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Individual or group.  (18 Responses)
Name  (13 Responses)
Organization  (13 Responses)
Group Name  (5 Responses)
Lead Contact  (5 Responses)
Contact Organization  (5 Responses)
Question 1  (16 Responses)
Question 1 Comments  (18 Responses)
Question 2  (16 Responses)
Question 2 Comments  (18 Responses)
Question 3  (16 Responses)
Question 3 Comments  (18 Responses)
Question 4  (0 Responses)
Question 4 Comments  (18 Responses)
 
Individual
John D. Martinsen
Snohomish Countly PUD
Yes
 
Yes
 
No
 
 
Group
NPCC
Guy Zito
NPCC
No comments.
No comments.
No comments.
No comments.
Individual
Ronald Szymczak
Exelon
Yes
 
Yes
 
No Preference
 
Requirement R1 should also require that the Available Transfer Capability Implementation Document specify the following: o PTDF and OTDF cutoff values used The term “planning of operations” is not a term use by all entities in the electric utility industry and has no agreed upon definition; consequently it should be used in a standard. ATC or AFC calculations cover the operating and planning time horizons and therefore, the calculations need to apply the appropriate contingency criteria for the time frame being studied. The following wording change is recommended: · Requirement 2.1.1.1. and 2.1.2.1. need to be revised as follows: “Use first Contingency criteria consistent with those first Contingency criteria used in operations studies and planning studies of operations for the applicable time periods, including use of Special Protection Systems.
Individual
John Harmon
Midwest ISO
Yes and No
 
Yes
 
No
 
The Midwest ISO thanks the Standard Drafting Team for consideration of its comments from the MOD-030-1. We applaud the revisions to requirements R2.1.3, R2.2, R2.3, and R11. The Midwest ISO continues to believe that the MOD-030-1 is more stringent than MOD-028 or MOD-029. R6.2/R6.4/R6.6/R7.2/R7.4/R7.6 are clear examples where MOD-030 is more stringent and the highest degree of compliance is not required for all three methodologies. The Midwest ISO is not convinced that similar seams coordination requirements exist for the other two standards, especially for MOD-029. The Standard Drafting Team has maintained that this does not apply to MOD-029 since it is not a “simulation” type methodology. While this is true, the Midwest ISO believes that impacts from neighboring entity generators and loop flows cannot be ignored and should still be considered in ATC calculations. With a much higher risk of compliance violation, entities may be deterred from implementing the Flowgate methodology even if it would increase system reliability. Since the Standard Drafting Team disagrees with our proposal, we request to remove these requirements from MOD-030 to achieve more unbiased standards so that each methodology maintains an equal level of compliance.
Group
Bonneville Power Administration
Denise Koehn
Transmission Reliability Program
Yes
The modifications to R2.1 are necessary to facilitate the manner in which WECC entities define Flowgates.
Yes
The additions of R2.1.1.3 and R2.1.2.3 are appreciated by BPA, as this permits the continued use of the process WECC entities use to define Flowgates, however, we believe that the below re-wording of these two sub-requirements is more precise and removes the vague phrase “protected by”. "If any limiting element is kept within its limit for its associated worst Contingency by operating within the limits of another Flowgate, then no new Flowgate needs to be established for such limiting elements or Contingencies."
No
 
BPA thanks the NERC ATC Standards Drafting Team for drafting this SAR and MOD-030-2, and moving so quickly to respond to the concerns of the Pacific NW regarding MOD-030-1.
Group
Standards Interface Subcommittee/Compliance Elements Development Resource Pool
John Blazekovich
Commonwealth Edison Co.
 
 
 
Standard – R1 MOD-030-02 Requirement (including sub-requirements) R1. The Transmission Service Provider shall include in its “Available Transfer Capability Implementation Document” (ATCID): [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R1.1. The criteria used by the Transmission Operator to identify sets of Transmission Facilities as Flowgates that are to be considered in Available Flowgate Capability (AFC) calculations. R1.2. The following information on how source and sink for transmission service is accounted for in AFC calculations including: R1.2.1. Define if the source used for AFC calculations is obtained from the source field or the Point of Receipt (POR) field of the transmission reservation. R1.2.2. Define if the sink used for AFC calculations is obtained from the sink field or the Point of Delivery (POD) field of the transmission reservation. R1.2.3. The source/sink or POR/POD identification and mapping to the model. R1.2.4. If the Transmission Service Provider’s AFC calculation process involves a grouping of generators, the ATCID must identify how these generators participate in the group. Proposed Measure M1. Each Transmission Service Provider shall provide its ATCID and other evidence (such as written documentation) to show that its ATCID contains the criteria used by the Transmission Operator to identify sets of Transmission Facilities as Flowgates and information on how sources and sinks are accounted for in AFC calculations. (R1) Attributes of the requirement Binary X Timing Omission X Communication Quality Other SDT Proposed Lower VSL The Transmission Service Provider does not include in its ATCID one or two of the sub-requirements listed under R1.2, or the sub-requirement is incomplete. CEDRP Proposed VSL OK – No Comments SDT Proposed Moderate VSL The Transmission Service Provider does not include in its ATCID three of the sub-requirements listed under R1.2,or the sub-requirement is incomplete. CEDRP Proposed VSL OK – No Comments SDT Proposed High VSL The Transmission Service Provider does not include in its ATCID the information described in R1.1.OR The Transmission Service Provider does not include in its ATCID the information described in R1.2 (1.2.1, 1.2.2.,1.2.3, and 1.2.4 are missing). CEDRP Proposed VSL OK – No Comments SDT Proposed Severe VSL The Transmission Service Provider does not include in its ATCID the information described in R1.1 and R1.2 (1.2.1, 1.2.2., 1.2.3, and 1.2.4 are missing). CEDRP Proposed VSL OK – No Comments FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? Yes. 3. Is it truly a “binary” requirement? No. 4. If yes, is the VSL assignment consistent with other binary requirement assignments? No. 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? Yes. Standard – R2 MOD-030-02 Requirement (including sub-requirements) R2. The Transmission Operator shall perform the following: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R2.1. Include Flowgates used in the AFC process based, at a minimum, on the following criteria: R2.1.1. Results of a first Contingency transfer analysis for ATC Paths internal to a Transmission Operator’s system up to the path capability such that at a minimum the first three limiting Elements and their worst associated Contingency combinations with an OTDF of at least 5% and within the Transmission Operator’s system are included as Flowgates. R2.1.1.1. Use first Contingency criteria consistent with those first Contingency criteria used in planning of operations for the applicable time periods, including use of Special Protection Systems. R2.1.1.2. Only the most limiting element in a series configuration needs to be included as a Flowgate. R2.1.1.3. If any limiting elements or Contingencies are already protected by another Flowgate, then no new Flowgates need to be established for such limiting elements or Contingencies. R2.1.2. Results of a first Contingency transfer analysis from all adjacent Balancing Authority source and sink (as defined in the ATCID) combinations up to the path capability such that at a minimum the first three limiting Elements and their worst associated Contingency combinations with an Outage Transfer Distribution Factor (OTDF) of at least 5% and within the Transmission Operator’s system are included as Flowgates unless the interface between such adjacent Balancing Authorities is accounted for using another ATC methodology. R2.1.2.1. Use first Contingency criteria consistent with those first Contingency criteria used in planning of operations for the applicable time periods, including use of Special Protection Systems. R2.1.2.2. Only the most limiting element in a series configuration needs to be included as a Flowgate. R2.1.2.3. If any limiting elements or Contingencies are already protected by another Flowgate, then no new Flowgates need to be established for such limiting elements or Contingencies. R2.1.3. With the exception of flowgates created to address temporary operating conditions, any limiting Element/Contingency combination at least within its Reliability Coordinator’s Area that has been subjected to an Interconnection-wide congestion management procedure within the last 12 months, unless the limiting Element/Contingency combination is accounted for using another ATC methodology. R2.1.4. Any limiting Element/Contingency combination within the Transmission model that has been requested to be included by any other Transmission Service Provider using the Flowgate Methodology or Area Interchange Methodology, where: R2.1.4.1. The coordination of the limiting Element/Contingency combination is not already addressed through a different methodology, and - Any generator within the Transmission Service Provider’s area has at least a 5% Power Transfer Distribution Factor (PTDF) or Outage Transfer Distribution Factor (OTDF) impact on the Flowgate when delivered to the aggregate load of its own area, or - A transfer from any Balancing Area within the Transmission Service Provider’s area to a Balancing Area adjacent has at least a 5% PTDF or OTDF impact on the Flowgate. - The Transmission Operator may utilize distribution factors less than 5% if desired. R2.1.4.2. The limiting Element/Contingency combination is included in the requesting Transmission Service Provider’s methodology. R2.2. At a minimum, establish a list of Flowgates by creating, modifying, or deleting Flowgate definitions at least once per calendar year. R2.3. At a minimum, establish a list of Flowgates by creating, modifying, or deleting Flowgates that have been requested as part of R2.1.4 within thirty calendar days from the request. R2.4. Establish the TFC of each of the defined Flowgates as equal to: - For thermal limits, the System Operating Limit (SOL) of the Flowgate. - For voltage or stability limits, the flow that will respect the SOL of the Flowgate. R2.5. At a minimum, establish the TFC once per calendar year. R2.5.1. If notified of a change in the Rating by the Transmission Owner that would affect the TFC of a flowgate used in the AFC process, the TFC should be updated within seven calendar days of the notification. R2.6. Provide the Transmission Service Provider with the TFCs within seven calendar days of their establishment. Proposed Measure M2. The Transmission Operator shall provide evidence (such as studies and working papers) that all Flowgates that meet the criteria described in R2.1 are considered in its AFC calculations. (R2.1) M3. The Transmission Operator shall provide evidence (such as logs) that it updated its list of Flowgates at least once per calendar year. (R2.2) M4. The Transmission Operator shall provide evidence (such as logs and dated requests) that it updated the list of Flowgates within thirty calendar days from a request. (R2.3) M5. The Transmission Operator shall provide evidence (such as data or models) that it determined the TFC for each Flowgate as defined in R2.4. (R2.4) M6. The Transmission Operator shall provide evidence (such as logs) that it established the TFCs for each Flowgate in accordance with the timing defined in R2.5. (R2.5) M7. The Transmission Operator shall provide evidence (such as logs and electronic communication) that it provided the Transmission Service Provider with updated TFCs within seven calendar days of their determination. (R2.6) Attributes of the requirement Binary Timing X Omission X Communication X Quality X Other SDT Proposed Lower VSL One or more of the following: • The Transmission Operator established its list of Flowgates less frequently than once per calendar year, but not more than three months late as described in R2.2. • The Transmission Operator established its list of Flowgates more than thirty days, but not more than sixty days, following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator has not updated its Flowgate TFC when notified by theTransmission Owner in more than 7 days, but it has not been more than 14 days since the notification (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs within seven days (one week) of their determination, but is has not been more than 14 days (two weeks) since their determination. CEDRP Proposed VSL OK – No Comments SDT Proposed Moderate VSL One or more of the following: • The Transmission Operator did not include a Flowgate in their AFC calculations that met the criteria described in R2.1. • The Transmission Operator established its list of Flowgates more than three months late, but not more than six months late as described in R2.2. • The Transmission Operatorestablished its list of Flowgates more than sixty days, but not more than ninety days, following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year, and it has been not more than 15 months since the last update. • The Transmission Operator has not updated its Flowgate TFC when notified by the Transmission Owner in more than 14 days, but it has not been more than 21 days since the notification (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 14 days (two weeks) of their determination, but is has not been more than 21 days (three weeks) since their determination CEDRP Proposed VSL One or more of the following: • The Transmission Operator did not include 1 or less than 25% of the total number of Flowgates in their AFC calculations that met the criteria described in R2.1. • The Transmission Operator established its list of Flowgates more than three months late, but not more than six months late as described in R2.2. • The Transmission Operator established its list of Flowgates more than sixty days, but not more than ninety days, following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year, and it has been not more than 15 months since the last update. • The Transmission Operator has not updated its Flowgate TFC when notified by the Transmission Owner in more than 14 days, but it has not been more than 21 days since the notification (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 14 days (two weeks) of their determination, but is has not been more than 21 days (three weeks) since their determination SDT Proposed High VSL One or more of the following: • The Transmission Operator did not include two to five Flowgates in their AFC calculations that met the criteria described in R2.1. • The Transmission Operator established its list of Flowgates more than six months late, but not more than nine months late as described in R2.2. • The Transmission Operator established its list of Flowgates more than ninety days, but not more than 120 days, following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year, and it has been more than 15 months but not more than 18 months since the last update. • The Transmission Operator has not updated its Flowgate TFCs when notified by the Transmission Owner in more than 21 days, but it has not been more than 28 days since the notification (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 21 days (three weeks) of their determination, but is has not been more than 28 days (four weeks) since their determination. CEDRP Proposed VSL One or more of the following: • The Transmission Operator did not include two or between 25 to 50% of the total number of Flowgates in their AFC calculations that met the criteria described in R2.1. • The Transmission Operator established its list of Flowgates more than six months late, but not more than nine months late as described in R2.2. • The Transmission Operator established its list of Flowgates more than ninety days, but not more than 120 days, following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year, and it has been more than 15 months but not more than 18 months since the last update. • The Transmission Operator has not updated its Flowgate TFCs when notified by the Transmission Owner in more than 21 days, but it has not been more than 28 days since the notification (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 21 days (three weeks) of their determination, but is has not been more than 28 days (four weeks) since their determination. SDT Proposed Severe VSL One or more of the following: • The Transmission Operator did not include six or more Flowgates in their AFC calculations that met the criteria described in R2.1. • The Transmission Operator established its list of Flowgates more than nine months late as described in R2.2. • The Transmission Operator did not establish its list of internal Flowgates as described in R2.2. • The Transmission Operator established its list of Flowgates more than 120 days following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator did not establish its list of external Flowgates following a request to create, modify or delete an external flowgate as described in R2.3. • The Transmission Operator did not determine the TFC for a flowgate as described in R2.4. • The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year, and it has been more than 18 months since the last update. (R2.5) • The Transmission Operator has not updated its Flowgate TFCs when notified by the Transmission Owner in more than 28 calendar days (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 28 days (4 weeks) of their determination. CEDRP Proposed VSL One or more of the following: • The Transmission Operator did not include more than 50% of the total number of Flowgates in their AFC calculations that met the criteria described in R2.1. • The Transmission Operator established its list of Flowgates more than nine months late as described in R2.2. • The Transmission Operator did not establish its list of internal Flowgates as described in R2.2. • The Transmission Operator established its list of Flowgates more than 120 days following a request to create, modify or delete a flowgate as described in R2.3. • The Transmission Operator did not establish its list of external Flowgates following a request to create, modify or delete an external flowgate as described in R2.3. • The Transmission Operator did not determine the TFC for a flowgate as described in R2.4. • The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year, and it has been more than 18 months since the last update. (R2.5) • The Transmission Operator has not updated its Flowgate TFCs when notified by the Transmission Owner in more than 28 calendar days (R2.5.1) • The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 28 days (4 weeks) of their determination. FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? No. 3. Is it truly a “binary” requirement? N/A 4. If yes, is the VSL assignment consistent with other binary requirement assignments? N/A 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? TOs may have less than 6 flowgates. It should be based on %. 6. Does the VSL redefine or undermine the stated requirement? See note 5. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R3 MOD-030-02 Requirement (including sub-requirements) R3. The Transmission Operator shall make available to the Transmission Service Provider a Transmission model to determine Available Flowgate Capability (AFC) that meets the following criteria: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R3.1. Contains generation Facility Ratings, such as generation maximum and minimum output levels, specified by the Generator Owners of the Facilities within the model. R3.2. Updated at least once per day for AFC calculations for intra-day, next day, and days two through 30. R3.3. Updated at least once per month for AFC calculations for months two through 13. R3.4. Contains modeling data and system topology for the Facilities within its Reliability Coordinator’s Area. Equivalent representation of radial lines and Facilities161kV or below is allowed. R3.5. Contains modeling data and system topology (or equivalent representation) for immediately adjacent and beyond Reliability Coordination Areas. Proposed Measure M8. The Transmission Operator shall provide evidence (such as written documentation, logs, models, and data) that the Transmission model used to determine AFCs contains the information specified in R3. (R3) Attributes of the requirement Binary Timing X Omission X Communication Quality X Other SDT Proposed Lower VSL One or more of the following: • The Transmission Operator used one to ten Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission Operator did not update the model per R3.2 for one or more • calendar days but not more than 2 calendar days • The Transmission Operator did not update the model for per R3.3 for one or more months but not more than six weeks CEDRP Proposed VSL One or more of the following: • The Transmission Operator used greater than zero, but less than 10% of Facility Ratings that were different or based on old information from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission Operator did not update the model per R3.2 for one or more • calendar days but not more than 2 calendar days • The Transmission Operator did not update the model for per R3.3 for one or more months but not more than six weeks SDT Proposed Moderate VSL One or more of the following: • The Transmission Operator used eleven to twenty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission Operator did not update the model per R3.2 for more than 2 calendar days but not more than 3 calendar days • The Transmission Operator did not update the model for per R3.3 for more than six weeks but not more than eight weeks CEDRP Proposed VSL One or more of the following: • The Transmission Operator used 25%, but not more than 50% of Facility Ratings that were different or based on old information from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission Operator did not update the model per R3.2 for more than 2 calendar days but not more than 3 calendar days • The Transmission Operator did not update the model for per R3.3 for more than six weeks but not more than eight weeks SDT Proposed High VSL One or more of the following: • The Transmission Operator used twenty-one to thirty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission Operator did not update the model per R3.2 for more than 3 calendar days but not more than 4 calendar days • The Transmission Operator did not update the model for per R3.3 for more than eight weeks but not more than ten weeks CEDRP Proposed VSL One or more of the following: • The Transmission Operator used 50%, but not more than 75% of Facility Ratings that were different or based on old information from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission Operator did not update the model per R3.2 for more than 3 calendar days but not more than 4 calendar days • The Transmission Operator did not update the model for per R3.3 for more than eight weeks but not more than ten weeks SDT Proposed Severe VSL One or more of the following: • The Transmission Operator did not update the model per R3.2 for more than 4 calendar days • The Transmission Operator did not update the model for per R3.3 for more than ten weeks • The Transmission Operator used more than thirty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission operator did not include in the Transmission model detailed modeling data and topology for its own Reliability Coordinator area. • The Transmission operator did not include in the Transmission modeling data and topology for immediately adjacent and beyond Reliability Coordinator area. CEDRP Proposed VSL One or more of the following: • The Transmission Operator did not update the model per R3.2 for more than 4 calendar days • The Transmission Operator did not update the model for per R3.3 for more than ten weeks • The Transmission Operator used more than 75% of Facility Ratings that were different or based on old information from those specified by a Transmission or Generator Owner in their Transmission model. • The Transmission operator did not include in the Transmission model detailed modeling data and topology for its own Reliability Coordinator area. • The Transmission operator did not include in the Transmission modeling data and topology for immediately adjacent and beyond Reliability Coordinator area. FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? No. 3. Is it truly a “binary” requirement? N/A 4. If yes, is the VSL assignment consistent with other binary requirement assignments? N/A 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Number of Facility Ratings should be based on %. 6. Does the VSL redefine or undermine the stated requirement? SDT Proposed VSLs assume that the entity may have more than 30 facility ratings 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R4 MOD-030-02 Requirement (including sub-requirements) R4. When calculating AFCs, the Transmission Service Provider shall represent the impact of Transmission Service as follows: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] - If the source, as specified in the ATCID, has been identified in the reservation and it is discretely modeled in the Transmission Service Provider’s Transmission model, use the discretely modeled point as the source. - If the source, as specified in the ATCID, has been identified in the reservation and the point can be mapped to an “equivalence” or “aggregate” representation in the Transmission Service Provider’s Transmission model, use the modeled equivalence or aggregate as the source. - If the source, as specified in the ATCID, has been identified in the reservation and the point cannot be mapped to a discretely modeled point or an “equivalence” representation in the Transmission Service Provider’s Transmission model, use the immediately adjacent Balancing Authority associated with the Transmission Service Provider from which the power is to be received as the source. - If the source, as specified in the ATCID, has not been identified in the reservation use the immediately adjacent Balancing Authority associated with the Transmission Service Provider from which the power is to be received as the source. - If the sink, as specified in the ATCID, has been identified in the reservation and it is discretely modeled in the Transmission Service Provider’s Transmission model, use the discretely modeled point as the sink. - If the sink, as specified in the ATCID, has been identified in the reservation and the point can be mapped to an “equivalence” or “aggregate” representation in the Transmission Service Provider’s Transmission model, use the modeled equivalence or aggregate as the sink. - If the sink, as specified in the ATCID, has been identified in the reservation and the point cannot be mapped to a discretely modeled point or an “equivalence” representation in the Transmission Service Provider’s Transmission model, use the immediately adjacent Balancing Authority associated with the Transmission Service Provider receiving the power as the sink. - If the sink, as specified in the ATCID, has not been identified in the reservation use the immediately adjacent Balancing Authority associated with the Transmission Service Provider receiving the power as the sink. Proposed Measure M9. The Transmission Service Provider shall provide evidence (such as written documentation and data) that the modeling of point-to-point reservations was based on the rules described in R4. (R4) Attributes of the requirement Binary Timing Omission X Communication Quality X Other SDT Proposed Lower VSL The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than zero, but not more than 5% of all reservations; or more than zero, but not more than 1 reservation, whichever is greater.. CEDRP Proposed VSL OK – No Comments SDT Proposed Moderate VSL The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than 5%, but not more than 10% of all reservations; or more than 1, but not more than 2 reservations, whichever is greater.. CEDRP Proposed VSL OK – No Comments SDT Proposed High VSL The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than 10%, but not more than 15% of all reservations; or more than 2, but not more than 3 reservations, whichever is greater.. CEDRP Proposed VSL OK – No Comments SDT Proposed Severe VSL The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than 15% of all reservations; or more than 3 reservations, whichever is greater.. CEDRP Proposed VSL OK – No Comments FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? No. 3. Is it truly a “binary” requirement? N/A 4. If yes, is the VSL assignment consistent with other binary requirement assignments? N/A 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R5 MOD-030-02 Requirement (including sub-requirements) R5. When calculating AFCs, the Transmission Service Provider shall: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R5.1. Use the models provided by the Transmission Operator. R5.2. Include in the transmission model expected generation and Transmission outages, additions, and retirements within the scope of the model as specified in the ATCID and in effect during the applicable period of the AFC calculation for the Transmission Service Provider’s area, all adjacent Transmission Service Providers, and any Transmission Service Providers with which coordination agreements have been executed. R5.3. For external Flowgates, identified in R2.1.4, use the AFC provided by the Transmission Service Provider that calculates AFC for that Flowgate. Proposed Measure M10. The Transmission Service Provider shall provide evidence including the models received from Transmission Operators and other evidence (such as documentation and data) to show that it used the Transmission Operator’s models in calculating AFC. (R5.1) M11. The Transmission Service Provider shall provide evidence (such as written documentation, electronic communications, and data) that all expected generation and Transmission outages, additions, and retirements were included in the AFC calculation as specified in the ATCID. (R5.2) M12. The Transmission Service Provider shall provide evidence (such as logs, electronic communications, and data) that AFCs provided by third parties on external Flowgates were used instead of those calculated by the Transmission Operator. (R5.3) Attributes of the requirement Binary Timing Omission X Communication Quality X Other SDT Proposed Lower VSL The Transmission Service Provider did not include in the AFC process one to ten expected generation or Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. CEDRP Proposed VSL The Transmission Service Provider did not include in the AFC process 5% to 10% of expected generation or Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. SDT Proposed Moderate VSL The Transmission Service Provider did not include in the AFC process eleven to twentyfive expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. CEDRP Proposed VSL The Transmission Service Provider did not include in the AFC process 10% to 25% of expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. SDT Proposed High VSL The Transmission Service Provider did not include in the AFC process twenty-six to fifty expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. CEDRP Proposed VSL The Transmission Service Provider did not include in the AFC process 25% to 50% of expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. SDT Proposed Severe VSL One or more of the following: • The Transmission Service Provider did not use the model provided by the Transmission Operator. • The Transmission Service Provider did not include in the AFC process more than fifty expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. • The Transmission Service provider did not use AFC provided by a third party. CEDRP Proposed VSL One or more of the following: • The Transmission Service Provider did not use the model provided by the Transmission Operator. • The Transmission Service Provider did not include in the AFC process more than 50% of expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. • The Transmission Service provider did not use AFC provided by a third party. FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? No. 3. Is it truly a “binary” requirement? N/A 4. If yes, is the VSL assignment consistent with other binary requirement assignments? N/A 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? VSLs should be based on % 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R6 MOD-030-02 Requirement (including sub-requirements) R6. When calculating the impact of ETC for firm commitments (ETCFi) for all time periods for a Flowgate, the Transmission Service Provider shall sum the following: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R6.1. The impact of firm Network Integration Transmission Service, including the impacts of generation to load, in the model referenced in R5.2 for the Transmission Service Provider’s area, based on: R6.1.1. Load forecast for the time period being calculated, including Native Load and Network Service load R6.1.2. Unit commitment and Dispatch Order, to include all designated network resources and other resources that are committed or have the legal obligation to run as specified in the Transmission Service Provider's ATCID. R6.2. The impact of any firm Network Integration Transmission Service, including the impacts of generation to load in the model referenced in R5.2 and has a distribution factor equal to or greater than the percentage1 used to curtail in the Interconnectionwide congestion management procedure used by the Transmission Service Provider, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed based on:. R6.2.1. Load forecast for the time period being calculated, including Native Load and Network Service load R6.2.2. Unit commitment and Dispatch Order, to include all designated network resources and other resources that are committed or have the legal obligation to run as specified in the Transmission Service Provider's ATCID. R6.3. The impact of all confirmed firm Point-to-Point Transmission Service expected to be scheduled, including roll-over rights for Firm Transmission Service contracts, for the Transmission Service Provider’s area. R6.4. The impact of any confirmed firm Point-to-Point Transmission Service expected to be scheduled, filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers, including roll-over rights for Firm Transmission Service contracts having a distribution factor equal to or greater than the percentage2 used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R6.5. The impact of any Grandfathered firm obligations expected to be scheduled or expected to flow for the Transmission Service Provider’s area. R6.6. The impact of any Grandfathered firm obligations expected to be scheduled or expected to flow that have a distribution factor equal to or greater than the percentage3 used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R6.7. The impact of other firm services determined by the Transmission Service Provider. Proposed Measure M13. The Transmission Service Provider shall demonstrate compliance with R6 by recalculating firm ETC for any specific time period as described in (MOD-001 R2), using the requirements defined in R6 and with data used to calculate the specified value for the designated time period. The data used must meet the requirements specified in MOD-030-1 and the ATCID. To account for differences that may occur when recalculating the value (due to mixing automated and manual processes), any recalculated value that is within +/- 15% or 15 MW, whichever is greater, of the originally calculated value, is evidence that the Transmission Service Provider used the requirements defined in R6 to calculate its firm ETC. (R6) Attributes of the requirement Binary X Timing Omission Communication Quality X Other SDT Proposed Lower VSL For a specified period, the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period, and the absolute value difference was more than 15% of the value calculated in the measure or 15MW, whichever is greater, but not more than 25% of the value calculated in the measure or 25MW, whichever is greater.. CEDRP Proposed VSL OK – No Comments SDT Proposed Moderate VSL For a specified period, the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period, and the absolute value difference was more than 25% of the value calculated in the measure or 25MW, whichever is greater, but not more than 35% of the value calculated in the measure or 35MW, whichever is greater. CEDRP Proposed VSL OK – No Comments SDT Proposed High VSL For a specified period, the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period, and the absolute value difference was more than 35% of the value calculated in the measure or 35MW, whichever is greater, but not more than 45% of the value calculated in the measure or 45MW, whichever is greater. CEDRP Proposed VSL OK – No Comments SDT Proposed Severe VSL For a specified period, the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period, and the absolute value difference was more than 45% of the value calculated in the measure or 45MW, whichever is greater. CEDRP Proposed VSL OK – No Comments FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? Yes 3. Is it truly a “binary” requirement? No. 4. If yes, is the VSL assignment consistent with other binary requirement assignments? Yes. 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R7 MOD-030-02 Requirement (including sub-requirements) R7. When calculating the impact of ETC for non-firm commitments (ETCNFi) for all time periods for a Flowgate the Transmission Service Provider shall sum: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R7.1. The impact of all confirmed non-firm Point-to-Point Transmission Service expected to be scheduled for the Transmission Service Provider’s area. R7.2. The impact of any confirmed non-firm Point-to-Point Transmission Service expected to be scheduled, filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers, that have a distribution factor equal to or greater than the percentage4 used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R7.3. The impact of any Grandfathered non-firm obligations expected to be scheduled or expected to flow for the Transmission Service Provider’s area. R7.4. The impact of any Grandfathered non-firm obligations expected to be scheduled or expected to flow that have a distribution factor equal to or greater than the percentage5 used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R7.5. The impact of non-firm Network Integration Transmission Service serving Load within the Transmission Service Provider’s area (i.e., secondary service), to include load growth, and losses not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. R7.6. The impact of any non-firm Network Integration Transmission Service (secondary service) with a distribution factor equal to or greater than the percentage6 used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider, filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R7.7. The impact of other non-firm services determined by the Transmission Service Provider. Proposed Measure M14. The Transmission Service Provider shall demonstrate compliance with R7 by recalculating non-firm ETC for any specific time period as described in (MOD-001 R2), using the requirements defined in R7 and with data used to calculate the specified value for the designated time period. The data used must meet the requirements specified in the standard and the ATCID. To account for differences that may occur when recalculating the value (due to mixing automated and manual processes), any recalculated value that is within +/- 15% or 15 MW, whichever is greater, of the originally calculated value, is evidence that the Transmission Service Provider used the requirements in R7 to calculate its non-firm ETC. (R7) Attributes of the requirement Binary X Timing Omission Communication Quality X Other SDT Proposed Lower VSL For a specified period, the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period, and the absolute value difference was more than 15% of the value calculated in the measure or 15MW, whichever is greater, but not more than 25% of the value calculated in the measure or 25MW, whichever is greater. CEDRP Proposed VSL OK – No Comments SDT Proposed Moderate VSL For a specified period, the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period, and the absolute value difference was more than 25% of the value calculated in the measure or 25MW, whichever is greater, but not more than 35% of the value calculated in the measure or 35MW, whichever is greater. CEDRP Proposed VSL OK – No Comments SDT Proposed High VSL For a specified period, the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period, and the absolute value difference was more than 35% of the value calculated in the measure or 35MW, whichever is greater, but not more than 45% of the value calculated in the measure or 45MW, whichever is greater. CEDRP Proposed VSL OK – No Comments SDT Proposed Severe VSL For a specified period, the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period, and the absolute value difference was more than 45% of the value calculated in the measure or 45MW, whichever is greater. CEDRP Proposed VSL OK – No Comments FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? Yes. 3. Is it truly a “binary” requirement? No. 4. If yes, is the VSL assignment consistent with other binary requirement assignments? Yes. 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R8 MOD-030-02 Requirement (including sub-requirements) R8. When calculating firm AFC for a Flowgate for a specified period, the Transmission Service Provider shall use the following algorithm (subject to allocation processes described in the ATCID): [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] AFCF = TFC – ETCFi – CBMi – TRMi + PostbacksFi + counterflowsFi Where: AFCF is the firm Available Flowgate Capability for the Flowgate for that period. TFC is the Total Flowgate Capability of the Flowgate. ETCFi is the sum of the impacts of existing firm Transmission commitments for the Flowgate during that period. CBMi is the impact of the Capacity Benefit Margin on the Flowgate during that period. TRMi is the impact of the Transmission Reliability Margin on the Flowgate during that period. PostbacksFi are changes to firm AFC due to a change in the use of Transmission Service for that period, as defined in Business Practices. counterflowsFi are adjustments to firm AFC as determined by the Transmission Service Provider and specified in their ATCID. Proposed Measure M15. Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates firm AFCs, as required in R8. Such documentation must show that only the variables allowed in R8 were used to calculate firm AFCs, and that the processes use the current values for the variables as determined in the requirements or definitions. Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows, TRM, CBM, etc…). The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider. (R8) Attributes of the requirement Binary Timing Omission X Communication Quality X Other Comments: The number of flowgates should not be specified in the VSLs as this can vary between entities. “Percentages should be used only on occasions that the author doesn’t know the number or can vary based on the entity involved” (as stated on page 31). SDT Proposed Lower VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than zero Flowgates, but not more than 5% of all Flowgates or 1 Flowgate (whichever is greater). CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than zero Flowgates, but not more than 5% of all Flowgates. SDT Proposed Moderate VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than 5% of all Flowgates or 1 Flowgates (whichever is greater), but not more than 10% of all Flowgates or 2 Flowgates (whichever is greater) CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than 5% of all Flowgates, but not more than 10% of all Flowgates. SDT Proposed High VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than 10% of all Flowgates or 2 Flowgates (whichever is greater), but not more than 15% of all Flowgates or 3 Flowgates (whichever is greater) CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than 10% of all Flowgates, but not more than 15% of all Flowgates. SDT Proposed Severe VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than 15% of all Flowgates or more than 3 Flowgates (whichever is greater). CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC, or used additional elements, for more than 15% of all Flowgates. FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? No. 3. Is it truly a “binary” requirement? No. 4. If yes, is the VSL assignment consistent with other binary requirement assignments? N/A 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes, it is clear and measureable. However, the measurement (M15), should be re-worded to clarify that all the variables allowed in R8 were used to calculate firm AFCs (regardless of whether they have a value of zero), and not just a sub-set of them. Of course, it should also be clear that no different or additional variables were used. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R9 MOD-030-02 Requirement (including sub-requirements) R9. When calculating non-firm AFC for a Flowgate for a specified period, the Transmission Service Provider shall use the following algorithm (subject to allocation processes described in the ATCID): [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] AFCNF = TFC – ETCFi – ETCNFi – CBMSi – TRMUi + PostbacksNFi + counterflows Where: AFCNF is the non-firm Available Flowgate Capability for the Flowgate for that period. TFC is the Total Flowgate Capability of the Flowgate. ETCFi is the sum of the impacts of existing firm Transmission commitments for the Flowgate during that period. ETCNFi is the sum of the impacts of existing non-firm Transmission commitments for the Flowgate during that period. CBMSi is the impact of any schedules during that period using Capacity Benefit Margin. TRMUi is the impact on the Flowgate of the Transmission Reliability Margin that has not been released (unreleased) for sale as non-firm capacity by the Transmission Service Provider during that period. PostbacksNF are changes to non-firm Available Flowgate Capability due to a change in the use of Transmission Service for that period, as defined in Business Practices. counterflowsNF are adjustments to non-firm AFC as determined by the Transmission Service Provider and specified in their ATCID. Proposed Measure M16. Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates non-firm AFCs, as required in R9. Such documentation must show that only the variables allowed in R9 were used to calculate non-firm AFCs, and that the processes use the current values for the variables as determined in the requirements or definitions. Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows, TRM, CBM, etc…). The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider. (R9) Attributes of the requirement Binary Timing Omission X Communication Quality X Other Comments: The number of flowgates should not be specified in the VSLs as this can vary between entities. “Percentages should be used only on occasions that the author doesn’t know the number or can vary based on the entity involved” (as stated on page 31). Also, corrected an editorial error: changed R8 to R9 in the VSLs SDT Proposed Lower VSL The Transmission Service Provider did not use all the elements defined in R8 when determining non-firm AFC, or used additional elements, for more than zero Flowgates, but not more than 5% of all Flowgates or 1 Flowgate (whichever is greater). CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than zero Flowgates, but not more than 5% of all Flowgates. SDT Proposed Moderate VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than 5% of all Flowgates or 1 Flowgate (whichever is greater), but not more than 10% of all Flowgates or 2 Flowgates (whichever is greater). CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than 5% of all Flowgates, but not more than 10% of all Flowgates. SDT Proposed High VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than 10% of all Flowgates or 2 Flowgates (whichever is greater), but not more than 15% of all Flowgates or 3 Flowgates (whichever is greater). CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than 10% of all Flowgates, but not more than 15% of all Flowgates. SDT Proposed Severe VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than 15% of all Flowgates or more than 3 Flowgates (whichever is greater). CEDRP Proposed VSL The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC, or used additional elements, for more than 15% of all Flowgates. FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? No. 3. Is it truly a “binary” requirement? No. 4. If yes, is the VSL assignment consistent with other binary requirement assignments? N/A 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes, it is clear and measureable. However, the measurement (M16), should be re-worded to clarify that all the variables allowed in R9 were used to calculate non-firm AFCs (regardless of whether they have a value of zero), and not just a sub-set of them. Ofcourse, it should also be clear that no different or additional variables were used. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R10 MOD-030-02 Requirement (including sub-requirements) R10. Each Transmission Service Provider shall recalculate AFC, utilizing the updated models described in R3.2, R3.3, and R5, at a minimum on the following frequency, unless none of the calculated values identified in the AFC equation have changed: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] R10.1. For hourly AFC, once per hour. Transmission Service Providers are allowed up to 175 hours per calendar year during which calculations are not required to be performed, despite a change in a calculated value identified in the AFC equation. R10.2. For daily AFC, once per day. R10.3. For monthly AFC, once per week. Proposed Measure M17. The Transmission Service Provider shall provide evidence (such as documentation, dated logs, and data) that it calculated AFC on the frequency defined in R10. (R10) Attributes of the requirement Binary X Timing X Omission Communication Quality Other SDT Proposed Lower VSL One or more of the following: • For Hourly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for one or more hours but not more than 15 hours, and was in excess of the 175-hour per year requirement. • For Daily, the values described in the AFC equation changed and the Transmission Service provider did not calculate for one or more calendar days but not more than 3 calendar days. • For Monthly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for seven or more calendar days, but less than 14 calendar days CEDRP Proposed VSL OK – No comment SDT Proposed Moderate VSL One or more of the following: • For Hourly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 15 hours but not more than 20 hours,and was in excess of the 175-hour per year requirement. • For Daily, the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 3 calendar days but not more than 4 calendar days. • For Monthly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for 14 or more calendar days, but less than 21 calendar days. CEDRP Proposed VSL OK – No comment SDT Proposed High VSL One or more of the following: • For Hourly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 20 hours but not more than 25 hours, and was in excess of the 175-hour per year requirement. • For Daily, the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 4 calendar days but not more than 5 calendar days. • For Monthly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for 21 or more calendar days, but less than 28 calendar days. CEDRP Proposed VSL OK – No comment SDT Proposed Severe VSL One or more of the following: • For Hourly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 25 hours, and was in excess of the 175-hour per year requirement. • For Daily, the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 5 calendar days. • For Monthly, the values described in the AFC equation changed and the Transmission Service provider did not calculate for 28 or more calendar days. CEDRP Proposed VSL OK – No comment FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? Yes 3. Is it truly a “binary” requirement? No. 4. If yes, is the VSL assignment consistent with other binary requirement assignments? Yes. 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? No. Standard – R11 MOD-030-02 Requirement (including sub-requirements) R11. When converting Flowgate AFCs to ATCs for ATC Paths, the Transmission Service Provider shall convert those values based on the following algorithm: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] ATC = min(P) P ={PATC1, PATC2,…PATCn} PATCn = Where: ATC is the Available Transfer Capability. P is the set of partial Available Transfer Capabilities for all “impacted” Flowgates honored by the Transmission Service Provider; a Flowgate is considered “impacted” by a path if the Distribution Factor for that path is greater than the percentage7 used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider on an OTDF Flowgate or PTDF Flowgate. PATCn is the partial Available Transfer Capability for a path relative to a Flowgate n. AFCn is the Available Flowgate Capability of a Flowgate n. DFnp is the distribution factor for Flowgate n relative to path p. Proposed Measure M18. The Transmission Service Provider shall provide evidence (such as documentation and data)when converting Flowgate AFCs to ATCs for ATC Paths, it follows the procedure described in R11. (R11) Attributes of the requirement Binary X Timing Omission Communication Quality X Other SDT Proposed Lower VSL N/A CEDRP Proposed VSL OK – No comment SDT Proposed Moderate VSL N/A CEDRP Proposed VSL OK – No comment SDT Proposed High VSL N/A CEDRP Proposed VSL OK – No comment SDT Proposed Severe VSL The Transmission Service Provider did not follow the procedure for converting Flowgate AFCs to ATCs described in R11. CEDRP Proposed VSL OK – No comment FERC Guidance for VSLs 1. Will the VSL assignment signal entities that less compliance than has been historically achieved is condoned? No. 2. Is the VSL assignment a binary requirement? Yes. 3. Is it truly a “binary” requirement? Yes, 4. If yes, is the VSL assignment consistent with other binary requirement assignments? Yes, 5. Is the VSL language clear & measurable (ambiguity removed)? If no, does the requirement or measure need to be revised? Yes. 6. Does the VSL redefine or undermine the stated requirement? No. 7. Is the VSL based on a single violation of the requirement (not multiple violations)? Yes.
Individual
Edward Davis
Entergy Services
Yes and No
See the additional item in #4 below that we would like addressed in this SAR.
Yes
 
No
 
In the earlier commenting stages on MOD-030-1, Entergy made the following comment and received clarification from the SDT. While this satified Entergy's concern regarding the SDT intent, it did not alleviate our concerns with future interpretations of the standard. Entergy: R3.5 - the phrase "and beyond" seems very open-ended. For the very near timeframes where state estimator models are used, this is the biggest concern. We cannot model neighboring systems in great detail because they do not allow that use of their CEII since we post these cases on our OASIS site. RESPONSE: R3.5 does not require modeling details in areas beyond your own - it allows equivalent representation which does not need to include CEII. Therefore, Entergy requests that the new SAR for MOD-030-2 be expanded to modify R3.5: "Contains modeling data and system topology for immediately adjacent Reliability Coordination Areas and beyond as necessary. Equivalent representation is allowed."
Group
FirstEnergy
Sam Ciccone
FirstEnergy Corp.
No
1. Every standard's purpose should be to increase, improve, or enhance the reliability of the BES. This purpose statement should be revised to state, "To increase reliability of the Bulk Electric System through consistency in the development, documentation, and implementation of transfer capability calculations for short-term use performed by entities using the Flowgate Methodology." 2. A variance should be added to the standard with regard to MOD-030 requirements that describe tasks which have been transferred by the MISO member transmission companies to the MISO organization. This transfer of responsibility is described in the MISO Transmission Owners Agreement and Attachment C of the MISO Open Access Transmission and Energy Market Tariff. The standard should include this variance to alleviate the compliance burden of creating delegation or JRO agreements on Transmission Operators (TOP) regarding the aforementioned tasks. It is FE's opinion that an Entity Variance as described in the NERC Reliability Standards Development Procedure is the appropriate mitigation measure. As described in the procedure, an Entity Variance is "Any variance from a NERC reliability standard that is proposed to apply to one entity or a subset of entities within a limited portion of a regional entity, such as a variance that would apply to a regional transmission organization or particular market or to a subset of bulk power system owners, operators, or users, shall be approved through the regular standards development process defined in the NERC Reliability Standards Development Procedure and shall be made part of the applicable NERC reliability standard." In accordance with the NERC Standard Development Procedure, the SAR process is the appropriate channel to include a variance. The procedure states: "Variances should be identified and considered when a SAR is posted for comment. Variances should also be considered in the drafting of a standard, with the intent to make any necessary variances a part of the initial development of a standard. The public posting allows for all impacted parties to identify the requirements of a NERC reliability standard that might require a variance." FE believes it is important to complete and include the MISO variance in conjunction with the drafting of the MOD-030-2 standard. FE requests the variance to cover TOP tasks as described in the following requirement: R2: Flowgate determination and calculation of TFC on flowgates.
Yes
 
Yes
See our comments in Question 1. There are conflicts between this standard and the MISO regional "regulatory functions".
The term "Grandfathered" is not a defined term in the NERC glossary and should not be capitalized in R6.5, R6.6, R7.3 and R7.4.
Individual
Kurt Conger
Energy Expert Services, Inc.
Yes
The proposed changes adequately reflect the concerns raised by parties regarding identification of flowgates.
Yes
 
No
 
 
Individual
Greg Lange
Public Utility District No. 2 of Grant County
Yes
The modifications to R2.1 are necessary to facilitate the manner in which WECC entities that use the Flowgate methodology to define Flowgates
Yes
The additions of R2.1.1.3 and R2.1.2.3 are appreciated as this permits the continued use of the process WECC entities that use the Flowgate methodology to define Flowgates, however, we believe that the below re-wording of these two sub-requirements is more precise and removes the vague phrase “protected by”. If any limiting element is kept within its limit for its associated worst contingency by operating within the limits of another Flowgate, then no new Flowgate needs to be established for such limiting elements or contingencies.
No
 
 
Individual
Kirit Shah
Ameren
Yes
 
Yes
 
No
 
AFC issues affect long term planning as well as planning in the Operating Time Horizon (go beyond 1 year). This is especially true when rollover rights are involved for requests that are 5 or more years in duration. The equivalent representation of facilities 161 kV and below is allowed, but this may lead to critical facilities being overlooked. This should be allowed only if these facilities are not limiting to transmission service and do not create constraints in real-time operation. The use of proxy flowgates should be discouraged. The term “and beyond” in R3.5 is not defined. This can be a concern when using state estimator models for near term analysis.
Individual
Rao Somayajula
ReliabilityFirst Corporation
Yes
 
Yes
 
No
 
 
Individual
Dan Rochester
Independent Electricity System Operator - Ontario
Yes
 
Yes
 
No
 
 
Individual
Larry Rodriguez
Entegra Power Group, LLC
No
I would include the language "equitable" to all entities involved. When Transmission Service Providers continue to have full control of the models built, the burden of "verification" is put on other entities to investigate consistency and transparancy.
No Preference
 
No Preference
 
These are more general, yet equally important comments considered applicable to not only MOD-030-2, but for the other MOD revisions as well: Stakeholders Participation: Stakeholders’ participation in the development and continued improvement of ATC standards and associated implementation is a key element to achieve success. NERC itself recognized the benefit and significance of the stakeholder process in the development of reliability standards. Order 693 at Cite 183. Thus, establishing forums and processes for stakeholders’ on-going participation at NERC and regional levels is a MUST. These stakeholder processes are required to vet issues and gain support for the initial approval of the ATC standard and on-going changes to it. NERC should clearly set out and document the processes by which comments and suggestion of stakeholders will be gathered, evaluated, and incorporated in the Standard. NERC Response15: NERC utilizes an ANSI-accredited process to ensure stakeholder participation, and encourages participation in any of its standards development efforts. Distribution Cut-off Factor: NERC should address the difference between distribution factor cut-off values for ATC calculations and the TLR process to ensure that this difference does not create undue discrimination. Additionally, a minimum value of 3% for distribution factor cut-off could be included in the ATC standard provided TSPs are given flexibility to use a higher cut-off value which could be set on a per flowgate basis. Further, consistent with the transparency requirement of Order 890, TSPs should be required to provide justification for the distribution factor cut-off value(s) used in their ATC calculations. Base Case Overloads (BCO): BCOs can occur in any of the ATC calculation time frames and may be spread over an entire region or be localized. In some TSP areas, BCOs have become a chronic situation and are mainly due to modeling flaws in the calculation of ETC. This causes serious problems for customers trying to get access to the transmission system. One of the main causes of chronic BCOs is the dispatch model which does not take into account transmission limitations and thus, yields unrealistic results. Furthermore, TSPs are not required to show that the dispatch model in their ATC calculations is feasible and resembles actual system operation. Thus, it is our opinion that the ATC standard has not fully met the ETC calculation requirement established in Order 890 at Cite 243 & 244. We believe that, in the calculation of ETC, all resources should be dispatched in a feasible and realistic manner such that transmission limitations are respected to the extent possible. The ATC standard should include clear & detailed guidelines for dispatching generating resources so that accurate and realistic models are used in ATC calculations which in turn should yield realistic ETC values. Dispatch Model and Must Run Units: The Standard has little detail and, practically, no guidelines on the dispatch model used in ATC/AFC calculations, except for the following statement included throughout the Standard: “Unit commitment and dispatch order, to include all designated network resources and other resources that are committed or have the legal obligation to run as they are expected to run”. This is a high level statement that needs to be developed into clear and measurable requirements to ensure consistency and fairness in ATC calculations. The dispatch model is the most important single factor in the determination of ATC values and, in particular, the modeling of Must Run Units, which is a critical issue. Consistent with the transparency requirement of Order 890, the generation dispatch model used in ATC calculations must be transparent and this issue must be addressed by the Standard. To reduce both the potential for undue discrimination and the number of “phantom congestion” incidents, and to improve accuracy of ATC calculations, NERC must develop detailed requirements for the dispatch model used in ATC calculations and establish measurements to evaluate compliance with the requirements. These requirements should be focused on the development and use of dispatch models that are realistic and consistent with well-established operational practices. To ensure that the model resembles actual system operation, the dispatch model should be benchmarked against real-time dispatch and consistency checks should be performed across the various ATC time frames. Consistency Between ATC calculations and Operational & Long-Term Expansion Studies: FERC Order 890/Cite 292 & 237 are very clear about requiring TSPs to use data and modeling assumptions for ATC calculations that are consistent with those used in operations planning and long-term system expansion studies. FERC clearly states its expectation in the following extract of Order 890/Cite 292: “We find that requiring consistency in the data and modeling assumptions used for ATC calculations will remedy the potential for undue discrimination by eliminating discretion and ensuring comparability in the manner in which a transmission provider operates and plans its system to serve native load and the manner in which it calculates ATC for service to third parties”. Furthermore, FERC establishes the following requirement in Citation 237 of Order 890: “We direct public utilities, working through NERC, to address, through the reliability standards process, any differences in developing TTC/TFC for transmission provided under the pro forma OATT and for transfer capability for native load and reliability assessment studies”. It is known that some Transmission Providers use a number of procedures such as: switching operating guides, generation re-dispatch, dropping load, etc. to mitigate transmission limit violations when performing reliability assessments of their systems in the planning horizon. Based on the application of mitigation procedures, these TSPs conclude that their transmission systems are reliable and thus, no transmission upgrades/reinforcements are needed. However, these mitigation procedures are not made available to third parties requesting transmission service and, as a result of this, transmission service requests are refused or the requestor is assigned financial responsibility for upgrading constrained facilities which could be mitigated by the application of the TSP operating procedures. Furthermore, these mitigation procedures typically are not included in the ATC models, which leads to artificial overloads, negative ATC/AFC, and the unduly discriminatory denial of transmission service. We believe that the MODs should fully incorporate the FERC directive in Order 890/Cite 292 & 237 and explicitly require TSPs to incorporate ALL data, modeling assumptions, and mitigation procedures used in operations planning and long-term expansion studies in their ATC/AFC models and calculations. Benchmarking of ATC Models: Order 890 at Cite 290 & 291 requires NERC to modify ATC-related standards to incorporate requirements for the periodic review, update, and benchmark of models used for ATC calculations. FERC states the following in Cite 290: “this [requirement] means that the models should be updated and benchmarked to actual events. We find that this requirement is essential in order to have an accurate simulation of the performance of the grid and from which to comparably calculate ATC, therefore increasing transparency and decreasing the potential for undue discrimination by transmission providers”. Adjacent Systems Representation: In order to produce accurate ATCs, it is not enough to merely check that adjacent systems are included in the model. Instead, it is critical to validate the performance of these models on an on-going basis and ensure that adjacent systems are being properly updated with discrete elements in TSP models with data such as: load, generation profile, net interchange, transactions, and outages, provided by adjacent system entities.
Individual
Jason Shaver
American Transmission Company
Yes
 
Yes
R2.1.3: group the exceptions at the end of the requirement for more clarity.
No
 
 
Group
MRO NERC Standards Review Subcommittee
Chuck Lawrence
ATC
No
The MRO suggests that the SAR Detailed Description should be expanded to review the criteria of flowgates to allow a waiver for small Transmission Service Providers or other appropriate remedies in non-RTO areas so that the number of flowgates is not excessive.
No
The MRO suggests that: Revise 2.1 to allow a waiver for small Transmission Service Providers or other appropriate remedies in non-RTO areas so that the number of flowgates is not excessive. Another appropriate remedy would be to exclude the need for a flowgate, where interconnection wide congestion management was a result of unusual operation conditions that are not reasonably expected to frequently occur again (such as, multiple prior outages of transmission facilities and/or critical generators). Revise R2.1.1 to: “… Available Transfer Capability (ATC) Paths …”, to give the meaning of the ATC acronym the first time that it occurs in the standard. Clarify that R2.1.1.3 and R2.1.2.3 may be applied separately in different operating conditions. Revise R2.1.3 to group all of the exceptions at the end of the requirement for more clarity.
No
 
The MRO suggests that: Remove the definition of ATC in R1.1 because it was already stated in the 4.1.1 of the Applicability section. In M13, change ‘specified in MOD-030-1’ to ‘specified in this standard’ because it should be MOD-030-2 for this version and it will be easy to overlook updating this item in future versions. In R6.2, the numeral of the first footnote superscript should be “1”, not “2”. If possible the footnote superscripts in R6.4, R6.6, R7.2, R7.4, and R7.6 should be “1” because they all refer to the same footnote text. The MRO suggests the drafting team prepare a white paper to explain application of this standard for various responsible entities. For example the MRO need to discuss the use of ATC paths in R2.1.1, R2.1.2, and R2.1.3. To understand the proper application of the requirement.
Individual
Kris Manchur
Manitoba Hydro
Yes
 
No
Manitoba Hydro agrees with the changes to R2.1, R2.2 and R2.3. Manitoba Hydro continues to question why is it only MOD 30 that requires a conversion formula? If standards are to be comparable, shouldn't all three standards (MOD 28, MOD 29 and MOD 30) have as a requirement to convert transmission capability from one method to the other? If changes are made to MOD 28 and MOD 29 for requiring conversion from method to the other, Manitoba Hydro may consider endorsing R11. Manitoba Hydro continues to be concerned that conversion from AFC to ATC cannot always be easily calculated in a formula when different assumptions are used for calculating transmission capability.
No
 
 
Individual
Jay Seitz
US Bureau of Reclamation
Yes
 
Yes
The modifications to R2.1 are necessary to facilitate the manner in which WECC entities that use the Flowgate methodology to define Flowgates. The additions of R2.1.1.3 and R2.1.2.3 are appreciated as this permits the continued use of the process WECC entities that use the Flowgate methodology to define Flowgates, however, we believe that the below re-wording of these two sub-requirements is more precise and removes the vague phrase "protected by". If any limiting element is kept within its limit for its associated worst Contingency by operating within the limits of another Flowgate, then no new Flowgate needs to be established for such limiting elements or Contingencies.
No