United States of America Before the Federal Energy Regulatory Commission 
Remedial Action Schemes Reliability Standard   |  Docket No. RM16-20-000 
Comments of the New England States Committee on Electricity

 Pursuant to the Federal Energy Regulatory Commission’s (“Commission”) Notice of Proposed Rulemaking issued on January 19, 2017 (the “NOPR”),[1] the New England States Committee on Electricity (“NESCOE”)[2] hereby submits these limited comments on the Commission’s proposal to approve Reliability Standard PRC-012-2 – Remedial Action Schemes (“RAS”).

The NOPR seeks comment, inter alia, on the Commission’s proposal to clarify, in a final rule, “that Reliability Standard PRC-012-2 will not modify or supersede any system performance obligations under Reliability Standard TPL-001-4.”[3]  NESCOE understands that ISO-NE, together with other system operators, is filing comments in this proceeding in response to the Commission’s request for comment on this proposed clarification.  These comments, as NESCOE understands, will request that any clarification in the final rule that Reliability Standard PRC-012-2 does not modify or supersede any system performance obligations under Reliability Standard TPL-001-4 also confirm that TPL-001-4 allows responsible entities to assume that all RAS are operating properly.

NESCOE recognizes the importance of, and shares the Commission’s interest in, implementing reliability standards that address risks to the bulk electric system.  However, as NESCOE has stated with respect to the development of mandatory standards, incremental reliability gains must be measured against the magnitude of risk and the cost associated with any such standard.  NESCOE is concerned that, absent confirmation that TPL-001-4 allows responsible entities to assume that all RAS operate properly, a clarification in any final rule that Reliability Standard PRC-012-2 does not modify or supersede any system performance obligations under Reliability Standard TPL-001-4 could be misinterpreted by responsible entities to require actions with respect to limited impact RAS that would add material costs to consumers without meaningful reliability benefits.  NESCOE respectfully urges the Commission to strongly consider ISO-NE’s comments on this issue.

Respectfully submitted,

 /s/ Jason R. Marshall
Jason R. Marshall
General Counsel
New England States Committee on Electricity
655 Longmeadow Street
Longmeadow, MA  01106
Tel: (617) 913-0342
jasonmarshall@nescoe.com

Date: April 10, 2017