UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Reliability Standards for)Docket No.RM12-22-000

Geomagnetic Disturbances)

COMMENTS OF ALBERTA ELECTRIC SYSTEM OPERATOR, CALIFORNIA
INDEPENDENT SYSTEM OPERATOR, ELECTRIC RELIABILITY COUNCIL OF
TEXAS, THE INDEPENDENT ELECTRICITY SYSTEM OPERATOR OF ONTARIO,

INC., ISO NEW ENGLAND INC., MIDWEST INDEPENDENT TRANSMISSION SYSTEM OPERATOR, INC., NEW YORK INDEPENDENT SYSTEM OPERATOR,
INC., AND SOUTHWEST POWER POOL, INC.

The Alberta Electric System Operator (“AESO”), California Independent System
Operator (“CAISO”), Electric Reliability Council of Texas (“ERCOT”), the Independent
Electricity System Operator of Ontario, Inc. (“IESO”), ISO New England Inc. (“ISO-
NE”), Midwest Independent Transmission System Operator, Inc. (“MISO”), New York
Independent System Operator, Inc. (“NYISO”), and Southwest Power Pool, Inc. (“SPP”)1
(collectively, “Joint ISOs/RTOs”) submit the following comments in response to the
Notice of Proposed Rulemaking (the “NOPR”) regarding the development of Reliability
Standards to address the potential risks to the Bulk-Power System from geomagnetic
disturbances (“GMD”) issued by the Federal Energy Regulatory Commission (the

“Commission”) on October 18, 2012, in this proceeding.2

1 The IESO is not subject to the Commission’s jurisdiction, and these comments do not constitute agreement or acknowledgement that it can be subject to the Commission’s jurisdiction. The AESO is also non-jurisdictional members of the IRC, but is not joining in these comments.

2 Reliability Standards for Geomagnetic Disturbances, 141 FERC ¶ 61,045 (2012).

I.BACKGROUND AND SUMMARY

A.Background

On April 20, 2012, the Commission issued a Technical Conference Agenda for a
conference to be held on April 30, 2012, in Docket No. AD12-13-000. The Technical
Conference Agenda invited comments on the Technical Conference discussions, which
focused on the reliability of the Bulk-Power System as affected by GMD, including the
risks and impacts from geomagnetically induced currents (“GIC”) to transformers and
other equipment on the Bulk-Power System and options for addressing or mitigating the
risks and impacts. On May 21, 2012, the ISO/RTO Council (“IRC”)3 submitted the
following comments on the issues presented in the Technical Conference:4

Additional analysis of actual data observation is necessary before any
reliability standards are proposed in this area given the need for
additional information on GMD impacts and effective mitigation.

In order to enable decisions on such standards, the North American
Electric Reliability Corporation (“NERC”) should work with its

stakeholders to assemble a common repository on geomagnetically
induced currents (“GIC”) indicators (such as neutral currents at

selected locations), such that researchers can correlate this phenomenon to actual observed impacts.

NERC’s interim report provides a sound framework for continuous improvement.

The industry has made observable progress since the blackout in Quebec in 1989.

The industry should work towards a manufacturers’ technical standard that rates a transformer’s estimated GIC resiliency.

3 The IRC is comprised of AESO, CAISO, ERCOT, IESO, ISO-NE, MISO, NYISO, PJM Interconnection, L.L.C. (“PJM”), and SPP.

4 See Geomagnetic Disturbances to the Bulk-Power System, Comments of ISO/RTO Council; Docket No. AD12-13-000 (filed May 21, 2012) (“Technical Conference Comments”).

The IRC supports the comments of PJM provided at the technical conference.

As noted above, on October 18, the Commission issued the NOPR proposing to
address the vulnerabilities regarding GMD by directing NERC “to develop and file for
approval Reliability Standards that address the potential severe, wide-spread impact of
GMD events on the reliable operation of the Bulk-Power System.”5 Under the
Commission’s proposal, the GMD Reliability Standards would be filed in two phases.

In the first phase of the proposal, the Commission would direct NERC to submit:

Reliability Standards that require owners and operators of the Bulk-Power
System to develop and implement operational procedures to mitigate the
effects of GMDs consistent with the reliable operation of the Bulk-Power
System.6

NERC would be required to file the Phase I Reliability Standards with the Commission
within 90 days of the effective date of a Final Rule in this proceeding.7 In the NOPR, the
Commission does not propose to require specific operational procedures, but offers
guidance and identifies certain examples of existing operational procedures to mitigate
GMD events.

In the second phase, the Commission would direct NERC to develop Reliability
Standards that would set forth a multi-phase process.8 More specifically, within six
months of the effective date of a Final Rule in this proceeding, NERC would file the
Phase II Reliability Standards requiring “owners and operators of the Bulk-Power

5 NOPR at P 15.

6 NOPR at P 16. For ease of reference, the comments hereinafter refer to the first phase of the Commission’s proposal as “Phase I”.

7 NOPR at P 16.

8 NOPR at P 25. For ease of reference, the comments hereinafter refer to the second phase of the Commission’s proposal as “Phase 2”.

System” to: (1) “conduct initial and on-going assessments of the potential impacts of
GMDs on Bulk-Power System equipment and on the Bulk-Power System as a whole”;9
and, (2) “[b]ased on those assessments . . . develop and implement a plan so that
instability, uncontrolled separation, or cascading failures of the Bulk-Power System,
caused by damage to critical or vulnerable Bulk-Power System equipment, or otherwise,
will not occur as a result of a GMD.”10 Although the Commission does not propose to
require specific solutions, the Phase II Reliability Standards would require the plans to
include “strategies for protecting against the potential impact of GMDs.”11

B. Summary of the Joint ISOs/RTOs Comments

The Joint ISOs/RTOs generally support the Commission’s multi-phased approach to address the vulnerabilities regarding GMD. To facilitate the development and implementation of the Phase I and Phase II Reliability Standards in a manner that achieve the intended reliability benefits, however, the Joint ISOs/RTOs offer the comments set forth in Section III, below.

To summarize, the Joint ISOs/RTOs’ comments request that the Commission, in a
Final Rule in this proceeding, direct NERC to develop GMD Reliability Standards that:

Account for the applicability of existing Reliability Standards to the issues
raised by GMDs before developing new GMD requirements to avoid the
potential for duplicative requirements that provide no incremental reliability
benefit.

Achieve Adequate Level of Reliability by affording the relevant functional
entities the authority and discretion to develop the Phase I operational
procedures that meet the needs of their respective systems, and the flexibility

9 NOPR at P 23.

10 NOPR at P 23.

11 NOPR at P 23.

necessary to determine the Phase II plans, solutions or means that are adequate and necessary to address the risks identified in the GMD vulnerability assessments.

Consistent with NERC construct, define regional scope and responsibilities in
the same terms as functional entities and areas and equipment as existing
reliability operational and equipment protection requirements. For example,
requirements for the Phase II primary assessments and mitigation plans
associated with Bulk-Power System equipment should be the responsibility of
equipment owners and Bulk-Power System as a whole assessments and
mitigation should be assigned to other appropriate functional entities - e.g.,
Transmission Operator.

In addition, with respect to the Phase I procedures, the Commission should clarify
that the relevant functional entities - and not NERC - should have the authority and
discretion to develop the Phase I procedures, as they have the detailed knowledge and
information necessary to understand potential GMD impacts and to develop the
appropriate operational procedures. However, NERC can play a valuable role that is
consistent with the NOPR’s approach12 by developing non-binding best practices
reference document based on existing operational procedures, inter alia, and a non-
exclusive illustrative list of considerations to guide the development of Phase I
procedures. Regarding Phase I, the Commission should also clarify the relationship
between NERC’s reporting requirement and NERC’s role in reviewing the functional
entities procedures. With respect to Phase II, the Commission should clarify certain
aspects of the assessment parameters.

Finally, the Commission’s Final Rule should allow a year for the Phase I and II
Reliability Standard development to be completed, and direct NERC to develop an

12 That is, not to dictate specific procedures or solutions, but to provide guidance and examples that support their development. See NOPR at PP 17-18, 26, 34.

implementation timeframe that accounts for the coordination between functional entities and prioritizes implementation schedules based on degrees of impacts.

II.COMMENTS

A.NERC Should be Required to Consider Existing Standards Prior to

the Development of GMD Reliability Standards to Avoid the Potential for Duplicative Requirements

Existing NERC Reliability Standards establish a comprehensive set of Bulk-
Power System operational and equipment protection requirements that may address the
concerns with the impact of GMD events on the reliable operation of the Bulk-Power
System. Among the Commission’s concerns with the impacts of GMDs, for example, is
the potential for GICs introduced by GMDs to cause voltage instability due to increased
reactive power (“VAr”) consumption and loss of VAr support.13 Because GMD raises
voltage concerns, existing NERC Reliability Standards like Voltage and Reactive
Control, VAR-001-2 R2,14 should be examined first to see if they can be used and/or
modified rather than create a new standard to address GMD VAr control. Accordingly,
the Joint ISOs/RTOs request that the Commission direct NERC to first consider the
applicability of existing Reliability Standards (e.g., Voltage and Reactive Control15) to

13 See NOPR at P 25.

14 The Voltage and Reactive Control Standard requires each Transmission Operator to acquire sufficient reactive resources - which may include, but are not limited to, reactive generation scheduling, transmission line and reactive resource switching, and controllable load - within its area to protect the voltage levels under normal and contingency conditions. This includes the Transmission Operator’s share of the reactive requirements of interconnecting transmission circuits.

15 Existing Reliability Standards and procedures associated with restoration are another example. The NOPR states that “the proposed Reliability Standards should also address operational procedures for restoring GMD impacted portions of the Bulk-Power System that take into account the potential for equipment that is damaged or out-of-service for an extended period of time.” See NOPR at P 20. It is unclear how restoration procedures for GMD impacts would differ from restoration procedures that are already in place for existing exposure. Thus, existing restoration requirements and/or procedures should be examined before new requirements and/or procedures are developed.

the issues raised by GMDs before developing new GMD requirements. Such an analysis would avoid the potential for duplicative and/or redundant obligations that provide no incremental reliability benefit.

B.Phase I Comments

1.The Phase I Reliability Standards Should Provide for Procedures

That Are Consistent With an Adequate Level of Reliability, Which May Differ by Region.

In Phase I, the Commission proposes to require NERC to develop Reliability Standards that would have “owners and operators” develop operating procedures to mitigate the effects of GMDs.

Any procedures developed should be required to support an Adequate Level of
Reliability to be consistent with the reliability goals of Section 215 of the Federal Power
Act.16 However, it is notable that the need for, and the effectiveness of, the operational
procedures that would be required by the proposed Phase I Reliability Standards will
depend on the geographic location of the system and the structural make-up of the grid
(e.g. type, location and operational characteristics of the Bulk-Power System equipment
and load characteristics). The owners and operators of the Bulk-Power System have the
detailed knowledge and information necessary to understand potential GMD impacts and
to develop procedures to address them.17 Accordingly, in order to achieve the intended

16 See 16 U.S.C. § 824(o)(c)1 (“Section 215”).

17 As the Technical Conference Comments stated, significant progress has been made since the blackout in
Quebec in 1989. See Technical Conference Comments at pp 3-4. GMD procedures already exist and are
being utilized in PJM, ISO-NE, MISO and NYISO. See id. For example, because the Hudson Valley is
particularly vulnerable to GMDs due to its geological composition, NYISO has been involved in GMD
operational protocols for over 30 years. NYISO has incorporated guidance provided by NPCC operating
procedures designed to protect its system against GMD and continuously monitors ground currents at
susceptible facilities. Since adopting these procedures, NYISO has not experienced a significant
disturbance caused by GICs. NYISO Transmission and Dispatching Operations Manual, Section 4.2.11,

(continued...)

reliability benefits, the owners and operators should have authority and discretion under
the Phase I Reliability Standards to develop the required operational procedures. This
approach is consistent with the Commission’s proposal and would facilitate more
immediate development of Phase I procedures, as they would allow functional entities
with varied topology and structure to more easily develop and garner industry-wide
support for the GMD Reliability Standards proposed for development in Phase I.18

2. The Relevant Functional Entities - and Not NERC - Should Have

Authority and Discretion to Develop the Phase I Procedures

The NOPR appears to provide NERC a direct role in the development of
functional entities’ operational plans and procedures. More specifically, the NOPR at P

19 provides:

The Commission expects that the ERO and owners and operators of the Bulk-Power System will draw on industry’s experience in developing and implementing existing operational procedures.

This appears to set an expectation that NERC, as the ERO, will have a direct role in the
development and implementation of functional entities operational plans and procedures
to address GMD and to ensure compliance with any GMD-related reliability standards.

As stated above, it is the owners and operators of the Bulk-Power System that
have the detailed knowledge and information necessary to understand potential GMD
impacts and to develop the appropriate procedures to address them. The insertion of a
third-party with governmental authority and oversight into each functional entities’

internal process and procedure planning and development will inhibit, rather than

________________________

(...continued)

SolarMagneticDisturbances,availableat:

http://www.nyiso.com/public/webdocs/markets_operations/documents/Manuals%20and%20Guides/Manua
ls/Operations/trans_disp.pdf.

18 See NOPR at PP 18 and 19.

enhance, such development for a number of reasons, e.g., the time and resources that
would be necessary to educate the ERO on each transmission system, its topology,
equipment, etc. and the potential difficulties and conflicts that could occur where the
ERO and a functional entity disagree on the rigor of proposed plans and procedures. In
order to achieve the intended reliability benefits within the intended time frame, the
owners and operators should have authority and discretion under the Phase I Reliability
Standards to develop the required operational procedures. Accordingly, the Joint
ISOs/RTOs respectfully request that the Commission provide such clarification in its
Final Rule.

3.NERC Should Develop a Non-Binding Best Practices Reference

Document to Support the Development of Phase I Operating

Procedures

As discussed above, the relevant functional entities should have the authority and
discretion to develop Phase I operational procedures that meet the needs of their
respective systems. However, NERC can play a valuable role in supporting the
development of the operational procedures by maintaining a non-binding best practices
reference guide that can be used by the functional entities in developing their procedures.
As noted by the Commission, the NERC Interim GMD Report19 already provides
examples of operational procedures for this purpose.20 In addition, the NOPR notes that
some areas already have GMD operating procedures in place. Collectively, these, as well
as any other relevant information and procedures, could serve as the basis for such a
reference document, which would be similar to a NERC Guideline, which is intended to

19 See North American Electric Reliability Corp., 2012 Special Reliability Assessment Interim Report:
Effects of Geomagnetic Disturbances on the Bulk Power System (February 2012 (“NERC Interim GMD
Report”), available at http://www.nerc.com/files/2012GMD.pdf.

20 See NOPR at P 19.

provide guidance on a particular topic for use by Bulk-Power System users, owners, or operators and are not intended to provide binding norms, to create reliability standards, or to create parameters by which compliance to standards is enforced. This could provide significant value to the functional entities and would facilitate the more immediate development of Phase I operational procedures by functional entities.21

4. NERC Should Define the Regional Scope and Responsibility for

the Phase I Reliability Standard(s) Procedures in the Same Terms of Functional Entities and Their Respective Areas and/or Equipment as Existing Reliability Operational and Equipment Protection Requirements

The NOPR discusses assigning the obligations under the proposed GMD
Reliability Standards in terms of owners and operators of the Bulk-Power System. Under
the NERC construct, owners and operators are assigned responsibility based on their
functional status.22 As discussed above, existing NERC Reliability Standards establish a
comprehensive set of Bulk-Power System requirements based on functional entity and/or
traditionally defined coordination areas and footprints, e.g., reliability coordination area,
balancing authority area, etc. Accordingly, the Commission should clarify that any
additional operational procedures defined by NERC for the Phase I Reliability Standards
should ensure that the responsibilities assigned therein are consistent with existing NERC
Reliability Standards in terms of the role of each of these entities.23

21 The NOPR supports this approach and distinction between the substantive and informational support roles of the functional entities and NERC, respectively. See NOPR at P 20:

While the proposed Reliability Standards should not necessarily specify what operational
procedures must be adopted, the ERO should give owners and operators of the Bulk-
Power System guidance as to what procedures have been or are expected to be effective
in mitigating the effects of GMDs consistent with the reliable operation of the Bulk-
Power System.

23 For purposes of GMD Reliability Standards, the key reliability functional entities from an operational
perspective may include: Reliability Coordinator (“RC”), Balancing Authority (“BA”), Transmission
Operator (“TOP”) and Generator Operator (“GOP”) functions. From a planning perspective, the standards

(continued...)

More specifically, the scope of the area operational procedures should be defined
in terms of functional entity equipment for the relevant functional entity equipment
owners - e.g. TOs/GOs/GOPs - and by functional area for the relevant operational
functional entities - e.g. RCs, TOPs and BAs. The relevant functional areas are the
logical areas for developing and applying GMD mitigation procedures. Presumably,
current Reliability Standards requirements and the traditional approach utilized in
existing Reliability Standards would be considered, but given that the NOPR discusses
responsibilities in terms of owners and operators generally, the Commission should
provide clarification in this regard to avoid the potential that the applicable area for
procedures developed pursuant to the Phase I Standards be defined in a different manner.

Applying the above concepts, with respect to Phase I procedures and Phase II
assessments and plans, responsibility should align with function - equipment owners
should be responsible for procedures, assessments and plans for their equipment, and
functional operational entities should be responsible for procedures/assessments and
plans for their functional areas, with appropriate coordination with equipment owners and
any other relevant functional entities (e.g., TOPs and BAs within an RC area may

coordinate their procedures/assessments/plans with the RC in the development of its
plan). For example, for equipment procedures, each generator owner and operator could
be tasked with developing procedures for their generation equipment, and could
coordinate as necessary given the common interests. The same could apply to TOs and

________________________

(...continued)

may include: Planning Authority (“PA”), Planning Coordinator (“PC”) and Transmission Planner (“TP”). With respect to the Bulk-Power System, the standards may include: Transmission Owners (“TO”) and Generation Owners (“GO”).

TOPs for transmission equipment. With respect to operational procedures, RCs, TOPs and BAs could develop procedures for their respective areas.

Finally, any necessary coordination should also be appropriately scoped and defined. For example, the existing Reliability Standards often have a maximum functional area limit such as a reliability coordination area or a balancing authority coordination area. These also represent a logical limit to the boundaries for the application of the operational procedures for GMD mitigation. Nonetheless, it is important to note that areas that are not synchronously connected should not be required to coordinate, because there is no risk of cross-regional GMD impacts if areas are only connected by asynchronous DC tie connections.

Related to the issue of assigning responsibility to the appropriate functional entity, at footnote 48 in the NOPR, the Commission states the Phase II assessments should consider the impact to the Bulk-Power System from GMD effects on non-Bulk Power System facilities. Non-Bulk Power System equipment interconnects with Bulk-Power System at distinct interfaces that are comprised of the non-Bulk-Power System equipment and specific Bulk-Power System equipment. The assessment responsibility of the impact of non-Bulk-Power System facilities to the Bulk-Power System should lie with the functional entities that own and operate the Bulk-Power System equipment that interconnects with the non-Bulk-Power System equipment. These entities are in the best position to assess that operational relationship.

In all cases, the requirements for the Phase I Reliability Standards - whether for
individual operating procedures or plans or for plans or procedures addressing

coordination -should harmonize and be consistent with the existing Reliability Standards and their existing equipment protection and other requirements.

5. NERC Should Establish a Non-Exclusive Illustrative List of

Considerations to Guide the Development of Phase I Standard Operating Procedures

Given the potential impact to equipment, the NOPR states that:

the proposed Reliability Standards should also address operational procedures for restoring GMD impacted portions of the Bulk-Power System that take into account the potential for equipment that is damaged or out-of-service for an extended period of time.24

The Standards should not mandate any particular procedures or considerations regarding
system restoration because they may not be relevant depending on the regional
conditions. Requiring implementation and/or consideration of inapplicable procedures or
inputs/considerations into the development of procedures may undermine the
effectiveness of the procedures and would not provide any benefit to overall Bulk-Power
System reliability.

6. NERC Should Establish a Phase I Standard Implementation

Timeframe that Accounts for the Relationship Between the
Operational Procedures Developed by the Different Functional
Entities

The NOPR does not mandate a particular implementation timeline for the Phase I
Reliability Standards, but does recommend 90 days after Commission approval.25

Although expeditious development of the Phase I Reliability Standard procedures is
desirable, 90 days is ambitious given the potential need to coordinate between multiple
entities. In other contexts, the Commission has allowed a year for the NERC standards
drafting process to promulgate and submit a standard. As the Technical Conference

24 NOPR at P 20.

25 NOPR at P 21.

Comments indicate, there is a great deal of data on GICs, geological variations, and differing regional system needs that should be considered in creating NERC Reliability Standards in this area. The Phase I Standards will also serve as the foundation for Phase II. Accordingly, the Commission should allow a year for the Phase I and Phase II Reliability Standards development to be completed, and direct NERC to develop the implementation timeline once it has a better idea of the degree of coordination that will be needed between the different functional entities.

In establishing the implementation timeframes, the coordination procedures and related implementation timeline should account for the sequential nature of the responsibilities related to the development of the procedures. For example, if the RC Area procedures require inputs based on other functional entity procedures, the standards would have to account for that in setting compliance timelines. Setting a general single period - e.g. six months - may prove unworkable if the operational procedure inputs to the RC Area procedures take 5 months to develop. In that example, the RC would have to wait for the procedures of the other relevant functional entities, which would put it in the untenable position of having to develop its procedures in 1 month especially given the stakeholder process requirements of some organizations.

7. The Commission Should Clarify the Relationship of the NERC

Reporting Requirements for Phase I Reliability Standard Procedure Effectiveness and NERC’s Role in Reviewing the Functional Entity Procedures

The NOPR proposes that, after implementation of the Phase I Reliability
Standards, NERC would be required to provide periodic reports on the effectiveness of

the operational procedures.26 In addition, NERC would be required to periodically review the procedures and make recommendations to the relevant functional entities that they incorporate lessons-learned and new research findings.27

As an initial matter, it is unclear how these reports and reviews relate to Phase II.
Specifically, Phase II appears to require a more thorough assessment of GMD
issues/impacts. Based on those assessments, entities are required to develop plans to
manage GMD impacts “so that instability, uncontrolled separation, or cascading failures
of the Bulk-Power System, caused by damage to critical or vulnerable Bulk-Power
System equipment, or otherwise, will not occur as a result of a GMD.” These plans will
include operational procedures, among other things. Presumably, given the more
thorough analysis in Phase II, the Phase II operating procedures would replace the Phase
I procedures, which appear to be more of a temporary means to achieve some degree of
GMD mitigation in the more immediate timeframe pending compliance with Phase II. If
that is the case, it is not clear that the Phase I reporting and effectiveness review provide
any value.

Assuming the Phase I operating procedures are different than the Phase II plans
and, therefore, the Phase I reports and effectiveness reviews proposed in the NOPR have
merit, absent experiencing actual GMD events, it is unclear how the effectiveness will be
measured. If an event does occur, the functional entities are in the best position to assess
the effectiveness of their GMD mitigating measures.28 Accordingly, to the extent NERC

26 See NOPR at P 21.

27 NOPR at P 21.

28 As discussed in Section III.C.1, below, the effectiveness of GMD mitigating measures can be determined
through the installation of monitoring equipment. Monitoring equipment should be recognized as
(continued...)

provides the periodic reports described in the NOPR, they should be based on assessments provided by the relevant functional entities. Similarly, the functional entities are in the best position to review their procedures and assess the value of incorporating best practices/lessons learned and/or new research findings. Finally, it is notable that, since effectiveness can only be reviewed and assessed following a GMD occurrence or event, NERC has already established an event analysis program, through which it could perform any necessary reviews and assessments.

8. NERC Should Coordinate the Initial Actions Proposed in the

NOPR with the Phase II Equipment Assessments

Simultaneous with the development and implementation of the Phase I Reliability Standards, the Commission is proposing to require NERC to identify facilities most atrisk from GMD and to conduct wide-area GMD assessments. The Commission notes certain characteristics that would scope these activities - i.e., critical transformers (e.g., step-up transformers at large generating facilities) and Bulk-Power System facilities that serve critical and priority loads.

These actions appear similar to the requirements in the Phase II Standards, which require Bulk-Power System equipment and system assessments, and it is likely that NERC will rely on information from the entities that will be performing the Phase II assessments. Thus, practically speaking, the relevant functional entities will likely be required to begin performing the Phase II assessments before the standards are in place, and they will be doing that analysis at the same time they are focused on complying with the Phase I Reliability Standards.

________________________

(...continued)

providing a mechanism to measure the effectiveness of mitigating plans, and as an acceptable solution to second stage needs assessments.

As such, the Commission should ensure that any such overlap of responsibilities
is coordinated and does not undermine the effectiveness of the proposed phased process.
Granted, the results from this analysis could be used in Phase II, but effectively requiring
it during Phase I may distract necessary resources from Phase I compliance, thereby
defeating the intent of the phased approach to GMD mitigation. At a minimum, the
results of this analysis should be complementary to the Phase II equipment and system
assessments to ensure the actions are coordinated and do not overlap or conflict with
Phase II tasks.

C.Phase II Comments

1.The Phase II Reliability Standards Should Provide for Plans that

Are Consistent With an Adequate Level of Reliability

The proposed Phase II Reliability Standards would require the relevant owners and operators to conduct assessments of GMD impacts on the Bulk-Power System equipment and on the Bulk-Power System as a whole.29 Based on those assessments, they would develop a plan “so that instability, uncontrolled separation, or cascading failures of the Bulk-Power System, caused by damage to critical or vulnerable BulkPower System equipment, or otherwise, will not occur as a result of a GMD.”30 The NOPR, however, states that “the plan cannot be limited to operational procedures or enhanced training alone, but should, subject to the needs identified in the assessments,” protect equipment from the effects of GMDs.31

29 See NOPR at P 23.

30 NOPR at P 23.

31 NOPR at P 23. The NOPR does not propose any specific solutions, but references different approaches
to equipment protection. See NOPR at PP 23, 34. The means noted included automatically blocking geo-
magnetically induced currents from entering the Bulk-Power System, instituting specification requirements

(continued...)

The Phase II Reliability Standards should be results-based and should establish a non-exclusive means of being compliant. They should not mandate a plan or solution to protect equipment because such measures may not be relevant or applicable given regional conditions or the results of the GMD vulnerability assessments. While some Phase II assessments may demonstrate the need for costly measures, others may show that significant GMDs are so infrequent in nature and pose fewer risks such that operational protocols may be adequate and necessary measures. Accordingly, the Phase II Reliability Standards should afford functional entities the flexibility necessary to determine the plans, solutions or means that are adequate and necessary to address the risks identified in the GMD vulnerability assessments.

In a similar vein, the Commission should clarify that the use of automatic
protection measures, such as automatic blocking devices, is not a required solution under
the proposed Phase II Reliability Standards. As the NOPR states, “some assessments will
demonstrate that automatic blocking is necessary in some instances.”32 Likewise, some
assessments may show that the risks are so minimal that only operational protocols are
warranted. The needs assessments should inform whether measures are needed and, to
the extent they are, which measures are adequate and necessary to protect against the
risks identified.

For example, a GMD vulnerability assessment may indicate that an Adequate
Level of Reliability could be achieved through the installation of monitoring equipment.

Monitoring equipment is a key component to achieving a comprehensive and effective

________________________

(...continued)

for new equipment, inventory management, and isolating certain equipment that is not cost effective to
retrofit.

32 NOPR at P 34.

program to mitigate GMD risks on the Bulk-Power System and, according to the NERC Interim Report:

Monitors are a key source of real-time information that can guide system
operators in determining real-time response. The monitors can also
provide valuable historical records of previous storm activity that can be
evaluated and factored into power system planning and analysis.33

Because the NERC Interim Report recommends monitoring equipment to arm system operators with information that can help them assess imminent transformer impacts due to GICs and take appropriate actions to prevent damage to equipment and a system blackout, it is important to recognize that the installation of such equipment and associated measures may be an appropriate solution depending upon the results of an entity’s of a GMD assessment.34

Accordingly, the Joint ISOs/RTOs request that the Commission clarify the
requirements of the Phase II Reliability Standards to recognize that these standards
should: (1) focus on the criteria for the GMD assessments, provided that the scope of
criteria must remain flexible to enable functional entities to apply all relevant criteria
regardless of whether they are established in the standards; (2) provide that the results of
the GMD assessments should dictate the identified solutions; and, (3) be designed with
the intent of achieving an Adequate Level of Reliability, which, depending on the results
of the GMD assessments, may not require development and implementation of plans or
solutions to protect equipment.

33 NERC GMD Interim Report at p 71.

34 Id.

2.NERC Should Define the Scope and Responsibility for the Phase II

Procedures in the Same Terms of Functional Entities and Their Respective Areas and/or Equipment as Existing Reliability Operational and Equipment Protection Requirements.

The Phase II proposal, as described above, creates two distinct tasks - one for Bulk-Power System equipment assessment and GMD mitigation and one for Bulk-Power System as a whole assessment and mitigation. As explained earlier, under the NERC construct, owners and operators are assigned responsibility based on their functional status. Accordingly, as with the Phase I Reliability Standards, the Phase II Reliability Standards should be clear in assigning the assessment responsibilities.

By way of example, Bulk-Power System equipment is generally under the
purview of the equipment owners. Because the Commission makes clear in the NOPR
that the final Reliability Standard must contain “uniform evaluation criteria”, see P28,
equipment owners are capable of assessing possible negative impacts on Bulk-Power
System equipment. Hence, it would follow that requirements for the primary assessment
and mitigation plans associated with Bulk Power System equipment should be the
responsibility of the equipment owners and Bulk-Power System as a whole assessment
and mitigation should be assigned to other appropriate functional entities - e.g. TOP.

More specifically, with respect to the system assessment, although the details will
be developed in the Standards development process, similar to the Phase I scope and
coordination, it is logical to define scope in terms of existing functional entities’
requirements and functional areas, and to require coordination between the relevant
functional entities in the same manner as discussed above - e.g. equipment owner

assessment and mitigation plans could be inputs into BA and TOP assessments and plans,
which could then be inputs into the RC assessment and plans. Consistent with the Phase

I comments, it is reasonable to cap the Phase II assessments in terms of area scope based
on RC Areas. The relevant existing, functional areas are the logical areas for developing
and applying GMD standards and requirements. Presumably, current Reliability
standards requirements and the traditional approach utilized in existing Reliability
Standards would continue to be considered, but the Commission should provide
clarification in this regard to avoid the potential that the applicable area for procedures
developed pursuant to the Phase II Standards be defined in a different manner and result
in inconsistent or duplicative responsibilities when coupled with existing Reliability
Standards and requirements.

3. The Commission Should Clarify Certain Aspects of the Proposed

Parameters that Should be Considered in the Phase II Standard Development Process

In the NOPR, the Commission proposes to require NERC to consider specific parameters in the Phase II Standards development process. Specifically, in Paragraphs 28 to 32, the NOPR proposes the following parameters:

1. Uniform evaluation criteria for owners and operators to follow when
conducting their assessments;

2. Assessments should evaluate the primary and secondary effects of GICs on
Bulk-Power System transformers, including the effects of GICs originating
from and passing to other regions;

3. Assessments should evaluate the effects of GICs on other Bulk-Power System
equipment, system operations, and system stability, including the anticipated
loss of critical or vulnerable devices or elements resulting from GIC-related
issues;

4. Wide-area or Regional assessments of GIC impacts should be performed in
conjunction with assessments by owners and operators of their own Bulk-
Power System components;

5. Assessments should be periodically updated, taking into account new
facilities, modifications to existing facilities, and new information, including
new research on GMDs, to determine whether there are resulting changes in

GMD impacts that require modifications to Bulk-Power System mitigation schemes.

The proposal to establish uniform assessment criteria will facilitate the
effectiveness of the resulting procedures and plans, and the proposed criteria are
reasonable. However, the list should not be exhaustive, nor should entities be required to
act on the basis of each parameter if their reviews/assessments show no reliability
impacts. As discussed above, GMD impacts will vary between regions based on several
factors. Accordingly, while a uniform set of parameters may assist entities in conducting
analyses and provide a base for reliability analyses, they should be considered factors
rather than separate requirements, and entities should have the discretion to consider any
and all parameters that are relevant for their particular characteristics that define their
systems. For this same reason, assessment of a particular parameter may not result in an
actionable issue. In those circumstances, entities should not be required to develop plans
to address that parameter - a determination of no impact should be acceptable.

With respect to the second and third parameters, without commenting on the proposed substance, similar to prior comments, the responsibility for the proposed assessment parameter should lie with the equipment owner when equipment related, and with the relevant functional entity when related to Bulk-Power System operation. Again, there should be appropriate coordination between assessments as necessary.

With respect to the fourth parameter, it is reasonable to expect that the relevant functional entities would engage in an iterative process that would allow for coordination of their respective assessments, ultimately leading to a wide-area assessment.

Finally, the fifth parameter would require periodic assessments. This is
reasonable and advisable, but it appears to overlap with the proposal in Phase I to require

NERC to do periodic reviews of entities GMD mitigation procedures. As discussed in relation to that aspect of the NOPR, the relevant functional entities are best suited to review and assess their plans and procedures, which is what appears to be contemplated by the fifth recommended parameter. The Commission should clarify that the functional entities should perform these reviews, and should reconcile this with the Phase I proposal to have NERC perform periodic reviews. The Joint ISOs/RTOs believe the proposed NERC reviews are likely unnecessary because they will be redundant with these reviews, the functional entities are better situated to perform these assessments, which could then be provided to NERC for their input, and, in the event that a GMD occurrence or event occurred, the NERC event analysis program is already established and could be utilized to evaluate the plans and procedures utilized to respond.

4. The Commission Should Allow Sufficient Time for Establishing

Phase II Reliability Standards and Prioritize the Implementation Schedule Based on Degrees of Impact

In the NOPR, the Commission proposes to require NERC to submit Phase II
Reliability Standards within six months of the date of a Final Rule. As with the Phase I
Standards, although speedy development of the Phase II Reliability Standard procedures
is desirable, six months is ambitious given the potential need to coordinate between
multiple entities. In other contexts, the Commission has allowed a year for the NERC
standards drafting process to promulgate and submit a standard. As the Technical
Conference Comments state, there is a great deal of data on GICs, geological variations,
and differing regional system needs that should be considered in creating NERC
standards in this area. Moreover, Phase II Reliability Standards need to be built upon
completed Phase I Standards, and allowing only three months between the Phase I and
Phase II standards will not allow sufficient time for the NERC Standards development

process to address all of the Phase II issues adequately. Accordingly, the Commission
should allow a year for the Standards development process for both phases to be
completed, and direct NERC to develop the implementation timeline once it has a better
idea of the degree of coordination that will be needed between the different functional
entities.

In the NOPR, the Commission also proposes an implementation schedule that prioritizes implementation based on relative impacts to the reliable operation of the BulkPower System in order to provide equipment that presents greater risk with necessary protection measures as soon as possible. This proposal is logical and should facilitate appropriate focusing of resources in the most efficient and effective manner.

The implementation schedule also should allow for the completion of GMD vulnerability assessments before requiring owners and operators of the Bulk-Power System to develop solutions. This will ensure that solutions are adequate and necessary to mitigate the risks identified in the needs assessments.

III.CONCLUSION

The Joint ISOs/RTOs respectfully request that the Commission formulate the
Final Rule in this proceeding in a manner consistent with the comments submitted herein.

Respectfully submitted,

/s/ Nancy Saracino
Nancy Saracino
General Counsel

Anthony Ivancovich

Deputy General Counsel, Regulatory* Anna McKenna

Assistant General Counsel, Regulatory

California Independent System Operator Corporation

151 Blue Ravine Road Folsom, California 95630 amckenna@caiso.com

/s/ Matthew Morais

Matthew Morais*

Assistant General Counsel

Electric Reliability Council of Texas, Inc.

2705 West Lake Drive
Taylor, Texas 76574
mmorais@ercot.com

/s/ Theodore J. Paradise

Raymond W. Hepper

Vice President, General Counsel, and Secretary

Theodore J. Paradise*

Assistant General Counsel, Operations and Planning

ISO New England Inc.

One Sullivan Road

Holyoke, Massachusetts 01040 tparadise@iso-ne.com

/s/ Stephen G. Kozey

Stephen G. Kozey*

Vice President, General Counsel, and Secretary

Midwest Independent Transmission System Operator, Inc.

P.O. Box 4202

Carmel, Indiana 46082-4202 skozey@midwestiso.org

Dated: December 21, 2012

/s/ Carl F. Patka

Carl F. Patka*

Assistant General Counsel Raymond Stalter

Director of Regulatory Affairs

New York Independent System Operator, Inc.

10 Krey Blvd

Rensselaer, New York 12144 cpatka@nyiso.com

_/s/Diana Pommen

Diana D. Pommen, MBA*

Director Interjurisdictional Affairs and Compliance

Alberta Electric System Operator

2500, 330 - 5th Avenue SW Calgary, AB T2P 0L4

diana.pommen@aeso.ca

/s/ Paul Suskie

Paul Suskie*

Senior Vice President, Regulatory Policy and General Counsel

Southwest Power Pool, Inc.

415 North McKinley, Suite 140 Little Rock, Arkansas 72205 psuskie@spp.org

/s/Brian Rivard

Brian Rivard*

Manager - Regulatory Affairs& Sector Policy Analysis

Ontario’s Independent Electricity System Operator

655 Bay Street, Suite 410 Toronto, Ontario M5G 2K4 brian.rivard@ieso.ca