 21 small entities to whom the proposed modifications to proposed Reliability

Standard TPL-001-5 apply will incur one-time costs of approximately $1,980 per entity

to implement the proposed Reliability Standard. We do not consider the estimated costs

for these 21 small entities to be a significant economic impact. 

Accordingly, the Commission certifies that this final rule will not have a 

significant economic impact on a substantial number of small entities.

VI. Document Availability

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.

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 

 52 Public utilities may fall under one of several different categories, each with a 

size threshold based on the company’s number of employees, including affiliates, 

the parent company, and subsidiaries. We are using a 500-employee threshold due to 

each affected entity falling within the role of Electric Bulk Power Transmission and 

Control (NAISC Code: 221121).
Docket No. RM19-10-000 - 25 -

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.

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

These regulations are effective [INSERT DATE sixty (60) days after date of 

publication in the FEDERAL REGISTER]. The Commission has determined, with the 

concurrence of the Administrator of the Office of Information and Regulatory Affairs of 

OMB, that this rule is not a “major rule” as defined in section 351 of the Small Business 

Regulatory Enforcement Fairness Act of 1996. The rule will be provided to the Senate, 

House, Government Accountability Office, and the SBA.

By the Commission. 

( S E A L )

Kimberly D. Bose,

Secretary.
Docket No. RM19-10-000 - 26 -

Note: The following appendix will not appear in the Code of Federal Regulations.

APPENDIX

List of Commenters

Abbreviation Commenter

AF&PA American Forest and Paper Association

APS Arizona Public Service Company

BPA Bonneville Power Administration

Carder William Carder

MISO Midcontinent Independent System Operator, Inc.

NERC North American Electric Reliability Corporation

Pugh Theresa Pugh

Trade Associations American Public Power Association, Edison Electric 

Institute, Large Public Power Council, National Rural Electric 

Cooperative Association

Tri-State Tri-State Generation and Transmission Association, Inc.

TVA Tennessee Valley Authority