Reports & Filings

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

On May 3, 2021, in Docket No. RM20-10-000, PJM filed on behalf of the ISO/RTO Council a motion for a 30-day extension of time for all parties to submit comments relating to the Supplemental Notice that introduces a new Transmission Organization Incentive.  The motion seeks to move the deadline from May 26, 2021 to June 25, 2021.

Document Link: RM20-10 IRC's Motion for Extension of Time on RTO Participation Adder Comments (5.3.21)

On August 21, the ISO-RTO Council (IRC) submitted comments and responses in reply to the United States Department of Energy’s (DOE) Notice of Request for Information (RFI), published in the Federal Register on July 8, 2020, regarding the proceedings on Securing the United States Bulk-Power System. In the RFI, the DOE seeks information to understand the energy industry’s current practices to identify and mitigate vulnerabilities in the supply chain for components of the bulk-power system (BPS).

Document Link: IRC Comments and Responses to DOE RFI re Supply Chain Management

On July 2, the ISO-RTO Council (IRC) submitted comments in response to the Federal Energy Regulatory Commission (FERC) Notice of Inquiry (Virtualization and Cloud Computing Services – Docket No. RM20-8-000), issued on February 20, 2020. The Notice of Inquiry seeks comment regarding the potential benefits and risks associated with the use of virtualization and cloud computing, and whether barriers impeding the adoption of virtualization and cloud computing exists in the North American Electric Reliability Corporation Inc. (NERC) Critical Infrastructure Protection (CIP) reliability standards. The IRC believes virtualization and cloud computing services can be utilized for myriad reliability related services, provided risks are sufficiently mitigated through mandatory cloud security requirements and that FERC should direction action by NERC to develop modifications to the CIP reliability standards to facilitate the voluntary adoption of virtualization and cloud computing services. The existing standards need to be evaluated in light of cloud computing practices, and revised to address some of the nuances of cloud computing.

Document Link: IRC-Comments-on-FERC-Virtualization-NOI

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