FERC-725Z, (DLO in RD22-2 and
Extension in IC22-24), Mandatory Reliability Standards: IRO
Reliability Standards
Revision of a currently approved collection
No
Regular
10/18/2022
Requested
Previously Approved
36 Months From Approved
11/30/2022
977
6,686
49,350
50,083
0
0
In general, information collection and
record retention requirements related to Reliability Standards are
not submitted to, or retained for audit by, the Commission. Rather
they are submitted to, or retained for audit by, NERC (the
Commission-approved ERO) or the Compliance Enforcement Authority,
as specified in each individual Reliability Standard. NERC
established the following IRO standards IRO-001-4, IRO-002-7,
IRO-008-2, IRO-009-2, IRO-010-2, IRO-014-3, IRO-017-1, and
IRO-018-1 within FERC-725Z: IRO-001-4 purpose is to establish the
responsibility of Reliability Coordinators to act or direct other
entities to act. In a joint petition dated May 30, 2019, the North
American Electric Reliability Corporation (“NERC”) and Western
Electricity Coordinating Council (“WECC”) requested Commission
approval for Reliability Standard IRO-002-6 (now IRO-002-7)
(Reliability Coordination, Monitoring and Analysis). NERC and WECC
stated that the “Reliability Standard IRO-002-7 reflects the
addition of a regional Variance containing additional requirements
applicable to Reliability Coordinators providing service to
entities in the Western Interconnection.” NERC maintains that the
data exchange capability requirement in Reliability Standard
IRO-002-7, Requirement R1 is covered by Reliability Standard
IRO-008-2, Requirement R1, which obligates the reliability
coordinator to perform operational planning analyses to assess
whether the planned operations for the next-day will exceed System
Operating Limits and Interconnection Reliability Operating Limits
within its Wide Area. NERC asserts that “to perform the required
operational planning analyses, the Reliability Coordinator must
have the data it deems necessary from those entities that possess
it.” Currently effective IRO-009-2 applicable to reliability
coordinators and the purpose of the standard is to prevent
instability, uncontrolled separation, or cascading outages that
adversely impact the reliability of the interconnection by ensuring
prompt action to prevent or mitigate instances of exceeding
Interconnection Reliability Operating Limits (IROLs). Additionally,
regarding data exchange, NERC cites Reliability Standard IRO-010-2
(Reliability Coordinator Data Specification and Collection) and its
stated purpose of preventing instability, uncontrolled separation,
or cascading outages “by ensuring the Reliability Coordinator has
the data it needs to monitor and assess the operation of its
Reliability Coordinator Area.” NERC states that under Reliability
Standard IRO-010-2, Requirements R1, R2 and R3, the reliability
coordinator must specify the data necessary for it to perform its
operational planning analyses and provide the specifications to the
entities from which it needs data who then must comply with the
data request using a mutually agreeable format and security
protocols. IRO-014-3 purpose is to ensure that each Reliability
Coordinator’s operations are coordinated such that they will not
adversely impact other Reliability Coordinator Areas and to
preserve the reliability benefits of interconnected operations.
IRO-017-1 (Outage Coordination) purpose is to ensure that outages
are properly coordinated in the Operations Planning time horizon
and Near-Term Transmission Planning Horizon. Reliability
coordinators, planning coordinators, balancing authorities,
transmission owners and transmission planners are applicable
entities for IRO-017-1. IRO-018-1 (Reliability Coordinator
Real-time Reliability Monitoring and Analysis Capabilities),
submitted by North American Electric Reliability Corporation
(NERC). Requirement R3 requires reliability coordinators to have an
alarm process monitor that provides notification to system
operators when the failure of a real-time monitoring alarm
processor has occurred. In this order, the Reliability Standards
build on monitoring, real-time assessments and support effective
situational awareness. T
There were corrections made to
the burden estimates. In the past, combining reliability standards
caused the same reliability standard to be accounted for multiple
times, resulting in the previously recorded 6,686 responses (i.e.
IRO-008-1 was carried over burden that should have been removed;
reporting 135 respondents with 46 responses per respondent in
error). These numbers were revised and updated to be the new
calculated total of 953 responses. Staff looked at each reliability
standard as its own unique project and in doing so eliminated the
multiple entity count by making a more accurate representation of
the number of responses. NERC added a new requirement requiring a
RC to use its SOL methodology when determining SOL exceedances for
its analyses and assessments and further revised a requirement
requiring the RC to use its SOL risk-based notification framework
when communicating SOL or IROL exceedances. Due to the revision of
IRO-008-2 (now IRO-008-3) the burden increased to 977 (increase of
12 responses) annual responses and 53,142 (increase of 2,304 burden
hours) annual burden hours.
$7,694
No
No
No
No
No
No
No
David O'Conner 202
502-6695
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.