172 FERC ¶ 61,225

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket Nos. RM19-16-000 and RM19-17-000; Order No. 873]

Electric Reliability Organization Proposal to Retire

Requirements in Reliability Standards Under the NERC Standards Efficiency Review

(Issued September 17, 2020)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Final rule.

SUMMARY: The Federal Energy Regulatory Commission (Commission) approves the 

retirement of 18 Reliability Standard requirements identified by the North American 

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

Organization. The Commission also remands proposed Reliability Standard FAC-008-4 

for further consideration by NERC. The Commission takes no action at this time on the 

proposed retirement of 56 MOD A Reliability Standard requirements.

DATES: This rule will become effective [INSERT DATE 60 days after date of 

publication in the FEDERAL REGISTER].

FOR FURTHER INFORMATION CONTACT:

Michael Gandolfo (Technical Information)

Office of Electric Reliability, Division of Reliability Standards and Security

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-6817
Docket Nos. RM19-16-000 and RM19-17-000 - 2 -

Mark Bennett (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE 

Washington, DC 20426

Telephone: (202) 502-8524

SUPPLEMENTARY INFORMATION
172 FERC ¶ 61,225

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Neil Chatterjee, Chairman;

 Richard Glick and James P. Danly.

Electric Reliability Organization Proposal to Retire

Requirements in Reliability Standards Under the NERC 

Standards Efficiency Review

Docket Nos. RM19-16-000

RM19-17-000

ORDER NO. 873

FINAL RULE

(Issued September 17, 2020)

1. Pursuant to section 215(d)(2) of the Federal Power Act (FPA),1 the Commission 

approves 18 of the 76 Reliability Standard requirements requested for retirement by the 

North American Electric Reliability Corporation (NERC).

2

 For the reasons discussed 

below, we determine that the retirement of the 18 Reliability Standard requirements 

through the retirement of four Reliability Standards and the modification of five

Reliability Standards is just, reasonable, not unduly discriminatory or preferential, and in 

the public interest.3

 The Commission also approves the associated violation risk factors, 

violation severity levels, implementation plan, and effective dates proposed by NERC.

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

2 NERC withdrew the originally requested retirement of Reliability Standard 

VAR-001-6, Requirement R2 on May 14, 2020.

3 The four Reliability Standards being eliminated in their entirety are Reliability 

Standards FAC-013-2 (Assessment of Transfer Capability for the Near-term 
Docket Nos. RM19-16-000 and RM19-17-000 - 2 -

2. As set forth in the petitions, we conclude that the 18 Reliability Standard 

requirements: (1) provide little or no reliability benefit; (2) are administrative in nature 

or relate expressly to commercial or business practices; or (3) are redundant with other 

Reliability Standards. These justifications are consistent with the Commission-approved 

rationale for retiring Reliability Standard requirements articulated in prior proceedings.4

 

3. The approved retirements will enhance the efficiency of the Reliability Standards 

program by reducing duplicative or otherwise unnecessary regulatory burdens. 

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

approve the retirement of 56 requirements constituting the so-called MOD A Reliability 

Standards.5

 The NOPR indicated that, if approved, the Commission intends to coordinate 

Transmission Planning Horizon), INT-004-3.1 (Dynamic Transfers), INT-010-2.1 

(Interchange Initiation and Modification for Reliability), MOD-020-0 (Providing 

Interruptible Demands and Direct Control Load Management Data to System 

Operations and Reliability Coordinators). The five modified Reliability Standards 

approved herein are Reliability Standards INT-006-5 (Evaluation of Interchange 

Transactions), INT-009-3 (Implementation of Interchange) and PRC-004-6 (Protection 

System Misoperation Identification and Correction), IRO-002-7 (Reliability 

Coordination—Monitoring and Analysis), TOP-001-5 (Transmission Operations).

4 North American Electric Reliability Corp., 138 FERC ¶ 61,193, at P 81 

(March 2012 Order), order on reh’g and clarification, 139 FERC ¶ 61,168 (2012); 

Electric Reliability Organization Proposal to Retire Requirements in Reliability 

Standards, Order No. 788, 145 FERC ¶ 61,147, at P 1 (2013) (stating that the proposed 

retirements “meet the benchmarks set forth in the Commission’s March 15, 2012 Order”). 

5 Electric Reliability Organization Proposal to Retire Requirements in Reliability 

Standards Under the NERC Standards Efficiency Review, 170 FERC ¶ 61,032 (2020)

(NOPR). The MOD A Reliability Standards proposed for retirement are MOD-001-1a 

(Available Transmission System Capability), MOD-004-1 (Capacity Benefit Margin), 

MOD-008-1 (Transmission Reliability Margin Calculation Methodology), MOD-028-2 
Docket Nos. RM19-16-000 and RM19-17-000 - 3 -

the effective dates for the retirement of the MOD A Reliability Standards with successor 

North American Energy Standards Board (NAESB) business practice standards.6

 On 

March 30, 2020, NAESB submitted Version 003.3 of the Standards for Business 

Practices and Communication Protocols for Public Utilities that, inter alia, include 

Modeling business practices. On July 16, 2020, the Commission issued a NOPR in 

Docket Nos. RM05-5-029 and RM05-5-030 proposing to amend its regulations to 

incorporate by reference, with certain enumerated exceptions, NAESB’s Version 003.3 

Business Practices.

7

 Comments on the NAESB NOPR are due on November 3, 2020.8 

In light of these developments, this final rule does not address the retirement of the 

MOD A Reliability Standards. The Commission will determine the appropriate action 

regarding the proposed retirement of the MOD A Reliability Standards at a later time.

5. While the Commission approves the 18 retirements, pursuant to FPA 

section 215(d)(4), we remand proposed Reliability Standard FAC-008-4.9

 As discussed 

below, we are satisfied with NERC’s justification for retiring Reliability Standard 

(Area Interchange Methodology), MOD-029-2a (Rated System Path Methodology), and 

MOD-030-3 (Flowgate Methodology).

6 NOPR, 170 FERC ¶ 61,032, at P 21, n.35.

7 Standards for Business Practices and Communication Protocols for Public 

Utilities, Notice of Proposed Rulemaking, Order No. 676, 85 FR 10571, 172 FERC 

¶ 61,047 (2020).

8 Standards for Business Practices and Communication Protocols for Public 

Utilities, 85 Fed. Reg. 55201 (September 4, 2020).

9 16 U.S.C. 824o(d)(4).
Docket Nos. RM19-16-000 and RM19-17-000 - 4 -

FAC-008-3, Requirement R7. However, for the reasons discussed below, we are not

persuaded that it is appropriate to retire Reliability Standard FAC-008-3, 

Requirement R8. Because the Commission, pursuant to FPA section 215(d)(4), must 

remand to NERC for further consideration a proposed modification to a Reliability 

Standard that the Commission disapproves in whole or in part, we remand proposed 

Reliability Standard FAC-008-4 to address our concerns with the retirement of 

Requirement R8. 

I. Background

A. Section 215 of the FPA

6. Section 215 of the FPA requires the Commission-certified Electric Reliability 

Organization (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.10 Pursuant to the requirements of FPA section 215, the 

Commission established a process to select and certify an ERO11 and, subsequently, 

certified NERC as the ERO.12

10 16 U.S.C. 824o(e)(3). 

11 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). 

12 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).
Docket Nos. RM19-16-000 and RM19-17-000 - 5 -

B. Prior Retirements of Reliability Standard Requirements

7. In the March 2012 Order, the Commission observed that NERC’s compliance 

program could be made more efficient by removing existing requirements deemed 

unnecessary for reliability.13 The Commission stated that if NERC believes certain 

Reliability Standards or requirements should be revised or removed, “we invite NERC to 

make specific proposals to the Commission identifying the Standards or requirements and 

setting forth in detail the technical basis for its belief.”14 Further, the Commission 

encouraged NERC “to propose appropriate mechanisms to identify and remove from the 

Commission-approved Reliability Standards unnecessary or redundant requirements.”15

8. In response, in February 2013, NERC proposed to retire 34 requirements within 

19 Reliability Standards based on the justification that the requirements “are redundant or 

otherwise unnecessary” and that “violations of these requirements . . . pose a lesser risk to 

the reliability of the Bulk-Power System.”16 NERC explained that the proposed 

retirements were based upon three major criteria: (1) whether a proposed retirement 

would create a reliability gap; (2) whether the requirement in question is administrative; 

involves data collection, retention, documentation, periodic updates or reporting; is a 

commercial or business practice; or is redundant; and (3) consideration of responses to 

13 March 2012 Order, 138 FERC ¶ 61,193 at P 81.

14 Id.

15 Id.

16 NERC, Petition, Docket No. RM13-8-000, at 2 (filed Feb. 28, 2013).
Docket Nos. RM19-16-000 and RM19-17-000 - 6 -

seven questions regarding the proposed retirement, including whether the requirement 

was part of a “find, fix and track” filing, the requirement’s violation risk factor level, and 

whether the requirement is part of on-going standards development project.

17

9. On November 21, 2013, the Commission approved the retirements that NERC 

proposed, and determined that the retirements “meet the benchmarks” set forth in the 

March 2012 Order that “requirements proposed for retirement either: (1) provide little 

protection for Bulk-Power System reliability; or (2) are redundant with other aspects of 

the Reliability Standards.”18 

C. NERC Standards Efficiency Review Project and Petitions

1. NERC Standards Efficiency Review Project

10. NERC states that the proposed retirements are the product of its Standards 

Efficiency Review (SER) Project. NERC explains that the SER Project began in 2017 

“to achieve [NERC’s] long-term strategic goal of establishing risk-based controls to 

minimize [Bulk-Power System] reliability risk while also driving operational efficiencies 

and effectiveness.”19 NERC states that in Phase 1 of the SER Project, teams of industry 

experts conducted a risk-based analysis of non-CIP Reliability Standards.

20 The purpose 

17 Id. at 4.

18 Electric Reliability Organization Proposal to Retire Requirements in Reliability 

Standards, Order No. 788, 145 FERC ¶ 61,147 (2013). 

19 Docket No. RM19-16-000 Petition at 3; Docket No. RM19-17-000 Petition at 4.

20 NERC states that Phase 2 of the SER Project will “consider recommendations 

for Reliability Standard revisions that would further improve the efficiency of the body of 

NERC Reliability Standards, such as through consolidation of Reliability Standard 

requirements . . . [and will] consider recommendations for standards-based improvements 
Docket Nos. RM19-16-000 and RM19-17-000 - 7 -

of this review, according to NERC, was “to identify Reliability Standard requirements 

that provide little or no benefit to reliability and should be retired.”21 NERC maintains 

that, unlike the periodic reviews22 of Reliability Standards performed by NERC pursuant 

to the NERC Rules of Procedure, the SER Project involved “exploring the relationships 

between the different Reliability Standards in a deeper way than would be feasible during 

a targeted periodic review . . . [and] allowed NERC to identify requirements that are not 

necessary for reliability or that are redundant to other requirements.”23

11. NERC contends that the SER Project “was conducted in an open and transparent 

manner, with broad industry participation.”24 NERC states that it initiated the standards 

development process to consider the retirement recommendations generated by the SER 

Project.

that would further reduce inefficiencies and promote effectiveness.” Docket 

No. RM19-16-000 Petition at 6-7; Docket No. RM19-17-000 Petition at 7.

21 Docket No. RM19-16-000 Petition at 5; Docket No. RM19-17-000 Petition at 6.

22 The NERC Rules of Procedure require a periodic review of each Reliability 

Standard; and they provide for a five-year cyclical review of Reliability Standards 

approved by the American National Standards Institute (ANSI) and 10-year cyclical 

review for Reliability Standards not approved by ANSI. See NERC Rules of Procedure, 

Section 317 and Appendix 3A (Standards Process Manual), section 13.0.

23 Docket No. RM19-16-000 Petition at 5; Docket No. RM19-17-000 Petition at 6.

24 Docket No. RM19-16-000 Petition at 5-6; Docket No. RM19-17-000 Petition 

at 7.
Docket Nos. RM19-16-000 and RM19-17-000 - 8 -

2. IRO, TOP and VAR Petition (Docket No. RM19-16-000)

12. On June 7, 2019, in Docket No. RM19-16-000, NERC submitted for Commission 

approval new versions of three Reliability Standards: IRO-002-7 (Reliability 

Coordination—Monitoring and Analysis), TOP-001-5 (Transmission Operations), and 

VAR-001-6 (Voltage and Reactive Control). 25 NERC explains that approval of the new 

versions would result in the retirement of four requirements from the currently-effective 

versions of the Reliability Standards.

26 NERC proposes to retire three of the existing 

requirements in Reliability Standards IRO-002 and TOP-001 that require the reliability 

coordinator, transmission operator, and balancing authority to have data exchange 

capabilities with entities having data needed to perform operational planning analyses 

and to develop operating plans for next-day operations. NERC contends that these 

requirements are redundant and not necessary “because the performance required by 

these requirements is inherent to the performance of other Reliability Standard 

requirements.”27 

13. In particular, NERC maintains that the data exchange capability requirement 

in Reliability Standard IRO-002-5, Requirement R1 is covered by Reliability 

25 On May 14, 2020, NERC withdrew its request to retire Reliability Standard 

VAR-001-6, Requirement R2.

26 The revised versions of the IRO and TOP Reliability Standards are not attached 

to this final rule. The complete text of the Reliability Standards is available on the 

Commission’s eLibrary document retrieval system in Docket No. RM19-16-000 and is 

posted on the ERO’s website, http://www.nerc.com.

27 Docket No. RM19-16-000 Petition at 7.
Docket Nos. RM19-16-000 and RM19-17-000 - 9 -

Standard IRO-008-2, Requirement R1, which obligates the reliability coordinator to 

perform operational planning analyses to assess whether the planned operations for the 

next-day will exceed System Operating Limits and Interconnection Reliability Operating 

Limits within its Wide Area. NERC asserts that “to perform the required operational

planning analyses, the Reliability Coordinator must have the data it deems necessary 

from those entities that possess it.”28

14. Additionally, regarding data exchange, NERC cites Reliability Standard 

IRO-010-2 (Reliability Coordinator Data Specification and Collection) and its stated 

purpose of preventing instability, uncontrolled separation, or cascading outages “by 

ensuring the Reliability Coordinator has the data it needs to monitor and assess the 

operation of its Reliability Coordinator Area.”29 NERC states that under Reliability 

Standard IRO-010-2, Requirements R1, R2 and R3, the reliability coordinator must 

specify the data necessary for it to perform its operational planning analyses and provide 

the specifications to the entities from which it needs data who then must comply with the 

data request using a mutually agreeable format and security protocols. 

15. NERC states that the performance of Reliability Standard IRO-010-2, 

Requirements R1, R2 and R3 is premised on the existence of data exchange capabilities, 

“regardless of whether a separate requirement expressly requires the Reliability 

28 Id. at 14-15.

29 Id. at 15.
Docket Nos. RM19-16-000 and RM19-17-000 - 10 -

Coordinator to have data exchange capabilities in place.”30 NERC therefore asserts that 

Reliability Standard IRO-002-5, Requirement R1 provides no additional reliability 

benefit and “is therefore unnecessary and redundant and should be retired.”31

16. NERC also proposes to retire Reliability Standards TOP-001-4, Requirements R19 

and R22. NERC explains that Requirements R19 and R22 of Reliability Standard 

TOP-001-4 require transmission operators and balancing authorities respectively to have 

data exchange capabilities with entities from which they need data to perform operational 

planning analyses (transmission operators) and next-day Operating Plans (balancing 

authorities). NERC notes, however, that Reliability Standard TOP-002-4, 

Requirement R1 requires a transmission operator to perform an operational planning 

analyses to determine whether next-day operations within its area will exceed System 

Operating Limits. NERC also states that TOP-002-4, Requirement R4 requires each 

balancing authority to have a next-day Operating Plan addressing expected generation 

resource commitment and dispatch, Interchange scheduling and related matters. NERC 

asserts that to satisfy these requirements, “each Transmission Operator and Balancing 

Authority must have the data it deems necessary from those entities that possess it.”32

17. NERC also points to Reliability Standard TOP-003-3 (Operational Reliability 

Data) whose purpose is “to ensure that the Transmission Operator and Balancing 

30 Id. 

31 Id.

32 Id. at 16.
Docket Nos. RM19-16-000 and RM19-17-000 - 11 -

Authority have data needed to fulfill their operational and planning responsibilities.” 

NERC contends that the requirements in Reliability Standard TOP-003-3 largely mirror 

the requirements in Reliability Standard IRO-010-2 discussed above, and thus, as with 

Reliability Standard IRO-010-2, transmission operators and balancing authorities must 

have data exchange capabilities with its reporting entities to satisfy the requirements of 

Reliability TOP-003-3. For these reasons, NERC contends that Reliability Standards 

TOP-001-4, Requirements R19 and R22 are unnecessary and redundant and should be 

retired. 

18. NERC requests that the Commission approve the implementation plan, attached to 

NERC’s petition as Exhibit B, and the associated violation risk factors and violation 

severity levels described in Exhibit D. The implementation plan provides that proposed 

Reliability Standards IRO-002-7 and TOP-001-5 would become effective on the first day 

of the first calendar quarter that is three months after regulatory approval. The currently 

effective versions of the Reliability Standards would be retired immediately prior to the 

effective date of the revised Reliability Standards. NERC explains that the requested 

timeline accounts for the time entities will need to update their systems and related

documentation.

3. FAC, INT, MOD and PRC Petition (Docket No. RM19-17-000)

19. On June 7, 2019, in Docket No. RM19-17-000, NERC submitted for Commission 

approval the proposed retirement of 10 currently-effective FAC, INT, MOD and PRC 
Docket Nos. RM19-16-000 and RM19-17-000 - 12 -

Reliability Standards in their entirety without replacement.33 Additionally, NERC

proposed modifications to four Reliability Standards reflecting the retirement of certain 

requirements from the currently-effective versions: FAC-008-4 (Facility Ratings), 

INT-006-5 (Evaluation of Interchange Transactions), INT-009-3 (Implementation of 

Interchange) and PRC-004-6 (Protection System Misoperation Identification and 

Correction).

34 NERC asserts that its proposals would not adversely impact reliability, but 

rather they “would benefit reliability by allowing entities to focus their resources on those 

Reliability Standard requirements that promote the reliable operation and planning of the 

BPS [Bulk-Power System] and avoid unnecessary regulatory burden.”35

20. Regarding the full FAC, INT, MOD and PRC Reliability Standards proposed for 

retirement, NERC contends that they are not necessary and that removing them would not 

adversely affect reliability. NERC states that retirement of the ten full Reliability 

33 Reliability Standards FAC-013-2 (Assessment of Transfer Capability for the 

Near-term Transmission Planning Horizon), INT-004-3.1 (Dynamic Transfers), 

INT-010-2.1 (Interchange Initiation and Modification for Reliability), MOD-001-1a 

(Available Transmission System Capability), MOD-004-1 (Capacity Benefit Margin), 

MOD-008-1 (Transmission Reliability Margin Calculation Methodology), MOD-020-0 

(Providing Interruptible Demands and Direct Control Load Management Data to System 

Operations and Reliability Coordinators), MOD-028-2 (Area Interchange Methodology), 

MOD-029-2a (Rated System Path Methodology), and MOD-030-3 (Flowgate 

Methodology).

34 The revised versions of the FAC, INT and PRC Reliability Standards are not 

attached to this final rule. The complete text of the Reliability Standards is available on 

the Commission’s eLibrary document retrieval system in Docket No. RM19-17-000 and 

is posted on the ERO’s website, http://www.nerc.com. 

35 Docket No. RM19-17-000 Petition at 7.
Docket Nos. RM19-16-000 and RM19-17-000 - 13 -

Standards is justified because they are primarily administrative in nature or largely 

related to commercial or business practices, and therefore no longer serve a reliability 

purpose.36 For example, NERC states that the transfer capability assessment required 

under Reliability Standard FAC-013-2 “serves only a market function” and “is not an 

indicator of [bulk electric system] reliability.”37 In supporting its conclusion that 

Reliability Standard INT-010-2.1 primarily relates to commercial and business practices, 

NERC notes that in 2013 the NERC Independent Experts Review Panel recommended 

retiring the previous version of the Reliability Standard “due to overlap with the NAESB 

Electronic Tagging Functional Specification.”38 

21. Similarly, regarding the MOD Reliability Standards, NERC states that “[Available 

Transfer Capability] and [Available Flowgate Methodology], as well as e-Tags, are 

commercially-focused elements facilitating interchange and balancing of interchange,” 

and that system operators maintain reliability by monitoring Real-time flows based on 

System Operating Limits and Interconnection Reliability Operating Limits.39 In 

particular, NERC explains that information on Interruptible Demands and Direct Control 

Load Management required under Reliability Standard MOD-020-0 is not useful for 

transmission operators and reliability coordinators, “who must plan and operate the 

36 Docket No. RM19-17-000 Petition at 13-24.

37 Id. at 13.

38 Id. at 16-19.

39 Id. at 21.
Docket Nos. RM19-16-000 and RM19-17-000 - 14 -

[Bulk-Power System] within System Operating Limits and Interconnection Reliability 

Operating Limits under the TOP and IRO Reliability Standards.”40

22. Regarding NERC’s proposed modified Reliability Standards, NERC states that the 

data provision obligations of currently effective Reliability Standard FAC-008-3,

Requirements R7 and R8 are redundant with Reliability Standards MOD-032-1, 

IRO-010-2 and TOP-003-3. NERC asserts that Requirements R3.1, R4 and R5 of 

currently-effective Reliability Standard INT-006-4 “provide little, if any, benefit or 

protection to the reliability operation of the [Bulk-Power System]”41 and that the 

substance of Requirements R4 and R5 in particular relate to commercial or business 

practices and are better addressed through the balancing authority’s e-Tag Authority 

Service.42 Also, NERC states that Requirement R1 of currently-effective Reliability 

Standard INT-009-2.1 is being revised to remove the reference to Reliability Standard 

INT-010, which is also proposed for retirement, and Requirement R2 is redundant with 

Reliability Standard BAL-005-1, Requirement R7.43 Finally, NERC states that it has 

determined that rather than the “specific, recurring and inflexible timeframe” set forth in 

Requirement R4 of currently-effective Reliability Standard PRC-004-5 for identifying the 

cause of a protection system misoperation, “it would be more effective to have entities 

40 Id. at 23.

41 Id. at 29.

42 Id. at 29-31.

43 Id. at 31-32.
Docket Nos. RM19-16-000 and RM19-17-000 - 15 -

investigate the causes of misoperations according to their own internal control policies 

and procedures.”44

23. NERC requests that the Commission approve the implementation plan, attached to 

NERC’s petition as Exhibit B, and the associated violation risk factors and violation 

severity levels, attached to NERC’s petition as Exhibit D, which are generally unchanged 

from the currently effective versions. For the Reliability Standards retired in their 

entirety, NERC proposes an effective date that is immediately upon regulatory approval 

of the retirement. NERC also seeks to retire the currently effective Reliability Standards 

FAC-008-3, INT-006-4, INT-009-2.1, and PRC-004-5(i) immediately prior to the 

effective date of their new versions.

D. Notice of Proposed Rulemaking

24. On January 23, 2020, the Commission issued a NOPR proposing to approve the 

retirement of 74 of the 77 Reliability Standard requirements requested by NERC. 

However, while proposing to approve the majority of Reliability Standard requirement 

retirements NERC proposed, the Commission expressed concern with NERC’s 

justification for retirement of Reliability Standard FAC-008-3, Requirement R7 and R8

because those requirements did not appear to be entirely redundant of other existing

Reliability Standards. Accordingly, the Commission sought more information from 

NERC regarding how other existing Reliability Standards render Reliability Standard 

44 Id. at 34.
Docket Nos. RM19-16-000 and RM19-17-000 - 16 -

FAC-008-3, Requirements R7 and R8 redundant, and how retiring those requirements 

would not create a reliability gap.

25. In response to the NOPR, the Commission received comments from NERC, Trade 

Associations (i.e., American Public Power Association, Edison Electric Institute, Large 

Public Power Council, National Rural Electric Cooperative Association, Transmission 

Access Policy Study Group), Bonneville Power Administration, Western Area Power 

Administration, and Jonathan Appelbaum. We address below the issues raised in the 

NOPR and comments. 

II. Discussion

A. Approved Retirement of 18 Reliability Standard Requirements

26. Pursuant to section 215(d)(2) of the FPA, the Commission approves NERC’s 

request to retire 18 Reliability Standard requirements as just, reasonable, not unduly 

discriminatory or preferential, and in the public interest. NERC’s petitions provide an 

adequate basis to conclude that the requirements proposed for retirement: (1) provide 

little or no reliability benefit; (2) are administrative in nature or relate expressly to 

commercial or business practices; or (3) are redundant with other Reliability Standards.

NERC’s justifications for retiring the 18 requirements are consistent with the retirement 

guidelines set forth by the Commission in Order No. 788 and with the determination that 

“requirements proposed for retirement can be removed from the Reliability Standards 
Docket Nos. RM19-16-000 and RM19-17-000 - 17 -

with little effect on reliability and an increase in efficiency of the ERO compliance 

program.”45 

27. While the Commission approves the retirement of the 18 Reliability Standard 

requirements, pursuant to FPA section 215(d)(4), we remand proposed Reliability 

Standard FAC-008-4. As discussed below, we are satisfied with the justification for 

retiring Reliability Standard FAC-008-3, Requirement R7 contained in NERC’s 

comments. However, for the reasons discussed below, we are not persuaded that it is 

appropriate to retire Reliability Standard FAC-008-3, Requirement R8. Because the 

Commission, pursuant to FPA section 215(d)(4), must remand to NERC for further 

consideration a proposed modification to a Reliability Standard that the Commission 

disapproves in whole or in part, we remand proposed Reliability Standard FAC-008-4 to 

address our concerns with the retirement of Requirement R8. 

B. Reliability Standard FAC-008-3, Requirements R7 and R8

1. NERC Petition

28. Reliability Standard FAC-008-3, Requirements R7 and R8 require generator 

owners and transmission owners, respectively, to provide facility ratings and related 

information to requesting reliability coordinators, planning coordinators, transmission 

planners, transmission owners and transmission operators. NERC contends that 

requirements in Reliability Standards MOD-032-1, IRO-010-2, and TOP-003-3 render 

45 Order No. 788, 145 FERC ¶ 61,147 at P 1.
Docket Nos. RM19-16-000 and RM19-17-000 - 18 -

the data provision obligations of Requirements R7 and R8 in Reliability Standard 

FAC-008-3 redundant and, therefore, unnecessary for reliability.46 

29. To support its redundancy claim, NERC explains that Reliability Standard 

MOD-032-1 requires generator owners and transmission owners to provide information 

on power capabilities and facility ratings (Requirement R2) to enable planning 

coordinators and transmission planners to “jointly develop steady-state, dynamics, and 

short circuit modeling data requirements and reporting procedures for the Planning 

Coordinator’s planning area” (Requirement R1). NERC further explains that Reliability 

Standard IRO-010-2 requires reliability coordinators to maintain “a documented 

specification for the data necessary to perform its Operational Planning Analyses, 

Real-time monitoring, and Real-time Assessments. This data necessarily includes 

Facility Ratings as inputs to System Operating Limit monitoring.”47 NERC notes that 

under Requirement R3 of IRO-010-2, the transmission owner and generator owner must 

provide such data. Finally, NERC points out that Reliability Standard TOP-003-3

requires the transmission operator to maintain data specifications (Requirement R1) and 

the transmission owner and generation owner to provide the requested data 

(Requirement R5). Relying on this framework of data specification and provision, NERC 

concludes that Reliability Standard FAC-008-3, Requirements R7 and R8 “are now 

46 Docket No. RM19-17-000 Petition at 15.

47 Id. at 28.
Docket Nos. RM19-16-000 and RM19-17-000 - 19 -

redundant to other more robust Reliability Standards and are no longer needed for 

reliability.”48

2. NOPR

30. While agreeing with NERC that Reliability Standards MOD-032-1, IRO-010-2 

and TOP-003-3 provide a basis for retiring certain elements of Reliability Standard 

FAC-008-3, Requirements R7 and R8, the Commission stated that NERC’s petition 

“does not address other elements of Requirements R7 and R8 that do not appear to be 

redundant.”49 The NOPR explained that Reliability Standard FAC-008-3, 

Requirements R7 and R8 require generation owners and transmission owners to provide 

facility ratings to several functional entity types, including transmission owners. The 

Commission observed that the three Reliability Standards NERC claims to render 

Requirements R7 and R8 redundant require generator owners and transmission owners to 

provide facility ratings to other functional entities, including reliability coordinators, 

planning coordinators, transmission planners, and transmission operators, they do not 

require the provision of facility ratings to transmission owners. The Commission 

expressed concern that eliminating the mandatory exchange of facility-related 

information with transmission owners could “impact reliability since these requirements 

48 Id.

49 NOPR, 170 FERC ¶ 61,032 at P 31.
Docket Nos. RM19-16-000 and RM19-17-000 - 20 -

ensure that all transmission owners have accurate facility-related information in the 

models that they use to plan and operate the bulk electric system.”50

31. The Commission also noted that Reliability Standards MOD-032-1, IRO-010-2, 

and TOP-003-3 do not address sub-requirement R8.1.2 of Reliability Standard 

FAC-008-3, relating to the identity of the next most limiting equipment of a requested 

facility. Further, the Commission observed that the Reliability Standards NERC claims 

are redundant also do not account for sub-requirement R8.2, which requires the 

identification and thermal rating of the existing next most limiting equipment of facilities 

with a thermal rating that limits the use of that facility by causing either an 

Interconnection Reliability Operating Limit, a limitation of Total Transfer Capability, an 

impediment to generator deliverability, or an impediment to service to a major load 

center as specified in FAC-008-3 (Requirement R8.2). 51

32. Therefore, the Commission stated that Reliability Standard FAC-008-3, 

Requirements R7 and R8 do not appear to be entirely redundant of the Reliability 

Standards cited by NERC and, if retired, could create reliability gaps. The Commission 

sought clarification from NERC because the petition does not address these 

non-redundant elements of Requirements R7 and R8. 

50 Id.

51 This requirement was developed in response to a directive in Order No. 693. 

Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 118 FERC

¶ 61,218, at P 756, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007); see

also NERC, Petition, Docket No. RD11-10-000, at 11-13, 20-21 (filed Jun. 15, 2011).
Docket Nos. RM19-16-000 and RM19-17-000 - 21 -

3. Comments

33. NERC, Trade Associations and Appelbaum support the retirement of Reliability 

Standard FAC-008-3, Requirements R7 and R8, maintaining that transmission owners do 

not need facility ratings and related information to perform their responsibilities.

52 In 

their view, transmission owners play a more limited role than the planning and operation 

function of the other applicable entities in Reliability Standard FAC-008-3. NERC notes

that the NERC Glossary describes transmission owner as an “entity that owns and 

maintains transmission facilities” and that a transmission owner is “not the functional 

entity directly responsible for complying with Reliability Standards for planning and 

operating the Bulk Power System.”53 Additionally, Appelbaum notes that “in many 

cases” transmission owner and generation owner interconnection agreements exist and 

contain provisions governing how facilities are operated and maintained, including the 

methodology and responsibility for rating facilities.54 By contrast Bonneville 

commented, without elaboration, that it agrees that Reliability Standards FAC-008, 

Requirements R7 and R8 should be retained.55

52 As discussed below, Appelbaum supports retaining sub-requirement R8.2.

53 NERC Comments at 8 (citing NERC Glossary of Terms Used in NERC 

Reliability Standards).

54 Appelbaum Comments at 3.

55 Bonneville Comments at 2.
Docket Nos. RM19-16-000 and RM19-17-000 - 22 -

34. NERC and Trade Associations assert that entities with the responsibility to plan 

and operate the Bulk-Power System (i.e., transmission operators and transmission 

planners) obtain the information they need under Reliability Standards MOD-032-1 and 

TOP-003-3, and thus they do not require Reliability Standard FAC-008-3, 

Requirements R7 and R8.56 Trade Associations state that “from a grid reliability 

perspective, it is the responsible Transmission Planner and Transmission Operator that 

need the facility ratings because they are accountable for the reliable planning and 

operation of the bulk electric system, not the Transmission Owner.”57 Further, Trade 

Associations note that the Commission previously approved the retirement of Reliability 

Standard FAC-008-3, Requirement R4, which had similar obligations to 

Requirements R7 and R8, based on the Commission’s conclusion that the requirement to 

make available such facility ratings information was an administrative task that provides 

little protection for bulk electric system reliability.58 

35. In response to the Commission’s concerns regarding Reliability Standard 

FAC-008-3, sub-requirements 8.1.2 and 8.2, NERC and Trade Associations assert that 

the “catch-all” provision in Reliability Standard MOD-032-1, Attachment 1 Data 

Reporting Requirements, requires transmission owners and generation owners to provide 

56 NERC Comments at 8; Trade Association Comments at 6.

57 Trade Association Comments at 7. 

58 Id. (citing Order No. 788, 145 FERC ¶ 61,147 at P 19).
Docket Nos. RM19-16-000 and RM19-17-000 - 23 -

“other information requested by the planning coordinator or transmission provider 

necessary for modeling purposes,” which includes data described in 

sub-requirements 8.1.2 and 8.2.59 Further, NERC and Trade Associations assert that 

reliability coordinators and transmission system operators obtain this information under 

the data specification requirements in Reliability Standards IRO-010-2 and TOP-003-3.60 

NERC concludes that “[n]ow that these broader data specification standards are in place, 

NERC has identified no reliability need to maintain additional requirements expressly 

requiring the provision of this data in the FAC-008 standards.”61 

36. Appelbaum contends that sub-requirement 8.2 should be retained, however,

because it “support[s] reliable operations under very limited circumstances and very 

limited locations, yet it is important enough to retain.”62 He explains that 

sub-requirement 8.2 focuses on specific circumstances, wherein having knowledge of the

increase in facility rating based on the next most limiting equipment improves system 

59 NERC Comments at 8-9; Trade Association Comments at 9.

60 NERC Comments at 9; Trade Associations Comments at 8-9 (“Reliability 

Standard TOP-003-3 (Operational Reliability Data) Requirements R3 and R5 require the 

provision of such information through data specifications that are issued by Transmission 

Operators.”)

61 NERC Comments at 9.

62 Appelbaum Comments at 7 (referring to load pockets that contain critical 

infrastructure, dense populations, or have large financial impacts).
Docket Nos. RM19-16-000 and RM19-17-000 - 24 -

operations, and therefore reliability, and “adds resilience to the operation of the Bulk 

Power System.”63

4. Commission Determination

37. Pursuant to FPA section 215(d)(4), we remand proposed Reliability Standard 

FAC-008-4. As discussed below, we are satisfied with NERC’s justification for retiring 

Reliability Standard FAC-008-3, Requirement R7. However, for the reasons discussed 

below, we are not persuaded that it is appropriate to retire Reliability Standard 

FAC-008-3, Requirement R8. Because the Commission, pursuant to FPA 

section 215(d)(4), must remand to NERC for further consideration a proposed 

modification to a Reliability Standard that the Commission disapproves in whole or in 

part, we remand proposed Reliability Standard FAC-008-4 to address our concerns with 

the retirement of Requirement R8. 

38. Regarding Reliability Standard FAC-008-3, Requirement R7, we are persuaded

that retiring Requirement R7 will not result in a reliability gap because Requirement R7

is redundant or otherwise provides little or no reliability benefit. We agree with NERC 

that, unlike transmission operators and transmission planners that need and will continue 

to receive facility ratings information under other Reliability Standards, transmission 

owners do not need to exchange facility ratings because they have a more limited 

functional role that does not involve planning and operating the Bulk-Power System.

63 Id. at 6-7.
Docket Nos. RM19-16-000 and RM19-17-000 - 25 -

Only Bonneville, a registered transmission owner, supported retaining Requirement R7, 

and no transmission owner submitted comments indicating that it needed the facility 

ratings information required under Requirement R7.64 Moreover, the Commission did 

not direct the inclusion of transmission owners in Requirement R7. Reliability Standard 

FAC-008-3, Requirement R7 was formerly designated Reliability Standard FAC-009-1, 

Requirement R2. The Commission approved Reliability Standard FAC-009-1, 

Requirement R2 in Order No. 693 and did so without requiring the sharing of facility 

ratings information with transmission owners.65 

39. While we determine that the retirement of Requirement R7 is appropriate, we are 

not convinced that the retirement of sub-requirements R8.1.2 and 8.2 will not result in a 

reliability gap. By retiring sub-requirements R8.1.2 and 8.2, transmission owners will no 

longer be required to communicate ratings information for solely owned limiting and next 

most limiting equipment present on jointly-owned facilities. Without ratings information 

on limiting and next most limiting equipment, transmission owners could lack the 

necessary information to correctly calculate the ratings for their jointly-owned facilities. 

The Commission recognized the importance of this type of information exchange in 

64 While Bonneville submitted comments supporting the retention of 

Requirement R7, Bonneville did not elaborate on its position.

65 Order No. 693, 118 FERC ¶ 61,218 at PP 772-774. NERC subsequently added 

transmission owners as recipients, without elaboration, when NERC revised Reliability 

Standard FAC-008 and retired Reliability Standard FAC-009.
Docket Nos. RM19-16-000 and RM19-17-000 - 26 -

Order No. 693 by directing NERC to require the sharing of information regarding the 

most limiting and next most limiting equipment when requested.66 

40. The transmission owner’s obligation under Reliability Standard FAC-008-3, 

Requirement R3 is also impacted by the proposed retirement of Requirement R8. 

Reliability Standard FAC-008-3, Requirement R3 requires transmission owners to have a 

documented facility ratings methodology for solely and jointly owned facilities that, 

pursuant to Requirement R3.3, includes a “statement that a Facility Rating shall respect 

the most limiting applicable Equipment Rating of the individual equipment that 

comprises that Facility.” In order to rate equipment accurately to avoid mis-ratings of 

jointly-owned transmission lines, the transmission owner needs information about the 

co-owner’s most limiting equipment on shared facilities. Therefore, under these 

circumstances, we conclude that Requirement R8 is needed to ensure that limiting and 

next limiting equipment is identified and communicated.

III. Information Collection Statement 

41. The information collection requirements contained in this final rule are subject to 

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

Paperwork Reduction Act of 1995.67 OMB’s regulations require approval of certain 

information collection requirements imposed by agency rules.68 Upon approval of a 

66 Order No. 693, 118 FERC ¶ 61,218 at PP 755-762.

67 44 U.S.C. 3507(d).

68 5 CFR 1320.
Docket Nos. RM19-16-000 and RM19-17-000 - 27 -

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 these collections of information unless the collections of information 

display a valid OMB control number. 

42. The Commission estimates that the final rule, which would retire 18 requirements 

of Reliability Standards without adding any new obligations on registered entities, would

result in a total reduction in burden for industry of 42,907.44 hours. The Commission 

based the burden reduction estimates on staff experience, knowledge, and expertise.

Reductions Due to Final Rule in Docket Nos. RM19-16 & RM19-17

Reliability 

Standard & 

Requirement

Type69 and 

Number of 

Entity

(1)

Number 

of Annual 

Responses 

Per 

Entity

(2)

Total 

Number 

of 

Responses

(1)*(2)=(3)

Average 

Number 

of 

Burden 

Hours 

per 

Response

(4)

Total Burden 

Hours

(3)*(4)=(5)

FERC-725A

FAC-013-2 RC (12) 8.33 100 26.67 2,667

INT-006-4 

R3.1, R4, R5, 

R5.1, R5.2, 

R5.3, R5.4, 

R5.5

BA/TSP (169) 1 169 56.3 9,514.7

INT-004-3.1 BA (97) 1 97 56.3 5,461.1

69 RC=Reliability Coordinator; BA=Balancing Authority; TSP=Transmission 

Service Provider; TO=Transmission Owner; GO=Generator Owner; DP=Distribution 

Provider; TP=Transmission Provider; and RP=Resource Planner. Our estimates are 

based on the NERC Compliance Registry of July 17, 2020, which indicates there are 

974 entities registered as GOs, 321 entities registered as TOs, 97 entities registered as 

BAs, 72 entities registered as TSPs, 198 entities registered as TPs312 entities registered 

as DPs, 160 entities registered as RPs, and 12 entities registered as RCs within the United 

States. 
Docket Nos. RM19-16-000 and RM19-17-000 - 28 -

INT-010-2.1 BA(97) 1 97 56.3 5,461.1

INT-009-2.1 

R2

BA (97) 1 97 56.3 5,461.1

MOD-020-0 TP/RP/DP/BA 

(767)

1 767 14.4 11,044.8

Sub-Total 

for FERC725A

1,239 1,327 39,609.8

FERC-725A(1C)

TOP-001-4 

R19 & R22

BA/TO/GO/DP 

(1,704)

.25 426 0.8 340.8

Sub-Total 

for FERC725A(1C)

1,704 426 340.8

FERC-725G1

PRC-004-5(i) 

R4

TO/GO/DP 

(1,607)

.41 659 4.36 2,873.24

Sub-Total 

for FERC725G1

1,607 659 2,873.24

FERC-725Z

IRO-002-6 

R1

RC (12) 1.17 14 5.97 83.6

Sub-Total 

for FERC725Z

12 14 83.6

Total 

Reductions 

Due to Final 

Rule in 

RM19-16 & 

RM19-17

2,426 42,907.44

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

FERC-725A(1C), Mandatory Reliability Standards for Bulk-Power System: Reliability 

Standard TOP-001-4; FERC-725G1, Mandatory Reliability Standards for the Bulk-Power 

System: Reliability Standard PRC-004-5(i); FERC-725Z, Mandatory Reliability 

Standards: IRO Reliability Standards.
Docket Nos. RM19-16-000 and RM19-17-000 - 29 -

Action: Reductions to Existing Collections of Information FERC-725A, 

FERC-725A(1C), and FERC-725Z; and Elimination of Collections of Information, and 

FERC-725G1.

OMB Control Nos: 1902-0244 (FERC-725A); 1902-0298 (FERC-725A(1C));1902-0284 

(FERC-725G1); and 1902-0276 (FERC-725Z)

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

Frequency of Responses: On occasion (and proposed for deletion). 

43. Necessity of the Information: This proceeding approves the retirement of four

Reliability Standards in their entirety and five revised Reliability Standards, reflecting a 

total of 18 retired requirements identified by NERC. The approved retirements either:

(1) provide little or no reliability benefit; (2) are administrative in nature or relate 

expressly to commercial or business practices; or (3) are redundant with other Reliability 

Standards. 

44. Internal review: The Commission has reviewed NERC’s proposal 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 reduction estimates associated with the information requirements approved for 

retirement.

45. Interested persons may obtain information on the reporting requirements by 

contacting the Federal Energy Regulatory Commission, Office of the Executive Director, 

888 First Street, NE, Washington, DC 20426 [Attention: Ellen Brown, e-mail: 

DataClearance@ferc.gov, phone: (202) 502-8663, fax: (202) 273-0873].
Docket Nos. RM19-16-000 and RM19-17-000 - 30 -

46. Comments concerning the information collections and requirements approved for 

retirement in this final rule and the associated burden estimates, should be sent to the 

Commission in this docket and may also be sent to the Office of Management and 

Budget, Office of Information and Regulatory Affairs [Attention: Desk Officer for the 

Federal Energy Regulatory Commission]. For security reasons, comments should be sent 

by e-mail to OMB at the following e-mail address: oira_submission@omb.eop.gov. 

Please refer to the appropriate OMB Control Number(s) and Docket Nos. RM19-16-000 

and RM19-17-000 in your submission.

IV. Regulatory Flexibility Act Certification 

47. The Regulatory Flexibility Act of 1980 (RFA)70 generally requires a description 

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

number of small entities. The RFA mandates consideration of regulatory alternatives that 

accomplish the stated objectives of a rule and that minimize any significant economic 

impact on a substantial number of small entities. The Small Business Administration’s 

Office of Size Standards develops the numerical definition of a small business.71 The 

Small Business Administration has established size standards, for the types of affected 

entities (noted in the table above), that range from a maximum of 250-1,000 employees

for an entity and its affiliates to be considered small.

70 5 U.S.C. 601-612.

71 13 CFR 121.101.
Docket Nos. RM19-16-000 and RM19-17-000 - 31 -

48. The Commission estimates the total industry reduction in burden for all entities 

(large and small) to be 42,907.44 hours (or approximately 18 hours (rounded) per 

response). The Commission believes that this will reduce burden and cost for all affected 

entities. 

49. Based on the information above, the Commission certifies that the reductions will 

not have a significant impact on a substantial number of small entities. Accordingly, no 

initial regulatory flexibility analysis is required.

V. Environmental Analysis

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

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

on the human environment.72 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.73 The actions 

approved here fall within this categorical exclusion in the Commission’s regulations.

VI. Document Availability 

51. 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 

72 Regulations Implementing the National Environmental Policy Act of 1969, 

Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs., Regulations

Preambles 1986-1990 ¶ 30,783 (1987).

73 18 CFR 380.4(a)(2)(ii).
Docket Nos. RM19-16-000 and RM19-17-000 - 32 -

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 

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

Washington, DC 20426.

52. 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 excluding the last three digits of this 

document in the docket number field.

53. 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.
Docket Nos. RM19-16-000 and RM19-17-000 - 33 -

VII. Effective Date and Congressional Notification

54. This final rule is effective [insert date 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. This final rule is being submitted to the Senate, 

House, and Government Accountability Office.

By direction of the Commission.

Nathaniel J. Davis, Sr.,

Deputy Secretary.
Docket Nos. RM19-16-000 and RM19-17-000 - 34 -

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

Appendix

Commenters

Abbreviation Commenter

NERC North American Electric Reliability Corporation

Trade Associations American Public Power Association, Edison Electric

Institute, Large Public Power Council, National Rural Electric 

Cooperative Association, Transmission Policy Study Group

Bonneville Bonneville Power Administration

WAPA Western Area Power Administration

Appelbaum Jonathan Appelbaum