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 Individual or group.NameOrganizationGroup NameLead ContactQuestion 1Question 2Question 2 CommentsQuestion 3Question 3 CommentsQuestion 4 Comments
IndividualJack Cashin/Barry GreenEPSA  Through this revision process, some of the MOD standards have included an explicit requirement for consistency between planning assumptions and modeling assumptions used in calculation of ATC. We believe this is appropriate and should be included in MOD 028.  no comment no commentno comment
IndividualJim UseldingerKansas City Power & Light  The Transmission Service Provider should be added along with TOP to perform these functions in all requirementsYes Yes  
IndividualPaul RochaCenterPoint Energy       The group of standards is for ATC and TRM methodologies that are not used in ERCOT. CenterPoint Energy is concerned that ERCOT might have to adopt the ATC and TRM methodologies prescribed in these standards, which we believe would not add value to the ERCOT region and could increase congestion in the region. Accordingly, CenterPoint Energy previously submitted comments to these standards asking for an exemption for the ERCOT region. We find the proposed standards unacceptable unless the following provision is added to each standard: This standard does not apply to ERCOT or any other region that operates as a single control area.
Group  SERC ATCWGDoug Bailey Yes Yes  
IndividualH. Steven MyersERCOT ISO  Requirement 1: I suggest modifying the requirement to state: "Each Transmission Service Provider with ATC Path(s) shall include in its Available Transfer Capability Implementation Document (ATCID), at a minimum, the following information relative to its methodology for determining TTC:" Requirement 2: I suggest modifying the requirement to state: "When calculating TTC for ATC Paths, the Transmission Operator with ATC Path(s) shall use a Transmission model that contains all of the following:" Requirement 3: I suggest modifying the requirement to state: "When calculating TTCs for ATC Paths, the Transmission Operator with ATC Path(s) shall include the following data for the Transmission Service Provider’s area. The Transmission Operator with ATC Path(s) shall also include the following data associated with Facilities that are explicitly represented in the Transmission model, as provided by adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed:" Requirement 4: I suggest modifying the requirement to state: "When calculating TTCs for ATC Paths, the Transmission Operator with ATC Path(s) shall meet all of the following conditions:" Requirement 5: I suggest modifying the requirement to state: "Each Transmission Operator with ATC Path(s) shall establish TTC for each ATC Path as defined below:" Requirement 6: I suggest modifying the requirement to state: "Each Transmission Operator with ATC Path(s) shall establish TTC for each ATC Path using the following process:" Requirement 7: I suggest modifying the requirement to state: "The Transmission Operator with ATC Path(s) shall provide the Transmission Service Provider of that ATC Path with the most current value for TTC for that ATC Path no more than:" Requirement 8: I suggest modifying the requirement to state: "When calculating Existing Transmission Commitments (ETCs) for firm commitments (ETCF) for all time periods for an ATC Path the Transmission Service Provider with ATC Path(s) shall use the following algorithm:" Requirement 9: I suggest modifying the requirement to state: "When calculating ETC for non-firm commitments (ETCNF) for all time periods for an ATC Path the Transmission Service Provider with ATC Path(s) shall use the following algorithm:" Requirement 10: I suggest modifying the requirement to state: "When calculating firm ATC for an ATC Path for a specified period, the Transmission Service Provider with ATC Path(s) shall utilize the following algorithm:" Requirement 11: I suggest modifying the requirement to state: "When calculating non-firm ATC for a ATC Path for a specified period, the Transmission Service Provider with ATC Path(s) shall use the following algorithm:"    I suggest modifying the Applicability section as follows: "4.1. Each Transmission Operator with ATC Path(s) that uses the Area Interchange Methodology to calculate Total Transfer Capabilities (TTCs) for ATC Paths." "4.2. Each Transmission Service Provider with ATC Path(s) that uses the Area Interchange Methodology to calculate Available Transfer Capabilities (ATCs) for ATC Paths."
Group  NERC RTOSDTJim Case, Chair     The Real Time Operation Standards Drafting Team is concerned that the proposed MOD standards do not include any reference to the Planning and Operating Limits mandated by the current FAC, IRO and TOP standards. These standards already include transmission flow limits both in the longer term planning time frame as well as the shorter term operating time frame. The proposed MOD standards seem to be establishing procedures to calculate the commercial boundaries without a direct link to the required reliability boundaries. ============================================================= MOD-001 R6 states that the TTC “use assumptions” no more limiting than those used in planning. The RTO SDT would ask shouldn’t TTC’s be required to be “no less limiting” than the SOLs / IROLs computed for the system? Current NERC standards are not just asset limits, they are also system limits. The current standards require that limits be calculated that recognize both local and wide-area impacts. The RTO SDT believes that by at least linking (if not entirely eliminating) the MOD standards to the current SOLs / IROLs requirements, the Industry would be more correctly linking how the system MUST BE operated to any NAESB business practice. Indeed it would seem that current tariffs are based on the computations used in current planning and operating environments. By using the current SOL / IROL limits the procedural / prescriptive requirement in MOD-001 R9 et al would be unnecessary (i.e. they would revert back to the FAC and IRO requirements) The questions for the ATC SDT: • How do these MOD standards relate to the SOLs / IROLs • Why should these ATC/TTC limits be decoupled from the SOLs / IROLs • Shouldn’t the long-term SOL / IROL limits computed in Planning be the TTC for the system (or at least the basis for the TTC) • Shouldn’t the short-term SOL / IROL be the basis for the ATC for the system? MOD-008 computes margins. By coordinating the MOD standards with the SOL / IROL standards, the only Business (not NERC) requirement may be to define the options on how the TSP could couple the various SOL / IROL values that it obtains from its RCs and TOPs. MOD-028 By using SOLs / IROLs there would be no need to get into ATC / AFC “methodologies”. Indeed standards that include “alternatives” are not defining a single “standard approach”. But by using specific planning and operating limits the methodologies become irrelevant. The “limit” becomes explicit and well-defined. Any margins or variations about those limits would then be obvious and transparent. What is most important is respecting the reliability-based limits and not how the commercial value is computed. If this idea of using SOLs / IROLs as the limit(s) or at least the basis for those commercial limits, then the TSP becomes a coordinator of which values to use for the commercial periods. The TSP would not be the computer of those limits. Thus MOD-028 could become a business practice for posting – rather then a standard for computations.
Group  NPCC Regional Standards CommitteeGuy V. Zitoa. R4.1: The "its" before ATCID should be replaced with "the" or “the Transmission Service Provider’s” since the ATCID is the TSP’s document. Same change to M4. b. R6.4: In general, a TOP doesn’t have contractual rights of a jointly-owned or allocated facility, whereas the TSP does. We suggest this requirement be revised to “For ATC Paths whose capacity uses jointly-owned or allocated Facilities, limit TTC for each Transmission Operator so the TTC does not exceed the contractual rights of the Transmission Service Provider of that ATC path.” c. M11: Same comment on M10 also applies here for R9 NoNo, those requirements (at least R5 and R6) that hold the TOP responsible for establishing TTCs should be assigned a Medium since TTCs set the reliability boundary, like an SOL or IROL, within which the TSP may provide transmission services. Failure to establish TTCs may result in the TSP over-selling transmission services beyond the reliability bounds, risking the BES to unreliable operation.    
IndividualThad NessAEP       The Applicability of this Standard should be solely upon the TSP, the Transmission Operator should not be subject to this Standard. From the previous set of responses, it is the apparent belief of the SDT that the calculation of ATC is needed for reliability (response to AECI for example). We disagree. Considering that ATC is a mathematical amalgamation of forecasted system conditions (load, outages, generation dispatch, others’ transactions, etc) compounded and adjusted by margins (TRM and CBM of own entity and other systems), using the calculated ATC to assess real or near real time transmission reliability would be – at best – unwise. Transmission Reliability can be assessed by monitoring specific and individual Facility loadings and/or other parameters, for example. The calculation of ATC and the value of resultant ATC is exactly for the purpose stated in the definition of ATC: “A measure of … capability….for further commercial activity” – and note the definition does not infer ATC is a measure of reliability. Granted, ATC is calculated FROM reliability derived values and concepts (such as ratings, contingency analysis aspects, SOLs etc), BUT the resultant ATC values are not an assessment of transmission reliability – and therefore not a function for the Transmission Operators, but rather the Transmission Service Provider. In addition, the Purpose statement is unclear and perhaps nonsensical. Is the purpose “to increase consistency and reliability in the development of documentation….” or “to support analysis and system operation”? What entities’ “short term use”? Suggestion: Purpose: To ensure consistency of calculation of those entities employing Area Interchange Methodology pursuant to MOD-001 R1.
Group  Public Service Commission of South CarolinaPhil Riley Yes Yes  
IndividualGreg RowlandDuke Energy Corporation  R1 – Need to ensure that comparable information should be required in either the study report or the ATCID in MOD-028, MOD-029 and MOD-030. R2.1 - Bulk electric system facilities 161kV and below may have significant network response. Since these facilities may have significant impact on TTC, documentation should be required by the standard for those facilities 161kV and below which are equivalized. This will provide transparency for impacted stakeholders. Yes Yes  
IndividualPatrick BrownPJM  PJM does not have any specific comments.YesPJM supports NERC’s position to revise all Violation Risk Factors to have an assigned risk factor of “Lower.” A Lower Risk Factor requirement is administrative in nature and is a requirement that, if violated, would not be expected to affect the electrical state or capability of the bulk power system, or the ability to effectively monitor and control the bulk power system.NoNERC states that a VSL defines the degree to which compliance with a requirement was not achieved. The violation severity levels for these draft standards now, for the most part, have a graded implementation, but PJM has a concern regarding the possibility of multiple violations resulting from a single event. PJM requests that double counting of violations for a single event be eliminated. A single event shall not result in multiple violations –this language to be added to the standard. PJM reiterates that while we will not choose the calculation methodologies used in MODs 28 and 29, these MODs will require modification to assure consistency with any revisions made to MOD 30. PJM is including specific comments for MOD 30 in Section VI of this document. PJM is not providing specific comments for MODs 28 and 29.
IndividualGreg Ward / Darryl CurtisOncor Electric Delivery  All schedules in ERCOT flow with no pre-defined paths and any congestion is mitigated by market mechanisms and/or verbal dispatch instructions from ERCOT (in the case of an emergency). Oncor is concerned about the risk of ERCOT being found in non-compliance with the underlying standard due to the methodologies not being a part of the ERCOT market. Furthermore, Oncor believes that implementation of the prescribed methodologies would add no value to the ERCOT market and could result in more system congestion. Oncor strongly suggests that this standard specify that it is not applicable to regions with a single control area and no defined ATC path(s). Yes Yes This standard should not apply to ERCOT for the reason expressed in question 1.
Group  Bonneville Power Denise KoehnBPA does not believe any are incorrect.Yes Yes none
IndividualRichard KafkaPepco Holdings, Inc  PHI supports the comments of PJM and will not submit duplicate comments     
IndividualEarl FairGainesville Regional Utilities  In R8&9, must you determine ETC by only using the inputs specified, or can you determine each one separately then sum them to get ETC? Some methods for determining ETC may not take into account each individual item and its effect on a given path.Yes YesGood improvement.None at this time.
Group  IRC Standards Review CommitteeCharles Yeunga. R4.1: The "its" before ATCID should be replaced with "the" or “the Transmission Service Provider’s” since the ATCID is the TSP’s document. Same change to M4. b. R6.4: In general, a TOP doesn’t have contractual rights of a jointly-owned or allocated facility, whereas the TSP does. We suggest this requirement be revised to “For ATC Paths whose capacity uses jointly-owned or allocated Facilities, limit TTC for each Transmission Operator so the TTC does not exceed the contractual rights of the Transmission Service Provider of that ATC path.” c. M10: This measure corresponds to R8, which stipulates the use of a specific algorithm. However, M10 provides the requirement for certain accuracy, which leads to the following questions: i. Is R8 about the use of an algorithm only or is it also about the proper or consistent setting of the variables within that algorithm? ii. If it is also the proper or consistent setting of the variables, the requirement should stipulate the conditions rather than leaving the assessment to a recalculation process (stipulated in M10) to determine if the algorithm and its settings have been properly used. iii. If accuracy is to be a criterion for having proper and consistent setting of the variables, it becomes a requirement and hence should be stipulated in the requirement section, not in the measure. d. M11: Same comment on M10 also applies here for R9. NoNo, those requirements (at least R5 and R6) that hold the TOP responsible for establishing TTCs should be assigned a Medium since TTCs set the reliability boundary, like an SOL or IROL, within which the TSP may provide transmission services. Failure to establish TTCs may result in the TSP over-selling transmission services beyond the reliability bounds, risking the BES to unreliable operation.NoNo. We suggest the following changes: a. R1: R1.5 contains several subrequirements. It is not clear what constitutes a failure of R1.5 when considering the VSLs for R1 (i.e. number of elements missing in the ATCID. For similar situations in MOD-008, it is stipulated that failing any one of the subrequirements would constitute a requirement failure. We therefore suggest adding a sentence under each of Moderate, High and Severe: “Any violation or violations of the sub-requirements of R1.5 shall be considered a single violation of R1.5.” b. R2: We do not agree with the VSL assignments. Note that R2 has 3 subrequirements, hence a Moderate should be assigned for failing 1 of the 3, a High for failing 2 and a Severe for failing all 3. A progressive VSL for R2.3 doesn’t work in this case since even having >30 incorrect ratings, the TOP would have only failed one of the 3 subrequirements and should not be assigned a Severe if it met the other 2. We suggest the SDT to revise these VSLs. c. R3: We do not agree with the VSL assignment. R3 has two subrequirements: R3.1 for on-peak and off-peak intra-day and next-day TTCs, and R3.2 for days two through 31 TTCs and for months two through 13 TTCs. A total failure of R3 would be failing both subrequirements. Within each of the subrequirements, there are 3 subrequirements. While the VSLs for each of R3.1 and R3.2 can be made progressive (graded) according to the extent of missing outages, additions, retirements, and load forecast and unit commitments, etc. they need to eventually be factored in the VSLs for R3. Suggest to revise the VSLs so that a Low would be missing some of the subrequirements in either R3.1 and R3.2, a Moderate for missing more of them, and so on with a Severe be assigned if the majority of the subrequirements in both R3.1 and R3.2 are missing. Better still, the SDT may consider rearranging R3 so that they can better facilitate VSL development. d. R4: Similar comments in R3 also apply here. In this case, modeling reservations’ sources or sinks is used as the parameter to assign progressive VSLs, leaving the violation of either R4.1 or R4.2 or failure to include firm transmission service (a part of R4.3) as the condition for a Severe. It appears that the impact of violation has been applied in arriving at the assigned VSLs, which is not proper. We suggest a rework of this set of VSL so that they are dependent on the extent to which the 3 subrequirments are violated. If necessary, the SDT may want to consider splitting R4.3 to separate out the inclusion of firm reservations requirement to make it a condition for assessing VSLs. e. R5: We do not agree that the VSL should be a single “Severe”. R5 contains 3 subrequirements. Presumably, a TSP may fail one or more of these subrequirements. A progressive (graded) VSL should be developed. f. R6: We assess that R6.1 and R6.2 are parts of a single process requirement. However R6.3 and R6.4 are distinct requirements that need to be met as well. Presumably, a TSP may fail anyone or more of the 3 subrequirements (R6.1 and R6.2 as a unit). Again, a progressive (graded) approach would be more appropriate. We suggest the SDT to revise the VSL for this requirement. g. R7: the second “OR” under the Severe column should be “AND” since the first two conditions both mean that the TOP fails R7.1 completely, but it’s only a part of R7. It needs to also fail R7.2 completely to have a Severe failure. To cover for case where the TOP fails either R7.1 or R7.2 completely but not both, the conditions under High may be revised to remove the “but not been more than” parts and include the “did not provide…” as an OR condition. h. R8: We would assume the “M9” referenced in this set of VSL really meant “M10”, or else these VSLs would be difficult to understand since R8 is on using the algorithm, not on the values whereas M9 is for R7 that stipulates the requirement for establishing TTC values. Please also see our comments on M10 under Q1. i. R9: Same comment as in VSLs for R8, except in this case the “M10” should be “M11”. Please also see our comments on M11 under Q1.  
IndividualRon FalsettiOntario IESO  1. We offer the following comments/suggestions: a. R4.1: The "its" before ATCID should be replaced with "the" or “the Transmission Service Provider’s” since the ATCID is the TSP’s document. Same change to M4. b. R6.4: In general, a TOP doesn’t have contractual rights of a jointly-owned or allocated facility, whereas the TSP does. We suggest this requirement be revised to “For ATC Paths whose capacity uses jointly-owned or allocated Facilities, limit TTC for each Transmission Operator so the TTC does not exceed the contractual rights of the Transmission Service Provider of that ATC path.” c. M10: This measure corresponds to R8, which stipulates the use of a specific algorithm. However, M10 provides the requirement for certain accuracy, which leads to the following questions: i. Is R8 about the use of an algorithm only or is it also about the proper or consistent setting of the variables within that algorithm? ii. If it is also the proper or consistent setting of the variables, the requirement should stipulate the conditions rather than leaving the assessment to a recalculation process (stipulated in M10) to determine if the algorithm and its settings have been properly used. iii. If accuracy is to be a criterion for having proper and consistent setting of the variables, it becomes a requirement and hence should be stipulated in the requirement section, not in the measure. d. M11: Same comment on M10 also applies here for R9. NoThose requirements (at least R5 and R6) that hold the TOP responsible for establishing TTCs should be assigned a Medium since TTCs set the reliability boundary, like an SOL or IROL, within which the TSP may provide transmission services. Failure to establish TTCs may result in the TSP over-selling transmission services beyond the reliability bounds, risking the BES to unreliable operation.NoWe suggest the following changes: a. R1: R1.5 contains several subrequirements. It is not clear what constitutes a failure of R1.5 when considering the VSLs for R1 (i.e. number of elements missing in the ATCID. For similar situations in MOD-008, it is stipulated that failing any one of the subrequirements would constitute a requirement failure. We therefore suggest adding a sentence under each of Moderate, High and Severe: “Any violation or violations of the sub-requirements of R1.5 shall be considered a single violation of R1.5.” b. R2: We do not agree with the VSL assignments. Note that R2 has 3 subrequirements, hence a Moderate should be assigned for failing 1 of the 3, a High for failing 2 and a Severe for failing all 3. A progressive VSL for R2.3 doesn’t work in this case since even having >30 incorrect ratings, the TOP would have only failed one of the 3 subrequirements and should not be assigned a Severe if it met the other 2. We suggest the SDT to revise these VSLs. c. R3: We do not agree with the VSL assignment. R3 has two subrequirements: R3.1 for on-peak and off-peak intra-day and next-day TTCs, and R3.2 for days two through 31 TTCs and for months two through 13 TTCs. A total failure of R3 would be failing both subrequirements. Within each of the subrequirements, there are 3 subrequirements. While the VSLs for each of R3.1 and R3.2 can be made progressive (graded) according to the extent of missing outages, additions, retirements, and load forecast and unit commitments, etc. they need to eventually be factored in the VSLs for R3. Suggest to revise the VSLs so that a Low would be missing some of the subrequirements in either R3.1 and R3.2, a Moderate for missing more of them, and so on with a Severe be assigned if the majority of the subrequirements in both R3.1 and R3.2 are missing. Better still, the SDT may consider rearranging R3 so that they can better facilitate VSL development. d. R4: Similar comments in R3 also apply here. In this case, modeling reservations’ sources or sinks is used as the parameter to assign progressive VSLs, leaving the violation of either R4.1 or R4.2 or failure to include firm transmission service (a part of R4.3) as the condition for a Severe. It appears that the impact of violation has been applied in arriving at the assigned VSLs, which is not proper. We suggest a rework of this set of VSL so that they are dependent on the extent to which the 3 subrequirments are violated. If necessary, the SDT may want to consider splitting R4.3 to separate out the inclusion of firm reservations requirement to make it a condition for assessing VSLs. e. R5: We do not agree that the VSL should be a single “Severe”. R5 contains 3 subrequirements. Presumably, a TSP may fail one or more of these subrequirements. A progressive (graded) VSL should be developed. f. R6: We assess that R6.1 and R6.2 are parts of a single process requirement. However R6.3 and R6.4 are distinct requirements that need to be met as well. Presumably, a TSP may fail anyone or more of the 3 subrequirements (R6.1 and R6.2 as a unit). Again, a progressive (graded) approach would be more appropriate. We suggest the SDT to revise the VSL for this requirement. g. R7: the second “OR” under the Severe column should be “AND” since the first two conditions both mean that the TOP fails R7.1 completely, but it’s only a part of R7. It needs to also fail R7.2 completely to have a Severe failure. To cover for case where the TOP fails either R7.1 or R7.2 completely but not both, the conditions under High may be revised to remove the “but not been more than” parts and include the “did not provide…” as an OR condition. h. R8: We would assume the “M9” referenced in this set of VSL really meant “M10”, or else these VSLs would be difficult to understand since R8 is on using the algorithm, not on the values whereas M9 is for R7 that stipulates the requirement for establishing TTC values. Please also see our comments on M10 under Q1. i. R9: Same comment as in VSLs for R8, except in this case the “M10” should be “M11”. Please also see our comments on M11 under Q1. None
IndividualAlessia DawesHydro One Networks  Measures M10 and M11 introduce requirements. Requirement 4.1, the "its" before ATCID should be replaced with "the Transmission Service Provider's". Same change to measure M4. Requirement 6.4, we suggest a following revision due to the fact that we cannot be sure "who owns the contractual rights, "For ATC Paths whose capacity uses jointly-owned or allocated Facilities, limit the TTC to respect the contractual rights on that ATC Path." NoR3, R5 and R6 should be assigned Medium since TTCs set the reliability boundary. There is a risk of unreliable operation of the BES when failing to establish TTCs result in the TSP over-selling transmission services beyond the reliability bonds.NoNote R1 has 5 sub-requirements, not four. In the VSL's for R1 include the statement, "Any violation or violations of the sub-requirements of R1.5 shall be considered a single violation of R1.5. The Lower VSL contains older wording and should be updated to similar wording as the rest of the levels: "The TSP has an ATCID but it is missing x of the five required elements in R1. The VSLs for R2 should be graded based on % to cater to different size systems. Also what is the logic behind using voltage 161 kV in the severe level? The VSLs for R3 should also be graded based on %. Correct VSLs for R8 and R9 with the correct reference to their Measures. We question the retirement of standards FAC-012 and FAC-013 as indicated in the implementation plan as those FAC standards pertain to different responsible entities than these MOD standards.
Group  MRO NERC Standards Review SubcommitteeTom Mielnik1. The MRO believes that R1.3 should be revised to delete the word "Any" from the phrase "Any contractual obligations…". This use of "Any" seems to be unnecessary and may result in over-the-top auditing. 2. The MRO believes the words "all of" should be deleted from R2, "any" from R3.1, "all" from R3.1.3, "any" from R3.2, "all" from R3.2.3, "all of" from R4, "all" from R4.1, "any" from R4.2, "all" and "any" from R4.3, "all" from R6.3, the two uses of "any" in the OSf, and the two uses of "any" in OSnf. The MRO believes the use of these words are unnecessary and may lead to over-the-top auditing. We believe that the Measures, Compliance, and the VSLs should be changed to match these changes to the requirements. 3. The MRO urges the SDT to delete the new measures M10, M11, M12, and M13. We believe that these new measures are micromanagement of the Transmission Service Provider and encourage over-the-top auditing. The MRO considers these measures as written as being "deal-killers".YesThe MRO commends the SDT on revising the VRFs to Lower. We believe the revised VRFs are in-line with the NERC definitions of the VRF levels.Yes 1. The MRO continues to have issues with the overall approach on this standard in combination with the MOD-030. As previously indicated in prior comment periods, the MRO has Transmission Service Providers that manage the levels of transmission service to a reliable level with flowgates and then establishes border control area-to-control area flows to contract path levels so that contractual rights are not exceeded. The MRO reads the MOD-028 standard to require the application of the MOD-028 methodology for its control area-to-control area path postings while MOD-030 standard is used for the flowgates postings. The MRO understands from a discusion with a member of the SDT that in actuality the intent is that the MOD-030 would be used for flowgate calculations and that these quantities could be converted into the ATC path quantities for the control area to control area paths from border companies to outside the Transmission Service Providers area. This application of the flow gate methodology to possibly generate all postings for a Transmission Service Provider including drive out is not clear from the standards and should be clarified in MOD-030 and possibly MOD-028. 2. The MRO commends the SDT in making significant changes to this standard and reissuing it for comment. The MRO believes the eventual standard that is approved will serve the industry and customers better as a result. 3. The MRO believes that the first time you use an abbreviation or acronym, you must spell out the full term followed by the abbreviation or acronym in brackets. Subsequent use of the term is then made by its abbreviation or acronym. ex: "Each Transmission Operator shall select one Available Transfer Capability (ATC) methodology2 for calculating ATC (Area Interchange methodology, Rated System Path methodology) or Available Flowgate Capacity (AFC) (Flowgate methodology) for each ATC Path per time period identified in R2 for those Facilities within its Transmission Operator Area."
IndividualAllen MosherAmerican Public Power Association  The Area Interchange Methodology Definition, like Rated System Path and Flowgate, includes the text: "Capacity Benefit Margin, Transmission Reliability Margin, and Existing Transmission Commitments are subtracted from the TTC, and Postbacks and counterflows are added, to derive Available Transfer Capability." This text descrives the derivation of ATC or AFC, and should not be part of a definition to differentiate between the AIM, RSP and Flowgate methods. R2.1 - I support allowing "Equivalent representation of radial lines and facilities 161 kV or below, but equivalences for elements of the regionally defined definition of the BES should be explained in the ATCID. R6.1 - This requirement and the associated footnote 1 provide that "The Transmission operator may honor distribution factors les than 5% if desired." MOD-29 and MOD-30 have similar language allowing use of alternative distribution factors, generally related to the use of TLR curtailment thresholds. These practices should be posted in the TSP's ATCID and coordinated with the applicable RC(s) and each adjacent TOP and TSP. R8 and R9 – Definition of “GF” Grandfathered Firm/Non-Firm Transmission Service – please delete “accepted by FERC” after “Safe Harbor Tariff.” FERC regulatory approval of a tariff for rate purposes is not relevant to what form of transmission service tariff a NERC TSP provides. Many utilities U.S. utilities that are not FERC jurisdictional for electric rate purposes. All Canadian TSPs are non-jurisdictional. R10 and R11 - Postbacks and counterflows: “Counterflows” should be a defined term. It is used in MOD-1, MOD-28, MOD-29 and MOD-30 and is an integral element in the calculation of ATC and AFC. The definition used in MOD-28-1 R10, for example, reads: “counterflowsF are adjustments to firm ATC as determined by the Transmission Service Provider and specified in the ATCID.” This definition does not in any way describe what a counterflow is. “Postbacks” should incorporate a working definition developed by NAESB, to be revised once due process is completed on this business practice. Alternatively, consider use of the following text to at minimum describe the nature of postbacks: “Postbacks[Firm][Non-Firm] are changes to firm [non-firm] ATC [AFC] due to a change in the amount of Firm [non-firm] Transmission Service reserved or scheduled for a period, as defined in Business Practices. Postbacks are generally a positive quantity.” Also, include Postbacks in the "e.g." list of factors in M12 and M13. Yes YesMajor improvement. We will want to refine in the future but good work here.These comments apply equally to MOD-1, MOD-28. MOD-29 and MOD-30 Excellent work by the SDT.
IndividualRex McDanielTexas-New Mexico Power Company  All schedules in ERCOT flow with no pre-defined paths and any congestion is mitigated by market mechanisms and/or verbal dispatch instructions from ERCOT (in the case of an emergency). Texas-New Mexico Power Company is concerned about the risk of ERCOT being found in non-compliance with the underlying standard due to the methodologies not being a part of the ERCOT market. Furthermore, TNMP believes that implementation of the prescribed methodologies would add no value to the ERCOT market and could result in more system congestion. TNMP strongly suggests that this standard specify that it is not applicable to regions with a single control area and no defined ATC path(s). Yes Yes This standard should not apply to ERCOT for the reason stated in Question 1.
IndividualAaron StaleyOrlando Utilities Commission   Yes Yes All the requirements and measures look great. One question on R8 and R9. In R8 and R9, it is obviously required that ETC is determined using only the inputs specified, however is it necessary to determine each of the individual inputs and then sum them to get ETC? For example the method for determining ETC might take into account only those items and their effect on the path, but may not break them out into their individual values (NITS, GF, PTP, OS) due to the nature of the method.
IndividualTony KroskeyBrazos Electric Power Cooperative, Inc.       Brazos Electric believes that the concept of a Area Interchange Methodology is not applicable to a single-control area operation like ERCOT. To address this issue, the Applicability section could be modified to state that only TOPs or TSPs that conduct area to area operations and hence have responsibility for ATC Path(s) must have an Area Interchange Methodology.
IndividualRick GonzalesNew York Independent System Operator  MOD-028 incorporates the new MOD-001 definition of "ATC Path." Please see the NYISO's comments on MOD-001 for an explanation of why this defined term appears to be overly broad when applied to the NYISO and could subject it to obligations, and potential penalties, that would be inconsistent with both the character of the NYISO's FERC-approved financial transmission service model and with waivers from the OASIS posting requirements that FERC has granted the NYISO. In particular, under R5 (and M7) of MOD-028, the current definition of ATC Path could be interpreted to require the NYISO to post TTCs for periods of time further in the future than one day-ahead for interfaces or scheduled lines for which FERC does not require the NYISO to post TTC beyond one-day ahead. As the NYISO discussed in its response to MOD-001, subjecting the NYISO to such requirements would serve no reliabilty purpose. The NYISO has proposed a revision to MOD-001 to address this concern. In the same vein, the SDT should revise R 3.2, R5, and R.7 to clarify that they do not require Transmission Operators to calculate (or establish) monthly ATCs (or TTCs) to the extent that they are not required under FERC’s regulations, or as a result of FERC orders, to calculate and post ATC for periods further out than one day-ahead The NYISO has previously commented that MOD-028 should be revised so that TTC would not have to be re-established (or re-calculated) at set intervals when the underlying inputs to TTC have not changed. The SDT previously made a similar change to the ATC re-calculation frequency requirement of what is now R8 under MOD-001 but has not yet made the corresponding change to MOD-028. The NYISO therefore respectfully renews its request that the STD make the requested changes to MOD-028. Under the NYISO system, TTC values do not change often. Accordingly, the proposed MOD-028 requirements would force the NYISO to adopt costly compliance measures that would offer no benefit to its customers and serve no reliability purpose. The NYISO has previously commented that it is critically important to it that the algorithm for calculating “Existing Transmission Commitments” (“ETC”) in MOD-028 (and -029) be interpreted flexibly. The NYISO’s existing ATC calculation procedure, which reflects the nature of its financial reservation system, and which has been accepted by the Commission, is to calculate firm and non-firm ATC as follows. ATC(Firm) = TTC – Transmission Flow Utilization(Firm) – TRM ATC(Non-Firm) = ATC(Firm) – Transmission Flow Utilization(Non-Firm) Where “Transmission Flow Utilization” represents the security constrained network powerflow solutions of the NYISO’s Security Constrained Unit Commitment software, with respect to the NYISO Day-Ahead Market, or its Real-Time Commitment and Real-Time Dispatch software with respect to the NYISO’s Real-Time Market. As the NYISO has explained in prior comments, it believes that the central role that Transmission Flow Utilization plays in its ATC/TTC calculations can be accommodated under proposed MOD-028 and MOD-029 by accounting for it in the ETC calculation algorithms established under R8 and R9. Specifically, the SDT's proposed definition of the OS(F) variable appears to be broad enough to encompass Transmission Flow Utilization. The NYISO has previously requested that the SDT clarify or revise the OS(F) definition so that it would clearly allow the NYISO to account for Transmisison Flow Utilization in this way. The SDT has not yet responded. Accordingly, the NYISO requests that the the OS(F) definition under R8 be revised to read: OS(F) is the firm capacity reserved for any other service(s), contract(s), or agreement(s) not specified above using Firm Transmission Service, including any other firm adjustments to reflect impacts from other ATC Paths of the Transmission Service Provider as specified in the ATCID, including security constrained network powerflow solutions produced by market software used by Transmisison Service Providers that administer FERC-approved organized markets. Similarly, the OS(F) definition under R9 should be revised to read: OS(F) is the non-firm capacity reserved for any other service(s), contract(s), or agreement(s) not specified above using Non-Firm Transmission Service, including any other firm adjustments to reflect impacts from other ATC Paths of the Transmission Service Provider as specified in the ATCID, including security constrained network powerflow solutions produced by market software used by Transmisison Service Providers that administer FERC-approved organized markets. Making these revisions should have no impact on the vast majority of Transmission Service Providers, because they will neither administer FERC-approved organized markets nor use Transmission Flow Utilization in their ATC/TTC calculations. On the other hand, it would permit the NYISO to come into compliance with NERC's proposed MOD standards without having to make fundamental changes to its FERC-approved market design or financial reservation transmission model. Order No. 890 was clear that it would not require fundamental changes to ISO/RTO market designs. This principle was recently upheld when FERC accepted the NYISO's Order No. 890 tariff compliance filing without requiring any changes to financial reservation transmission model. The NYISO asks that the SDT make the required revision in order to elimiante any possibility of a conflict between the NYISO's FERC approved system and the NERC MOD standards. The NYISO recognizes that the definition of OS(F) may already be broad enough to accommodate Transmission Flow Utilization. If the SDT does not make the requested revision the NYISO will take the position that it may describe its use of Transmission Flow Utilization in the ETC calculation within its ATCID. Nevertheless, because this issue is so important to the NYISO's future compliance with NERC's MOD standards the NYISO would strongly prefer that the issue be expressly addressed within the text of MOD-028 and (MOD-029). The NYISO may raise the issue at FERC if it is not addressed by NERC.