Monitoring System Conditions - Transmission Operations Reliability Standard

Transmission Operations Reliability Standards Interconnection Reliability Operations and

Coordination Reliability Standards

)Docket No. RM13-12-000
)

)Docket No. RM13-14-000

)Docket No. RM13-15-000
)

COMMENTS OF THE ISO/RTO COUNCIL IN SUPPORT OF

MOTION OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
TO DEFER ACTION

Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission1 (the “Commission”), the ISO/RTO Council (“IRC”) submits these comments in support of the Motion of the North American Electric Reliability Corporation (“NERC”) to Defer Action (the “Motion”).

I.IDENTIFICATION OF FILING PARTY

The IRC is comprised of the Alberta Electric System Operator (“AESO”); California
Independent System Operator Corporation (“CAISO”); Electric Reliability Council of Texas, Inc. (“ERCOT”); the Independent Electricity System Operator (“IESO”); ISO New England Inc. (“ISO-NE”); Midcontinent Independent System Operator, Inc. (“MISO”); New York
Independent System Operator, Inc. (“NYISO”); PJM Interconnection, L.L.C. (“PJM”); and
Southwest Power Pool, Inc. (“SPP”).2

1 18 C.F.R § 385.213 (2013).

2 AESO and IESO are not FERC-jurisdictional and AESO is not joining for jurisdictional reasons. However, IESO is joining in support of these comments.

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II.COMMENTS

The NERC Motion requests the Commission to delay action in the Notice of Proposed

Rulemaking issued in the referenced dockets on November 21, 2013 (the “NOPR”).3 In the

NOPR, the Commission raised a concern that NERC has “removed critical reliability aspects that are included in the currently-effective standards without adequately addressing these aspects in the proposed standards.”4

The NERC Motion requests the delay of action in order to give NERC the opportunity to
hold two technical conferences and concurrently, to work with the NERC Standards Committee
to re-formulate a standard drafting team to prepare revisions (informed by the technical
conferences) to the proposed standards at issue in the NOPR. The IRC believes this is a prudent
course of action, and supports the process proposed in the NERC Motion.5
The TOP and IRO standards apply to two critical reliability functions - the Reliability Coordinator and Transmission Operator functions, which, with limited exceptions, IRC members perform. The IRC believes the NERC proposal, which utilizes proposed technical conferences and the standards development process, will facilitate a thorough review of the relevant issues by providing opportunities for input from all interested parties, including NERC and the
Commission. Technical conferences and the standards development process are established
means that allow opportunity for both formal and informal participation and comment.
Accordingly, the IRC respectfully submits that the NERC proposal is a reasonable and judicious

3 Monitoring System Conditions- Transmission Operations Reliability Standard Transmission Operations Reliability
Standards Interconnection Reliability Operations and Coordination Reliability Standards, 145 FERC ¶ 61,158
(2013).

4 NOPR at P 4.

5 These comments take no position on 1) the merits of the proposed standards; 2) the related concerns raised by the Commission in the NOPR; or 3) the proposed agenda for the technical conferences provided in Attachment A of the NERC Motion.

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means to facilitate the development of effective and efficient revisions to the relevant standard groups and achieve industry consensus.

III.CONCLUSION

For the foregoing reasons, the IRC respectfully requests that the Commission grant the

NERC Motion.

Respectfully submitted,

/s/ Matthew Morais/s/Theodore J. Paradise

Matthew MoraisRaymond W. Hepper

Director, Federal PolicyVice President, General Counsel, and Secretary

Electric Reliability Council of Texas, Inc.Theodore J. Paradise

2705 West Lake DriveAssistant General Counsel - Operations and

Taylor, Texas 76574Planning

ISO New England Inc.

One Sullivan Road

Holyoke, MA 01040-2841

/s/ Stephen G. Kozey/s/ Paul Suskie

Stephen G. KozeyPaul Suskie

Vice President, General Counsel, Legal &Sr. VP - Regulatory Policy and General Counsel

Compliance Services.Southwest Power Pool, Inc.

Midcontinent Independent System201 Worthen Drive

Operator, Inc.Little Rock, AR 72223

P.O. Box 4202

Carmel, Indiana 46082-4202

/s/ Anna McKenna/s/ Carl F. Patka

Nancy SaracinoCarl F. Patka

General CounselAssistant General Counsel

Roger CollantonRaymond Stalter

Deputy General CounselDirector, Regulatory Affairs

Anna A. McKennaNew York Independent System Operator,

Assistant General Counsel-RegulatoryInc.

California Independent System Operator10 Krey Boulevard

CorporationRensselaer, New York 12144

250 Outcropping Way

Folsom, California 95630

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/s/ Craig Glazer/s/ Jessica Savage

Craig GlazerJessica Savage

Vice President - Federal Government PolicyManager, Government and Regulatory Affairs

Robert EckenrodIndependent Electricity System Operator

Senior CounselStation A, Box 4474

PJM Interconnection, LLCToronto, Ontario M5W 4E5

1200 G Street, N.W., Suite 600 Washington, D.C. 20005

Dated: January 6, 2014

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