Reports & Filings

The IRC filed a limited answer to comments reiterating its request that the Commission approve proposed NERC Reliability Standards EOP-011-3 and EOP-012-1, direct NERC to revise EOP-012-1 to address issues identified in the IRC’s December 8, 2022 comments, and submit a revised version of EOP-012-1 no later than November 2023

Document Link: motion-for-leave-to-answer-and-limited-answer-of-the-isorto-council-docket-no-rd231000

The IRC submitted comments in response to NERC’s petition for approval of proposed Reliability Standards EOP-011-3 and EOP-012-1 (Cold Weather Standards).

Document Link: irc-comments-on-nerc-cold-weather-standards-eop121-rd23-1

The IRC submitted reply comments in connection with FERC’s proposal to impose automatic penalties on transmission providers for study delays.

Document Link: irc-comments-on-interconnection-nopr-imposition-of-penalties-for-delayed-studies

The ISO/RTO Council filed reply comments on FERC’s credit information sharing NOPR.  The IRC urges FERC to grant each RTO/ISO the flexibility to share information with other RTOs/ISOs as and when necessary to accurately assess market participants’ credit exposure and common risks that could have an impact across the organized wholesale electric markets.

Document Link: irc-files-reply-comments-on-fercs-credit-information-sharing-nopr

The ISO/RTO Council submits comments in FERC Docket RM22-14 – Improvements to Generator  Interconnection Procedures and Agreements.  The ISO/RTO Council opposes the adoption of a proposal to impose automatic penalties on RTOs/ISOs should interconnection deadlines be missed and urges the Commission to engage in further consultation with the RTOs/ISOs, Transmission Owners, and Interconnection Customers to develop alternatives.

Document Link: IRC-submits-comments-in-FERC-Docket-RM22-14

The ISO/RTO Council submits comments on FERC’s notice of proposed rulemaking in RM22-13.  The IRC supports a rule which would permit the RTOs/ISOs to allow the voluntary sharing of credit-related information among themselves.

Document Link: IRC-comments-on-FERC-notice-of-proposed-rulemaking-in-RM22-13-20221007

The ISO/RTO Council comments on FERC’s transmission and cost allocation notice of proposed rulemaking support the adoption of a long-term scenario-based transmission planning process that anticipates the transmission needs of the changing resource mix and demand.  The IRC requests FERC provide each region flexibility to tailor a long-term planning construct that accommodates regional differences, while addressing any long-term planning principles, objectives, and parameters that FERC adopts.

Document Link: IRC-Comments-FERCs-transmission-and-cost-allocation-RM21-17-000-20220817

The IRC comments on proposed changes to survey forms used by the Energy Information Administration to collect energy data.

Document Link: IRC Comments on Proposed Changes to EIA 930 and new EIA 930A

On January 20, 2022, the Federal Energy Regulatory Commission issued a notice of proposed rulemaking in RM22-3 that proposes to direct the North American Electric Reliability Corporation to develop and submit for approval new or modified Reliability Standards that require internal network security monitoring within a trusted Critical Infrastructure Protection networked environment for high and medium impact Bulk Electric System Cyber Systems.  The Commission solicited comments by March 28, 2022.

Document Link: 2022-03-28 RM22-3 INSM NOPR Comments

On July 15, 2021, the Commission issued the Advance Notice of Proposed Rulemaking (“ANOPR”) in the above-captioned proceeding, which presented potential reforms to improve electric regional transmission planning and cost allocation and generator interconnection processes. As relevant here, the Commission invited all interested persons to submit comments on the potential reforms and in response to specific questions by October 12, 2021, with reply comments due November 9, 2021.4

Document Link: Docket No-RM21-17-000

ISO/RTO Council (IRC) report examines how the future of the North American power grid depends on effectively adding renewables to the grid, the accuracy and availability of data from “behind-the-meter” resources, and coordinating these distributed energy resources at the grid operator level to preserve reliability.

Document Link: 20170315_IRC_Emerging_Technologies_Report_Press_Release

The CEOs of the six independent system operators (ISOs) and regional transmission organizations (RTOs) regulated by the Federal Energy Regulatory Commission (FERC) today appeared before the Commission to discuss the 2010 ISO/RTO Metrics Report filed in December. The metrics report provided FERC with extensive data on grid operations and power markets in their regions.

Document Link: 20110120_2010IRCMetricsReport_PresentationToFERC_PressRelease

The independent system operators (ISOs) and regional transmission organizations (RTOs) regulated by the Federal Energy Regulatory Commission (FERC) today submitted to FERC a metrics report providing extensive data on grid operations and power markets in their regions.

Document Link: 20101207_2010IRCPerformanceMetricsReport_PressRelease