UNITED STATES OF AMERICA
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Reliability Standards for Geomagnetic Disturbances
Docket No. RM12-22-000
The American Public Power Association (“APPA”), the Edison Electric Institute (“EEI”), the Large Public Power Council (“LPPC”) and the National Rural Electric Cooperative Association (“NRECA”), jointly on behalf of their respective member companies (collectively the “Trade Associations”) hereby respectfully submits these Comments in response to the Notice of Proposed Rulemaking (“NOPR”) issued by the Federal Energy Regulatory Commission (“Commission” or “FERC”) on October 18, 2012, in the above-referenced docket. The NOPR proposes to direct the North American Electric Reliability Corporation (“NERC”) to create and submit Reliability Standards that address and mitigate the effects of geomagnetic disturbances (“GMDs”) on the Bulk- Power System (“BPS”) caused by solar events.