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Individual or group.  (27 Responses)
Name  (17 Responses)
Organization  (17 Responses)
Group Name  (10 Responses)
Lead Contact  (10 Responses)
Contact Organization  (10 Responses)
Question 1  (24 Responses)
Question 1 Comments  (27 Responses)
Question 2  (24 Responses)
Question 2 Comments  (27 Responses)
Question 3  (19 Responses)
Question 3 Comments  (27 Responses)
Question 4  (24 Responses)
Question 4 Comments  (27 Responses)
Question 5  (19 Responses)
Question 5 Comments  (27 Responses)
Question 6  (23 Responses)
Question 6 Comments  (27 Responses)
Question 7  (16 Responses)
Question 7 Comments  (27 Responses)
Question 8  (16 Responses)
Question 8 Comments  (27 Responses)
Question 9  (17 Responses)
Question 9 Comments  (27 Responses)
 
Individual
Dan Rochester
Independent Electricity System Operator
No
Generally speaking, ATCs/AFCs are commercial parameter – a service, determined and sold within reliability boundaries. The concept of overselling Firm ATC/AFC is thus misapplied. Selling ATCs/AFCs, firm or otherwise, is a business decision that should be governed by standard business practices, not reliability standards. We have a concern that NERC reliability standards are used to govern proper business behaviors. From a process viewpoint, over selling transmission service does not automatically result in power flowing on the transmission network. Once a transmission customer has confirmed a transmission reservation, the customer only has a right but not an obligation to use the service. Before any power actually flows on the system to exercise a transmission reservation, an Arranged Interchange must be submitted to enable implementation of the arranged transaction using the reserved service. The responsible entities (BA, TSPs) must approve the Arranged Interchange before it becomes a Confirmed Interchange. When a transmission constraint exists on the system, power flows on critical facilities will be adjusted to allow the flow to occur without risking the interconnected system’s reliability. This is far from shedding firm load to preserve reliability. And even when over-sold transmission services are used that result in a transmission constraint or SOL/IROL exceedences, the TOP and RC can implement available control measures to mitigate these constraints. In brief, to use NERC reliability standards to govern a business decision is inappropriate, and to suggest that over selling of Firm ATC/AFC will result in affecting the control and reliability of the BES, which is the basis for a Medium VRF, is ungrounded. We therefore do not agree that the accurate determination of ATCs and AFCs to avoid overselling of Firm ATC/AFC bears any Medium risk. Finally, accurate determination of ATCs and AFCs may not prevent a TSP from overselling, making this argument moot. That said, the only requirements that may warrant a Medium VRF would be those associates with the determination of TTCs/TFCs as they set the reliability boundaries for subsequent ATC/AFC calculations, and specific requirements for the use of CBM and TRM. Please see our specific comments below on the latter 2 items. We are unable to identify any cases where firm load was shed as a result of “overselling” transmission services in the ten+ years since FERC mandated open access and set firm transmission service at the same level of NITS and NNL. There are many ways to mitigate a transmission overload such as redispatch, reconfiguration and implementing the transmission loading relief procedure before any load gets shed to accommodate use of reserved transmission services. We would also point out that by interrupting NNL, native load is not necessarily curtailed. It is that portion of the transmission capability that is used for supplying Network and Native Load that needs to be interrupted. System readjustment, redispatch, purchases, etc. can provide the required NNL adjustments.
Yes
 
 
No
Based on our arguments in question 1, we believe all the VRFs for this standard should be Lower, except for R6 which addresses the TTC determination.
No
Based on our analysis of question 1, we believe that R1-R9 should have Lower VRFs. We do, however, believe that for those areas that employ CBM, lack of CBM could have a direct impact on the electrical state of the BES so we agree with R11 to R12 having Medium VRFs. R10 is a condition for requesting the use of CBM for import, it is not a reliability requirement in the context that “thou shall do this to preserve reliability”. Clearly, one would violate this condition if one requests the use of CBM without declaring a NERC EEA Level 2 or higher. However, such a violation will have no adverse impact on reliability. A Lower is the appropriate VRF for this requirement.
 
No
Based on our answer to question 1 and our belief that only those requirements associated with TTC calculation and certain requirements on the determination and use of CBM and TRM have a direct impact on the electrical state of the BES, all requirements in this standard should have a Lower VRF except R2 to R7, which can be a Medium.
No
Based on our answer to question 1 and our belief that only those requirements associated with TTC calculation and certain requirements on the determination and use of CBM and TRM have a direct impact on the electrical state of the BES, all requirements in this standard should have a Lower VRF except R1 to R4, which can be a Medium.
No
Based on our answer to question 1 and our belief that only those requirements associated with TTC calculation and certain requirements on the determination and use of CBM and TRM have a direct impact on the electrical state of the BES, all requirements in this standard should have a Lower VRF except R2, which can be a Medium.
Individual
Chuck Falls
Salt River Project
Yes
 
Yes
 
 
Yes
 
 
Yes
 
 
Yes
 
 
Individual
Vann Weldon
ERCOT Inc.
No
Selling Firm ATC/AFC is a commercial activity. The system is operated in real time through redispatch of generation, TLRs or other actions so that SOLs/IROLs are not exceeded and no firm load is shed. Overselling firm service would only require load shedding if other mitigating operating actions were not taken as mentioned above. A “Medium” VRF requires directly affecting the electrical state, capability, or monitoring and control of the BPS. The definitions of “directly” are: in a direct line, without intervening space, next in order, immediately, straight away. Overselling of ATC/AFC cannot by itself result in an SOL or IROL, nor will an SOL or IROL occur “next in order”, “immediately”, or “straight away” after ATC/AFC is oversold. To equate the ‘direct’ affect of the market action of overselling ATC/AFC with failure of a segment of the grid or generation resource is a unjustifiable stretch.
Yes
 
No
A “Medium” VRF requires directly affecting the electrical state, capability, or monitoring and control of the BPS. The definitions of “directly” are: in a direct line, without intervening space, next in order, immediately, straight away. CBM cannot by itself result in an SOL or IROL, nor will an SOL or IROL occur “next in order”, “immediately”, or “straight away” after an erroneous CBM is posted.
 
 
 
 
 
 
Individual
Rao Somayajula
ReliabilityFirst Corporation
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
Group
FirstEnergy
Sam Ciccone
FirstEnergy Corp.
No
FirstEnergy Corp. agrees with comments submitted by MISO and PJM to all questions on this comment form. Also, FirstEnergy Corp. offers the following additional comments: The reservation (sale) of transmission capacity does not in and of itself insure that energy will ever flow on the reservation. Until energy flows, there is no risk to the reliability of the Bulk Electric System and, consequently, no opportunity to exceed SOL or IROL thresholds. Energy transactions must be approved prior to implementation. To use an example from the airline industry, several times flights can be overbooked. Applying the VRF rules to this example, this would be considered a "Lower" VRF. Although there is a relationship between overselling tickets and exceeding safe loading capacity, the airline would never let the plane take off with a load it cannot handle. Therefore, overselling airline tickets would not hinder the safety of passengers nor the effectiveness of the airline agents and pilots to monitor the capacity loading of a plane before departure.
 
 
 
 
 
 
 
 
Individual
Richard Kafka
Pepco Holdings, Inc.
No
Overselling of Firm Transmission is a commercial issue, not a reliability issue. Various planning analyses following the TPL standards are used to determine the expected transfer limits that are reasonably expected for several prescribed conditions. In the operations environment, there is an on-going collection of experience in scheduling transactions and generation commitment. Operations planners commit sufficient internal deliverable resources to meet expectations of internal load and scheduled net interchange. Additionally, operations and scheduling include the ability to continue reliable operations following a range of contingencies. No matter how much FIRM ATC is sold, what matters is how much is scheduled, and that occurs in the operations planning environment.
Yes
As discussed in comments to Question 1, operational processes will protect against this.
No
CBM is used in a planning horizon, along with long term forecasts and internal deliverability studies to determine the required level of internal resources. As necessary or desired for economics, transactions will be scheduled in to serve internal load. As discussed previously, there are operational processes and procedures downstream of ATC (and CBM) calculations that are used by TOP’s and RC’s to ensure the reliability of the system by real-time monitoring and controlling of SOLs and IROLs. Tools include scheduling and Redispatch of generation resources.
No
For the reasons submitted on previous questions, these VRFs should be 'Lower" as developed by the industry.
No
These VRFs should be 'Lower' as previously explained. The industry's advice has been disregarded.
No
The VRFs for MOD-008-1 were raised based on rasing the VRFs of lower numbered MOD standards.
No
 
No
 
 
Individual
Ronald Schellberg
Idaho Power Company
No
I do not view a violation to normally have a direct or an in-direct "affect the electrical state or the capability of the BPS". This is more a contract issue between the TP and the customer to correct an over-sold situation. Interruption and Curtailment of reservations/schedule rarely result in load shedding, declaring ATC calculations to be a "medium" risk appears to be claiming the "sky is falling".
Yes
 
No
The decision to hold and have available CBM capacity is dependant on the ammount of margin a LSE hold internal to its system or because of its location within the interconnection. One can not make a blanket assumption that not having CBM will necessitate the shedding of firm load. Shedding of load is one means to restore a L&R balance, but that does not mean the electrical state or capability of the BPS has been affected.
No
The ATC calculations help manage the commercial allocation of transmission capacity. Regardless of the amount sold. Other standards assure that the electrical state or capability of the BPS will not be affected. I believe the VRF for all MOD-001 requirements should remain "lower" as balloted and approved.
No
The CBM calculations help manage the commercial allocation of transmission capacity. Regardless of the amount sold. Other standards assure that the electrical state or capability of the BPS will not be affected. I believe the VRF for all MOD-004 requirements should remain as balloted and approved.
No
The ATC calculations help manage the commercial allocation of transmission capacity. Regardless of the amount sold. Other standards assure that the electrical state or capability of the BPS will not be affected. I believe the VRF for all MOD-008 requirements should remain "lower" as balloted and approved.
 
No
The ATC calculations help manage the commercial allocation of transmission capacity. Regardless of the amount sold. Other standards assure that the electrical state or capability of the BPS will not be affected. I believe the VRF for all MOD-029 requirements should remain "lower" as balloted and approved.
 
Individual
James H. Sorrels, Jr.
AEP
No
Thank you for the opportunity to comment. AEP appreciates the Board’s efforts in reviewing these VRFs and seeking input from the stakeholders. We support the approach that VRFs be addressed through the established standards development process, which would include balloting by the stakeholders. PART 1: If “No,” please explain either: 1.) how you avoid overselling of Firm ATC/AFC, 2.) how you mitigate the effects of such overselling such that load shedding is unnecessary, or 3.) why you believe there is no relationship between overselling of Firm ATC/AFC and exceeding SOL/IROLs. As previously described, a “Medium” VRF, if violated, could directly affect the electrical state or capability of the BPS; directly affect the ability to effectively monitor and control the BES; or could do so in a planning time frame, under emergency, abnormal, or restorative conditions. Fundamentally, it is unreasonable to conclude that the standard has a “direct affect” when ATC or AFC is not determined for all portions of the BES. Both Texas and portions of the northeast and the west do not post ATC values (and where ATC is posted it is for ‘paths’ that extend from/to the TSP’s boundaries), yet they are able to effectively monitor and control all their facilities within the BES both in normal conditions and under emergency, abnormal, and restorative conditions, irrespective if an ATC value is known or even calculated. Based on the nature of ATC and this standard, AEP believes that the stakeholder process resulted in a correct assessment of a “Lower” VRF assignment. To avoid ‘overselling’ simply stop selling when ATC reaches zero. NERC’s VRF report to the Board does not appear to have overstated the standard’s importance of ATC (and AFC) to the reliability of the BES. It is simply not reasonable to conclude that the standard “directly affects” the BES. PART 2: “If “No,” please explain how the effects of overselling firm service would not potentially require load shedding to maintain such service.” Another key consideration in determining the VRF is that ATC/AFC is intended for planning on the BES and not intended as a real-time reliability tool. The energy flows and schedules are the reliability element in real-time. ATC/AFC is a “right to use,” not a “declaration of use” and can not be oversold as suggested in the NERC VRF report. Analogies could be drawn to a hotel reservation. Your hotel reservation may be used to plan your expected arrival, but you could still be turned away if the hotel is at maximum capacity. Similarly, ATC/AFC is useful to plan how conditions may be tomorrow, but in real-time the actual flows and schedules are the reliability element. As maximum capacity is reached, schedules are denied, existing transactions are curtailed to allow higher priority ones to be scheduled, or system reconfiguration may occur. Fortunately, this reliability element already has established tools and mechanisms, such as those found in the INT and IRO standards, that have a direct affect the electrical state or capacity of the BES and provide the ability to effectively monitor and control the BES in the various conditions that may occur.
Yes
 
No
Once again, the MOD-004-1 standard is only applicable to those areas that ‘maintains CBM’ (per R1). Fundamentally, it is unreasonable to conclude that CBM has a “direct affect” when the determination or calculation of CBM is one of choice and is not required for all participants on the BES. Many TSPs do not maintain CBM, yet each are able to effectively monitor and control their facilities within the BES both in normal conditions and under emergency, abnormal, and restorative conditions. Based on the elective nature of this standard, AEP believes that the stakeholder process resulted in a correct assessment of a “Lower” VRF assignment. While mentioned, NERC’s VRF report to the Board does not include an examination of the optional nature of this standard and, inadvertently, may have overstated the standard’s importance to the BES. With this understanding, it would not be reasonable to conclude that the standard “directly affects” the BES for some areas, but is not necessary in other areas to prevent this “direct affect” on the BES.
No
Based on our comments in Question #1, AEP agrees with the results of the stakeholder process that established “Lower” VRFs for all of the standard’s requirements and for the over-all standard.
No
Based on our comments in Question #3, AEP agrees with the results of the stakeholder process that established “Lower” VRFs for all of the standard’s requirements and for the over-all standard.
No
Once again, the MOD-008-1 standard is only applicable to those Transmission Operators that maintain TRM. Fundamentally, it is unreasonable to conclude that the standard has a “direct affect” when the use of the TRM is not required for all Transmission Operators on the BES. Based on the elective nature of this standard, AEP believes that the stakeholder process resulted in a correct assessment of a “Lower” VRF assignment. NERC’s VRF report to the Board does not include an examination of the optional nature of this standard and, inadvertently, may have overstated the standard’s importance to the TRM. With this understanding, it would not be reasonable to conclude that the standard “directly affects” the TRM for some areas, but is not necessary in other areas to prevent this “direct affect” on the BES.
No
Standard MOD-028-1 is a methodology to support standard MOD-001-1 Requirement 3, and requires specification of rules and process for a TSP implementing this methodology. As described in the response to Question #1, it is unreasonable to conclude that the standard has a “direct affect” when the use of the ATC or AFC is not required for all participants on the BES. It would not be reasonable to conclude that the standard “directly affects” the BES for some areas, but is not necessary in other areas to prevent this “direct affect” on the BES. Per the FERC order Guideline 2 (X = A + B + C) and Guideline 3 )standards that support similar goals to have consistent VRFs): since X (MOD-001-1) is appropriately a “Lower” VRF, then any supporting standard A (MOD-028-1), standard B (MOD-029-1), and standard C (MOD-030-1) must also be a “Lower” VRF. Based on the optional nature of the standard and the identified guidelines, Standard MOD-028-1 must have the same rating as MOD-001-1, which is a “Lower”VRF.
No
MOD-029-1 is a methodology for calculating TTC using a model that meets the specified scope and criteria. Standard MOD-029-1 is a methodology to support standard MOD-001-1 Requirement 3, and requires specification of rules and process for a TSP implementing this methodology. As described in the response to Question #1, it is unreasonable to conclude that the standard has a “direct affect” when the use of the ATC or AFC is not required for all participants on the BES. It would not be reasonable to conclude that the standard “directly affects” the BES for some areas, but is not necessary in other areas to prevent this “direct affect” on the BES. Per the FERC order Guideline 2 (X = A + B + C) and Guideline 3 (standards that support similar goals to have consistent VRFs): since X (MOD-001-1) is appropriately a “Lower” VRF, then any supporting standard A (MOD-028-1), standard B (MOD-029-1), and standard C (MOD-030-1) must also be a “Lower” VRF. Based on the optional nature of the standard and the identified guidelines, Standard MOD-029-1 must have the same rating as MOD-001-1, which is a “Lower” VRF.
No
Standard MOD-030-1 is a methodology to support standard MOD-001-1 Requirement 3, and requires specification of rules and process for a TSP implementing this methodology. As described in the response to Question #1, it is unreasonable to conclude that the standard has a “direct affect” when the use of the ATC or AFC is not required for all participants on the BES. It would not be reasonable to conclude that the standard “directly affects” the BES for some areas, but is not necessary in other areas to prevent this “direct affect” on the BES. Per the FERC order Guideline 2 (X = A + B + C) and Guideline 3 (standards that support similar goals must have consistent VRFs): since X (MOD-001-1) is appropriately a “Lower” VRF, then any supporting standard A (MOD-028-1), standard B (MOD-029-1), and standard C (MOD-030-1) must also be a “Lower” VRF. Based on the optional nature of the standard and the identified guidelines, Standard MOD-030-1 must have the same rating as MOD-001-1, which is a “Lower” VRF.
Individual
Gordon Rawlings
BC Transmission Corp.
No
Firm ATC values are calculated from the equation TTC = ATC + ETC + CBM + TRM - Postbacks – counterflows up to 13 months ahead and TTC is calculated expecting SOL/IROLs known at the time. However, SOL/IROLs may change/reduce prior to the operating hour. If TTC and calculated earlier could not be supported by the updated SOL/IROLs, and if Firm ATC calculated earlier was purchased ahead of time, an overselling Firm ATC for this particular operating hour exists. In this case, all firm services are curtailed pro rata to the extent necessary prior to the operating hour to ensure no SOL/IROLs violation. Therefore, overselling Firm ATC will not lead to a SOL/IROLs violation. Overselling of Firm ATC/AFC is not a Medium risk to the bulk electric system. What does “load shedding to maintain such service” mean? Does it mean 1) curtailing firm transmission service to TSP’s native load to allow PTP hour-ahead energy schedules using prior firm PTP service reservations, 2) curtailing firm transmission to TSP’s native load real-time due to real-time SOL/IROLs violation, or (3) shedding TSP’s native load retail-time to maintain PTP scheduling flow? (1) and (2) are not realistic since all firm services are to be curtailed pro-rata. If (2), shedding load real-time may be required as an immediate response to contingencies. This is not due to overselling firm service.
Yes
 
No
Setting aside CBM is not a mandatory requirement.
No
In R1 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if they lead to SOL/IROLs violation. This can only occur when TTC/TFC values are greater than a SOL or an IROL or insufficient TRM is set aside. Therefore, R1 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R2 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R2 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R3 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R3 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R6 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R6 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R7 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R7 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R8 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R8 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R9 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R9 of MOD-001-1 should be Lower. Only the requirements in MOD-008-1, MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs.
 
No
In R2 of MOD-008-1, NERC staff recommends a Medium VRF; it should be listed as Lower. An error in including CBM will increase the amount set aside for TRM but not risk SOL/IROLs violation.
No
In R1 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R1 of MOD-028-1 should be Lower. In R2 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R2 of MOD-028-1 should be Lower. In R4 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R4 of MOD-028-1 should be Lower. In R8 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R8 of MOD-028-1 should be Lower. In R10 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R10 of MOD-028-1 should be Lower.
No
In R1 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. In R5 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R5 of MOD-029-1 should be Lower. In R7 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values are determined from TTC/TFC values that are greater than a SOL or an IROL. Therefore, R7 of MOD-029-1 should be Lower.
 
Individual
Ross Kovacs
Georgia Transmission Corporation
No
As long as Firm TTC/TFC is not exceeded, overselling of Firm ATC/AFC is not a Medium risk to the bulk electric system. Firm ATC/AFC values are simply components of the TTC/TFC equations. From the equations in MOD-028-1 and MOD-029-1, TTC = ATC + ETC + CBM + TRM - Postbacks - counterflows. From the equation in MOD-030-1, TFC = AFC + ETC + CBM + TRM - Postbacks - counterflows. As long as TTC/TFC is less than the SOL/IROLs, there is no concern with overselling of Firm ATC/AFC. Mitigation is not needed if TTC/TFC is not exceeded. SOL/IROLs directly impact TTC/TFC, not ATC/AFC. If “No,” please explain how the effects of overselling firm service would not potentially require load shedding to maintain such service. Comment: As long as the TTC/TFC is less than the SOL/IROLs, there is no overselling firm service that would potentially require load shedding to maintain such service. Further, overselling is not the same as power flow on the electric system. If no one schedules on the reservation, there is no power flow to create a reliability concern.
Yes
 
Yes
 
No
In R1 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R1 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R2 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R2 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R3 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R3 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R6 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R6 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R7 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R7 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R8 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R8 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R9 of MOD-001-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R9 of MOD-001-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs.
No
In R1 of MOD-004-1, NERC staff recommends a Medium VRF; it should be listed as Lower. CBM must be released as non-firm transmission when it is not needed for CBM, and many entities do not use CBM. These are economic decisions that each entity makes with the approval of the entity’s regulator. Only the requirements in MOD-004-1 that allow scheduling to implement the decisions in the same-day time horizon should be listed as Medium. In R2 of MOD-004-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely documentation and sharing of documentation. Only the requirements in MOD-004-1 that allow scheduling of CBM in the same-day time horizon should be listed as Medium. In R5 of MOD-004-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely posting of studies and allocation of CBM. Only the requirements in MOD-004-1 that allow scheduling of CBM in the same-day time horizon should be listed as Medium. In R7 of MOD-004-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely documentation and sharing of documentation. Only the requirements in MOD-004-1 that allow scheduling of CBM in the same-day time horizon should be listed as Medium. In R11 of MOD-004-1, NERC staff recommends a Medium VRF; we agree that it should be listed as Medium. Only the requirements in MOD-004-1 that allow scheduling of CBM in the same-day time horizon should be listed as Medium. In R12 of MOD-004-1, NERC staff recommends a Medium VRF; we agree that it should be listed as Medium. Only the requirements in MOD-004-1 that allow scheduling of CBM in the same-day time horizon should be listed as Medium.
No
In R1 of MOD-008-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely documentation. In R2 of MOD-008-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely sharing of documentation. In R4 of MOD-008-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely sharing of the documented TRM values. In R5 of MOD-008-1, NERC staff recommends a Medium VRF; it should be listed as Lower. This requirement is largely sharing of documentation.
No
In R1 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R1 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R2 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R2 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R3 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R3 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R4 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R4 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R5 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R5 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R6 of MOD-028-1, NERC staff recommends a Medium VRF; we agree that should be listed as Medium. R6 is the requirement in MOD-028-1 that prevents TTC/TFC from exceeding an SOL or IROL. In R7 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R7 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R8 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R8 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R10 of MOD-028-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R10 of MOD-028-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs.
No
In R1 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R1 of MOD-029-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R2 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R2 of MOD-029-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R3 of MOD-029-1, NERC staff recommends a Medium VRF; we agree that should be listed as Medium. R3 is the requirement in MOD-029-1 that prevents TTC/TFC from exceeding an SOL or IROL. In R4 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R4 of MOD-029-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R5 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R5 of MOD-029-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R7 of MOD-029-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R7 of MOD-029-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs.
No
In R1 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R1 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R2 of MOD-030-1, NERC staff recommends a Medium VRF; we agree that should be listed as Medium. R2 is the requirement in MOD-030-1 that prevents TTC/TFC from exceeding an SOL or IROL. In R3 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R3 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R4 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R4 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R5 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R5 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R6 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R6 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R8 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R8 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs. In R10 of MOD-030-1, NERC staff recommends a Medium VRF; it should be listed as Lower. ATC or AFC calculations and values should only be Medium VRFs if the resulting ATC/AFC values lead to overselling Firm ATC/AFC that may necessitate the shedding of firm load. This can only occur when TTC/TFC values are greater than a SOL or an IROL. Therefore, R8 of MOD-030-1 should be Lower. Only the requirements in MOD-028-1, MOD-029-1, and MOD-030-1 that prevent TTC/TFC from exceeding an SOL or IROL should be Medium VRFs.
Individual
Patrick Brown
PJM Interconnection
No
There are operational processes and procedures downstream of ATC calculations that are used by TOP’s and RC’s to ensure the reliability of the system by real-time monitoring and controlling of SOLs and IROLs. Specifically, the IRO, BAL, and INT series of standards adequately address the ability to monitor and control the BPS regardless of system conditions or pre-conditions. PJM believes that the effect of loop flow on operations has been a more significant risk then overselling ATC.
Yes
 
No
PJM uses CBM as a margin in the ATC calculation and does not schedule CBM like a reservation, therefore not having CBM available will not result in load shedding on the PJM system. There are other methods to import the required energy into PJM. In addition, there are operational processes and procedures downstream of ATC calculations that are used by TOP’s and RC’s to ensure the reliability of the system by real-time monitoring and controlling of SOLs and IROLs. Specifically, the IRO, BAL, and INT series of standards adequately address the ability to monitor and control the BPS regardless of system conditions or pre-conditions.
No
In addition to the response to question 1, PJM disagrees that the following requirements in MOD 1 will directly affect the electrical state or the capability of the BPS, or directly affect the ability to effectively monitor and control the BPS. R1 requires each Transmission Operator to select one of the several available methods for calculating ATC. Mod 28, 29 and 30 are valid methods that can be used to calculate ATC. Picking one method over another will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R2 specifies the future time periods when the ATC calculations need to be performed. The time period of calculation may be a tariff or NAESB issue but will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R3 requires each TSP to document the attributes of their ATC calculation. Documentation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R6 and R7 require that assumptions used for calculating various components of the ATC should not be more limiting than those used in the planning of operations for the corresponding time period. Using “over conservative” assumptions in the ATC calculation may be a NAESB equity issue but will not directly affect the electrical state or the capability of the BPS, or directly affect the ability to effectively monitor and control the BPS. R8 and R9 address future period calculation refresh rates and sharing of data with external entities. Neither of these requirements will directly affect the electrical state or the capability of the BPS, or directly affect the ability to effectively monitor and control the BPS.
No
In addition to the response to question 1, PJM disagrees that the following requirements in MOD 4 will directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R1 requires each TSP that maintains CBM to document the attributes of their CBM calculation. Documentation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R2 requires the TSP make the CBM documentation available to external entities. Making documentation available to external entities will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R4 provides a description of several valid types of methods available for the CBM calculation and requires the TSP to choose one method. The mathematical method of calculation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R5 specifies the periodicity of the CBM calculation. The periodicity of calculation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS.
No
In addition to the response to question 1, PJM disagrees that the following requirements in MOD 8 will directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R1 requires each TO document the attributes of their TRM margin calculation. Documentation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R2 specifies that the TO shall not add additional margin into the TRM calculation. Using “overly conservative” assumptions in the TRM calculation may be an NAESB equity issue but will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R4 and R5 address the periodicity of the calculation and exchanging the information with external entities and will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS.
 
 
No
In addition to the response to question 1, PJM disagrees that the following requirements in MOD 30 will directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R1 requires each TSP to document the attributes of their flowgate capability calculation. Documentation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R2 describes the tasks that each TO needs to perform to calculate the AFC. The calculation process will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS. R3 requires the TO make available to the power system model to the TSP to determine AFC and will not directly affect the ability to effectively monitor and control the BPS. R4 defines how various transactions should be represented in the AFC calculation and will not directly affect the ability to effectively monitor and control the BPS. R5, R6 specifies how certain quantities should be incorporated into the AFC calculation and will not directly affect the ability to effectively monitor and control the BPS. R8 is the algorithm used for calculating AFC for some future time period that will not directly affect the ability to effectively monitor and control the BPS. R10 addresses the periodicity of the AFC calculation. The periodicity of calculation will not directly affect the electrical state or the capability of the BPS or directly affect the ability to effectively monitor and control the BPS.
Group
SERC OC Standards Review Group
Jerry Tang, vice Chair – SERC ATCWG
Municipal Electric Authority of Georgia
No
While we agree that overselling of firm ATC/AFC may affect the electric system, it doesn’t mean that SOLs or IROLs will be exceeded because of many different mitigation procedures available; therefore, not all the VRFs as set by NERC staff should be raised from low to medium.
Yes
 
Yes
 
No
We feel R1, R3, R6 and R7 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS. Individual SERC members will provide more specific reasons for their disagreement with changes suggested by NERC Staff in their individual comments.
No
We feel R1, R2, and R7 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS. Individual SERC members will provide more specific reasons for their disagreement with changes suggested by NERC Staff in their individual comments.
No
We feel R1, and R2 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS. Individual SERC members will provide more specific reasons for their disagreement with changes suggested by NERC Staff in their individual comments.
No
We feel R1 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS. Individual SERC members will provide more specific reasons for their disagreement with changes suggested by NERC Staff in their individual comments.
 
No
We feel R1 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS. Individual SERC members will provide more specific reasons for their disagreement with changes suggested by NERC Staff in their individual comments.
Group
Bonneville Power Administration
Denise Koehn
Transmission Reliability Program
No
Load shedding to avoid exceeding SOL/IROLs is not necessary until the scheduling of such firm reservations approach the SOL/IROL. Overselling alone should not result in load shedding, as there is no guarantee a schedule will be submitted against the reservation. If necessary, limiting the schedules so they do not exceed the SOL/IROL will prevent load shedding.
Yes
 
 
No
BPA believes all requirements of MOD-001-1 should have a “Lower” VRF as this standard’s requirements only speak to the calculation of ATC/AFC values – reliability is not endangered by the overselling of ATC, but rather by the overscheduling of the system, which these standards do not address.
 
No
BPA believes all requirements of MOD-008-1 should have a “Lower” VRF as this standard’s requirements only speak to the calculation of TRM, which is a component of ATC/AFC values – reliability is not endangered by the overselling of ATC, but rather by the overscheduling of the system, which these standards do not address.
 
No
BPA believes all requirements of MOD-029-1 should have a “Lower” VRF as this standard’s requirements only speak to the calculation of ATC/AFC values – reliability is not endangered by the overselling of ATC, but rather by the overscheduling of the system, which these standards do not address.
No
BPA believes all requirements of MOD-030-1 should have a “Lower” VRF as this standard’s requirements only speak to the calculation of ATC/AFC values – reliability is not endangered by the overselling of ATC, but rather by the overscheduling of the system, which these standards do not address.
Group
The Southeast Coalition
Roberto Paliza
Paliza Consulting, LLC.
Yes
 
No
Comments: In certain regions of the country, transactions within a control area, i.e. internal-transactions, with a NERC priority 6 are not curtailed under TLR because they are not considered “interchange” transactions and thus, they are not processed by the IDC. These non-firm internal-transactions are curtailed along with Network and Native Load (NNL) service in TLR events. Thus, in these regions, overselling of non-firm NERC priority 6 internal-transactions could lead to curtailment of firm service.
Yes
Comments: Agree. But the standard should recognize that some Load Serving Entities (LSEs) do not need CBM because the availability and diversity of third-party generation sources located in and around these entities ensure availability of imports into these LSEs. All LSEs should be required to perform a CBM requirement analysis in a transparent manner. A CBM requirement of zero could be a valid conclusion for some LSEs.
Yes
Comments: Agree with all proposed risk factors except R4 & R5 VRFs. We believe that the VRFs for R4 & R5 should be set to ‘Medium’ instead of ‘Lower’ because it is important to notify adjacent Transmission Operators and Reliability Coordinators of changes in ATC methodology to avoid overselling which may lead to curtailment of firm service. Timely notification of ATC calculation changes among adjacent Transmission Providers/Operators is very important to have an accurate and reliable coordination of ATCs and avoid overselling of transmission service.
 
Yes
 
 
 
Yes
Comments: Agree with all proposed risk factors except R7, R9 & R11 VRFs. We believe that the VRFs for R7, R9 & R11 should be set to ‘Medium’ instead of ‘Lower’. R7 & R9 are associated with calculation of non-firm ATC. As explained in question 2 above, overselling of non-firm NERC priority 6 internal-transactions could lead to curtailment of firm service. Thus, R7 & R9 VRFs should be set to ‘Medium’. R11 establishes the equation to convert AFCs to ATCs. This conversion is not done for convenience only. Conversion of AFC to ATC values is needed to support the transmission market because although, AFCs are the direct outcome of the calculations, transmission service is posted and sold in terms of ATCs. Therefore, an incorrect conversion of AFCs to ATCs could lead to misleading postings and overselling of firm service.
Individual
Dennis Kimm
MidAmerican Energy
Yes
The LSEs are relying on firm service to serve load and if that service is oversold and curtailments need to take place, it is definitely putting LSEs at risk of shedding firm load. Inside a LMP market, firm transmission service really has no meaning, but in a bilateral environment, the calculation of firm service that is linked to a capacity purchase is very important.
Yes
Non-firm service should be used for economic purchases only.
Yes
This would only apply if the the LSE is relying on CBM in resource adequacy. If the CBM = 0 then my answer would be "NO"
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
 
Individual
Jason Shaver
American Transmission Company
No
There is no “direct” relationship between selling ATC/AFC and load shedding. Any time an unforeseen system condition arises there is the possibility that ATC/AFC has been oversold, but that does not mean that and SOL/IROL will be violated or that load will be shed. The problems potentially arise when ATC/AFC is oversold AND all or most of the reservations in one direction are scheduled upon AND a relatively small amount of reservations in the counterflow direction have been scheduled upon AND the amount of flow above the ATC/AFC exhausts the TRM and CBM that have been set aside for the path/flowgate. Maintaining the firm service is not the top priority, serving load is. Firm service can be curtailed under TLR 5 without shedding load.
Yes
 
Yes
 
No
Based on the response to item 1, the VRF’s for this standard should be “Lower”. Further, regarding R6 and R7, if the TO or TSP does NOT follow these requirements, the result is that the entity would calculate ATC or AFC using assumptions that are MORE LIMITING than those used in operations, which results in LESS firm ATC or AFC being made available. Underselling Firm ATC or AFC does not adversely affect the electrical state of the BPS or directly affect the ability to effectively monitor the BPS, so a “Medium” VRF is not warranted.
No
Comments: Only requirements dealing with the use of CBM in the real-time operating horizon (R11 and R12) should be given VRF’s of “Medium”. All other should be given a VRF of “Lower” because they do not “directly” affect the electrical state or capability of the BPS. Determining the amount of CBM “allocated” and “used” is a bookkeeping exercise. There should not be a circumstance under which an energy deficient entity with sufficient import ties is denied use of CBM and is forced to shed load. In the planning horizon, a certain amount of CBM is set aside in order to provide the breathing room necessary to serve load in severe resource outage scenarios, but in an operational emergency the firm service other than CBM can be curtailed to allow the load in question to be served. Sink points of any curtailed firm service would then either acquire new service on paths that do not exacerbate any overloads or could rely on CBM themselves in order to not shed load.
No
Based on the response to item 1, the VRF’s for this standard should be “Lower”. Further, regarding R1 and R2, double-counting CBM factors in withholding TRM may results in underselling Firm ATC or AFC, but this does not adversely affect the electrical state of the BPS or directly affect the ability to effectively monitor the BPS, so a “Medium” VRF is not warranted.
 
 
No
The medium VRF’s are predicated on the assumption that overselling Firm ATC/AFC “directly” causes load shed or “directly” impacts the capability of the BPS, which is not true, per the response to item 1. All VRF’s for this standard should be “Lower”.
Group
PacifiCorp
Sandra Shaffer
Pacificorp
 
 
 
 
 
 
 
 
 
Individual
Greg Rowland
Duke Energy
No
Comments: There is no direct relationship between selling ATC and exceeding SOL/IROLs because there is no requirement that Firm ATC/AFC, once sold, must be scheduled to move energy. Comments: As stated above, not all firm service that is sold is scheduled. There are many barriers that prevent overselling from resulting in overscheduling. The Reliability Coordinators are required to perform Operational Planning Analyses for the next day and Real-Time Assessments intra-day to detect and prevent any IROL violations. TLRs currently in effect can prevent loading of new schedules or increases in schedules that adversely impact heavily loaded lines. Experienced system operators also must approve schedules before they are implemented. There are also remedies other than load shedding in the event that the system is overscheduled, such as redispatching generation, reconfiguring the transmission system, calling TLRs to cut schedules and deploying reserves. From the standpoint of risk to the BPS and the fact that these VRF’s are associated with a reliability standard, controlled load shedding does not necessarily indicate a significant BPS reliability risk – especially because load shedding would normally be implemented after the previously mentioned remedies.
Yes
Comments: The determination of Non-Firm ATC/AFC is a “Lower” risk activity because it can not directly affect the electrical state or the capability of the BPS, or the ability to effectively monitor and control the BPS.
Yes
Comments: It may necessitate shedding firm load only if the entity in an energy-deficient situation is counting on it to access energy.
No
Comments: The VRF for R1, R2, R3, R6, R7, and R8 should remain “Lower” because the VRF for Firm ATC as well as Non-Firm ATC should be “Lower”. In addition, R6 and R7 were designed primarily to ensure comparability, not reliability. Using assumptions in the TTC and ATC calculation that are more limiting than those used in planning of operations would most likely result in conservative TTC/ATC values. Overall the ATC Standards contain requirements that are more commercial in nature than the majority of other NERC Reliability Standards and therefore violation of the requirements in the ATC Standards would generally result in less risk to the reliable operation of the Bulk Electric System. To support consistency of VRFs among standards the majority of the VRFs for the ATC Standards should be “Lower”. The VRF for R9 should be “Medium” because it supports Recommendation 24 of the Final Report on the August 14, 2003 Blackout.
No
Comments: R1, R2, R7, R11 and R12 are the only requirements that should be assigned a “Medium” VRF. Denial of access to available CBM is more likely to directly affect the electrical state of the BPS than correct Firm ATC determination because this deals with actual scheduling, in an energy deficient state. The VRF for R5 should remain “Lower” rather be assigned “Medium”. If the TSP does not establish a CBM no entity will be erroneously depending on it.
No
Comments: The VRF for R2 should remain “Lower” because there is no adverse reliability affect in including additional risks in TRM, and would thus not invalidate the TTC/ATC calculation. If anything it would be unnecessarily conservative. Leaving the VRF for R2 at “Lower” would remove the argument for R1 to be anything other than “Lower”. Since Duke disagrees that determination of Firm ATC should have a “Medium” VRF, there is no argument for R4 and R5 to have “medium” VRFs, and they should therefore be left at “Lower”.
No
For the reasons stated in the response to Question 1 above, Duke does not believe that the calculation of Firm ATC is directly tied to the ability to serve load. We find that the NERC staff analysis has taken too narrow and literal an interpretation of the VRF definitions. The concept of risk includes a measure of probability as well as a measure of the severity of consequences. The probability of incorrect ATC calculations resulting in load loss is quite small as argued previously. Load loss in and of itself does not necessarily affect the reliability of the BPS, which should be the primary focus of the NERC Reliability Standards. This analysis therefore inappropriately attempts to equate BPS reliability with commercial concerns and customer service reliability. For these reasons the VRF for R10 should not be raised to “Medium”, but should remain “Lower”. Duke disagrees that the VRF assignment for Firm ATC determination should be “Medium”, and therefore disagrees that R1, R3, R4, R5, R6, R7, and R8 should be assigned “Medium” VRFs. FAC-008 contains requirements for development of facility ratings and therefore is the primary vehicle for fulfilling Recommendation 27 of the Final Report on the August 14, 2003 Blackout. R2 should not be relied on to fulfill that recommendation, so there remains no reason to raise the VRF for R2 to “Medium”.
No
Comments: Duke disagrees that the VRF assignment for Firm ATC determination should be “Medium” for the reasons stated in the response to Question 7, and therefore disagrees that R1, R2, R3, R4, R5, and R7 should be assigned “Medium” VRFs.
No
Comments: Duke disagrees that the VRF assignment for Firm ATC determination should be “Medium” for the reasons stated in the response to Question 7, and therefore disagrees that R1, R2, R3, R4, R5, R6, R8, and R9 should be assigned “Medium” VRFs.
Group
Midwest ISO Standards Collaborators
Jason Marshall
Midwest ISO
No
First, the concept of overselling Firm ATC/AFC is misapplied. To avoid overselling Firm ATC/AFC, you simply sell no more ATC/AFC when the ATC/AFC reaches zero. Transmission studies used to determine TTC/TFC are based on a set of assumed conditions. Changes to those assumptions will result in differing values of TTC/TFC. If all ATC/AFC is sold based on the latest system conditions and then those conditions change, it is possible that there may be negative ATC/AFC. Thus, Transmission Service Providers would not have sold some of the transmission reservations had they anticipated the change to the transmission system assumptions. Transmission Service Providers and their associated planners and operators regularly respond to these types of conditions and there is not a single documented case of it leading to load shedding. Because of this, it would be difficult to conclude that the system is really oversold. Furthermore, what does this really mean for the system to be oversold, in any case? We believe bullet 3 demonstrates the author(s) misunderstanding of assessing Violation Risk Factors. The definition of the Violation Risk Factors does not require that there is no relationship between selling of Firm ATC/AFC and exceeding SOL/IROLs to establish that the Violation Risk Factor is Lower. In fact, the very definition of Lower includes “be expected to affect” and “directly affect”. Thus, there can be a relationship and there is a relationship. Rather to meet the Medium Violation Risk Factor definition a violation of the requirement must directly affect the electrical state or capability of the BPS, directly affect the ability to monitor and control the BPS or in the planning time frame, under emergency abnormal, or restorative conditions, could meet either of the previous two. “Overselling” Firm ATC/AFC does not meet these criteria because there is not a direct link. Selling transmission service does not result in transmission flows and cannot even be predicted to consistently result in transmission flows. Once a transmission customer has confirmed a transmission reservation, the customer only has a right but not an obligation to use the service. Before any flow ever even will occur on the system due to a transmission reservation, an E-Tag must be submitted to schedule the service, all reliability entities (BA, TSPs) must approve the schedule. If there is a TLR level 3 or higher implemented, the schedule will be either halted or reallocated. One may argue that it is not necessary for actual flows to materialize on the transmission system because the Medium VRF definition considers the planning time frames. However, we counter that the argument is irrelevant because AFC/ATC are only calculated 13 months out, and TRM is intended to account for some of the uncertainties that could occur this far out. Thus, again, there is no direct connection. Does planning horizon even apply? In the ten+ years since FERC mandated open access and set firm transmission service at the same level of NITS and NNL, please give us an example when firm load was ever shed from “overselling” transmission service? We cannot identify any examples. There are so many ways to mitigate a transmission overload, such as redispatch and reconfiguration, that it is highly unlikely that an entity will ever have to shed load due to selling transmission service. After all, selling firm transmission service does not create more load.
Yes
 
Yes
 
No
Based on our arguments in question 1, we believe all the VRFs for this standard should be Lower.
No
Based on our analysis of question 1, we believe that R1-R10 should have Lower VRFs. We do believe that lack of CBM could have directly affected that electrical state of the BES, so we agree with R11 and R12 having Medium VRFs.
No
We do not see how TRM can directly impact the electrical state of the BES. Based on our answer to question 1 and our response here, we believe that all the VRFs should be Lower.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, we believe that all of the VRFs should be Lower.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, we believe that all of the VRFs should be Lower.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, we believe that all of the VRFs should be Lower.
Individual
Aaron Staley
Orlando Utilities Commisson
 
Yes
The overselling of Non-Firm by itself will not lead to the unexpected shedding of firm load.
 
No
R6 & R7 should be assigned a lower VRF. The justification of a "Medium" VRF on firm ATC is based on the premise that overselling of firm ATC can result in system problems. A Violation of R6 or R7 would make less ATC available, which would not contribute to the system problems. A violation of R6 and R7 just means the TSP or TOP is not providing consistent treatment of customers, but will not result in overselling of firm ATC.
 
No
R2 should be assigned a lower VRF. The justification of a "Medium" VRF for firm ATC is based on the premise that overselling of firm ATC can result in system problems. A Violation of R2 would make less ATC available, which would not contribute to the system problems. A violation of R2 means a TOP is double counting or including considerations not allowed under R1, in either case however the violation would not result in the overselling of firm ATC.
 
 
 
Individual
Edward Davis
Entergy Services, Inc
No
In its staff analysis, NERC states that, “[f]irm transmission service is sold to customers with the contractual obligation that the provider take action to ensure that service is not interrupted. When operating conditions require firm transmission service to be interrupted, it is possible that customer load will be lost. Accordingly, NERC staff believes that the interruption of firm service and possible accompanying load loss directly affects the state or capability of the [Bulk Power System].” See NERC Staff Report at 3. NERC staff then uses this assumption to justify the increase of several ATC-related VRFs that involve the determination of “firm” commitments. Entergy disagrees with the underlying premise that NERC staff uses to increase ATC-related VRFs from “lower” to “medium” for several reasons. First, transmission providers are not contractually obligated to ensure firm transmission service is not interrupted, and we know of no order or regulation that finds otherwise. Second, NERC staff’s analysis assumes that the calculation of ATC/AFC reflects the actual, real-time use of the transmission system. However, calculation of ATC/AFC is accomplished through the use of models that simulate system conditions, and these models, by their very nature, are predicative tools based on assumptions subject to change during the operating and planning horizons. In fact, the Federal Energy Regulatory Commission (“FERC” or “Commission”) has recognized this fact in its orders. In its market-based rate order, the Commission stated that it, “agrees... that short-term firm reservations can be unpredictable, driven by real time system conditions.” See Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities, 119 FERC 61,295 at P 368 (2007). For longer term service, ATC calculations may be affected by changes in system topology and other factors. Generation locations, run levels, transfers of power on other transmission systems, pre-loading the transmission providers system in real time, and many other system conditions may lead to potentially overloaded facilities during real-time operation. In order to deal with such issues, procedures, such as Transmission Loading Relief (“TLR”) and Redispatch, are utilized in order to avoid the shedding of firm load. In such situations, use of Commission-accepted practices and procedures, designed to avoid the shedding of firm load, should be factored into NERC staff’s analysis and the underlying “determination” alone should not be viewed as having a direct impact on the Bulk Power System thus necessitating a VRF of “medium.” Finally, the Commission has recognized in other contexts that congestion is an economic issue and not a reliability issue. For example, on the Entergy system, upgrades to reduce TLRs are considered economic upgrades and not reliability upgrades. See Entergy Services, Inc., 115 FERC 61,095 (2006), order on reh’g, 116 FERC 61,275 (2006). For these reasons, Entergy believes that the VRFs for ATC-related Reliability Standards should be “lower” as approved by the stakeholders.
Yes
 
Yes
 
No
Entergy believes that the ATC-related VRFs should be “lower” as approved by the stakeholders. See comments above. In addition, Entergy has concerns generally with NERC’s application of Guideline 2 in MOD-001-1 as well as in other ATC-related standards. It also has more specific concerns related to specific requirements of MOD-001-1. Entergy will first set forth its overarching concern with the application of Guideline 2, and then address its specific issues related to certain requirements in MOD-001-1. In its Staff Report, NERC staff has predicated its entire analysis on its finding that, “the determination of ATC can cause a direct impact on the ability to effectively monitor and control the [Bulk Power System]…[thus] the assignment of a “medium” VRF more aptly describes the general impact caused by the determination of ATC specifically and the implementation of the ATC standards in general.” Staff report at p. 3 (emphasis added). NERC staff then uses this general finding to apply Guideline 2 of the Commission’s May 18, 2007, Order on Violation Risk Factors, 119 FERC 61,145. As set forth above, Entergy disagrees with the underlying premise and believes that the requirements should reflect the “lower” VRF approved by the stakeholders. However, even if you assume that NERC staff’s assumption about the impact is correct, it has misapplied the guidelines issued by FERC for setting Violation Risk Factors. Guideline 2, as recognized by NERC Staff in its report, requires that a “requirement within a standard that is essential to achieving compliance with another requirement in the standard should have a VRF consistent with the requirement it is supporting.” Staff Report at 4 (emphasis added). In other words, Guideline 2 requires that requirements be consistent within the same standard. However, all of the requirements for MOD-001-1 were approved by the stakeholders as “lower” VRFs. Thus, NERC staff has substituted its judgment for that of the stakeholders, and then used Guideline 2 to justify changing most of the VRFs in MOD-001 from “lower” to “medium.” Entergy believes that this is an inaccurate application of Guideline 2, which was designed to ensure consistency within a reliability standard. Thus, all of the VRFs should retain the “lower” designation approved by the stakeholders. Having said that, if NERC staff does not recommend “lower” VRFs for all of the requirements, it should, at a minimum, adopt the “lower” VRFs for certain documentation requirements. Entergy disagrees with the application of the “medium” VRF to several documentation requirements that are administrative in nature and pose no real threat to the Bulk Power System. In fact, the Commission has recognized that, “[a] “lower” risk Requirement, by definition, indicates that the corresponding Requirements are “administrative” in nature.” Mandatory Reliability Standards for Critical Infrastructure Protection, 126 FERC 61,065 (2009). Applying a “lower” VRF to administrative and documentation requirements is consistent with NERC’s approach to other Reliability Standards. In several other standards, NERC has approved lower VRFs for documentation requirements while maintaining higher VRFs for other requirements within the same standard. See CIP-005-1, CIP-007-1, FAC-008-1, NUC-001-1, PRC-004-1, PRC-016-0, and TPL-004-0. Entergy’s concerns with NERC staff’s specific findings related to VRFs for certain requirements in MOD-001-1 are as follows: Requirement R1 requires a Transmission Operator to select a single methodology for calculating ATC or AFC. The choice of a single methodology does not directly affect the reliability of the Bulk Power System and thus R1 should be a “Lower” VRF. Requirement R3 requires a Transmission Provider to keep an ATC Implementation Document. Again, documentation does not have a direct impact on the Bulk Power System and such requirements should receive a “lower” VRF.
No
Please see comments above regarding Entergy’s disagreement with the underlying premise that NERC staff uses to increase ATC-related VRFs from “lower” to medium” and to justify increasing VRFs for documentation and administrative requirements from “lower” to “medium.” Regarding specific requirements, Entergy offers the following comments: Requirement R1 requires only administrative information and descriptions for inclusion in the CBMID. We therefore recommend this VRF remain at “lower” and not be changed to “medium.” Requirement R2 requires a Transmission Provider to make its CBM Implementation Plan available to Transmission Operators, Transmission Service Providers, Reliability Coordinators, Transmission Planners and Planning Coordinators. As set forth above, administrative activities do not affect the Bulk Power System and thus should be given a VRF of “lower.” In addition, NERC staff’s proposal to give this requirement a “medium” VRF is inconsistent with the “lower” VRF assigned to MOD-001-1 R5, which requires that the ATC Implementation Plan be made available to the same entities. Requirement R7 requires only administrative information be passed to LSEs and RPs. We therefore recommend this VRF remain at “lower” and not be changed to “medium.”
No
Please see comments above regarding Entergy’s disagreement with the underlying premise that NERC staff uses to increase ATC-related VRFs from “lower” to “medium” and to justify increasing VRFs for documentation and administrative requirements from “lower” to “medium.” Requirement R1 requires a Transmission Provider to keep a TRM Implementation Document. Again, documentation does not have a direct impact on the Bulk Power System and such requirements should receive a “lower” VRF.
No
Please see comments above regarding Entergy’s disagreement with the underlying premise that NERC staff uses to increase ATC-related VRFs from “lower” to medium” and to justify increasing VRFs for documentation and administrative requirements from “lower” to “medium.” Regarding specific requirements, Entergy offers the following comments: For Requirement R1 NERC Staff states that R1 “specifies the creation of rules and process that later requirements mandate the use of” and then calling on FERC VRF Guideline 2 justify the proposed change to Medium VRF. Entergy disagrees with NERC Staff that this requirement “specifies the creation of rules and process.” R1 requires only administrative information and descriptions for inclusion in the ATCID. We therefore recommend this VRF remain at “lower” and not be changed to “medium.”
Yes
 
No
Please see comments above regarding Entergy’s disagreement with the underlying premise that NERC staff uses to increase ATC-related VRFs from “lower” to “medium” and to justify increasing VRFs for documentation and administrative requirements from “lower” to “medium.” Regarding specific requirements, Entergy offers the following comments: For Requirement R1 NERC Staff states that R1 “specifies the creation of rules and process that later requirements mandate the use of” and then calling on FERC VRF Guideline 2 justify the proposed change to Medium VRF. We disagree with Staff that this requirement “specifies the creation of rules and process”. There is only administrative information and descriptions required by R1 to be included in the ATCID. We therefore recommend this VRF remain at “lower” and not be changed to “medium.”
Group
MRO NERC Standards Review Subcommittee
Michael Brytowski
Midwest Reliability Organization
No
There is no “direct” relationship between selling ATC/AFC and load shedding. Any time an unforeseen system condition arises there is the possibility that ATC/AFC has been oversold, but that does not mean that and SOL/IROL will be violated or that load will be shed. The problems potentially arise when ATC/AFC is oversold AND all or most of the reservations in one direction are scheduled upon AND a relatively small amount of reservations in the counterflow direction have been scheduled upon AND the amount of flow above the ATC/AFC exhausts the TRM and CBM that have been set aside for the path/flowgate. In fact, the very definition of Lower includes “be expected to affect”. Rather to meet the Medium Violation Risk Factor definition a violation of the requirement must directly affect the electrical state or capability of the BPS, directly affect the ability to monitor and control the BPS or in the planning time frame, under emergency abnormal, or restorative conditions, could meet either of the previous two Therefore, since there is not a direct relationship or impact on the bulk electric system that overselling ATC/AFC leads to firm load shedding, by definition the VRF does not meet the “Medium” criteria. The MRO NSRS believes the VRF should remain “Lower”. MRO NSRS believes NERC incorrectly applied Guideline 2 to the requirements. The FERC in their Guideline 2 calls for consistency within requirements and sub-requirements. What NERC lists as Guideline 2 is their interpretation/paraphrasing and is not correct. NERC states that if X=A+B and ‘X’ is higher, then ‘A’ and ‘B’ must be higher. The MRO NSRS strongly disagrees with NERC’s conclusion, and believes it is not necessary for ‘A’ or ‘B’ to be higher for ‘X’ to be higher. In the ten plus years since FERC mandated open access and set firm transmission service at the same level of NITS and NNL, please give us an example when firm load was ever shed from “overselling” transmission service? We cannot identify any examples. There are so many ways to mitigate a transmission overload, such as redispatch and reconfiguration, that it is highly unlikely that an entity will ever have to shed load due to selling transmission service. After all, selling firm transmission service does not create more load. As long as the TTC/TFC is less than the SOL/IROLs, there is no overselling firm service that would potentially require load shedding to maintain such service. Maintaining the firm service is not the top priority, serving load is. Firm service can be curtailed under TLR 5 without shedding load.
Yes
 
Yes
 
No
Based on the MRO NSRS arguments in question 1, the MRO NSRS believes all the VRFs for this standard should be “Lower”. None of the requirements for MOD-001-1 directly impacts the reliability of the BPS.
No
Based on our analysis of question 1, we believe that R1-R10 should have Lower VRFs. The MRO NSRS does believe that lack of CBM could directly affect the electrical state of the BPS, so the MRO NSRS agrees with R11 and R12 having Medium VRFs.
No
The MRO NSRS does not see how TRM can directly impact the electrical state of the BPS. Based on our answer to question 1 and our response here, the MRO NSRS believes that all the VRFs should be, ”Lower”. Further, regarding R1 and R2, double-counting CBM factors in withholding TRM may results in underselling Firm ATC or AFC, but this does not adversely affect the electrical state of the BPS or directly affect the reliability of the BPS, so a “Medium” VRF is not warranted
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, the MRO NSRS believes that all of the VRFs should be “Lower”.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, the MRO NSRS believes that all of the VRFs should be “Lower”.
No
The medium VRF’s are predicated on the assumption that overselling Firm ATC/AFC “directly” causes load shed or “directly” impacts the capability of the BPS, which is not true, per the response to item 1. All VRF’s for this standard should be “Lower”.
Group
Santee Cooper
Terry L. Blackwell
Santee Cooper
No
The buying of ATC through OASIS is simply a reservation system. ATC has to be scheduled before the energy is allowed to flow. Selling of ATC is simply a reservation and there is not a direct relationship to load shedding. ATC has to be scheduled and there are barriers in place to prevent overscheduling. Real-time and next day studies are performed to detect potential SOL or IROL violations. If potential violations are detected, actions are taken to elminate them.
Yes
 
No
See comments on Question 5.
No
R1 requires the selection of an ATC methodology. Selection of an ATC methodology does not have a direct affect on the reliability of the BPS. This VRF should be changed back to Lower. R3 requires the TP to have an ATCID. A requirement for having documentation does not have a direct affect on the reliability of the BPS. This VRF should be changed back to Lower. R6 and R7 These requirements relate to more of a business practice for the industry and have no direct affect on the reliability of the BPS. The VRFs for R6 and R7 should be changed back to Lower. R9 requires a that data be provided to others within 30 calendar days. If data does not have to be provided until 30 days then it does not have an immediate affect on the BPS so the VRF for this requirement should be changed back to Lower.
No
R1 requires the TP to have a CBMID. A requirement for having documentation does not have a direct affect on the reliability of the BPS. This VRF should be changed back to Lower. R2 requires the TP to make its CBMID available. This does not warrant a VRF of Medium and should be changed back to Lower. R7 requires notification to those that requested CBM. A notification does not warrant a VRF of Medium and should be changed back to Lower.
No
R1 requires the TP to have a TRMID. A requirement for having documentation does not have a direct affect on the reliability of the BPS. This VRF should be changed back to Lower. R2 seems to relate more to a business practice for the industry and should be changed back to a VRF of Lower. R3 requires the TP to make its TRMID available. This does not warrant a VRF of medium and should be changed back to Lower.
No
R1 requires certain information be documented in the ATCID. Requirements that are for documenation only should be designated as a Lower VRF.
 
 
Individual
Ray Kershaw
ITC Holdings
 
 
 
No
ITC agrees with all changed VRFs accept those for R7. While we believe this would constitute a serious violation, it would be a violation based on “discriminatory” or NAESB criteria and not NERC reliability criteria. If assumptions were “less limiting” than operational planning criteria, it would meet Medium VRF criteria but having “more limiting” criteria would make the ATC results “discriminatory” but stronger from a reliability perspective. We recommend changing to “Lower”.
No
ITC agrees with all changed VRFs, however we disagree with lower VRF for R6 and R8. The logic that you are at least a year or two away from a reliability problem if a planner fails to determine appropriate CBM is “short-sighted”. CBM is a margin designed to prevent sales of transmission service so that it can be used in an emergency to serve load and thus prevent unnecessary load shedding. If insufficient CBM is preserved and firm service, particularly any long term firm service, is sold, there will not be sufficient CBM when that year or two (or five) is up. Given the time frame required for planning most transmission upgrades or generator resource additions, the planner may and likely will not have time to rectify the situation. Once the service is sold as firm, it cannot be rescinded. Postponing a reliability problem is not a justification for lower VRF, we strongly recommend changing to this to “Medium” and believe it meets the criteria stated for this, particularly within the first 5 year time frame. With regard to R8, this is more of a problem for the resource planner. CBM represents a resource to them and failure to notify them may result in there having insufficient time to acquire additional resources. We believe the SDT put this requirement in for good reason. We suggest a medium VRF.
Yes
 
No
We do not necessarily concur with NERC staff in that failure to calculate non-firm properly only has financial impacts. Selling high levels of non-firm is beneficial in that it insures full utilization of the transmission system and, as such, should not be discouraged. However, there is a risk in “over-selling” the system, such that excessive sales result in a constant reliance on TLR levels to insure that excess non-firm sales are not scheduled, thus overloading the system. “Over-selling” non-firm does not have reliability consequences in so far as it is managed properly. The measures are aimed at compliance with calculation criteria but do not include any measures as to how often non-firm sales result in excessive TLRs or actual system overloads. In examining standards related to TLR and scheduling, we’re not sure that there is any connection between excess non-firm sales and observed real-time problems that these sales might produce. In the absence of this connection, we recommend that the VRF for R9 and R11 be changed to Medium VRF because the consequence of a violation can be more than just financial.
No
We do not necessarily concur with NERC staff in that failure to calculate non-firm properly only has financial impacts. Selling high levels of non-firm is beneficial in that it insures full utilization of the transmission system and, as such, should not be discouraged. However, there is a risk in “over-selling” the system, such that excessive sales result in a constant reliance on TLR levels to insure that excess non-firm sales are not scheduled, thus overloading the system. “Over-selling” non-firm does not have reliability consequences in so far as it is managed properly. The measures are aimed at compliance with calculation criteria but do not include any measures as to how often non-firm sales result in excessive TLRs or actual system overloads. In examining standards related to TLR and scheduling, we’re not sure that there is any connection between excess non-firm sales and observed real-time problems that these sales might produce. In the absence of this connection, we recommend that the VRF for R6 and R8 be changed to Medium VRF because the consequence of a violation can be more than just financial.
No
We do not necessarily concur with NERC staff in that failure to calculate non-firm properly only has financial impacts. Selling high levels of non-firm is beneficial in that it insures full utilization of the transmission system and, as such, should not be discouraged. However, there is a risk in “over-selling” the system, such that excessive sales result in a constant reliance on TLR levels to insure that excess non-firm sales are not scheduled, thus overloading the system. “Over-selling” non-firm does not have reliability consequences in so far as it is managed properly. The measures are aimed at compliance with calculation criteria but do not include any measures as to how often non-firm sales result in excessive TLRs or actual system overloads. In examining standards related to TLR and scheduling, we’re not sure that there is any connection between excess non-firm sales and observed real-time problems that these sales might produce. In the absence of this connection, we recommend that the VRF for R7 and R9 be changed to Medium VRF because the consequence of a violation can be more than just financial.
Individual
D. Bryan Guy
Progress Energy Carolina, Inc
No
There is no direct relationship between selling ATC and exceeding SOL/IROLs because not all ATC, once sold, must be scheduled to move energy. There are many barriers that prevent overselling from resulting in overscheduling. The RCs are required to perform Operational Planning Analyses for the next day and Real-Time Assessments intra-day to detect and prevent any IROL violations. TLRs currently in effect can prevent loading of new schedules or increases in schedules that adversely impact heavily loaded lines. Experienced system operators also must approve schedules before they are implemented. There are also remedies other than load shedding in the event that the system is overscheduled, such as redispatching generation, reconfiguring the transmission system, calling TLRs to cut schedules and deploying reserves.
Yes
 
Yes
 
No
R1, and R3, should stay at a lower VRF because these requirements are documentation related and do not directly affect the reliability of the BPS. R6 and R7 should stay at a lower VRF because some of the assumptions made during the planning time frame may not be valid in a real-time calculation due to the currently known conditions of the power system.
No
R1 and R2 should stay at a lower VRF because these requirements are documentation related and do not directly affect the reliability of the BPS. R7 should stay at a lower VRF because the requirements impact the way Firm ATC is determined or approved.
No
R1 and R2 should stay at a lower VRF because these requirements are documentation related and do not directly affect the reliability of the BPS.
 
 
No
R1
Group
Southern Company - Transmission
Marc M. Butts
Southern Company Services
No
We feel that the question itself is misleading by inferring that firm load would be shed when an inaccurate ATC is made. Also, we feel that no TSP would sell an unlimited amount of ATC. There is no direct relationship between selling ATC and exceeding SOL/IROLs because not all ATC, once sold, must be scheduled to move energy. There are many barriers that prevent overselling from resulting in over-scheduling. The Reliability Coordinators are required to perform Operational Planning Analyses for the next day and Real-Time Assessments intra-day to detect and prevent any IROL violations. Also, there are other mitigating measures that exist that would reduce or eliminate the probability of shedding load to prevent any SOL/IROL violations. These would include, but are not limited to, system reconfiguration, reserves, generation re-dispatch and utilizing other external resources. Utilizing the TLR process is also available if needed, as a last resort. It is important to note that if an entity would have to resort to shedding load while exceeding the ATC, there are likely other extenuating causes other than an inaccurate ATC calculation. For example, abnormal system events or multiple contingencies could affect or reduce the TTC of the interface resulting in a lower ATC.
Yes
 
Yes
 
No
We feel R1, R3, R6 and R7 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS.
No
We feel all requirements should stay at a lower VRF (other than R11 and R12) because we feel that these requirements do not directly affect the reliability of the BPS, that would necessitate a medium VRF.
No
We feel R1, and R2 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS.
No
We feel R1 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS.
 
No
We feel R1 should stay at a lower VRF because we feel that these requirements do not directly affect the reliability of the BPS.
Group
ISO/RTO Council Standards Review Committee (SRC)
Ben Li
IESO
No
Generally speaking, ATCs/AFCs are commercial parameter – a service, determined within reliability boundaries. This service is thus sold within reliability bounds. The concept of overselling Firm ATC/AFC is thus misapplied. To avoid overselling Firm ATC/AFC, one simply sells no more ATC/AFC when the ATC/AFC reaches zero. Transmission studies used to determined TTC/TFC are based on a set of assumed conditions. Changes to those assumptions will result in differing values of TTC/TFC. If all ATC/AFC is sold based on the latest system conditions and then those conditions change, it is possible that there may be negative ATC/AFC. Thus, the Transmission Service Planner wouldn’t have sold some of the transmission reservations had it anticipated the change to the transmission system assumptions. Planners and operators regularly respond to these types of conditions and there is not a single documented case of “overselling” transmission service leading to load shedding. So how can you say the system is really oversold and what does this term really mean anyway? We believe question 3.) above demonstrates a misunderstanding of assessing Violation Risk Factors. The definition of the Violation Risk Factors does not require that there is no relationship between selling of Firm ATC/AFC and exceeding SOL/IROLs to establish that the Violation Risk Factor is Lower. In fact, the very definition of Lower includes “be expected to affect” and “directly affect”. Thus, there can be a relationship and there is a relationship. To meet the Medium Violation Risk Factor definition, a violation of the requirement must directly affect the electrical state or capability of the BPS, directly affect the ability to monitor and control the BPS or in the planning time frame, under emergency abnormal, or restorative conditions, could meet either of the previous two. “Overselling” Firm ATC/AFC does not meet these criteria because there is not direct link. Selling transmission service does not automatically result in transmission flows and can’t even be predicted to consistently result in transmission flows. Once a transmission customer has confirmed a transmission reservation, the customer only has a right but not an obligation to use the service. Before any flow actually occurs on the system from a transmission reservation, an E-Tag must be submitted to schedule the service and all reliability entities (BA, TSPs) must approve the schedule. When a transmission constraint exists on the system, power flows on critical facilities will be adjusted to allow the flow to occur without risking the interconnected system’s reliability. One may argue that it is not necessary for actual flows to materialize on the transmission system because the Medium VRF definition considers the planning time frames. However, we counter that the argument is irrelevant because AFC/ATC are only calculated out 13 months and TRM is intended to account for some of the uncertainties that could occur this far out. Thus again there is no direct connection. Does planning horizon even apply? In the ten+ years since FERC mandated open access and set firm transmission service at the same level as NITS and NNL, please give us an example when firm load was ever shed from “overselling” transmission service? We can’t identify any examples. There are so many ways to mitigate a transmission overload such as redispatch and reconfiguration that it is highly unlikely that an entity will every have to shed load due to selling transmission service. After all, selling firm transmission service does not create more load.
Yes
 
 
No
 
No
Based on our analysis of question 1, we believe that R1-R10 should have Lower VRFs. We do, however, believe that for those areas that employ CBM, lack of CBM could directly affect the electrical state of the BES so we agree with R11 and R12 having Medium VRFs.
No
We do not see how TRM can directly impact the electrical state of the BES. TRM is a reliability margin to cover operating uncertainties, and is one of the components used in determining ATC/AFC. Based on our answer to question 1 and our response related to the ATC/AFC here, we believe that all the VRFs for the TRM related standard requirements should be Lower.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, we believe that all of the VRFs for this standard should be Lower.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, we believe that all of the VRFs for this standard should be Lower.
No
Based on our answer to question 1 and our belief that the only CBM from these standards could have a medium VRF, we believe that all of the VRFs for this standard should be Lower.