Foundation for Resilient Societies comments under RM15-11, & seeks remand of proposed Standard TPL-007-1 to include true 1-in-100 yr storm magnitude, reactive power (VAR) impacts, coastal effect and modeling for cost-effective hardware protection.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Reliability Standard for ) Docket No. RM15-11- 000 Transmission System Planned Performance ) for Geomagnetic Disturbance Events ) COMMENTS OF THE FOUNDATION FOR RESILIENT SOCIETIES Submitted to FERC on July 27, 2015 Pursuant to the Federal Energy Regulatory Commissions (FERC or Commission) Notice of Proposed Rulemaking (GMD NOPR) issued on May 16, 2015,1 the Foundation for Resilient Societies (Resilient Societies) respectfully submits Comments on the Commissions proposal to approve the framework of Reliability Standard TPL-007-1 of the North American Electric Reliability Corporation (NERC) as just and reasonable, to approve specific requirements of the standard, and to direct NERC to develop modifications to Reliability Standard TPL-007-1 and submit informational filings. Background In FERC Order 779, FERC directed NERC to develop Second Stage Geomagnetic Disturbance (GMD) Reliability Standards:1 TheSecondStageGMDReliabilityStandardsmustidentifybenchmarkGMDeventsthat specifywhatseverityGMDeventsaresponsibleentitymustassessforpotentialimpacts ontheBulkPowerSystem.Iftheassessmentsidentifypotentialimpactsfrombenchmark GMDevents,theReliabilityStandardsshouldrequireownersandoperatorstodevelop andimplementaplantoprotectagainstinstability,uncontrolledseparation,orcascading 1 Reliability Standard for Transmission System Planned Performance for Geomagnetic Disturbance Events, Notice of Proposed Rulemaking (NOPR), 151 FERC 61,134 (May 14, 2015) (GMD NOPR), 80 FR 29990 (May 26, 2015). 1 Reliability Standards for Geomagnetic Disturbances , Docket No. RM12-22-000; FERC Order No. 779, 143 FERC 61,147 (May 16, 2013) (FERC Order 779), 78 FR 30747 (May 23, 2013), p. 2. 1 failuresoftheBulkPowerSystem,causedbydamagetocriticalorvulnerableBulk PowerSystemequipment,orotherwise,asaresultofabenchmarkGMDevent. (Emphasis added.) As we will show in this comment, both the Benchmark GMD Event and the assessment criteria to identify potential impacts from the Benchmark GMD Event are fatally flawed. As a result, it is exceedingly unlikely that GMD Vulnerability Assessments by owners and operators will result in any significant protection against instability, uncontrolled separation, or cascading failures of the Bulk-Power System, except by voluntary action beyond the requirements of this standard. Framework of Standard TPL-007-001 Overlapping Thresholds for Solar Storm Threat and Assumed Invulnerability of Transformers The fundamental framework of Standard TPL-007-001 is defective because it overlaps a low solar storm threat or Benchmark GMD Event, expressed in volts per kilometer, with a very high assumed invulnerability of transformers (also known as Geomagnetically Induced Current (GIC) withstand rating) expressed in amps per phase. Only transformers having a lower withstand rating than the modeled GIC from the Benchmark GMD event would undergo thermal assessment to determine if hardware protection might be required. If Standard TPL-007-1 we