UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Grid Resilience in Regional Transmission)Docket No. AD18-7-000

Organizations and Independent System Operators)

COMMENTS OF CALIFORNIA INDEPENDENT SYSTEM OPERATOR

CORPORATION, ISO NEW ENGLAND INC., MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC., NEW YORK INDEPENDENT SYSTEM OPERATOR,
INC., AND SOUTHWEST POWER POOL, INC.

The California Independent System Operator Corporation (“CAISO”), ISO New England
Inc. (“ISO-NE”), Midcontinent Independent  System Operator, Inc. (“MISO”), New York

Independent System Operator, Inc. (“NYISO”), and Southwest Power Pool, Inc. (“SPP”) (“Joint
Commenters”) respectfully submit this limited reply to the Comments and Responses of PJM
Interconnection,  L.L.C. (“PJM”), filed  with  the Federal Energy  Regulatory  Commission

(“Commission”) on March 9, 2018.1  In response to questions posed by the Commission in the
January 8, 2018 Order Terminating Rulemaking Proceeding, Initiating New Proceeding, and
Establishing Additional Procedures  in the captioned proceeding,2  PJM  requests that the
Commission  require  all  Regional  Transmission  Organizations (“RTOs”)  and  Independent

System Operators (“ISOs”) to undertake a series of actions, many of which are based on initiatives or reforms PJM is pursuing to address issues it faces.

In this reply, the Joint Commenters respectfully request that the Commission decline to
impose the PJM-identified proposals on other regions.3  As fully discussed below, the record in
this proceeding does not support any universal resilience standard or tariff changes requirements

1 Grid Resilience in Regional Transmission Organizations and Independent System Operators, Comments and
Responses of PJM Interconnection, L.L.C., Docket No. AD18-7-000 (March 9, 2018) (“PJM Response”).

2 Grid Resilience in Regional Transmission Organizations and Independent System Operators, 162 FERC ¶ 61,012 (2018) (“Resilience Order”).

3 The individual RTOs/ISOs joining in these comments may also file separate reply comments in this proceeding.

to be applied to all RTOs/ISOs.  To the contrary, the record demonstrates that RTOs/ISOs have
different resilience issues and priorities, and requiring all RTOs/ISOs to follow PJM’s proposed
schedule on the issues pertinent to PJM will undermine each RTO/ISO’s efforts to address the
specific challenges within its region.  Thus, the Commission should reject PJM’s requests and
allow individual RTOs/ISOs to pursue the resilience-related issues and initiatives they have
identified in their region through collaborative efforts with their stakeholders and pursuant to the
timeframes they have established.  Joint Commenters take no position on PJM’s requested relief
insofar as it relates solely to specific circumstances presented within PJM’s region.

I.BACKGROUND

In the Resilience Order, the Commission terminated a rulemaking initiated by the United
States Department of Energy’s Proposed Rule on Grid Reliability and Resilience Pricing,4 and
established the instant proceeding to examine the resilience of the bulk power system in
RTO/ISO regions.  The Commission sought to comprehensively examine the bulk power
system’s resilience with the goals of developing a common definition of resilience, better
understanding how each RTO/ISO assesses resilience in its region, and evaluating whether
further Commission action regarding resilience is necessary.5  To those ends, the Commission
posed  specific questions to the  RTOs/ISOs  seeking  information  on how each RTO/ISO
understands resilience, assesses resilience in its respective region, and mitigates resilience risks.6

4 Grid Resilience Pricing Rule, 82 Fed. Reg. 46,940 (Oct. 10, 2017).

5 See Resilience Order at P 19 (explaining, “[w]e recognize that the RTOs/ISOs are well-suited to understand the
needs of their respective regions and initially assess how they address resilience given their individual geographic
needs.”).

6 Id. at P 23 (noting that the Commission understands resilience to mean “[t]he ability to withstand and reduce the
magnitude and/or duration of disruptive events, which includes the capability to anticipate, absorb, adapt to, and/or
rapidly recovery from such an event.”).  See id. at P 19 (emphasizing, “[t]he efforts of RTOs and ISOs on grid
resilience encompass a range of activities, including wholesale electric market design, transmission planning,
mandatory reliability standards, emergency action plan development, inventory management, and routine system
maintenance.”).

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On March 9, 2018, each RTO/ISO filed its response to the Resilience Order.7  The responses focused on how each respective RTO/ISO currently assesses and supports resilience of the bulk power system within its footprint, the specific or unique challenges facing its region, and the path forward within its region to address potential challenges to resilience.

Each RTO/ISO’s response identified the steps it has undertaken in planning, markets, and
operations to support the reliability and resilience of the bulk power system in its region.  The
responses make clear the prevalence and strong influence of regional differences in assessing and
addressing  resilience given, among other things, differences in  various factors, such  as
geography, resource mix, fuel supply options, and environmental requirements.  Although not all
RTOs/ISOs identified immediate or imminent resilience concerns in their regions, each identified
specific potential improvements intended to enhance resilience within their respective region.
The potential improvements identified by each RTO/ISO and their ongoing evaluation thereof
reflect each region’s specific needs, circumstances, and conditions.  The responses also described
the ongoing initiatives or future efforts within each region to further pursue these potential
enhancements.

Despite the unique circumstances and conditions facing each region, PJM’s Response
requests in several instances that the Commission direct all RTOs/ISOs to undertake certain

7 See Grid Resilience in Regional Transmission Organizations and Independent System Operators, Comments of the
California Independent System in Response to the Commission’s Request for Comments About System Resiliency
and Threats to Resilience, Docket No. AD18-7-000 (March 9, 2018) (“CAISO Response”); Grid Resilience in
Regional Transmission Organizations and Independent System Operators, Response of ISO New England Inc.,
Docket No. AD18-7-000 (March 9, 2018) (“ISO-NE Response”); Grid Resilience in Regional Transmission
Organizations and Independent System Operators, Responses of the Midcontinent Independent System Operator,
Inc., Docket No. AD18-7-000 (March 9, 2018) (“MISO Response”); Grid Resilience in Regional Transmission
Organizations and Independent System Operators, Response of the New York Independent System Operator, Inc.,
Docket No. AD18-7-000 (March 9, 2018) (“NYISO Response”); Grid Resilience in Regional Transmission
Organizations and Independent System Operators, Comments of Southwest Power Pool, Inc., Docket No. AD18-7-
000 (March 9, 2018) (“SPP Response”).

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reforms based on efforts PJM is actively pursuing to address issues specific to its region.8  For example, PJM requests that the Commission take the following action:

Requests that all RTOs (and jurisdictional transmission providers in non-RTO
regions) submit a subsequent filing, including any necessary proposed tariff
amendments,  for  any  proposed  market  reforms  and  related  compensation
mechanism to address resilience concerns within nine to twelve months from
issuance of a Final Order in this docket.  PJM, together with its stakeholders, is
already actively evaluating such potential reforms that advance operational
characteristics that support reliability and resilience, including (i) improvements
to its Operating Reserve market rules and to shortage pricing, (ii) improvements
to its Black Start requirements, (iii) improvements to energy price formation that
properly value resources based upon their reliability and resilience attributes, and
(iv) integration of distributed energy resources (“DERs”), storage, and other

emerging technologies.  A deadline for submission of market rule reforms that the RTO feels would assist with the resilience efforts would help ensure focus on these issues in the stakeholder process.

The PJM Response similarly requests that the Commission establish a deadline (9-12 months)
for all ISOs and RTOs (as well as all transmission providers in non-RTO regions) to (1) submit
filings, including any necessary tariff amendments, to implement resilience planning criteria and
processes, and (2) file any necessary rule changes to improve cross-industry coordination,
planning, restoration activities, and market mechanisms.9  The Joint Commenters address these
requests in this reply.

II.COMMENTS.

The  Commission  Should  Not  Impose  on Other  RTOs/ISOs  the  Actions  and Deadlines Specified in PJM’s Response

The Commission should not impose on other RTOs/ISOs the specific actions and
deadlines PJM requests, many of which are based on reforms PJM  is pursuing to address issues
specific to its region.  The record in this proceeding is comprehensive and reflects the unique
resilience issues and initiatives that vary from region to region.  The Commission should

8 See PJM Response at 5-8, 65-66, 68.

9 See id. at 5-8, 65-66.

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continue to recognize regional differences that exist among RTO/ISO wholesale market structures, tariffs, and governance structures.  If the Commission chooses to impose any obligations or deadlines as a result of PJM’s requests, the Joint Commenters request the Commission only apply those obligations to PJM.

Consistent with the expectations and requirements of the Resilience Order, each of the
RTOs/ISOs has identified unique resilience challenges that exist in their respective regions given
the specific circumstances and conditions in their regions, such as differences in geography,
resource mix, fuel supply, environmental requirements, and how each approaches and mitigates
these challenges.10  The considerations and approaches reflected in the responses are different
even with respect to threats that potentially affect all regions, such as weather-related events and
fuel supply.

Although challenges presented by ongoing changes to the resource mix and fuel supply
potentially affect all regions, the actual and expected resource mix, the specific risks presented,
the urgency and magnitude of the impact, and the potential solutions to address such risks vastly
differ among the regions.  For example, as detailed in ISO-NE’s response, New England’s
continuing industry trends of replacing coal-fired, oil-fired, and nuclear generation with natural
gas-fuel and renewable resources that rely on non-firm or inherently intermittent fuel have

10 See CAISO Response at 10-11 (identifying naturally occurring risks, such as earthquakes, drought, and changing
weather conditions (cloud cover, solar eclipse) as the primary challenges to the resilience of the CAISO bulk power
system); ISO-NE Response at 4-5 (identifying fuel security as the most significant risk to the resilience of New
England’s bulk power system); MISO Response at 2-3 (noting, “MISO does not have any imminent or immediate
resilience concerns,” but identifying three areas were improvements can be made relative to the experiences in its
region - information technology tools, transmission planning, and inter-regional operations); NYISO Response at
28-33 (identifying ongoing initiatives and future efforts in response to the ongoing transformation of the electric
system that is occurring in New York); SPP Response at 4 (identifying extreme weather, such as tornados and
drought, as primary resilience risks).

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heightened the region’s fuel-security risk,11 which ISO-NE’s response identifies as the most
significant and imminent risk to the resilience of New England’s bulk power system.12  MISO,
like ISO-NE, is also experiencing an influx of natural gas-fired resources; however, such
increases do not present the same risks as in New England, where fuel-infrastructure and dual-
fuel capability are limited.  As MISO’s response indicated, while reliance on gas-fired generation
has grown significantly in recent years, because of MISO’s geographic scope and position,
natural gas supply infrastructure disruptions are low-probability risks.13  The NYISO is also
experiencing ongoing changes to the resource mix in New York, including increasing reliance on
natural gas-fired generation, increasing levels of renewable resources, and increasing deployment
of distributed energy resources.  The NYISO’s current fuel-security risks, as its response
explained, are “mitigated by the strong presence of dual-fuel capability throughout the State’s
current natural gas-fired generation fleet, and diversity of natural gas pipelines and LDC systems
that serve the generators.”14  The NYISO, however, recognized the need to continue to evaluate
potential fuel-security concerns on an ongoing basis.15  The NYISO also noted the challenges
and opportunities presented by the ongoing transformation of New York’s electric system and
identified a series of initiatives it is already pursuing with its stakeholders in response thereto.16

Further, the CAISO and SPP identified naturally-occurring weather events as the primary
risks to resilience within their footprints, but their paths forward differ.  The CAISO footprint
“faces natural threats primarily from earthquakes, drought, and fires, not hurricanes or extreme

11 ISO-NE refers to fuel-security risk is  the possibility that the region’s generating fleet will not have, or be able to obtain, the fuel they need to produce the energy required to meet system demand and maintain required reserves during expended periods of cold winter weather.

12 See id. at 6-8.

13 See MISO Response at 13.

14 NYISO Response at 25.

15 Id. at 31-32

16 Id. at 28-33.

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cold conditions like other regions.”17  As the CAISO explained, CAISO-specific planning
standards and operational measures already enable the CAISO to assess and prepare for extreme
events.18  For example, the CAISO has adopted specific regional planning standards that permit
it, inter alia, to identify and approve reliability solutions that go beyond NERC- and WECC-
established requirements19 (e.g., to mitigate the risk of extreme events in the San Francisco
Peninsula and potentially other areas on the grid and to mitigate NERC TPL-001-4 standard P1-
P7 contingencies in high density urban load areas in lieu of allowing non-consequential load
dropping).  Given its geographical footprint, SPP’s response also identified severe weather
events, such as tornados (which can destroy significant portions of the bulk power system),
drought, and ice storms, as the primary impacts to the region’s bulk power system resilience.20
SPP currently evaluates these extreme events through planning assessments.  However, SPP
identified, inter alia, clear resilience-supporting cost recovery and cost allocation mechanisms to
ensure sufficient funding for identified transmission needs to support the robustness of the
system in order to mitigate these resilience risks as an area where more work needs to be done in
its region.21

As the Resilience Order recognized,22 and the responses show, resilience challenges
differ in each RTO/ISO-operated region, given significant regional differences.  RTOs/ISOs
must be afforded the flexibility to prioritize, in collaboration with their respective region’s

17 CAISO Response at 5, 10-11.

18 See id. at 13-14 (describing, the efforts CAISO undertakes to understand risks associated with these types of

extreme events, such as regularly communicating and coordinating with third parties with expertise in these areas,
such as the “experts at the US Geological Survey regarding earthquake risks,” “weather agencies regarding potential
El Nino, La Nina, and weather-related matters,” and “the California Department of Forestry and Fire Protection”
regarding “expected fire dangers as California’s fire season approaches and during the season itself.); id. at 14, 27
(describing, CAISO planning and operational efforts to assess and prepare for the impacts of extreme events).

19 See id. at 23-24, 46-47.

20 See SPP Response at 4, 12.

21 See id. at 12-13, 14.

22 Resilience Order at P 25-26.

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stakeholders, their own efforts, and identify the solutions that are needed to maintain reliability
and resilience based on their specific circumstances and conditions.  PJM’s request for the
Commission to impose selected reforms and arbitrary deadlines on all RTOs/ISOs fails to
account for differences in the nature and scope of any concerns among the regions.  The request
also fails to account for unique regional governance structures, stakeholder concerns, and
decision-making dynamics that must be respected in order to develop broadly supported
proposals  within  each  region  and  minimize  otherwise  avoidable  litigation  before  the
Commission.  As a result of these differences, the priorities and solutions PJM has identified as
appropriate for its region might not be appropriate or necessary to resolve problems in another
region.  A Commission directive to all RTOs/ISOs imposing deadlines to address the PJM-
identified proposals could thwart or frustrate progress made, or divert resources from further
progress, in addressing a region’s specific needs.

Accordingly, if the Commission chooses to impose any obligations as a result of PJM’s
requests, the Joint Commenters request the Commission apply those obligations only to PJM,
and allow for other RTOs/ISOs to continue working through the governance processes within
their respective regions on resolving the resilience challenges they face within timeframes that
account for the complexities of the challenges and the potential solutions to address them.

III.CONCLUSION

WHEREFORE, for the reasons set forth above, the Joint Commenters respectfully request that the Commission take these comments into consideration and not impose the actions or deadlines identified in the PJM Response on all RTOs/ISOs, given regional differences and the unique circumstances and conditions facing each region.

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Respectfully submitted,

/s/ Anthony J. Ivancovich/s/ Garrett E. Bissell

Roger E. CollantonRobert E. Fernandez, General Counsel

General CounselRaymond Stalter, Director, Regulatory Affairs

Anthony J. IvancovichGarrett E. Bissell, Senior Attorney

Deputy General CounselNew York Independent System Operator,

Anna McKennaInc.

Assistant General Counsel10 Krey Boulevard

Andrew UlmerRensselaer, New York 12144

Director, Federal Regulatory AffairsEmail:  gbissell@nyiso.com

California Independent System Operator Corporation

250 Outcropping Way
Folsom, CA 95630
Tel: (916) 608-7135
Fax: (916) 608-7222

Email: aivancovich@caiso.com

/s/ Raymond W. Hepper/s/ Joseph W. Ghormley

Raymond W. HepperPaul Suskie

Vice President, General Counsel, and SecretaryExecutive Vice President,

Monica GonzalezRegulatory Policy &

Senior Regulatory CounselGeneral Counsel

ISO New England Inc.Joseph W. Ghormley

One Sullivan RoadSenior Attorney

Holyoke, Massachusetts 01040Southwest Power Pool, Inc.

Tel:  (413) 535-4000201 Worthen Drive

Fax:  (413) 535-4379Little Rock, AR 72223

Email:  mgonzalez@iso-ne.comPhone: (501) 614-3200

Fax: (501) 482-2022

Email:  psuskie@spp.org

jghormley@spp.org

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/s/ Jonathan J. Tauber

Andre T. Porter

Vice President and General Counsel Jonathan J. Tauber

Managing Senior Corporate Counsel Midcontinent Independent

System Operator, Inc.
720 City Center Drive
Carmel, IN 46032
Phone: (317) 249-5200

Email:  aporter@misoenergy.org
jtauber@misoenergy.org

Dated:  May 8, 2018

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CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Holyoke, Massachusetts this 8th day of May, 2018.

/s/ Julie Horgan

Julie Horgan

eTariff Coordinator

ISO New England Inc.
One Sullivan Road
Holyoke, MA 01040
(413) 540-4683

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