UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Remedial Action Schemes)

Reliability Standard)Docket No. RM16-20-000

JOINT COMMENTS OF NEW YORK INDEPENDENT SYSTEM OPERATOR,

INDEPENDENT ELECTRICITY SYSTEM OPERATOR, ISO NEW ENGLAND, INC., AND ELECTRIC RELIABILITY COUNCIL OF TEXAS, INC. IN RESPONSE TO
NOTICE OF PROPOSED RULEMAKING

The New York Independent System Operator, ISO New England Inc., Independent
Electric System Operator, and Electric Reliability Council of Texas, Inc. (together, the ISOs)
respectfully submit these joint comments in response to the Notice of Proposed Rulemaking
issued by the Commission in the referenced docket on January 19, 2017, proposing approval of Reliability Standard PRC-012-2 - Remedial Action Schemes.1  The ISOs support PRC-012 as drafted, and the Commission’s proposal to approve the proposed Reliability Standard.  The ISOs provide these comments to address certain of the Commission’s questions concerning “limited impact” Remedial Action Schemes (“RAS”).

First, as explained below, the ISOs agree that PRC-012-2, as drafted, does not supersede or modify system performance requirements of TPL-001-4.  Second, the ISOs do not believe that it is necessary at this time to include a definition of “limited impact RAS” in the NERC Glossary of Terms Used in NERC Reliability Standards.

1 See Remedial Action Schemes Reliability Standard, 158 FERC ¶ 61,042 (2017), 82 Fed. Reg. 9702 (Feb. 8, 2017) (“NOPR).

I.The ISOs agree that PRC-012-2, as drafted, does not supersede or modify

system performance requirements of TPL-001-4.

In the NOPR, the Commission proposes to clarify that proposed Reliability Standard

PRC-012-2 will not modify or supersede any system performance obligations under Reliability
Standard TPL-001-4.  The Commission seeks comment on this proposal.2
The ISOs agree that  PRC-012-2 does not supersede or modify the system performance requirements of TPL-001-4 because, under TPL-001-4, responsible entities assume that all RAS operate correctly3 and they are required to ensure that non-consequential load loss be less than 75 MW when a RAS operates.4  Thus, neither PRC-012-2 nor a “limited impact” RAS designation affects the system performance requirements of TPL-001-4, including the performance
requirement that Non-Consequential Load Loss may not exceed 75 MW for certain Category P1,
P2, or P3 contingencies.  For this reason, no clarification to the standard is necessary.  However,
if the Commission determines that some clarification may be helpful, the Commission may wish
to confirm in the final rule on PRC-012-2 that, under TPL-001-4, responsible entities can assume
that all RAS operate as designed.

Notably, as the Commission states, PRC-012-2 supplements TPL-001-4 and “enhances
reliability by addressing all aspects of RAS in a single, continent-wide Reliability Standard and
by assigning specific RAS responsibilities to appropriate functional entities.”5  With respect to
limited impact RAS, PRC-012-2 affirms that a “RAS designated as limited impact cannot, by

2 NOPR at P 16.

3 See TPL-001-4, Table 1 - Steady State & Stability Performance Planning Events, P5 “Delayed Fault Clearing due to the failure of a non-redundant relay protecting the Faulted element to operate as designed…” and Footnote 13 “Applies to the following relay functions or types: pilot (#85), distance (#21), differential (#87), current (#50, 51, and 67), voltage (#27 & 59), directional (#32, & 67), and tripping (#86, & 94).”

4 See TPL-001-4, Footnote 12.

5 NOPR at 15.

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inadvertent operation or failure to operate, cause or contribute to BES Cascading, uncontrolled
separation, angular instability, voltage instability, voltage collapse, or unacceptably damped
oscillations.”6  The design and implementation requirements imposed on limited action RAS—
including exemption from the single component malfunction analysis otherwise mandated for
RAS by PRC-012-2 Requirement 4.1.4—are commensurate with the lesser risk they pose to the
BES.  In addition, in New England, retrofitting existing limited impact RASs to make them fully
redundant would add unnecessary costs to the system without a commensurate increase in
system reliability.  Further, as described in greater detail in NERC’s Comments on the NOPR,
additional regional controls are in place for evaluation of Type III RAS and Local Area
Protection Schemes (“LAPS”).  The ISOs believe that, combined, these existing regional
processes and PRC-012-2 provide an appropriate level of oversight for RAS, including limited
impact RAS.

II.The ISOs do not believe it is necessary to include a definition of “limited

impact RAS” in the NERC Glossary of Terms Used in NERC Reliability

Standards.

In the NOPR, the Commission requests comment on whether the term “limited impact
RAS” should be defined in the NERC Glossary of Terms Used in NERC Reliability Standards
(“NERC Glossary”).7  The ISOs do not believe a Glossary Revision is necessary at this time.
“Limited impact RAS” does not appear elsewhere as a defined term in other Reliability
Standards; thus, the additional utility of a NERC Glossary definition is minimal.    The
performance criteria described in PRC-012-2, Requirement 4.1.3, Footnote 1 provide an

6 PRC-012-2, Requirement 4.1.3, Footnote 1.

7 NOPR at P 17.

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adequate level of guidance to fulfill the Planning Coordinator and Reliability Coordinator obligations associated with limited action RAS.

III.Conclusion

The ISOs respectfully request that the Commission consider its comments on proposed

Reliability Standard PRC-012-2. Respectfully submitted,

/s/ Margoth R. Caley

Raymond W. Hepper

Vice President, General Counsel and Corporate Secretary

Theodore J. Paradise

Assistant General Counsel - Operations and Planning

Margoth R. Caley

Senior Regulatory Counsel

ISO New England Inc.

One Sullivan Road

Holyoke, MA 01040-2841 mcaley@iso-ne.com

/s/ Nathan Bigbee

Chad. V. Seely

Vice President and General Counsel Nathan Bigbee

Assistant General Counsel

Electric Reliability Council of Texas, Inc.

7620 Metro Center Blvd. Austin, TX  78744

nathan.bigbee@ercot.com

4

/s/ Christopher R. Sharp

Robert E. Fernandez, General Counsel Raymond Stalter

Director of Regulatory Affairs Carl F. Patka

Assistant General Counsel Christopher R. Sharp

Senior Compliance Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard Rensselaer, NY  12144 csharp@nyiso.com

/s/ Tam Wagner

Tam Wagner

Senior Manager, Regulatory Affairs

Independent Electricity System Operator

1600-120 Adelaide Street West Toronto Ontario  M5H1T1

Canada

Tam.wagner@ieso.ca