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 Individual or group.NameOrganizationGroup NameLead ContactContact OrganizationQuestion 1Question 2Question 2 CommentsQuestion 3Question 3 CommentsQuestion 4 Comments
Group  SERC ATCWGDoug BaileyTennessee Valley Authority Yes Yes  
Group  WECC Market Interface Committee / Sub Commtt? ATC Task ForceW. Shannon BlackSMUDMOD-30, M13 and M14 as drafted require the TSP to be "capable" of demonstration but do not require actual demonstration. The WECC Team suggests a minor rewrite to state, "The TSP shall demonstrate that..." This shifts the measurement from the TSP's mere capability to an actual performance. Yes Yes Should the term "dispatch order" in MOD-30, R6.1.2 be a capitalized defined term?
IndividualJack Cashin/Barry GreenEPSA   Through this revision process, some of the MOD standards have included an explicit requirement for consistency between planning assumptions and modeling assumptions used in calculation of ATC. In particular, requirement 6.1 of the previous version of MOD 030 included such a requirement and we believe it should be retained.  No comment no commentno comment
IndividualJim UseldingerKansas City Power & Light   The Transmission Service Provider should be added along with the TOP for these functions in all requirements.Yes Yes  
IndividualPaul RochaCenterPoint Energy        The group of standards is for ATC and TRM methodologies that are not used in ERCOT. CenterPoint Energy is concerned that ERCOT might have to adopt the ATC and TRM methodologies prescribed in these standards, which we believe would not add value to the ERCOT region and could increase congestion in the region. Accordingly, CenterPoint Energy previously submitted comments to these standards asking for an exemption for the ERCOT region. We find the proposed standards unacceptable unless the following provision is added to each standard: This standard does not apply to ERCOT or any other region that operates as a single control area.
Group  WECC Market Interface Committee ATC Task ForceW. Shannon BlackSMUD MOD-30, M13 and M14 as drafted require the TSP to be "capable" of demonstration but do not require actual demonstration. The WECC Team suggests a minor rewrite to state, "The TSP shall demonstrate that..." This shifts the measurement from the TSP's mere capability to an actual performance. Yes Yes Should the term "dispatch order" in MOD-030, R6.1.2 be a capitalized defined term?
IndividualH. Steven MyersERCOT ISO   Requirement 1: I suggest modifying the requirement to state: "The Transmission Service Provider with ATC Path(s) shall include in its “Available Transfer Capability Implementation Document” (ATCID)." Requirement 2: I suggest modifying the requirement to state: "The Transmission Operator with ATC Path(s) shall perform the following:" Requirement 3: I suggest modifying the requirement to state: "The Transmission Operator with ATC Path(s) shall make available to the Transmission Service Provider with ATC Path(s) a Transmission model to determine Available Flowgate Capability (AFC) that meets the following criteria:" Requirement 4: I suggest modifying the requirement to state: "When calculating AFCs, the Transmission Service Provider with ATC Path(s) shall represent the impact of Transmission Service as follows:" Requirement 5: I suggest modifying the requirement to state: "When calculating AFCs, the Transmission Service Provider with ATC Path(s) shall:" Requirement 6: I suggest modifying the requirement to state: "When calculating the impact of ETC for firm commitments (ETCFi) for all time periods for a Flowgate, the Transmission Service Provider with ATC Path(s) shall sum the following:" Requirement 7: I suggest modifying the requirement to state: "When calculating the impact of ETC for non-firm commitments (ETCNFi) for all time periods for a Flowgate the Transmission Service Provider with ATC Path(s) shall sum:" Requirement 8: I suggest modifying the requirement to state: "When calculating firm AFC for a Flowgate for a specified period, the Transmission Service Provider with ATC Path(s) shall use the following algorithm:" Requirement 9: I suggest modifying the requirement to state: "When calculating non-firm AFC for a Flowgate for a specified period, the Transmission Service Provider with ATC Path(s) shall use the following algorithm:" Requirement 10: I suggest modifying the requirement to state: "Each Transmission Service Provider with ATC Path(s) shall recalculate AFC, utilizing the updated models described in R3.3, R3.4, and R5, at a minimum on the following frequency:" Requirement 11: I suggest modifying the requirement to state: "When converting Flowgate AFCs to ATCs (and TFCs to TTCs) for ATC Paths, the Transmission Service Provider with ATC Path(s) shall convert those values based on the following algorithm:"    I suggest modifying the Applicability section to state: "4.1.1 Each Transmission Operator with ATC Path(s) that uses the Flowgate Methodology to support the calculation of Available Transfer Capabilities (ATCs) for ATC Paths." "4.1.2 Each Transmission Service Provider with ATC Path(s) that uses the Flowgate Methodology to calculate ATCs for ATC Paths."
IndividualFrank CumptonCalifornia ISO        R 3 – Should the actual Flowgate model made available to TSP upon request ONLY under NDA??? Confidential Model and access??? R 11 – SDT should clarify that MOD 30 R11 only specifies HOW AFC be converted and DOES NOT REQUIRE that it must be converted, as intent of SDT. MOD 30 does not REQUIRE that all AFCs be converted and posted to OASIS, irrespective of whether or not the ATC Path definition applies to internal lines for those with a flow based model.
IndividualMaria NeufeldManitoba Hydro    Yes Yes MH echoes the concerns raised and documented by MISO that MOD-030 requirements are generally more stringent than those outlined for MOD-028 and MOD-029.
Group  NPCC Regional Standards CommitteeGuy V. ZitoNortheast Power Coordinating CouncilNoneYes Yes  
Group  FirstEnergyDoug HohlbaughFirstEnergy Corp.Requirement 2, Applicable Entity: FE believes that this requirement and its associated sub-requirements are incorrectly assigned to the Transmission Operator. In reviewing the presently approved Functional Model (FM) Version 3 and its associated Technical Document, the determination of total transfer capability clearly falls to a planning function. In FM Version 3, task 3c of the Function – Planning Reliability states "Review and determine total transfer capability (generally one year and beyond) as appropriate." This is the only area that explicitly states "determine" as it relates to total transfer capability. The FM Version 3 later describes the responsibilities of the Planning Coordinators and Transmission Planners as having a role in coordinating total transfer capability. Nowhere within the Functional Model is this assignment relegated to the real-time aspect of the Transmission Operator. Additionally, since R2.5 allows the responsible entity to establish Total Flowgate Capabilities once per year, it would seem reasonable that this would be applicable to a planning function. FirstEnergy believes the appropriate responsible entity is the Planning Coordinator or Transmission Planner since this entity would likely have the same wide-area view that is covered by the corresponding Transmission Service Provider who is determining the Available Flowgate Capacility. Assigning the determination of total transfer capability to the Planning Coordinator would also better align the standard for implementation within the RTO construct as well as non-market areas. The tasks described within R2 are completed by FE's RTO organizations – MISO and PJM – for the transmission facilities owned and operated by FirstEnergy. The standard should not be written in a way that would knowingly require some sort of delegation assignment for a large portion of the transmission system. R2 - MOD-030 does not appear to be consistent with MOD-028 and MOD-029 with respect to the criterion on which contingencies must be analyzed to determine Total Transfer Capability. In MOD-030 R2 is very prescriptive on how TFC is determined with regard to the contingencies that must be analyzed and the distribution factor thresholds that lead to a flowgate definition. However, MOD-028 and MOD-029 simply require the ATCID to describe the "how". For example, in MOD-028 R1.4 states that the ATCID include "A description of the manner in which Contingencies are identified for use in the TTC [Total Transfer Capability] process." FE suggest changes are needed to R2 to align with the MOD-028 and MOD-029 standards. R2.4 – The first bullet of R2.4 should state that when a TFC is based on a thermal rating that it reflects the lowest facility rating for the monitored facility(ies) considered in the flowgate. The reference to the SOL should be reserved to only the second bullet which would appropriately account for a voltage or stability limit. R10 – As stated in FE's MOD-001 comments, it is suggested that the requirements for frequency of recalculating ATC be dealt with in MOD-001 (R8) to ensure a consistent application across MOD-028, MOD-029 and MOD-030 that presently does not exist. If MOD-001 R8 is revised as suggested, R10 in MOD-030 can be deleted. YesFE supports the SDT's adjustment of VRFs such that no VRF within the ATC standards exceeds a "Lower" rating. We concur with the team's reasoning and rationale provided in response to ballot comments in making this change.NoIn the Severe category VSLs for requirement R3, we suggest removing the word "detailed" when referring to detailed modeling data as it is ambiguous and subjective. FirstEnergy appreciates the Standard Drafting Team's decision to move to a formal comment period based on the prior initial ballot feedback. We commend the team for moving quickly to respond to the ballot comments and providing the industry a revised set of standards to review and comment. We suggest striking the words "short term use" from the purpose statement as we believe this methodology should also be valid in the planning horizon as a longer term projection of TFC and AFC. Regarding the revision to the Effective Date, while FirstEnergy agrees that there is a need to ensure that the standard is implemented consistently across the entire continent we are concerned with the Effective Date being subject to approval of ALL regulatory authorities. We believe an appropriate Implementation Plan should reflect a period of time beyond the NERC Board of Trustee approval date that would reflect when the requirements are considered mandatory and enforceable. The timeline should allow sufficient time for regulatory authority reviews, with the intent of sanctions also being enforced in conjunction with the conclusion of the implementation period. However, a delay from a given regulatory agency should not impact when the requirements are considered mandatory and enforceable for the bulk electric system.
IndividualThad NessAEP        The Purpose statement is unclear and perhaps nonsensical. Is the purpose “to increase consistency and reliability in the development of documentation….” or “to support analysis and system operation”? What entities’ “short term use”? Suggestion: Purpose: To ensure consistency of calculation of those entities employing Flowgate Methodology pursuant to MOD-001 R1.
Group  Public Service Commission of South CarolinaPhil RileyPublic Service Commission of South Carolina Yes Yes  
IndividualPatrick BrownPJM   Requirement 1 • Add to the end of R1 “provided that the data is not market sensitive.” Requirement 2 • R2.1.3 – The interconnection wide congestion management procedures should be listed for each Interconnection. For the Eastern Interconnection this is the TLR process. Requirement 3 • R3.2 and R3.3 -The update frequency for AFC calculations should be addressed by NAESB Business Practices. • R3.4 – The last sentence in R3. 4 should be replaced with; “Equivalent representation of radial lines and facilities is allowed consistent with the Bulk Electric System standards.” Requirement 5 • R5.2 - R3.6 in MOD 001 requires outages to be included in the daily and monthly calculations. R5.2 in MOD 30 requires outages to be included in the hourly calculations. A single requirement should be placed in MOD-001and applied consistently across MODS 28, 29 and 30. Requirement 6 • R6.3 - PJM understands the SDT’s reasons for using “Confirmed” reservations in accordance with the FERC regulations. Reservations that are in “Accepted”, as well as, “Confirmed” status should be included. Once service is “Accepted” by a TP it cannot be retracted. Using reservations that are in “Accepted” and “Confirmed” status should also be included in MOD-030 R6.3, R6.4, R7.1, and R7.2. This does not prevent the TP from decrementing for accepted and confirmed TSRs. We understand that some TPs maintain two sets of ATCs. One set is maintained internally and accounts for accepted and confirmed TSRs. The other set of ATC values is maintained externally and only accounts for confirmed TSRs. It is important for TPs who maintain two sets of ATC values to post the “internal” ATC values to provide greater transparency and give customers a more accurate picture of capability available to new requests. Requirements 7 and 9 • R7 and R9 Non-firm should be removed from this Reliability Standard and be considered NAESB scope. Requirement 10 • The periodic requirements of R10 are NAESB scope. This requirement should be eliminated. YesPJM supports NERC’s position to revise all Violation Risk Factors to have an assigned risk factor of “Lower.” A Lower Risk Factor requirement is administrative in nature and is a requirement that, if violated, would not be expected to affect the electrical state or capability of the bulk power system, or the ability to effectively monitor and control the bulk power system.NoNERC states that a VSL defines the degree to which compliance with a requirement was not achieved. The violation severity levels for these draft standards now, for the most part, have a graded implementation, but PJM has a concern regarding the possibility of multiple violations resulting from a single event. PJM requests that double counting of violations for a single event be eliminated. A single event shall not result in multiple violations –this language to be added to the standard. Add a new item 6 to section A of MOD-001. For example a review of MOD-001 R2 and R8 and MOD-30 R10 should be performed for determination of multiple violations resulting from one event. The MOD standards extend into areas that should be covered and addressed by NAESB Business Practices (as defined in MOD-001 Definitions). The frequency of postings and frequency of AFC/ATC calculations should be NAESB Business Practices, and not included in the NERC Standards as reliability based requirements (see specific details for MOD-001 R2 and R7 and MOD-030 R10 in the Specific Comments sections below). Non-firm should be removed from this reliability standard. • Reservations in “Accepted”, as well as, “Confirmed” status should be included in ATC calculation (see MOD030 R6.3). Once the transmission provider has accepted the request, the provider is now required to provide service; therefore, not decrementing for accepted TSRs could result in over commitment.
IndividualGreg RowlandDuke Energy Corporation   R1 – Need to ensure that comparable information should be required in either the study report or the ATCID in MOD-028, MOD-029 and MOD-030. R2.1.1.1 - Replace phrase “operations studies and planning studies” with the phrase “planning of operations”, to be consistent with the wording in MOD-001 R6. R2.1.2.1 - Replace phrase “operations studies and planning studies” with the phrase “planning of operations”, to be consistent with the wording in MOD-001 R6. R3.4 - Bulk electric system facilities 161kV and below may have significant network response. Since these facilities may have significant impact on AFC, documentation should be required by the standard for those facilities 161kV and below which are equivalized. This will provide transparency for impacted stakeholders. Yes Yes  
IndividualGreg Ward / Darryl CurtisOncor Electric Delivery   All schedules in ERCOT flow with no pre-defined paths and any congestion is mitigated by market mechanisms and/or verbal dispatch instructions from ERCOT (in the case of an emergency). Oncor is concerned about the risk of ERCOT being found in non-compliance with the underlying standard due to the methodologies not being a part of the ERCOT market. Furthermore, Oncor believes that implementation of the prescribed methodologies would add no value to the ERCOT market and could result in more system congestion. Oncor strongly suggests that this standard specify that it is not applicable to regions with a single control area and no defined ATC path(s).Yes Yes This standard should not apply to ERCOT for the reason expressed in question 1.
Group  Bonneville PowerDenise KoehnTransmission Reliability ProgramBPA does not believe any of the requirements are incorrect, though some are too prescriptive. See our response to question 4.Yes Yes BPA thanks the drafting team for clarifying that MOD-030 does not require the conversion of AFC to ATC and agrees with your assessment that there is no reliability need for such conversion. In addition, BPA respectfully submits the following observations and suggestions: a. There appears to be some conflicting overlap between R2.1.-R2.1.4.2. in MOD-030-1 and the System Operating Limits (SOL) Standards (FAC-010-1 and FAC-011-1). It is unclear to BPA that there is any reliability-based need for the identification of more Flowgates than are needed to protect SOLs. To that end, BPA suggests the following modifications to and renumbering of the above mentioned requirements: R2.1. Identify Flowgates used in the AFC process based, at a minimum, on the following criteria: R2.1.1. As necessary to protect established System Operating Limits (SOLs) or 2.1.1.1 Results of a first Contingency transfer analysis for ATC Paths internal to a Transmission Operator’s system up to the path capability such that at a minimum the first three limiting Elements and their worst associated Contingency combinations with an OTDF of at least 5% and within the Transmission Operator’s system are included as Flowgates. 2.1.1.1.1. Use first Contingency assumptions consistent with those first Contingencies used in operations studies and planning studies for the applicable time periods, including use of Special Protection Systems. 2.1.1.1.2. Only the most limiting element in a series configuration needs to be included as a Flowgate. 2.1.1.2. Results of a first Contingency transfer analyses from all adjacent Balancing Authority source and sink (as defined in the ATCID) combinations up to the path capability such that at a minimum the first three limiting Elements and their worst associated Contingency combinations with an Outage Transfer Distribution Factor (OTDF) of at least 5% and within the Transmission Operator’s system are included as Flowgates unless the interface between such adjacent Balancing Authorities is accounted for using another ATC methodology. 2.1.1.2.1. Use first Contingency assumptions consistent with those first Contingencies used in operations studies and planning studies for the applicable time periods, including use of Special Protection Systems. 2.1.1.2.2. Only the most limiting element in a series configuration needs to be included as a Flowgate. R2.1.2. Any limiting Element/Contingency combination within the Transmission model that has been subjected to an Interconnection-wide congestion management procedure within the last 12 months, unless the limiting Element/Contingency combination is accounted for using another ATC methodology. R2.1.3. Any limiting Element/Contingency combination within the Transmission model that has been requested to be included by any other Transmission Service Provider using the Flowgate Methodology or Area Interchange Methodology, where: 2.1.3.1. If the coordination of the limiting Element/Contingency combination is not already addressed through a different methodology, and - Any generator within the Transmission Service Provider’s area has at least a 5% Power Transfer Distribution Factor (PTDF) or Outage Transfer Distribution Factor (OTDF) impact on the Flowgate when delivered to the aggregate load of its own area, or - A transfer from any Balancing Area within the Transmission Service Provider’s area to a Balancing Area adjacent has at least a 5% PTDF or OTDF impact on the Flowgate. - The Transmission Operator may utilize distribution factors less than 5% if desired. 2.1.3.2. If the limiting Element/Contingency combination is included in the requesting Transmission Service Provider’s methodology. b. R2.4 has two bulletized sub-requirements that should either be numbered with a brief description provided as to how one would “respect the SOL” vs. simply setting the TFC equal to the SOL; or collapsed into R2.4 as follows: R2.4. Establish the TFC of each of the defined Flowgates as equal to: the System Operating Limit (SOL) of the Flowgate. c. The Time Horizons listed for all requirements should include the “Long-term Planning” Horizon, as ATC or AFC is to be calculated beyond the seasonal window. d. Balancing Authorities may be appropriately identified as Applicable Entities in this MOD and request that the Standards Drafting Team provide an explanation as to why they are not listed.
IndividualRichard KafkaPepco Holdings, Inc   PHI supports the comments of PJM and will not submit duplicate comments.     
Group  ISO RTO Council/Standards Review Committee (SRC)Charles YeungSouthwest Power PoolRequirement 1 Add to the end of R1 “provided that the data is not market sensitive.” Requirement 2 R2.1 addresses criteria for identifying flowgates used in the AFC process. Certain operating conditions cause the use of temporary flowgates. Coordination tests may be executed between entities for a temporary flowgate which will be included in AFC calculations and congestion management systems. Would these situations require these temporary flowgates to remain in AFC processes even after the temporary conditions return to normal (transmission elements return to service)? In some cases, temporary flowgates created for short-term may not necessarily fall under the criteria established in R2.1 but should be allowed because of their immediate need in reliably operating the transmission system. R2.3 stipulates that: “At a minimum, establish the list of Flowgates to create, modify, or delete external Flowgates that have been requested within thirty calendar days from the request.” The requirement is unclear on how a Flowgate gets removed merely through a request if the criteria applied to R2 and its sub-requirements remain in effect to justify keeping the Flowgate in the AFC list. Further, who has the authority to make this request and on what basis the request can be granted? The standard is silent on these issues. This requirement is very loose which needs tightening up. Requirement 3 R3.2 and R3.3 -The update frequency for AFC calculations should be addressed by NAESB Business Practices. R3.4 – The last sentence in R3. 4 should be replaced with; “Equivalent representation of radial lines and facilities is allowed consistent with the Bulk Electric System definition.” Requirement 5 R5.2 - R3.6 in MOD 001 requires outages to be included in the daily and monthly calculations. R5.2 in MOD 30 requires outages to be included in the hourly calculations. A single requirement should be placed in MOD-001 and applied consistently across MODS 28, 29 and 30. Requirement 6 R6.3 - The IRC understands the SDT’s reasons for using “Confirmed” reservations in accordance with the FERC regulations. Reservations that are in “Accepted”, as well as, “Confirmed” status should be included. Once service is “Accepted” by a TSP it cannot be retracted. Using reservations that are in “Accepted” and “Confirmed” status should also be included in MOD-030 R6.3, R6.4, R7.1, and R7.2. This does not prevent the TSP from decrementing for accepted and confirmed TSRs. We understand that some TSPs maintain two sets of ATCs. One set is maintained internally and accounts for accepted and confirmed TSRs. The other set of ATC values is maintained externally and only accounts for confirmed TSRs. It is important for TSPs who maintain two sets of ATC values to post the “internal” ATC values to provide greater transparency and give customers a more accurate picture of capability available to new requests. Requirements 7 and 9 R7 and R9 Non-firm should be removed from this Reliability Standard and be considered NAESB scope. Requirement 10 The periodic requirements of R10 are NAESB scope. This requirement should be eliminated. YesThe MOD standards assess the correct amount of reliability risk in areas that do not affect reliability. The IRC supports the position that no requirement from this set of ATC standards should have an assigned Risk Factor exceeding “Lower”. A Lower Risk Factor requirement is administrative in nature and (a) is a requirement that, if violated, would not be expected to affect the electrical state or capability of the bulk power system, or the ability to effectively monitor and control the bulk power system; or (b) is a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or restorative conditions anticipated by the preparations, be expected to affect the electrical state or capability of the bulk power system, or the ability to effectively monitor, control, or restore the bulk power system.NoNERC states that a VSL defines the degree to which compliance with a requirement was not achieved. The violation severity levels for these draft standards now, for the most part, have a graded implementation, but the IRC has a concern regarding the possibility of multiple violations resulting from a single event. The IRC requests that the potential for double counting of violations for a single event be eliminated. 
IndividualRon FalsettiOntario IESO   We have the following comments on the Requirements and Measures: a. R2.3 stipulates that: “At a minimum, establish the list of Flowgates to create, modify, or delete external Flowgates that have been requested within thirty calendar days from the request.” The requirement is unclear on how a Flowgate gets removed merely through a request if the criteria applied to R2 and its sub-requirements remain in effect to justify keeping the Flowgate in the AFC list. Further, who has the authority to make this request and on what basis the request can be granted? The standard is silent on these issues. This requirement, to say the least, is very loose. b. R2.5 does not cover the situations when transmission configuration changes occur that results in a change to the SOL and hence the Flowgate TTC. c. The term “Transmission Service” in R4 is unclear. Does it mean transmission service reservations, or commitments? This needs to be clarified. d. The last bullet in R2.1.4.1 and the footnote to R6.2, R6.4, R7.2, R7.4 and R7.6 allow the use of threshold lower than 5%. This makes the 5% threshold stipulated in R2.1.1, R2.1.2 and R2.1.4 not enforceable. If lower threshold can be used, why stipulate a 5% in the first place? e. M1: This measure assesses compliance of R1.1; there is no measure for R1.2. f. M13 for R6: R6 stipulates the algorithm to establish AFCs. However, M13 provides the requirement for certain accuracy, which leads to the following questions: i. Is R6 about the use of an algorithm only or is it also about the proper or consistent setting of the variables within that algorithm? ii. If it is also the proper or consistent setting of the variables, the requirement should stipulate the conditions rather than leaving the assessment to a recalculation process (stipulated in M13) to determine if the algorithm and its settings have been properly used. ii. If accuracy is to be a criterion for having proper and consistent setting of the variables, it becomes a requirement and hence should be stipulated in the requirement section, not in the measure. g. M14 for R7: The same comment on M13 also applies here for R7. h. M18 for R11: Suggest to revised M18 to: “The Transmission Service Provider shall provide evidence (such as documentation and data) when converting Flowgate AFCs to ATCs (and TFCs to TTCs) for ATC Paths, it follows the procedure described in R11.” NoR2 should be assigned a Medium VRF since TFCs set the reliability boundary, like an SOL or IROL, within which the TSP may provide transmission services. Failure to establish TFCs may result in the TSP over-selling transmission services beyond the reliability bounds, risking the BES to unreliable operationNoWe have the following comments on the VSLs: a. R1: The VSLs are proper for this requirement. However, the Measure needs to be fixed so that they correspond to the VSLs. Please see our comments on M1 under Q1. b. R2: We suggest the VSLs for R2 be rewritten, and where necessary, restructure R2 altogether to facilitate development of VSLs. For example, R2.1 is only one of the 6 subrequirements of R2, yet a condition that “The Transmission Operator did not include six or more Flowgates in their its AFC calculations that met the criteria described in R2.1.” would put the TOP to a Severe violation despite the TOP might have met all the remaining 5 subrequirements. Another example is that the TOP is more than 9 month late in establishing the list of internal Flowgates but has otherwise met all the other subrequirements. Further, there are far too many single condition that would put a TOP to Severe violation despite it may have et all the other conditions, and there is no violation level assigned to failing R2.5.1, which is to update TFC when notified of a rating change. A major rewrite of this set of VSL in conjunction with restructuring R2 appears to be an appropriate course for the SDT. c. R3: Similar situation as in R2. R3 has 5 subrequirements and hence failing just one of them (except R3.1 for which VSLs are progressive (graded)) should not be assigned a Severe level. There needs to be consideration given to failing some combination of them for which Low, Moderate and High VSLs should be assigned. Unlike R2, R3 has a simpler structure and hence may not need to be restructured to facilitate proper assignments of VSLs. d. R5: This requirement has 3 subrequirements. It is generally expected that failing one of the 3 subrequirements would result in a Moderate VSL, 2 for a High VSL and all 3 for a Sever VSL as opposed to seeing only the graded VSL for failing R5.2. Furthermore, there may not be a large number of outages/retirements (for example 26-50) occurring during a modeling period within the total area that a TSP needs to model. Some VSLs for R5.2 may not be applicable for some TSPs even they may miss all the outages/retirements within the total area that it needs to model. Suggest the SDT revise this set of VSLs to take into account failing any combination of the 3 subrequirements, and the range of area size (and hence the total number of possible outages within a period) that a TSP needs to model. e. R6: For these VSLs to be appropriate, please see our comments and suggestion for changes on M13 under Q1. f. R7: For these VSLs to be appropriate, please see our comments and suggestion for changes on M14 under Q1. g. R8: The VSL has a condition that there is a violation if additional elements are used in the calculation of firm AFCs. Not allowing the use of additional elements is not stipulated in the requirement. Suggest to remove this condition from the VSL, or add this requirement to R8. h. R9: Same comment on R8 also applies here for calculating non-firm AFCs. i. R10: The VSLs as written indicates that failing any one of the 3 beyond some threshold levels would constitute a Severe violation. This is not consistent with the general principle that failing all subrequirements would result in a Severe violation. Suggest the SDT revise this set of VSLs to achieve consistency with the general principle. j. R11: Please see our comment on M18 under Q1. If the wording to M18 is revised as suggested, the wording for the VSL condition should be changed accordingly. We commend the SDT for having worked very hard to try to meet FERC’s earlier deadline, and for taking very positive steps responding to industry comments received from previous round of posting for comment and from the failed balloting process. However, owing to the number and size of the standards, there is a great potential for inconsistent treatment to the requirements, measures and VSLs among the standards. After reviewing all 6 standards and offering comments, we’ve found that there is quite a bit of inconsistency among the standards. For example, for a similar process, some requirements in a standard have only one level of subrequirements while in another standard there are two levels. In some standards that have requirements that contain subrequirements, there is only one measure while in another standard, similar process having similar requirement structure may have multiple measures. Still the vast majority of inconsistency is found in the VSLs: for similar requirement structure and content, some have appropriately graded VSLs while some have binary (none or Severe) VSLs; some have graded VSLs that is a function of the number of subrequirements violated while others have VSLs that is determined by the extent of violation of any one of the subrequirements. The inconsistent wording among the requirements, their measures and VSLs is another area of concern. We realize the SDT is still working with a tight timeline. Nonetheless, we feel that the needed time must be spent to review the structure and quality of these standards to support measurability and the ability to develop proper VSLs. Unlike the development of VSLs for the approved standards – a process that did not allow for changing the requirements, the ATC SDT has the freedom to change the requirements as it sees necessary to facilitate proper development of measures and ease of VSL development thereby achieving a set of quality standards that are measurable and enforceable. We therefore suggest the SDT do spend some time to refine these standards to improve their quality rather than trying to post them in short order to get ahead on the timeline.
IndividualJohn HarmonThe Midwest ISO   •In the Purpose field, why specify for short term use only? The Midwest ISO believes this methodology is valid for the planning horizon also. •R2 – In general, we believe this is not treated equally comparing to MOD-028 and MOD-029. There isn’t a minimum criterion on what contingencies have to be included in MOD-028 or MOD-29. All they need to do is to include in their ATCID. Why can’t flowgate methodology do the same thing? •R2.1.1/R2.1.2 – Below are a couple of comments related to these requirements. oR2.1.1.1/R2.1.2.1 – Overall, both requirements as written are unclear. The Midwest ISO questions what assumptions are referenced in these requirements and how would an auditor be able to verify that the TO is compliant. The Midwest ISO requests the requirement to either list specific assumptions or be deleted and leave it to FERC to address the issues on a case by case basis. oR2.1.1.2/R2.1.2.2 – The Midwest ISO requests that an example of the limiting element in series be provided. •R2.1.3 – The Midwest ISO believes that this requirement is too burdensome and stringent, and sometimes will have no effect on a TO or TSP. If a TO chooses to model the topology for a TO or TSP far removed from its respective region, why is it mandated that all flowgates with TLR be honored. This requirement also gives no service for an instance where a TLR may occur due to a temporary condition such as a forced outage. This will greatly increase the number of flowgates that each TO will have to account for in their load flow calculations without much perceived benefit. •R2.2 – Edited the statement to read: "At a minimum, establish the list of Flowgates at least once per calendar year." The Midwest ISO believes that this would be a clearer requirement. •R2.3 – Edit the statement to read: "At a minimum, establish the list of external Flowgates that have been requested within thirty calendar days from the request." The Midwest ISO believes that this would be a clearer requirement. •R2.4 – The Midwest ISO believes that this requirement is identical to R12 in TOP-002. Since TOP-002 R12 will not be retired, R2.4 in MOD-030 is redundant and should be removed. However, if the DT does not agree, The Midwest ISO would then comment that for thermal limits, the thermal rating of the Flowgate should be used and not the SOL. •R4 – The Midwest ISO has two comments related to this requirement: oThe Midwest ISO has observed that a similar requirement is not in MOD-029. We feel that TSPs that follow the Rated System Path methodology should also be subjected to this requirement. This continues to demonstrate that more stringent requirements are placed on MOD-030 than the other methodologies. oThe sub-requirements (identified with a dash in the standard) seem to be written as though they are mutually exclusive. The Midwest ISO believes that a Source or Sink identified in a reservation that is discretely modeled can still be mapped to an “equivalence” or “aggregate” representation in the model. Background: For the Midwest ISO, although the internal Local Balancing Authorities are discretely modeled, we would still like to map it to an “aggregate” – MISO – to be consistent with what is expected to be scheduled in real time. •R5.2 – Language should be added to say that this requirement applies if the data is supplied by the entities owning the information. •R6.2/R6.4/R6.6/R7.2/R7.4/R7.6 – The Midwest ISO has two comments related to these requirements: oLanguage should be added to state that the requirements are applicable only if the other TSPs provide necessary information. oThe Midwest ISO has observed that similar requirements are not in MOD-028 nor MOD-029. We feel that TSPs that use MOD-028 and MOD-029 should also be subjected to this requirement. This continues to demonstrate that more stringent requirements are placed on MOD-030 than the other methodologies. •R10 –First, the Midwest ISO believes that this requirement should be removed because there is no companion requirement in MOD-028 and MOD-029. Second, any forgiveness/tolerance for error should be included in the requirement instead of the VSL table because it is the requirement that determines whether the entities are in compliance, NOT the VSL table. Third, if this requirement has to stay, it should include similar outage/maintenance allowances for hourly values as in MOD-001. •R11 – The formula, as it is written, would result in using different flowgates to convert AFC to ATC and TFC to TTC. The Midwest ISO believes that we should use the same flowgate for both conversions. The formula should be used only for AFC-ATC conversion. TTC should be calculation by dividing TFC by DF for the same most ATC-limiting flowgate, •M11 – Revise the language to match revisions in R5.2 •M13&M14 – The Midwest ISO feels that both of these requirements are too burdensome for TSPs and ISOs/RTOs. The amount of data that would have to be retained for a 60 day period is too great. The Midwest ISO also questions the basis for a 60 day period and why these requirements were greatly expanded from their original wording. If the point of the requirement is to audit calculated values for compliance, how is the specific number of days of data relevant? The requirements from the previous version were appropriate. •M17 – Should reference calculating AFC not ATC. •Compliance 1.3 – The Midwest ISO questions the value in requiring that the list of Flowgates and their ratings be retained for 3 years when all other requirements are only 12 months? Yes NoThe tolerances included in the VSLs for R10 should be moved into the requirement itself.The Midwest ISO believes that MOD-030 continues to be more stringent than MOD-028 and MOD-029.
Group  Entergy Services Inc.Narinder K. SainiEntergy Services Inc.R1.2 Add "definitions" to the requirement to read: "source and sink definitions". Similar to a comment provided for MOD-001, R2.1.1.1 and 2.1.2.1 use the term "operations studies and planning studies." Again, we believe that the intent is to tie reliability focused studies to the commercial ATC type studies. we think the inclusion of "reliability" with these terms helps to clarify the intent. Also, if the terms can be stadardized for both MOD-001 and MOD-030, then that would be optimum. MOD-028 and 029 do not specifically try to make this correlation and raises a question of why that is not done. R2.1.1 - needs rewording for clarification: From the results of a first Contingency transfer analysis for ATC Paths internal to a Transmission Operator’s system up to the path capability, as a minimum the first three limiting Elements and their worst associated Contingency combinations with an OTDF of 5% or less and within the Transmission Operator’s system shall be included as Flowgates. R2.1.1.1 - The specific reference to SPS is misleading. There is nothing in the standards that preclude the use of SPSs, so being silent is better than pointing out just one technology. The use or non-use of SPSs could be presented in the assumptions/evidence documented per MOD-001 M Throughout - There are several references to the limiting element and contingency combinations. However, some flowgates are so sensitive to transfers that they need to be included for PTDF vs. OTDF. R2.1.4.1 & 2.1.4.2 - Delete "If" at the beginning of the requirements statements. R2.1.2 - needs rewording for clarification. From the results of a first Contingency transfer analyses from all adjacent Balancing Authority source and sink (as defined in the ATCID) combinations up to the path capability, a minimum the first three limiting Elements and their worst associated Contingency combinations with an Outage Transfer Distribution Factor (OTDF) of 5% or less and within the Transmission Operator’s system shall be included as Flowgates unless the interface between such adjacent Balancing Authorities is accounted for using another ATC methodology. 2.1.3 - How often does this update have to occur? R2.1.3 & 2.1.4 - Insert "Include" at the beginning of the requirements statements. R2.2 - Reword to "At a minimum create, modify, or delete the list of internal Flowgate definitions at least once per calendar year." R2.3 - Reword similar to R2.2. R5.2 Replace "during the period calculated" with "during the applicable period of the AFC calculation". R3.5 - the phrase "and beyond" seems very open-ended. For the very near timeframes where state estimator models are used, this is the biggest concern. We cannot model neighboring systems in great detail because they do not allow that use of their CEII since we post these cases on our OASIS site. R5.3 - The reference should be to R2.1.4 rather than R2.1.3 R6.3, 6.4, 6.5, and 6.6 - These requirements should not refer to only "all confirmed firm Point-to-Point Transmision Service expected to be scheduled". All confirmed firm Point-to-Point Transmission Service should be included for determining the impacts of ETC for firm commitments. The wording for R6.2 needs "based on:" added to the end to read like R6.1. R6.2 & 6.4 & 6.6 - Add a requirement that requires your neighbors to tell you about their NITS. If these requirements are going to stand, you need a way to ensure that you can get the appropriate data from neighbors in order to be compliant. The footnotes in R6.2, 6.4, 6.6, 7.2, 7.6, & 11 should be deleted with the suggested rewording of R2.1.1 and R2.1.2. R6.4 and 7.2 - how do you accomplish "filtered to reduce or eliminate duplicate impacts" especially as it relates to neighboring TSPs PTP reservations? The formula in R9 should be modified to replace ETCFi by a new term to reflect Firm commitments expected to be scheduled. TRMui definition should not use the term "Transmission Reliability Margin that has not been released (unreleased) for sale as TRM is not expected to be released. Only different values of TRM can be used for non firm ATC/AFC calculations different/lower than those used for firm. R10 - recalculation frequency in this requirement should be similar that included in MOD-001 R8. R10.1 - Entergy recommends to modify the language to "For Hourly, once per hour at least 99% of hours every calendar year." Yes Yes  
Group  MRO NERC Standards Review SubcommitteeTom MielnikMidAmerican Energy Company (MEC)1. The MRO commends the SDT on revising R2.1.1 resulting in an improved description of contingency combinations to be included as flowgates. 2. The MRO commends the SDT on making numerous revisions to clarify that the standard provides the basis for AFC calculations not ATC. We believe that some additional changes in this regard are required. Under A. Introduction, 4. Applicability, 4.1.1 needs to be clarified by stating that the applicability of the standard is for "Each Transmission Operator that uses the Flowgate Methodology to support the calculation of AFCs on flowgates and when converting AFCs to ATCs." 4.1.2 needs to be clarified by stating that "Each Transmission Service Provider that uses The Flowgate Methodology to calculate AFCs on flowgates and when coverting AFCs to ATCs." 3. The MRO believes the words "all" should be deleted from R2.1.2, "any" from R2.1.3, three uses of "any" from R2.1.4, "all" from R5.2, "any" from R5.2, "all" from R6.1.2, two uses of "any" from R6.2, "all" from R6.2.2, "all" from R6.3, "any" and "all" from R6.4, "any" from R6.5, "any" and "alll" from R6.6, "all" from R7.1, "any" and "all" from R7.2, "any" from R7.3, "any" and "all" from R7.4, "any" and "all" from R7.6, "any" from R9. The MRO believes the use of these words are unnecessary and may lead to over-the-top auditing. We believe that the Measures, Compliance, and the VSLs should be changed to match these changes to the requirements. 4. R2.5.1 provides for only seven calendar days for updating the TFC once the Transmission Service Provider is notified of a change in a Rating. The MRO recommends that this be extended to 14 calendar days. 5. The MRO does not understand the need for R3.1 in requiring that generation Facility Ratings, such as generation maximum and mimum output levels must be included within the model. The MRO believes that there are instances where it would be inappropriate to base the AFC on the generation maximum or minimum output levels. Therefore, the MRO believes that this requirement should either be significantly revised to indicate what the SDT really means or else be deleted. 6. The MRO believes that the second sentence of R3.4 which specifies the extent to which equivalence is included in modeling be deleted. This seems to be micromanagement and could very well result in inappropriate models that result in worse AFCs. 7. The MRO urges the SDT to delete the new measures M13, M14, M15, and M16. We believe that these new measures are micromanagement of the Transmission Service Provider and encourage over-the-top auditing. The MRO considers these measures as written as being "deal-killers". 8. The MRO notices that MOD-028-1 provides in R6.3 provides for the use of "the lesser of the sum of incremental transfer capability and impacts of Firm Transmission Services" or the "sum of Facility Ratings of all ties comprising the ATC Path." It also provides in R6.4 for limiting TTC so that "TTC does not exceed that Transmission Operator's contractual rights." The MRO notes that similar provisions are missing from MOD-030-1. The MRO recommends that at a minimum, R11 provide that when flowgate AFCs are converted to ATCs that the ATCs have provisions for limiting ATCs to the sum of Facility Ratings of all ties comprising the ATC path and that such ATCs do not exceed Transmission Operator's contractual rights on the ATC path. YesThe MRO commends the SDT on revising the VRFs to Lower. We believe the revised VRFs are in-line with the NERC definitions of the VRF levels. Yes 1. The MRO continues to have issues with the overall approach on this standard in combination with the MOD-028. As previously indicated in prior comment periods, the MRO has Transmission Service Providers that manage the levels of transmission service to a reliable level with flowgates and then establishes border control area-to-control area flows to contract path levels so that contractual rights are not exceeded. The MRO reads the MOD-028 standard to require the application of the MOD-028 methodology for its control area-to-control area path postings while MOD-030 standard is used for the flowgate postings. The MRO understands from a discussion with a member of the SDT that in actuality the intent is that the MOD-030 would be used for flowgate calculations and that these quantities could be converted into the ATC path quantities for the control area to control area paths from border companies to outside the Transmission Service Providers area. This application of the flow gate methodology to possibly generate all postings in for a Transmission Service Provider including drive out is not clear from the standards and should be clarified in MOD-030 and possibly MOD-028. 2. The MRO commends the SDT in making significant changes to this standard and reissuing it for comment. The MRO believes the eventual standard that is approved will serve the industry and customers better as a result. 3. The MRO acknowledges the consistant application of spelling out the full term followed by the abbreviation or acronym in brackets on the first time use. With the goal of consistancy across all the standards. 4. R6 and R7 – Overall, both requirements as written are unclear. The MRO asks that the standards drafting team specify what assumptions are referenced or else delete these requirements. The MRO notes that these requirements are covered by FERC order #890 anyway. 5. In the Purpose field, why specify for short term use only? The MRO believes this methodology is valid for the planning horizon also. 6. R2 – In general, we believe this is not treated equally comparing to MOD-028 and MOD-029. There isn’t a minimum criterion on what contingencies have to be included in MOD-028 or MOD-29. All they need to do is to include in their ATCID. Why can’t flowgate methodology do the same thing? 7. R2.1.3 – TheMRO believes that this requirement is too burdensome and stringent, and sometimes have no effect on a TO or TSP. If a TO chooses to model the topology for a TO or TSP far removed from its respective region, why is it mandated that all flowgates with TLR be honored. This requirement also gives no service for an instance where a TLR may occur due to a temporary condition such as a forced outage. This will greatly increase the number of flowgates that each TO will have to account for in their load flow calculations without much perceived benefit. 8. R2.2 – Edited the statement to read: At a minimum, establish the list of Flowgates at least once per calendar year. The MRO believes that this would be a clearer requirement. 9. R2.3 – Edit the statement to read: At a minimum, establish the list of external Flowgates that have been requested within thirty calendar days from the request. The MRO believes that this would be a clearer requirement. 10. R2.4 – The MRO believes that this requirement is identical to R12 in TOP-002. Since TOP-002 R12 will not be retired, R2.4 in MOD-030 is redundant and should be removed. However, if the DT does not agree, The MRO would then comment that for thermal limits, the thermal rating of the Flowgate should be used and not the SOL. 11. R4 – The MRO has two comments related to this requirement: A. The MRO has observed that a similar requirement is not in MOD-029. We feel that TSPs that follow the Rated System Path methodology should also be subjected to this requirement. This continues to demonstrate that more stringent requirements are placed on MOD-030 than the other methodologies. B. The sub-requirements (identified with a dash in the standard) seem to be written as though they are mutually exclusive. The MRO believes that a Source or Sink identified in a reservation that is discretely modeled can still be mapped to an “equivalence” or “aggregate” representation in the model. 12. R5.2 – Language should be added to say that this requirement applies if the data is supplied by the entities owning the information. 13. R6.2/R6.4/R6.6/R7.2/R7.4/R7.6 – The MRO has two comments related to these requirements: A. Language should be added to state that the requirements are applicable only if the other TSPs provide necessary information. B. The MRO has observed that similar requirements are not in MOD-028 nor MOD-029. We feel that TSPs that use MOD-028 and MOD-029 should also be subjected to this requirement. This continues to demonstrate that more stringent requirements are placed on MOD-030 than the other methodologies. 14. R10 –First of all, All three methodologies should have the same calculation frequency and the same allowance for outages. The MRO believes that a load flow for hourly values shall be conducted at least once per day. Lowering the requirement for all to once per hour is overly burdensome.this requirement should be removed as there is no companion requirement in MOD-028 and MOD-029. Second, any forgiveness/tolerance for error should be included in the requirement instead of the VSL table because it is the requirement that determines whether the entities are in compliance, NOT the VSL table. Third, if this requirement has to stay, it should use similar outage/maintenance allowances for hourly values as in MOD-001. 15. R11 – The formula, as it is written, would result in using different flowgates to convert AFC to ATC and TFC to TTC. The MRO believes that we should use the same flowgate for both conversions. The formula should be used only for AFC-ATC conversion. TTC should be calculation by dividing TFC by DF for the same most ATC-limiting flowgate. 16. M17 – Should reference calculating AFC not ATC.
Group  Southwest Power PoolKevin BatesSouthwest Power Pool Yes   R2.1.3. Any limiting Element/Contingency combination within the Transmission model that has been subjected to an Interconnection-wide congestion management procedure within the last 12 months. R2.1 addresses criteria for identifying flowgates used in the AFC process. Certain operating conditions cause the use of temporary flowgates. Coordination tests may be executed between entities for a temporary flowgate which will be included in AFC calculations and congestion management systems. Would these situations require these temporary flowgates to remain in AFC processes even after the temporary conditions return to normal (transmission elements return to service)? In some cases, temporary flowgates created for short-term may not necessarily fall under the criteria established in R2.1 but should be allowed because of their immediate need in reliably operating the transmission system.
IndividualJason ShaverAmerican Transmission Company   1. A.3 Clarify whether "for short term use" refers to the Operating Horizon, short term (1-5 yr) Planning Horizon, or both. 2. R2.1.2/M2 Delete the word "all" to avoid being overly inclusive. 3. R2.1.3 Delete the word "any" to "applicable" and change the term "Transmission model" to "Transmission Operator's area" to avoid being overly inclusive. 4. R2.1.4 Delete the words "any" to "applicable" and change the terms "Transmission model" to "Transmission Operator's area" to avoid being overly inclusive. 5. R2.4, R2.5, & R2.6/M5, M6, & M7 Remove these requirments and measures because the are redundant with R11 and R12 of TOP-002-2. If R2.5.1 is retained, then change the "seven calendar days" to "fourteen calendar days". 6.R3 Change "Transmission model" to "Transmission model of the Transmission Operator's area" 7. R3.4 Change "within its Reliability Coordinator's area" to "within the Transmission Operator's area". 8. R3.5 Change "beyond Reliability Coordinator's Areas" to "beyond the Transmission Operator's area". 9. R6.3 Need to include "Accepted" transmission service in the determination of Existing Transmission Commitments or clarify the reasoning for not including it (otherwise how are they accounted for?) M13, M14 For consistency, spell out "Transmission Service Provider". Yes Yes The first time that each abbreviation or acronym is introduced, the full terminology should be stated followed by the abbreviation or acronym in brackets (i.e. TFC). Modification to Applicability Section: 4.1.1 Each Transmission Operator that uses the Flowgate Methodology 4.1.2 Each Transmission Service Provided that uses the Flowgate Methodology We believe that the remaining language ("to support the calculation of ATC for ATC Paths) can be deleted because of the subsequent changes to MOD-001-1. The SDT changes MOD-001-1 to accommodate both ATC and AFC. Please see our comments to MOD-001-1 that if implemented by the SDT should make the deletion acceptable. Proposed Effective Date: Please see our comments in MOD-001-1 about the proposed effective date.
IndividualRex McDanielTexas-New Mexico Power Company   All schedules in ERCOT flow with no pre-defined paths and any congestion is mitigated by market mechanisms and/or verbal dispatch instructions from ERCOT (in the case of an emergency). Texas-New Mexico Power Company is concerned about the risk of ERCOT being found in non-compliance with the underlying standard due to the methodologies not being a part of the ERCOT market. Furthermore, TNMP believes that implementation of the prescribed methodologies would add no value to the ERCOT market and could result in more system congestion. TNMP strongly suggests that this standard specify that it is not applicable to regions with a single control area and no defined ATC path(s).Yes Yes This standard should not apply to ERCOT for the reason stated in Question 1.
Group  Electric Service DeliveryReza EbrahimianAustin Energy      These comments are filed on behalf of City of Austin d/b/a Austin Energy to address proposed NERC 5 MOD Standards. Austin Energy is a municipally owned electric utility and a transmission service provider with the Electric Reliability Council of Texas (ERCOT). ERCOT now operates as a Single Balancing Authority with no explicit transmission services being sold. Current ERCOT market rules allow open transmission access to all loads and resources. ERCOT will continue to operate as a Single Balancing Authority under Nodal market design. Accordingly, as explained in more detail below, the NERC 5 MOD Standards should not be applied to ERCOT and transmission service providers within ERCOT under its current or proposed Nodal market design. Austin Energy requests that the NERC Standards Drafting team add language to these Standards to clarify that MOD-001-1, MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 Standards are not applicable to regions with a Single Balancing Authority that do not use ATC methodology and any of its components in their market operations. Applicable definitions: According to NERC Reliability Standards Glossary of Terms, Available Transfer Capability (ATC) is defined as: “A measure of the transfer capability remaining in the physical transmission network for further commercial activity over and above already committed uses. It is defined as Total Transfer Capability (TTC) less existing transmission commitments (including retail customer service), less a Capacity Benefit Margin (CBM), less a Transmission Reliability Margin (TRM), plus Postbacks, plus counterflows”. TTC is defined as: the amount of electric power that can be transferred over the interconnected transmission network in a reliable manner while meeting all of a specific set of defined pre- and post-contingency system conditions. CBM is defined as the amount of transmission transfer capability reserved by load serving entities to ensure access to generation from interconnected systems to meet generation reliability requirements. TRM also is a component of ATC defined as: that amount of transmission transfer capability necessary to ensure that the interconnected transmission network is secure under a reasonable range of uncertainties in system conditions. Comments: ERCOT is an interconnection and a region with no synchronous AC ties with any other interconnections. In July 2001, based on a deregulated Retail and restructured Wholesale Markets, the ERCOT interconnection began acting as a Single Balancing Authority. The ERCOT market is designed such that there are no explicit transmission services being sold, hence, Available Transfer Capability (ATC) is not a measure used in a commercial activity within the ERCOT market. The current ERCOT market rules allow open transmission access to all eligible loads and resources without considering any specific Transmission Service Provider (TSP). Transmission facilities ratings are based upon individual branch element designs and in cases of dynamic ratings, ambient conditions are also considered. ERCOT has several DC ties and an asynchronous tie using a Variable Frequency Transformer (VFT); however, the associated interchange capabilities are planned and coordinated by the TSPs involved. The current ERCOT Zonal Market uses a flow based congestion management methodology to predict potential congestions in the Day Ahead and Adjustment Periods. During the operating period, generation shift factors are used to determine the dispatch needed to remain within the constrained limits. The local congestions are managed using full AC load flow analysis and unit specific redispatch. MOD-001-1 is entirely about methodology and calculation of ATC, therefore, this standard is not applicable to ERCOT. MOD-008-1 covers Transmission Reliability Margin (TRM) methodology calculation. Mathematically, ATC is defined as Total Transfer Capability (TTC) less the TRM and Capacity Benefit Margin (CBM). Therefore, TRM also is not applicable to ERCOT. MOD-028-1 covers Area Interchange calculation Methodology. Since ERCOT is a single control area, Area Interchange calculation is not applicable. MOD-029-1 covers Rated System Path Methodology, which is used to calculate TTC and ATC calculations. Therefore MOD-029-1 is not applicable to ERCOT. MOD-030-1 covers Flowgate methodology calculation of ATC, and therefore, is not applicable to ERCOT. ERCOT is currently transitioning to a Nodal Market, with a scheduled start date of December 1, 2008. The Nodal Market uses a Security Constrained Economic Dispatch (SCED) approach to dispatch individual generating units and manage congestion. In the Nodal Market, ERCOT will still operate as a Single Balancing Authority. This again will not use ATC methodology, and aforementioned standards are not applicable to ERCOT in its ensuing Nodal Market. Therefore, Austin Energy requests that the NERC Standards Drafting team add language to these Standards to clarify that MOD-001-1, MOD-008-1, MOD-028-1, MOD-029-1, and MOD-030-1 Standards are not applicable to regions with a Single Balancing Authority that do not use ATC methodology and any of its components in their market operations.
IndividualAllen MosherAmerican Public Power Association   OTDF definition - capitalize "facilities" The Flowgate Methodology definition, like Area Interchange and Rated System Path, includes the text: "Capacity Benefit Margin, Transmission Reliability Margin, and Existing Transmission Commitments are subtracted from the TTC, and Postbacks and counterflows are added, to derive Available Transfer Capability." This text describes the derivation of ATC or AFC, and should not be part of a definition to differentiate between the AIM, RSP and Flowgate methods. R3.4 - I support allowing "Equivalent representation of radial lines and facilities 161 kV or below” but equivalences for Elements included in the regional definition of the BES should be posted and explained in the TOP’s and TSP’s ATCID. R2.1.4.1, bullet #3 - This requirement states: “The Transmission Operator may utilize distribution factors less than 5% if desired.” R6.2, R6.4, R6.6, R7.2, R7.4 and R7.6 and R11, definition of “P” each contain the following the following footnote: "A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized." MOD-28 AIM has similar language allowing use of alternative distribution factors, generally related to the use of differing local, subregional or regional TLR curtailment thresholds. Repetition of similar text in multiple requirements and identical footnotes indicates a single additional Requirement should be added to the Flowgate standard and Area Interchange standard. Alternatively, add the following sentence to R2.1.4.1 and to footnotes 1-7: “This lesser Distribution Factor shall be posted in the TSP’s ATCID and coordinated with the applicable RC(s) and each adjacent TOP and TSP.” R8 and R9 - Postbacks and counterflows: “Counterflows” should be a defined term. It is used in MOD-1, MOD-28, MOD-29 and MOD-30 and is an integral element in the calculation of ATC and AFC. The definition used in MOD-28-1 R10, for example, reads: “counterflowsF are adjustments to firm ATC as determined by the Transmission Service Provider and specified in the ATCID.” This definition does not in any way describe what a counterflow is. “Postbacks” should incorporate a working definition developed by NAESB, to be revised once due process is completed on this business practice. Alternatively, consider use of the following text to at minimum describe the nature of postbacks: “Postbacks[Firm][Non-Firm] are changes to firm [non-firm] ATC [AFC] due to a change in the amount of Firm [non-firm] Transmission Service reserved or scheduled for a period, as defined in Business Practices. Postbacks are generally a positive quantity.” Also, include Postbacks in the "e.g." list of factors in M15 and M16. Yes YesYes - a major improvementGreat work - thanks to the SDT
IndividualTony KroskeyBrazos Electric Power Cooperative, Inc.        Brazos Electric believes that the concept of the Flowgate Methodology to support the calculation of Available Transfer Capabilities (ATCs) for ATC Paths is not applicable to a single-control area operation like ERCOT. To address this issue, the Applicability section could have a clarifying statement that only TOPs or TSPs conducting area to area operations and hence have responsibility for ATC Path(s) are subject to the requirements of MOD-030 if it uses a Flowgate Methodology.