NERC Petition

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
EOP-010-1 – GEOMAGNETIC DISTURBANCE OPERATIONS
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
Stacey Tyrewala
Senior Counsel
Brady Walker
Associate Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation
November 14, 2013

TABLE OF CONTENTS
I. 

EXECUTIVE SUMMARY .................................................................................................... 2 

II.  NOTICES AND COMMUNICATIONS ................................................................................ 4 
III.  BACKGROUND .................................................................................................................... 4 
A. 

Regulatory Framework ..................................................................................................... 4 

B. 

NERC Reliability Standards Development Process ......................................................... 5 

C. 

Technical Background: Geomagnetic Disturbances ....................................................... 6 

D. 

History of Project 2013-03, Geomagnetic Disturbance Mitigation ................................. 7 

IV.  JUSTIFICATION FOR APPROVAL .................................................................................... 8 
A. 

Applicability of EOP-010-1 – Geomagnetic Disturbance Operations ............................. 8 

B. 

Requirements in EOP-010-1 – Geomagnetic Disturbance Operations .......................... 10 

C. 

Commission Directives Addressed ................................................................................ 15 

D. 

Enforceability of EOP-010-1 ......................................................................................... 16 

V.  CONCLUSION ..................................................................................................................... 17 

Exhibit A

Proposed Reliability Standard, EOP-010-1 –Geomagnetic Disturbance Operations

Exhibit B

Implementation Plan for EOP-010-1

Exhibit C

Order No. 672 Criteria for EOP-010-1

Exhibit D

White Paper Supporting Network Applicability of EOP-010-1

Exhibit E

White Paper Supporting Functional Entity Applicability of EOP-010-1

Exhibit F

Analysis of Violation Risk Factors and Violation Security Levels

Exhibit G

Analysis of Commission Directives

Exhibit H

Summary of Development History and Complete Record of Development

Exhibit I

Standard Drafting Team Roster for Project 2013-03, Geomagnetic Disturbance
Mitigation

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
EOP-010-1 – GEOMAGNETIC DISTURBANCE OPERATIONS
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”)3 hereby submits proposed Reliability
Standard EOP-010-1 for Commission approval. NERC requests that the Commission approve
proposed Reliability Standard EOP-010-1 (Exhibit A) and find that the proposed Reliability
Standard is just, reasonable, not unduly discriminatory or preferential, and in the public interest.4
NERC also requests approval of the associated implementation plan (Exhibit B), Violation Risk
Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibit F), as detailed in this
petition.
As required by Section 39.5(a)5 of the Commission’s regulations, this petition presents
the technical basis and purpose of proposed Reliability Standard EOP-010-1, a demonstration
that the proposed Reliability Standard meets the criteria identified by the Commission in Order

1

16 U.S.C. § 824o (2006).
18 C.F.R. § 39.5 (2013).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006) (“ERO
Certification Order”).
4
Unless otherwise designated, all capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards, available at http://www.nerc.com/files/Glossary_of_Terms.pdf.
5
18 C.F.R. § 39.5(a) (2013).
2

1

No. 6726 (Exhibit C) and a summary of the development history (Exhibit H). Proposed
Reliability Standard EOP-010-1 was approved by the NERC Board of Trustees on November 7,
2013.
I.

EXECUTIVE SUMMARY
Geomagnetic disturbances (“GMD”) occur when solar storms on the sun’s surface send

electrically charged particles toward earth, where they interact with the earth’s magnetic
field. Proposed Reliability Standard EOP-010-1—Geomagnetic Disturbance Operations would
be a new Reliability Standard that attempts to mitigate the effects of GMD events by
implementing Operating Plans,7 Operating Processes,8 and Operating Procedures9 and is
responsive to Commission concerns in Order No. 779.10
In Order No. 779, the Commission directed the development of Reliability Standards to
address GMDs in two stages.11 In the first stage, the subject of this petition, NERC is submitting
proposed Reliability Standard EOP-010-1, requiring owners and operators of the Bulk-Power
System to develop and implement Operational Procedures to mitigate the effects of GMDs
6

The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, at P 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).
7
An “Operating Plan” is defined in the Glossary of Terms Used in NERC Reliability Standards as “A
document that identifies a group of activities that may be used to achieve some goal. An Operating Plan may contain
Operating Procedures and Operating Processes. A company-specific system restoration plan that includes an
Operating Procedure for black-starting units, Operating Processes for communicating restoration progress with other
entities, etc., is an example of an Operating Plan.” Available at http://www.nerc.com/files/Glossary_of_Terms.pdf
8
The term “Operating Procedure” is defined in the Glossary of Terms Used in NERC Reliability Standards
as “A document that identifies specific steps or tasks that should be taken by one or more specific operating
positions to achieve specific operating goal(s). The steps in an Operating Procedure should be followed in the order
in which they are presented, and should be performed by the position(s) identified. A document that lists the specific
steps for a system operator to take in removing a specific transmission line from service is an example of an
Operating Procedure.” Available at http://www.nerc.com/files/Glossary_of_Terms.pdf
9
The term “Operating Process” is defined in the Glossary of Terms Used in NERC Reliability Standards as
“A document that identifies general steps for achieving a generic operating goal. An Operating Process includes
steps with options that may be selected depending upon Real-time conditions. A guideline for controlling high
voltage is an example of an Operating Process.” Available at http://www.nerc.com/files/Glossary_of_Terms.pdf
10
Reliability Standards for Geomagnetic Disturbances, Order No. 779, 143 FERC ¶ 61,147 (2013)(“Order
No. 779”).
11
Id.

2

consistent with the reliable operation of the Bulk-Power System. The second stage of Reliability
Standards to address GMDs, currently under development, requires NERC to develop proposed
Reliability Standards that require owners and operators of the Bulk-Power System to conduct
initial and on-going vulnerability assessments of the potential impact of benchmark GMD events
on Bulk-Power System equipment and the Bulk-Power System as a whole.12
During a severe GMD event, geomagnetically-induced current (“GIC”) flow in
transformers (resulting in half-cycle saturation) can substantially increase absorption of reactive
power, create harmonics, and, in some cases, cause transformer hot-spot heating, which could
lead to loss of Reactive Power support-- thereby causing voltage instability, protective relay
Misoperations and potential equipment loss-of-life or damage. As a high-impact, low-frequency
event, GMDs pose a unique threat to Bulk-Power System reliability, and the proposed Reliability
Standard is intended to lessen the impact of such events.
As the Commission noted in Order No. 779, “[o]perational procedures may help alleviate
abnormal system conditions due to transformer absorption of reactive power during GMD
events, helping to stabilize system voltage swings, and may potentially isolate some equipment
from being damaged or misoperated.”13 The proposed Reliability Standard allows entities to
tailor their Operating Plans, Processes and Procedures based on the responsible entity’s
assessment of entity-specific factors, such as geography, geology, and system topology. The
coordination of the Operating Plans, Processes and Procedures would be overseen by the
Reliability Coordinator, consistent with its wide-area perspective.
The proposed Reliability Standard is an important first step in addressing the issue of
GMDs and can be implemented relatively quickly. While responsible entities will develop and
12

See Order No. 779 at P 54. The Second Stage GMD Reliability Standard must identify what severity GMD
events (i.e., benchmark GMD events) that responsible entities will have to assess for potential impacts on the BulkPower System.
13
Id. at P 36.

3

implement Operational Procedures or Operational Processes, NERC will continue to support
those efforts through the GMD Task Force, for example, by identifying and sharing Operating
Plans, Processes, and Procedures found to be the most effective.
NERC requests that the Commission approve proposed Reliability Standard EOP-010-1
and find that the proposed Reliability Standard is just, reasonable, not unduly discriminatory or
preferential, and in the public interest.
II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the

following:14
Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Assistant General Counsel
Stacey Tyrewala*
Senior Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
III.

Mark G. Lauby*
Vice President and Director of Standards
Laura Hussey*
Director of Standards Development
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
[email protected]
[email protected]

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005,15 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power
System, and with the duties of certifying an ERO that would be charged with developing and
14

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2013), to allow the inclusion
of more than two persons on the service list in this proceeding.
15
16 U.S.C. § 824o (2006).

4

enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)16
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
States will be subject to Commission-approved Reliability Standards. Section 215(d)(5)17 of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability
Standard. Section 39.5(a)18 of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes should become
mandatory and enforceable in the United States, and each modification to a Reliability Standard
that the ERO proposes should be made effective.
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA19 and Section 39.5(c)20 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the
content of a Reliability Standard.
B.

NERC Reliability Standards Development Process

The proposed Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process.21 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards

16

Id. § 824(b)(1).
Id. § 824o(d)(5).
18
18 C.F.R. § 39.5(a) (2012).
19
16 U.S.C. § 824o(d)(2).
20
18 C.F.R. § 39.5(c)(1).
21
Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
17

5

Development) of its Rules of Procedure and the NERC Standard Processes Manual.22 In its ERO
Certification Order, the Commission found that NERC’s proposed rules provide for reasonable
notice and opportunity for public comment, due process, openness, and a balance of interests in
developing Reliability Standards and thus satisfies certain of the criteria for approving Reliability
Standards.23 The development process is open to any person or entity with a legitimate interest
in the reliability of the Bulk-Power System. NERC considers the comments of all stakeholders,
and a vote of stakeholders and the NERC Board of Trustees is required to approve a Reliability
Standard before the Reliability Standard is submitted to the Commission for approval.
C.

Technical Background: Geomagnetic Disturbances

A GMD is caused by solar events resulting in distortions of the earth’s magnetic field,
and can be of varying intensity. The science regarding the impacts of GMDs on electric power
systems is still in the developmental stages and much remains to be learned about the unique
threat GMDs pose to reliability. The characteristics of GMDs (e.g., the peak and duration of
induced geo-electric fields) experienced by the power system is dependent on a number of
factors, including where the geomagnetic storm is centered, the direction of the fields along with
their polarity, geomagnetic latitude, and the geology (electrical conductivity of the ground). As
the Commission noted in Order No. 779, “while there is an ongoing debate as to how a severe
GMD event will most likely impact the Bulk-Power System, there is a general consensus that
GMD events can cause wide-spread blackouts due to voltage instability and subsequent voltage
collapse, thus disrupting the reliable operation of the Bulk-Power System.”24

22

The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.
23
116 FERC ¶ 61,062 at P 250 (2006).
24
Order No. 779 at P 24 (internal citation omitted).

6

D.

History of Project 2013-03, Geomagnetic Disturbance Mitigation

In June 2010, NERC identified that GMDs were a serious threat to the reliable operation
of the Bulk-Power System and that this issue required significant staff and industry attention
with close monitoring of progress. Since that time, NERC has spent a substantial amount of time
and effort working with experts across the North American power industry, U.S. and Canadian
government agencies, transformer manufacturers, and other vendors, in developing scientifically
sound and repeatable conclusions.
In early 2011, a NERC-sponsored GMD Task Force was formed to “develop a technical
white paper describing the evaluation of scenarios of potential GMD impacts, identifying key
bulk power system parameters under those scenario conditions, and evaluating potential
reliability implications of these incidents.”25 The resulting report, the NERC Interim GMD
Report evaluating the effects of GMDs on the Bulk-Power System, was issued in February
2012.26
In October 2012, the Commission issued a Notice of Proposed Rulemaking (“NOPR”)
proposing to direct that NERC submit to the Commission for approval proposed Reliability
Standards that address the risks posed by GMDs to the reliable operation of the Bulk-Power
System.27 The NOPR stated that GMD vulnerabilities are not adequately addressed in the
existing Reliability Standards and that this constitutes a reliability gap because GMD events can
cause the Bulk-Power System to collapse suddenly and can potentially damage equipment on the

25

NERC, Board of Trustees Minutes, Exhibit J, at 1 (Nov. 4, 2010), available at
http://www.nerc.com/docs/docs/bot/BOT-1110m-open-complete.pdf.
26
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.
27
Reliability Standards for Geomagnetic Disturbances, Notice of Proposed Rulemaking, 77 FR 64,935 (Oct.
24, 2012), 141 FERC ¶ 61,045 (2012) (“NOPR”).

7

Bulk-Power System.28 In May 2013, the Commission issued Order No. 779 directing NERC to
develop proposed Reliability Standards addressing GMD events in two stages, as explained
herein.
IV.

JUSTIFICATION FOR APPROVAL
As discussed in detail in Exhibit C, proposed Reliability Standard EOP-010-1--

Geomagnetic Disturbance Operations satisfies the Commission’s criteria in Order No. 672 and is
just, reasonable, not unduly discriminatory or preferential, and in the public interest. The
purpose of proposed Reliability Standard EOP-010-1 is to mitigate the reliability impacts of
GMD events by implementing Operating Plans, Processes, and Procedures. Provided below is
an explanation of the applicability of the proposed Reliability Standard and a justification on a
Requirement-by-Requirement basis.
A.

Applicability of EOP-010-1 – Geomagnetic Disturbance Operations

The proposed Reliability Standard is applicable to: (1) Transmission Operators with a
Transmission Operator Area that includes a power transformer with a high side wye-grounded
winding with terminal voltage greater than 200 kV, and (2) Reliability Coordinators.29 This
applicability is consistent with Order No. 779 and the NERC Functional Model.
As the Commission noted in Order No. 779, “[b]ecause many Bulk-Power System
transformers are grounded, the GIC appears as electrical current to the Bulk-Power System and
flows through the ground connection and conductors, such as transformers and transmission
lines.”30 The applicability of proposed Reliability Standard EOP-010-1 recognizes the technical
considerations of the impact of a GMD on the Bulk-Power System.

28

Id. at P 4.
A power transformer with a “high side wye-grounded winding” refers to a power transformer with
windings on the high voltage side that are connected in a wye configuration and have a grounded neutral connection.
30
Order No. 779 at P 6 citing North American Electric Reliability Corp., 2012 Special Reliability Assessment
29

8

The NERC Functional Model is structured to ensure that there are no gaps or overlaps in
the performance of operation Tasks in the operating timeframe anywhere in the Bulk Electric
System.31 A Reliability Coordinator has responsibility and authority for reliable operation within
the Reliability Coordinator Area. A Reliability Coordinator’s scope includes a wide-area view
with situational awareness of neighboring Reliability Coordinator Areas. Its scope includes both
transmission and balancing operations, and it has the authority to direct other functional entities
to take certain actions to ensure that its Reliability Coordinator Area operates reliably.
Like the Reliability Coordinator, the Transmission Operator has responsibility and
authority for the reliable operation of the transmission system within a specified area. The
Transmission Operator is responsible for the Real-time operating reliability of the transmission
assets under its purview, which is referred to as the Transmission Operator Area. The
Transmission Operator has the authority to take certain actions to ensure that its Transmission
Operator Area operates reliably.
Together, the inclusion of these two functional entities— Reliability Coordinators and
Transmission Operators— in proposed Reliability Standard EOP-010-1, provides for the
development and implementation of Operational Procedures and coordination across regions.32

Interim Report: Effects of Geomagnetic Disturbances on the Bulk Power System at ii (February 2012) (NERC
Interim GMD Report), available at http://www.nerc.com/files/2012GMD.pdf.
31
The NERC Reliability Functional Model is available at:
http://www.nerc.com/pa/Stand/Functional%20Model%20Archive%201/Functional_Model_V5_Final_2009Dec1.pdf
32
The NERC Functional Model describes the relationships between functional entities in performing their
reliability related tasks. The Reliability Coordinator "Coordinates with Transmission Operators on system
restoration plans, contingency plans, and reliability-related services" ahead of time, and " Issues corrective actions
and emergency procedures directives to Transmission Operators, Balancing Authorities, Generator Operators,
Distribution Providers, and Interchange Coordinators" in real time.
Available at:
http://www.nerc.com/pa/Stand/Functional%20Model%20Archive%201/Functional_Model_V5_Final_2009Dec1.pdf
See also, Exhibit E.

9

As explained in Exhibit D, the applicability threshold of greater than 200 kV is based on
analysis by the standard drafting team. There are several key parameters in assessing the impacts
of a GMD, including:


Transformer grounding and core construction;



System topology;



Geographic location;



Resistance values of the elements of the DC network used to evaluate GIC
distribution within the network.

Based on an analysis of these factors, the standard drafting team determined that a voltage
threshold of greater than 200 kV is appropriate. This finding is supported by operating
experience and the preponderance of peer-reviewed studies on GMD effects.33 Further, the
standard drafting team determined that the effect of GIC in networks less than 200 kV has
negligible impact on the reliability of the interconnected transmission system. Therefore, as
noted above, the applicability of proposed Reliability Standard EOP-010-1 also recognizes the
technical considerations of the impact of a GMD on the Bulk-Power System.
B.

Requirements in EOP-010-1 – Geomagnetic Disturbance Operations

The proposed Reliability Standard consists of three Requirements. Requirement R1
addresses coordination within a Reliability Coordinator Area. Requirement R2 addresses the
dissemination of space weather information to ensure that entities within a Reliability
Coordinator Area have the appropriate information necessary to take action and that the same
information is available to all entities. Requirement R3 requires the development of GMD
Operating Procedures or Processes. Collectively, these Requirements satisfy the Commission’s

33

See Exhibit D.

10

directives in Order No. 779 and are intended to mitigate the effects of GMD events through the
implementation of Operating Plans, Processes, and Procedures.
Proposed Requirements
R1.

Each Reliability Coordinator shall develop, maintain, and implement a GMD Operating
Plan that coordinates GMD Operating Procedures or Operating Processes within its
Reliability Coordinator Area. At a minimum, the GMD Operating Plan shall include:
1.1
A description of activities designed to mitigate the effects of GMD events on the
reliable operation of the interconnected transmission system within the Reliability
Coordinator Area.
1.2
A process for the Reliability Coordinator to review the GMD Operating
Procedures or Operating Processes of Transmission Operators within its
Reliability Coordinator Area.
Requirement R1 of proposed Reliability Standard EOP-010-1 requires several actions

from Reliability Coordinators: development, maintenance, and implementation of a GMD
Operating Plan, as well as coordination. An Operating Plan is maintained when it is kept
relevant by taking into consideration system configuration, conditions, or operating experience,
as needed to accomplish its purpose. An Operating Plan is implemented by carrying out its
stated actions. The coordination is intended to ensure that Operating Procedures and Operating
Processes within a Reliability Coordinator Area34 are not in conflict with one another; it is not
intended to be a review by the Reliability Coordinator of the technical aspects of the GMD
Operating Procedures or Processes. Transmission Operators are responsible for the technical
integrity of their Operating Procedures or Processes pursuant to Requirement R3. For example,
if Company A submitted an Operating Procedure proposing to take Line X out of service under
specified GMD conditions, and Company B submitted an Operating Procedure that relies on
Line X remaining in service in the event of a GMD -- it is the responsibility of the Reliability

34

The term “Reliability Coordinator Area” is defined in the Glossary of Terms Used in NERC Reliability
Standards as “The collection of generation, transmission, and loads within the boundaries of the Reliability
Coordinator. Its boundary coincides with one or more Balancing Authority Areas.”
Available at http://www.nerc.com/files/Glossary_of_Terms.pdf

11

Coordinator to identify this conflict. The Reliability Coordinator could then require Company A
and Company B to resolve this conflict and resubmit their Operating Procedures.
Part 1.1 of Requirement R1 requires Reliability Coordinators to describe the activities
that must be undertaken in order to mitigate the effects of a GMD. Those activities could require
a Balancing Authority to take action. Pursuant to IRO-001, the Reliability Coordinator has clear
decision-making authority to act and to direct actions to be taken by Transmission Operators,
Balancing Authorities, Generator Operators, Transmission Service Providers, Load-Serving
Entities, and Purchasing-Selling Entities within its Reliability Coordinator Area to preserve the
integrity and reliability of the Bulk Electric System. Part 1.2 of Requirement R1 requires
Reliability Coordinators to establish a process to review the GMD Operating Procedures or
Operating Processes of the Transmission Operators in the Reliability Coordinator Area

R2.

Each Reliability Coordinator shall disseminate forecasted and current space weather
information to functional entities identified as recipients in the Reliability Coordinator's
GMD Operating Plan.
Requirement R2 of proposed Reliability Standard EOP-010-1 addresses the

dissemination of space weather information; such information can be used for situational
awareness and safe posturing of the system. Space weather information can also be used for
monitoring the progress of a GMD event. As the entity with a wide-area view, the Reliability
Coordinator is responsible for disseminating space weather information to ensure coordination
and consistent awareness in its Reliability Coordinator Area.
Requirement R2 of proposed Reliability Standard EOP-010-1 replaces IRO-005-3.1a,
Requirement R3. IRO-005- 3.1a, Requirement R3 states:
Each Reliability Coordinator shall ensure its Transmission Operators and Balancing
Authorities are aware of Geo-Magnetic Disturbance (GMD) forecast information and
assist as needed in the development of any required response plans.
12

Reliability Standard IRO-005-4, which addresses reliability coordination for current day
operations, has been adopted by the NERC Board and filed with the Commission, and would
retire IRO-005-3.1a , Requirement R3.35 Therefore, to ensure responsibility for disseminating
space weather information in the Reliability Coordinator Area is maintained while avoiding
duplicative requirements being enforceable at the same time, if proposed Reliability Standard
EOP-010-1 becomes effective prior to the retirement of IRO-005-3.1a, Requirement R2 of EOP010-1 shall become effective on the first day following retirement of IRO-005-3.1a as detailed in
Exhibit B.

R3.

Each Transmission Operator shall develop, maintain, and implement a GMD Operating
Procedure or Operating Process to mitigate the effects of GMD events on the reliable
operation of its respective system. At a minimum, the Operating Procedure or Process
shall include:
3.1.
3.2.
3.3.

Steps or tasks to receive space weather information.
System Operator actions to be initiated based on predetermined conditions.
The conditions for terminating the Operating Procedure or Operating Process.

Requirement R3 of proposed Reliability Standard EOP-010-1 requires Transmission
Operators to develop Operating Procedures or Operating Processes to address GMD events.
Similar to Requirement R1, an Operating Procedure or Operating Process is implemented by
carrying out its stated actions. An Operating Procedure or Operating Process is maintained when
it is kept relevant by taking into consideration system configuration, conditions, or operating
experience, as needed to accomplish its purpose. Requirement R3 is not prescriptive and allows
35

Reliability Standard IRO-005-4 provides:
Requirement R1. When the results of an Operational Planning Analysis or Real-time Assessment indicate
an anticipated or actual condition with Adverse Reliability Impacts within its Reliability Coordinator Area, each
Reliability Coordinator shall notify all impacted Transmission Operators and Balancing Authorities in its Reliability
Coordinator Area.
Requirement R2. Each Reliability Coordinator that identifies an anticipated or actual condition with
Adverse Reliability Impacts within its Reliability Coordinator Area shall notify all impacted Transmission Operators
and Balancing Authorities in its Reliability Coordinator Area when the problem has been mitigated.

13

entities to tailor their Operational Procedures or Processes based on the responsible entity’s
assessment of entity-specific factors, such as geography, geology, and system topology. This
approach is consistent with the development of results-based Reliability Standards.36 As the
Commission noted in Order No. 779, owners and operators of the Bulk-Power System are most
familiar with their own equipment and system configurations.37
Part 3.1 of Requirement R3 requires Transmission Operators to specify in their Operating
Procedures or Processes steps or tasks that must be conducted to receive space weather
information. Part 3.2 of Requirement R3 requires Transmission Operators to specify what
actions must be taken under what conditions and such conditions must be predetermined. Part
3.3 of Requirement R3 requires Transmission Operators to specify when and under what
conditions the Operating Procedure or Process is exited. For example, if an Operating Procedure
specifies that certain actions must be taken when a space weather alert is received, the Operating
Procedure should specify when such actions would be terminated. Collectively, these Parts of
Requirement R3 ensure that there is a baseline level of detail in the Operating Procedures or
Processes while maintaining necessary flexibility in order to allow responsible entities to tailor
their Operating Procedures or Processes as needed. Furthermore, the proposed Reliability
Standard is technology neutral.
Proposed Reliability Standard EOP-010-1 does not prescribe specific actions that must be
taken by responsible entities because a “one-size fits all” approach to crafting GMD Reliability
Standards would fail to recognize the important role of locational differences.38 Indeed, the

36

Results-based Reliability Standards focus on required actions or results and not necessarily the methods by
which those actions or results must be accomplished.
37
Order No. 779 at P 38.
38
As Commissioner LaFleur has noted, the panelists at the April 30, 2012 FERC technical conference agreed
that “there can be considerable differences in GMD exposure and impacts depending on geography, where you are
in the earth, ground conditions, grid configuration, and equipment condition…” See Electric Infrastructure Security
Summit III, London, May 14-15, 2012, The House of Parliament, United Kingdom at p. 25.

14

Commission stated in Order No. 779 that it “do[es] not expect that owners and operators of the
Bulk-Power System will necessarily develop and implement the same operational procedures.”39
The standard drafting team determined that the variability in the impacts of GMD precludes the
development of prescriptive requirements.40
For these reasons, the proposed Reliability Standard is just and reasonable and should
mitigate the effects of GMD events through the implementation of Operating Plans, Processes,
and Procedures.
C.

Commission Directives Addressed

As explained in Exhibit G, the proposed Reliability Standard satisfies all of the
Commission’s directives in Order No. 779 with respect to Stage 1 of the GMD Reliability
Standards. Requirements R1 and R3 of proposed Reliability Standard EOP-010-1 satisfy the
Commission’s directive to submit “within six months of the effective date of this Final Rule, one
or more Reliability Standards requiring 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.”41 Requirement R1 requires Reliability
Coordinators to develop, maintain and implement a GMD Operating Plan that coordinates GMD
Operating Procedures within its Reliability Coordinator Area. Requirement R3 requires
Transmission Operators to develop, maintain, and implement an Operating Procedure or
Operating Process to mitigate the effects of GMD events on the reliable operation of its
respective system. Order No. 779 became effective on July 22, 2013 and the instant petition is
being submitted within six months, in compliance with the Commission’s directive. The

39
40
41

Order No. 779 at P 38 (emphasis added).
See Consideration of Comments: Project 2013-03 (August 30, 2013) at p. 37.
Order No. 779 at P 30.

15

proposed Reliability Standard satisfies the Commission’s directives and also addresses the
Commission’s concerns regarding the need for flexibility in Operational Procedures.
D.

Enforceability of EOP-010-1

The proposed Reliability Standard includes Violation Risk Factors (“VRFs”) and
Violation Severity Levels (“VSLs”). The VSLs provide guidance on the way that NERC will
enforce the Requirements of the proposed Reliability Standard. The VRFs are one of several
elements used to determine an appropriate sanction when the associated Requirement is violated.
The VRFs assess the impact to reliability of violating a specific Requirement. The VRFs and
VSLs for the proposed Reliability Standards comport with NERC and Commission guidelines
related to their assignment. For a detailed review of the VRFs, the VSLs, and the analysis of
how the VRFs and VSLs were determined using these guidelines, please see Exhibit F.
The proposed Reliability Standard also include Measures that support each Requirement
by clearly identifying what is required and how the Requirement will be enforced. These
Measures help ensure that the Requirements will be enforced in a clear, consistent, and nonpreferential manner and without prejudice to any party.42

42

Order No. 672 at P 327 (“There should be a clear criterion or measure of whether an entity is in compliance
with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance
so that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner.”).

16

V.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission:
•

approve the proposed Reliability Standard and associated elements included in Exhibit
A, effective as proposed herein;

•

approve the implementation plan included in Exhibit B as proposed herein.
Respectfully submitted,
/s/ Stacey Tyrewala
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
Stacey Tyrewala
Senior Counsel
Brady Walker
Associate Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

Date: November 14, 2013