UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Reliability Standard for Geomagnetic)Docket No.RM14-1-000

Disturbance Operations)

COMMENTS OF THE ISO/RTO COUNCIL

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
supporting comments in response to the Notice of Proposed Rulemaking issued by the
Commission in the referenced docket on January 16, 2014, proposing approval of Reliability
Standard EOP-010-1 (Geomagnetic Disturbance Operations) (the “NOPR”).2
The proposed reliability standard is designed to mitigate the effects of geomagnetic disturbances (“GMDs”) on the Bulk-Power System by requiring responsible entities to
implement Operating Plans and Operating Procedures or Processes.3 The Commission also
proposes to approve the associated violation risk factors and violation severity levels,
implementation plan, and effective dates proposed by the North American Electric Reliability
Corporation (“NERC”).4

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,

1 18 C.F.R. § 385.213 (2013).

2 See Reliability Standard for Geomagnetic Disturbance Operations, 146 FERC ¶ 61,015 (2014), 79 Fed. Reg. 3547 (January 22, 2014).

3 NOPR at P 1.
4 Id.

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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”).5

II.COMMENTS

The IRC supports the Commission’s proposal to approve the proposed GMD standard as submitted by NERC. With respect to the scope of the applicability of the proposed standard, the IRC believes that for the First Stage GMD Reliability Standards, the Reliability Coordinator (“RC”) and the Transmission Operator (“TOP”) are the appropriate reliability functions to which the standard should apply. As the Commission notes in the NOPR, the RC has the wide-area view and, accordingly, operational oversight of the relevant RC area.

Coordinating GMD plans and related operational responses across RC areas makes sense
in terms of regional management of these circumstances in an effective and efficient manner by
aligning with a wide area, but also ensuring that area aligns with the overarching operational
reliability function under the standards - i.e., the RC function. This captures the operational
realities and efficiencies established under the NERC reliability functions and standards. Any
regional coordination that did not align with the NERC reliability functions and standards would
potentially require redefining relationships and roles, or establishing new ones, which would be
ineffective and inefficient.

In terms of obligations, the proposed standard strikes a reasonable balance between
establishing appropriate structures and interactions/relationships, and provides the requisite
flexibility necessary to allow subject entities to develop their respective plans and procedures

5 AESO and IESO are not FERC-jurisdictional. AESO does not join in these comments.

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based on their particular circumstances. As the Commission correctly notes, the impact of GMD
events can differ due to regional differences, both in terms of externalities, such as geology, and
in terms of system topology and structure. Accordingly, any GMD rule must accommodate such
distinctions by ensuring that entities have adequate flexibility to develop plans and procedures
that best meet their respective needs and circumstances. Thus, similar to the general rule for
NERC standards, the GMD standard should focus on the “what,” leaving the “how” to the
functional entities.

The proposed standard is reasonable in terms of both the scope of applicability and the
substantive and procedural obligations. Accordingly, the IRC supports the Commission’s
proposal to approve the proposed standard as filed by NERC, and looks forward to working with the Commission, NERC and other interested entities in developing the Second Stage GMD
Reliability Standard(s).

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III.CONCLUSION

The IRC respectfully requests that the Commission proceed in a manner consistent with

the comments submitted herein.6

Respectfully submitted,

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

Matthew MoraisRaymond W. Hepper

Director, Federal PolicyVice President, General

Electric Reliability Council of Texas, Inc.Counsel, and Secretary

7620 Metro Center DriveTheodore J. Paradise

Austin, Texas 78744Assistant General Counsel - Operations and

Planning

Margoth R. Caley
Regulatory Counsel

ISO New England Inc.

One Sullivan Road

Holyoke, MA 01040-2841

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

Stephen G. KozeyPaul Suskie

Senior Vice-President, Legal andExecutive Vice President, Regulatory Policy and

Compliance Services, General Counsel andGeneral Counsel

SecretarySouthwest Power Pool, Inc.

Midcontinent Independent System201 Worthen Drive

Operator, Inc.Little Rock, AR 72223

P.O. Box 4202

Carmel, Indiana 46082-4202

6 Due to the need for final coordination among multiple ISOs/RTOs on these comments, the comments are filed just after the close of business. The IRC respectfully moves for leave to file these comments out of time, given that no party will be prejudiced thereby.

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

Roger E. CollantonCarl F. Patka

General CounselAssistant General Counsel

Anna A. McKennaRaymond Stalter

Assistant General Counsel-RegulatoryDirector, Regulatory Affairs

California Independent System OperatorNew York Independent System Operator,

CorporationInc.

250 Outcropping Way10 Krey Boulevard

Folsom, California 95630Rensselaer, New York 12144

/s/ Craig Glazer/s/ Jessica Savage

Craig GlazerJessica Savage

Vice President - Federal Government PolicySupervisor, 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: March 24, 2014

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