Rule2023-13286
Transmission System Planning Performance Requirements for Extreme Weather
Primary source
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Published
June 23, 2023
Effective
September 21, 2023
Issuing agencies
Energy DepartmentFederal Energy Regulatory Commission
Abstract
The Federal Energy Regulatory Commission directs the North American Electric Reliability Corporation, the Commission-certified Electric Reliability Organization, to develop a new or modified Reliability Standard no later than 18 months of the date of publication of this final rule in the Federal Register to address reliability concerns pertaining to transmission system planning for extreme heat and cold weather events that impact the Reliable Operation of the Bulk- Power System. Specifically, we direct the North American Electric Reliability Corporation to develop a new or modified Reliability Standard that requires the following: development of benchmark planning cases based on prior extreme heat and cold weather events and/or future meteorological projections; planning for extreme heat and cold events using steady state and transient stability analyses that cover a range of extreme weather scenarios, including the expected resource mix's availability during extreme weather conditions and the broad area impacts of extreme weather; and corrective action plans that include mitigation activities for specified instances where performance requirements during extreme heat and cold events are not met.
Full Text
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[Federal Register Volume 88, Number 120 (Friday, June 23, 2023)]
[Rules and Regulations]
[Pages 41262-41287]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-13286]
[[Page 41261]]
Vol. 88
Friday,
No. 120
June 23, 2023
Part IV
Department of Energy
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Federal Energy Regulatory Commission
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18 CFR Part 40
Transmission System Planning Performance Requirements for Extreme
Weather; Final Rule
Federal Register / Vol. 88, No. 120 / Friday, June 23, 2023 / Rules
and Regulations
[[Page 41262]]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
18 CFR Part 40
[Docket No. RM22-10-000; Order No. 896]
Transmission System Planning Performance Requirements for Extreme
Weather
AGENCY: Federal Energy Regulatory Commission, Department of Energy.
ACTION: Final rule.
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SUMMARY: The Federal Energy Regulatory Commission directs the North
American Electric Reliability Corporation, the Commission-certified
Electric Reliability Organization, to develop a new or modified
Reliability Standard no later than 18 months of the date of publication
of this final rule in the Federal Register to address reliability
concerns pertaining to transmission system planning for extreme heat
and cold weather events that impact the Reliable Operation of the Bulk-
Power System. Specifically, we direct the North American Electric
Reliability Corporation to develop a new or modified Reliability
Standard that requires the following: development of benchmark planning
cases based on prior extreme heat and cold weather events and/or future
meteorological projections; planning for extreme heat and cold events
using steady state and transient stability analyses that cover a range
of extreme weather scenarios, including the expected resource mix's
availability during extreme weather conditions and the broad area
impacts of extreme weather; and corrective action plans that include
mitigation activities for specified instances where performance
requirements during extreme heat and cold events are not met.
DATES: This rule is effective September 21, 2023.
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#e18c80898c8e8e85cf8c8893898498858093a187849382cf868e97"><span class="__cf_email__" data-cfemail="402d21282d2f2f246e2d293228253924213200262532236e272f36">[email protected]</span></a>
Gonzalo E. Rodriguez (Legal Information), Office of the General
Counsel, Federal Energy Regulatory Commission, 888 First Street NE,
Washington, DC 20426, (202) 502-8568, <a href="/cdn-cgi/l/email-protection#80e7efeefae1ecefaef2efe4f2e9e7f5e5fac0e6e5f2e3aee7eff6"><span class="__cf_email__" data-cfemail="03646c6d79626f6c2d716c67716a6476667943656671602d646c75">[email protected]</span></a>
SUPPLEMENTARY INFORMATION:
Table of Contents
Paragraph
Nos.
Introduction................................................ 1
II. Background.............................................. 8
A. Legal Authority...................................... 8
B. Reliability Standard TPL-001-5.1 (Transmission System 10
Planning Performance Requirements).....................
C. Prior Commission Actions To Address the Reliability 14
Impacts of Extreme Weather.............................
D. Notice of Proposed Rulemaking........................ 17
III. The Need for Reform.................................... 20
IV. Discussion.............................................. 25
A. Directive to NERC To Develop New or Modified 25
Reliability Standard...................................
B. Develop Benchmark Events and Planning Cases Based on 30
Major Prior Extreme Heat and Cold Weather Events and/or
Meteorological Projections.............................
1. Comments......................................... 32
2. Commission Determination......................... 35
C. Definition of ``Wide-Area''.......................... 41
1. Comments......................................... 44
2. Commission Determination......................... 50
D. Entities Responsible for Developing Benchmark Events 51
and Planning Cases, and for Conducting Transmission
Planning Studies of Wide-Area Events...................
1. Comments......................................... 53
a. Entity Responsible for Development of 53
Benchmark Events...............................
b. Entity Responsible for Development of 54
Planning Cases and Conducting Transmission
Planning Studies of Wide-Area Events...........
2. Commission Determination......................... 58
a. Entity Responsible for Establishing Benchmark 58
Events.........................................
b. Entities Responsible for Development of 60
Planning Cases and Conducting Transmission
Planning Studies of Wide-Area Events...........
E. Coordination Among Registered Entities and Sharing of 63
Data and Study Results.................................
1. Comments......................................... 66
2. Commission Determination......................... 72
F. Concurrent/Correlated Generator and Transmission 78
Outages................................................
1. Comments......................................... 82
2. Commission Determination......................... 88
G. Conduct Transmission System Planning Studies for 95
Extreme Heat and Cold Weather Events...................
1. Steady State and Transient Stability Analyses.... 95
a. Comments..................................... 98
b. Commission Determination..................... 111
2. Sensitivity Analysis............................. 118
a. Comments..................................... 121
b. Commission Determination..................... 124
3. Modifications to the Traditional Planning 127
Approach...........................................
a. Comments..................................... 131
b. Commission Determination..................... 134
H. Implement a Corrective Action Plan if Performance 139
Standards Are Not Met..................................
1. Comments......................................... 143
a. Jurisdictional Issues........................ 143
b. Corrective Action Plans...................... 144
c. Generation and Transmission Capacity Increase 148
and Resource Adequacy Issues...................
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d. Notification to Applicable Regulatory 151
Authorities or Governing Bodies Responsible for
Retail Electric Service Issues.................
2. Commission Determination......................... 152
a. Jurisdictional Issues........................ 154
b. Circumstances That Require Corrective Action 157
Plans..........................................
c. Generation and Transmission Capacity Increase 161
and Resource Adequacy Issues...................
d. Notification to Applicable Regulatory 165
Authorities or Governing Bodies Responsible for
Retail Electric Service Issues.................
I. Other Extreme Weather-Related Events and Issues...... 169
1. Comments......................................... 170
2. Commission Determination......................... 177
J. Reliability Standard Development and Implementation 181
Timeline...............................................
1. Comments......................................... 182
2. Commission Determination......................... 188
V. Information Collection Statement......................... 194
VI. Environmental Analysis.................................. 196
VII. Regulatory Flexibility Act............................. 197
VIII. Document Availability................................. 200
IX. Effective Date and Congressional Notification........... 203
Appendix A: Commenter Names.................................
I. Introduction
1. Pursuant to section 215(d)(5) of the Federal Power Act (FPA),\1\
the Commission directs the North American Electric Reliability
Corporation (NERC), the Commission-certified Electric Reliability
Organization (ERO), to submit a new Reliability Standard or
modifications to Reliability Standard TPL-001-5.1 that addresses
concerns pertaining to transmission system planning for extreme heat
and cold weather events that impact the Reliable Operation \2\ of the
Bulk-Power System.\3\
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\1\ 16 U.S.C. 824o(d)(5).
\2\ 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).
\3\ 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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2. We take this action to address challenges associated with
planning for extreme heat and cold weather events, particularly those
that occur during periods when the Bulk-Power System must meet
unexpectedly high demand.\4\ Extreme heat and cold weather events have
occurred with greater frequency in recent years, and are projected to
occur with even greater frequency in the future.\5\ These events have
shown that load shed during extreme temperature result in unacceptable
risk to life and have extreme economic impact.\6\ As such, the impact
of concurrent failures of Bulk-Power System generation and transmission
equipment and the potential for cascading outages \7\ that may be
caused by extreme heat and cold weather events should be studied and
corrective actions should be identified and implemented.
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\4\ 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).
\5\ See e.g., 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).
NOAA, Adam Smith, 2022 U.S. Billion-dollar Weather and Climate
Disasters in Historical Context (Jan. 10, 2023), <a href="https://www.climate.gov/news-features/blogs/2022-us-billion-dollar-weather-and-climate-disasters-historical-context">https://www.climate.gov/news-features/blogs/2022-us-billion-dollar-weather-and-climate-disasters-historical-context</a>.
\6\ FERC, NERC, and Regional Entity Staff, The February 2021
Cold Weather Outages in Texas and the South Central United States,
at 9, 192 (Nov. 16, 2021), <a href="https://www.ferc.gov/media/february-2021-cold-weather-outages-texas-and-south-central-united-states-ferc-nerc-and">https://www.ferc.gov/media/february-2021-cold-weather-outages-texas-and-south-central-united-states-ferc-nerc-and</a> (2021 Cold Weather Event Report).
\7\ NERC Glossary of Terms Used in Reliability Standards
(Updated Mar. 8, 2023) (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 summer heat in regions like the Pacific Northwest and
extreme winter cold in regions like Texas have increased demand for
electricity at times when historically demand has been low.\9\ As
events such as these will likely continue to present challenges in the
future, transmission planners and planning coordinators must account
for this new reality in 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
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\ each of which put stress on
the Bulk-Power System and resulted in some degree of load shed. In some
cases, these events nearly caused system collapse
[[Page 41264]]
and uncontrolled blackouts, which were avoided due to system operator
actions.
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\11\ See Transmission System Planning Performance Requirements
for Extreme Weather, Notice of Proposed Rulemaking, 87 FR 38,020
(June 27, 2023), 179 FERC ] 61,195 at PP 24-36 (2022) (NOPR)
(discussing these prior events in detail).
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5. Given the reliability risks associated with extreme heat and
cold weather events, including the potential for widespread blackouts,
maintaining the reliability of the Bulk-Power System requires
transmission system planning to account for the potential impact of
extreme heat and cold weather over wide geographical areas, and to
consider the changing resource mix. Reliability Standard TPL-001-4 \12\
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.\13\ Both it and its successor, TPL-001-5.1,
include provisions for transmission planners and planning coordinators
to study system performance under extreme events based on their
experience; \14\ however, neither standard specifically requires
entities to conduct performance analysis for extreme heat and cold
weather, despite the fact that such conditions have clearly
demonstrated a risk to the Reliable Operation of the Bulk-Power System,
thus leaving a reliability gap in system planning.
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\12\ Effective July 1, 2023, Reliability Standard TPL-001-4 will
be replaced by Reliability Standard TPL-001-5.1. Unless otherwise
specified, the use of Reliability Standard TPL-001-5.1 in this final
rule also refers to its predecessor, Reliability Standard TPL-001-4.
\13\ Reliability Standard TPL-001-5, at 1.
\14\ Id. at tbl. 1.
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6. To address this reliability gap, we direct NERC to develop a new
or modified Reliability Standard that requires the following: (1) the
development of benchmark planning cases based on information such as
major prior extreme heat and cold weather events and/or future
meteorological projections; (2) planning for extreme heat and cold
weather events using steady state and transient stability analyses
expanded to cover a range of extreme weather scenarios, including
expected availability of the resource mix during extreme heat and cold
weather conditions, and including the broad area impacts of extreme
heat and cold weather; and (3) the development of corrective action
plans that mitigate specified instances where performance requirements
during extreme heat and cold weather events are not met. In directing
NERC to develop a new or modified Reliability Standard, we are not
proposing specific requirements. Instead, we identify concerns that
should be addressed by the proposed Reliability Standard. NERC may
propose to develop a new or modified Reliability Standard that address
our concerns in an equally efficient and effective manner; however,
NERC's proposal should explain how it addresses the Commission's
concerns.\15\
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\15\ 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, 72 FR 40717
(July 25, 2007), 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'').
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7. We direct NERC to submit the proposed new or modified
Reliability Standard no later than 18 months from the publication of
this final rule in the Federal Register. We believe that an 18-month
deadline provides sufficient time for NERC to develop a responsive
Standard in consideration of the issues involved and the steps in
NERC's standards development process. Further, we direct NERC to ensure
that the proposed new or modified Reliability Standard becomes
mandatory and enforceable beginning no later than 12 months from the
effective date of Commission approval of the new or modified
Reliability Standard.
II. Background
A. Legal Authority
8. Section 215 of the FPA provides that the Commission may certify
an ERO, the purpose of which is to develop mandatory and enforceable
Reliability Standards, subject to Commission review and approval.\16\
Reliability Standards may be enforced by the ERO, subject to Commission
oversight, or by the Commission independently.\17\ Pursuant to section
215 of the FPA, the Commission established a process to select and
certify an ERO,\18\ and subsequently certified NERC.\19\
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\16\ 16 U.S.C. 824o(c).
\17\ Id. 824o(e).
\18\ 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).
\19\ 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.\20\ 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, or when ordering the ERO to submit to the
Commission a proposed Reliability Standard that addresses a specific
matter.\21\
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\20\ 16 U.S.C. 824o(d)(5).
\21\ 18 CFR 39.5(g) (2022).
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B. Reliability Standard TPL-001-5.1 (Transmission System Planning
Performance Requirements)
10. Transmission system planning refers to the evaluation of future
transmission system performance and creation of corrective action plans
that include mitigation to remedy identified deficiencies.\22\ The
planning horizon associated with transmission system planning covers
near term (one to five years), long-term (six to ten years), and
beyond.\23\
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\22\ NERC Glossary (defining ``Planning Assessment'' as
``documented evaluation of future Transmission System performance
and Corrective Action Plans to remedy identified deficiencies'').
\23\ Id. (defining ``Near-Term Transmission Planning Horizon''
and ``Long-Term Transmission Planning Horizon'').
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11. Reliability Standard TPL-001-5.1 establishes minimum
transmission system planning performance requirements to plan a Bulk-
Power System that will operate reliably over a broad spectrum of system
conditions and following a wide range of probable contingencies.\24\
Under Requirement R2 of Reliability Standard TPL-001-5.1, each
transmission planner and planning coordinator must prepare an annual
planning assessment for its portion of the Bulk-Power System.\25\ This
planning assessment is required for both near-term and long-term
transmission planning horizons.\26\
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\24\ Reliability Standard TPL-001-5.1, Purpose.
\25\ Id., at 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 (converge numerically) or not
solve (diverge numerically). 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).
\26\ See Reliability Standard TPL-001-5.1, at Requirement 2.1
(Near-Term Transmission Planning Horizon) and Requirement R.2.2
(Long-Term Transmission Planning Horizon).
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12. Requirements R3 and R4 of Reliability Standard TPL-001-5.1
[[Page 41265]]
require in part that planning coordinators and transmission planners
conduct steady state and stability studies 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.
13. Table 1 of Reliability Standard TPL-001-5.1 includes a list of
examples of planning events (i.e., Category P1 through P7) \27\ for
which specific studies may be required 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.''
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\27\ Categories P1 through P7 are defined in TPL-001-5.1 in
Table 1--Steady State & Stability Performance Planning Events.
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C. Prior Commission Actions To Address the Reliability Impacts of
Extreme Weather
14. On June 1 and 2, 2021, the Commission convened a staff-led
technical conference on Climate Change, Extreme Weather, and Electric
System Reliability.\28\ 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.\29\
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\28\ Climate Change, Extreme Weather, and Electric System
Reliability, Notice of Technical Conference, Docket No. AD21-13-000,
at 1 (Mar. 5, 2021).
\29\ Id. at 2.
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15. In the pre- and post-conference comments, industry experts
agreed that extreme weather events are likely to become more severe and
frequent in the future.\30\ They also acknowledged the challenges
associated with planning for extreme events, including shifting
scheduled maintenance and canceling or recalling transmission and
generation assets from scheduled maintenance to meet demand under
unexpected circumstances.\31\ Further, commenters discussed potential
changes to the Reliability Standards to address planning and
operational preparedness for energy adequacy risks,\32\ contingencies
related to extreme weather events, and wide-area transmission planning
and development challenges, among others.\33\ Comments also addressed
more directly the potential reliability gaps in the existing set of
Reliability Standards, including Reliability Standard TPL-001-4, and
identified potential solutions.\34\
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\30\ 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; AEP Pre-Conference Comments at 5.
\31\ June 2, 2021, Tr. at 21-23 (Wesley Yeomans, Vice President
of Operations, NYISO).
\32\ ISO-New England Inc. Pre-Conference Comments at 10.
\33\ Midcontinent Independent System Operator (MISO) Pre-
Conference Comments at 4-5, 14-17.
\34\ See e.g., NERC Pre-Conference Comments at 6; MISO Post-
Conference Comments at 20; Pacific Gas & Electric Company Pre-
Conference Comments at 19-20; PJM Post-Conference Comments at 21;
CAISO Post-Conference Comments at 10.
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16. On August 24, 2021, and February 16, 2023, the Commission
approved revised Reliability Standards to address some of the
reliability risks posed by extreme cold weather.\35\ These Reliability
Standards, among other things, require generators to implement plans
for cold weather preparedness and implement freeze protection measures
to mitigate the reliability impacts of extreme cold weather on their
generating units. The new and revised standards also 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.\36\
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\35\ 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) and Order Approving Extreme Cold Weather
Reliability Standards EOP-011-3 and EOP-012-1 and Directing
Modification of Reliability Standard EOP-012-1, 182 FERC ] 61,094
(2023).
\36\ Id. P 3.
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D. Notice of Proposed Rulemaking
17. On June 26, 2022, the Commission issued the Notice of Proposed
Rulemaking (NOPR) proposing to direct NERC to develop a new or modified
Reliability Standard to address a lack of a long term planning
requirement for extreme heat and cold weather events.\37\ Specifically,
the Commission proposed to direct NERC to develop either modifications
to Reliability Standard TPL-001-5.1 or a new Reliability Standard, to
require the following: (1) development of benchmark planning cases
based on major prior extreme heat and cold weather events and/or
meteorological projections; (2) planning for extreme heat and cold
weather 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 wide-area impacts of extreme heat
and cold weather; and (3) development of corrective action plans that
mitigate any instances where performance requirements for extreme heat
and cold weather events are not met.\38\
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\37\ NOPR, 179 FERC ] 61,195 at P 47.
\38\ Id. P 51.
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18. The NOPR preliminarily found that, based on the wide geographic
impacts on the Bulk-Power System of previous extreme heat and cold
weather events, the study criteria for extreme heat and cold events
should 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.\39\
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\39\ Id. P 67.
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19. The NOPR sought comments on all aspects of the proposed
directives, including among others: (1) the development of benchmark
planning cases; (2) requiring transmission planning studies of wide-
area extreme heat and cold events; (3) the study of concurrent
generator and transmission outages; (4) the analysis of sensitivities;
(5) modifications to current deterministic planning approaches; (6)
coordination among registered entities and sharing of study results;
(7) requiring entities to implement corrective action plans if
performance standards are not met; and (8) whether the final rule
should address other extreme weather events beyond heat and cold
events. The comment period for the NOPR ended on August 26, 2022, and
the Commission received 33 sets of comments.\40\
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\40\ A list of commenters to the NOPR and the abbreviated names
used in this final rule appear in Appendix A.
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III. The Need for Reform
20. 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.
The NOPR discussed seven major extreme heat and cold weather events
that had
[[Page 41266]]
occurred since 2011.\41\ Of these, four (2011, 2013, 2018, and 2021)
were extreme cold weather events that nearly caused system collapse if
the operators had not acted to shed load.\42\ The remaining three
events (2014, 2020, and 2021) were extreme heat weather events that
resulted in generation losses and varying degrees of load shedding.\43\
Since the issuance of the NOPR, another extreme cold weather event
indicated reliability challenges faced by the Bulk-Power System. In
December 2022, Winter Storm Elliott caused extreme cold conditions that
significantly stressed the Bulk-Power System, forcing some utilities to
deploy rolling blackouts to preserve Bulk-Power System reliability.\44\
These extreme heat and cold events demonstrate a risk to Reliable
Operation of the Bulk-Power System.
---------------------------------------------------------------------------
\41\ For a full discussion of these extreme weather events, see
NOPR, 179 FERC ] 61,195 at PP 24-33.
\42\ See e.g., 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>
(impacting nearly 4.4 million electric customers in ERCOT); 2013 PJM
Heat Wave Analysis at 5 (impacting approximately 45,000 customers in
PJM).
\43\ See, e.g., 2021 Cold Weather Event Report at 133.
\44\ FERC, FERC, NERC to Open Joint Inquiry into Winter Storm
Elliott (Dec. 2022), <a href="https://www.ferc.gov/news-events/news/ferc-nerc-open-joint-inquiry-winter-storm-elliott">https://www.ferc.gov/news-events/news/ferc-nerc-open-joint-inquiry-winter-storm-elliott</a>.
---------------------------------------------------------------------------
21. While wide-area extreme heat and cold weather events may not
occur every year, their frequency and magnitude are expected to
increase. The National Oceanic and Atmospheric Administration's (NOAA)
data and analyses show an increasing trend in extreme heat and cold
weather events,\45\ and the U.S. Environmental Protection Agency
climate change indicators also show upward trends in heatwave
frequency, duration, and intensity.\46\ NOAA states that climate change
is also driving more compound events, i.e., multiple extreme events
occurring simultaneously or successively, such as concurrent heat waves
and droughts, and more extreme heat conditions in cities.\47\
---------------------------------------------------------------------------
\45\ See NOAA., Nat'l Centers for Envtl. Info., U.S. Billion-
Dollar Weather and Climate Disasters (2023), <a href="https://www.ncei.noaa.gov/access/billions/">https://www.ncei.noaa.gov/access/billions/</a>.
\46\ U.S. EPA, Climate Change Indicators in the United States
(last updated May 2, 2023), <a href="https://www.epa.gov/climate-indicators">https://www.epa.gov/climate-indicators</a>.
\47\ NOAA, 2022 U.S. Billion Dollar Weather and Climate
Disasters in Historical Context (2023), <a href="https://www.climate.gov/news-features/blogs/2022-us-billion-dollar-weather-and-climate-disasters-historical-context">https://www.climate.gov/news-features/blogs/2022-us-billion-dollar-weather-and-climate-disasters-historical-context</a>.
---------------------------------------------------------------------------
22. These conditions have created an urgency to address the
negative impact of extreme weather on the reliability of the Bulk-Power
System. To that end, the directives to NERC in this final rule aim to
improve system planning specifically for extreme heat and cold weather
events. 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. Responsible entities could then use the studies to develop
transmission system operational strategies or corrective action plans
with mitigations that could be deployed in preparation for extreme heat
and cold events.
23. The current transmission planning Reliability Standards,
however, do not obligate transmission planners and planning
coordinators to consider extreme hot and cold weather in their
transmission assessments. In particular, Reliability Standard TPL-001-
5.1 requires steady state and stability analyses to be performed for
certain extreme events but does not require steady state and stability
analyses for extreme heat and cold conditions.\48\ Likewise, while
Reliability Standard TPL-001-5.1 Table 1, provisions 2.f (stability)
and 3.b (steady state), requires responsible entities to study events
based on operating experience that may result in a wide-area
disturbance,\49\ the Standard does not specify the study of extreme
heat or cold conditions.
---------------------------------------------------------------------------
\48\ See Reliability Standard TPL-001-5.1, at Requirements R3
and R4 and Table 1.
\49\ Id. at Table 1, provisions 2.f and 3.b.
---------------------------------------------------------------------------
24. System planning measures alone will not eliminate the
reliability risk associated with extreme heat and cold events. The
directives to improve transmission planning discussed in this final
rule will prepare the Bulk-Power System for extreme weather events in
the long term and will work together with the requirements in the Cold
Weather Reliability Standards to mitigate the near-term reliability
impact of extreme weather events. Improved 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.
IV. Discussion
A. Directive to NERC To Develop New or Modified Reliability Standard
25. Pursuant to FPA section 215(d)(5), we adopt the NOPR proposal
and direct NERC to submit a new Reliability Standard or modifications
to Reliability Standard TPL-001-5.1 requiring transmission system
planning for extreme heat and cold weather events that impact the
Reliable Operation of the Bulk-Power System. For the reasons discussed
in section III above, we conclude that it is necessary to update the
transmission planning Reliability Standard to reflect the impact of
extreme heat and cold weather events on the reliability of the Bulk-
Power System. Most commenters support the NOPR proposal to develop
mandatory transmission system planning requirements for extreme heat
and cold weather events.\50\ Commenters also agree that Commission
action is necessary to address the reliability gaps pertaining to the
consideration of extreme heat and cold weather events that exist in
current transmission planning processes.\51\
---------------------------------------------------------------------------
\50\ See, e.g., MISO Transmission Owners Comments at 1-2;
Indicated Trade Associations Comments at 1-2; NYISO Comments at 1-2;
AEP Comments at 1; ACP Comments at 1; PIOs Comments at 1.
\51\ See, e.g., EPRI Comments at P 4.
---------------------------------------------------------------------------
26. Although supportive of the need to consider extreme weather in
the transmission planning process, PJM Interconnection, L.L.C. (PJM) is
critical of the Commission's proposed ``piecemeal'' approach and
suggests that the Commission harmonize this rulemaking with other
Commission actions on transmission planning.\52\ While we agree that it
is important for NERC and applicable planning entities to consider how
requirements implemented pursuant to this rulemaking may interact with
processes carried out pursuant to other Commission actions on
transmission planning, we disagree with PJM's suggestion that this
proceeding is not an appropriate forum for directing changes to the
NERC Reliability Standards. While there is undoubtedly a nexus between
the long-term planning for expected changes in resources and demand as
contemplated in Docket No. RM21-17-000 and Reliability Standards for
extreme weather, each set of reforms is subject to differing statutory
schemes and other considerations, and each aims at related but distinct
challenges. The Commission's transmission planning reform efforts
require individual consideration, as they each concern different
transmission planning objectives, time horizons, and areas of
Commission jurisdiction. This proceeding is conducted pursuant to the
Commission's jurisdiction under section 215 of the FPA and contemplates
transmission planning entity actions that may be needed in the planning
timeframe of six to ten years and beyond to mitigate the impacts of
extreme weather, whereas the proceeding in Docket No. RM21-17-000 was
initiated
[[Page 41267]]
pursuant to the Commission's jurisdiction under section 206 of the FPA,
considers a more fulsome range of practices that may be required to
render rates just and reasonable, and contemplates a planning horizon
of 20 years.\53\ While addressing these related efforts in a single
proceeding may have benefits, it also would risk complicating the
development of solutions and making the process more unwieldy. The
Commission has thus determined to take this step to facilitate
solutions to one aspect of the extreme weather challenge, as part of a
series of actions that build on each other by seeking to address the
many areas that affect extreme weather reliability.
---------------------------------------------------------------------------
\52\ PJM Comments at 3-4, 7.
\53\ See Building for the Future Through Elec. Reg'l
Transmission Planning & Cost Allocation & Generator Interconnection,
Notice of Proposed Rulemaking, 87 FR 26504, (May 4, 2022), 179 FERC
] 61,028 (2022).
---------------------------------------------------------------------------
27. Accordingly, we adopt the NOPR proposal and direct NERC to
develop a new or modified Reliability Standard to require the
following: (1) development of benchmark planning cases based on major
prior extreme heat and cold weather events and/or meteorological
projections; (2) planning for extreme heat and cold weather 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 wide-area impacts of extreme heat and cold weather; and
(3) development of corrective action plans that mitigate specified
instances where performance requirements for extreme heat and cold
weather events are not met.\54\ We also direct NERC to identify the
responsible entities for developing benchmark planning cases and
conducting wide-area studies under the new or modified Reliability
Standard.
---------------------------------------------------------------------------
\54\ NOPR, 179 FERC ] 61,195 at P 51.
---------------------------------------------------------------------------
28. Given the importance of timely addressing the identified
reliability gap, we direct NERC to submit the responsive new or
modified Reliability Standard within 18 months of the date of
publication of this final rule in the Federal Register. We further
direct NERC to develop a phased-in implementation timeline for the
different requirements of the new or modified Reliability Standard
(i.e., developing benchmark planning cases, conducting studies,
developing corrective action plans) that shall begin within 12 months
of the effective date of a Commission order approving the proposed
Reliability Standard.
29. We address below in further detail issues raised in the NOPR
and in comments regarding: (1) development of benchmark events and
planning cases; (2) definition of ``wide-area;'' (3) entities
responsible for developing benchmark events and conducting transmission
planning studies of wide-area events; (4) coordination among registered
entities and sharing of data and study results; (5) concurrent/
correlated generator and transmission outages; (6) conducting
transmission system planning studies for extreme heat and cold weather
events; (7) corrective action plans; (8) other extreme weather events;
and (9) Reliability Standard development and implementation timeline.
B. Develop Benchmark Events and Planning Cases Based on Major Prior
Extreme Heat and Cold Weather Events and/or Meteorological Projections
30. In the NOPR, the Commission proposed to direct NERC to include
in the new or modified Reliability Standard benchmark events that
responsible entities must study.\55\ The NOPR proposed basing such
benchmark events on prior events (e.g., the February 2011 Southwest
Cold Weather Event and the January 2014 Polar Vortex Cold Weather
Event) and/or meteorological projections. Recognizing that extreme
weather risks may vary from region to region and change over time, the
NOPR proposed to direct NERC to consider approaches that would provide
a uniform framework for developing benchmark events 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).\56\
Although the NOPR did not specify how these benchmark events should be
developed, the NOPR provided two examples: (1) NERC could develop the
benchmark event or events during the standard development process; or
(2) NERC could include in the new or modified Reliability Standard a
framework establishing a common design basis for the development of
benchmark events. The NOPR also suggested including in the modified
standard the primary features of the benchmark event(s) while
designating NERC or another entity to periodically update benchmark
events.\57\
---------------------------------------------------------------------------
\55\ Id.
\56\ Id. P 52.
\57\ Id. P 53.
---------------------------------------------------------------------------
31. The NOPR also proposed that establishing one or more benchmark
planning cases, based on benchmark events, should form the basis for
sensitivity analysis. In addition to providing valuable case study
information to be applied to preparing for possible comparable future
events, these events would also serve as a basis for effectively using
assets and resources. Specifically, once developed, responsible
entities would use the benchmark events to develop benchmark planning
cases to conduct studies to assess 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.\58\ The NOPR sought comments on all aspects of the
proposed directive.
---------------------------------------------------------------------------
\58\ Id.
---------------------------------------------------------------------------
1. Comments
32. Commenters generally agree with the NOPR proposal to direct
NERC to develop requirements that address the types of extreme heat and
cold weather scenarios that responsible entities are required to
study.\59\ Indicated Trade Associations caution, however, that
universal benchmark events would be hard to implement given regional
differences.\60\ As such, and consistent with the NOPR proposal,
Indicated Trade Associations, APS, Bonneville Power Administration
(BPA), and Idaho Power, among others, agree that regional differences
(e.g., climate, topology, electrical characteristics) should be
considered in developing benchmark events.\61\
---------------------------------------------------------------------------
\59\ See, e.g., NERC Comments at 7-8; AEP Comments at 7;
Indicated Trade Associations Comments at 8; NARUC Comments at 5.
\60\ Indicated Trade Associations Comments at 8.
\61\ See id.; APS Comments at 3; BPA Comments at 3; Idaho
Comments at 2.
---------------------------------------------------------------------------
33. Regarding how benchmark events should be developed, NERC notes
that significant work will be necessary to develop a uniform planning
approach that properly accounts for regional differences in climate and
weather patterns, among other considerations. Accordingly, NERC asks
for flexibility in developing benchmark events, including considering
options beyond those identified in the NOPR.\62\ Indicated Trade
Associations recommend that NERC consider all the examples of benchmark
events identified in the NOPR.\63\ PJM indicates that developing
benchmark events will require scientific and meteorological expertise
to ensure that NERC guidelines and criteria reflect statistically valid
scenarios for the meteorological projections and their possible impacts
on transmission planning. As such, PJM recommends that the Commission
engage the national
[[Page 41268]]
labs, Regional Transmission Organizations (RTO), NOAA, and other
agencies to develop extreme weather ``design threshold'' metrics, as
well as investigate targeted planning thresholds (e.g., 1-in-50-year
events).\64\ Other commenters highlight the necessity of ensuring that
benchmark events are not only developed using historical extreme heat
and cold event data, but more importantly use future meteorological
projections in order to prepare for plausible extremes in future
years.\65\
---------------------------------------------------------------------------
\62\ NERC Comments at 8-9.
\63\ Indicated Trade Associations Comments at 8.
\64\ PJM Comments at 9.
\65\ See, e.g., EPRI Comments at P 5; Entergy Comments at 3.
---------------------------------------------------------------------------
34. All those who submitted comments regarding the NOPR proposal to
require periodic updates to benchmark events agree with the need to do
so. For example, Union for Concerned Scientists (UCS) points to the
scientific consensus that climate change is altering the intensity and
frequency of extreme weather conditions as a reason to require the
periodic update of benchmark events.\66\ American Electric Power
Service Corporation (AEP) recommends updating the benchmark events
every three years, consistent with the Commission's proposed planning
cycle for regional transmission planning, based on the most up-to-date
data.\67\ In contrast, Midcontinent Independent System Operator, Inc.
(MISO) suggests that, consistent with similar requirements in
Reliability Standard TPL-007-4 (Transmission System Planned Performance
for Geomagnetic Disturbance Events) and Reliability Standard PRC-006-5
(Automatic Underfrequency Load Shedding) extreme heat and cold weather
benchmark events should be updated every five years.\68\ Other
commenters recommend that the key aspects of the benchmark be updated
periodically, without opining on the periodicity of updates.\69\
---------------------------------------------------------------------------
\66\ UCS Comments at 7.
\67\ AEP Comments at 3-4 (citing Docket No. RM21-17-000).
\68\ MISO Comments at 3.
\69\ See, e.g., APS Comments at 3; Entergy Comments at 4;
Indicated Trade Associations Comments at 8.
---------------------------------------------------------------------------
2. Commission Determination
35. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR
proposal and direct NERC to: (1) develop extreme heat and cold weather
benchmark events, and (2) require the development of benchmark planning
cases based on identified benchmark events. Without specific
requirements describing the types of heat and cold scenarios that
responsible entities must study, the new or modified Reliability
Standard may not provide a significant improvement upon the status quo.
Benchmark events will provide a defined event that will form the basis
for assessing system performance during extreme heat and cold weather
events. Benchmark events will also form the basis for a planner's
benchmark planning case--i.e., the base case representing system
conditions under the relevant benchmark event--that will be used to
study the potential wide-area impacts of anticipated extreme heat and
cold weather events.
36. Although the NOPR outlined some of the Commission's
expectations for the development of benchmark events, including that
benchmark events be based on prior extreme heat and cold events and/or
meteorological projections,\70\ there is currently no established
guidance or set of tools in place to facilitate the development of
extreme heat and cold benchmark events for the purpose of informing
transmission system planning. As recommended by commenters, NERC should
consider the examples of approaches for defining benchmark events
identified in the NOPR (e.g., the use of projected frequency or
probability distribution).\71\ NERC may also consider other approaches
that achieve the objectives outlined in this final rule. Further, as
recommended by PJM, we believe there is value in engaging with national
labs, RTOs, NOAA, and other agencies and organizations in developing
benchmark events. Considering NERC's key role, technical expertise, and
experience assessing the reliability impacts of various events and
conditions, we encourage NERC to engage with national labs, RTOs, NOAA,
and other agencies and organizations as needed. To that end, as
discussed in section IV.J below, we have modified the NOPR proposal to
allow more time for NERC to consider these complex issues and engage
additional expertise where necessary.
---------------------------------------------------------------------------
\70\ 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.
\71\ See supra P 33.
---------------------------------------------------------------------------
37. Because the impact of most extreme heat and cold events spans
beyond the footprints of individual planning entities, it is important
that all responsible entities likely to be impacted by the same extreme
weather events use consistent benchmark events. Doing so is important
to ensuring that neighboring planning regions are assuming similar
weather conditions and are able to coordinate their assumptions
accordingly. As a result, defining the benchmark event in a manner that
provides responsible entities significant discretion to determine the
applicable meteorological conditions would not meet the objectives of
this final rule.
38. At the same time, because different regions experience weather
conditions and their impacts differently, a single benchmark event for
the entire Nation is unlikely to meet the objectives of this final
rule. Accordingly, in developing extreme heat and cold benchmark
events, NERC shall ensure that benchmark events reflect regional
differences in climate and weather patterns.
39. We also direct NERC to include in the Reliability Standard the
framework and criteria that responsible entities shall use to develop
from the relevant benchmark event planning cases to represent potential
weather-related contingencies (e.g., concurrent/correlated generation
and transmission outages, derates) and expected future conditions of
the system such as changes in load, transfers, and generation resource
mix, and impacts on generators sensitive to extreme heat or cold, due
to the weather conditions indicated in the benchmark events. Developing
such a framework would provide a common design basis for responsible
entities to follow when creating benchmark planning cases. This would
not only help establish a clear set of expectations for responsible
entities to follow when developing benchmark planning events, but also
facilitate auditing and enforcement of the Standard.
40. We also direct NERC to ensure the reliability standard contains
appropriate mechanisms for ensuring the benchmark event reflects up-to-
date meteorological data. The increasing intensity, frequency, and
unpredictability of extreme weather conditions requires that key
aspects of the benchmark events be reviewed, and if necessary, updated
periodically to ensure the corresponding benchmark planning cases
reflect updated meteorological data. For example, a requirement that
defines a fixed benchmark event with no provision for future updates
(e.g., defining the benchmark event for a responsible entity as the
most severe heat wave in the last twenty years measured from the
effective date of the standard) may not provide an accurate indicator
of future risks. To the extent NERC determines that the benchmark event
should be fixed or only updated
[[Page 41269]]
periodically,\72\ we agree with MISO that including a mechanism to
update the benchmark event at least every five years would strike a
reasonable balance between the benefits of using the most up-to-date
meteorological data and administrative the burdens of collecting and
analyzing such data.
---------------------------------------------------------------------------
\72\ See, e.g., Reliability Standard EOP-012-1 (Extreme Cold
Weather Preparedness and Operations), at Requirement 4 (requiring
generator owners to calculate the generator extreme cold weather
temperature every five years).
---------------------------------------------------------------------------
C. Definition of ``Wide-Area''
41. In the NOPR, the Commission proposed to direct NERC to require
in a new or modified Reliability Standard that transmission planning
studies consider the wide-area impacts of extreme heat and cold
weather.\73\ The NOPR explained that the impacts 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.\74\ The
NOPR also pointed out that failure to study the wide-area impact of
extreme heat or cold weather conditions in transmission planning could
result in reliability issues affecting multiple regions or multiple
planning coordinator areas remaining undetected in the long-term
planning horizon. This, in turn, could lead to otherwise avoidable
system conditions that would be only one contingency away from voltage
collapse and uncontrolled blackouts.\75\
---------------------------------------------------------------------------
\73\ NOPR, 179 FERC ] 61,195 at P 64.
\74\ Id.
\75\ Id. P 66.
---------------------------------------------------------------------------
42. The NOPR proposed that, based on prior events, the study
criteria for extreme heat and cold weather events should consider 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.
43. To identify opportunities for improved wide-area planning
studies and coordination, the NOPR sought comments on whether wide-area
planning studies should be defined geographically or electrically.\76\
---------------------------------------------------------------------------
\76\ Id. P 67. The NOPR also solicited comment on which entities
should oversee and coordinate the wide-area planning models and
studies, as well as addressing the results of the studies, and how
they should communicate those results among transmission planners.
Id. These comments are addressed below in the sections D and E.
---------------------------------------------------------------------------
1. Comments
44. AEP, MISO Transmission Owners, and Tri-State Generation and
Transmission Association, Inc. (Tri-State) favor defining wide-area
geographically.\77\ MISO Transmission Owners assert that wide-area must
be defined by geography to address issues in each region as best suited
for that region, given that extreme heat and cold weather risks, and
the appropriate responses thereto, vary by geography.\78\ Tri-State
explains that ``wide-area'' should be defined geographically, because
for a transmission planner to evaluate a large area weather event, it
would need to be modeled within the transmission planner's area, as
well as neighboring entities.\79\
---------------------------------------------------------------------------
\77\ AEP Comments at 16; MISO Transmission Owners Comments at 4.
\78\ Id. at 4.
\79\ Tri-State Comments at 5-6.
---------------------------------------------------------------------------
45. Although MISO Transmission Owners support a geographic
definition, they also caution that RTO regions, Order No. 1000 planning
regions, and NERC Regional Entities do not have identical footprints.
Therefore, MISO Transmission Owners recommend that the final rule
direct NERC to propose modifications to Reliability Standards to
provide appropriately flexible provisions to address scenarios where
those inconsistent footprints may introduce conflicts.\80\
---------------------------------------------------------------------------
\80\ MISO Transmission Owners Comments at 4.
---------------------------------------------------------------------------
46. Idaho Power, on the other hand, comments that ``wide-area''
should be defined electrically to better capture the interdependency of
systems.\81\
---------------------------------------------------------------------------
\81\ Idaho Power Comments at 4.
---------------------------------------------------------------------------
47. LCRA Transmission Services Corporation (LCRA), Electric Power
Research Institute (EPRI), and PJM prefer that ``wide-area'' be defined
both geographically and electrically. LCRA explains that this is
necessary to represent the geographic correlation of extreme weather
events and the electrical connectivity of the transmission system.\82\
EPRI cautions that ``geographic definitions of wide area events will
need to be developed for inclusion in resource adequacy or production
cost models'' for purposes of identifying the snapshot conditions that
should serve as the primary inputs to the transmission planning
assessments.\83\ Further, EPRI explains that ``wide area events defined
electrically can be used to represent acute switching events that occur
over much shorter timescales and can be used to capture discrete
impacts defined as contingency events, which occur concurrent with the
extreme temperature condition.'' \84\
---------------------------------------------------------------------------
\82\ LCRA Comments at 3; EPRI Comments at P 18; PJM Comments at
10.
\83\ EPRI Comments at P 18.
\84\ Id. at 12.
---------------------------------------------------------------------------
48. Other commenters, while not indicating a preference between
electrical or geographical definition, highlight that extreme heat and
cold weather events are not bound by the footprint of utilities or
authorities that separate planning and balancing areas.\85\ Indicated
Trade Associations recommend that the Commission invest the NERC
standard drafting team with substantial discretion in addressing
whether and how wide-area planning studies should be defined
geographically or electrically.\86\
---------------------------------------------------------------------------
\85\ UCS Comments at 8; Entergy Comments at 5; EDF at Comments
23; MISO Transmission Owners Comments at 4.
\86\ Indicated Trade Associations at 10.
---------------------------------------------------------------------------
49. Although also not stating a preference as to whether to define
``wide-area'' electrically or geographically, Entergy Services, LLC
(Entergy) cautions against expecting transmission planners and
coordinators ``to overlap benchmark events between regions'' because
``[s]uch overlapping could result in modeling of extreme heat and cold
events over regions that are much larger than the areas in which such
events are likely to occur.'' \87\
---------------------------------------------------------------------------
\87\ Entergy Comments at 5-6.
---------------------------------------------------------------------------
2. Commission Determination
50. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR
proposal and direct NERC to require that transmission planning studies
under the new or revised Reliability Standard consider the wide-area
impacts of extreme heat and cold weather. We direct NERC to clearly
describe the process that an entity must use to define the wide-area
boundaries. While commenters provide various views in favor of both a
geographical approach and electrical approach to defining wide-area
boundaries, we do not adopt any one approach in this final rule.
Rather, we believe that this technical matter deserves a more fulsome
vetting in the Reliability Standards development process. NERC should
consider the comments in this proceeding when developing a new or
modified reliability standard that considers the broad area impacts of
extreme heat and cold weather.\88\
---------------------------------------------------------------------------
\88\ Cf., Order No. 693, 118 FERC ] 61,218 at P 188 (directing
NERC to address NOPR comments suggesting specific new improvements
to the Reliability Standards in the standards development process,
noting that it ``does not direct any outcome other than that the
comments receive consideration.'').
---------------------------------------------------------------------------
D. Entities Responsible for Developing Benchmark Events and Planning
Cases, and for Conducting Transmission Planning Studies of Wide-Area
Events
51. The NOPR proposed to direct NERC to develop requirements that
address the types of extreme heat and
[[Page 41270]]
cold scenarios responsible entities are required to study, including
the development of benchmark events and benchmark planning cases.\89\
The NOPR solicited feedback on which entities should be responsible for
updating benchmark events and whether, and to what extent, it may be
appropriate to allow designated entities to periodically update key
aspects of the benchmark events.\90\
---------------------------------------------------------------------------
\89\ NOPR, 179 FERC ] 61,195 at PP 50-51.
\90\ Id. P 53.
---------------------------------------------------------------------------
52. As a separate matter, the NOPR proposed to require that
transmission planning studies that consider the wide-area impacts of
extreme heat and cold weather.\91\ To inform this directive, the NOPR
solicited comment on which entities should oversee and coordinate the
wide-area planning models and studies, as well as which entities should
have responsibility to address the results of the studies.\92\
---------------------------------------------------------------------------
\91\ Id. P 64.
\92\ Id. P 67.
---------------------------------------------------------------------------
1. Comments
a. Entity Responsible for Development of Benchmark Events
53. There is no consensus among the commenters regarding which
entities should be tasked with developing the benchmark events.
Indicated Trade Associations suggest that the subject matter experts on
the NERC standard drafting team should develop the benchmark
events.\93\ Entergy also suggests that the NERC develop the benchmark
events, as NERC will be able to tailor the benchmark events to reflect
regional variations in extreme weather risk.\94\ All other commenters
on this issue proposed that other entities be responsible for benchmark
event development.\95\ For example, New York Independent System
Operator, Inc. (NYISO) and MISO Transmission Owners posit that entities
registered with NERC as planning coordinators or transmission planners
should be given the latitude to develop the benchmark events.\96\ AEP
recommends that each planning coordinator should develop individualized
benchmark events for its planning area, except in regions that lack the
necessary resources or expertise, in which case the Regional Entities
should coordinate and review the benchmark event process in
collaboration with these smaller planning coordinators in that
region.\97\ American Clean Power Association (ACP) suggests that the
Regional Entities should develop the benchmark events that will be
evaluated by all transmission planners and planning coordinators in a
given region.\98\
---------------------------------------------------------------------------
\93\ Indicated Trade Associations Comments at 8.
\94\ Entergy Comments at 4.
\95\ See. e.g., EDF Comments at 8.
\96\ NYISO Comments at 13; MISO Transmission Owners Comments at
5.
\97\ AEP Comments at 9.
\98\ ACP Comments at 3.
---------------------------------------------------------------------------
b. Entity Responsible for Development of Planning Cases and Conducting
Transmission Planning Studies of Wide-Area Events
54. Regarding development of benchmark planning cases, beyond
existing registered entities, Arizona Public Service Company (APS)
recommends ``that a regional planning entity would be the appropriate
entity to determine the benchmark planning cases and develop the
scenarios that constitute an extreme event in their region.'' \99\
---------------------------------------------------------------------------
\99\ APS Comments at 3.
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55. Further, commenters suggest a variety of entities to perform
the wide area studies. NERC suggests that a registered entity subject
to the Reliability Standard, such as a planning coordinator or
transmission planner, should be responsible for performing the wide-
area studies.\100\ AEP asserts that the planning coordinators should
oversee and coordinate the wide-area planning models and studies,
communicate the results, and work to mitigate issues that require
corrective action.\101\
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\100\ AEP Comments at 20; NERC Comments at 9-10.
\101\ AEP Comments at 16.
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56. APS and MISO Transmission Owners express concern that an
individual transmission planner or planning coordinator would not be
positioned to perform a wide-area assessment of extreme weather
conditions because of its limited geographical visibility.\102\
Similarly, Entergy also questions whether a single transmission planner
would be able to model a wide-area event on its own. Entergy believes
that the responsibility for performing the analysis should lie with the
RTOs or Regional Entities, with input provided by member transmission
owners and transmission planners.\103\ Alternatively, APS suggested a
regional planning entity, such as those created under Order No. 1000,
would be appropriate to oversee and coordinate wide-area planning
models and studies.\104\ Idaho Power Company (Idaho Power) asserts that
regional planning groups such as Western Power Pool are the ones best
positioned to coordinate and perform the wide-area planning
studies.\105\
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\102\ APS Comments at 4; MISO Transmission Owners Comments at 4.
\103\ Entergy Comments at 6.
\104\ APS Comments at 4.
\105\ Idaho Power Comments at 4.
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57. Environmental Defense Fund (EDF), Tri-State, and Eversource
Energy Service Company (Eversource) propose that reliability
coordinators should have the responsibility to perform wide-area
planning and coordination in collaboration with other impacted
reliability coordinators.\106\
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\106\ EDF Comments at 23; Tri-State Comments at 6; Eversource
Comments at 5.
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2. Commission Determination
a. Entity Responsible for Establishing Benchmark Events
58. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR
proposal and direct NERC to develop benchmark events for extreme heat
and cold weather events through the Reliability Standards development
process. We agree with Indicated Trade Associations that the
development of adequate benchmark events is critical and should be
committed to the subject matter experts on the standards drafting team.
We also agree with Entergy that NERC will be able to tailor benchmark
events to capture regional differences and the different risks that
each region faces during extreme heat and cold weather events. While
Regional Entities and reliability coordinators are encouraged to
participate in the NERC Reliability Standards development process to
develop the benchmark events, we disagree with AEP and other commenters
who recommend that entities other than NERC take the lead in the
development of benchmark events.
59. Further, requiring NERC to develop the new or modified
Reliability Standard's benchmark events is consistent with the approach
the Commission took in Order No. 779, when the Commission directed NERC
to develop benchmark events for geomagnetic disturbance analyses.\107\
For the same reasons, we also conclude that NERC is best positioned to
define mechanisms to periodically update extreme heat and cold weather
benchmark events, as discussed above.\108\
---------------------------------------------------------------------------
\107\ Reliability Standards for Geomagnetic Disturbances, Order
No. 779, 143 FERC ] 61,147, at P 2 (2013).
\108\ See supra P 40.
---------------------------------------------------------------------------
b. Entities Responsible for Development of Planning Cases and
Conducting Transmission Planning Studies of Wide-Area Events
60. We also direct NERC to designate the type(s) of entities
responsible for
[[Page 41271]]
developing benchmark planning cases and conducting wide-area studies
under the new or modified Reliability Standard. The scope of extreme
weather event studies will likely cover large geographical areas far
exceeding the smaller individual transmission planner or planning
coordinator planning areas. Accordingly, we agree with APS that the
benchmark planning cases should be developed by registered entities
such as large planning coordinators, or groups of planning
coordinators, with the capability of planning on a regional scope.\109\
---------------------------------------------------------------------------
\109\ According to the NERC Registration Matrix, there are
currently 211 transmission planners and 66 planning coordinators in
the United States. While some of these entities operate over large
geographic areas--for example, PJM and MISO are the only planning
coordinators in the Reliability First footprint--the majority
operate on a much smaller scale--WECC and SERC have 59 planning
coordinators, some of which are small cities and counties. NERC, NCR
Active Entities List, (last visited Apr. 7, 2023) <a href="https://www.nerc.com/pa/comp/Registration%20and%20Certification%20DL/NERC_Compliance_Registry_Matrix_Excel.xlsx">https://www.nerc.com/pa/comp/Registration%20and%20Certification%20DL/NERC_Compliance_Registry_Matrix_Excel.xlsx</a>.
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61. We also disagree with assertions that reliability coordinators
should be responsible for developing benchmark planning cases or
conducting wide-area studies. We believe the designated responsible
entities should have certain characteristics, including having a wide-
area view of the Bulk-Power System and the ability to conduct long-term
planning studies across a wide geographic area. The responsible
entities should also have the planning tools, expertise, processes, and
procedures to develop benchmark planning cases and analyze extreme
weather events in the long-term planning horizon. Under the NERC
functional model, however, reliability coordinators have responsibility
for the real-time operation of the bulk-power system. Accordingly, we
conclude that reliability coordinators are not well suited for
developing benchmark planning cases or conducting wide-area studies.
62. To comply with this directive, NERC may designate the tasks of
developing benchmark planning cases and conducting wide-area studies to
an existing functional entity or a group of functional entities (e.g.,
a group of planning coordinators). NERC may also establish a new
functional entity registration to undertake these tasks. In the
petition accompanying the proposed Reliability Standard NERC should
explain how the applicable registered entity or entities meet the
objectives outlined above.
E. Coordination Among Registered Entities and Sharing of Data and Study
Results
63. The NOPR explained that Reliability Standard TPL-001-5.1 cross-
references Reliability Standard MOD-032-1 (Data for Power System
Modeling Analysis), which establishes consistent modeling data
requirements and reporting procedures for the development of planning
horizon cases necessary to support analysis of the reliability of the
interconnected system.\110\ Reliability Standard MOD-032-1 ensures an
adequate means of data collection for transmission planning. It
requires applicable registered entities to provide steady-state,
dynamic, and short circuit modeling data to their 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.
---------------------------------------------------------------------------
\110\ NOPR, 179 FERC ] 61,195 at P 80.
---------------------------------------------------------------------------
64. The NOPR stated that, while balancing authorities and other
entities must share system information and study results with their
transmission planner and planning coordinator pursuant to Reliability
Standards MOD-032-1 and TPL-001-5.1, there is no required sharing of
such information related to extreme heat or cold weather events--or
required coordination--among planning coordinators and transmission
planners with transmission operators, transmission owners, and
generator owners.\111\ 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 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 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.\112\
---------------------------------------------------------------------------
\111\ Id. P 81.
\112\ Id.
---------------------------------------------------------------------------
65. The NOPR proposed to direct NERC to 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.\113\ The NOPR solicited comments on whether existing
Reliability Standards are sufficient to ensure that responsible
entities performing studies of extreme heat and cold weather events
have the necessary data, and/or whether the Commission should direct
additional changes pursuant to FPA section 215(d)(5) to address the
issue.\114\ The NOPR also sought comments on the following: (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.
---------------------------------------------------------------------------
\113\ Id. P 82.
\114\ Id. P 63.
---------------------------------------------------------------------------
1. Comments
66. There is no consensus among commenters on whether Reliability
Standards TPL-001.5.1 and MOD-032-1 are adequate means of data
collection for transmission planning, with some commenters raising
concerns about the types of data that will be needed to conduct extreme
heat and cold weather studies under the new or modified Reliability
Standard and whether such data can be obtained through existing
processes.
67. For example, NERC and Idaho Power believes that the existing
standards are sufficient.\115\ According to NERC, the Commission does
not need to direct revisions to Reliability Standard MOD-032-1 to
account for new data required for extreme heat and cold weather studies
because the standard requires functional entities to provide ``other
information requested by the Planning Coordinator or Transmission
Planner necessary for modeling purposes'' for each of the three types
of data required (steady-state, dynamics, and short circuit).\116\
Thus, NERC asserts that planning coordinators and transmission planners
are empowered to request any specific data needed for studies of
extreme heat and cold conditions. According to Idaho Power, because (1)
utilities currently share contingencies to be studied with neighboring
entities to get feedback and make updates as needed and (2) utilities
share TPL-001 reports with other utilities subject to the execution of
a non-disclosure agreement, the Commission proposal would be redundant
of current practice.\117\
---------------------------------------------------------------------------
\115\ NERC Comments at 13; Idaho Power Comments at 5.
\116\ NERC Comments at 13.
\117\ Idaho Power Comments at 5.
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[[Page 41272]]
68. In contrast, Tri-State indicates that there is no requirement
for transmission customers to provide data for extreme heat and cold
weather conditions such as load forecast data.\118\ AEP asserts that
planning coordinators and transmission planners have limited insight
into a generator's likelihood of availability during extreme weather
events, particularly limited for inverter-based resources.\119\ EPRI
states that there is limited modeling of protection systems in dynamic
assessments currently, and any dynamic simulation of extreme events
would require significant modeling of protection systems to provide for
convergence of the numerical simulation.\120\ NYISO notes that
Reliability Standard TPL-001 currently limits transmission planners or
planning coordinators to requesting data pertaining to their own
planning area.\121\
---------------------------------------------------------------------------
\118\ Tri-State Comments at 4-5.
\119\ AEP Comments at 15.
\120\ EPRI Comments at P 11.
\121\ NYISO Comments at 14.
---------------------------------------------------------------------------
69. Other commenters suggest that it will be necessary to define
the data needed by responsible entities to perform studies under the
new or modified Reliability Standard. AEP proposes that the Commission
hold a technical conference to help define the data needed to perform
the extreme weather assessments and the avenue through which
information will be shared.\122\ Indicated Trade Associations recommend
that, although Reliability Standard MOD-032-1 might be adequate as a
data source, the Commission should recognize in any final rule that the
standard drafting team should be tasked with identifying what data is
already collected and specifying what new data is needed to perform the
assessments for extreme heat and cold.\123\
---------------------------------------------------------------------------
\122\ AEP Comments at 4.
\123\ Indicated Trade Associations Comments at 9-10.
---------------------------------------------------------------------------
70. Regarding the sharing of study results and coordination among
entities, Tri-State suggests that the balancing authority should
address the results of the studies and how they should communicate
those results among the transmission planners. Tri-State also asserts
that the balancing authority is responsible for resource adequacy and
should communicate resource needs for the area with the responsible
transmission planners who can evaluate system needs and ``provide
access to remove'' resource needs.\124\ EPRI does not opine on who
should do the wide-area coordination, but states that some level of
coordination will be required to ensure accurate assessments of wide
area events that impact geographic footprints across multiple planning
entities.\125\ UCS suggests that the final rule should direct the
sharing of modeling information between planning areas regarding
extreme weather benchmark events, because ensuring reliability will
depend on the extent to which neighboring regions cooperate.\126\
---------------------------------------------------------------------------
\124\ Tri-State Comments at 6.
\125\ EPRI Comments at P 19.
\126\ UCS Comments at 8.
---------------------------------------------------------------------------
71. NERC asserts that while wide-area studies should be coordinated
as appropriate for the area, the specific procedural details for
coordination on wide-area studies do not need to be mandated in a
Reliability Standard. NERC adds that other coordination requirements,
such as those related to sharing of study results and coordination for
corrective actions across multiple transmission planner areas, can be
addressed through the standard development process with consideration
of any factors identified by the commenters in this proceeding.\127\
Similarly, Indicated Trade Associations recommend that the Commission
empower the standards drafting team to consider whether coordination
between a variety of functional entities, and across regions, would be
the most effective means of addressing certain identified extreme heat
and cold weather events.\128\
---------------------------------------------------------------------------
\127\ NERC Comments at 10.
\128\ Indicated Trade Associations Comments at 5.
---------------------------------------------------------------------------
2. Commission Determination
72. Pursuant to section 215(d)(5) of the FPA, we adopt and modify
the NOPR proposal and direct NERC to require functional entities to
share with the entities responsible for developing benchmark planning
cases and conducting wide-area studies the system information necessary
to develop benchmark planning cases and conduct wide-area studies.
Further, responsible entities must share the study results with
affected transmission operators, transmission owners, generator owners,
and other functional entities with a reliability need for the
studies.\129\
---------------------------------------------------------------------------
\129\ The NOPR proposed to direct NERC to ensure that functional
entities share necessary system information with planning
coordinators and transmission planners, as these entities conduct
current transmission planning studies under TPL-001-5.1. Because
this final rule directs NERC to determine the entities that will be
responsible for conducting studies under the new or modified
Reliability Standard, we modify the NOPR accordingly to ensure the
selected responsible entity has the means to request and receive
necessary system information.
---------------------------------------------------------------------------
73. We agree with commenters that Reliability Standard MOD-032-1
allows for data collection for extreme heat and cold weather events.
However, only planning coordinators and transmission planners can
request data from other entities through Reliability Standard MOD-032-1
processes. Because in this final rule we direct NERC to determine the
responsible entities that will be developing benchmark planning cases
and conducting wide-area studies, it is possible that the selected
responsible entities under the new or modified Reliability Standard
will not be able to request and receive needed data pursuant to MOD-
032-1, absent modification to that Standard.
74. Regarding EPRI's statement of insufficiency of dynamic modeling
of protection systems, we consider the insufficiency of protection
system modeling to be an ongoing deficiency in the modeling process.
The dynamics databases used for transient stability simulations by
various interconnections typically do not include comprehensive dynamic
models of relays installed in the interconnection. Thus, in addressing
our directive above, NERC should evaluate this deficiency during the
standard development process.
75. We disagree with UCS's recommendation that the final rule
should direct the sharing of modeling information between planning
areas regarding extreme weather benchmark events. We expect that the
existing practice (e.g., MOD-032-1) of responsible entities sharing
modeling information between planning areas will continue, without the
need for us to specifically direct that in this final rule.
76. Rather than predetermine each aspect of the coordination
process, we believe the decision of which entities are best positioned
for wide-area coordination should be left to NERC. We therefore direct
NERC to address the requirement for wide-area coordination through the
standard development process, giving due consideration to relevant
factors identified by commenters in this proceeding.
77. We agree with NERC and Indicated Trade Associations that
coordination requirements, such as those related to the sharing of
study results and corrective actions across multiple transmission
planner areas, are best addressed through the standard development
process, which we expect will consider relevant factors identified by
the commenters in this proceeding. Although this final rule does not
specify how study results must be shared, we believe that the new or
modified Reliability Standard must require responsible entities to
share these studies with affected functional entities. The sharing of
study results will alert entities of reliability concerns identified
[[Page 41273]]
in wide-area studies.\130\ Further, requiring responsible entities to
share study results with functional entities with a reliability related
need for the study is consistent with existing planning assessment
sharing requirements under Reliability Standard TPL-001-5.1.\131\
Therefore, we direct NERC to require in the new or modified Reliability
Standard that responsible entities share the results of their wide-area
studies with other registered entities such as transmission operators,
transmission owners, and generator owners that have a reliability
related need for the studies.
---------------------------------------------------------------------------
\130\ NOPR, 179 FERC ] 61,195 at P 81.
\131\ See Reliability Standard TPL-001-5.1, Requirement R8.
---------------------------------------------------------------------------
F. Concurrent/Correlated Generator and Transmission Outages
78. The NOPR stated that 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 NOPR indicated that extreme heat could lead to
significant derating, reduced lifetime, or failure of power
transformers, while extreme cold could lead to at least temporary
transmission facility outages.\132\
---------------------------------------------------------------------------
\132\ NOPR, 179 FERC ] 61,195 at P 68.
---------------------------------------------------------------------------
79. As such, the NOPR posited that modeling the loss of these
generators and transmission equipment during extreme heat and cold
weather events would allow planners to assess 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.\133\ In addition, the NOPR indicated that
modeling concurrent generator and transmission outages would also allow
planners to better identify appropriate solutions to be incorporated
into corrective action plans.\134\
---------------------------------------------------------------------------
\133\ Id. P 69.
\134\ Id.
---------------------------------------------------------------------------
80. The NOPR also proposed that accounting for concurrent outages
including modeling the derating and possible loss of wind and solar
generators, as well as natural gas generators sensitive to extreme heat
and cold conditions 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. Thus, the NOPR suggested that requiring transmission
planners and planning coordinators to study concurrent generator and
transmission failures under extreme heat and cold events to account for
the expected resource mix's availability during these extreme
conditions is one way to address the reliability gap in Reliability
Standard TPL-001-5.1.\135\
---------------------------------------------------------------------------
\135\ Id. P 72.
---------------------------------------------------------------------------
81. To identify the scope of these planning studies, the NOPR
sought comments on the following: (1) the assumptions (e.g., weather
forecast, load forecast, transmission voltage levels, generator types,
multi-day low wind, and solar events) 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
penetration of wind, solar, and natural gas generation should trigger
additional analyses.\136\
---------------------------------------------------------------------------
\136\ Id.
---------------------------------------------------------------------------
1. Comments
82. Commenters mostly agree with the NOPR that responsible entities
should evaluate the risk of correlated or concurrent outages and
derates of all types of generation resources (i.e., conventional and
renewables) as well as transmission facilities related to extreme
weather events.\137\ For example, the Federal Energy Advocate for the
Public Utilities Commission of Ohio (Ohio FEA) recommends that the
Standard incorporate asset correlations and interdependencies, and
consider the extent to which they can be obviated or mitigated because
asset performance or failure is highly correlated with their dependency
on weather conditions and on the performance of nearby or related
infrastructure.\138\ Idaho Power notes that while Reliability Standard
TPL-001-5.1 already addresses the loss of multiple generating stations
resulting from conditions such as the loss of a large gas pipeline into
a region or multiple regions that have significant gas-fired
generation, the standard could be modified to include the impact of
renewable energy resource response due to extreme weather as well.\139\
While agreeing with the NOPR proposal, Public Interest Organizations
(PIOs) and ACP argue that any requirement to study concurrent or
correlated generation outages should be extended to conventional
generators to account for the reliability risk and to eliminate undue
discrimination caused by overstating the reliability contributions of
conventional generators relative to renewable and storage
resources.\140\
---------------------------------------------------------------------------
\137\ EDF Comments at 22; ACP Comments at 5; PIOs Comments at 9;
AEP Comments at 4; UCS Comments at 12; and Americans for Clean
Energy Grid Comments at 6 (ACEG Comments).
\138\ Ohio FEA Comments at 5.
\139\ Idaho Power Comments at 4.
\140\ PIOs Comments at 23-24.
---------------------------------------------------------------------------
83. Some commenters assert that the NOPR proposal on modeling the
effects of potential concurrent transmission and generator outages
might be unnecessary. ISO New England Inc. (ISO-NE) takes issue with
including the expected resource mix's availability during extreme
weather conditions as part of extreme weather scenarios. ISO-NE asserts
that resource mix availability should not be addressed in a
transmission planning standard because it is addressed as part of
resource adequacy assessment and other Reliability Standards, such as
the Cold Weather Reliability Standards. Further, ISO-NE argues that
transmission planning Reliability Standards need to consider resource
availability in planning cases, because generators will be required to
be ready to perform in extreme weather events under those other
standards.\141\ EPRI asks if the Commission intends for the concurrent
outages of generation and transmission assets to be modeled as an acute
event, and if so, requests clarification as to how it differs from the
P3 category of contingency events from TPL-001-5.1.\142\
---------------------------------------------------------------------------
\141\ ISO-NE Comments at 2-4.
\142\ EPRI Comments at PP 20-21. Category P3 requires the study
of the loss of a generator unit followed by system adjustments,
followed by a loss of one of the following: generator or
transmission circuit or transformer or shunt device or single pole
of a DC line as stated in Reliability Standard TPL-001.5.1, Table 1.
---------------------------------------------------------------------------
84. NYISO recommends that, as the extreme events in Reliability
Standard TPL-001-5.1 are analogous to extreme contingencies rather than
extreme system conditions such as heatwaves, cold snaps, droughts,
etc., NERC planning events should be expanded to include the weather-
related loss of generation across areas of the system in the design-
basis contingencies rather than as an extreme contingency.\143\
---------------------------------------------------------------------------
\143\ NYISO Comments at 13.
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[[Page 41274]]
85. Regarding modeling assumptions, LCRA asserts that the Standard
should not be prescriptive regarding the modeling assumptions,
particularly concerning generation availability, beyond developing the
study base case when available generation is insufficient to meet the
load with respect to extreme weather events.\144\ LCRA also cautions
that modeling too many outages will result in an unsolvable case that
cannot be analyzed.\145\
---------------------------------------------------------------------------
\144\ LCRA Comments at 3.
\145\ Id.
---------------------------------------------------------------------------
86. While no comments recommended any specific threshold of
penetration of renewable resources that would trigger additional
analysis, PJM notes that special studies may be needed as greater
numbers of renewable, inverter-based resources (IBR), connect to the
Bulk-Power System. With a much higher IBR penetration level, a more
material change to dynamic and steady state assessment will likely be
needed to capture the impacts of higher penetration levels of IBRs and
much reduced conventional generation support.\146\ APS, however,
suggests that the Commission should not set a penetration threshold,
arguing that the entity performing the study should determine the
threshold, which likely would differ depending on the characteristics
of the particular system.\147\
---------------------------------------------------------------------------
\146\ PJM Comments at 11.
\147\ APS Comments at 5.
---------------------------------------------------------------------------
87. Electric Power Supply Association (EPSA) suggests that the
Commission direct NERC to examine how it defines and measures its
resource adequacy benchmarks, including the impacts of non-dispatchable
resources with increasing penetration in the system and the
availability of dispatchable, flexible resources which are increasingly
being replaced by new, less flexible resources or technologies.\148\
---------------------------------------------------------------------------
\148\ EPSA Comments at 3.
---------------------------------------------------------------------------
2. Commission Determination
88. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR
proposal and direct NERC to require under the new or revised
Reliability Standard the study of concurrent/correlated generator and
transmission outages due to extreme heat and cold events in benchmark
events as described in more detail below.
89. We disagree with comments suggesting that the modeling of
concurrent/correlated generator and transmission outages is
unnecessary.\149\ As discussed in the NOPR, and reinforced by
commenters, the failures of individual generators during extreme
weather events are not independent.\150\ Previous extreme weather
events have demonstrated that there is a high correlation between
generator outages and cold temperatures, indicating that as
temperatures decrease, unplanned generator outages and derates
increase.\151\ Because of this correlation, it is necessary that
responsible entities evaluate the risk of correlated or concurrent
outages and derates of all types of generation resources and
transmission facilities as a result of extreme heat and cold events, as
commenters suggest.\152\
---------------------------------------------------------------------------
\149\ See, e.g., ISO-NE Comments at 2-4.
\150\ NOPR, 179 FERC ] 61,195 at P 70.
\151\ Id. PP 70-71.
\152\ See supra P 82.
---------------------------------------------------------------------------
90. Further, we disagree with ISO-NE that resource mix availability
should not be considered here because it is considered in resource
adequacy planning and in other Reliability Standards. Although resource
outages are an important input into the resource adequacy studies, they
are also an important determinant in assessing the adequacy of the
transmission system.\153\ Therefore, it will be necessary to consider
the impact of extreme weather events on generators anticipated to be
connected to the subject transmission system during the study period.
Similarly, although the Cold Weather Reliability Standards require
generators to be prepared to be available and perform at or above their
extreme cold weather temperature during extreme weather events,
generator availability is not guaranteed by any Reliability Standard,
and outages occur for many reasons. Accordingly, some generators may
still be unavailable under extreme heat or cold conditions and thus
their potential outages must be considered in extreme heat and cold
weather planning scenarios.
---------------------------------------------------------------------------
\153\ This understanding is consistent with section 215(a)(1) of
the FPA, 16 U.S.C. 824o(a)(1), which defines Bulk-Power System to
include ``electric energy from generation facilities needed to
maintain transmission system reliability.''
---------------------------------------------------------------------------
91. Although several commenters ask for flexibility as to modeling
assumptions, we believe that it is necessary for the Reliability
Standard to strike a balance between allowing responsible entities
discretion to ensure the study incorporates their operating experience
and the need to create a robust framework that ensures extreme heat and
cold events are adequately studied. Thus, while generation and
transmission availability and concurrent outages must be included in
the benchmark planning case, we defer to NERC to develop the framework
and criteria that responsible entities shall use to represent potential
weather-related contingencies (e.g., concurrent/correlated generation
and transmission outages, derates) in the relevant benchmark event
planning cases.\154\
---------------------------------------------------------------------------
\154\ See supra P 39. Reliability Standard TPL-001-5.1
Requirement 1.1.5 requires responsible entities to maintain system
models that represent projected system conditions, including
resources required for load. Because drought conditions may impact
the availability of certain supply resources, we expect that the new
or revised Reliability Standard will include a similar requirement
that accounts for the impact of drought conditions on generation
where appropriate.
---------------------------------------------------------------------------
92. Regarding the comments of NYISO and EPRI on the difference
between extreme events and contingencies covered under Reliability
Standard TPL-001-5.1, we clarify that all contingencies included in
benchmark planning cases under the new or modified Reliability Standard
will represent initial conditions for extreme weather event planning
and analysis. These contingencies (i.e., correlated/concurrent,
temperature sensitive outages, and derates) shall be identified based
on similar contingencies that occurred in recent extreme weather events
or expected to occur in future forecasted events.
93. Regarding PJM's comment regarding the likely need for
additional studies to capture the impacts of higher penetration levels
of renewables and much reduced conventional generation support, we note
that the benchmark planning case will include this information pursuant
to our directive above regarding benchmarking planning cases.
Accordingly, we do not foresee the need for the additional studies
suggested by PJM.
94. Lastly, regarding EPSA's comment requesting that we direct NERC
to examine how it defines and measures its resource adequacy
benchmarks, we note that resource adequacy benchmarks are outside the
scope of this proceeding.
G. Conduct Transmission System Planning Studies for Extreme Heat and
Cold Weather Events
1. Steady State and Transient Stability Analyses
95. The Commission proposed in the NOPR to require both steady
state and transient stability analyses be conducted for extreme heat
and cold weather events as part of transmission planning studies.\155\
Consistent with Reliability Standard TPL-001-5.1, the NOPR stated that
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
[[Page 41275]]
conditions.\156\ The NOPR explained that a steady-state analysis is
based on a snapshot in time where the bulk electric system facilities
such as generators, transmission lines, transformers etc. are modeled
as fixed and load is modeled as a constant.\157\ On the other hand,
transient stability or dynamic analyses simulate the time-varying
characteristics of the system during a disturbance that occurs during
an extreme heat or cold event.\158\ The NOPR further stated that
performing these studies in the long-term planning horizon period
(i.e., six to ten years and beyond) will provide an adequate lead time
for entities to develop and implement corrective action plans to reduce
the likelihood or mitigate the consequences and adverse impacts of such
events.\159\
---------------------------------------------------------------------------
\155\ NOPR, 179 FERC ] 61,195 at P 69.
\156\ Id. P 70.
\157\ Id. P 59.
\158\ Id. P 60.
\159\ Id. P 58.
---------------------------------------------------------------------------
96. The NOPR noted that the use of dynamic studies is particularly
important given the changing resource mix and the need to understand
the dynamic behavior of both traditional generators and variable energy
resources (VERs) (i.e., wind and solar photovoltaic).\160\
---------------------------------------------------------------------------
\160\ Id. P 61.
---------------------------------------------------------------------------
97. The NOPR sought comments on all aspects of the proposal, and
specifically, on whether responsible entities should include
contingencies based on their planning area and perform both steady
state and transient stability (dynamic) analyses using extreme heat and
cold cases. In addition, the NOPR invited comments on the following
topics: (1) the set of contingencies responsible entities must
consider; (2) required analyses to assess voltage stability, frequency
excursions 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.\161\
---------------------------------------------------------------------------
\161\ Id. P 62. The NOPR also sought comment on whether existing
Reliability Standards are sufficient to ensure that responsible
entities performing studies of extreme heat and cold weather
conditions have the necessary data, and/or whether the Commission
should direct additional modifications pursuant to FPA section
215(d)(5) to address this issue. Id. P 63. This question is
discussed in section IV.E of this final rule.
---------------------------------------------------------------------------
a. Comments
98. All those who commented on the NOPR proposal to require both
steady state and transient stability analyses agree with the NOPR that
both steady state and transient stability analyses should be performed
in order to understand the potential impacts of extreme heat and cold
weather events.\162\ Below, we discuss comments received on the
following topics: (i) required contingencies; (ii) analyses of common
mode failures; and (iii) demand response.
---------------------------------------------------------------------------
\162\ See, e.g., NERC Comments at 9; PJM Comments at 10; Tri-
State Comments at 4; Eversource Comments at 5; WE ACT for
Environmental Justice Comments at 4; LCRA Comments at 3; UCS
Comments at 7.
---------------------------------------------------------------------------
i. Required Set of Contingencies
99. Idaho Power supports the inclusion of contingencies listed in
Table 1 of Reliability Standard TPL-001-4 such as the loss of two
generating stations resulting from, among other events, severe weather,
as it currently applies these contingencies in its severe weather
studies.\163\
---------------------------------------------------------------------------
\163\ Idaho Power Comments at 3.
---------------------------------------------------------------------------
100. AEP recommends that the Commission direct NERC to revise and
reclassify the contingency lists in Reliability Standard TPL-001-5.1 to
``reflect the unique challenges posed by extreme weather events'' and
to ensure that the bulk electric system is operated to withstand N-1-1
contingencies ``without interruption of firm transmission service or
non-consequential load loss.'' \164\ NYISO recommends expanding NERC
planning events to include the weather-related loss of generation
across areas of the system in the design-basis contingencies rather
than as an extreme contingency.\165\ Southern California Edison Company
(SCE) suggests that NERC determine whether additional contingencies
should be developed to evaluate potential reliability risks from events
occurring at the same or sequential times in the same region that have
the potential to pose an aggregate impact on electricity assets,
operations, and services, e.g., an extreme heat event that reduces grid
capacity while increasing demand for cooling.\166\ LCRA suggests that
performing contingency analyses similar to what is required under
Reliability Standard CIP-014-3 (Physical Security) may be useful.\167\
LCRA states, for example, that the analysis could study the outage of
medium impact facilities (e.g., single circuit, common tower). If the
result of the analysis identifies instability, cascading, uncontrolled
islanding, or excessive load shed, these facilities could be identified
as ``weather critical'' and targeted for hardening as part of a
corrective action plan.\168\
---------------------------------------------------------------------------
\164\ AEP Comments at 4.
\165\ NYISO Comments at 14.
\166\ SCE Comments at 4.
\167\ Reliability Standard CIP-014-3 requires entities to assess
their transmission facilities to determine whether, if rendered
inoperable or damaged, they could result in widespread instability,
uncontrolled separation, or cascading. Reliability Standard CIP-014-
3 (Physical Security), at 1.
\168\ LCRA Comments at 2.
---------------------------------------------------------------------------
101. Other commenters state that responsible entities should be
able to consider contingencies beyond those in Table 1 of Reliability
Standard TPL-001.5.1 that will affect their study area.\169\ For
example, PJM emphasizes the need for regional variance for unique
contingencies to be studied.\170\ Eversource recommends that the
Commission avoid prescription and allow details such as the types of
required contingencies to be determined during the standard development
process.\171\
---------------------------------------------------------------------------
\169\ AEP Comments at 4; Idaho Power Comments at 3; Tri-State
Comments at 4, PJM Comments at 11.
\170\ AEP Comments at 4; Idaho Power Comments at 3; Tri-State
Comments at 4, PJM comments at 11.
\171\ Eversource Comments at 4.
---------------------------------------------------------------------------
102. EPRI asserts that clarification is needed to differentiate
between events that impact the initial conditions of the benchmark
scenario for which the contingency events will be analyzed, and the
actual contingencies meant to be captured as acute impacts to the
system that occur over a wide area and can be studied through the
steady state and transient stability processes.\172\
---------------------------------------------------------------------------
\172\ EPRI Comments at P 21.
---------------------------------------------------------------------------
ii. Analyses for Common Mode Failures
103. NERC and ACP agree that Reliability Standard TPL-001-5.1
should better address the risk posed by extreme heat and cold weather
events and the associated common mode failure impacting resource
availability and the transmission system.\173\
---------------------------------------------------------------------------
\173\ NERC Comments at 6; ACP Comments at 9 n.23.
---------------------------------------------------------------------------
104. EPRI states that the benchmark planning cases, which serve as
the basis for steady state and transient stability assessments,
historically have not been developed to include the correlated impacts
of common mode events based on the impact of extreme temperature on
load and the availability of derated generation and transmission
capacity. EPRI asserts that capturing extreme temperature conditions
for both heat and cold would require a new approach that directly
accounts for the correlated temperature-related impacts to supply and
demand.\174\ EPRI agrees with the Commission's proposal that dynamic
models of VERs need to be included in the studies but states they would
need to be sufficiently robust to accurately capture system performance
under extreme weather conditions.\175\
---------------------------------------------------------------------------
\174\ EPRI Comments at PP 3-4.
\175\ Id. P 11.
---------------------------------------------------------------------------
[[Page 41276]]
105. Indicated Trade Associations state that in any case modeling
these scenarios will likely require additional resources in time,
expertise, and enhanced software capabilities.\176\ Indicated Trade
Associations ask that the standard drafting team recognize the range
and quantity of complexities layered into the modeling process, e.g.,
whether concurrent generators must be in a single or multiple balancing
authority area, how many generators are needed for a given study, and
if there is a particular combination of generators needed for
modeling.\177\
---------------------------------------------------------------------------
\176\ Indicated Trade Associations at 9.
\177\ Id.
---------------------------------------------------------------------------
iii. Demand Response
106. EDF and UCS suggest that when evaluating relevant distribution
system impacts, responsible entities should focus on the impacts of the
extreme weather event on both electric demand and on the capability of
the distribution system assets, including demand response, distributed
storage and generation, and utility-scale storage, to mitigate
reliability risks.\178\
---------------------------------------------------------------------------
\178\ EDF Comments at 22-23; UCS Comments at 7-8.
---------------------------------------------------------------------------
107. APS comments that demand response should be used as a tool to
resolve issues and only studied when it is relied on as a mitigation
action.\179\
---------------------------------------------------------------------------
\179\ APS Comments at 4.
---------------------------------------------------------------------------
108. Eversource states that the Commission should encourage
regional flexibility in any consideration of demand response.
Eversource further comments that the Commission should not impose a
``one size fits all'' approach for resources that may significantly
differ based on location. It is also concerned that during extreme
weather events, demand response with heating or cooling-based load
reduction may not be achievable due to safety concerns.\180\
---------------------------------------------------------------------------
\180\ Eversource Comments at 6.
---------------------------------------------------------------------------
109. EPRI asserts that steady state simulation cannot sufficiently
capture demand response, and that there is limited capability to
capture the aggregated dynamic response of demand in the load models
used in positive sequence platforms. EPRI adds that ``the impacts of
demand response are better represented through appropriate temporal and
diurnal patterns that would inform the load and demand profile under a
given extreme temperature condition. This information is best
represented in operational assessments such as resource adequacy or
production cost modeling.'' \181\
---------------------------------------------------------------------------
\181\ EPRI Comments at P 12.
---------------------------------------------------------------------------
110. LCRA notes that while the role of demand response in its
portion of the Bulk-Power System is negligible today, this could change
in the future as additional large loads (e.g., cryptocurrency mining
and data centers) are energized. LCRA states that this trend should be
observed for further consideration in the future.\182\
---------------------------------------------------------------------------
\182\ LCRA Comments at 2-3.
---------------------------------------------------------------------------
b. Commission Determination
111. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR
proposal and direct NERC to require in the proposed new or modified
Reliability Standard that responsible entities perform both steady
state and transient stability (dynamic) analyses in the extreme heat
and cold weather planning studies. In a steady state analysis, the
system components are modeled as either in-service or out-of-service
and the result is a single point-in-time snapshot of the system in a
state of operating equilibrium. A transient stability (dynamic)
analysis examines the system from the start to the end of a disturbance
to determine if the system regains a state of operating
equilibrium.\183\ Performing both analyses ensures that the system has
been thoroughly assessed for instability, uncontrolled separation, and
cascading failures in both the steady state and the transient stability
realms.
---------------------------------------------------------------------------
\183\ Plots are created during the dynamic simulation from pre
to post disturbance and are then examined for voltage, frequency,
and rotor angle stability, which cannot be assessed using only a
steady state analysis.
---------------------------------------------------------------------------
112. We also adopt the NOPR proposal and direct NERC to define a
set of contingencies that responsible entities will be required to
consider when conducting wide-area studies of extreme heat and cold
weather events under the new or modified Reliability Standard. We
believe that it is necessary to establish a set of common contingencies
for all responsible entities to analyze. Required contingencies, such
as those listed in Table 1 of Reliability Standard TPL-001-5.1 (i.e.,
category P1 through P7), establish common planning events that set the
starting point for transmission system planning assessments. Requiring
the study of predefined contingencies will ensure a level of uniformity
across planning regions--a feature that will be necessary in the new or
revised Reliability Standard considering that extreme heat and cold
weather events often exceed the geographic boundaries of most existing
planning footprints.
113. Additionally, establishing a set of required contingencies
will aide in the auditing and enforcement of the new or revised
Reliability Standard. While we do not require in this final rule the
inclusion of any particular contingency, we agree with commenters that
the contingencies required in the new or revised Reliability Standard
should reflect the complexities of transmission system planning studies
for extreme heat and cold weather events. As such, NERC may determine
whether contingencies P1 through P7 should also apply to the new or
modified Reliability Standard, or whether a new set of contingencies
should be developed.
114. Regarding the request for clarification from EPRI as to what
outages should be included in the benchmark planning case versus
modeled as contingencies, we believe the standard drafting team is best
positioned to consider that specific question. By definition, the
benchmark planning case will already include certain weather-related
contingencies that therefore will not be studied as additional
contingencies when conducting extreme weather studies.\184\ For
example, baseline drought conditions will be present in the benchmark
planning case as part of the system models representing projected
system conditions,\185\ whereas the impacts of more severe droughts
could be studied during sensitivity analysis as a variation to the
benchmark planning case's generation assumptions.\186\ As discussed in
section IV.F above, we direct NERC to develop specific criteria for
determining which outages should be considered in the benchmark
planning case.
---------------------------------------------------------------------------
\184\ See supra P 39.
\185\ See supra note 155.
\186\ See infra P 124.
---------------------------------------------------------------------------
115. Regarding the study of common mode failures, we reiterate our
above directives concerning the study of concurrent/correlated
generator and transmission outages. We believe that, as suggested by
Indicated Trade Associations, the standard development process will
provide an adequate platform to address the concerns raised by
commenters regarding common mode failures.
116. We also direct NERC to require in the new or modified
Reliability Standard that responsible entities model demand load
response in their extreme weather event planning area. As indicated by
several commenters, because demand load response is generally a
mitigating action that involves reducing distribution load during
periods of stress to stabilize the Bulk-Power System, its effect during
an extreme weather event should be modeled.
117. Regarding EPRI's comment that steady state simulation cannot
[[Page 41277]]
sufficiently capture demand load response, we believe EPRI's comments
are accurate for modeling in the operational timeframe for temporal and
diurnal studies. However, we recognize that it is possible that the
loads used to represent extreme heat and cold events will include the
effects of demand load response because entities' load data obtained
from historical data during these past extreme events will reflect the
effects of demand load response. If that is the case, demand load
response will be automatically factored into the benchmark planning
case. Thus, in addressing this directive, we expect NERC to determine
whether responsible entities will need to take additional steps to
ensure that the impacts of demand load response are accurately modeled
in extreme weather studies, such as by analyzing demand load response
as a sensitivity, as is currently the case under Reliability Standard
TPL-001-5.1.\187\
---------------------------------------------------------------------------
\187\ Reliability Standard TPL-001-5.1, at Requirement 2.1.3.
---------------------------------------------------------------------------
2. Sensitivity Analysis
118. In the NOPR, the Commission proposed directing NERC to
establish a requirement for responsible entities to consider system
models and sensitivity cases when assessing extreme heat and extreme
cold weather.\188\ The NOPR explained that, while Reliability Standard
TPL-001-5.1 requires the use of sensitivity power flow cases, the
Standard does not require responsible entities to model the
simultaneous variation of load, generation, and transfers necessary to
account for the impacts of extreme heat and cold weather events. This,
in turn, could result in failure to detect in the planning horizon
potential reliability issues such as widespread outages and cascading
failures.\189\
---------------------------------------------------------------------------
\188\ NOPR, 179 FERC ] 61,195 at P 73. Sensitivity analyses
consider the impact on a base case by altering discrete variables.
\189\ Id.
---------------------------------------------------------------------------
119. The NOPR further stated that to accurately model the impacts
of extreme heat and cold weather events it would be necessary to define
and model in sensitivity analyses demand probability scenario cases,
generators that are affected by these events (i.e., wind tripping off,
solar dropping off, gas plants not being operational due to gas
restrictions/freeze-offs, etc.) and transfer levels.\190\
---------------------------------------------------------------------------
\190\ Id.
---------------------------------------------------------------------------
120. The NOPR requested comment on: (1) whether to require
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.\191\
---------------------------------------------------------------------------
\191\ Id. P 74.
---------------------------------------------------------------------------
a. Comments
121. Some commenters support requiring the consideration of certain
sensitivities. For example, AEP recommends that a baseline set of
sensitivities should be defined by the NERC standard drafting team and
there should be flexibility for planning coordinators to introduce
further sensitivities if deemed necessary.\192\ EPRI suggests that
multiple hours may need to be studied over the course of the extreme
temperature window to capture sensitivities related to generation and
demand that can lead to differing steady state and dynamic stability
impacts. EPRI also recommends that in addition to the sensitivities
driven by the operational performance of the system, the standard
should include other external drivers that may compound system
conditions during the extreme temperature events, such as a concurrent
lull in wind speeds that would limit wind generation outputs.\193\
---------------------------------------------------------------------------
\192\ AEP Comments at 12.
\193\ EPRI Comments at P 22.
---------------------------------------------------------------------------
122. Other commenters suggest reasons why it may not be necessary
for the Commission to direct the study of additional sensitivities.
NYISO and LCRA explain that extreme heat and cold weather impacts and
unavailability of natural gas fuel are already studied as sensitivities
under Reliability Standard TPL-001-5.1.\194\ Similarly, Indicated Trade
Associations assert that the extreme weather base case should already
represent system conditions at or near possible seasonal extreme
weather limits and that, as such, many additional sensitivities may not
be necessary.\195\ LCRA adds that the effect of changing inputs (e.g.,
load and generation, including generation retirements and forced
generation outages) should be captured in the contingency definitions,
performance requirements, and analysis for the given region and extreme
weather case.\196\
---------------------------------------------------------------------------
\194\ NYISO Comments at 13; LCRA Comments at 3.
\195\ Indicated Trade Associations Comments at 10.
\196\ LCRA Comments at 3.
---------------------------------------------------------------------------
123. Idaho Power, APS, and Indicated Trade Associations indicate
that given the diversity among utilities with respect to load profiles,
geographic footprint, resource mix, particular utility, its resource
mix, and geographic footprint, and available resources and needs, the
Commission should allow entities to select the sensitivities they will
study.\197\
---------------------------------------------------------------------------
\197\ Indicated Trade Associations Comments at 11; Idaho Power
Comments at 4-5; APS Comments at 7.
---------------------------------------------------------------------------
b. Commission Determination
124. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR
proposal and direct NERC to require the use of sensitivity cases to
demonstrate the impact of changes to the assumptions used in the
benchmark planning case. Sensitivity analyses help a transmission
planner to determine if the results of the base case are sensitive to
changes in the inputs. The use of sensitivity analyses is particularly
necessary when studying extreme heat and cold events because some of
the assumptions made when developing a base case may change if
temperatures change--for example, during extreme cold events, load may
increase as temperatures decrease, while a decrease in temperature may
result in a decrease in generation. We agree with AEP, and we direct
NERC to define during the Reliability Standard development process a
baseline set of sensitivities for the new or modified Reliability
Standard. While we do not require the inclusion of any specific
sensitivity in this final rule, NERC should consider including
conditions that vary with temperature such as load, generation, and
system transfers.\198\
---------------------------------------------------------------------------
\198\ NOPR, 179 FERC ] 61,195 at P 73.
---------------------------------------------------------------------------
125. We do not agree with Idaho Power, APS, and Indicated Trade
Associations that responsible entities alone should determine the
sensitivity cases that must be considered in the responsible entity's
study. Failure to consider variations in conditions necessary to
reflect extreme heat or cold weather events could result in major
reliability risks being overlooked and undetected in the planning
horizon.\199\ We do, however, believe that responsible entities should
be free to study additional sensitivities relevant to their planning
areas. Because wide-area studies conducted under the new or modified
Reliability Standard will be likely based on footprints significantly
larger than those typically concerned under Reliability Standard TPL-
001.5.1, cooperation will be necessary between responsible entities
conducting extreme heat and cold weather studies and other registered
entities within their extreme weather study footprints to ensure the
selection of appropriate sensitivities. EPRI's comment further
highlights the need for coordination between
[[Page 41278]]
registered entities to capture sensitivities related to variable energy
resources and demand.
---------------------------------------------------------------------------
\199\ See id.
---------------------------------------------------------------------------
126. We disagree with NYISO and LCRA that extreme heat and cold
weather impacts are already studied as sensitivities under Reliability
Standard TPL-001-5.1. Although TPL-001-5.1 mandates sensitivity
analysis by varying one or more conditions specified in the standard
such as load, generation, and transfers, this analysis alone cannot
capture the complexities of extreme heat and cold weather conditions.
Sensitivity analyses consider the impact on a base case of the
variability of discrete variables. Extreme heat and cold weather
impacts, on the other hand, may include numerous concurrent outages and
derates which cannot be studied as part of a single-variable
sensitivity analysis. Under the new or modified Reliability Standard,
however, these outages will be captured in the benchmark planning case
upon which sensitivity analyses will be performed.
3. Modifications to the Traditional Planning Approach
127. In the NOPR, the Commission proposed to direct NERC to
consider alternative planning methods and techniques that diverge from
past Reliability Standard requirements to better capture the challenges
posed by extreme heat and cold events.\200\
---------------------------------------------------------------------------
\200\ Id. P 75.
---------------------------------------------------------------------------
128. The NOPR stated that Reliability Standard TPL-001-5.1 is based
on a deterministic approach, which uses planned contingencies and
specific 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.\201\ However, as noted
in the NOPR, 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.\202\
---------------------------------------------------------------------------
\201\ Id.
\202\ Id.
---------------------------------------------------------------------------
129. The NOPR explained the value of establishing a new or modified
planning approach to better capture the impacts of, and ensure reliable
planning and operation in response to, extreme heat and cold
events.\203\ Specifically, the NOPR mentioned as an option expanding
current deterministic studies to include probabilistically developed
scenarios as an option to better account for uncertainties during
extreme heat and cold weather conditions, since probabilistic tools can
capture ``random uncertainties in power system planning, including
those in load forecasting, generator performance, and failures of
system equipment.'' \204\
---------------------------------------------------------------------------
\203\ Id. P 78.
\204\ Id. P 79.
---------------------------------------------------------------------------
130. Finally, the NOPR sought comments 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, the NOPR sought comments on the use of a
hybrid deterministic/probabilistic planning approach and the following:
(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.\205\
---------------------------------------------------------------------------
\205\ Id.
---------------------------------------------------------------------------
a. Comments
131. Many commenters support the use of probabilistic methods in
transmission planning to account for uncertainty in availability of
transmission and generation in extreme weather conditions.\206\ For
example, PJM states that the use of probabilistic modeling ``would help
establish the baseline and sensitivity system conditions upon which
deterministic approaches for go/no-go corrective action transmission
build decisions would be made.'' \207\ EPRI discusses potential
deficiencies in traditional deterministic approaches in planning
studies in cases where uncertainty and variability will increase on
both the generation and demand side across a variety of temperature
extremes. EPRI raises concerns that scenarios or system conditions that
result in consequential stability implications may not be adequately
captured in the planning models using the traditional deterministic
approach.\208\ ACP states that there is precedent for using
probabilistic tools in assessing electric reliability, as these methods
are widely used by utilities and RTOs to assess resource adequacy and
loss of load risk.\209\
---------------------------------------------------------------------------
\206\ See, e.g., NESCOE Comments at 9; EPRI Comments at P 24;
PJM Comments at 11; EDF Comments at 20; PIOs Comments at 7; ACEG
Comments at 7; NARUC Comments at 5-6; ACP Comments at 15; Entergy
Comments at 6.
\207\ PJM Comments at 11.
\208\ EPRI Comments at P 24.
\209\ ACP Comments at 16.
---------------------------------------------------------------------------
132. Other commenters do not support a requirement to use
probabilistic methods. For example, while AEP recognizes the value of
probabilistic methods, it warns that the industry is not yet ready
because the necessary methods, frameworks, and tools are not yet
available to transmission planners.\210\ Several other commenters warn
that it would be premature to require the use of probabilistic
methods.\211\ Trade Associations express concern that probabilistic
planning based on extremely low probability events is highly
speculative and dependent on the judgment of planners, which increases
the complexity and risk associated with the development of transmission
projects, hampering the construction of needed transmission.\212\ Idaho
Power also does not think converting to a probabilistic approach is
necessary as sensitivities with appropriate inputs will capture the
impacts of extreme weather using deterministic techniques.\213\ LCRA
comments that probabilistic analysis requires large samples (i.e.,
number of events), but given the infrequent occurrence of extreme
weather events, it would be challenging to layer probabilistic
assumptions into transmission planning analyses.\214\
---------------------------------------------------------------------------
\210\ AEP Comments at 22.
\211\ APS Comments at 7 (requesting that the Commission hold
``robust industry-wide discussions to discuss probabilistic
approaches''); Tri-State Comments at 8.
\212\ Trade Associations Comments at 11.
\213\ Idaho Power Comments at 5.
\214\ LCRA Comments at 3-4.
---------------------------------------------------------------------------
133. Supporters of the use of probabilistic methods acknowledge
that implementation poses challenges. For example, EPRI comments that
implementation of probabilistic methods would require new processes to
link and communicate data across models, such as linking generation and
transmission expansion assessments, resource adequacy, production cost
models, and transmission planning assessments.\215\ Further, new
statistical methods and processes will be needed to inform the
selection of powerflow cases for planning assessments.\216\ PJM states
that the benefits of applying probabilistic methods would require
knowing in advance pre-established bounded parameter ranges, so
[[Page 41279]]
reasonable selection of probabilistic method assumptions lead to
benchmark planning cases that reflect statistically credible
scenarios.\217\ PJM further states that this should be the result of
coordinated analysis among RTOs, NOAA, DOE Labs, and NERC.\218\ Entergy
asserts that the probabilistic approach is significantly more
complicated than deterministic planning and cautions that any
requirement for probabilistic planning must have requirements that
reasonably can be performed, are assessable, and are auditable for
compliance.\219\ Because of the potential challenges associated with
implementing probabilistic planning requirements, Tri-State recommends
the further study of and development of best practices for
probabilistic planning.\220\
---------------------------------------------------------------------------
\215\ EPRI Comments at P 25.
\216\ Id.
\217\ PJM Comments at 11.
\218\ Id.
\219\ Entergy Comments at 9.
\220\ Tri-State Comments at 8.
---------------------------------------------------------------------------
b. Commission Determination
134. Pursuant to section 215(d)(5) of the FPA, the Commission
adopts and modifies the NOPR proposal and directs NERC to require in
the new or modified Reliability Standard the use of planning methods
that ensure adequate consideration of the broad characteristics of
extreme heat and cold weather conditions. We further direct NERC to
determine during the standard development process whether probabilistic
elements can be incorporated into the new or modified Reliability
Standard and implemented presently by responsible entities. If NERC
identifies probabilistic elements which responsible entities can
feasibly implement and that would improve upon existing planning
practices, we expect the inclusion of those methods in the proposed
Reliability Standard.
135. Including probabilistic scenarios in the planning process
could result in a planning approach that better captures the
uncertainties of extreme weather events, thus better preparing
responsible entities to ensure Reliable Operation under stressed
conditions.\221\ Further, we agree with commenters that the use of
probabilistic methods by responsible entities would help ensure
Reliable Operation of the Bulk-Power System as probabilistic methods
better characterize multi-day wide-area events such as extreme heat and
cold events.\222\
---------------------------------------------------------------------------
\221\ NOPR, 179 FERC ] 61,195 at P 76.
\222\ EPRI Comments at 4.
---------------------------------------------------------------------------
136. However, we recognize, as certain commenters point out, that a
prescriptive requirement to add probabilistic planning methods to
better understand reliability implications could be met by significant
challenges. Some of the challenges identified by commenters include
lack of commercially available tools required for probabilistic
modeling and lack of planning staff trained in the use of these tools
and in carrying out probabilistic studies. Further, there may be a need
to develop and maintain probabilistic databases that include, for
example, outage data from extreme weather-dependent grid components and
generation resources.
137. Because of these implementation concerns, we believe that the
best course of action is to allow NERC to use its expertise and the
standard development process to address the concerns identified by
commenters and develop proposed modifications to existing planning
methods that address the Commission's directive to use transmission
planning methods that adequately characterize the effects of extreme
heat and cold weather conditions on the transmission system, including
incorporating probabilistic elements where possible. The standard
development process will also provide an adequate forum in which to
evaluate the many recommendations that commenters have presented in
response to the NOPR.
138. We also direct NERC to identify during the standard
development process any probabilistic planning methods that would
improve upon existing planning practices, but that NERC deems
infeasible to include in the proposed Reliability Standard at this
time. If any such methods are identified, NERC shall describe in its
petition for approval of the proposed Reliability Standard the barriers
preventing the implementation of those probabilistic elements. We
intend to use this information to determine whether and what next steps
may be warranted to facilitate the use of probabilistic methods in
transmission system planning practices.
H. Implement a Corrective Action Plan if Performance Standards Are Not
Met
139. The NOPR noted that under the currently effective Reliability
Standard TPL-001-5.1, planning coordinators and transmission planners
are required to evaluate possible actions to reduce the likelihood or
mitigate the consequences of extreme weather events, but are not
obligated to develop corrective action plans, even if such events are
found to cause cascading outages.\223\ Because of the potential
severity of extreme heat and cold weather events and their likelihood
to cause system instability, uncontrolled separation, or cascading
failures as a result of a sudden disturbance or unanticipated failure
of system elements, the NOPR proposed to direct NERC to require
corrective action plans that include mitigation for any instances where
performance requirements for extreme heat and cold events are not
met.\224\
---------------------------------------------------------------------------
\223\ NOPR, 179 FERC ] 61,195 at P 83. Reliability Standard TPL-
001-5.1, 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.
\224\ Id.
---------------------------------------------------------------------------
140. Consistent with the existing requirements of Reliability
Standard TPL-001-5.1, the NOPR proposed to provide responsible entities
with the flexibility to determine the actions to include in their
corrective action plans to remedy identified deficiencies in
performance. The NOPR included several examples of actions that could
be included in a corrective action plan: 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. The NOPR
observed that 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.\225\
---------------------------------------------------------------------------
\225\ Id. P 84.
---------------------------------------------------------------------------
141. The NOPR explained that increases in interregional transfer
capability could be considered as one option to address potential
reliability issues during extreme weather events.\226\ The NOPR noted
that 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.\227\ 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.\228\
---------------------------------------------------------------------------
\226\ Id. P 85.
\227\ Id.
\228\ Id. In this proceeding, 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.
---------------------------------------------------------------------------
[[Page 41280]]
142. To ensure the timely development and implementation of
corrective action plans, the NOPR sought comments on the timeframe for
developing such corrective action plans and sharing of the corrective
actions with other interconnected planning entities.\229\ In addition,
to identify opportunities for improved wide-area planning studies and
coordination, the NOPR requested comment on how to develop corrective
action plans that mitigate issues that require corrective action by,
and coordination among, multiple transmission owners.\230\
---------------------------------------------------------------------------
\229\ Id.
\230\ Id. P 67.
---------------------------------------------------------------------------
1. Comments
a. Jurisdictional Issues
143. Several commenters raise jurisdictional concerns regarding
corrective action plans.\231\ While Indicated Trade Associations
support the NOPR proposal to require corrective action plans addressing
vulnerabilities identified in the study process, they also urge that
the Commission ``remain mindful'' of the statutory limitation set forth
in FPA section 215(i) that NERC and the Commission do not have
authority ``to order the construction of additional generation or
transmission capacity or to set or enforce compliance with standards
for adequacy or safety of electric facilities or services.'' \232\ In
particular, Indicated Trade Associations express concern that certain
examples of potential corrective action plans mentioned in the NOPR,
including ``planning for additional contingency reserves . . . or
increasing intra- and inter-regional transfer capabilities,'' exceed
the Commission's authority under section 215 of the FPA.\233\
Similarly, Electric Reliability Council of Texas, Inc. (ERCOT) opines
that ``[r]equiring transmission planners to address what is
fundamentally a resource adequacy concern through the transmission
planning process would usurp the authority of the states, which are
responsible for ensuring the adequacy of the generation supply.'' \234\
---------------------------------------------------------------------------
\231\ Indicated Trade Associations Comments at 11-12; ERCOT
Comments at 5.
\232\ Indicated Trade Association Comments at 12 (citing 16
U.S.C. 824o(i)).
\233\ Id. at 11-12; ERCOT Comments at 5.
\234\ ERCOT Comments at 5.
---------------------------------------------------------------------------
b. Corrective Action Plans
144. Most commenters agree that corrective action plans should be
required to address system performance issues identified in studies
under extreme heat and cold weather conditions.\235\ NERC agrees that
any revised Reliability Standard directed under a final rule issued in
this proceeding should require that entities develop corrective action
plans for instances where performance requirements for selected extreme
weather and environmental conditions are not met for at least some of
the planning scenarios.
---------------------------------------------------------------------------
\235\ See, e.g., NERC Comments at 10; NARUC Comments at 6;
NESCOE Comments at 3; MISO Comments at 4.; PJM Comments at 12.
---------------------------------------------------------------------------
145. BPA asserts that several of the corrective action plan
examples listed in the NOPR, such as transmission switching/
reconfiguration, or adjusting transmission and generation maintenance
outages, would likely be covered by Reliability Standard EOP-011-2,
requiring transmission operators and balancing authorities to have
operating plans to mitigate operating emergencies including determining
the reliability impacts of extreme weather conditions. Therefore, BPA
cautioned, any modifications to Reliability Standard TPL-001-5.1 should
be careful not to encroach upon the authority and discretion of
transmission operators and balancing authorities.\236\
---------------------------------------------------------------------------
\236\ BPA Comments at 4.
---------------------------------------------------------------------------
146. Some commenters do not support the NOPR proposal to require
the development and implementation of corrective action plans for all
instances where performance requirements for extreme heat and cold
events are not met. APS asserts that ``corrective action plans should
be focused on the most likely and impactful events, which may not
include extreme weather scenarios,'' and that as such, it disagrees
that corrective action plans ``should be required for results that come
out of sensitivity analysis, which includes extreme weather
scenarios.''
147. With regard to costs, National Association of Regulatory
Utility Commissioners (NARUC) asserts that mitigation and corrective
actions to minimize loss of load and improve resilience should be
subjected to a cost/benefit analysis.\237\ Entergy suggests that the
Commission ``provide additional guidance regarding the level of
performance it expects during extreme heat and cold events,'' including
consideration of ``the cost effects on customers relative to the
potential risks and the time-frame in which those risks are likely to
arise.'' \238\
---------------------------------------------------------------------------
\237\ NARUC Comments at 6.
\238\ Entergy Comments at 2.
---------------------------------------------------------------------------
c. Generation and Transmission Capacity Increase and Resource Adequacy
Issues
148. Most commenters agree that the responsible entities developing
corrective action plans should evaluate a range of solutions, including
transmission upgrades to increase interregional transfer capability
and/or building generation to address generation deficiency under
extreme weather events.\239\ Some commenters, however, question the
efficacy of corrective action plans and suggest that alternative
approaches are preferable.
---------------------------------------------------------------------------
\239\ See, e.g., NARUC Comments at 6; UCS Comments at 9; PIOs
Comments at 15; AEP Comments at 5; ACEG Comments at 8; ACP Comments
at 11; Entergy Comments at 8.
---------------------------------------------------------------------------
149. With regards to transmission capacity, and specifically
interregional transfer capabilities, many commenters agree that
adequate interregional transfer capability would help address
reliability challenges posed by extreme heat and cold weather
conditions.\240\ Some commenters urge the Commission to set a minimum
interregional transfer capability requirement.\241\ However, most
commenters addressing this topic opine that interregional transfer
requirements, including setting necessary or minimum transfer levels
and direction, should be addressed outside of the Reliability Standard
TPL-001-5.1 planning process.\242\ For example, MISO Transmission
Owners suggest that interregional transfers could be better dealt with
under Order No. 1000 Regional Transmission Planning processes.\243\
MISO recommends that corrective action plans require meaningful
mitigation, such as investment in transmission solutions, to address
issues identified in an extreme weather event study.\244\ Conversely,
Idaho Power states that if regional transmission facilities are to be
considered as corrective actions, Idaho Power would have concerns with
the efficacy of those corrective actions given the amount of time
necessary to build new transmission.\245\
---------------------------------------------------------------------------
\240\ AEP Comments at 2; ACP Comments at 19; ACEG Comments at 9;
PJM Comments at 12; see MISO Transmission Owners Comments at 5-6.
\241\ EDF Comments at 27; AEP Comments at 2; ACP Comments at 19;
ACEG Comments at 9; PJM Comments at 12.
\242\ MISO Transmission Owners Comments at 5-6; ACP Comments at
19; ACEG Comments at 9; AEP Comments at 2.
\243\ MISO Transmission Owners Comments at 5.
\244\ MISO Comments at 4.
\245\ Idaho Power Comments at 4, 6.
---------------------------------------------------------------------------
150. Most commenters who disagree with the NOPR proposal to allow
entities to consider additional generation capacity as a corrective
action plan measure disagree on the
[[Page 41281]]
basis that resource adequacy is not a matter that should be dealt with
within the transmission planning process.\246\ For example, ISO-NE
asserts that the purpose of Reliability Standard TPL-001-5.1 is not to
ensure resource adequacy, but to ensure that load can be served.\247\
ACP and PIOs question the efficacy of building new generation as part
of a corrective action plan because such new generation may be subject
to the same issues as existing generation--for example, if an extreme
cold event leads to the outage of weather-sensitive generators, adding
more weather-sensitive generators will not resolve the resource
deficiency.\248\
---------------------------------------------------------------------------
\246\ See, e.g., PJM Comments at 12; ERCOT Comments at 5; ISO-NE
Comments at 4.
\247\ ISO-NE Comments at 4.
\248\ ACP Comments at 6; PIOs Comments at 16.
---------------------------------------------------------------------------
d. Notification to Applicable Regulatory Authorities or Governing
Bodies Responsible for Retail Electric Service Issues
151. ACP, New England States Committee on Electricity (NESCOE), and
Entergy comment that entities must coordinate with state and local
authorities in the development of corrective action plans involving
generation and transmission capacity.\249\ For example, NESCOE suggests
that corrective action plans be informed by state officials'
perspectives, consider a variety of mitigation options, and include a
detailed explanation of how the entity weighed the various
options.\250\ Additionally, NESCOE points out that given the likelihood
that corrective action plans will include load shed, state officials
should be involved in the corrective action plan process.\251\ NESCOE
proposes that responsible entities seek input from state regulators
during their planning process. Alternatively, NESCOE recommends the
adoption of the Joint Federal-State Task Force on Electric Transmission
model to create a similar task force focusing on extreme weather and
grid reliability.\252\
---------------------------------------------------------------------------
\249\ See ACP Comments at 18; NESCOE Comments at 3; see also
Entergy Comments at 9 (stating in the context of the development of
corrective action plans that ``[t]he Commission also should ensure
that the relevant retail regulators have input into the level of
risks versus costs a transmission owner should accept.'').
\250\ NESCOE Comments at 3.
\251\ Id. at 5.
\252\ Id. at 6.
---------------------------------------------------------------------------
2. Commission Determination
152. Pursuant to section 215(d)(5) of the FPA, the Commission
adopts and modifies the NOPR proposal and directs NERC to require in
the new or modified Reliability Standard the development of extreme
weather corrective action plans for specified instances when
performance standards are not met. In addition, as explained below, we
direct NERC to develop certain processes to facilitate interaction and
coordination with applicable regulatory authorities or governing bodies
responsible for retail electric service as appropriate in implementing
a corrective action plan.
153. We adopt our rationale set forth in the NOPR and conclude that
the directive to require the development of corrective action plans is
needed for Reliable Operation of the Bulk-Power System. Under the
currently effective Reliability Standard TPL-001-5.1, planning
coordinators and transmission planners are required to evaluate
possible actions to reduce the likelihood or mitigate the consequences
of extreme weather events, but are not obligated to develop corrective
action plans, even if such events are found to cause cascading outages.
Experience over the past decade has demonstrated that the potential
severity of extreme heat and cold weather events exacerbates the
likelihood to cause system instability, uncontrolled separation, or
cascading failures as a result of a sudden disturbance or unanticipated
failure of system elements. Thus, we conclude that entities should
proactively address known system vulnerabilities by developing
corrective action plans that include mitigation for specified instances
where performance requirements for extreme heat and cold events are not
met.
a. Jurisdictional Issues
154. We reject the arguments that our directive to require
responsible entities to develop corrective action plans may exceed the
Commission's jurisdiction. Section 215(i)(2) of the FPA states that the
Commission and ERO are not authorized to order the construction of
additional generation or transmission capacity as part of a Reliability
Standard.\253\ Consistent with this limitation, the final rule does not
require any responsible entity to engage in the construction of
additional generation or transmission capacity. Moreover, while the
final rule directs NERC to include in a new or modified Reliability
Standard a requirement for entities to develop a corrective action plan
to address extreme heat and cold weather events during the transmission
planning process, the final rule does not mandate the use of any
specific mitigation measure.\254\
---------------------------------------------------------------------------
\253\ 16 U.S.C. 824o(i)(2).
\254\ NOPR, 179 FERC ] 61,195 at P 84 (``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'').
---------------------------------------------------------------------------
155. As noted by commenters, the NOPR provided examples of various
activities that may be appropriate under a corrective action plan, some
of which may require state or local authorizations (e.g., generation or
transmission development).\255\ Other examples mentioned in the NOPR
include ``implementing new energy efficiency programs to decrease load,
. . . transmission switching, or adjusting transmission and generation
maintenance outages based on longer-lead forecasts,'' \256\ none of
which involve the construction of generation or transmission capacity.
In addition, responsible entities have the option to use controlled
load shed as a mitigation measure. In sum, while responsible entities
would have the obligation to develop and implement a corrective action
plan, the Commission is not directing any specific result or content of
the corrective action plan. In such circumstances, the Commission's
directive does not exceed the jurisdictional limits set forth in
section 215(i) of the FPA.\257\
---------------------------------------------------------------------------
\255\ Id.
\256\ Id.
\257\ S.C. Pub. Serv. Auth. v. FERC, 762 F.3d 41, 80 (D.C. Cir.
2014).
---------------------------------------------------------------------------
156. In response to ERCOT and other commenters, the Commission's
action does not usurp state authority with regard to resource adequacy.
As explained above, the directive that responsible entities develop
corrective action plans in certain circumstances does not require the
construction of additional generation or transmission capacity.
Further, as discussed below, responsible entities that elect mitigation
activities that involve increased transmission or generation capacity
will of course be subject to the authority of such state agencies or
others with legal jurisdiction over the construction of transmission or
generation facilities.
b. Circumstances That Require Corrective Action Plans
157. As stated above, we adopt and modify the NOPR proposal and
direct NERC to require in the new or modified Reliability Standard the
development of corrective action plans that include mitigation for
specified instances where performance requirements for extreme heat and
cold events are not met--i.e., when certain studies conducted under the
Standard show that an extreme heat or cold event would result in
cascading outages, uncontrolled separation, or instability.\258\ We
agree with APS that
[[Page 41282]]
neither version 4 nor 5.1 of Reliability Standard TPL-001-5.1 require
corrective action plans for extreme heat and cold weather events.
Extreme heat and cold weather events, which pose a serious risk to the
Reliable Operation of the Bulk-Power System, are increasing in
frequency and intensity. We believe that in taking steps to avoid
occurrences of cascading outages, uncontrolled separation, or
instability under extreme heat and cold, corrective action plans would
also minimize the extent and duration of loss of load and improve Bulk-
Power System resilience during extreme heat and cold weather
events.\259\
---------------------------------------------------------------------------
\258\ NOPR, 179 FERC ] 61,195 at P 83.
\259\ Id. P 84.
---------------------------------------------------------------------------
158. Although the NOPR proposed requiring the development of
corrective action plans for any instance where performance requirements
for extreme heat and cold events are not met, we give NERC in this
final rule the flexibility to specify the circumstances that require
the development of a corrective action plan. For example, NERC should
determine whether corrective action plans should be required for single
or multiple sensitivity cases, and whether corrective action plans
should be developed if a contingency event that is not already included
in benchmark planning case would result in cascading outages,
uncontrolled separation, or instability.\260\ Because we also direct
NERC to establish required study contingencies and baseline
sensitivities,\261\ we believe it is necessary for NERC to develop
those aspects of the Standard prior to determining the instances under
which corrective action plans must be developed.
---------------------------------------------------------------------------
\260\ Under Reliability Standard TPL-001-5.1, corrective action
plans are not required for single sensitivity cases.
\261\ See supra PP 111, 124.
---------------------------------------------------------------------------
159. With regard to BPA's suggestion that Reliability Standard EOP-
011-2 already addresses certain mitigation measures listed in the NOPR
as examples, we clarify that nothing in the final rule affects the
responsibilities or obligations of registered entities under that
Reliability Standard and note that there are important differences in
the scope and intent of EOP-011-2 and the Reliability Standard we are
directing be developed here. Specifically, while Reliability Standard
EOP-011-2 includes provisions to determine reliability impacts of
extreme cold conditions and extreme weather conditions,\262\ it does
not require the transmission operator to mitigate the condition. In
addition, Reliability Standard EOP-011-2 addresses the issues within
the operating time frame. Corrective action plans, as proposed in the
NOPR, would be developed in the planning horizon to address the issues
in the long-term planning time frame. Simultaneously, such issues would
be addressed by Reliability Standard EOP-011-2 in the operating time
frame should the studied extreme weather condition occur. As such,
there would not be any encroachment or conflict between the two
standards.
---------------------------------------------------------------------------
\262\ Reliability Standard EOP-011-2, Requirement 1.2.6.
---------------------------------------------------------------------------
160. With respect to arguments from NARUC and Entergy that the
Commission should require cost-benefit analysis for corrective action
plans or otherwise provide additional guidance as to the cost impacts
on customers, we decline to do so. FPA section 215 does not require the
use of cost-benefit analysis and, given the flexibility allowed to
responsible entities in crafting a corrective action plan, we are not
persuaded such a requirement would be warranted in this instance.
Regarding the cost impact on customers more generally, we believe that
NERC should have an opportunity in the first instance to balance such
impacts and present a new or modified Reliability Standard for
Commission approval. As articulated in Order No. 672, the cost of
compliance is but one factor in determining whether to approve a
proposed Reliability Standard and we will consider the potential cost
impacts in the context of the larger record.\263\
---------------------------------------------------------------------------
\263\ See Order No. 672, 114 FERC ] 61,104 at P 330.
---------------------------------------------------------------------------
c. Generation and Transmission Capacity Increase and Resource Adequacy
Issues
161. As discussed above, corrective action plans are not required
to use any specific mitigation measure and responsible entities are not
required to build transmission or generation. Nevertheless, some
entities may choose to include additional transmission or generation
capacity as a mitigation measure in their corrective action plan,
subject to the approval of relevant regulatory authorities.
162. With respect to the use of transmission as a mitigation
measure, as stated in the NOPR and echoed by commenters, interregional
transfer capability can be a solution to some extreme weather-related
reliability concerns. We recognize that a proposal by a planning entity
to increase its interregional transfer capability to address the impact
of extreme heat and cold conditions on its portion of the Bulk-Power
System may be acceptable in a corrective action plan, and we expect
that the benchmark planning cases developed, and wide-area studies
conducted under this Standard could be beneficial for purposes of
determining interregional transfer needs. However, we decline to set a
minimum interregional transfer capability requirement in this
proceeding and note the Commission's ongoing pending proceeding
addressing such a requirement in Docket No. AD23-3.
163. Regarding Idaho Power's concern given the amount of time
necessary to build new transmission,\264\ we note that corrective
action plans address deficiencies identified in a long-term
transmission planning timeframe (i.e., six to ten years and beyond).
The period associated with a transmission project will inform whether
and when that project may be included in an extreme weather corrective
action plan. For example, a transmission project that is not expected
to be operational in the six-to-ten-year long-term horizon may not be
relied upon in an extreme weather corrective action plan to mitigate
identified system deficiencies within that time horizon. In that
circumstance, the responsible entity will have to develop an extreme
weather corrective action plan that includes other measures that can be
implemented to ensure Reliable Operation of its portion of the Bulk-
Power System.
---------------------------------------------------------------------------
\264\ Idaho Power Comments at 4, 6.
---------------------------------------------------------------------------
164. With respect to concerns that generation capacity is not
appropriately included in corrective because it should be addressed
through resource adequacy processes, we reiterate our findings above in
section IV.F that the purpose of the new or modified Standard is to
address transmission system deliverability and not to supplant or
duplicate resource adequacy processes. With respect to concerns from
PIOs and ACP that generation may be ineffective as a mitigation
measure, we note that responsible entities have the flexibility to
determine the appropriate mitigation measure for their circumstances.
d. Notification to Applicable Regulatory Authorities or Governing
Bodies Responsible for Retail Electric Service Issues
165. We direct NERC to require in the new or modified Reliability
Standard that responsible entities share their corrective action plans
with, and solicit feedback from, applicable regulatory authorities or
governing bodies responsible for retail electric service issues. We
agree with commenters that relevant state entities should have the
opportunity to provide input during the
[[Page 41283]]
development of corrective action plans. Just as this final rule seeks
to ensure Reliable Operation of the Bulk-Power System during extreme
heat and cold weather events, regulatory authorities and governing
bodies responsible for retail electric service are taking actions to
ensure reliability for local stakeholders. As such, we believe that
requiring responsible entities to seek input from applicable regulatory
authorities or governing bodies responsible for retail electric service
issues when developing corrective action plans could help ensure that
shared opportunities to increase system reliability are not missed.
Further, as NESCOE points out, such consultation may allow these
entities to better understand ``the cost implications of various
approaches'' and, therefore, provide ``better insight into the
considerations and tradeoffs inherent in the options available.'' \265\
---------------------------------------------------------------------------
\265\ NESCOE Comments at 4.
---------------------------------------------------------------------------
166. We also agree with NESCOE that sharing corrective action plans
with applicable regulatory authorities or governing bodies responsible
for retail electric service is necessary given the possibility that
corrective action plans could include load shedding.\266\ As the
Commission has stated in the past, we believe that the public should
have notice and understanding of a responsible entity's plans to shed
non-consequential load.\267\ Therefore, just as Reliability Standard
TPL-001-5.1 requires planning coordinators and transmission planners to
notify stakeholders, including applicable regulatory authorities or
governing bodies responsible for retail electric service, of their
intent to include non-consequential load loss in corrective action
plans for certain single-contingency events,\268\ the new or modified
Reliability Standard must also require responsible entities to
similarly communicate their intent to use non-consequential load shed
in their extreme weather corrective action plans.
---------------------------------------------------------------------------
\266\ Id. at 5.
\267\ Transmission Planning Reliability Standards, Order No.
762, 77 FR 26686 (May 7, 2012), 139 FERC ] 61,060, at P 65 (2012).
\268\ Reliability Standard TPL-001-5.1, at attach. 1.
---------------------------------------------------------------------------
167. Further, because an important goal of transmission planning is
to avoid load shed,\269\ any responsible entity that includes non-
consequential load loss in its corrective action plan should also
identify and share with applicable regulatory authorities or governing
bodies responsible for retail electric service alternative corrective
actions that would, if approved and implemented, avoid the use of load
shedding. Examples could include building additional generation and/or
transmission capacity, energy efficiency programs, and demand load
response programs.\270\
---------------------------------------------------------------------------
\269\ Order No. 693, 118 FERC ] 61,218 at P 1,795.
\270\ To be clear, responsible entities may also pursue such
mitigating actions in the first instance, subject to the approval of
relevant regulatory authorities. See supra P 161.
---------------------------------------------------------------------------
168. While we direct NERC to require registered entities to
communicate the results of their studies and share their extreme
weather corrective action plans with applicable regulatory authorities
or governing bodies responsible for retail electric service, NERC
should not attempt to mandate that entities which are not under the
Commission's jurisdiction participate in the development of corrective
action plans.
I. Other Extreme Weather-Related Events and Issues
169. While the NOPR focused on extreme heat and cold weather
events, the NOPR recognized 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. In the NOPR, the Commission raised a concern that drought may
cause or contribute to conditions that affect reliable operation of the
Bulk-Power System such as transmission outages, reduced plant
efficiency, and reduced generation capacity. The Commission sought
comment on whether drought should be included along with extreme heat
and cold weather events within the scope of the Reliability
Standard.\271\ Additionally, the Commission invited comment on whether
other extreme events with significant impact on the reliability of the
Bulk-Power System could also be considered and modeled in the
future.\272\
---------------------------------------------------------------------------
\271\ NOPR, 179 FERC ] 61,195 at P 92.
\272\ Id. P 93.
---------------------------------------------------------------------------
1. Comments
170. Indicated Trade Associations, EDF, and ACP support including
the consideration of drought with extreme heat and cold weather events
within the scope of the new or modified Reliability Standard.\273\ NERC
agrees, suggesting that drought conditions be studied in drought-prone
areas of the country.\274\ EDF notes that drought events can
significantly impact the capacity and operation of water-cooled fossil
and nuclear generators and other water-cooled assets, as well as
hydroelectric generators. EDF also asserts that drought events are also
highly correlated with high temperature and wildfires. Therefore,
according to EDF, a failure to consider drought impacts could result in
an overestimation of generation availability during an extreme heat
weather event and understate the risks of that event.\275\
---------------------------------------------------------------------------
\273\ Indicated Trade Associations Comments at 13; EDF Comments
at 19; ACP Comments at 18-19.
\274\ NERC Comments at 12.
\275\ EDF Comments at 24.
---------------------------------------------------------------------------
171. Similarly, Indicated Trade Associations note that they support
the study of long-term drought impacts on relevant generation (e.g.,
hydro-electric, geothermal, and nuclear generation) in regions where
drought has been, or may plausibly become, an issue. They add that
droughts are sustained long-term conditions that may be fundamentally
studied and addressed differently--for example, as a fuel supply
sensitivity--than a short-term extreme heat or cold weather event.\276\
However, Indicated Trade Associations believe that the Commission
should not attempt to address all types of extreme weather events at
once in the Reliability Standard, but rather take a phased
approach.\277\
---------------------------------------------------------------------------
\276\ Indicated Trade Associations Comments at 13.
\277\ Id.
---------------------------------------------------------------------------
172. ACP states ``[b]ecause drought events are already widespread
across all regions, and climate change will make them even more
frequent and widespread, it would be prudent for the Commission and
NERC to require all regions to include drought in their analysis of
severe weather benchmark events under TPL-001.'' \278\
---------------------------------------------------------------------------
\278\ ACP Comments at 10.
---------------------------------------------------------------------------
173. Tri-State notes that drought is already sufficiently included
in the resource forecasts developed by Resource Planners.\279\
---------------------------------------------------------------------------
\279\ Tri-State Comments at 8.
---------------------------------------------------------------------------
174. Certain commenters support the inclusion of extreme weather
events beyond heat, cold and drought. For example, NERC identifies
extreme weather conditions for inclusion in required studies, such as
high winds, diminished winds, dust, smoke, fog, and increased cloud
cover.\280\ According to NERC, such long-term, widespread weather and
environmental conditions can impact resource availability and the
transmission system. Other commenters suggest the inclusion of other
extreme weather events such as wildfires, hurricanes, and tornadoes;
\281\ rain and wind (including derechos), and ice storms; \282\ debris
flow (landslide risk following wildfire scars and heavy
[[Page 41284]]
precipitation) and rain-on-snow events that may lead to dam
overtopping.\283\
---------------------------------------------------------------------------
\280\ NERC Comments at 12.
\281\ EDF Comments at 25.
\282\ AEP Comments at 5.
\283\ SCE Comments at 6-7.
---------------------------------------------------------------------------
175. EPRI points out that certain extreme weather events such as
hurricanes or flooding can and do often occur independent of extreme
heat and cold events. As such, EPRI states that the standard should
identify climate and weather-related threats that occur concurrently or
independently based on the planning area's local footprint and develop
scenarios accordingly.\284\
---------------------------------------------------------------------------
\284\ EPRI Comments at P 29.
---------------------------------------------------------------------------
176. In contrast, MISO and LCRA comment that the Reliability
Standard should be limited to extreme heat and cold events. MISO also
comments that there is a fundamental difference between extreme heat
and cold events and other extreme weather events: extreme temperature
events would likely result in the load increasing and continuing to
stay online, while other extreme weather events such as hurricanes or
tornados create the possibility of load loss. MISO also points out that
the operation horizon will continue to prepare for situations like
hurricanes, tornados, or ice storms.\285\ Likewise, LCRA adds that
drought and other extreme weather events beyond extreme temperature are
already modeled by existing extreme event contingencies.\286\
---------------------------------------------------------------------------
\285\ MISO Comments at 2.
\286\ LCRA Comments at 4.
---------------------------------------------------------------------------
2. Commission Determination
177. We decline to direct NERC to create or modify a Reliability
Standard to specifically require the assessment of the impacts of
drought conditions as part of extreme heat and cold transmission system
planning. As explained above, the type of long-term meteorological
study involved in extreme heat and cold event transmission planning
necessarily includes examining the extreme weather impact on base
climate conditions over the study period, conditions that would have to
include anticipated drought conditions in relevant planning areas.\287\
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\287\ See supra P 114
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178. We agree with various commenters that drought conditions may
impact reliability,\288\ and drought impacts on generation are already
studied in the resource forecasts developed by resource planners and
mitigated by operating procedures. Additionally, droughts that may
occur concurrently with extreme heat and cold events will be included
in the benchmark planning case, as drought conditions would be present
in the meteorological data that feeds the benchmark planning case,\289\
and the possibility of more severe drought could be reflected as part
of a sensitivity analysis.\290\
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\288\ See e.g., EDF Comments at 24.
\289\ See supra note 155.
\290\ See supra P 114 and note 155.
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179. Regarding other extreme weather events such as NERC's concern
with high winds, diminished winds, dust, smoke, smog fog, extreme
snowstorms, flooding and increased cloud cover, and extreme snowstorms,
or other commenters recommendations to include hurricanes, tornados,
heavy rain and wind, and ice storms; and adjacent events such as
wildfires, debris flow, and flooding, we agree that these conditions
may affect the Bulk-Power System. However, we are not persuaded that a
directive to address these events in the new or modified Reliability
Standard is warranted at this time.
180. As MISO indicates, there are fundamental differences between
extreme heat and cold events and other extreme weather events that cast
doubt as to whether this Reliability Standard is the correct vehicle
for addressing their impacts.\291\ For instance, extreme heat and cold
events generally affect large geographic areas, while other extreme
weather and adjacent events such as tornadoes, hurricanes, storms,
floods, and wildfires tend to have more localized impacts. Moreover, as
MISO points out, extreme heat and cold weather events are typically
characterized by potential sustained load increases, while other
extreme weather events typically result in load losses.
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\291\ MISO Comments at 2.
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J. Reliability Standard Development and Implementation Timeline
181. The Commission proposed to direct NERC to develop a new or
modified Reliability Standard within one year of the effective date of
a final rule in this proceeding, with compliance obligations beginning
no later than 12 months from Commission approval of the proposed
Reliability Standard.\292\
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\292\ NOPR, 179 FERC ] 61,195 at P 48.
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1. Comments
182. NERC raises no concerns with the proposed 12-month proposal to
create a new or modified Reliability Standard; however, NERC requests
that the Commission consider coordinating the timing of this final rule
to allow NERC to benefit from the informational filings in Docket Nos.
RM22-16-000 and AD21-13-000, as information obtained from these reports
``may prove useful to the NERC standard development process.'' \293\
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\293\ NERC Comments at 14. In Docket Nos. RM22-16-000 and AD21-
13-000, the Commission proposes directing transmission providers to
submit one-time informational reports describing their current or
planned policies and processes for conducting extreme weather
vulnerability assessments. One-Time Informational Reports on Extreme
Weather Vulnerability Assessments; Climate Change, Extreme Weather,
& Elec. Sys. Reliability, Notice of Proposed Rulemaking, 87 FR 39414
(July 1, 2022), 179 FERC ] 61,196 (2022) (Informational Reports
NOPR).
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183. PJM and MISO Transmission Owners state that one year will not
be enough time to develop the proposed Reliability Standard.\294\ PJM
states that such a short timeframe will hamper stakeholder input.\295\
PJM further comments that the NOPR's proposed timeline for standard
development is not ``sequenced with any of the other activities
associated with ensuring enhanced reliability planning'' and will thus
``divert resources from the more comprehensive work that is needed in
this area.'' \296\ MISO Transmission Owners agree that ``one year's
time is not long enough'' to modify or create a new Reliability
Standard, and the Commission should give NERC ``more time.'' \297\
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\294\ PJM Comments at 14; MISO Transmission Owners Comments at
7.
\295\ PJM Comments at 14.
\296\ Id.
\297\ MISO Transmission Owners Comments at 7.
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184. Regarding the effective date of any resulting Reliability
Standard, NERC requests that the Commission clarify the proposed
implementation schedule, i.e., ``whether entities must begin to comply
with all new study requirements within one year of Commission approval
(i.e., completed studies with Corrective Action Plans developed), or
whether a phased-in approach beginning no later than one year is
permitted for entities to coordinate on the development of new models,
collect new data, and perform the necessary coordination to study wide
area impacts before completing studies and developing any associated
Corrective Action Plans.'' \298\
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\298\ NERC Comments at 14-15.
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185. PJM also states that one year is not enough time for
responsible entities to implement the new or revised Reliability
Standard, because after Commission approval ``Transmission Providers
like PJM will have responsibility to translate it into workable
planning process methodologies and related stakeholder-approved manual
language.'' \299\
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\299\ PJM Comments at 14-15.
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186. PJM further calls for flexibility on setting start dates for
the implementation period for different
[[Page 41285]]
entities given variances in regional planning cycles.\300\ APS echoes
the call for flexibility as to the timeframe for developing a
corrective action plan as the potential mitigation strategies may vary
or include neighboring entities.\301\
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\300\ Id.
\301\ APS Comments at 8.
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187. AEP proposes that the Commission provide responsible entities
``at least two years to implement stability analysis'' after the
proposed Reliability Standard takes effect, and that corrective action
plans be developed ``within one year of the assessment of reliability
deficiency.'' \302\
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\302\ AEP Comments at 13, 24.
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2. Commission Determination
188. We direct NERC to submit a new or modified Reliability
Standard within 18 months of the date of publication of this final rule
in the Federal Register. Further, we direct NERC to propose an
implementation timeline for the new or modified Reliability Standard,
with implementation beginning no later than 12 months after the
effective date of a Commission order approving the proposed Reliability
Standard.
189. We agree with NERC that it is important to coordinate the
timeline for the development of a Reliability Standard under this
proceeding with that of the extreme weather one-time informational
reports required under Docket Nos. RM22-16-000 and AD21-13-000.\303\
The Informational Reports Final Rule, which is being issued
concurrently with this final rule, directs responsible entities to
develop and file with the Commission within 120 days of that order's
publica
[…truncated; see source link]Indexed from Federal Register on June 23, 2023.
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