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Proposed Rule2022-13471

Transmission System Planning Performance Requirements for Extreme Weather

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Published

June 27, 2022

Issuing agencies

Energy DepartmentFederal Energy Regulatory Commission

Abstract

The Federal Energy Regulatory Commission proposes to direct that the North American Electric Reliability Corporation, the Commission-certified Electric Reliability Organization, submit to the Commission modifications to Reliability Standard TPL-001-5.1 (Transmission System Planning Performance Requirements) within one year of the effective date of a final rule in this proceeding to address reliability concerns pertaining to transmission system planning for extreme heat and cold weather events that impact the reliable operations of the Bulk-Power System. Specifically, we propose to direct NERC to develop modifications to Reliability Standard TPL-001-5.1 to require: development of benchmark planning cases based on information such as major prior extreme heat and cold weather events or future meteorological projections; planning for extreme heat and cold events using steady state and transient stability analyses expanded to cover a range of extreme weather scenarios including the expected resource mix's availability during extreme weather conditions, and including the broad area impacts of extreme weather; and corrective action plans that include mitigation for any instances where performance requirements for extreme heat and cold events are not met.

Full Text

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<title>Federal Register, Volume 87 Issue 122 (Monday, June 27, 2022)</title>
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[Federal Register Volume 87, Number 122 (Monday, June 27, 2022)]
[Proposed Rules]
[Pages 38020-38044]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-13471]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

18 CFR Part 40

[Docket No. RM22-10-000]

Transmission System Planning Performance Requirements for Extreme
Weather

AGENCY: Federal Energy Regulatory Commission, Department of Energy.

ACTION: Notice of proposed rulemaking.

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SUMMARY: The Federal Energy Regulatory Commission proposes to direct
that the North American Electric Reliability Corporation, the
Commission-certified Electric Reliability Organization, submit to the
Commission modifications to Reliability Standard TPL-001-5.1
(Transmission System Planning Performance Requirements) within one year
of the effective date of a final rule in this proceeding to address
reliability concerns pertaining to transmission system planning for
extreme heat and cold weather events that impact the reliable
operations of the Bulk-Power

[[Page 38021]]

System. Specifically, we propose to direct NERC to develop
modifications to Reliability Standard TPL-001-5.1 to require:
development of benchmark planning cases based on information such as
major prior extreme heat and cold weather events or future
meteorological projections; planning for extreme heat and cold events
using steady state and transient stability analyses expanded to cover a
range of extreme weather scenarios including the expected resource
mix's availability during extreme weather conditions, and including the
broad area impacts of extreme weather; and corrective action plans that
include mitigation for any instances where performance requirements for
extreme heat and cold events are not met.

DATES: Comments are due August 26, 2022.

ADDRESSES: Comments, identified by docket number, may be filed in the
following ways. Electronic filing through <a href="https://www.ferc.gov">https://www.ferc.gov</a>, is
preferred.
<bullet> Electronic Filing: Documents must be filed in acceptable
native applications and print-to-PDF, but not in scanned or picture
format.
<bullet> For those unable to file electronically, comments may be
filed by U.S. Postal Service mail or by hand (including courier)
delivery.
[cir] Mail via U.S. Postal Service only: Addressed to: Federal
Energy Regulatory Commission, Office of the Secretary, 888 First Street
NE, Washington, DC 20426.
[cir] For delivery via any other carrier (including courier):
Deliver to: Federal Energy Regulatory Commission, Office of the
Secretary, 12225 Wilkins Avenue, Rockville, MD 20852.

FOR FURTHER INFORMATION CONTACT:
Mahmood Mirheydar (Technical Information), Office of Electric
Reliability, Federal Energy Regulatory Commission, 888 First Street NE,
Washington, DC 20426, (202) 502-8034, <a href="/cdn-cgi/l/email-protection#482529202527272c6625213a202d312c293a082e2d3a2b662f273e">[email&#160;protected]</a>
Milena Yordanova (Legal Information), Office of the General Counsel,
Federal Energy Regulatory Commission, 888 First Street NE, Washington,
DC 20426, (202) 502-6194, <a href="/cdn-cgi/l/email-protection#573a3e3b323936792e3825333639382136173132253479303821">[email&#160;protected]</a>

SUPPLEMENTARY INFORMATION:

Table of Contents

Paragraph
Nos.

I. Introduction............................................ 1
II. Background............................................. 8
A. Legal Authority..................................... 8
B. Climate Change, Extreme Weather, and Electric System 10
Reliability Technical Conference......................
C. Overview of Technical Conference Comments........... 13
D. Cold Weather Reliability Standards.................. 18
E. Reliability Standard TPL-001-4 (Transmission System 20
Planning Performance Requirements)....................
III. The Need for Reform................................... 24
A. Recent Events Show Changes in Weather Patterns 24
Resulting in More Extreme Heat and Cold Weather Events
B. NERC Reliability Standards Do Not Require Planning 37
To Minimize the Increasing Reliability Risks
Associated With Anticipated Extreme Heat and Cold
Weather Events........................................
IV. Proposed Directives.................................... 47
A. Develop Benchmark Planning Cases Based on Major 50
Prior Extreme Heat and Cold Weather Events............
B. Transmission System Planning for Extreme Heat and 57
Cold Weather Events...................................
1. Steady State and Transient Stability Analyses... 58
2. Transmission Planning Studies of Wide-Area 64
Events............................................
3. Study Concurrent Generator and Transmission 68
Outages...........................................
4. Sensitivity Analysis............................ 73
5. Modifications to the Traditional Planning 75
Approach..........................................
6. Coordination Among Planning Coordinators and 80
Transmission Planners and Sharing of Study Results
C. Implement a Corrective Action Plan If Performance 83
Standards Are Not Met.................................
D. Other Extreme Weather-Related Events and Issues..... 90
V. Information Collection Statement........................ 94
VI. Environmental Assessment............................... 96
VII. Regulatory Flexibility Act Certification.............. 97
VIII. Comment Procedures................................... 100
IX. Document Availability.................................. 103

I. Introduction

1. Pursuant to section 215(d)(5) of the Federal Power Act (FPA),\1\
the Commission proposes to direct that the North American Electric
Reliability Corporation (NERC), the Commission-certified Electric
Reliability Organization (ERO), submit modifications to Reliability
Standard TPL-001-5.1 (Transmission System Planning Performance
Requirements) \2\ that address concerns pertaining to transmission
system planning for extreme heat or cold weather events that impact the
reliable operation \3\ of the Bulk-Power System.\4\
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\1\ 16 U.S.C 824o(d)(5).
\2\ Transmission Planning Reliability Standard TPL-001-5, Order
No. 867, 85 FR 8155 (Feb. 13, 2020), 170 FERC ] 61,030, at P 1
(2020) (approving the proposed Reliability Standard TPL-001-5 and
associated implementation plan). N. Am. Elec. Reliability Corp.,
Docket No. RD20-8-000 (June 10, 2020) (delegated order) (approving
Reliability Standard TPL-001-5.1). This NOPR refers to Reliability
Standard TPL-001-5.1 to reflect that the currently effective version
4 of the Reliability Standard will be soon replaced by version 5.1
and any modifications proposed in the NOPR will apply only to TPL-
001-5.1.
\3\ The FPA defines ``Reliable Operation'' as ``operating the
elements of the Bulk-Power System within equipment and electric
system thermal, voltage, and stability limits so that instability,
uncontrolled separation, or cascading failures of such system will
not occur as a result of a sudden disturbance, including a
cybersecurity incident, or unanticipated failure of system
elements.'' 16 U.S.C. 824o(a)(4).
\4\ The Bulk-Power System is defined in the FPA as ``facilities
and control systems necessary for operating an interconnected
electric energy transmission network (or any portion thereof), and
electric energy from generating facilities needed to maintain
transmission system reliability. The term does not include
facilities used in the local distribution of electric energy.'' Id.
824o(a)(1).

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[[Page 38022]]

2. We take this action to address planning challenges associated
with extreme heat and cold weather events, particularly those that
occur during periods when the Bulk-Power System must meet unexpectedly
high demand.\5\ Extreme heat and cold weather events are occurring with
greater frequency, and are projected to occur with even greater
frequency in the future.\6\ As such, the impact of concurrent failures
of Bulk-Power System generators and transmission equipment and the
potential for cascading outages \7\ that may be caused by extreme heat
and cold events should be studied and corrective actions should be
identified and implemented.
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\5\ Technical Conference June 1-2, 2021, Climate Change, Extreme
Weather, and Electric System Reliability, Docket No. AD21-13-000
(June 1-2, 2021), June 1, 2021 Tr. 26: 3-7 (Derek Stenclik, Founding
Partner, Telos Energy, Inc.), 31:7-8 (Judy Chang, Undersecretary of
Energy, Massachusetts).
\6\ Environmental Protection Agency, Climate Change Indicators:
Weather and Climate (May 12, 2021) (EPA Climate Change Indicators),
<a href="https://www.epa.gov/climate-indicators/weather-climate">https://www.epa.gov/climate-indicators/weather-climate</a> (showing an
upward trend in extreme heat and cold weather events).
\7\ NERC Glossary of Terms Used in Reliability Standards
(Updated March 29, 2022) (NERC Glossary). NERC defines ``cascading''
as, ``The uncontrolled successive loss of System Elements triggered
by an incident at any location. Cascading results in widespread
electric service interruption that cannot be restrained from
sequentially spreading beyond an area predetermined by studies.''
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3. At the Commission's June 1-2, 2021 technical conference on
Climate Change, Extreme Weather, and Electric System Reliability, there
was consensus among panelists that planners cannot simply project
historical weather patterns forward to effectively forecast the future,
since climate change has made the use of historical weather
observations no longer representative of future conditions.\8\ For
example, extreme heat in summer in regions like the Pacific northwest
and extreme cold in winter in regions like Texas has increased demand
for electricity at times when historically demand has been low and such
events will likely continue to present challenges in the future.\9\
Therefore, transmission planners and planning coordinators need to
reflect these new realities into their planning processes.\10\
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\8\ June 1, 2021 Tr. 30:2-3 (Chang), 31:12-18 (Lisa Barton,
Executive Vice President/Chief Operating Officer, American Electric
Power).
\9\ June 1, 2021 Tr. 31:1-6 (Chang); June 2, 2021 Tr. 72:8-10
(Amanda Frazier, Senior Vice President of Regulatory Policy, Vista
Corp.); 9:1-5 (Wesley Yeomans, Vice President of Operations, New
York Independent System Operator, Inc. (NYISO)) (noting that in New
York the majority of the extreme conditions were cold weather
related but that there can be heat waves in New York City, and more
heat waves are expected).
\10\ June 1, 2021 Tr. 35:1-6 (Chang). See also US News,
Blackouts in US Northwest Due to Heat Wave, Deaths Reported (June
29, 2021), <a href="https://www.usnews.com/news/business/articles/2021-06-29/rolling-blackouts-for-parts-of-us-northwest-amid-heat-wave">https://www.usnews.com/news/business/articles/2021-06-29/rolling-blackouts-for-parts-of-us-northwest-amid-heat-wave</a>; Judah
Cohen et al., Linking Arctic Variability and Change With Extreme
Winter Weather in the United States, 373 Sci. 1116, 1120 (2021),
<a href="https://www.science.org/doi/10.1126/science.abi9167">https://www.science.org/doi/10.1126/science.abi9167</a> (a study
connecting the 2021 extreme cold weather event in Texas and the
South-central United States to global warming-induced weather
anomalies that are likely to continue to produce severe winter storm
events).
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4. Since 2011, the country has experienced at least seven major
extreme heat and cold weather events,\11\ all of which put stress on
the Bulk-Power System, and resulted in some degree of load shed, and in
some cases nearly caused system collapse and uncontrolled blackouts,
which were only avoided via the actions of system operators. Of these,
the four most severe occurred in 2011, 2013, 2018, and 2021. The
extreme weather conditions in the February 2011 Southwest Cold Weather
Event resulted in the acumulative loss of approximately thirty thousand
megawatts of generation resources, causing the Electric Reliability
Council of Texas (ERCOT) to shed load to prevent widespread,
uncontrolled blackouts throughout the entire ERCOT Interconnection. The
September Midwest and Mid-Atlantic 2013 Heatwave Event lasted over
three days and at its peak required a 5,791 MW reduction in load. The
PJM Interconnection, L.L.C. (PJM) analysis during the event indicated a
need for pre-contingency load shed to avoid post-contingency voltage
collapse and a potential cascading outage.\12\ During the January 2018
South Central Cold Weather Event in the Midwest, had the grid operator
lost the single largest contingency of 1,163 MW, there could have been
firm load shedding to maintain system stability. In February of 2021,
the extensive cold in the South Central and Texas regions required a
combined total of 23,418 MW of firm load shed to maintain Bulk-Power
System reliability; it was the largest controlled load shedding event
in U.S. history. During this 2021 Cold Weather Event, had frequency in
Texas remained under its lowest point on February 15, 2021 for an
additional five minutes, approximately 17,000 MW of additional
generation would have tripped, potentially blacking out the entire
ERCOT Interconnection. ERCOT shed firm load in order to maintain
frequency to prevent a collapse of the system.\13\
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\11\ This NOPR references the following seven extreme heat and
cold weather events experienced since 2011: (1) February 2011
Southwest Cold Weather Event; (2) September Midwest and Mid-Atlantic
2013 Heatwave Event; (3) January 2014 Polar Vortex Cold Weather
Event; (4) January 2018 South Central Cold Weather Event; (5) August
2020 California Heatwave Event; (6) 2021 Cold Weather Event; (7)
June 2021 the Pacific Northwest Heatwave Event. The naming of the
events is based on the title of the associated reliability report
for each event cited below.
\12\ PJM, Technical Analysis of Operational Events and Market
Impacts during the September 2013 Heat Wave, at 13 (Dec. 23, 2013),
<a href="https://www.yumpu.com/en/document/read/40807126/20131223-technical-analysis-of-operational-events-and-market-impacts-during-the-september-2013-heat-wave">https://www.yumpu.com/en/document/read/40807126/20131223-technical-analysis-of-operational-events-and-market-impacts-during-the-september-2013-heat-wave</a>.
\13\ FERC, NERC, Regional Entity Staff Report, The February 2021
Cold Weather Outages in Texas, and the South-Central United States,
at 133 (Nov. 2021) (2021 Cold Weather Event Report).
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5. Given the reliability risks associated with extreme heat and
cold weather events, including the potential for widespread blackouts,
we believe it would be appropriate for planning of the transmission
system to account for extreme heat and cold weather events' potential
impact over wide geographical areas, and to consider the changing
resource mix and associated planning assumptions. Reliability Standard
TPL-001-4, the currently effective transmission system planning
standard, was developed to establish transmission system planning
performance requirements that ensure that the Bulk-Power System
operates reliably over a broad spectrum of system conditions and
following a wide range of probable contingencies. Reliability Standard
TPL-001-4, and its successor, TPL-001-5.1, includes provisions for
transmission planners and planning coordinators to study system
performance under extreme events based on their experience. However,
the current standards do not specifically require that a performance
analysis be conducted for extreme heat and cold weather, despite the
fact that such events have demonstrated a potential harm to reliable
operations of the Bulk-Power System, thus leaving a gap in system
planning.
6. To address this reliability gap, we propose to direct NERC to
develop modifications to Reliability Standard TPL-001-5.1 to require:
(1) development of benchmark planning cases based on information such
as major prior extreme heat and cold weather events or future
meteorological projections; (2) planning for extreme heat and cold
events using steady state and transient stability analyses expanded to
cover a range of extreme weather scenarios including the expected
resource mix's availability during extreme heat and cold weather
conditions, and including the broad area impacts of extreme heat and
cold

[[Page 38023]]

weather; and (3) corrective action plans that include mitigation for
any instances where performance requirements for extreme heat and cold
events are not met. In proposing to direct NERC to modify Reliability
Standard TPL-001-5.1, we are not proposing specific requirements.
Instead, we identify concerns that we believe should be addressed. NERC
may propose to develop new or modified Reliability Standards that
address our concerns in an equally efficient and effective manner.
However, NERC's proposal should explain how it addresses the
Commission's concerns.\14\
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\14\ See e.g., Mandatory Reliability Standards for the Bulk-
Power Sys., Order No. 693, 72 FR 16416 (Apr. 4, 2007), 118 FERC ]
61,218, at PP 186, 297, order on reh'g, Order No. 693-A, 120 FERC ]
61,053 (2007) (``where the Final Rule identifies a concern and
offers a specific approach to address the concern, we will consider
an equivalent alternative approach provided that the ERO
demonstrates that the alternative will address the Commission's
underlying concern or goal as efficiently and effectively as the
Commission's proposal''); Reliability Standards for Physical Sec.
Measures, 146 FERC ] 61,166, at P 13 (2014).
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7. We further propose to direct NERC to submit modifications to
Reliability Standard TPL-001-5.1 within one year of the effective date
of a final rule in this proceeding with compliance obligations for all
proposed new or modified Reliability Standards beginning no later than
12 months from the date of Commission approval of the modified
Reliability Standard. Finally, we invite comments on whether to also
direct NERC to address in Reliability Standard TPL-001-5.1 other
extreme weather-related events.

II. Background

A. Legal Authority

8. Section 215 of the FPA requires a Commission-certified ERO to
develop mandatory and enforceable Reliability Standards, subject to
Commission review and approval. Reliability Standards may be enforced
by the ERO, subject to Commission oversight, or by the Commission
independently.\15\ Pursuant to section 215 of the FPA, the Commission
established a process to select and certify an ERO,\16\ and
subsequently certified NERC.\17\
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\15\ 16 U.S.C. 824o(e).
\16\ Rules Concerning Certification of the Elec. Reliability
Org. & Procedures for the Establishment, Approval, & Enf't. of Elec.
Reliability Standards, Order No. 672, 71 FR 8662 (Feb. 17, 2006),
114 FERC ] 61,104, order on reh'g, Order No. 672-A, 71 FR 19814
(Apr. 18, 2006), 114 FERC ] 61,328 (2006).
\17\ N. Am. Elec. 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).
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9. Pursuant to section 215(d)(5) of the FPA, the Commission has the
authority, upon its own motion or upon complaint, to order the ERO to
submit to the Commission a proposed Reliability Standard or a
modification to a Reliability Standard that addresses a specific matter
if the Commission considers such a new or modified Reliability Standard
appropriate to carry out section 215 of the FPA.\18\ Further, pursuant
to Sec. 39.5(g) of the Commission's regulations, the Commission may
order a deadline by which the ERO must submit a proposed or modified
Reliability Standard, when ordering the ERO to submit to the Commission
a proposed Reliability Standard that addresses a specific matter.\19\
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\18\ 16 U.S.C. 824o(d)(5).
\19\ 18 CFR 39.5(g) (2021).
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B. Climate Change, Extreme Weather, and Electric System Reliability
Technical Conference

10. On March 5, 2021, the Commission announced that staff would
hold a technical conference to discuss issues surrounding the threat to
electric system reliability posed by climate change and extreme weather
events.\20\ The Commission sought to understand, among other things,
whether further action from the Commission is needed to help achieve an
electric system that can withstand, respond to, and recover from
extreme weather events.\21\ On March 15, 2021, the Commission invited
comments on a range of issues related to Bulk-Power System reliability,
including how extreme weather events (e.g., hurricanes, extreme heat,
extreme cold, drought, storms), have impacted the electric system and
whether these events would require changes to the way generation,
transmission, substation, or other facilities are designed, built,
sited, and operated.\22\ The Commission also inquired whether there are
opportunities to improve the NERC Reliability Standards to address
vulnerabilities to Bulk-Power System reliability due to climate change
or extreme weather events in the areas of transmission planning, Bulk-
Power System operations, Bulk-Power System maintenance, and emergency
operations.\23\
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\20\ Climate Change, Extreme Weather, and Electric System
Reliability, Notice of Technical Conference, Docket No. AD21-13-000,
at 1 (Mar. 5, 2021).
\21\ Id. at 2.
\22\ Supplemental Notice of Technical Conference, Docket No.
AD21-13-000, at 1, 3 (Mar. 15, 2021).
\23\ Id. at 5.
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11. On June 1 and 2, 2021, the Commission convened a staff-led
technical conference on Climate Change, Extreme Weather, and Electric
System Reliability focused on: (1) ways in which planning practices
might evolve to achieve outcomes that reflect consumer needs for
reliable electricity in the face of patterns of climate change and
extreme weather events that diverge from historical trends; (2) best
practices throughout the industry for assessing the risks posed by
climate change and extreme weather and developing cost-effective
mitigation; (3) ways in which existing operating practices may
necessitate updated techniques and approaches in light of increasing
instances of extreme weather and longer-term threats posed by climate
change; (4) best practices for the recovery period following an extreme
weather event; and (5) the role that coordination and cooperation
across jurisdictions could play in planning, operations, and recovery
practices to address climate change and extreme weather events.\24\
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\24\ Supplemental Notice of Technical Conference, Docket No.
AD21-13-000, at 1, 3 (May 27, 2021) (attaching agenda).
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12. Following the conference, the Commission invited comments on
specific topics discussed at the conference, such as the possibility
of: incorporating probabilistic methods into local transmission
planning and/or regional transmission planning; coordinating transfers
across the seams between Regional Transmission Organizations; the
possibility of modifying transmission planning requirements established
under Reliability Standard TPL-001 to better assess and mitigate the
risk of extreme weather events and associated common mode failures;
additional changes to the NERC Reliability Standards to address the
risk of extreme weather events; and among other topics, whether target
levels of interregional transfer capacity could help facilitate more
effective development of interregional transmission projects to help
ensure reliability and resilience during extreme weather events.\25\
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\25\ Notice Inviting Post-Technical Conference Comments, Docket
No. AD21-13-000, at 3, 5 (Aug. 11, 2021).
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C. Overview of Technical Conference Comments

13. Commenters submitted more than 50 sets of pre-conference and 20
post-conference comments on a wide range of issues, including the types
of extreme weather events experienced,\26\ and the range of mitigating
measures that could be taken to address the specific risks of climate
change in various regions of the country. Commenters expressed

[[Page 38024]]

concerns that the impacts of climate change are anticipated to affect
the electric system in multiple, compounding, and synergistic ways.\27\
Generally, industry experts agreed that extreme weather events are
likely to become more severe and frequent in the future,\28\ and
acknowledged the challenges associated with planning for extreme
events, including shifting scheduled maintenance, canceling or
recalling transmission and generation assets from scheduled maintenance
to meet demand under unexpected circumstances.\29\
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\26\ See, e.g., California Independent System Operator
Corporation (CAISO) Pre-Conference Comments at 3.
\27\ Environmental Defense Fund and Columbia Law School's Sabin
Center for Climate Change Law Pre-Conference Comments at 4.
\28\ CAISO Pre-Conference Comments at 1-3; California Public
Utilities Commission Pre-Conference Comments at 4; Oregon Public
Utilities Commission Pre-Conference Comments at 2-3; NYISO Pre-
Conference Comments at 4.
\29\ June 2, 2021, Tr. at 21-23 (Wesley Yeomans, Vice President
of Operations, NYISO).
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14. Some commenters discussed potential changes to the NERC
Reliability Standards to address planning and operational preparedness
for energy adequacy risks,\30\ contingencies related to extreme weather
events, and wide-area transmission planning and development
challenges,\31\ among others. In addition, participants advocated for
planning that reflects the new climate-change driven conditions, as the
expected impacts of climate change ``need to be baked into the rest of
your planning and development activities.'' \32\
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\30\ ISO-New England Inc. Pre-Conference Comments at 10.
\31\ Midcontinent Independent System Operator (MISO) Pre-
Conference Comments at 4-5, 14-17.
\32\ June 1, 2021 Tr. 136:18-21 (Neil Millar, Vice President,
Transmission Planning & Infrastructure Development, CAISO).
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15. Pacific Gas and Electric Company states that Reliability
Standard TPL-001-4 already requires transmission planners to evaluate
extreme events, but could benefit from providing further clarity on the
events to consider, as well as the extent to which investments can be
made to the grid to mitigate the identified issues for the given event
evaluated.\33\
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\33\ Pacific Gas and Electric Company Pre-Conference Comments at
19-20.
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16. Post-conference comments also addressed more directly the
potential reliability gaps in the existing set of Reliability
Standards, including Reliability Standard TPL-001-4. For example, MISO
argues that while current Commission-approved Reliability Standards
provide for the assessment of the impacts of extreme events that may
include climate-driven weather events, they do not include requirements
to mitigate consequences from such events.\34\ Similarly, PJM states
that Reliability Standard TPL-001-4 should be modified to specifically
account for extreme weather events by mandating regional extreme
weather design standards for transmission and generation operating
criteria.\35\ CAISO also states that Reliability Standard TPL-001 may
not serve as the best means to assess the threat and risk of extreme
weather events.\36\
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\34\ MISO Post-Conference Comments at 20.
\35\ PJM Post-Conference Comments at 21.
\36\ CAISO Post-Conference Comments at 10.
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17. NERC agrees that with proper planning, including consideration
not only of historic temperature averages but also consideration of
conditions during extreme weather events and the linkage between
critical infrastructures, the risks associated with extreme weather and
the changing resource mix can be mitigated.\37\ NERC agrees that
enhancements to the Reliability Standards could be beneficial. Some
examples of potential enhancements include requiring reliability
coordinators, balancing authorities, or planning coordinators to
determine the temperature to which plants in their respective areas
must weatherize; requiring reliability coordinators or balancing
authorities to develop seasonal emergency energy management plans, to
address conditions such as wildfires, extreme hot and cold
temperatures, and severe storms (i.e., hurricanes); requiring
reliability coordinators to develop a rolling three week emergency
energy management plan; and requiring balancing authorities to prepare
a seasonal energy management plan based on regional extreme weather
scenarios identified in NERC's seasonal assessments.\38\
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\37\ NERC Pre-Conference Comments at 6.
\38\ Id. at 15-16; NERC Post-Conference Comments at 5-7
(explaining that additional modifications to the Reliability
Standards may be appropriate as the resource mix is transformed to
one that is more sensitive to severe weather conditions, as some
types of severe weather events or conditions could result in the
loss of a substantial amount of resources due to fuel concerns).
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D. Cold Weather Reliability Standards

18. NERC and the Commission have begun to address the effects of
extreme cold weather on generating units, specifically focusing on
improved performance of generating units during cold weather
conditions. On August 24, 2021, the Commission approved revised
Reliability Standards to address some of the reliability risks posed by
extreme cold weather.\39\ Effective April 2023, those Reliability
Standards will, inter alia, require generators to implement plans for
cold weather preparedness and require the balancing authority,
transmission operator, and reliability coordinator to plan and operate
the grid reliably during cold weather conditions by requiring the
exchange of certain information related to the generator's capability
to operate under such conditions.\40\
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\39\ N. Am. Elec. Reliability Corp., 176 FERC ] 61,119 (2021).
The Commission approved proposed Reliability Standards EOP-011-2
(Emergency Preparedness and Operations); IRO-010-4 (Reliability
Coordinator Data Specification and Collection); and TOP-003-5
(Operational Reliability Data) (collectively, the Cold Weather
Reliability Standards).
\40\ Id. P 3.
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19. The proposed improvements to transmission planning discussed in
this NOPR and the requirements in the Cold Weather Reliability
Standards both work together to mitigate the reliability impact of
extreme weather events, such as the 2021 Cold Weather Event in Texas
and South-Central United States. To ensure reliability, transmission
planning should be considered in the context of generators' performance
and availability during extreme heat and cold events.

E. Reliability Standard TPL-001-4 (Transmission System Planning
Performance Requirements)

20. Transmission system planning refers to the evaluation of future
transmission system performance and creation of corrective action plans
that includes mitigation for extreme heat and cold events to remedy
identified deficiencies.\41\ The planning horizon associated with
transmission system planning covers near term (one to five years),
long-term (six to 10 years), and beyond.\42\
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\41\ NERC Glossary defines ``Planning Assessment'' as
``documented evaluation of future Transmission System performance
and Corrective Action Plans to remedy identified deficiencies.''
\42\ Id.
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21. Reliability Standard TPL-001-4, applicable to planning
coordinators and transmission planners, establishes minimum
transmission system planning performance requirements within the
identified planning horizon to plan a Bulk-Power System that will
operate reliably over a broad spectrum of system conditions and follow
a wide range of probable contingencies.\43\ Under Reliability Standard
TPL-001-4, and Reliability Standard TPL-001-5.1, Requirement R2, each
transmission planner and planning coordinator must prepare an annual
planning assessment of its portion of the Bulk-Power System based on
current or qualified past studies, document its assumptions, and
document the summarized results of the

[[Page 38025]]

steady state analyses, short circuit analyses, and stability
analyses.\44\ This planning assessment is required for both near-term
and long-term transmission planning horizons.\45\
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\43\ Reliability Standard TPL-001-4, Purpose.
\44\ Reliability Standard TPL-001-4/5.1, Requirement 2. Further,
steady-state analyses are a snapshot in time where load and system
conditions (e.g., generators, lines, facilities) are modeled as
constant (not as changing over time). The analysis will either solve
or diverge (not solved). See IEEE, Transactions on Power Systems,
Vol. 19, No. 2, (May 2004) (power system stability is the ability of
an electric power system, for a given initial operating condition,
to regain a state of operating equilibrium after being subjected to
a physical disturbance, with most system variables bounded so that
practically the entire system remains intact); see also, Kundur,
Prabha, Power System Stability and Control, McGraw Hill, at 26
(1994).
\45\ See Reliability Standard TPL-001-4, Requirement 2.1 (Near-
Term Transmission Planning Horizon) and Requirement R.2.2 (Long-Term
Transmission Planning Horizon).
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22. Requirements R3 and R4 of Reliability Standard TPL-001-4
require in part that planning coordinators and transmission planners
conduct steady state and stability analyses of pre-specified extreme
events and evaluate possible actions designed to reduce the likelihood
or mitigate the consequences and adverse impacts of the event(s), if
the analysis concludes that the pre-selected extreme events cause
cascading outages.
23. Table 1 of Reliability Standard TPL-001-4 includes a list of
examples of planning events for which specific studies may be required,
generally, based on the entity's own evaluation that such an event
could occur within its operating area. Section 3.a of Table-1, Steady
State & Stability Performance Extreme Events, states that steady state
analysis should be conducted for wide-area events affecting the
transmission system based on system configuration and how it can be
affected by events such as wildfires and severe weather (e.g.,
hurricanes and tornadoes). In addition, section 3.b serves as a catch-
all provision, stating that steady state analysis should be performed
for ``other events based upon operating experience that may result in
wide-area disturbances.''

III. The Need for Reform

A. Recent Events Show Changes in Weather Patterns Resulting in More
Extreme Heat and Cold Weather Events

24. Recent extreme weather-related events that spread across large
portions of the country over the past decade demonstrate the challenges
to transmission planning from extreme heat and cold weather patterns.
Since 2011, the country has experienced at least seven major extreme
heat and cold weather events; of these, four neared system collapse
(2011, 2013, 2018, and 2021 extreme cold weather events) if the
operators had not acted to shed load. The remaining three events (2014,
2020, 2021 extreme heat weather events) resulted in generation loss and
varying degrees of load shedding.
25. These extreme heat and cold events demonstrate a risk to
reliable operation of the Bulk-Power System. Below we discuss in detail
how recent extreme cold and heat events have demonstrated such risks,
including resource availability, limitations of the transmission system
locally and over a wide area, and limitations of interregional transfer
capabilities.
26. From February 1 to February 4, 2011, the southwest region of
the United States experienced unusually cold and windy weather,
referred to as the February 2011 Southwest Cold Weather Event. Low
temperatures during the period were in the teens for five consecutive
mornings and there were many sustained hours of below freezing
temperatures throughout Texas and New Mexico. Low temperatures in
Albuquerque, New Mexico ranged from 7 degrees Fahrenheit to minus seven
degrees Fahrenheit over the period, compared to a normal range of 51 to
26 degrees Fahrenheit. Temperatures in Dallas, Texas ranged from 19
degrees to 14 degrees Fahrenheit, compared to a normal range of 60 to
mid-to-upper 30s degrees Fahrenheit. Many cities in the region did not
see temperatures above freezing until February 4, 2011. In addition,
sustained high winds of over 20 mph produced severe wind chill factors.
The extreme weather conditions resulted in the loss of a significant
number of generators which occurred almost simultaneously, causing
ERCOT to shed load to prevent widespread, uncontrolled blackouts
throughout the entire ERCOT Interconnection.\46\ As a result,
approximately 4.4 million electric customers were affected over the
course of the event.\47\
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\46\ FERC and NERC Staff Report, Outages and Curtailments During
the Southwest Cold Weather Event of February 1-5, 2011, at 7 (Aug.
2011), <a href="https://www.ferc.gov/sites/default/files/2020-05/ReportontheSouthwestColdWeatherEventfromFebruary2011Report.pdf">https://www.ferc.gov/sites/default/files/2020-05/ReportontheSouthwestColdWeatherEventfromFebruary2011Report.pdf</a>. Load
shedding may be used to reduce an overload condition (such as when
thermal limits on a transmission line are exceeded), to recover from
an under-frequency condition, or to return voltage to a normal
level.
\47\ Id. at 1.
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27. Two years later, the Midwest and mid-Atlantic experienced
unseasonably hot weather from September 9 through September 11, 2013,
which led to emergency conditions in the PJM service area. During this
period, temperatures ranged from the upper 80s into the 90s Fahrenheit,
which in some areas like Cleveland translated into conditions of over
20 degrees above normal.\48\ As a result, demand for electricity
reached an all-time high for September within PJM's footprint.
Transmission owners tend to schedule maintenance outages during the
fall and spring, increasing the risk of system stress during periods of
weather-related high energy demand, such as occurred in September 2013.
PJM implemented controlled outages in a few constrained areas to
prevent uncontrolled blackouts over larger areas that could have
affected many more customers.\49\ In preparation for another day of
unseasonably high use of electricity, on September 11, PJM called for
voluntary demand response \50\ across much of its service area,
resulting in a 6,048 MW reduction in electricity demand, the largest
amount of demand response PJM had ever received. During the entire
event PJM shed 157 MW of load affecting approximately 45,000
customers.\51\
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\48\ PJM, Technical Analysis of Operational Events and Market
Impacts during the September 2013 Heat Wave, at 7, Figure 1, RTO
Temperatures (Dec. 23, 2013) (PJM Heat Wave Analysis), <a href="https://www.yumpu.com/en/document/read/40807126/20131223-technical-analysis-of-operational-events-and-market-impacts-during-the-september-2013-heat-wave">https://www.yumpu.com/en/document/read/40807126/20131223-technical-analysis-of-operational-events-and-market-impacts-during-the-september-2013-heat-wave</a>.
\49\ Id. at 4.
\50\ Under demand response programs, retail customers volunteer
and are paid to reduce their electricity use when requested.
\51\ PJM Heat Wave Analysis at 5.
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28. Another extreme event occurred the following year, in early
January 2014, when the Midwest, south central, and east coast regions
of the country experienced an extreme cold weather event known as the
polar vortex, referred to as the January 2014 Polar Vortex Cold Weather
Event, where extreme cold resulted in temperatures 20 to 30 degrees
Fahrenheit below normal.\52\ Some areas faced days that were 35 degrees
Fahrenheit or more below their normal temperatures. These extreme
temperatures resulted in record high electrical demand on January 6 and
again on January 7, 2014. During the January 2014 Polar Vortex Cold
Weather Event, the cold weather increased demand for natural gas, which
caused a significant amount of gas-fired generation to become
unavailable due to unavailability of the non-firm gas purchases they
relied on. The cold weather and issues from fuel combined for over
35,000 MW of generator outages during the height of the polar vortex

[[Page 38026]]

weather conditions.\53\ By employing communication tools, interruptible
load, demand-side management tools, and voltage reduction, balancing
authorities and load serving entities were mostly able to maintain
their operating reserve margins and serve firm load and only one
balancing authority was required to shed 300 MW of firm load. Many
outages, including a number of those in the southeastern United States,
were the result of temperatures that fell below a plant's design
basis.\54\
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\52\ NERC, Polar Vortex Review (Sept. 2014) (Polar Vortex
Review), <a href="https://www.nerc.com/pa/rrm/January%202014%20Polar%20Vortex%20Review/Polar_Vortex_Review_29_Sept_2014_Final.pdf">https://www.nerc.com/pa/rrm/January%202014%20Polar%20Vortex%20Review/Polar_Vortex_Review_29_Sept_2014_Final.pdf</a>.
\53\ Id. at 4.
\54\ Id. at iii.
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29. Further, in mid-January 2018, a large area of the south-central
region of the United States saw unusually cold weather, with
temperatures dropping from about five degrees Fahrenheit to as much as
27 degrees Fahrenheit below the normal daily minimums. Texas,
Louisiana, Arkansas, Oklahoma, Mississippi, Missouri, and other
neighboring states were all affected by the extreme cold weather, which
lasted from January 12 to January 19, 2018, known as the January 2018
South Central Cold Weather Event.\55\ The reliability coordinators in
MISO did not anticipate the numerous mitigation measures they would
need to take to maintain Bulk-Power System reliability at the peak of
the event (January 17, 2018), including transmission loading relief,
transmission reconfiguration, and the need to be prepared to shed firm
load in the event of an additional contingency in MISO South of 1,163
MW.\56\ Although the system remained stable on January 17, 2018, this
event represented a near miss of cascading outages.
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\55\ FERC and NERC Staff Report, The South Central United States
Cold Weather Bulk Electric System Event of January 17, 2018, at 6-8
(July 2019) (2018 Cold Weather Event Report), <a href="https://www.nerc.com/pa/rrm/ea/Documents/South_Central_Cold_Weather_Event_FERC-NERC-Report_20190718.pdf">https://www.nerc.com/pa/rrm/ea/Documents/South_Central_Cold_Weather_Event_FERC-NERC-Report_20190718.pdf</a>.
\56\ Id. at 12.
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30. Two years later, the western United States suffered another
intense and prolonged heatwave affecting many areas across the Western
Interconnection during a five-day period from August 14 through August
19, 2020 (August 2020 California Heatwave Event). With temperatures
between 15- and 30-degrees Fahrenheit above normal, many areas in the
western parts of the country broke daily heat records. Some areas in
the southwest posted record temperatures: Phoenix, Arizona reached a
record 115 degrees Fahrenheit. Even cities located further north had
similar temperature spikes, with Portland, Oregon, registering 102
degrees Fahrenheit. Because of these high temperatures, electricity
demand in the Western Interconnection reached a record high on August
18, 2020.\57\ On August 14 and 15, CAISO shed firm load to maintain the
operating reserves needed to maintain the reliability and security of
the Bulk-Power System. Several other entities reported being one
contingency away from needing to shed load as well.\58\
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\57\ Western Electricity Coordinating Council, August 2020
Heatwave Event Analysis Report, at 1-2 (Mar. 19, 2021) (2020 Heat
Event Report), <a href="https://www.wecc.org/Reliability/August%202020%20Heatwave%20Event%20Report.pdf">https://www.wecc.org/Reliability/August%202020%20Heatwave%20Event%20Report.pdf</a>.
\58\ Id. at 1.
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31. More recently, in February 2021, Texas and the South-Central
United States experienced the 2021 Cold Weather Event, the fourth cold-
weather-related event in the last ten years to jeopardize Bulk-Power
System reliability. Temperatures began to drop below freezing in Texas
and the Southwest Power Pool, Inc. (SPP) region on February 8, 2021,
but temperatures dropped even lower during the week of February 14,
reaching their nadir on February 15 and 16, 2021. Daily low
temperatures for February 15th were as much as 40 to 50 degrees lower
than average daily minimum temperatures for that day. In addition to
the arctic air, the cold front brought periods of freezing
precipitation and snow to large parts of Texas and the South Central
region, starting February 10, and extending into the week of February
14, 2021.\59\
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\59\ 2021 Cold Weather Event Report at 9, 12-13.
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32. This was the most devastating cold-weather-related event in the
last 10 years to impact Bulk-Power System reliability, with a combined
23,418 MW of manual firm load shed, the largest controlled firm load
shed event in U.S. history.\60\ The unplanned generation outages that
escalated during the event, 65,622 MW, were more than four times as
large as the previous largest event, in 2011 (14,702 MW).\61\ ERCOT
faced the greatest challenge due to the magnitude of unplanned
generating unit outages in its area, coupled with its limited ability
to import power to help offset generation shortfalls. Notably, the
entire ERCOT Interconnection has a maximum total import limitation of
only 1,220 MW, which limited ERCOT's ability to import electricity to
meet demand.\62\ In Texas alone, this event resulted in more than 4.5
million people losing power, cost the Texas economy between $80 to $130
billion, and caused at least 210 deaths.\63\ Had frequency in Texas
remained under its lowest point for an additional five minutes during
the peak of the event, approximately 17,000 MW of additional generation
would have tripped, potentially blacking out the entire ERCOT
Interconnection. In contrast to ERCOT, some regions, such as MISO and
SPP, had the ability to import power from the east, where weather
conditions were less severe, to make up for a large portion of their
generation shortfalls during the event. For example, PJM was exporting
an unprecedented amount of electricity into MISO and SPP, reaching over
15,700 MW of interregional transfers on February 15, 2021.\64\
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\60\ Id. at 9.
\61\ Id.
\62\ Id. at 127 n.197.
\63\ Id. at 10.
\64\ PJM Post-Conference Comments at 17-18; 2021 Cold Weather
Event Report at 229 n. 355. Interregional transfer capability allows
an entity in one region with available energy to assist one or more
entities in another region that is experiencing an energy shortfall
due to the extreme weather event.
---------------------------------------------------------------------------

33. Finally, in June 2021 the Pacific Northwest experienced another
record-breaking heat wave, referred to as June 2021 the Pacific
Northwest Heatwave. During the event, Seattle set an all-time record
high temperature of 104 degrees Fahrenheit on June 27, 2021, while
Portland had two back-to-back all-time records, on June 26 and 27,
2021, where temperatures reached 108- and 112-degrees Fahrenheit,
respectively.\65\ While such events are still rare in today's climate,
researchers believe such events are likely to become more common in the
future.\66\
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\65\ Climate Signals, Northwest Pacific Heat Wave June 2021
(Oct. 2021), <a href="https://www.climatesignals.org/events/northwest-pacific-heat-wave-june-2021#/more">https://www.climatesignals.org/events/northwest-pacific-heat-wave-june-2021#/more</a>.
\66\ Sjoukje Y. Philip, Sarah F. Kew et al., Rapid attribution
analysis of the extraordinary heatwave on the Pacific Coast of the
US and Canada (June 2021), at 199, <a href="https://www.worldweatherattribution.org/wp-content/uploads/NW-US-extreme-heat-2021-scientific-report-WWA.pdf">https://www.worldweatherattribution.org/wp-content/uploads/NW-US-extreme-heat-2021-scientific-report-WWA.pdf</a>.
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34. While these wide-area extreme events may not occur every year,
their frequency and magnitude are expected to increase. NOAA's data and
analyses show an increasing trend in extreme heat and cold events,\67\
and the U.S. Environmental Protection Agency climate change indicators
also show upward trends in heatwave frequency, duration, and
intensity.\68\ NOAA states that climate change is also driving more
compound events, which are multiple extreme events occurring
simultaneously or successively, such as concurrent heat waves and
droughts,

[[Page 38027]]

and more extreme heat conditions in cities.\69\
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\67\ NOAA website, Climate Data Online (NOAA website, Climate
Data Online), <a href="https://www.ncdc.noaa.gov/cdo-web/">https://www.ncdc.noaa.gov/cdo-web/</a>.
\68\ EPA Climate Change Indicators.
\69\ NOAA website, Climate Data Online.
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35. With respect to extreme cold, NOAA explains that accelerated
arctic warming is likely contributing to the increasing frequency of
Arctic polar vortex-stretching events that deliver extreme cold to the
United States and Canada, including the winter 2021 Texas cold
wave.\70\ NOAA climate data indicates that the occurrence of
significant cold weather events is trending higher nationwide.\71\
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\70\ NOAA, Climate Program Office, Research Links Extreme Cold
Weather in the United States to Arctic Warming, <a href="https://cpo.noaa.gov/Interagency-Programs/NIHHIS/ArtMID/6409/ArticleID/2369/Research-Links-Extreme-Cold-Weather-in-the-United-States-to-Arctic-Warming?msclkid=f9ad03bcc7c911ecba22ebf3e1ead5d9">https://cpo.noaa.gov/Interagency-Programs/NIHHIS/ArtMID/6409/ArticleID/2369/Research-Links-Extreme-Cold-Weather-in-the-United-States-to-Arctic-Warming?msclkid=f9ad03bcc7c911ecba22ebf3e1ead5d9</a>.
\71\ NOAA website, Climate Data Online.
---------------------------------------------------------------------------

36. As discussed, the recent extreme heat and cold events have had
a significant impact on the reliability of the Bulk-Power System.
However, the potential impact of widespread extreme heat and cold
events on the reliability of the Bulk-Power System can be modeled and
studied in advance as part of near-term and long-term transmission
system planning. Transmission planners could use the studies to develop
transmission system operational strategies or corrective action plans
with mitigation that could be deployed prior to and in preparation for
extreme heat and cold events. Examples of such corrective action plans
include planning for additional contingency reserves or implementing
new energy efficiency programs to decrease load,\72\ planning for
additional interregional transfer capability, transmission switching/
reconfiguration, or adjusting transmission and generation maintenance
outages based on longer-lead forecasts. Therefore, given the urgency of
addressing the negative impact of extreme weather on the reliability of
the Bulk-Power System, the proposed directives to NERC in this NOPR aim
to improve system planning specifically for extreme heat and cold
weather events.
---------------------------------------------------------------------------

\72\ Contingency reserves would only contribute to a corrective
action plan to the extent that they are expected to perform during
the applicable modeled extreme weather event(s) and thereby
contribute to meeting the applicable performance criteria.
Accordingly, if for instance, extreme cold is anticipated to cause
fuel unavailability for the applicable area, a corrective action
plan would need to account for such limitations.
---------------------------------------------------------------------------

B. NERC Reliability Standards Do Not Require Planning To Minimize the
Increasing Reliability Risks Associated With Anticipated Extreme Heat
and Cold Weather Events

37. The currently effective Reliability Standard TPL-001-4 and the
to-be-effective TPL-001-5.1, Requirements R3 and R4 require steady
state and stability analyses to be performed for extreme events
``listed in Table 1 that are expected to produce more severe system
impacts.'' Table 1, Steady State & Stability Performance Extreme
Events, under the Steady State analysis, sections 3.a.iii and 3.a.iv
lists wildfires and severe weather (e.g., hurricanes and tornadoes) as
potential events that could be studied. However, neither Requirements
R3 or R4, nor the associated Table 1 specifically require steady state
analyses for extreme heat and cold conditions to be completed as part
of the transmission planner's or planning coordinator's planning
assessment. Finally, Table 1, provisions 2.f (stability) and 3.b
(steady state), require the responsible entities to study events based
on operating experience that may result in a wide-area disturbance, but
they do not specify the study of extreme heat or cold conditions.
38. System planning measures alone will not eliminate the
reliability risk associated with extreme heat and cold events. However,
system planning will limit the impact of such events and reduce the
risk to the reliability of the Bulk-Power System, which prior events
demonstrate is significant.
39. The country experienced wide-spread cold weather events in
2011, 2014, 2018, and 2021. With the exception of the January 2018
South Central Cold Weather Event, planned and unplanned generating unit
outages caused energy emergencies and triggered the need for firm load
shed. As evidenced by the last cold weather event in 2021, where
generation loss and loss of load were the most extreme, it becomes
increasingly more important to consider changes in transmission
planning. Although during the January 2018 South Central Cold Weather
Event the system remained stable, the 2018 Cold Weather Event Report
addressing this specific event recommended that MISO and other
reliability coordinators perform voltage stability analyses when under
similarly constrained conditions, benchmark planning and operations
models against actual events that strained the system, perform periodic
impact studies to identify which elements in the adjacent reliability
coordinators' systems have the most impact on their own systems, and
perform drills with entities involved in load shedding to prepare to
execute load-shedding for maintaining reserves while at the same time
alleviating severe transmission conditions.\73\
---------------------------------------------------------------------------

\73\ 2018 Cold Weather Event Report at 12-13.
---------------------------------------------------------------------------

40. Having the necessary data and performing modeling in advance of
extreme cold temperatures could allow transmission planners and
operators to assess the potential impact of an event to identify
corrective actions that could be taken well in advance of the event.
Such action could include ensuring generators have winterized their
equipment, scheduling fewer planned outages of generating units and
transmission lines, and endeavoring to maintain transmission ties
intact to: (1) permit maximum transfers to an area experiencing a
deficiency in generation; (2) minimize the possibility of cascading
outages; and (3) assist in restoring operation to normal.\74\ While
these corrective action plans may not fully mitigate the potential
impact of these events, they could minimize the impact and reduce
system restoration time.
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\74\ ERCOT, Nodal Operating Guide, at 137 (Jan. 1, 2022),
<a href="https://www.ercot.com/files/docs/2021/12/21/Nodal%20Operating%20Guide.pdf">https://www.ercot.com/files/docs/2021/12/21/Nodal%20Operating%20Guide.pdf</a>.
---------------------------------------------------------------------------

41. Past experience can inform how steady state and stability
analyses should model transmission and generator outages, including
availability of wind, natural gas, and other resources sensitive to
extreme cold conditions. For example, the February 2021 cold weather-
related outages in Texas and the south-central United States caused
4,125 outages/derates of generating units (i.e., approximately 456 GW
during event in total event area). Of the total generation losses, 59%
were gas-fired generating units due to fuel issues \75\ and a pipeline
equipment failure, and 27% were wind generation due to blade icing.\76\
---------------------------------------------------------------------------

\75\ Fuel issues included 87% natural gas fuel supply issues
(decreased natural gas production, terms and conditions of natural
gas commodity and transportation contracts, low pipeline pressure
and other issues) and 13% other fuel issues.
\76\ 2021 Cold Weather Event Report at 163.
---------------------------------------------------------------------------

42. While heat events have different planning challenges, they also
present a serious risk to the Bulk-Power System and often require
operators to shed load to maintain system stability. The recent extreme
heat events resulted in a variety of reliability issues such as
controlled rolling blackouts and transmission congestion. During the
August 2020 California Heatwave Event, wind production was low during
the evenings, and solar generation was declining during the peak demand
hours, leading to reserve shortages.

[[Page 38028]]

Similar to Texas, California relies on wind and solar generation to
meet normal peak day demand, but wind and solar generation were largely
unavailable. Steady state and stability analyses of study cases modeled
to reflect past extreme conditions as well as modeling of availability
of generation resources during extreme heat conditions in the planning
process could have better prepared the transmission operators for such
conditions.
43. Past extreme heat and cold events discussed above demonstrate
the importance of assessing resource and reserve requirements under
extreme heat and cold weather conditions. Developing and using extreme
heat and cold weather scenarios in planning analyses will help to
identify the potential risks that extreme events may pose to the Bulk-
Power System. Based on the risks identified, appropriate mitigations or
corrective action plans such as requiring additional reserves and
transfer capability can be developed and deployed to address the risks
and specify what should be planned for the longer term to ensure the
availability of electricity in real time.
44. NERC recognizes that extreme events present a reliability risk
and there are opportunities to improve the transmission planning
processes. Following the 2021 extreme cold weather event, NERC issued a
level 2 NERC Alert to industry on cold weather preparations for extreme
weather events with five recommendations to assist reliability
coordinators, balancing authorities, transmission operators, and
generator owners in preparing for the winter season. NERC's level 2
Alerts recommend but do not mandate registered entities to take
specific actions.\77\ The Alert recommended seasonal operating plans
for the upcoming winter season, which would include plans to utilize
additional transmission capacity, consideration of the import
capability of the system and resource availability constraints on
external systems, and load forecasting practices that consider extreme
events, among other recommendations.\78\ The NERC Alert did not include
any recommendations concerning long-term transmission planning.
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\77\ NERC, About Alerts, <a href="https://www.nerc.com/pa/rrm/bpsa/Pages/About-Alerts.aspx">https://www.nerc.com/pa/rrm/bpsa/Pages/About-Alerts.aspx</a>.
\78\ NERC, Alert R-2021-08-18-01 Extreme Cold Weather Events
(Aug. 18, 2021), <a href="https://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/NERC%20Alert%20R-2021-08-18-01%20Extreme%20Cold%20Weather%20Events.pdf">https://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/NERC%20Alert%20R-2021-08-18-01%20Extreme%20Cold%20Weather%20Events.pdf</a>.
---------------------------------------------------------------------------

45. In addition, in 2021 NERC formed the Energy Reliability
Assessment Task Force (ERATF) to assess risks associated with unassured
energy supplies, including the inconsistent output from variable
renewable energy resources, fuel location, and volatility in forecasted
load, which can result in insufficient amounts of energy on the system
to serve electrical demand.\79\ The ERATF uses resource adequacy models
to address energy availability concerns related to the operations
planning horizon (i.e., one day to one year) and near-term planning
horizon (i.e., one to five years).\80\ In December of 2021, the ERATF
prepared a draft Standard Authorization Request (SAR) and based on the
comments to the SAR, two SARs were created: a planning SAR and an
operations/operations planning SAR, aiming to create or modify NERC
Reliability Standards across the operations/operational planning time
horizon and the planning time horizon. To discuss this latest update
with industry members, NERC held an informational Webinar on May 19,
2022, and the two SARs were scheduled for committee consideration on
June 8, 2022.\81\
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\79\ NERC, Energy Reliability Assessment Task Force website,
(ERAFT website), https://www.nerc.com/comm/RSTC/Pages/
ERATF.aspx#:~:text=%E2%80%8B%E2%80%8B%E2%80%8B%E2%80%8B%E2%80%8B,insu
fficient%20amounts%20of%20energy%20on.
\80\ NERC Post-Technical Conference Comments at 7.
\81\ NERC, Informational Webinar: Industry Webinar Energy
Reliability Assessment Task Force Update on the Revised SARs (May
19, 2022), <a href="https://www.nerc.com/pa/RAPA/Lists/RAPA/DispForm.aspx?ID=480">https://www.nerc.com/pa/RAPA/Lists/RAPA/DispForm.aspx?ID=480</a>; NERC, Reliability and Security Technical
Committee Meeting Agenda, SAR Draft.
---------------------------------------------------------------------------

46. While these ongoing efforts by NERC and industry members are
intended to improve system reliability, they do not directly address
the gap in transmission planning related to extreme heat and cold
weather. NERC acknowledges that heat and cold events have effects on
the grid but at this time has not determined that modifications to TPL-
001-5.1 are needed to address extreme weather events.\82\
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\82\ NERC, 2021 ERO Reliability Risk Priorities Report, Risk
Profile 2, at 26 (July 2021), <a href="https://www.nerc.com/comm/RISC/Documents/RISC%20ERO%20Priorities%20Report_Final_RISC_Approved_July_8_2021_Board_Submitted_Copy.pdf">https://www.nerc.com/comm/RISC/Documents/RISC%20ERO%20Priorities%20Report_Final_RISC_Approved_July_8_2021_Board_Submitted_Copy.pdf</a>; see also NERC Post-Conference Comments at 5
(referencing Reliability Standard TPL-001-4, NERC states that
``[w]ith respect to extreme weather more generally, NERC staff will
continue to examine the Reliability Standards to determine if other
modifications are needed.'').
---------------------------------------------------------------------------

IV. Proposed Directives

47. We preliminarily find that a reliability gap exists in
Reliability Standard TPL-001-5.1 with respect to a lack of a long-term
planning requirement for extreme heat and cold weather events.
Accordingly, pursuant to section 215(d)(5) of the FPA, we propose to
direct that NERC develop modifications to Reliability Standard TPL-001-
5.1 to require: (1) development of benchmark planning cases based on
information such as major prior extreme heat and cold weather events or
future meteorological projections; \83\ (2) planning for extreme heat
and cold events using steady state and transient stability analyses
expanded to consider a range of extreme heat and cold weather scenarios
(i.e., sensitivities to be applied to the benchmark base case(s)),
including the expected resource mix's availability during extreme heat
and cold weather conditions, and including the broad area impacts of
extreme heat and cold weather; and (3) corrective action plans that
include mitigation for any instances where performance requirements for
extreme heat and cold events are not met. We further elaborate on the
substance of these proposed directives below. In proposing to direct
NERC to develop modifications to Reliability Standard TPL-001-5.1, we
are not proposing specific requirements; we are identifying concerns
that we believe should be addressed. NERC may propose to develop new or
modified Reliability Standards that address these concerns in an
equally efficient and effective manner as the requirements proposed in
this paragraph; however, NERC must explain how its proposal addresses
the Commission's concerns.\84\
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\83\ For instance, a benchmark event could be constructed based
on data from a major prior extreme heat or cold event, with
adjustments if necessary to account for the fact that future
meteorological projections may estimate that similar events in the
future are likely to be more extreme.
\84\ Order No. 693, 118 FERC ] 61,218 at P 186; Reliability
Standards for Physical Sec. Measures, 146 FERC ] 61,166 at P 13.
---------------------------------------------------------------------------

48. We further propose to direct NERC to submit modifications to
Reliability Standard TPL-001-5.1 within one year of the effective date
of a final rule in this proceeding with compliance obligations for all
proposed new or modified Reliability Standards beginning no later than
12 months from the date of Commission approval of the modified
Reliability Standard. Finally, we invite comments on whether to also
direct NERC to address in Reliability Standard TPL-001-5.1 other
extreme weather-related events.
49. Below we provide additional context for these three proposed
directives and describe reliability concerns and potential options for

[[Page 38029]]

consideration that we believe would address these concerns.

A. Develop Benchmark Planning Cases Based on Major Prior Extreme Heat
and Cold Weather Events

50. As part of its revisions to Reliability Standard TPL-001-5.1,
we are proposing to direct that NERC develop requirements that address
the types of extreme heat and cold scenarios the responsible entities
are required to study. Reliability Standard TPL-001-5.1 does not
require any specific approach to studying extreme heat and cold events
and we are concerned that, without specific requirements describing the
types of heat and cold scenarios that entities must study, the standard
may not provide a significant improvement upon the status quo.
51. To accomplish this, the modified Reliability Standard developed
by NERC should include benchmark events that responsible entities must
study, as well as guidelines regarding which range of sensitivities
must be applied to these benchmark event scenarios. Such benchmark
events should be based on prior events (e.g., February 2011 Southwest
Cold Weather Event, January 2014 Polar Vortex Cold Weather Event) and/
or constructed based on meteorological projections, as described above.
In addition to providing valuable case study information to be applied
to possible comparable future events, these events will also serve as a
basis for effectively using assets and resources. Once developed, the
results of the benchmark events studies could be applied to determine
the limitations of the transmission system locally and over a wide-
area, and to understand resource availability and potential firm load
shedding requirements under stressed conditions.
52. While extreme weather risks may vary from region to region and
change over time, it is important that transmission planners and
planning coordinators likely to be impacted by the same types of
extreme weather events use consistent benchmark events. In determining
an appropriate benchmark event, NERC should consider approaches to
provide a uniform framework while still recognizing regional
differences. For example, NERC could define benchmark events around a
projected frequency (e.g., 1-in-50-year event) or probability
distribution (95th percentile event),
53. We propose to provide NERC with flexibility in defining one or
more appropriate benchmark events. For example, one approach could be
for NERC to develop the common benchmark event or events through the
standards development process and include the relevant parameters of
the benchmark event or events in the modified reliability standard.
Another approach could be to include in the modified standard the
primary features of the benchmark event or events (e.g., the expected
occurrence such as one-in-50 years) while designating another set of
entities, such as the Regional Entities, reliability coordinators, or
even NERC itself, as responsible for periodically updating key aspects
of the benchmark events based on the most up-to-date data. Such a
method for developing benchmark events and scenarios could establish a
common design basis across the industry while still recognizing
regional differences in climate and weather patterns. We seek comment
on whether, and to what extent, it may be appropriate to allow
designated entities to periodically update key aspects of the benchmark
events.
54. As discussed further below, establishing one or more benchmark
events should form the basis for sensitivity analysis, which provide
better visibility into the actual system conditions during extreme heat
and cold. For example, sensitivity analysis could include analysis of
simultaneously varying generation dispatch (e.g., wind, solar, natural
gas, and other fuel generation availability), system transfers, and
load, which have been observed during prior extreme heat and cold
events.
55. In addition to establishing requirements that address the
extreme heat and cold scenarios that responsible entities are required
to study, NERC could also establish measures of system performance
(stability, voltage, thermal limits, etc.) to determine whether the
responsible entities must implement a corrective action plan.
Performance requirements are a corollary to study requirements--without
clear performance requirements, the obligations on responsible entities
to mitigate issues with system performance may be unclear. Moreover,
performance requirements are an integral part of the existing
Reliability Standard TPL-001-5.1.\85\ Accordingly, NERC should
incorporate performance requirements for extreme heat and cold
conditions when modifying TPL-001-5.1.
---------------------------------------------------------------------------

\85\ See Reliability Standard TPL-001-5.1 (Transmission System
Planning Performance Requirements), Requirements R1 through R8.
---------------------------------------------------------------------------

56. In establishing any proposed performance requirements, NERC
should seek to prevent system instability, uncontrolled separation, and
cascading outages. While load shedding could still occur during extreme
heat and cold events to prevent instability, uncontrolled separation,
and cascading, it should be minimized as much as possible. Developing
benchmark events and associated corrective actions to be deployed prior
to and during the event, would result in better system performance in
real time.

B. Transmission System Planning for Extreme Heat and Cold Weather
Events

57. As discussed above, we propose to direct that NERC develop
modifications to Reliability Standard TPL-001-5.1 to require planning
for extreme heat and cold events using steady state and transient
stability analyses expanded to consider a range of extreme heat and
cold weather scenarios including the expected resource mix's
availability during extreme heat and cold weather conditions, and
including the broad area impacts of extreme heat and cold weather. In
this section, we discuss six topics which NERC would be required to
address in a modified Reliability Standard pursuant to the proposed
directive: (1) steady state and transient stability analysis; (2)
transmission planning studies of wide area issues; (3) concurrent
generator and transmission outages; (4) sensitivity analysis; (5)
consideration of modifications to the traditional planning approach;
and (6) coordination among planning coordinators and transmission
planners and sharing of results. We note that a range of methods/
approaches could satisfy the Commission's directive with regard to
issues (3) through (6). NERC would retain flexibility with regard to
how to address these topics, so long as it incorporates them into its
proposed solution. To better inform our directive to NERC in the final
rule, we invite comments on these matters.
1. Steady State and Transient Stability Analyses
58. To maintain and improve the reliability of the Bulk-Power
System, it is important to conduct both steady state and stability
analyses for extreme heat and cold events as part of transmission
planning studies. As discussed above, steady state and stability
analyses of study cases modeled to reflect past and forecasted extreme
heat and cold conditions would better prepare transmission operators
for such conditions. Further, this approach is consistent with
Reliability Standard TPL-001-5.1, which requires both steady state and
stability analyses for extreme events identified in Table 1 of the
Standard. Performing these studies in the long-term planning horizon
time frame (i.e., five to 10 years) will provide an adequate lead time
for entities to

[[Page 38030]]

develop and implement corrective action plans to reduce the likelihood
or mitigate the consequences and adverse impacts of such events.
59. A steady-state analysis or assessment is based on a snapshot in
time where bulk-electric system facilities such as generators,
transmission lines, transformers, etc. are modeled as fixed and load is
modeled as a constant. The steady state analysis assesses the ability
of the system to deliver electricity to load within the ratings and
constraints of generators and transmission lines. It also includes a
contingency analysis to predict electrical system conditions when
elements are removed from the base case.\86\
---------------------------------------------------------------------------

\86\ NERC, Compliance Implementation Guidance Real-time
Assessment Quality of Analysis, at 3 (May 2019), <a href="https://www.nerc.com/pa/comp/guidance/EROEndorsedImplementationGuidance/TOP-010-1">https://www.nerc.com/pa/comp/guidance/EROEndorsedImplementationGuidance/TOP-010-1</a>(i)%2520R3%2520and%2520IRO-018-1(i)%2520R2%2520-
%2520RTA%2520Quality%2520of%2520Analysis%2520(OC).pdf.
---------------------------------------------------------------------------

60. Transient stability or dynamic studies add to the steady state
analyses simulate the time-varying characteristics of the system during
a disturbance that occurs during an extreme heat or cold weather event.
They are time-domain analyses that assess angular stability, voltage
stability, and frequency excursions.\87\ Transient angular stability is
the ability of interconnected synchronous machines of a power system to
remain in synchronism after being subjected to a disturbance (i.e.,
fault, sudden loss of load, and generation tripping).\88\ Transient
voltage stability refers to the ability of a power system to maintain
steady voltages at all buses in the system after being subjected to a
disturbance.\89\
---------------------------------------------------------------------------

\87\ Indian Institute of Technology Patna, Power System Dynamics
and Control, at 1, (Power System Dynamics), https://www.iitp.ac.in/
~siva/2022/ee549/Introduction_Power_System_Stability.pdf.
\88\ Id. at 3.
\89\ Id. at 15.
---------------------------------------------------------------------------

61. While we recognize dynamic studies can be more resource
intensive to perform, we believe that the consideration of both types
of studies is important to understand the potential impacts of extreme
heat and cold weather events. We believe the consideration of dynamic
studies is particularly important given the changing resource mix and
the need to understand the dynamic behavior of both traditional
generators as well as variable energy resources (VER) (mainly wind and
photovoltaic solar).
62. To that end, we seek comments on whether planning coordinators
and transmission planners should include contingencies based on their
planning area and perform both steady state and transient stability
(dynamic) analyses using extreme heat and cold cases. We are inviting
comments on the following topics regarding planning for extreme heat
and cold weather conditions: (1) the set of contingencies planning
coordinators and transmission planners must consider; (2) required
analyses to ensure system stability, frequency excursion and angular
deviations caused as a result of near simultaneous outages or common
mode failures of VERs; and (3) the role of demand response under such
scenarios.
63. Finally, we emphasize the continued importance of ensuring that
entities responsible for performing assessments under TPL-001-5.1 are
able to obtain the necessary data. Currently, the data for steady-
state, dynamic, and short circuit modeling can be obtained pursuant to
Reliability Standard MOD-32-1, Requirement 1 (Data for Power System
Modeling and Analysis), which is referenced in Reliability Standard
TPL-001-5.1. Specifically, Reliability Standard MOD-32-1 allows
planning coordinators and transmission planners to request data from
the generator owners and transmission owners, which are obligated to
provide the specified data.\90\ Consistent with the existing standards,
we believe it is important for NERC to ensure that registered entities
responsible for performing studies of extreme weather are able to
access the data necessary to complete such studies. Accordingly, we
seek comment on whether the existing Reliability Standards are
sufficient to ensure that responsible entities performing studies of
extreme heat and cold weather conditions have the necessary data, or
whether the Commission should direct additional changes pursuant to FPA
215(d)(5) to address that issue.
---------------------------------------------------------------------------

\90\ Reliability Standard MOD-032-1, Requirements R1 and R2.
---------------------------------------------------------------------------

2. Transmission Planning Studies of Wide-Area Events
64. As discussed above, our proposed directive would include
modifications to TPL-001-5.1 to require transmission planning studies
that consider the broad area impacts of extreme heat and cold weather.
The effects of extreme weather events on the reliable operation of the
Bulk-Power System can be widespread, potentially causing simultaneous
loss of generation and increased transmission constraints within and
across regions. The studies required by TPL-001-5.1, however, have
traditionally focused on local planning and typically do not address
the issues caused by wide-area extreme heat and cold weather events on
a regional or interconnection scale.\91\
---------------------------------------------------------------------------

\91\ June 1, 2021 Tr. 153: 2-9. (Frederick Heinle, Assistant
People's Counsel, Office of the People's Counsel for the District of
Columbia).
---------------------------------------------------------------------------

65. Reliability Standard TPL-001-5.1 does not contemplate the
consideration of impacts from wide-area events \92\ that may impact
multiple planning coordinators simultaneously; in contrast, TPL-001-5.1
only requires identifying and evaluating selected wide-area events
resulting from conditions such as loss of a large gas pipeline into a
region or multiple regions that have significant gas-fired generation,
and does not specify studying potential issues resulting from extreme
heat and cold.\93\
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\92\ Reliability Standard TPL-001-5.1, Table 1, Steady State &
Stability Performance Extreme Events, uses the term ``wide area
events'' to refer to such things as loss of two generating stations
resulting from conditions including severe weather or wildfires,
distinguishing such events from ``local area events'' affecting the
transmission system, which may involve the isolated loss of a
transmission tower, substation, or generating station.
\93\ Reliability Standard TPL-001-5.1, Table 1, Steady State &
Stability Performance Extreme Events, Section 3(a)(i).
---------------------------------------------------------------------------

66. Failure to study the wide-area impact of extreme heat or
extreme cold weather conditions when an entity conducts transmission
planning, could result in reliability issues that simultaneously affect
multiple regions to remain undetected in the long-term planning
horizon. This, in turn, could lead to otherwise avoidable situations
where the system is one contingency away from voltage collapse and
uncontrolled blackouts.
67. Based on prior events, we preliminarily find that it is
appropriate that the study criteria for extreme heat and cold events
include a consideration of wide-area conditions affecting neighboring
regions and their impact on one planning area's ability to rely on the
resources of another region during the weather event. To identify
opportunities for improved wide-area planning studies and coordination,
we seek comment on: (1) whether wide-area planning studies should be
defined geographically or electrically; (2) which entities should
oversee and coordinate the wide-area planning models and studies (e.g.,
reliability coordinators, regional planning groups); (3) which entities
should have responsibility to address the results of the studies, and
how they should communicate those results among transmission planners;
and (4) how to develop corrective action plans that mitigate issues
that require corrective action by, and coordination among, multiple
transmission owners.

[[Page 38031]]

3. Study Concurrent Generator and Transmission Outages
68. Concurrent outages occur nearly simultaneously in different
planning areas due to the same extreme weather events, such as the
unplanned generator outages associated with the major extreme heat and
cold events discussed above. Generation resources that are sensitive to
severe weather conditions may cease operation during extreme heat and
cold events, thus contributing to wide-area concurrent outages. In
addition, the performance of power transformers, transmission lines,
and other equipment degrades under extreme heat and may have to come
out of service. Extreme heat could lead to significant derating,
reduced lifetime, and even possible failures of power transformers,
while extreme cold could lead to at least temporary facility
transmission outages.\94\
---------------------------------------------------------------------------

\94\ MIT News, Preventing the Next Blackout (Dec. 5, 2017),
<a href="https://news.mit.edu/2017/mit-study-climate-change-effects-large-transformers-1205">https://news.mit.edu/2017/mit-study-climate-change-effects-large-transformers-1205</a>; see also IEEE Standard C57.91-2011, Table 2; IEEE
Standard C57.91-2011, Table 3; 2021 Cold Weather Event Report at 95.
---------------------------------------------------------------------------

69. Therefore, modeling the loss of these generators and
transmission equipment during extreme heat and cold weather events
would allow planners to determine the effects of potential concurrent
transmission and generator outages and study the feasibility (i.e.,
availability and deliverability) of external generation resources that
could possibly be imported to serve load during such events, thereby
minimizing the potential impact of extreme heat and cold events on
customers.\95\ Modeling concurrent generator and transmission outages
would also allow planners to better identify appropriate solutions to
be incorporated into corrective action plans.
---------------------------------------------------------------------------

\95\ The Cold Weather Reliability Standards referenced supra
take effect in April 2023, and are expected to improve generating
unit performance and help alleviate some of the unsustainable levels
of generation outages seen during extreme events. Improved
transmission planning alone cannot overcome the challenges
associated with generator outages during extreme events. Therefore,
both the Cold Weather Reliability Standards and this proposal to
improve transmission planning are necessary for the Bulk Power
System to perform reliably in the face of future extreme weather
events.
---------------------------------------------------------------------------

70. Extreme cold effects on generators vary by generator type,
cooling systems, and fuel sources.\96\ Transmission planners commonly
assume that the failures of individual generators are independent. This
understanding, however, is inconsistent with documented historical
events, that show multiple coincident outages due to the same cause.
For instance, the 2021 extreme cold event demonstrated the limitations
of such an assumption. Between February 8 and February 20, 2021,
approximately 44% of generator outages were caused by freezing issues,
31% by fuel issues related to extreme cold weather, and another 21%
were caused by mechanical/electrical failures related to cold
weather.\97\ Meanwhile, wind turbine generators were the second largest
share of individual generating units after gas-fired generators that
suffered freezing issues in the southern part of SPP and Texas, as
temperatures dropped well below zero degrees Fahrenheit.\98\
Transmission facilities were also affected in the short-term, as
transmission operators managed to return them into service.\99\
Likewise, the 2018 Cold Weather Event Report revealed that there is a
high correlation between generator outages and cold temperatures,
indicating that as temperatures decrease, unplanned generator outages
and derates increase.\100\
---------------------------------------------------------------------------

\96\ Polar Vortex Review at 12.
\97\ 2021 Cold Weather Event Report at 15-16.
\98\ Id. at 75.
\99\ Id. at 95.
\100\ 2018 Cold Weather Event Report at 80.
---------------------------------------------------------------------------

71. Similarly, extreme heat impacts on generators vary by generator
type, and the common implication is a reduction in the overall
generation capacity throughout the wide area affected by the heat
event.\101\ Generally, extreme heat poses more of a threat to the
functioning of a solar panel than extreme cold. As temperatures
increase above 77 degrees Fahrenheit, which is a standard test
condition, solar panels generate less voltage and become less
efficient,\102\ producing less power for a given amount of solar energy
depending on the solar panel temperature coefficient.\103\ For example,
during the 2020 heat event in California, wind and solar generation
were largely unavailable.\104\ While extreme cold temperatures on clear
days would not negatively impact energy output. Also, solar panels are
built to be waterproof to protect the electronic components against
heavy rain and to withstand hailstorms. However, snow,\105\ ice
accumulation, or cloud cover that commonly accompany extreme cold
weather could prevent the panels from receiving as much sunlight, which
would limit their power production and efficiency.
---------------------------------------------------------------------------

\101\ Department of Energy, U.S. Energy Sector Vulnerabilities
to Climate Change and Extreme Weather, Department of Energy, at 19-
22 (July 11, 2013), <a href="https://www.energy.gov/sites/default/files/2013/07/f2/20130716-Energy%20Sector%20Vulnerabilities%20Report.pdf">https://www.energy.gov/sites/default/files/2013/07/f2/20130716-Energy%20Sector%20Vulnerabilities%20Report.pdf</a>
(listing the impacts of increased ambient air temperature on the
various types of generators).
\102\ IEEEXplore, International Conference on Current Trends in
Computer, Electrical, Electronics and Communication (ICCTCEEC-2017),
Effect of Temperature on Performance of Solar Panels--Analysis,
<a href="https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=8455109">https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=8455109</a>.
\103\ Temperature coefficient describes the percentage of power
output that is lost by a specific solar panel as the temperature
rises above 77 degrees Fahrenheit.
\104\ 2020 Heat Event Report at 11.
\105\ A recent study by Sandia National Labs identified snow
events as causing the largest performance reductions at solar
facilities. See Nicole D. Jackson & Thushara Gunda, Evaluation of
Extreme Weather Impacts on Utility-Scale Photovoltaic Plant
Performance in the United States, 302, Applied Energy, 1:7 (2021),
<a href="https://www.researchgate.net/publication/353944206_Evaluation_of_extreme_weather_impacts_on_utility-scale_photovoltaic_plant_performance_in_the_United_States">https://www.researchgate.net/publication/353944206_Evaluation_of_extreme_weather_impacts_on_utility-scale_photovoltaic_plant_performance_in_the_United_States</a>.
---------------------------------------------------------------------------

72. Requiring transmission planners and planning coordinators to
study concurrent generator and transmission failures under extreme heat
and cold events is one way to address the reliability gap. Accounting
for concurrent outages in planning studies would provide a more
realistic assessment of system conditions (i.e., updated conditions
based on historic benchmarked performance) during potential extreme
heat and cold events and will help better assess the probability of
potential occurrences of cascading outages, uncontrolled separation, or
instability. Transmission planners and planning coordinators could also
model the derating and possible loss of wind and solar generators, as
well as natural gas generators sensitive to extreme heat and cold
conditions. To identify the scope of these planning studies, we are
seeking comments on: (1) the assumptions (e.g., weather forecast, load
forecast, transmission voltage levels, generator types, multi-day low
wind, solar event, etc.) used in modeling of concurrent outages due to
extreme heat and cold weather events; (2) what assumptions should be
included when performing modeling and planning for generators sensitive
to extreme heat and cold; (3) how the impact of loss of generators
sensitive to extreme heat and cold should be factored into long-term
planning; (4) the extent of neighboring systems' or planning areas'
outages that should be modeled in transmission planning studies; and
(5) whether a certain threshold of penetration of wind, solar
generation, and natural gas generators should trigger additional
analyses.
4. Sensitivity Analysis
73. As part of its revisions to TPL-001-5.1, NERC should establish
a requirement for sensitivity analysis for

[[Page 38032]]

transmission planners and planning coordinators to consider system
models and sensitivity cases when assessing extreme heat and extreme
cold weather. A sensitivity case is a variation from the base case that
helps a transmission planner to determine if the results are sensitive
to changes in the inputs. Reliability Standard TPL-001-5.1, Requirement
R2.1.4 requires that sensitivity power flow cases be used to
demonstrate the impact of changes to the basic assumptions used in the
models for system peak load or system off-peak load. These changes
include, among other things, conditions that vary with temperature;
specifically, load, generation, and system transfers.\106\ While
requiring the variation of one of the specified conditions to
demonstrate a measurable change, it does not require the simultaneous
variation of load, generation and transfers necessary to model
conditions that reflect extreme heat or cold weather conditions, thus
potentially causing major reliability issues (i.e., widespread outages,
cascading, etc.) to remain overlooked and undetected in the planning
horizon. To model the effect of extreme heat or cold weather, demand
probability scenario cases (90/10, 80/20, 50/50),\107\ generators that
are affected by these events (i.e., wind tripping off, solar dropping
off, gas plants not operational due to gas restrictions/freeze-offs,
etc.), and transfer levels need to be defined and modeled in
sensitivity analyses.
---------------------------------------------------------------------------

\106\ To effectively model the Bulk-Power System, transmission
planners need make assumptions that create scenarios that are valid,
realistic, and defendable. See North American Transmission Forum,
TPL-001-4 Reference Document, at 8-9 (Aug. 2, 2021), <a href="https://www.natf.net/docs/natf/documents/resources/planning-and-modeling/natf-tpl-001-4-reference-document.pdf">https://www.natf.net/docs/natf/documents/resources/planning-and-modeling/natf-tpl-001-4-reference-document.pdf</a>. Specifically, appropriate
assumptions and corresponding model adjustments need to be made
regarding load (demand), generation (particularly that of
renewables), and transfers (power flows between regions or zones).
See National Renewable Energy Laboratory, Report: The Evolving Role
of Extreme Weather Events in the U.S. Power System with High Levels
of Variable Renewable Energy (Dec. 2021), <a href="https://www.nrel.gov/docs/fy22osti/78394.pdf">https://www.nrel.gov/docs/fy22osti/78394.pdf</a>.
\107\ Demand scenario cases are given designations based on the
percent probability the actual system's peak demand for the period
under study will be above or below certain level. For example, for a
90/10 case, the system demand is modeled at a level that there is a
90% probability the actual system demand will be below that level
and a 10% probability that the actual system demand will be above
that level. Other designations follow similarly using different
percentages.
---------------------------------------------------------------------------

74. Therefore, we seek comment on: (1) requiring transmission
planners and planning coordinators to assess reliability in the
planning horizon for sensitivity cases in which multiple inputs, e.g.,
load and generator failures, change simultaneously during extreme heat
and cold events; and (2) the range of factors and the number of
sensitivity cases that should be considered to ensure reliable
planning.
5. Modifications to the Traditional Planning Approach
75. In modifying TPL-001-5.1, we propose to direct NERC to consider
planning methods and techniques that diverge from past Reliability
Standard requirements.\108\ Reliability Standard TPL-001-5.1 is based
on a deterministic approach, which uses planned contingencies and
definite performance criteria to study system response to various
conditions. This approach yields accurate planning when the power
supply is highly dispatchable, weather is predictable, and near-record
peak demand is reached only a few days a year.\109\ However, the
current planning approach applied in Reliability Standard TPL-001-5.1
likely is not sufficient to accurately characterize the reliability
risk from extreme heat and cold weather given the high degree of
uncertainty inherent in predicting severe weather and its impact on
generation resources, transmission, and load.
---------------------------------------------------------------------------

\108\ We are not making a proposed finding at this time that
modifications to the traditional planning approach are necessary to
properly plan for extreme weather. Nonetheless, there is sufficient
concern such that we believe NERC should consider alternative
approaches when developing a new or modified Reliability Standard in
response to a final rule in this proceeding.
\109\ June 1, 2021 Tr. 31 (Barton).
---------------------------------------------------------------------------

76. An alternative to the deterministic approach is to use
probabilistic approaches in transmission planning. Probabilistic
transmission planning captures random uncertainties in power system
planning, including those in load forecasting, generator performance,
and failures of system equipment. The probabilistic method is not
intended to replace the deterministic criterion but adds one more
dimension to enhance the transmission planning process.\110\
---------------------------------------------------------------------------

\110\ IEEE Explore, Probabilistic Planning of Transmission
Systems: Why, How and an Actual Example, at 1 (July 2008), <a href="https://ieeexplore.ieee.org/document/4596093">https://ieeexplore.ieee.org/document/4596093</a>.
---------------------------------------------------------------------------

77. NERC has recognized the need to incorporate probabilistic
approaches into planning activities. For example, NERC's Probabilistic
Assessment Working Group develops probabilistic analysis that
contributes to NERC's Long-Term Reliability Assessment every other
year. NERC is also investigating the development of probabilistic
methods to study resource adequacy, energy sufficiency, and
transmission adequacy for reliable delivery in composite reliability
studies as well as to develop enhanced reliability metrics.\111\
---------------------------------------------------------------------------

\111\ NERC Post-Technical Conference Comments 3.
---------------------------------------------------------------------------

78. Therefore, to ensure reliable planning and operations in
response to extreme heat and cold events, we believe that a new or
modified approach may be beneficial to capture these events during the
planning process. The new approach could include elements of both
deterministic and probabilistic approaches to assess reliability
outcomes. For example, the January 2018 South Central Cold Weather
Event in the South Central part of the country was a near-miss where
MISO would have been required to perform firm load shed if its next-
worst contingency occurred (i.e., outage of 1,163 MW generation in MISO
South). The load shed would have been needed to alleviate low voltages
at many locations that would have been significantly below their limits
due to the failure of almost 200 generating units. Including scenarios
in the planning process in which generator failures are
probabilistically evaluated could result in a planning approach better
prepared to ensure reliable outcomes compared to the existing planning
requirements under Reliability Standard TPL-001-5.1.
79. One option to modify the existing planning approach would be to
expand the required deterministic studies to include probabilistically
developed scenarios. Therefore, we seek comments on industry's
experience and opinion on combining or layering probabilistic and
deterministic approaches when planning for extreme heat and cold
weather conditions in the context of Reliability Standard TPL-001-5.1.
Specifically, we seek comments on the use of the proposed hybrid
planning approach and: (1) the assumptions from the deterministic and
probabilistic approaches that should be applied to study extreme heat
and cold weather events; (2) the potential planning challenges from
combining the two planning approaches; (3) the costs associated with
adjustments to the currently applied deterministic approach; (4) the
implementation period necessary for proposed changes; and (5) the
reliability benefits that could result.
6. Coordination Among Planning Coordinators and Transmission Planners
and Sharing of Study Results
80. Reliability Standard TPL-001-5.1 cross-refences Reliability
Standard MOD-032-1 (Data for Power System Modeling and Analysis), which
establishes consistent modeling data requirements and reporting
procedures

[[Page 38033]]

for development of planning horizon cases necessary to support analysis
of the reliability of the interconnected transmission system.
Reliability Standard MOD-032-1 ensures adequate means of data
collection for transmission planning. It requires each balancing
authority, generator owner, load serving entity, resource planner,
transmission owner, and transmission service provider to provide
steady-state, dynamic, and short circuit modeling data to its
transmission planner(s) and planning coordinator(s). The modeling data
is then shared pursuant to the data requirements and reporting
procedures developed by the transmission planner and planning
coordinator as set forth in Reliability Standard TPL-001-5.1,
Requirement R1.
81. While balancing authorities and other entities must share
system information and study results with their transmission and
planning coordinator pursuant to Reliability Standards MOD-032-1 and
TPL-001-5.1 as described above, there is no required sharing of such
information--or required coordination--among planning coordinators and
transmission planners with transmission operators, transmission owners,
and generator owners, thus limiting the benefits of additional
modeling. Sharing system information and study results and enhancing
coordination among these entities for extreme heat and cold weather
events could result in more representative planning models by better:
(1) integrating and including operations concerns (e.g., lessons
learned from past issues including corrective actions and projected
outcomes from these actions, evolving issues concerning extreme heat/
cold) in planning models; and (2) conveying reliability concerns from
planning studies (e.g., potential widespread cascading, islanding,
significant loss of load, blackout, etc.) as they pertain to extreme
heat or cold.
82. Therefore, as part of its revisions, NERC should require system
information and study results sharing, and coordination among planning
coordinators and transmission planners with transmission operators,
transmission owners, and generator owners for extreme heat and cold
weather events. To better understand the benefits of the suggested
actions, we are inviting comments on: (1) the parameters and timing of
coordination and sharing; (2) specific protocols that may need to be
established for efficient coordination practices; and (3) potential
impediments to the proposed coordination efforts.

C. Implement a Corrective Action Plan If Performance Standards Are Not
Met

83. Pursuant to FPA 215(d)(5), we propose to direct NERC to modify
Reliability Standard TPL-001-5.1 to require corrective action plans
that include mitigation for any instances where performance
requirements for extreme heat and cold events are not met. Under the
currently effective Reliability Standard TPL-001-4, planning
coordinators and transmission planners are required to evaluate
possible actions to reduce the likelihood or mitigate the consequences
of extreme events but are not obligated to develop corrective action
plans. Specifically, if such events are found to cause cascading
outages, they need only be evaluated for possible actions designed to
reduce their likelihood or mitigate their consequences and adverse
impacts.\112\ Accordingly, because of their potential severity, we
believe that extreme heat and cold weather events should require
evaluation and the development and implementation of corrective action
plans to help protect against system instability, uncontrolled
separation, or cascading failures as a result of a sudden disturbance
or unanticipated failure of system elements.
---------------------------------------------------------------------------

\112\ Reliability Standard TPL-001-4, Requirements R3.3.5 and
R4.4.5 require computer simulation analyses of extreme events listed
in Table 1 of the standard (some listed are examples and are not
definitive), and if the analysis concludes there is Cascading caused
by the occurrence of extreme events, an evaluation of possible
actions designed to reduce the likelihood or mitigate the
consequences and adverse impacts of the event(s) shall be conducted.
---------------------------------------------------------------------------

84. Consistent with the existing requirements of TPL-001-5.1, we
believe it is appropriate to provide responsible entities with the
flexibility to determine the best actions to include in their
corrective action plan to remedy any identified deficiencies in
performance. Examples of actions that could be included in a corrective
action plan are planning for additional contingency reserves or
implementing new energy efficiency programs to decrease load,
increasing intra- and inter-regional transfer capabilities,
transmission switching, or adjusting transmission and generation
maintenance outages based on longer-lead forecasts. Well planned
mitigation and corrective actions that account for some of these
contingencies will minimize loss of load and improve resilience during
extreme heat and cold weather events.
85. In particular, increases in interregional transfer capability
could be considered as one option to address potential reliability
issues during extreme weather events. Such transfer capability would
allow an entity in one region with available energy to assist one or
more entities in another region that is experiencing an energy
shortfall due to the extreme weather event. Increasing interregional
transfer capability may be a particularly robust option for planning
entities attempting to mitigate the risks associated with concurrent
generator outages over a wide area.\113\
---------------------------------------------------------------------------

\113\ In this NOPR we refer to interregional transfer capability
strictly in the context of improving the reliability of the Bulk-
Power System through improved transmission system planning and
associated modifications to NERC's Reliability Standards. As such,
our proposals here are distinct from the requirements for
interregional coordination and cost allocation for public utility
transmission providers. See Transmission Planning and Cost
Allocation by Transmission Owning and Operating Public Utilities,
Order No. 1000, 76 FR 49842 (Aug. 11, 2011), 136 FERC ] 61,051
(2011), order on reh'g, Order No. 1000-A, 77 FR 32184 (May 31,
2012), 139 FERC ] 61,132, order on reh'g and clarification, Order
No. 1000-B, 77 FR 64890 (Oct. 24, 2012), 141 FERC ] 61,044 (2012),
aff'd sub nom. S.C. Pub. Serv. Auth. v. FERC, 762 F.3d 41 (D.C. Cir.
2014).
---------------------------------------------------------------------------

86. Recent events have shown that interregional transfer capability
can be critical to maintaining reliability during extreme weather
events. For example, during the 2021 Cold Weather Event in Texas and
the South Central United States, SPP and MISO imported power from other
balancing authorities to make up for their increasing load levels and
generation shortfalls, because the eastern part of the Eastern
Interconnection did not have the same arctic weather conditions.
Specifically, MISO was able to import large amounts of power from
neighbors to the east (e.g., PJM), and SPP was able to transfer some of
that power through MISO into its region. Those east-to-west transfers
into MISO peaked at nearly 13,000 MW.\114\ PJM had additional energy
available to be transferred but could not facilitate the transfer due
to internal congestion in neighboring systems.\115\
---------------------------------------------------------------------------

\114\ 2021 Cold Weather Event Report at 15.
\115\ PJM Post-Conference Comments at 19-20.
---------------------------------------------------------------------------

87. Recent events have also shown that the loss of interregional
transfer capability can have significant implications for system
reliability during extreme weather events. For instance, during the
August 2020 California Heatwave Event, there was a reduction in the
transfer capability through the Northwest AC Intertie by as much as
1,250 MW due to another extreme weather event that occurred earlier in
2020 which damaged transmission facilities in the northwest part of the
Western Interconnection. The transfer capability of the intertie
linking

[[Page 38034]]

Canadian and U.S. power systems was also reduced by up to 750 MW due to
other planned maintenance outages, further limiting the ability to
transfer energy from the north to the load centers in the south.\116\
---------------------------------------------------------------------------

\116\ 2020 Heat Event Report at 6.
---------------------------------------------------------------------------

88. Thus, we believe that there may be potential benefits in better
incorporating interregional transfer capability into corrective action
plans, where warranted and encourage NERC to consider establishing
requirements that appropriately recognize the value of interregional
transfer capability.
89. To ensure corrective action plans are developed and implemented
in a timely fashion, we invite comments on the timeframe for developing
such corrective action plans and sharing of the corrective actions with
other interconnected planning entities.

D. Other Extreme Weather-Related Events and Issues

90. While the focus of this NOPR is on extreme heat and cold
weather events, we recognize that long-term drought, particularly when
occurring in conjunction with high temperatures, could also pose a
serious risk to Bulk-Power System reliability over a wide geographical
area.\117\ In particular, we are concerned that drought may cause or
contribute to conditions that affect reliable operation of transmission
systems such as transmission outages, reduced plant efficiency, and
reduced generation capacity.
---------------------------------------------------------------------------

\117\ DOE, Impacts of Long-term Drought on Power Systems in the
U.S. Southwest, at 5, <a href="https://www.energy.gov/sites/prod/files/Impacts%20of%20Long-term%20Drought%20on%20Power%20Systems%20in%20the%20US%20Southwest%20%E2%80%93%20July%202012.pdf">https://www.energy.gov/sites/prod/files/Impacts%20of%20Long-term%20Drought%20on%20Power%20Systems%20in%20the%20US%20Southwest%20%E2%80%93%20July%202012.pdf</a>.
---------------------------------------------------------------------------

91. Some examples of recorded events of reduced power production
from drought were seen in the Midwest in 2007 forcing nuclear and coal-
fired plants to shut down and curtail operations and along the
Mississippi River in 2006, which affected nuclear plants in Illinois
and Minnesota.\118\ According to a study conducted by NOAA's drought
task force, climate change has intensified the drought conditions
gripping the Southwestern United States, the region's most severe on
record, with precipitation at the lowest 20-month level documented
since 1895.\119\ The study indicates that the drought that emerged in
early 2020 in California, Nevada and the ``Four Corners'' states of
Arizona, Utah, Colorado and New Mexico has led to unprecedented water
shortages in reservoirs across the region, while exacerbating
devastating western wildfires over the past two years.\120\
---------------------------------------------------------------------------

\118\ Id. at 6.
\119\ NOAA, Assessment Report the 2020-2021 Southwestern U.S.
Drought, at 6, <a href="https://cpo.noaa.gov/MAPP/DTF4SWReport">https://cpo.noaa.gov/MAPP/DTF4SWReport</a>.
\120\ Reuters, Southwest U.S. Drought, Worst in a Century,
Linked by NOAA to Climate Change (Sept. 21, 2021), https://
www.reuters.com/business/environment/southwest-us-drought-worst-
century-linked-by-noaa-climate-change-2021-09-21/
#:~:text=The%20drought%20emerged%20in%20early,two%20years%2C%20the%20
report%20noted.
---------------------------------------------------------------------------

In addition, NERC's 2022 Summer Reliability Assessment concludes
that in 2022 drought threatens wide areas of North America, mainly in
the western United States and Texas, resulting in challenges to area
electricity supplies.\121\
---------------------------------------------------------------------------

\121\ NERC, 2022 Summer Reliability Assessment, at 5 (May 2022),
<a href="https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments">https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments</a>%20DL/
NERC_SRA_2022.pdf.
---------------------------------------------------------------------------

92. Therefore, we seek comments on whether drought should be
included along with extreme heat and cold weather events within the
scope of Reliability Standard TPL-001-5.1 system planning requirements.
These comments will assist the Commission in determining whether the
final rule should direct that NERC further modify Reliability Standard
TPL-001-5.1 to require transmission planners to conduct transmission
planning assessments of the effects of drought conditions on
transmission system operations.
93. Finally, we invite comments on whether other extreme weather
events with significant impact on the reliability of the Bulk-Power
System (e.g., tornadoes, hurricanes) could also be considered and
modeled in the future to improve system performance during these
events.

V. Information Collection Statement

94. The information collection requirements contained in this
Notice of Proposed Rulemaking are subject to review by the Office of
Management and Budget (OMB) under section 3507(d) of the Paperwork
Reduction Act of 1995.\122\ OMB's regulations require approval of
certain information collection requirements imposed by agency
rules.\123\ Upon approval of a collection of information, OMB will
assign an OMB control number and expiration date. Respondents subject
to the filing requirements of this rule will not be penalized for
failing to respond to this collection of information unless the
collection of information displays a valid OMB control number.
---------------------------------------------------------------------------

\122\ 44 U.S.C. 3507(d).
\123\ 5 CFR 1320.11.
---------------------------------------------------------------------------

95. The proposal to direct NERC modify existing Reliability
Standard TPL-001 (Transmission System Planning Performance
Requirements), is covered by, and already included in, the existing
OMB-approved information collection FERC-725 (Certification of Electric
Reliability Organization; Procedures for Electric Reliability
Standards; OMB Control No. 1902-0225),under Reliability Standards
Development.\124\ The reporting requirements in FERC-725 include the
ERO's overall responsibility for developing Reliability Standards, such
as the TPL-001 Reliability, which is designed to ensure the BES will
operate reliably over a broad spectrum of system conditions and
following a wide range of probable contingencies.\125\ The Commission
will submit to OMB a request for a non-substantive revision of FERC-725
in connection with this NOPR.
---------------------------------------------------------------------------

\124\ Reliability Standards Development as described in FERC-725
covers standards development initiated by NERC, the Regional
Entities, and industry, as well as standards the Commission may
direct NERC to develop or modify.
\125\ Reliability Standard TPL-001-4, Purpose.
---------------------------------------------------------------------------

VI. Environmental Assessment

96. 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.\126\ 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.\127\ The actions proposed here
fall within this categorical exclusion in the Commission's regulations.
---------------------------------------------------------------------------

\126\ Regulations Implementing the National Environmental Policy
Act of 1969, Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats.
& Regs., ] 30,783 (1987) (cross-referenced at 41 FERC ] 61,284).
\127\ 18 CFR 380.4(a)(2)(ii) (2021).
---------------------------------------------------------------------------

VII. Regulatory Flexibility Act Certification

97. The Regulatory Flexibility Act of 1980 (RFA) \128\ generally
requires a description and analysis of proposed rules that will have
significant economic impact on a substantial number of small entities.
---------------------------------------------------------------------------

\128\ 5 U.S.C. 601-612.
---------------------------------------------------------------------------

98. We are proposing only to direct NERC, the Commission-certified
ERO, to develop modified Reliability Standards that require enhanced
long-term system transmission planning designed to prepare for extreme
heat and cold

[[Page 38035]]

weather conditions.\129\ Therefore, this Notice of Proposed Rulemaking
will not have a significant or substantial impact on entities other
than NERC. Consequently, the Commission certifies that this Notice of
Proposed Rulemaking will not have a significant economic impact on a
substantial number of small entities.
---------------------------------------------------------------------------

\129\ Cf. Cyber Sec. Incident Reporting Reliability Standards,
Notice of Proposed Rulemaking, 82 FR 61499 (Dec. 28, 2017), 161 FERC
] 61,291 (2017) (proposing to direct NERC to develop and submit
modifications to the NERC Reliability Standards to improve mandatory
reporting of Cyber Security Incidents, including incidents that
might facilitate subsequent efforts to harm the reliable operation
of the BES); Internal Network Sec. Monitoring for High and Medium
Impact Bulk Elec. Sys. Cyber Sys., 178 FERC ] 61,038 (2020)
(proposing to direct NERC to new or modified Reliability Standards
that require internal network security monitoring within a trusted
Critical Infrastructure Protection networked environment for high
and medium impact Bulk Electric System Cyber Systems).
---------------------------------------------------------------------------

99. Any Reliability Standards proposed by NERC in compliance with
this rulemaking will be considered by the Commission in future
proceedings. As part of any future proceedings, the Commission will
make determinations pertaining to the Regulatory Flexibility Act based
on the content of the Reliability Standards proposed by NERC.

VIII. Comment Procedures

100. The Commission invites interested persons to submit comments
on the matters and issues proposed in this notice to be adopted,
including any related matters or alternative proposals that commenters
may wish to discuss. Comments are due August 26, 2022. Comments must
refer to Docket No. RM22-3-000, and must include the commenter's name,
the organization they represent, if applicable, and address in their
comments. All comments will be placed in the Commission's public files
and may be viewed, printed, or downloaded remotely as described in the
Document Availability section below. Commenters on this proposal are
not required to serve copies of their comments on other commenters.
101. The Commission encourages comments to be filed electronically
via the eFiling link on the Commission's website at <a href="http://www.ferc.gov">http://www.ferc.gov</a>. The Commission accepts most standard word processing
formats. Documents created electronically using word processing
software must be filed in native applications or print-to-PDF format
and not in a scanned format. Commenters filing electronically do not
need to make a paper filing.
102. Commenters that are not able to file comments electronically
may file an original of their comment by USPS mail or by courier-or
other delivery services. For submission sent via USPS only, filings
should be mailed to: Federal Energy Regulatory Commission, Office of
the Secretary, 888 First Street NE, Washington, DC 20426. Submission of
filings other than by USPS should be delivered to: Federal Energy
Regulatory Commission, 12225 Wilkins Avenue, Rockville, MD 20852.

IX. Document Availability

103. 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 (<a href="http://www.ferc.gov">http://www.ferc.gov</a>). At
this time, the Commission has suspended access to the Commission's
Public Reference Room due to the President's March 13, 2020
proclamation declaring a National Emergency concerning the Novel
Coronavirus Disease (COVID-19).
104. 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.
105. 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
<a href="/cdn-cgi/l/email-protection#fb9d9e899894959792959e888e8b8b94898fbb9d9e8998d59c948d">[email&#160;protected]</a>, or the Public Reference Room at (202) 502-
8371, TTY (202)502-8659. Email the Public Reference Room at
<a href="/cdn-cgi/l/email-protection#59292c3b35303a772b3c3f3c2b3c373a3c2b363634193f3c2b3a773e362f">[email&#160;protected]</a>.
By direction of the Commission. Commissioner Danly is concurring
with a separate statement attached. Commissioner Clements is concurring
with a separate statement attached. Commissioner Phillips is concurring
with a separate statement attached.

Issued: June 16, 2022.
Debbie-Anne A. Reese,
Deputy Secretary.
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Transmission System Planning Performance Requirements for Extreme
Weather
Docket No. RM22-10-000
(Issued June 16, 2022)
DANLY, Commissioner, concurring:
1. I concur in today's notice of proposed rulemaking directing the
North American Electric Reliability Corporation (NERC) to submit
modifications to Reliability Standard TPL-001-5.1 to address
reliability concerns related to transmission system planning.\130\ It
will take over two years, at a minimum, from this notice of proposed
rulemaking (NOPR) to the ultimate implementation of any such changes.
Reliability Standard development is neither swift nor agile, and this
NOPR will not, indeed cannot, timely address the projected risk of
widespread blackouts this summer,\131\ nor can they be in place quickly
enough to address future summer and winter reliability challenges over
the next couple of years. Yet, I agree it is an important (albeit
small) step to establish mandatory and enforceable compliance
obligations to promote proactive planning for weather-related events.
---------------------------------------------------------------------------

\130\ Transmission Sys. Planning Performance Requirements for
Extreme Weather, 179 FERC ] 61,195 (2022).
\131\ Chairman Glick says that I am ``prone to hyperbole'' when
I warn that blackouts are the likely outcome of the majority's
misguided policies to prop up renewables at the expense of
competitive markets and existing fossil resources. Rich Heidorn Jr.,
Summer Forecasts Spark Warnings of `Reliability Crisis' at FERC, RTO
Insider (May 19, 2022), <a href="https://www.rtoinsider.com/articles/30170-summer-forecasts-spark-warnings-reliability-crisis-ferc">https://www.rtoinsider.com/articles/30170-summer-forecasts-spark-warnings-reliability-crisis-ferc</a>. Chairman
Glick appears to be confusing ``hyperbole'' with ``reality.''
California and Texas have already experienced blackouts. Over two-
thirds of the nation faces ``elevated [reliability] risk'' this
summer. Ethan Howland, FERC commissioners respond to elevated power
outage risks across two-thirds of US, Utility Dive (May 20, 2022),
<a href="https://www.utilitydive.com/news/ferc-nerc-power-outage-risks-summer-drought/624111/">https://www.utilitydive.com/news/ferc-nerc-power-outage-risks-summer-drought/624111/</a> (``At its monthly meeting Thursday, Federal
Energy Regulatory Commission members dissected the North American
Electric Reliability Corp.'s warning that roughly two-thirds of the
United States faces [sic] heightened risks of power outages this
summer.'').
---------------------------------------------------------------------------

2. The NOPR makes use of, indeed bases our action upon, an ever-
growing narrative: reliability challenges arise primarily from weather-
related events.\132\ But even if one were to grant that certain parts
of the United States were experiencing statistically unusual weather
when compared to historical baselines, that has absolutely nothing to
do with whether the markets and regulated utilities are procuring

[[Page 38036]]

sufficient generation of the correct type to ensure resource adequacy
and system reliability. We cannot blame our problems on the weather.
The problem is federal and state policies which, by mandate or subsidy,
spur the development of weather dependent generation resources at the
expense of the dispatchable resources needed for system stability and
resource adequacy. This is seen in particularly stark terms in our
markets in which subsidies, combined with failed market design, warp
price signals. This destroys the incentives required to ensure the
orderly entry, exit, and retention of the necessary quantities of the
necessary types of generation. The thinner and thinner margins that
result render the Bulk-Power System more and more susceptible to the
caprices of weather. We have been warned by credible sources on the
matter: NERC,\133\ the RTOs,\134\ and Commission staff.\135\
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\132\ See Chairman Glick (@RichGlickFERC), Twitter (May 19,
2022, 11:13 a.m.), <a href="https://twitter.com/RichGlickFERC/status/1527306459263881223?s=20&t=3a4C-1cac3nmFkjZyvoUDA">https://twitter.com/RichGlickFERC/status/1527306459263881223?s=20&t=3a4C-1cac3nmFkjZyvoUDA</a> (``Extreme weather
may be the single most important factor impacting #grid #reliability
& the impacts of expected heat, drought, wildfires, hurricanes, &
other events--all pose a big threat. Keeping eye on West, ERCOT, &
parts of MISO this summer.''); Benjamin Mullin, Climate Change is
Straining California's Energy System, Officials Say, N.Y. Times (May
6, 2022), <a href="https://www.nytimes.com/2022/05/06/business/energy-environment/california-electricity-shortage.html">https://www.nytimes.com/2022/05/06/business/energy-environment/california-electricity-shortage.html</a>.
\133\ See generally North American Electric Reliability Corp.,
2022 Summer Reliability Assessment (May 2022), <a href="https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments">https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments</a> %20DL/NERC_SRA_2022.pdf. In
addition, NERC has warned that system operators in areas of
significant amounts of solar photovoltaic (PV) resources should be
aware of the potential for resource loss events during grid
disturbances. Id. at 6. NERC has further warned that ``[i]ndustry
experience with unexpected tripping of [Bulk-Power System]-connected
solar PV generation units can be traced back to the 2016 Blue Cut
fire in California, and similar events have occurred as recently as
Summer 2021. A common thread with these events is the lack of
inverter-based resource (IBR) ride-through capability causing a
minor system disturbance to become a major disturbance. The latest
disturbance report reinforces that improvements to NERC Reliability
Standards are needed to address systemic issues with IBRs.'' Id.
NERC also explains that ``because the electrical output of variable
energy resources (e.g., wind, solar) depends on weather conditions,
on-peak capacity contributions are less than nameplate capacity.''
Id. at 45.
\134\ See, e.g., California Independent System Operator Corp.,
2022 Summer Loads and Resources Assessment (May 18, 2022), <a href="http://www.caiso.com/Documents/2022-Summer-Loads-and-Resources-Assessment.pdf">http://www.caiso.com/Documents/2022-Summer-Loads-and-Resources-Assessment.pdf</a>; Midcontinent Independent System Operator (MISO),
Lack of Firm generation may necessitate increased reliance on
imports and use of emergency procedures to maintain reliability
(Apr. 28, 2022), <a href="https://www.misoenergy.org/about/media-center/miso-projects-risk-of-insufficient-firm-generation-resources-to-cover-peak-load-in-summer-months/">https://www.misoenergy.org/about/media-center/miso-projects-risk-of-insufficient-firm-generation-resources-to-cover-peak-load-in-summer-months/</a>; PJM Interconnection, L.L.C. (PJM),
Energy Transition in PJM: Frameworks for Analysis (Dec. 15, 2021),
<a href="https://pjm.com/-/media/committees-groups/committees/mrc/2021/20211215/20211215-item-09-energy-transition-in-pjm-whitepaper.ashx">https://pjm.com/-/media/committees-groups/committees/mrc/2021/20211215/20211215-item-09-energy-transition-in-pjm-whitepaper.ashx</a>
(addressing renewable integration).
\135\ See Staff Presentation on 2022 Summer Energy Market and
Reliability Assessment (AD06-3-000), FERC, at slide 9 (May 19,
2022), <a href="https://www.ferc.gov/news-events/news/presentation-report-2022-summer-energy-market-and-reliability-assessment">https://www.ferc.gov/news-events/news/presentation-report-2022-summer-energy-market-and-reliability-assessment</a> (identifying
the Western U.S., Texas, MISO and Southwest Power Pool as ``[p]arts
of North America are at elevated or high risk of energy shortfalls
during peak summer conditions'') (emphasis in original); id. at
slide 10 (In MISO, ``[g]eneration capacity declined 2.3% since 2021
resulting in [a] lower reserve margin'' and the ``[n]orth and
central areas [are] at risk of reserve shortfall in extreme
temperatures, high generation outages, or low wind'' with ``[s]ome
risk of insufficient operating reserves at normal peak demand.'').
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3. As more nuclear \136\ and coal plants \137\--with their high
capacity factors and onsite fuel--announce early retirements, the
dispatchable resources that remain are predominantly natural gas
generators. Backstopping weather-dependent resources with gas
generators, largely dependent on just-in-time delivery of gas, raises
its own set of reliability concerns, particularly in areas--like New
England--with inadequate pipeline infrastructure. On top of this, the
Commission has delayed the processing of pipeline certificates and cast
a chill over the pipeline industry with its ``draft policy statements''
\138\ and orders throwing the finality of fully litigated certificates
into doubt.\139\ Under pressure to reduce emissions at all costs,
pipelines have moved to electrify compressor stations, furthering an
unhealthy co-dependency between the gas and electric systems. And the
efforts of politically motivated financial institutions to cut fossil
fuel producers' access to capital has added to the current supply
crunch.\140\ Yet, we are led to believe that extreme weather is
supposed to be the culprit for the nation's looming reliability woes.
Not so.
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\136\ U.S. Energy Information Administration, U.S. nuclear
electricity generation continues to decline as more reactors retire
(Apr. 8, 2022), <a href="https://www.eia.gov/todayinenergy/detail.php?id=51978">https://www.eia.gov/todayinenergy/detail.php?id=51978</a>.
\137\ Ethan Howland, Coal plant owners seek to shut 3.2 GW in
PJM in face of economic, regulatory and market pressures, Utility
Dive (Mar. 22, 2022), <a href="https://www.utilitydive.com/news/coal-plant-owners-seek-to-retire-power-in-pjm/620781/">https://www.utilitydive.com/news/coal-plant-owners-seek-to-retire-power-in-pjm/620781/</a>.
\138\ See Certification of New Interstate Nat. Gas Facilities,
178 FERC ] 61,107 (2022) (Danly and Christie, Comm'rs, dissenting));
Consideration of Greenhouse Gas Emissions in Nat. Gas Infrastructure
Project Revs., 178 FERC ] 61,108 (2022) (Danly and Christie,
Comm'rs, dissenting); see also Certification of New Interstate Nat.
Gas Facilities, 178 FERC ] 61,197, at P 2 (2022) (converting the two
policy statements to ``draft policy statements''). It is worth
noting that PJM and MISO filed comments on the draft policy
statements. PJM and MISO May 25, 2022 Limited Reply Comments, Docket
Nos. PL18-1-001 and PL21-3-001, at 4 (``[A]ny future Commission
pipeline policy should consider the importance of ensuring that
needed pipeline infrastructure can be timely sited, and ensure that
the need for infrastructure to meet electric system reliability is
affirmatively considered and not lost in the debate over the scope
of environmental reviews to be undertaken by the Commission.'').
\139\ See, e.g., Algonquin Gas Transmission, LLC, 174 FERC ]
61,126 (2021) (Danly and Christie, Comm'rs, dissenting).
\140\ Matt Egan, Energy crisis will set off social unrest,
private-equity billionaire warns, CNN Business (Oct. 26, 2021),
<a href="https://edition.cnn.com/2021/10/26/business/gas-prices-energy-crisis-schwarzman/index.html">https://edition.cnn.com/2021/10/26/business/gas-prices-energy-crisis-schwarzman/index.html</a> (``Part of the problem, [Blackstone CEO
Stephen Schwarzman] said, is that it's getting harder and harder for
fossil fuel companies to borrow money to fund their expensive
production activities, especially in the United States. And without
new production, supply won't keep up.'').
---------------------------------------------------------------------------

4. The question of whether the weather is getting worse is a red
herring. The much more relevant question is whether current system
operations and tariff and market design are adequate to maintain
reliability. The present high risk of reliability failures proves that
they are not. That the policies of the Commission and other government
bodies are undermining reliability is far more obvious than the
question of whether, and how, the weather is getting worse and what
specific effects that worsening weather might have on the stability of
the electric system. That question of the weather's effect on
reliability is a subject that doubtless merits study and planning, but
misguided government policies are the root cause of the alarming
reliability issues facing the nation, not the weather.
For these reasons, I respectfully concur.

-----------------------------------------------------------------------
James P. Danly,

Commissioner.
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Transmission System Planning Performance Requirements for Extreme
Weather
Docket No. RM22-10-000
(Issued June 16, 2022)
CLEMENTS, Commissioner, concurring:
1. Today's Notice of Proposed Rulemaking (NOPR) is an important
step to ensure that the North American Electric Reliability Corporation
(NERC) builds upon existing practices to better account for extreme
weather in transmission system planning. Together with the Notice of
Proposed Rulemaking proposing to direct transmission providers to
submit informational reports describing their current or planned
policies and processes for conducting extreme weather vulnerability
assessments,\1\ it will facilitate steps to enhance the reliability of
the electric system.
---------------------------------------------------------------------------

\1\ One Time Informational Reports on Extreme Weather
Vulnerability Assessments, 179 FERC ] 61,196 (2022).
---------------------------------------------------------------------------

2. NERC already addresses extreme weather in several ways. For
example, Reliability Standard TPL-001-4 requires planning coordinators
and transmission planners to conduct an analysis of extreme weather
events and

[[Page 38037]]

evaluate potential actions for reducing the likelihood or mitigating
the consequences of the event creating adverse impacts.\2\ NERC also
recently adopted Cold Weather Reliability Standards, which require
generators to prepare and implement plans for cold weather, and require
the exchange of information between the balancing authority,
transmission operator, and reliability coordinator about the
generator's ability to operate under cold weather conditions to ensure
grid reliability.\3\ Further, NERC has prioritized improving bulk
electric system resilience to wide-spread long-term extreme temperature
events in its 2022 Enterprise Work Plan,\4\ and is pursuing
enhancements to reliability standards for the operational planning
timeframe to address extreme weather via its Energy Reliability
Assessment Task Force.\5\ Yet even with these actions, utilities and
grid operators remain underprepared for the changing climate and the
increasing frequency of extreme weather it is bringing, as is evident
in NERC's 2022 Summer Reliability Assessment. Therein, NERC highlights
the elevated risk of an energy emergency due to the increased demand
for electricity driven by above average temperatures combined with a
reduced capacity because extreme drought conditions threaten the
availability of hydroelectric energy for transfer.\6\ Had the nation's
utilities and grid operators better planned for climate change and the
attendant increased likelihood of these conditions, they would be
better prepared for the conditions we are likely to face this summer.
---------------------------------------------------------------------------

\2\ Reliability Standard TPL-001-4; see also Notice of Proposed
Rulemaking, Transmission System Planning Performance Requirements
for Extreme Weather (Extreme Weather NOPR), 179 FERC ] 61,195, at PP
20-23 (2022) (discussing the requirements set forth in TPL-001-4).
\3\ See Extreme Weather NOPR at PP 18-19 (discussing Cold
Weather Reliability Standards, 176 FERC ] 61,119, at PP 1, 3
(2021)).
\4\ See NERC, 2022 ERO Enterprise Work Plan Priorities, at 3
(Nov. 4, 2021), available at <a href="http://nerc.com/AboutNERC/StrategicDocuments/ERO_2022_Work_Plan_Priorities_Board_Approved_Nov_4_2021.pdf">nerc.com/AboutNERC/StrategicDocuments/ERO_2022_Work_Plan_Priorities_Board_Approved_Nov_4_2021.pdf</a>.
\5\ See NERC, DRAFT Energy Management Recommendations for Long
Duration Extreme Winter and Summer Conditions, available at <a href="https://www.nerc.com/comm/RSTC/ERATF/Combined-Energy-Management-Roadmap.pdf">https://www.nerc.com/comm/RSTC/ERATF/Combined-Energy-Management-Roadmap.pdf</a>
(last accessed June 15, 2022).
\6\ NERC, 2022 Summer Reliability Assessment, at 7, 9 (May
2022), available at <a href="https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments">https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments</a>%20DL/NERC_SRA_2022.pdf.
---------------------------------------------------------------------------

3. There is no more urgent priority for this Commission than to
reform system planning so that it sufficiently contemplates and
provides mechanisms to address the impact of extreme weather events on
the electricity grid. Across geographies, regulatory regimes, regional
resource mixes and market designs, the impact of extreme weather has
vastly outpaced regulatory adaptation to it. So, I am glad to support
this priority by voting for today's NOPR, which complements NERC's
ongoing efforts to address the operational time frame and fills a gap
by ensuring that Reliability Standards better account for extreme
weather in planning. I write separately for two reasons.
4. First, while it represents an important step in tackling extreme
weather's myriad impacts on the transmission system, strong follow
through from NERC will be required to ensure a reliability standard
that addresses extreme weather reliability challenges in a
comprehensive and cost-effective manner. While the proposed rule seeks
comments on whether drought should be included along with extreme heat
and cold weather events within the scope of Reliability Standard TPL-
001-5.1, I believe that what we already know about meteorological
projections and drought's anticipated impacts on the electricity system
compel the development of drought benchmark events in applicable
regions of the country.\7\ The question for me is not whether such
events should be included, but how TPL-001-5.1 should cover the impact
of drought induced reductions in supply on regions already experiencing
unprecedented reductions in reservoir supply and increased wildfire
risk. Further, NERC can facilitate cost effective implementation of
these reliability standard modifications by requiring modeling of
extreme weather events according to consistent planning rules,
providing for consultation with states and other regulators in the
development of corrective actions plans, and by considering of the
interaction between this proposed Reliability Standard and related
planning processes and rules, including the Commission's recently
issued notice of proposed rulemaking regarding long-term regional
transmission planning.\8\ I urge stakeholders to provide
recommendations to NERC as to how best to account for these
considerations in commenting on this proposal.
---------------------------------------------------------------------------

\7\ See Extreme Weather NOPR at PP 90-92 (discussing the
anticipated impacts of drought on the electricity system); infra P
8.
\8\ Building for the Future Through Electric Regional
Transmission Planning and Cost Allocation and Generator
Interconnection, 179 FERC ] 61,028 (2022) (Regional Planning NOPR).
---------------------------------------------------------------------------

5. Second, it is important to note that if we are to cost-
effectively ensure system reliability as the frequency and intensity of
extreme weather events continues to increase, further action is
necessary to complement today's initial proposal. We have learned a
good amount about the impact of extreme weather on the electricity
system the hard way.\9\ We have the opportunity to learn a great deal
more from the substantial amount of important information and good
ideas that stakeholders submitted in response to the Commission's
inquiry into Climate Change, Extreme Weather, and Electric System
Reliability in Docket No. AD21-13.
---------------------------------------------------------------------------

\9\ Severe weather events have caused significant outages in the
past decade. See NOPR at P 26 (discussing February 2011 Southwest
Cold Weather Event where low temperatures caused uncontrolled
blackouts throughout ERCOT's entire region, effecting 4.4 million
electric customers), P 28 (discussing January 2014 Polar Vortex Cold
Weather Event where increased demand for gas and the unavailability
of gas-fired generation led to 35,000 MW of generator outages, and
PP 31-32 (describing how the 2021 Cold Weather Event brought the
largest controlled load shed in U.S. history, with more than 4.5
million people losing power, resulting in at least 210 people
dying).
---------------------------------------------------------------------------

6. Themes that emerge from this collective experience and record
include, at least, the need to consider: (1) establishing a process for
setting explicit minimum interregional transfer capability requirements
or otherwise identifying least regrets interregional solutions, (2)
improved scheduling and coordination in non-RTO regions, and (3)
ensuring that planning and market mechanisms appropriately reflect
resource availability during extreme weather events, accounting for the
possibility of common mode failures or other correlated outages.\10\ As
I provide in more detail below, I urge my colleagues to prioritize
these complementary issues in the months to come.
---------------------------------------------------------------------------

\10\ While this statement highlights key priority areas for
further inquiry, it is not intended to be exclusive. For instance,
while I do not discuss it in detail here, I support Commissioner
Phillips' call for an examination of whether the Commission should
require revisions to RTO/ISO generation and transmission outage
scheduling practices. See Extreme Weather NOPR (Phillips, Comm'r,
concurring) at PP 8-9.
---------------------------------------------------------------------------

A. Ensuring Cost-Effective Implementation of This NOPR

7. The effectiveness of this NOPR depends upon NERC implementing it
in a manner that comprehensively addresses extreme weather threats,
provides for consistency in modeling scenarios and methods to the
greatest extent possible, facilitates consultation with state
regulators, and appreciates its interrelation with the Commission's
Regional Planning NOPR. I urge NERC and stakeholders to provide
feedback on the following issues, which may facilitate strengthening
the effectiveness of the eventual reliability standard.

[[Page 38038]]

8. Initially, in addition to benchmark cases for extreme heat and
cold, it seems prudent to include drought within the scope of
Reliability Standard TPL-001-5.1. It is not surprising that, as noted
in comments in the extreme weather docket, the more frequent and severe
droughts occurring and expected to worsen in parts of the West and
Southwest portend potentially significant grid impacts via limitations
on hydroelectric generating facilities as well as thermal facilities
that require water for cooling.\11\ These drought conditions also, of
course, serve as a main driver of what the Oregon Public Utility
Commission describes as ``one of the most pressing and difficult
issues: the rapidly increasing risk of highly destructive wildfires.''
\12\ While the need to consider a drought benchmark case does not
currently arise in all regions of the country, failure to contemplate
the impacts of drought in relevant regions as part of equipping
transmission planning to effectively address extreme weather would
hamper a final Reliability Standard's impact.
---------------------------------------------------------------------------

\11\ See, e.g., Comments of Environmental Defense Fund and
Columbia Law School Sabin Center for Climate Change Law, Docket No.
AD21-13, at 3 (filed Sept. 27, 2021) (``[C]hanges to the
availability of water for cooling at thermal power plants and for
hydroelectric generation will depart from historical patterns.'');
Comments of the California Independent System Operator, Docket No.
AD21-13 at 3 (filed April 15, 2021) (noting that drought already
``has affected the availability of hydroelectric facilitates in some
years'').
\12\ Comments of the Oregon Public Utility Commission, Docket
No. AD21-13, at 2 (filed Apr. 14, 2021).
---------------------------------------------------------------------------

9. Further, I am pleased to see the proposal's emphasis that ``it
is important that transmission planners and planning coordinators
likely to be impacted by the same types of extreme weather events use
consistent benchmark events.'' \13\ I urge NERC and stakeholders to
contemplate the benefits of consistent modeling practices and modeling
assumptions, and to provide feedback on how such consistency can best
be achieved within the scope of this proposed rule.\14\ Consistency in
the inputs and assumptions feeding these cases and scenarios will allow
for neighboring transmission planners and planning coordinators to work
together towards cost-effective corrective actions, like increasing
transfer capability, that could otherwise be missed for lack of apples-
to-apples comparisons.
---------------------------------------------------------------------------

\13\ Extreme Weather NOPR at P 52.
\14\ See Comments of the Institute for Policy Integrity Docket
No. AD21-13, at 8 (filed Apr. 14, 2021) (emphasizing potential
benefits of consistent modeling practices); see also Pre-Technical
Conference Comments of Exelon Corporation Docket No. AD21-13, at 14
(filed Apr. 15, 2021) (suggesting a process by which regulators and
experts could ``define a reasonable range of scenarios describing
potential climate-change related weather events and longer-term
climate patters over the coming decades'').
---------------------------------------------------------------------------

10. In addition, I encourage NERC to set forth a process that
provides for consultation with states in the development of corrective
action plans, given that many components of such plans could be state
jurisdictional. As we see in other contexts, states' jurisdiction over
their resource mix and the Federal Power Act's separation of authority
between FERC and states means that consideration of some of the more
cost-effective options for corrective actions, including reducing
demand through energy efficiency and other demand side resource
development, cannot be properly facilitated without state
partnership.\15\ States' decisions regarding the siting of generation
and transmission facilities may also be impacted by extreme
weather.\16\ Consulting with states will both ensure that opportunities
for addressing reliability changes with state-jurisdictional solutions
are not missed, and provide a path to regulatory approval of such
solutions in a manner that ensures both FERC and state regulators are
informed of the costs and benefits of different corrective actions.\17\
High-level coordination would also allow for harmony between the
extreme weather modeling methods of states and those of NERC, such as
``referring to an agreed set of climate modeling parameters or
scenarios,'' where appropriate in developing their own solutions.\18\
---------------------------------------------------------------------------

\15\ See Comments of PJM Interconnection, L.L.C. Docket No.
AD21-13, at 9 (filed Apr. 15, 2021) (``[C]oordination with states
(including state permitting agencies) on climate change and extreme
weather events [is] critical.''); Comments of the R Street Institute
Docket No. AD21-13, at 15 (filed Apr. 15, 2021) (``It is imperative
for future reliability policy to harmonize the actions of federal
and state authorities, at least to a basic degree.''); see also
Motion to Intervene and Comments of the National Association of
Regulatory Utility Commissioners Docket No. AD21-13, at 2 (filed
Apr. 14, 2021) (urging the Commission to confer with the states
``where climate change and extreme weather events may implicate both
federal and state issues'').
\16\ See Comments of the National Rural Electric Cooperative
Association Docket No. AD21-13, at 13 (filed Apr. 15, 2021). See
also id. (``Most of the necessary decision-making and policy-
making'' with regard to extreme weather ``will be at state and local
levels.'').
\17\ See Comments of the Institute for Policy Integrity, Docket
No. AD21-13, at 8 (filed Apr. 14, 2021) (coordination would
``facilitat[e] state efforts to encourage development of flexible
resources'').
\18\ Id.
---------------------------------------------------------------------------

11. Further, in considering how to address the aims of this
proposal cost effectively, it is important for NERC and stakeholders to
consider how this proposal to reform TPL-001-5.1 may interact with the
Commission's notice of proposed rulemaking on regional transmission
planning and cost allocation.\19\ That NOPR proposes to require
transmission planners to engage in probabilistic, scenario-based
planning for longer-term system needs, including at least one extreme
weather scenario, but exempts shorter-term reliability planning from
this scenario planning requirement. Since efficiencies are gained when
considering multiple drivers for new transmission investment and it is
likely that some amount of the corrective action that may emerge from
the new reliability standard involves regional or interregional
transmission development, it is important to derive stakeholders'
perspectives on how potential performance standards and corrective
actions under a revised reliability standard interact with both
shorter-term reliability and proposed longer term planning, both in
terms of consistency in planning inputs and the selection of cost-
effective solutions. For instance, processes may be established to
prioritize finding solutions via long-term planning in the first
instance wherever possible, or to incorporate multiple drivers and
probabilistic benefit cost assessments into the reliability planning
process, so as to leverage the benefits of multi-value planning.
---------------------------------------------------------------------------

\19\ Regional Planning NOPR, 179 FERC ] 61,028.
---------------------------------------------------------------------------

B. Need for Further Actions To Ensure System Reliability

12. The Commission developed a robust record in response to the
Commission's technical conference on climate change, extreme weather,
and electric system reliability, and the Commission's technical
conference to discuss resource adequacy developments in the Western
Interconnection.\20\ Today's NOPR will facilitate better planning for
extreme weather events, but the record in those dockets, as well as in
the Commission's inquiry into potential improvements in transmission
system planning,\21\ suggests action is necessary on several fronts to
better facilitate cost-effective solutions. It is important to
highlight three areas for which further inquiry is merited: \22\ (1)
increasing interregional transfer capability; (2) improving
transmission scheduling and coordination in non-RTO regions; and (3)
ensuring that planning and market mechanisms properly reflect resource
availability during extreme weather

[[Page 38039]]

events, accounting for the possibility of common mode failures or other
correlated outages.
---------------------------------------------------------------------------

\20\ See Docket Nos. AD21-13 and AD21-14.
\21\ See Docket No RM21-17.
\22\ While this statement highlights key priority areas for
further inquiry, it is not intended to be exclusive. See supra n.
10.
---------------------------------------------------------------------------

1. Increasing Interregional Transfer Capability

13. Numerous commenters have highlighted that interregional
transfer capability renders the grid more resilient to extreme weather
events.\23\ As a recent report from The Brattle Group summarizes,
``[n]umerous studies have confirmed the significant benefits of
expanding interregional transmission in North America, demonstrating
that building new interregional transmission projects can lower overall
costs, help diversify and integrate renewable resources more cost
effectively, and reduce the risk of high-cost outcomes and power
outages during extreme weather events.'' \24\
---------------------------------------------------------------------------

\23\ See Post-Conference Comments of American Electric Power,
Docket No. AD21-13, at 8 (filed Sept. 27, 2021) (arguing that
increased interregional transfer capability is ``an important
component of meeting the challenges'' extreme weather poses for the
system); Post-Conference Comments of Midcontinent Independent System
Operator Inc., Docket No. AD21-13, at 23 (filed Sept. 27, 2021)
(finding interregional transfer capacity improves the resilience of
the power system); Comments of Americans for a Clean Energy Grid,
Docket No. AD21-11 (filed Feb. 22, 2022), Attachment 1: Grid
Strategies LLC, Fleetwide Failures: How Interregional Transmission
Tends to Keep the Lights On When There is a Loss of Generation (Nov.
2021), Attachment 2: Grid Strategies LLC, Transmission Makes the
Power System Resilient to Extreme Weather (July 2021), Attachment 3:
Grid Strategies, LLC, The One-Year Anniversary of Winter Storm Uri,
Lessons learned and the Continuing Need for Large-Scale Transmission
(Feb. 13, 2022), Attachment 4: General Electric International, Inc.,
Potential Customer Benefits of Interregional Transmission (Nov. 29,
2021), and Attachment 5: Pfeifenberger et al., A Roadmap to Improved
Interregional Transmission Planning (Nov. 30, 2021); Initial
Comments of PJM Interconnection, L.L.C., Docket No. RM21-17, at 72-
73 (filed Oct. 12, 2021) (``Greater interregional transfer
capability has a significant reliability benefit for both adjoining
regions as demonstrated . . . by the February 2021 Cold Snap and the
2014 Polar Vortex.'') (emphasis omitted).
\24\ Pfeifenberger et al., A Roadmap to Improved Interregional
Transmission Planning (Nov. 30, 2021) at iii, available at <a href="https://www.brattle.com/wp-content/uploads/2021/11/A-Roadmap-to-Improved-Interregional-Transmission-Planning_V4.pdf">https://www.brattle.com/wp-content/uploads/2021/11/A-Roadmap-to-Improved-Interregional-Transmission-Planning_V4.pdf</a>; see also id. at 2, Table
1, Summary of Select Recent Interregional Transmission Studies.
---------------------------------------------------------------------------

14. Yet Eversource Energy observes that ``[d]espite numerous
studies suggesting the importance of increased interregional ties, most
planning regions do not currently perform regular studies to assess
whether increased interregional transmission capability could increase
reliability during severe weather events.'' \25\ This gap in planning,
along with many other barriers to constructing interregional transfer
capability,\26\ threatens to dissuade transmission planners and
planning coordinators from pursuing enhanced interregional transfer
capability as a corrective action strategy, even where it is the most
effective solution for customers.
---------------------------------------------------------------------------

\25\ Post-Conference Comments of Eversource Energy, Docket No.
AD21-13, at 6-7 (filed Sept. 27, 2021).
\26\ See Pfeifenberger et al. at 4-5 (summarizing barriers to
interregional transmission planning and development).
---------------------------------------------------------------------------

15. As highlighted in section A above, consistent benchmark cases,
scenarios, and other modeling practices will help to facilitate
transmission planners and planning coordinators' pursuit of shared
solutions, such as enhanced interregional transfer capability. Yet even
with a common framework, coordination between regions is likely to
prove challenging. Setting a minimum level of transfer capability could
provide a unified planning goal for neighboring regions and thereby
ameliorate this planning challenge.\27\ American Electric Power (AEP)
recommends that ``a minimum interregional transfer capability should be
established through a thorough risk assessment on a nationwide, and
region to region basis, using sensitivity analyses on the frequency of
extreme weather events, projections of climate change impacts, and
project retirements, constraints, and load changes over various
timelines.'' \28\ A capability requirement might vary, for instance,
according to a region's generation mix, load, weather, and correlation
with neighboring regions across these various attributes, and would
protect system reliability by ``provid[ing] the ability to access
additional generation in the event local (or even regional) generation
is unable to serve customers or maintain reliability.'' \29\
---------------------------------------------------------------------------

\27\ See, e.g., Post-Conference Comments of PJM Interconnection,
L.L.C., Docket No. AD21-13, at 19-20 (filed Apr. 15, 2021) (noting
that a ``national standard or recommended planning driver for bi-
directional transfer capability'' would facilitate ``interregional
coordination'').
\28\ Post-Conference Comments of American Electric Power, Docket
No. AD21-13, at 10 (filed Sept. 27, 2021).
\29\ Id. at 9-10.
---------------------------------------------------------------------------

16. A process for setting interregional transfer capability
requirements could address a gap in existing regulation. As AEP argues,
``[b]ecause the current process evaluates transfer capability on a
regional, or balancing authority-specific basis,'' it does not capture
``the efficiencies'' of connections ``between the regions.'' \30\
``[F]ailure to evaluate the grid as a whole makes the grid more
susceptible to . . . the impacts of increasingly extreme weather events
that impact large geographic areas,'' rendering ``the overall
resilience and reliability the transmission grid less robust than it
could be.'' \31\
---------------------------------------------------------------------------

\30\ Id. at 9.
\31\ Id.
---------------------------------------------------------------------------

17. As this discussion suggests, both section 215 and section 206
of the Federal Power Act are implicated by the development of
interregional transfer capability. I urge stakeholders and this
Commission to further explore whether section 215, section 206, or a
combination thereof may serve as the basis for establishing specific
minimum interregional transfer capability requirements or otherwise
establishing least regrets interregional planning targets.

2. Improving Transmission Scheduling and Coordination in Non-RTO
Regions

18. Enhanced transmission scheduling and coordination between
balancing area authorities--in particular, RTO-to-non-RTO and non-RTO-
to-non-RTO coordination--would improve grid reliability during extreme
weather events, lower costs for customers, and level the regulatory
playing field between RTO and non-RTO regions. Transmission scheduling
and coordination can potentially be improved both via mandating a
transition to flowgate methodology for determining transmission
capacity in areas that continue to use path-based methodologies, and
via facilitation of economic redispatch and narrowing the circumstances
under which transmission curtailment procedures are permissible.
19. As leading electricity market economists have observed, ``in an
electricity network, power flows along parallel paths dictated by
physical laws rather than the contract path, creating widespread
externalities whose complexity grows with network size.'' \32\ Without
``an appropriate mechanism to allocate transmission capacity''
according to true flow, market participants ``are unlikely to take into
consideration the effects of power flows that diverge from the contract
path.'' \33\ Despite the efficiencies of a flow-based method, however,
the Reliability Standards continue to permit entities to choose either
a path-based or a flow-based method of transmission method,\34\ with
most entities in the Western

[[Page 38040]]

Interconnection continuing to use the less efficient path-based
method.\35\
---------------------------------------------------------------------------

\32\ Chao et al., Flow-based Transmission Rights and Congestion
Management, Electricity Journal at 39 (2000), available at <a href="https://oren.ieor.berkeley.edu/pubs/flowbase.pdf">https://oren.ieor.berkeley.edu/pubs/flowbase.pdf</a>.
\33\ Id.
\34\ NERC Reliability Standard MOD-29 sets forth requirements
for path-based transmission management, while Reliability Standard
MOD-30 sets forth the requirements for a flow-based method.
\35\ See Joint Comments of Arizona Public Service Company and
Public Service Company of Colorado, Docket No. AD21-14, at 5-6
(filed Jan. 31, 2022).
---------------------------------------------------------------------------

20. Arizona Public Service and Public Service Company of Colorado
argue that ``the path based approach results in less efficient
transmission system use and could hamper the contracting and delivery
of capacity resources across the Western Interconnection.'' \36\ By
contrast, ``a flow-based methodology, through its more realistic
assessment of impacts to the entirety of the transmission system, in
general enables greater utilization of the system as a whole.'' \37\ As
the West faces increased frequency and duration of extreme weather
events, achieving maximum reliability value from all existing
infrastructure is imperative.\38\ This raises the question whether the
Reliability Standards should require all applicable entities to
transition to a flow-based methodology.
---------------------------------------------------------------------------

\36\ Id. at 5.
\37\ Id. at 6.
\38\ See Technical Conference Tr., June 24, 2021, Docket No.
AD21-14-000, at 301:14 (Chairman Glick: ``I'm wondering if there are
things we can do in the near term . . . that would help facilitate
and improve [the] resource adequacy situation or at least improve
[the] reliability situation.''); 307:2 (Amanda Ormond, in response:
``I want to just talk about efficiency of the existing transmission
system because we certainly need to get more out of what we have,
and Alice Jackson from [X]cel mentioned the flow-based [methodology]
as you did. I think that's really important that we move to a flow[-
based methodology] because [that would facilitate] know[ing] more
about what's on the system where.'').
---------------------------------------------------------------------------

21. Beyond ensuring that transmission capacity is measured and
scheduled in a manner that better matches the reality of the system,
the Commission should explore complementary action to improve the
ability of non-RTO system operators to provide transmission service
when the grid is constrained. Transmission Loading Relief (TLR)
procedures and Qualified Path Unscheduled Flow Relief (USF) procedures,
the default methods of managing transmission congestion between
balancing areas outside of RTO/ISO markets, are blunt instruments that
in some cases fail to facilitate power transfers that would aid system
reliability during extreme weather, and in other cases impose higher
overall costs than appropriate redispatch of generation. As MISO
highlights in its post-technical conference comments in Docket No.
AD21-13, TLR fails to ``assure reliable service'' because it ``reli[es]
on curtailment of interchange transactions.'' \39\ TLR and USF
procedures curtail transactions in a pre-set priority order, without
locational marginal pricing or another adequate mechanism to guide them
toward redispatching generation to facilitate optimal transmission
flows. By contrast, economic ``[r]edispatch offers a way, in the vast
majority of circumstances, to ensure that all transactions continue to
be served despite transmission congestion.'' \40\ RTO and ISOs
generally utilize TLRs to mitigate an overload only where they have
``exhausted all other means available, short of load shedding.'' \41\
---------------------------------------------------------------------------

\39\ Post-Conference Comments of Midcontinent Independent System
Operator, Docket No. AD21-13, at 10 (filed Sept. 27, 2021).
\40\ Id.
\41\ See, e.g., PJM Manual 37, Reliability Coordination Sec.
4.1; Southwest Power Pool, Congestion Management & Communication
Processes, 5, 12-13 (2013).
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22. While the existing pro-forma Open Access Transmission Tariff
(OATT) currently permits a transmission provider to use redispatch to
maintain reliability during transmission constraints,\42\ David Patton
of Potomac Economics, the independent market monitor for NYISO, MISO,
ISO-NE, and ERCOT, testified at the extreme weather technical
conference that he was ``unaware in non-market areas of any redispatch
that's actually being provided in order to supply transmission
service.'' \43\ The Commission should investigate how it may be able to
facilitate economic redispatch in non-RTOs and reduce usage of TLRs and
USFs in these areas. I am not aware of any systematic examination of
the magnitude of potential benefits to improved coordination practices,
but they are likely significant. During winter storm Uri, sophisticated
RTO transmission scheduling practices facilitated the flow of between
10,000 and 14,000 MW from PJM to support operations in MISO and
beyond.\44\ Yet the use of such practices is not universal. TLRs were
invoked on average over 200 times per year in the Eastern
Interconnection across the past four years.\45\ Public data for USFs,
used across the Western Interconnection where economic redispatch is
less prevalent, is not available.
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\42\ See pro forma OATT Sec. 33.2 (providing that network and
native load resources will be redispatched without regard to
ownership on a least cost basis to provide the amount of congestion
relief assigned to all network and native load customers, and that
the costs of such redispatch will be allocated on a load ratio share
basis).
\43\ See Technical Conference Tr., June 2, 2021, Docket No.
AD21-13-000, at 67:21-23 (filed July 22, 2021).
\44\ See Technical Conference Tr., Docket No. AD21-13, at 64:5-7
(Renuka Chatterjee) (filed July 22, 2021) (stating that PJM sent
10,000 to 14,000 MW to MISO and areas west of MISO during the
February event).
\45\ See NERC, TLR Logs, available at <a href="https://www.nerc.com/pa/rrm/TLR/Pages/TLR-Logs.aspx">https://www.nerc.com/pa/rrm/TLR/Pages/TLR-Logs.aspx</a> (last accessed June 14, 2022).
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23. I encourage non-RTO system operators to take action to improve
their transmission scheduling practices, to highlight for the
Commission challenges that they face in doing so, and to identify
potential solutions to those challenges. Absent voluntary improvements
by non-RTO system operators, I believe it would be appropriate for the
Commission to consider requiring changes to the pro forma OATT to
mandate transmission scheduling improvements. As MISO argues, ``greater
grid connectedness that has developed since Order No. 890, emerging
reliability needs not met by the status quo, including the TLR process,
and the inflexibility of the TLR process in responding to extreme
weather . . . have potentially created conditions that may make the
lack of reliability redispatch to bordering utilities potentially
unjust and unreasonable.'' \46\
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\46\ Post-Conference Comments of Midcontinent Independent System
Operator, Docket No. AD21-13, at 11 (filed Sept. 27, 2021).
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24. While some commenters endorsed the general idea of improving
transmission scheduling practices,\47\ MISO was the only entity to
provide detailed recommendations and factual support for doing so.\48\
MISO provides several suggestions to the Commission, including (1)
encouraging seams agreements that require non-RTOs/ISOs to compensate
RTOs/ISOs for redispatch provided through market flows and for RTOs/
ISOs to compensate non-RTOs/ISOs for reliability redispatch, when the
market flows or the reliability redispatch are the more economical
solution to a congestion problem at their seam, (2) allowing an RTO/ISO
to file a presumptively just and reasonable unexecuted joint operating
agreement or other agreement incorporating such redispatch provisions
in cases where an RTO/ISO cannot reach agreement with a neighboring
non-RTO/ISO transmission provider on joint redispatch,\49\ (3)
clarifying that the reliability redispatch provided under OATT section
33.2 is

[[Page 38041]]

available sub-hourly,\50\ and (4) modifying OATT section 33.2 to permit
redispatch not just by network resources of the transmission provider
and its network transmission customers, but also from other generators
including merchants.\51\ It also more broadly recommends ``[m]odifying
the pro forma OATT to require least cost dispatch of a transmission
provider's resources and to require network resources to manage seam
congestion'' such ``that, in addition to requiring reliability
redispatch when feasible to relieve constraints within the transmission
provider's own system, the transmission provider is also required to
provide such service to each of its directly-connected public utility
neighbors (or non-jurisdictional transmission providers that provide
reliability redispatch) prior to implementing TLR procedures.'' \52\
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\47\ See, e.g., Post-Conference Comments of Natural Resources
Defense Council, Sierra Club, Sustainable FERC Project, and Union of
Concerned Scientists, Docket No. AD21-13, at 13 (filed Sept. 27,
2017) (arguing that improved coordination of exports and imports
between RTOs/ISOs and non-RTO/ISO regions will enhance system
resilience); Post-Conference Comments of the Michigan Public Service
Commission, Docket No. AD21-13, at 10 (filed Sept. 24, 2021)
(strongly supporting improved coordination and management at market
seams).
\48\ See Post-Conference Comments of Midcontinent Independent
System Operator, Docket No. AD21-13, at 10 (filed Sept. 27, 2021).
\49\ Id. at 9, 14-15.
\50\ Id. at 11-12.
\51\ Id. at 13.
\52\ Id. at 11.
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25. These recommendations warrant serious consideration. A more
robust record is necessary to examine these ideas and other potential
actions to improve transmission system scheduling, management, and
coordination. I encourage stakeholders to bring forth proposals to the
Commission on this topic, and to provide comments and information
pertinent to the ideas discussed herein. I further recommend that the
Commission take action to gather more information on these issues, such
as by issuing a notice of inquiry, an order directing reports from NERC
and the relevant Balancing Authorities, or a combination thereof, in
order to gather more information on the use of path based management as
well as USFs and TLRs,\53\ the potential benefits of improved
transmission scheduling, management, and coordination practices, and
how such improvements could be achieved. Such proceedings could gather
data on the extent to which additional transmission capacity could be
freed up via a transition to flowgate methodologies, and the extent to
which TLR and USF procedures are unnecessarily curtailing transmission
that could have otherwise been facilitated by economic redispatch. They
could also examine how non-RTO market operators could implement
economic redispatch in the absence of organized markets setting
locational marginal prices.
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\53\ NERC publishes data on TLR events on its website, but does
not provide easily accessible information regarding the
circumstances necessitating TLR usage. See <a href="https://www.nerc.com/pa/rrm/TLR/Pages/TLR-Logs.aspx">https://www.nerc.com/pa/rrm/TLR/Pages/TLR-Logs.aspx</a> (last accessed June 13, 2022). I am not
aware of public data on the use of USFs in the Western
Interconnection.
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3. Properly Accounting for Resource Availability During Extreme Weather
26. As many commenters stressed in response to the Commission's
technical conference examining extreme weather, another pressing issue
is the need to ensure that planning procedures, resource adequacy
mechanisms, and reserves markets appropriately reflect the availability
of resources during extreme weather events, properly accounting for
common mode outages or other correlated outages.\54\
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\54\ See, e.g., Comments of Buckeye Power, Inc., Docket No.
AD21-13 at 7 (filed Apr. 15, 2021) (``[N]ew planning criteria for
resource adequacy should be developed that expressly address extreme
weather events and other unusual scenarios that can threaten
reliability.''); Comments of Tabors Caramanis Rudkevich, Docket No.
AD21-13, at 10-11, 21-24 (filed Apr. 15, 2021) (stating that
seasonal resource adequacy assessments ``do not . . . adequately
account for either common mode events or extreme events perceived to
have a low probability,'' and advocating for ``the adoption of
advanced resource adequacy methodologies and technologies that are
capable of evaluation of large numbers of stochastically generated
scenarios that incorporate and quantify both common mode events and
the probability of extreme events''); Comments of Dominion Energy
Services, Inc., Docket No. AD21-13, at 5 (filed Apr. 15, 2021)
(``Constraints arising on natural gas pipelines during extreme
weather may also impact the viability of operating reserves relied
upon by the Regional Transmission Organizations,'' potentially
leaving them ``with a false sense of security that [they have] a
sufficient amount of operating reserves'' when that is not the
case.); Comments of LS Power Development, LLC, Docket No. AD21-13,
at 4 (filed Apr. 15, 2021) (``[P]lanning procedures must recognize
and account for common mode failure among various resource classes
with respect to particular weather events and require protections
and redundancies to prevent catastrophic failures like those that
occurred in Texas.'').
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27. Resource adequacy methodologies, in particular, are an area
where accurately assessing anticipated availability of resources is
critical so as to ensure that applicable planning and market design
achieves the desired target level of system reliability. Commenters at
the extreme weather technical conference generally agreed that existing
methods are outdated and do not appropriately reflect extreme
weather.\55\ Failure to appropriately account for resource availability
jeopardizes the reliability of grid systems in extreme weather, so
doing the hard work of updating these methodologies is an urgent
concern.
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\55\ See, e.g., June 1, 2021 Tr. at 31:15 (Lisa Barton) (``[T]he
current deterministic planning methodology that we have used today [
] works when supply is highly dispatchable[,] when weather is
predictable[, and] when peak demand is reached only a few days a
year,'' and ``fundamentally needs to change'' to address current
conditions); 112-113, 127-128 (Mark Lauby) (highlighting the
outdated nature of 1-in-10 LOLE, and noting that it was developed on
the assumption that generator forced outages are independent, an
unrealistic assumption given the likelihood of common mode events
caused by extreme weather); at 118 (Richard Tabors) (``Our resource
adequacy metrics and planning methods systematically understate the
probability, the depth, and economic health and safety costs of high
impact events.'').
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28. NYISO and PJM have made significant strides recently in
establishing processes to ensure that their capacity markets better
account for correlated availability of resources,\56\ but more work is
needed to implement these mechanisms, and to ensure that they are
fairly assessing the contributions of different resource types. While
NYISO's approved proposal explicitly contemplates extending this
methodology to all resource types (albeit while providing very limited
detail on how it will do so),\57\ PJM's approved method is confined to
wind, solar, storage, and hybrid resources.\58\ ISO-NE's external
market monitor has argued that applying ELCC to thermal resources would
better reflect their value.\59\
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\56\ See PJM Interconnection, L.L.C., 176 FERC ] 61,056, at P 3
(2021) (approving a proposal by PJM to implement an ELCC methodology
for crediting variable and limited duration resources); New York
Independent System Operator, 179 FERC ] 61,102, at PP 75-82 (2022)
(approving NYISO's proposal to implement a marginal capacity
accreditation design via either ELCC or a similar Marginal
Reliability Improvement technique).
\57\ 179 FERC ] 61,102 at PP 79, 90.
\58\ 176 FERC ] 61,056 at P 7.
\59\ See Potomac Economics, 2020 Assessment of the ISO New
England Electricity Markets, June 2021 at 92 (``EFORd alone does not
accurately describe'' the reliability value of ``intermittent
renewables, energy-limited resources, long lead time or very large
conventional generators, and generators that can experience a common
loss of a limited fuel supply'' because ``these resource types pose
the risk of correlated outage or limited availability of a large
amount of capacity under peak conditions''), and 84 (arguing that
the availability of these resource types is overestimated in GE-
MARS, ISO-NE's resource adequacy model).
---------------------------------------------------------------------------

29. Further inquiry is necessary to investigate appropriate
methodologies for accounting for correlated outages of resources during
extreme weather, including common mode outages related to unavailable
fuel supply such as gas-fired resources without fuel during winter
events or hydro-electric resources experiencing drought conditions, and
correlated de-rates that may occur in relation to extreme weather such
as difficulty cooling thermal facilities. I urge stakeholders, grid
operators, and my colleagues at the Commission to work expeditiously to
address these questions and facilitate appropriate market reforms.

C. Conclusion

30. As the Extreme Weather NOPR highlights, climate change poses a
severe reliability threat to the bulk electric system. Addressing that
threat is

[[Page 38042]]

a multi-faceted challenge posing complex issues for which there is no
single answer. However, if implemented in a comprehensive and cost-
effective manner, today's NOPR promises to be an important and prudent
step forward in protecting customers against the effects of extreme
weather. By taking complementary actions in the future that build on
this step, the Commission will continue to fulfill its responsibility
of ensuring bulk electric system reliability.
For these reasons, I respectfully concur.

-----------------------------------------------------------------------

Allison Clements,

Commissioner.
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Transmission System Planning Performance Requirements for Extreme
Weather
Docket No. RM22-10-000
(Issued June 16, 2022)
PHILLIPS, Commissioner, concurring:
1. I concur in today's Notice of Proposed Rulemaking \1\ to
emphasize the critical importance of ensuring that the Bulk-Power
System is prepared for extreme weather events in both the near-term and
long-term. While this NOPR has the potential to reduce the threat to
the reliability of the electric system, I note that we must remain
vigilant as much work remains to ensure reliable delivery of power to
consumers during times of stress and to resolve resilience concerns on
the transmission system.
---------------------------------------------------------------------------

\1\ Transmission System Planning Performance Requirements for
Extreme Weather, 179 FERC ] 61,195 (2022) (NOPR).
---------------------------------------------------------------------------

2. Climate change and extreme weather are, of course, complex
issues of enormous importance to the United States. In my view, this
NOPR is another step on the path to mitigating the long-term effects of
extreme weather; however, I remain concerned about the grid's near-term
reliability, particularly during the upcoming summer and winter
seasons.\2\ Still, with that in mind, I am voting in favor of issuing
this NOPR because it is needed as an incremental improvement to
Reliability Standard TPL-001-5.1 (Transmission System Planning
Performance Requirements), which I believe currently contains a
reliability gap.\3\
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\2\ On August 24, 2021, the Commission approved revised
Reliability Standards to address certain reliability risks posed by
extreme cold weather. Cold Weather Reliability Standards, 176 FERC ]
61,119, at P 1 (2021).
\3\ To its credit, in the wake of Winter Storm Uri, the North
Electric Reliability Corporation (NERC) issued a level 2 NERC Alert
to industry on cold weather preparations for extreme weather events,
which acknowledged the reliability risks associated with more
frequent extreme weather conditions. NERC, Alert R-2021-08-18-01
Extreme Cold Weather Events (Aug. 18, 2021) (``The recent extreme
cold weather events across large portions of North America have
highlighted the need to assess current operating practices and
identify some recommended improvements, so that system operations
personnel are better prepared to address these challenges. The
events have caused major interruptions to resources, transmission
paths and ultimately, end-use customers.'').
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3. The NOPR proposes to direct NERC to modify Reliability Standard
TPL-001-5.1 to require the development of benchmark planning cases
based on past extreme heat and cold weather events.\4\ Currently,
Reliability Standard TPL-001-5.1 does not prescribe specific
benchmarks, and I believe determining and using the appropriate
benchmark will lead to better planning. While extreme weather can be
unpredictable, applying a suitable benchmark study should lead to
understanding resource availability and load shedding requirements
under harsh conditions. Indeed, using benchmarks may also improve
interregional coordination when load shedding and cascading outages
occur.\5\
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\4\ NOPR at PP 51-56.
\5\ See infra at PP 6-8.
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4. The NOPR also proposes to direct NERC to modify Reliability
Standard TPL-001-5.1 to require corrective action plans when
performance requirements for extreme heat and cold weather events are
not met.\6\ Currently, the reliability standards require that
responsible entities evaluate possible actions to reduce the likelihood
or mitigate the consequences of such events. These entities, however,
are not obligated to take corrective actions to ensure such failures do
not happen again.\7\ I believe this NOPR rightly identifies this gap
and assures that transmission planners rigorously address uncertainties
surrounding extreme weather events in the planning process.
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\6\ NOPR at PP 6, 83.
\7\ Id. at P 83 (``[P]lanning coordinators and transmission
planners are required to evaluate possible actions to reduce the
likelihood or mitigate the consequences of extreme events but are
not obligated to developed corrective action plans. Specifically, if
such events are found to cause cascading outages, they need only be
evaluated for possible actions designed to reduce their likelihood
or mitigate their consequences and adverse impacts [citation
removed]. Accordingly, because of their potential severity, we
believe that extreme heat and cold weather events should require
evaluation and the development and implementation of corrective
action plans to help protect against system instability,
uncontrolled separation, or cascading failures as a result of a
sudden disturbance or unanticipated failure of system elements.'').
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5. Looking forward, and beyond the important charge we have
proposed here, I believe the Commission should next consider further
interregional reliability planning reforms. When we issued a NOPR on
regional transmission planning and cost allocation in April, I said in
my concurrence:
As we continue to examine those issues, I urge the Commission to
act expeditiously to propose interregional reliability planning
reforms. Looking beyond regional boundaries is important so that cost-
efficient regional and interregional projects can be considered and
studied together. We should consider whether neighboring regions should
adopt common planning assumptions and methods that allow for region-
specific inputs. Additionally, I believe we must consider whether to
adopt a requirement for a minimum amount of interregional transfer
capacity to protect against shortfalls, especially during extreme
weather events.\8\
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\8\ Building for the Future through Electric Regional
Transmission Planning and Cost Allocation and Generator
Interconnection, 179 FERC ] 61,028 (2022) (Phillips, Comm'r,
concurring, at P 7).
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I note we will continue to develop the record in our proceeding on
regional transmission planning and cost allocation, and in response to
today's NOPR. We should examine these and other records closely to
determine the best course of further action on this ripe issue.
6. The regional nature of extreme weather highlights the
difficulties facing our industry in addressing highly variable risks.
The challenges facing California are very different from the challenges
facing Texas. I believe a minimum transfer capability requirement is
needed, because enhanced transfer capability may be the best way to
take advantage of the diversity of energy sources and the many ways in
which we can support the grid. Order No. 1000 was intended to encourage
more interregional planning and development,\9\ but, simply put,
interregional projects are not being constructed,\10\ and transfer
capacity in

[[Page 38043]]

effect has been limited. Many commenters also point out the importance
of adopting a minimum level of interregional transfer capability.\11\
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\9\ Transmission Planning and Cost Allocation by Transmission
Owning and Operating Public Utilities, Order No. 1000, 136 FERC ]
61,051 (2011), order on reh'g, Order No. 1000-A, 139 FERC ] 61,132
(2012), order on reh'g and clarification, Order No. 1000-B, 141 FERC
] 61,044 (2012), aff'd sub nom. D.C. Pub. Serv. Auth. v. FERC, 762
F.3d 41 (D.C. Cir. 2014).
\10\ See Americans for a Clean Energy Grid, Planning for the
Future: FERC's Opportunity to Spur More Cost-Effective Transmission
Infrastructure, <a href="https://cleanenergygrid.org/wp-content/uploads/2021/01/ACEG_Planning-for-the-Future1.pdf">https://cleanenergygrid.org/wp-content/uploads/2021/01/ACEG_Planning-for-the-Future1.pdf</a> (``For all of the best efforts
of the Commission and regional planning authorities, the current set
of transmission regulations have resulted in inadequate levels of
infrastructure that have burdened the interconnection process with
the task of planning new network facilities--a task that sh

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