NERC submits Comments on the Interpretation of Reliability Standard TPL-002-0

On May 10, 2010, in Docket Nos. RM06-16-000 and RM10-6-000, NERC submitted comments on the interpretation of Transmission Planning and Reliability Standards TPL-002-0.  In its NOPR, FERC proposed to interpret Requirement R1.3.10 of the TPL-002-0 to require “‘that planners study, in their system assessments, the non-operation of primary protection systems in order to ascertain whether an how reliance on the as-designed backup or redundant protection systems affects reliability.’”  In its comments, NERC argues that FERC’s alternative proposal “improperly expands the conditions that must be studied and addressed under TPL-002-1” thereby adding “new requirements” and exceeding the scope of its authority under Section 215 of the Federal Power Act. It also argues that the proposed interpretation is “inconsistent with the purpose and text” of Reliability Standard TPL-002 as previously approved by the Commission.  To read NERC’s comments, click here.