156 FERC ¶ 61,062

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 35 

[Docket No. RM16-8-000; Order No. 828]

Requirements for Frequency and Voltage Ride Through Capability of Small Generating 

Facilities

(Issued July 21, 2016)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final rule.

SUMMARY: The Federal Energy Regulatory Commission (Commission) is modifying 

the pro forma Small Generator Interconnection Agreement (SGIA). The pro forma SGIA 

establishes the terms and conditions under which public utilities must provide 

interconnection service to small generating facilities of no larger than 20 megawatts. The 

Commission is modifying the pro forma SGIA to require newly interconnecting small 

generating facilities to ride through abnormal frequency and voltage events and not 

disconnect during such events. The specific ride through settings must be consistent with 

Good Utility Practice and any standards and guidelines applied by the transmission 

provider to other generating facilities on a comparable basis. The Commission already 

requires generators interconnecting under the Large Generator Interconnection 

Agreement to meet such requirements, and it would be unduly discriminatory not to also 

impose these requirements on small generating facilities. The Commission concludes 
Docket No. RM16-8-000 - 2 -

that newly interconnecting small generating facilities should have ride through 

requirements comparable to large generating facilities.

EFFECTIVE DATE: This Final Rule will become effective [Insert Date 65 days after 

publication in the FEDERAL REGISTER].

FOR FURTHER INFORMATION CONTACT:

Monica Taba (Technical Information)

Office of Electric Reliability

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6789

Monica.Taba@ferc.gov

Alan Rukin (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-8502

Alan.Rukin@ferc.gov

SUPPLEMENTARY INFORMATION:
156 FERC ¶ 61,062

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Norman C. Bay, Chairman;

 Cheryl A. LaFleur, Tony Clark,

and Colette D. Honorable.

Requirements for Frequency and Voltage Ride Through 

Capability of Small Generating Facilities

Docket No. RM16-8-000

ORDER NO. 828

FINAL RULE

(Issued July 21, 2016)

1. In this Final Rule, the Commission modifies the pro forma Small Generator 

Interconnection Agreement (SGIA) originally set forth in Order No. 20061and revised in 

Order No. 7922to require small generating facilities interconnecting through the SGIA to 

ride through abnormal frequency and voltage events and not disconnect during such 

events.3 Pursuant to section 206 of the Federal Power Act (FPA), the Commission finds 

 

1 Standardization of Small Generator Interconnection Agreements and 

Procedures, Order No. 2006, FERC Stats. & Regs. ¶ 31,180, order on reh’g, Order 

No. 2006-A, FERC Stats. & Regs. ¶ 31,196 (2005), order granting clarification, Order 

No. 2006-B, FERC Stats. & Regs. ¶ 31,221 (2006) (Order No. 2006).

2 Small Generator Interconnection Agreements and Procedures, Order No. 792, 

145 FERC ¶ 61,159 (2013), clarified, Order No. 792-A, 146 FERC ¶ 61,214 (2014) 

(Order No. 792).

3

In Order No. 2003, the Commission defined “ride through” to mean a generating 

facility staying connected to and synchronized with the transmission system during 

(continued ...)
Docket No. RM16-8-000 - 2 -

that, given the changes to conditions since the Commission last evaluated whether to 

impose ride through requirements on small generating facilities, the revisions to the pro 

forma SGIA are necessary to remedy undue discrimination by ensuring that small 

generating facilities have ride through requirements comparable to large generating 

facilities.4

2. As a result of this Final Rule, small generating facilities are required to not 

disconnect automatically or instantaneously from the system or equipment of the 

transmission provider and any affected systems for an under-frequency or over-frequency 

condition, or an under-voltage or over-voltage condition. Furthermore, the transmission 

provider must coordinate the small generating facility’s protective equipment settings 

with any automatic load shedding program (e.g., under-frequency load shedding, undervoltage load shedding). The specific ride through settings must be consistent with Good 

Utility Practice and any standards and guidelines applied by the transmission provider to 

other generating facilities on a comparable basis. These requirements will apply to new 

interconnection customers that execute or request the unexecuted filing of an SGIA on or 

 

system disturbances within a range of over- and under-frequency conditions, in 

accordance with Good Utility Practice. Standardization of Generator Interconnection 

Agreements and Procedures, Order No. 2003, FERC Stats. & Regs. ¶ 31,146, at P 562 

n.88 (2003), order on reh’g, Order No. 2003-A, FERC Stats. & Regs. ¶ 31,160, order on 

reh’g, Order No. 2003-B, FERC Stats. & Regs. ¶ 31,171 (2004), order on reh’g, Order 

No. 2003-C, FERC Stats. & Regs. ¶ 31,190 (2005), aff'd sub nom. Nat’l Ass’n of 

Regulatory Util. Comm’rs v. FERC, 475 F.3d 1277 (D.C. Cir. 2007), cert. denied, 552 

U.S. 1230 (2008) (Order No. 2003). Reliability Standard PRC-024-1 requires bulk 

electric system generation to ride through over- and under- voltage conditions.

4 16 U.S.C. 824e.
Docket No. RM16-8-000 - 3 -

after the effective date of this Final Rule. These requirements will also apply to existing 

interconnection customers that, pursuant to a new interconnection request, execute or 

request the unexecuted filing of a new or modified SGIA on or after the effective date of 

this Final Rule.

I. Background

3. The pro forma SGIA establishes the terms and conditions under which public 

utilities must provide interconnection service to small generating facilities of no larger 

than 20 megawatts (MW). Currently, the pro forma SGIA does not mandate that small 

generating facilities have the capability to ride through voltage or frequency disturbances.

4. In Order No. 2006, the Commission explored whether voltage ride through 

requirements proposed for large wind generating facilities should apply to small 

generating facilities.

5

 A commenter during that proceeding asked the Commission to 

implement ride through standards for small generating facilities similar to those proposed 

for large generating facilities. However, other commenters responded that special 

capabilities, such as low voltage ride through, were not needed for any small generating 

facility, whether wind-powered or not. The Commission concluded that wind generating 

facilities interconnecting under Order No. 2006 would be small and would have minimal 

 

5 Order No. 2006, FERC Stats. & Regs. ¶ 31,180 at P 24.
Docket No. RM16-8-000 - 4 -

impact on the transmission provider’s electric system and, therefore, need not be subject 

to ride through requirements.6

5. More recently, the Commission again addressed these requirements with regard to 

small generating facilities in Order No. 792.7 In that proceeding, the Commission 

proposed to revise section 1.5.4 of the pro forma SGIA to address the reliability concern 

related to automatic disconnection of small generating facilities during over- and underfrequency events, which could become a greater concern at high penetrations of 

distributed energy resources.8 The proposed revisions to section 1.5.4 would have 

required the interconnection customer to design, install, maintain, and operate its small 

generating facility, in accordance with the latest version of the applicable standards to 

prevent automatic disconnection during over- and under-frequency events.9

 

6

Id. The penetration of small generating facilities has increased since the 

Commission analyzed the impact of small generating facilities in Order No. 2006. See

infra P 8.

7 Order No. 792, 145 FERC ¶ 61,159.

8 Small Generator Interconnection Agreements and Procedures, Notice of 

Proposed Rulemaking, 142 FERC ¶ 61,049, at P 46 (2013) (Order No. 792 NOPR). 

NERC defines distributed energy resources to mean resources that are distributed 

geographically and not centralized like traditional generation resources. NERC, Essential 

Reliability Services Task Force Measures Report, (Nov. 2015), http://www.nerc.com/co

mm/Other/essntlrlbltysrvcstskfrcDL/ERSTF%20Framework%20Report%20-

%20Final.pdf.

9

Id.
Docket No. RM16-8-000 - 5 -

6. The Commission declined to adopt this proposed revision in Order No. 792.10 

Instead, the Commission recognized that the Institute of Electrical and Electronics 

Engineers (IEEE) was, at the time, in the process of amending IEEE Standard 1547, 

which is an interconnection standard for interconnecting distributed resources with 

electric power systems that is referenced in the Small Generator Interconnection 

Procedures.11 The Commission also noted that IEEE was about to begin a full IEEE 

Standard 1547 revision process in 2014, where frequency and voltage ride through 

requirements in the standard were to be evaluated. The Commission concluded that it 

would continue to monitor the IEEE Standard 1547 revision process and could revise the 

pro forma SGIA as it relates to IEEE Standard 1547 in the future, if necessary.

12

7. Since the Commission issued Order No. 792, IEEE has completed a partial 

revision of IEEE Standard 1547, which is IEEE Standard 1547a. IEEE is now in the 

process of fully revising IEEE Standard 1547. The partially revised standard, IEEE 

Standard 1547a, permits generating facilities to have wider trip settings compared with 

IEEE Standard 1547. These wider trip settings allow generating facilities to stay 

connected to the grid for greater frequency or voltage excursions facilitating their ability 

 

10 Order No. 792, 145 FERC ¶ 61,159 at P 220.

11 Id.

12 Id.
Docket No. RM16-8-000 - 6 -

to ride through such excursions. IEEE Standard 1547a also permits – but does not 

mandate – ride through requirements.13

8. Following the Commission’s evaluation of the need for ride through requirements 

for small generating facilities in the Order Nos. 2006 and 792 rulemaking proceedings, 

the impact of small generating facilities on the grid has changed, and the amount has 

increased. For example, as the North American Electric Reliability Corporation (NERC)

has noted in multiple reports, the mix of generation resources is changing and the high 

penetration of distributed energy resources will impact the reliability of the electric grid if 

sufficient care is not taken to mitigate potential adverse impacts.14 NERC also has found 

that a lack of coordination between small generating facilities and Reliability Standards 

can lead to events where system load imbalance may increase during frequency 

excursions or voltage deviations due to the disconnection of distributed energy resources, 

which may exacerbate a disturbance on the Bulk-Power System.15 In addition, the 

 

13 IEEE Standard 1547a contains “must trip” requirements; it does not have “must 

ride through” requirements. By widening the trip settings, IEEE Standard 1547a permits 

generating facilities to trip at a later time. This change effectively allows generating 

facilities to ride through disturbances, but they are not required to do so.

14 See NERC Special Report, Potential Bulk System Reliability Impacts of 

Distributed Resources (Aug. 2011), http://www.nerc.com/docs/pc/ivgtf/IVGTF_TF-1-

8_Reliability-Impact-Distributed-Resources_Final-Draft_2011.pdf; see also NERC 

Integration of Variable Generation Task Force Draft Report, Performance of Distributed 

Energy Resources During and After System Disturbance (Dec. 2013), 

http://www.nerc.com/comm/PC/Integration%20of%20Variable%20Generation%20Task

%20Force%20I1/IVGTF17_PC_FinalDraft_December_clean.pdf.

15 NERC Essential Reliability Services Report at 21.
Docket No. RM16-8-000 - 7 -

Commission has observed the growth in grid-connected solar photovoltaic generation 

since the issuance of Order No. 2006 and the growth in small generator interconnection 

requests driven by state renewable portfolio standards, reductions in cost for solar panels, 

and deployment of new technologies.

16

 Moreover, technology now available to newly 

interconnecting small generating facilities, such as smart inverters, permits the capability 

to ride through frequency and voltage disturbances.17

II. Notice of Proposed Rulemaking

9. On March 23, 2016, the Commission issued a Notice of Proposed Rulemaking that 

proposed to add new section 1.5.7 to the pro forma SGIA,

18 which would require small 

generating facilities to ride through defined frequency and voltage disturbances. 

10. In response to the NOPR, eleven entities submitted substantive comments, which

generally support the Commission’s proposal.19 These comments have informed our

determinations in this Final Rule.

 

16 See, e.g., Order No. 792, 145 FERC ¶ 61,159 at P 15; Solar Energy Indus. 

Ass’n, Solar Industry Data, http://www.seia.org/research-resources/solar-industry-data 

(last visited Jul. 5, 2016).

17 See Electric Power Research Institute, Recommended Settings for Voltage and 

Frequency Ride Through of Distributed Energy Resources, 28-29 (May 2015), 

http://www.epri.com/abstracts/Pages/ProductAbstract.aspx?ProductId=00000000300200

6203.

18 Requirements for Frequency and Voltage Ride Through Capability of Small 

Generating Facilities, 154 FERC ¶ 61,222 (2016) (NOPR).

19 Appendix A lists the entities that submitted comments and the shortened names 

used throughout this Final Rule to describe those entities.
Docket No. RM16-8-000 - 8 -

III. Discussion

11. For the reasons discussed below, we adopt the NOPR proposal and require small 

generating facilities to ride through abnormal frequency and voltage events comparable 

to large generating facilities. We find that, given the changes to conditions since the 

Commission last evaluated whether to impose ride through requirements on small 

generating facilities, the revisions to the pro forma SGIA are necessary to remedy undue 

discrimination by ensuring that small generating facilities have ride through requirements 

comparable to large generating facilities.20 Specifically, since the Commission’s last 

consideration of this issue, IEEE has revised its standards, and IEEE Standard 1547a now 

provides wider trip settings that allow small generating facilities more leeway to ride 

through disturbances. In addition, distributed energy resources have had an increasing 

presence and impact on the electric system. The absence of ride through requirements for 

small generating facilities increases the risk that an initial voltage or frequency 

disturbance may cause a significant number of small generating facilities to trip across a 

particular area or Interconnection, further exacerbating the initial disturbance. Large 

generating facilities are already subject to ride through requirements to avoid these types 

of occurrences.21

 

20 16 U.S.C. 824e. The Commission routinely evaluates the effectiveness of its 

regulations and policies in light of changing industry conditions to determine if changes 

in these conditions and policies are necessary. See, e.g., Integration of Variable Energy 

Resources, Order No. 764, FERC Stats. & Regs, ¶ 31,331 (2012).

21 See Order No. 2003, FERC Stats. & Regs. ¶ 31,146 at P 562 n.88.
Docket No. RM16-8-000 - 9 -

12. The Commission acknowledges that some areas have a greater penetration of 

distributed resources than others at this time. Nevertheless, the Commission believes that 

the proposed reforms to the pro forma SGIA are appropriate on an industry-wide basis 

now. The Commission continues to affirm that this Final Rule is not intended to interfere 

with state interconnection procedures or agreements in any way. The pro forma SGIA 

applies only to interconnections made subject to a jurisdictional open access transmission 

tariff (OATT) for the purposes of jurisdictional wholesale sales. Similar to the approach 

in Order Nos. 2006 and 792, the Commission hopes that the changes to the pro forma

SGIA resulting from this Final Rule will be helpful to states when updating their own 

interconnection rules, but the states are under no obligation to adopt the provisions of the 

Commission’s proposal.22

A. Revision of the Pro Forma SGIA

1. NOPR Proposal

13. In the NOPR, the Commission proposed to revise the pro forma SGIA to include 

proposed section 1.5.7, which would require interconnection customers to ensure the 

frequency ride through capability and the voltage ride through capability of small 

generating facilities that execute or request the unexecuted filing of interconnection 

agreements following the effective date of the proposed section 1.5.7. Proposed section 

1.5.7 would also require a small generating facility not to disconnect automatically or 

 

22 Order No. 792, 145 FERC ¶ 61,159 at P 27; Order No. 2006, FERC Stats. & 

Regs. ¶ 31,180 at P 8.
Docket No. RM16-8-000 - 10 -

instantaneously from the system or equipment of the transmission provider and any 

affected systems for an under-frequency or over-frequency condition, or an undervoltage or over-voltage condition. In addition, the transmission provider must 

coordinate the small generating facility’s protective equipment settings with any 

automatic load shedding program.

2. Comments

14. The substantive comments filed in response to the NOPR generally support the 

proposal to modify the pro forma SGIA.23 Commenters agree with the need for fair and 

equitable treatment between small and large generating facilities, the need for effective 

protections for system operation while also avoiding increased costs, and the potential to 

improve system stability and reliability over the coming years by adopting the proposed 

modifications to the pro forma SGIA.24 Commenters acknowledge the proposal’s 

benefits, stating it will simplify operational conditions, especially considering the rising 

small generator penetration levels on the distribution system.25 NERC states that 

revising the pro forma SGIA to impose ride through requirements would be consistent 

 

23 Peak Reliability Comments at 3; Idaho Power Comments at 2; PNM Comments 

at 1; SoCal Edison Comments at 2; ISO/RTO Council Comments at 6; Trade 

Associations Comments at 4; Bonneville Comments at 1; EPRI Comments at 7; NERC 

Comments at 2; PG&E Comments at 2.

24 SoCal Edison Comments at 2; Peak Reliability Comments at 3; EPRI Comments 

at 7.

25 PNM Comments at 2; Trade Associations Comments at 7.
Docket No. RM16-8-000 - 11 -

with the results of a number of NERC’s reliability assessments.26 Trade Associations 

and PNM agree that the absence of ride through requirements for small generating 

facilities increases the risk that an initial voltage or frequency disturbance may cause a 

significant number of small generating facilities to trip offline, exacerbating the initial 

disturbance.27 

15. Idaho Power claims that if more small generation facilities connect to its system, 

without the proposed changes to the pro forma SGIA, it would become increasingly 

difficult for it to comply with Reliability Standards PRC-006-2 (Automatic 

Underfrequency Load Shedding) and BAL-003-1.1 (Frequency Response and Frequency 

Bias Setting).

28

 

16. The ISO/RTO Council recommends that the proposed required characteristics for 

small generating facilities should be demonstrated “as tested,” and that this should be 

specified in the pro forma SGIA section 1.5.7. The ISO/RTO Council notes that 

demonstrating characteristics “as tested” is already required under section 24 of the large 

generator interconnection agreement (LGIA). The ISO/RTO Council further explains 

that, while the pro forma SGIA does not presently have such language, the “as tested” 

 

26 NERC Comments at 4.

27 PNM Comments at 2; Trade Associations Comments at 7.

28 Idaho Power Comments at 2.
Docket No. RM16-8-000 - 12 -

requirement applies to small generating facilities pursuant to the directives in Order No. 

2006.29

17. Some commenters request that the Commission delay implementation of the Final 

Rule. While EPRI does not believe that additional action is required for other existing 

interconnected small generating facilities, EPRI comments that additional reliability 

studies may be required if aggregate penetration levels increase sufficiently before the 

modifications to the pro forma SGIA and revised IEEE Standard 1547 become 

effective.30 EPRI notes the need for timely revision and balloting of IEEE Standard 

1547, as well as prompt adoption of the standard.31 Trade Associations suggest waiting 

until after key industry standards are approved and the safety and effectiveness of smart 

inverter technology is validated. 32 Trade Associations request time to allow entities to 

resolve outstanding concerns such as personnel and asset safety, as well as the ability to 

effectively coordinate protections systems between the local utility and interconnecting 

resources.33 EPRI and IEEE assert that relevant stakeholders, including transmission 

owners and transmission operators, should engage with the IEEE Standard 1547 revision 

 

29 ISO/RTO Council Comments at 7 (citing Order No. 2006, FERC Stats. & Regs. 

¶ 31,180 at P 59).

30 EPRI Comments at 7.

31 Id. at 7-8.

32 Trade Associations Comments at 7-8; EPRI Comments at 7-8.

33 Trade Associations Comments at 7-8.
Docket No. RM16-8-000 - 13 -

process to ensure that the final framework and requirements for ride through can be 

consistently applied to meet individual system needs.34

18. Trade Associations claim that the new ride through capability requirements are 

only possible through smart inverter technology, but point out that key associated 

specifications contained in the reference standards remain unapproved. Trade 

Associations explain that distribution feeders are often designed as radial feeders that 

depend on remote generation to quickly disconnect when the utility source is 

disconnected. According to Trade Associations, failure to do so may result in 

unintentional islands which create safety hazards for personnel and customers, as well as 

liability concerns. Trade Associations caution that directing small generation facilities 

to ride through disturbances may create islanding conditions and relaxed response to 

fault conditions.

19. Further, Trade Associations claim that more industry discussion is needed to 

ensure that small generators’ interconnections meet the unique regional utility safety and 

reliability concerns before the proposed revisions to section 1.5.7 of the pro forma SGIA 

are adopted. Trade Associations suggest that the Commission include the issues in this 

proceeding in the three regional technical conferences recommended by Edison Electric 

Institute in Docket No. RM16-6-000.35

 

34 EPRI Comments at 7-8.

35 Trade Associations Comments at 13-14. In Docket No. RM16-6-000, the 

Commission issued a Notice of Inquiry seeking comment on the need for reforms to its 

(continued ...)
Docket No. RM16-8-000 - 14 -

20. Trade Associations also suggest that the Commission explore how changes made 

to the pro forma SGIA often influence state regulations. Trade Associations note that 

distribution level interconnections are broadly supported by industry standards and 

company interconnection rules; and alignment to pro forma SGIA may be inappropriate 

for some state regulations.

36

3. Commission Determination

21. As discussed above, we find the revisions to the pro forma SGIA adopted herein 

are necessary to remedy treatment that is unjust, unreasonable, and unduly 

discriminatory and preferential because there is no technical or economic basis to require 

small and large generating facilities to follow different requirements in regards to 

voltage and frequency ride through. Our revisions will place similar requirements on 

large generating facilities and small generating facilities for ride through capabilities. 

As discussed above, the NOPR proposal received widespread support from commenters. 

Further, the absence of ride through requirements for small generating facilities may 

have adverse impacts on the reliability of the electric grid. We find that the lack of ride 

through requirements for small generating facilities is unduly discriminatory. This is 

due to the increased presence and impact of small generating facilities, including 

distributed energy resources, on the electric system, that could create reliability issues if 

 

rules and regulations regarding the provision and compensation of primary frequency 

response.

36 Trade Associations Comments at 14.
Docket No. RM16-8-000 - 15 -

they do not have the capability to ride through voltage or frequency disturbances. 

Further, improvements in technology, such as smart inverters, make it economically 

feasible for small generating facilities to ride through voltage and frequency 

disturbances. We acknowledge that some areas have a greater penetration of distributed 

resources than others at this time. Nevertheless, we believe that the proposed reforms to 

the pro forma SGIA are appropriate on an industry-wide basis now and that deferred 

action would not be appropriate.

22. We recognize the work of the IEEE 1547 Working Group, but we determine that 

there is a pressing need to establish ride through capability requirements at this time 

because we expect a continuing increase in penetration of small generating facilities. 

The revisions to the pro forma SGIA that we now approve will require the small 

generating facility to implement ride through settings based on a technical standard 

established by the transmission provider.

23. While Trade Associations point out that IEEE is revising IEEE Standard 1547, 

the standard does not currently require ride through capability. We are acting now to 

ensure that all affected jurisdictional small generating facilities will have the ride 

through capability, as allowed by IEEE Standard 1547a.37 

24. We are persuaded by the ISO/RTO Council’s recommendation to add the “as 

tested” language to section 1.5.7 of the pro forma SGIA to harmonize the requirements 

 

37 As we also explained in the NOPR, the Commission’s proposal was not 

intended to impede the ongoing efforts of the IEEE 1547 Working Group, and we 

reiterate that point here. NOPR, 154 FERC ¶ 61,222 at P 8 n.19.
Docket No. RM16-8-000 - 16 -

between the pro forma SGIA and the pro forma LGIA. Pursuant to this “as tested” 

language, the interconnection customer must provide the successfully completed test 

results to the transmission provider in a similar manner as in section 24.4 of the pro 

forma LGIA. We believe that the addition of “as tested” language does not create an 

extra burden on either party to an interconnection agreement because the pro forma

SGIA already includes testing requirements in section 2.1.

38 The “as tested” language 

assures the transmission provider that the required ride through capability can actually 

be performed by the small generating facility.

25. We hereby adopt new section 1.5.7 of the pro forma SGIA showing the changes 

made to the Commission’s proposal in the NOPR as follows:

1.5.7 The Interconnection Customer shall ensure “frequency 

ride through” capability and “voltage ride through” 

capability of its Small Generating Facility. The 

Interconnection Customer shall enable these 

capabilities such that its Small Generating Facility 

shall not disconnect automatically or instantaneously 

from the system or equipment of the Transmission 

Provider and any Affected Systems for a defined 

under-frequency or over-frequency condition, or an 

under-voltage or over-voltage condition, as tested 

pursuant to section 2.1 of this agreement. The defined 

conditions shall be in accordance with Good Utility 

Practice and consistent with any standards and 

guidelines that are applied to other generating facilities 

in the Balancing Authority Area on a comparable 

basis. . . .

 

38 Pro forma SGIA, Section 2.1 “Equipment Test and Inspection.”
Docket No. RM16-8-000 - 17 -

26. We recognize the Trade Associations’ concern about potential tension between 

ride through requirements and anti-islanding protection. Ensuring the safety of utility 

lineworkers is critically important, and an issue the Commission takes seriously. Based 

on our consideration of the record, we believe that the ride through requirements adopted 

herein are technically and safely achievable. In particular, we note that this Final Rule 

provides significant flexibility for transmission providers to account for potential safety 

and islanding concerns. For example, the transmission provider can determine specific 

ride through settings needed to address those concerns so long as those settings are 

consistent with Good Utility Practice and any standards and guidelines applied to other 

generating facilities on a comparable basis.

27. Furthermore, we note that islanding and personnel safety are not new issues 

resulting from this Final Rule; to the contrary, they will continue to be important 

concerns regardless of the reforms adopted in this Final Rule. Accordingly, we 

emphasize the importance of implementing ride through requirements through careful 

coordination between the interconnection customer and the transmission provider, as well 

as the utilization of appropriate safety procedures for utility personnel, particularly 

effective and thorough communication for lineworkers in the field, when performing 

remedial actions following a system disturbance. We support the continued efforts by 

industry to explore innovative ways to detect island conditions in order to mitigate the 

risk of unintentional islands.

28. In light of our goal to prevent undue discrimination, we seek to provide guidelines 

that will be applied to generating facilities on a comparable basis, while allowing for 
Docket No. RM16-8-000 - 18 -

justified differences on a case by case basis. For example, if a transmission provider 

believes a particular facility has a higher risk of unintentional islanding due to specific 

conditions on that facility, the revisions to the pro forma SGIA will permit the 

transmission provider to coordinate with the small generating facility to set ride through 

settings appropriate for those conditions, in accordance with Good Utility Practice and 

the appropriate technical standards. For facilities with a lower risk of forming an 

unintentional island, the transmission provider can implement a longer ride through 

requirement, in accordance with Good Utility Practice and the appropriate technical 

standards. We believe that the flexibility provided by section 1.5.7 allows for appropriate 

ride through requirements while recognizing the need to address any safety concerns.

B. Referencing Specific Technical Standards

1. NOPR Proposal

29. In the NOPR, the Commission proposed to avoid prescriptive frequency and 

voltage ride through requirements to allow for the development of appropriate systemspecific standards, noting that the standards can be based on work developed by 

recognized standards settings bodies, such as IEEE.

2. Comments

30. Commenters request that the proposed rule contain explicit references to 

standards such as the Reliability Standards and IEEE and UL standards.39 The ISO/RTO 

Council states that Reliability Standards already provide requirements for coordination 

 

39 ISO/RTO Council Comments at 7.
Docket No. RM16-8-000 - 19 -

of automatic under-frequency generator tripping with automatic under-frequency load 

shedding programs that should be incorporated in the new ride through requirements. 

The ISO/RTO Council suggests that the pro forma SGIA explicitly reference Reliability 

Standard PRC-024 (Generator Frequency and Voltage Protective Relay Settings) and 

applicable regional Reliability Standards as part of the definition of “Good Utility 

Practice” and for the coordination of automatic generator tripping with automatic load 

shedding.

40

 The ISO/RTO Council also recommends that the pro forma SGIA refer to 

the Reliability Standards and regional Reliability Standards for coordination of 

automatic generator tripping with automatic load shedding, and as appropriate, permit 

individual transmission providers to also reference their automatic load-shed program.

31. Commenters assert that specifying certain technical standards would be beneficial 

for consistent enforceability; specifically, some commenters suggest that the pro forma

SGIA reference IEEE and UL 1741 standards to describe “Good Utility Practice.”41

EPRI and IEEE comment that failure to harmonize ride through requirements with the 

proposed draft IEEE 1547 requirements may introduce confusion and ultimately delay 

testing and compliance, exposing the electric system to an increased reliability risk.42 

PNM recognizes that there are challenges to developing specific settings applicable to 

 

40 Id. at 6-7.

41 PNM Comments at 3; EPRI Comments at 13; IEEE Comments at 2.

42 EPRI Comments at 13; IEEE Comments at 2.
Docket No. RM16-8-000 - 20 -

all small generating facilities.43 However, PNM states that the Commission should still 

consider documenting some ride through expectation similar to those outlined in the 

LGIA requirements. PNM requests that the pro forma SGIA revisions consider a 

minimum ride through duration based on fault clearing times and a minimum voltage.

PNM also requests that the Commission specify the location where the frequency and 

voltage measurements are taken to comply with the requirements, such as the point of 

interconnection.

32. SoCal Edison observes that the California Public Utilities Commission (CPUC) 

has established, through its retail Rule 21 tariff, smart inverter requirements for small 

generators interconnecting to the distribution systems of California’s investor owned 

utilities, and low/high voltage ride through and low/high frequency ride through are part 

of the new required capabilities for small generators.44 SoCal Edison explains that the 

CPUC ordered all investor owned utilities “to seek approval as may be needed for 

conforming changes to harmonize their federal wholesale Tariffs interconnection 

specifications with the revisions to Electric Tariff Rule 21.”45

3. Commission Determination

33. We are not persuaded by commenters’ arguments for the need to reference 

specific technical standards and decline to incorporate by reference any specific standard 

 

43 PNM Comments at 2.

44 SoCal Edison Comments at 3.

45 Id.
Docket No. RM16-8-000 - 21 -

into the pro forma SGIA or to specify ride through duration and voltage and frequency 

levels. We therefore decline to modify the NOPR proposal in this regard.

34. To accommodate the differences in voltage and frequency ride through 

capabilities inherent in the different generation technologies, we believe that requiring 

basic performance expectations without explicitly specifying the duration or voltage and 

frequency levels allows the flexibility to apply appropriate ride through settings with 

coordination and approval of the transmission operator. As EPRI and IEEE note, the 

ride through requirement framework in the draft IEEE Standard 1547 is being structured 

along “performance categories” that take into account the technological differences of 

various types of small generating facilities. Once finalized, IEEE Standard 1547 may be 

used as a technical guide to meet the requirements adopted herein. Until revisions to 

IEEE Standard 1547 are finalized, however, transmission providers and affected 

interconnection customers must coordinate appropriate alternative frequency and voltage 

ride through settings.

35. Furthermore, as a pragmatic matter, by setting minimum ride through capability 

requirements that are not tied to a specific standard, the requirements in section 1.5.7 of 

the pro forma SGIA would remain applicable following any updates from IEEE 

Standard 1547 or other applicable standards, without having to modify the pro forma

SGIA each time any such standard is updated.

36. In response to PNM’s clarification request, we clarify that the point of 

interconnection is the appropriate place to measure frequency and voltage to comply 

with the ride through requirements. 
Docket No. RM16-8-000 - 22 -

C. Regional Differences 

1. NOPR Proposal

37. The Commission proposed to permit RTOs and ISOs to seek “independent entity 

variations” from the proposed revisions to the pro forma SGIA.

2. Comments

38. Multiple commenters support the Commission’s proposal to permit RTOs and 

ISOs to seek “independent entity variations” from the proposed revisions to the pro 

forma SGIA.46

39. Trade Associations request that the Commission also affirm the ability of 

transmission providers that are not members of RTOs or ISOs to seek variations from 

the pro forma SGIA to ensure consistency with regional reliability requirements. Trade 

Associations explain that differences in resource penetration and configuration (such as 

state renewable portfolio standards or wind generation in remote locations) have led to 

regional reliability requirements. Trade Associations note that the Commission 

recognized in Order No. 2003 that such regional reliability requirements might justify 

variations to pro forma interconnection agreements and procedures.47 SoCal Edison 

believes that, to the extent that some regions may need additional time to implement the 

 

46 Trade Associations Comments at 12-13; SoCal Edison Comments at 4; 

ISO/RTO Council Comments at 6.

47 Trade Associations Comments at 12-13.
Docket No. RM16-8-000 - 23 -

proposed ride through requirements on small generating facilities, the Commission 

should grant such time.48

3. Commission Determination

40. We adopt the NOPR proposal and permit ISOs and RTOs to seek “independent 

entity variations” from revisions to the pro forma SGIA.49 Also, as proposed in the 

NOPR, if a transmission provider seeks a deviation from section 1.5.7 of the pro forma

SGIA, it must demonstrate that the deviation is consistent with or superior to the 

principles set forth in this Final Rule.

41. In addition, we clarify that we will also consider requests for “regional reliability 

variations,” provided that such requests are supported by references to regional 

Reliability Standards, explain why these regional Reliability Standards support the 

requested variation, and include the text of the referenced Reliability Standards.

50

 While 

some regions currently have greater penetration of small generation facilities than others, 

we are acting now to set a national minimum ride through capability before future 

increases in deployment of small generation facilities.

 

48 SoCal Edison Comments at 4.

49 See Order No. 792, 145 FERC ¶ 61,159 at P 274 (citing Order No. 2003, FERC 

Stats. & Regs. ¶ 31,146 at PP 822-827).

50 See id. P 273 (citing Order No. 2006, FERC Stats. & Regs. ¶ 31,180 at P 546).
Docket No. RM16-8-000 - 24 -

IV. Compliance and Implementation

42. Section 35.28(f)(1) of the Commission’s regulations requires every public utility 

with a non-discriminatory open access transmission tariff OATT on file to also have an 

SGIA on file with the Commission.51

43. We reiterate that the requirements of this Final Rule apply to all newly 

interconnecting small generating facilities that execute or request the unexecuted filing of

an SGIA on or after the effective date of this Final Rule as well as existing 

interconnection customers that, pursuant to a new interconnection request, execute or 

request the unexecuted filing of a new or modified SGIA on or after the effective date.

44. We require each public utility transmission provider that has an SGIA within its 

OATT to submit a compliance filing within 65 days following publication in the Federal 

Register.52 The compliance filing must demonstrate that it meets the requirements set 

forth in this proposal.

45. The Commission recently issued Order No. 827, a final rule in Docket No. RM16-

1-000, directing transmission providers to submit SGIA revisions related to reactive 

 

51 18 CFR 35.28(f)(1).

52 For purposes of this Final Rule, a public utility is a utility that owns, controls, or 

operates facilities used for transmitting electric energy in interstate commerce, as defined 

by the FPA. See 16 U.S.C. 824(e). A non-public utility that seeks voluntary compliance 

with the reciprocity condition of an OATT may satisfy that condition by filing an OATT, 

which includes an SGIA.
Docket No. RM16-8-000 - 25 -

power requirements to the Commission.53 Those compliance filings are due to the 

Commission on September 21, 2016. To facilitate administrative efficiency, we will 

require the compliance filings for this Final Rule and Order No. 827 to be filed in one 

combined filing. Once this Final Rule is published in the Federal Register, the 

Commission will provide a short extension to the compliance dates in both proceedings 

such that the compliance dates are the same.

46. As discussed above, we are not requiring changes to interconnection agreements 

that were executed prior to the effective date of this Final Rule. Instead, the requirements 

of this Final Rule apply to newly interconnecting small generating facilities that execute 

or request the unexecuted filing of an interconnection agreement on or after the effective 

date. The requirements of this Final Rule also apply to existing small generating 

facilities that, pursuant to a new interconnection request, require new or modified 

interconnection agreements that are executed or requested to be filed unexecuted on or 

after the effective date.

47. Some public utility transmission providers may have provisions in their existing 

SGIAs or other document(s) subject to the Commission’s jurisdiction that the 

Commission has deemed to be consistent with or superior to the pro forma SGIA or are 

permissible under the independent entity variation standard or regional reliability 

 

53 Reactive Power Requirements for Non-Synchronous Generation, Order No. 827, 

81 Fed. Reg. 40,793 (Jun. 23, 2016), 155 FERC ¶ 61,277 (2016).
Docket No. RM16-8-000 - 26 -

standard.54 Where these provisions would be modified by this Final Rule, public utility 

transmission providers must either comply with this Final Rule or demonstrate that these 

previously-approved variations continue to be consistent with or superior to the pro 

forma SGIA as modified by this Final Rule or continue to be permissible under the 

independent entity variation standard or regional reliability standard.

55

48. We find that transmission providers that are not public utilities must adopt the 

requirements of this Final Rule as a condition of maintaining the status of their safe 

harbor tariff or otherwise satisfying the reciprocity requirement of Order No. 888.56

V. Information Collection Statement

49. The following collection of information contained in this Final Rule is subject to

review by the Office of Management and Budget (OMB) regulations under section 

3507(d) of the Paperwork Reduction Act of 1995.57 OMB’s regulations require approval 

 

54 See Order No. 792, 145 FERC ¶ 61,159 at P 270.

55 See 18 CFR 35.28(f)(1)(i).

56 Promoting Wholesale Competition Through Open Access Non-Discriminatory 

Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities 

and Transmitting Utilities, Order No. 888, FERC Stats. & Regs. ¶ 31,036, at 31,760-63 

(1996), order on reh’g, Order No. 888-A, FERC Stats. & Regs. ¶ 31,048, order on reh’g, 

Order No. 888-B, 81 FERC ¶ 61,248 (1997), order on reh’g, Order No. 888-C, 82 FERC 

¶ 61,046 (1998), aff’d in relevant part sub nom. Transmission Access Policy Study Group 

v. FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New York v. FERC, 535 U.S. 1 

(2002).

57 44 U.S.C. 3507(d).
Docket No. RM16-8-000 - 27 -

of certain information collection requirements imposed by agency rules.58 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 Final Rule will 

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

collection of information displays a valid OMB control number.

50. The reforms adopted in this Final Rule revise the Commission’s pro forma SGIA 

in accordance with section 35.28(f)(1) of the Commission’s regulations.59 This Final 

Rule applies to all newly interconnecting small generating facilities that execute or 

request the unexecuted filing of an SGIA on or after the effective date of this Final Rule 

as well as existing interconnection customers that, pursuant to a new interconnection 

request, execute or request the unexecuted filing of a new or modified SGIA on or after 

the effective date, to ensure frequency ride through capability and voltage ride through 

capability in accordance with good utility practice and consistent with any standards and 

guidelines that are applied to other generating facilities in the balancing authority area on 

a comparable basis. The reforms adopted in this Final Rule would require filings of 

SGIAs with the Commission. The Commission anticipates the revisions required by this 

Final Rule, once implemented, will not significantly change existing burdens on an 

ongoing basis. With regard to those public utility transmission providers that believe that 

they already comply with the revisions adopted in this Final Rule, they can demonstrate 

 

58 5 CFR 1320.11.

59 18 CFR 35.28(f)(1).
Docket No. RM16-8-000 - 28 -

their compliance in the filing required 65 days after the effective date of this Final Rule. 

The Commission will submit the proposed reporting requirements to OMB for its review 

and approval under section 3507(d) of the Paperwork Reduction Act.60

51. While the Commission expects the revisions adopted in this Final Rule will 

provide significant benefits, the Commission understands that implementation would 

entail some costs. The Commission solicited comments on the accuracy of provided 

burden and cost estimates and any suggested methods for minimizing the respondents’ 

burdens. The Commission did not receive any comments concerning its burden or cost 

estimates. As explained above, we will require the compliance filings for this Final Rule 

and Order No. 827 to be filed in one combined filing. We expect that this will reduce the 

burden on public utility transmission providers at the time the Commission gives notice 

of the extension of the compliance date and requirement to combine compliance filings.

Burden Estimate: The Commission believes that the burden estimates below are 

representative of the average burden on respondents. The estimated burden and cost for 

the requirements adopted in this Final Rule follow.61

 

60 44 U.S.C. 3507(d).

61 Commission staff estimates that industry is similarly situated in terms of hourly 

cost (wages plus benefits). Based on the Commission 2016 average cost (wages plus 

benefits), $74.50/hour is used.
Docket No. RM16-8-000 - 29 -

FERC 516A revisions in RM16-8

No. of 

Respondents62

(1)

Annual No. 

of 

Responses 

per 

Respondent

(2)

Total No. 

of 

Responses 

(1)*(2)=(3)

Average 

Burden 

(Hrs.) & 

Cost ($) 

Per 

Response

(4)

Total 

Annual 

Burden Hrs. 

& Total 

Annual Cost 

($)

(3)*(4)=(5)

Conforming 

SGIA

changes to 

incorporate 

revisions 118 1 118

7.5 hrs.; 

$558.75

885 hrs.;

$65,932.50

Total

118

7.5 hrs.; 

$558.75

885 hrs.;

$65,932.50

Cost to Comply: The Commission has projected the additional cost of compliance as 

follows:63

 Year 1: $65,932.50 for all affected entities ($558.75/utility)

 Year 2 and subsequent years: $0

After implementation in Year 1, the reforms proposed in this Final Rule would be 

complete.

Title: FERC-516A, Standardization of Small Generator Interconnection Agreements and 

Procedures.

 

62 Number of Applicable Registered Entities.

63 The costs for Year 1 would consist of filing proposed changes to the pro forma

SGIA with the Commission within 65 days of the effective date of the final revision plus 

initial implementation. The Commission does not expect any ongoing costs beyond the 

initial compliance in Year 1.
Docket No. RM16-8-000 - 30 -

Action: Revision of currently approved collection of information.

OMB Control No.: 1902-0203

Respondents for this Rulemaking: Businesses or other for profit and/or not-for-profit 

institutions.

Frequency of Information: One-time during Year 1.

Necessity of Information: The Commission adopts changes to the pro forma SGIA in 

order to more efficiently and cost-effectively interconnect generating facilities no larger 

than 20 MW (small generating facilities) to Commission-jurisdictional transmission 

systems. The purpose of this Final Rule is to revise the pro forma SGIA so small 

generating facilities can be reliably and efficiently integrated into the electric grid and to 

ensure that Commission-jurisdictional services are provided at rates, terms and conditions 

that are just and reasonable and not unduly discriminatory or preferential. This Final 

Rule seeks to achieve this goal by amending the pro forma SGIA to include new section 

1.5.7.

Internal Review: The Commission has reviewed the changes and has determined that the 

changes are necessary. These requirements conform to the Commission’s need 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 

collection requirements.
Docket No. RM16-8-000 - 31 -

52. 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.

53. Comments on the collection of information and the associated burden estimate in 

the Final Rule should be sent to the Commission in this docket and may also be sent to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 

725 17th Street, NW, Washington, DC 20503 [Attention: Desk Officer for the Federal 

Energy Regulatory Commission], at the following e-mail address: 

oira_submission@omb.eop.gov. Please reference OMB Control No. 1902-0203 and the 

docket number of this rulemaking in your submission.

VI. Regulatory Flexibility Act

54. The Regulatory Flexibility Act of 1980 (RFA)64 generally requires a description 

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

of small entities. The RFA does not mandate any particular outcome in a rulemaking. It 

only requires consideration of alternatives that are less burdensome to small entities and 

an agency explanation of why alternatives were rejected.

55. The Small Business Administration (SBA) revised its size standards (effective 

January 22, 2014) for electric utilities from a standard based on megawatt hours to a 

standard based on the number of employees, including affiliates. Under SBA’s 

 

64 5 U.S.C. 601-612.
Docket No. RM16-8-000 - 32 -

standards, some transmission owners will fall under the following category and 

associated size threshold: electric bulk power transmission and control, at 500 

employees.65

56. The Commission estimates that the total number of public utility transmission 

providers that would have to modify the SGIAs within their currently effective OATTs is 

118. Of these, the Commission estimates that approximately 43% are small entities. The 

Commission estimates the average cost to each of these entities will be minimal, 

requiring on average 7.5 hours or $558.75. According to SBA guidance, the 

determination of significance of impact “should be seen as relative to the size of the 

business, the size of the competitor’s business, and the impact the regulation has on larger 

competitors.”66 The Commission does not consider the estimated burden to be a 

significant economic impact. As a result, the Commission certifies that the reforms 

adopted in this Final Rule would not have a significant economic impact on a substantial 

number of small entities.

VII. Environmental Analysis

57. The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 

 

65 13 CFR 121.201, Sector 22 (Utilities), NAICS code 221121 (Electric Bulk 

Power Transmission and Control).

66 U. S. Small Business Administration, A Guide for Government Agencies How to 

Comply with the Regulatory Flexibility Act, at 18 (May 2012), https://www.sba.gov/sites/

default/files/advocacy/rfaguide_0512_0.pdf.
Docket No. RM16-8-000 - 33 -

on the human environment.67 As we stated in the NOPR, the Commission concludes that 

neither an Environmental Assessment nor an Environmental Impact Statement is required 

for the revisions adopted in this Final Rule under section 380.4(a)(15) of the 

Commission’s regulations, which provides a categorical exemption for approval of 

actions under sections 205 and 206 of the FPA relating to the filing of schedules 

containing all rates and charges for the transmission or sale of electric energy subject to 

the Commission’s jurisdiction, plus the classification, practices, contracts and regulations 

that affect rates, charges, classifications, and services.68 The revisions adopted in this 

Final Rule would update and clarify the application of the Commission’s standard 

interconnection requirements to small generating facilities. 

58. Therefore, this Final Rule falls within the categorical exemptions provided in the 

Commission’s regulations, and as a result neither an Environmental Impact Statement 

nor an Environmental Assessment is required.

VIII. Document Availability

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

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

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

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

 

67 Regulations Implementing National Environmental Policy Act, Order No. 486, 

FERC Stats. & Regs. ¶ 30,783 (1987).

68 18 CFR 380.4(a)(15).
Docket No. RM16-8-000 - 34 -

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

Washington, DC 20426.

60. From the Commission’s Home Page on the Internet, this information is available 

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

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

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

digits, in the docket number field.

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

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

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

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

public.referenceroom@ferc.gov.

IX. Effective Date and Congressional Notification

62. The Final Rule is effective [INSERT DATE 65 days from publication in 

FEDERAL REGISTER]. However, as noted above, the requirements of this Final Rule 

will apply only to all newly interconnecting small generating facilities that execute or 

request the unexecuted filing of an SGIA on or after the effective date of this Final Rule 

as well as existing interconnection customers that, pursuant to a new interconnection 

request, execute or request the unexecuted filing of a new or modified SGIA on or after 

the effective date. The Commission has determined, with the concurrence of the 

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

Final Rule is not a “major rule” as defined in section 351 of the Small Business 
Docket No. RM16-8-000 - 35 -

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

Senate, House, Government Accountability Office, and Small Business Administration.

By the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.
Docket No. RM16-8-000 - 36 -

Appendix A

List of Substantive Commenters (RM16-8-000)

Bonneville Bonneville Power Administration

Trade Associations Edison Electric Institute/American Public Power 

Association/Large Public Power Council /National 

Rural Electric Cooperative Association

EPRI Electric Power Research Institute

Idaho Power Idaho Power Company

IEEE Institute of Electrical and Electronics Engineers

ISO/RTO Council ISO/RTO Council

NERC North American Electric Reliability Corporation

PG&E Pacific Gas and Electric Company

Peak Reliability Peak Reliability

PNM Public Service Company of New Mexico

SoCal Edison Southern California Edison Company

In addition, Entergy Services, Inc. submitted non-substantive comments.