TAPS efforts included the following significant activities:


Early in 2009 Senate leaders floated a number of legislative proposals to promote greater development of transmission, driven in large part by their desire to overcome barriers to delivery of renewable resources to load.  Early proposals from Senate Majority Leader Harry Reid (D-NV) and Energy and Natural Resources Committee Chairman Jeff Bingaman (D-NM) included: a requirement for Interconnection-wide planning organizations, more transmission planning authority for the Federal Energy Regulatory Commission (FERC); full federal siting of projects endorsed by the Interconnection-wide planning process; and authority to FERC to socialize the costs of approved projects to all load serving entities in the respective Interconnections.  Reid’s proposal also provided preferential treatment for transmission projects designed to deliver renewable resources only.

TAPS met with Members of Congress, Administration officials and FERC to advocate an inclusive, transparent regional transmission planning supplemented by a mandatory inter-regional planning process for extra high voltage and multi-regional projects; enhanced federal siting authority if states fail to act to implement approved projects promptly; joint ownership of major new facilities for public power and cooperative utilities and other smaller Load Serving Entities; and requiring FERC to establish cost allocation principles and enhanced cost recovery certainty through a rulemaking.

In July, the Senate Energy and Natural Resources Committee approved a bill, S. 1462, which contains transmission provisions consistent with most of TAPS’ priorities. However, TAPS does not support the Corker (R-TN) cost allocation language adopted by the Committee, which would allow FERC to allocate costs of new transmission facilities only in proportion to measurable economic or reliability benefits.  TAPS believes this methodology is unworkable and will hamper the development of needed transmission. In June, as part of H.R. 2454, the Waxman-Markey comprehensive climate and energy legislation, the House approved changes in transmission policy that TAPS does not support.  Those changes, which were added to the bill without much discussion just before it went to the House floor for a vote, include enhanced “backstop” federal siting authority only in the Western Interconnection and only for lines primarily used for renewable energy.

Resolution of differences between the House and Senate transmission titles is tied to Senate passage of a climate change bill, because Congressional leaders, at present, seem intent on keeping the energy and climate bills tied together.  That could change if the Senate leadership finds it impossible to craft a climate bill that can attract the needed 60 votes.

Federal cyber security legislation was another priority for TAPS in the 111th Congress.  TAPS is part of an industry coalition that is working with Members of Congress and FERC to find consensus on legislation that would give FERC narrow authority to address imminent cyber security threats to the bulk power system.


NERC’s transformation into the Electric Reliability Organization authorized by the Energy Policy Act of 2005 to establish and enforce mandatory reliability standards, subject to FERC review, has enhanced the importance of the standards development process at NERC and, for the related business practices, at NAESB.  Since his “retirement” from Vermont Public Power Supply Authority in 2006, Bill Gallagher has mobilized and coordinated TAPS efforts to monitor and participate in NERC and NAESB activities to protect the interests of TDUs.  Bill was recently elected as the vice chair of the NERC Members Representative Committee.

TAPS has worked to ensure TDU representation at both NERC and NAESB.  TAPS has significant representation on the NERC Member Representatives Committee, the NAESB Board, and the NAESB Wholesale Electric Quadrant Executive Committee, and is represented on most NERC standing committees.  TAPS members also participate in significant drafting teams at NERC and/or NAESB.

TAPS has also made its voice heard on reliability issues through submissions to FERC in NERC- and NAESB-related proceedings, as well as submission of comments to NERC and NAESB.

NERC and NAESB ATC Standards (RM05-5; RM08-19, RM09-5, RM06-16)

  • TAPS submits Comments to FERC on May 26, 2009 concerning FERC’s NERC ATC Standards NOPR.
  • TAPS submits Comments to FERC on May 26, 2009 concerning FERC’s NAESB ATC Standards NOPR.
  • TAPS files on December 23, 2009 for clarification of the effective date of NERC’s FERC-approved ATC standards.

Transmission Relay Loadability Standards (RM08-13) 

  • TAPS submits Comments, supported by the Affidavit of Frank Gaffney (FMPA), to FERC on August 17, 2009 concerning FERC’s TRL Standards NOPR.

Topological and Impedence Element Ranking (TIER) of BPS (RM06-16)

  • TAPS submits Comments to FERC on October 28, 2009 regarding use of the TIER methodology to determine the facilities included in the bulk power system.

NERC Budget (RR08-6 and RR07-14) 

  • On January 14, 2009, TAPS files in support of NERC 2009 budget’s omission of its readiness program.
  • On April 6, 2009, TAPS files in support of NERC’s compliance filing on same point.

NERC Standards Applicability Issues

  • April 13, 2009 TAPS comments to NERC regarding RFC proposed UFLS standard applicable beyond Registry Criteria, and protests restrictions on scope of permissible comments.
  • TAPS members form an informal group to provide support to the TAPS members on the Standards Drafting Team for the proposed continent-wide UFLS standard. 

NERC Compliance Process

  • On November 13, 2009, TAPS joins with American Public Power Association, Canadian Electricity Association, Edison Electric Institute, Electric Power Supply Association, Electricity Customers Resource Council, the National Rural Electric Cooperative Association in commenting on proposed forms for NERC’s Compliance Monitoring and Enforcement Program. 

NERC Cyber Concept Paper

  • TAPS comments to NERC on September 4, 2009 concerning NERC’s Cyber Concept Paper.

NERC Functional Model Revisions

  • TAPS comments to NERC on August 19, 2009 regarding proposed revisions to the Functional Model.
  • TAPS comments to NERC on October 26, 2009 regarding further revisions to the Functional Model. 

NERC Confidentiality Issues

  • April 27, 2009 TAPS comments to NERC in opposition to proposed modifications to the Reliability Standards Development Procedures manual that would unduly restrict the entities permitted to comment on standards developed in response to national security emergency situations. 
  • April 15, 2009 TAPS comments to NERC on draft Regional Entity Confidentiality Agreement. 

NAESB Network Service Business Practices 

  • TAPS submits informal comments to NAESB on October 14, 2009 WEQ OASIS Business Practices for network service.

FERC (Non-Reliability Initiatives)

Integrating Renewable Resources Into the Wholesale Electric Grid (AD09-4)

  • TAPS submits Post-Technical Conference Comments (April 30, 2009).

Transmission Planning Processes Under Order 890

  • TAPS submits Initial Comments on November 23, 2009 and Reply Comments on December 17, 2009.

Market-Based Rates for Public Utilities (RM04-7)

  • TAPS files Comments on November 30, 2009 in opposition to the Compliance Working Group’s (“CWG”) October 28, 2009 Amended Request for Clarification.
  • TAPS replies to CWG on December 22, 2009.

Wholesale Competition in Regions with Organized Electric Markets (RM07-19 and AD07-7)

  • TAPS (with APPA, NRECA and AMP) seeks rehearing of FERC Order 719-A regarding ARC (Aggregator of Retail Customers) issues on August 17, 2009.

Standards of Conduct for Transmission Providers (RM07-1)

  • TAPS requests clarification or rehearing of Order 717-A on November 16, 2009 to ensure that a G&T coop’s sales to its distribution coops, and a municipal joint action agency’s sales to its municipal members, are treated the same as a vertically integrated utility’s retail sales for standards of conduct purposes.

Control Requirements for MBR and Mergers (EL08-87/PL09-3)

  • January 16, 2009 TAPS submits Post-Workshop Comments.

Smart Grid Policy (PL09-4)

  • June 2, 2009 TAPS responds to FERC supplemental request for comments.