To establish consistent modeling data requirements and reporting procedures for development of planning horizon cases necessary
4.1. Functional Entities
4.1.1 Balancing Authority
4.1.2 Generator Owner
4.1.3 Load Serving Entity
This proposed standard combines “Planning Authority” with “Planning Coordinator” in the list of applicable functional entities. The NERC Functional Model lists “Planning Coordinator” while the registration criteria list “Planning Authority,” and they are not yet synchronized. Until that occurs, the proposed standard applies to both Planning Authority and Planning Coordinator.
4.1.5 Resource Planner
4.1.6 Transmission Owner
4.1.7 Transmission Planner
4.1.1 Reliability Coordinator
MOD-032-1, Requirement R1 shall become effective on the first day of the first calendar quarter that is 12 months after the date that the standard is approved by an applicable governmental authority or as otherwise provided for in a jurisdiction where approval by an applicable governmental authority is required for a standard to go into effect. Where approval by an applicable governmental authority is not required, MOD-032-1, Requirement R1 shall become effective on the first day of the first calendar quarter that is 12 months after the date the standard is adopted by the NERC Board of Trustees or as otherwise provided for in that jurisdiction.
MOD-032-1, Requirements R2, R3, and R4 shall become effective on the first day of the first calendar quarter that is 24 months after the date that the standard is approved by an applicable governmental authority or as otherwise provided for in a jurisdiction where approval by an applicable governmental authority is required for a standard to go into effect. Where approval by an applicable governmental authority is not required, MOD-032-1, Requirements R2, R3, and R4 shall become effective on the first day of the first calendar quarter that is 24 months after the date the standard is adopted by the NERC Board of Trustees or as otherwise provided for in that jurisdiction.
MOD-032-1 exists in conjunction with MOD-033-1, both of which are related to system-level modeling and validation. Reliability Standard MOD-032-1 is a consolidation and replacement of existing MOD-010-0, MOD-011-0, MOD-012-0, MOD-013-1, MOD-014-0, and MOD-015-0.1, and it requires data submission by applicable data owners to their respective Transmission Planners and Planning Coordinators to support the Interconnection-wide case building process in their Interconnection. Reliability Standard MOD-033-1 is a new standard, and it requires each Planning Coordinator to implement a documented process to perform model validation within its planning area.
The transition and focus of responsibility upon the Planning Coordinator function in both standards are driven by several recommendations and FERC directives from FERC Order No. 693, which are discussed in greater detail in the rationale sections of the standards. One of the most recent and significant set of recommendations came from the NERC Planning Committee’s System Analysis and Modeling Subcommittee (SAMS). SAMS proposed several improvements to the modeling data standards, to include consolidation of the standards (the SAMS whitepaper is available from the December 2012 NERC Planning Committee’s agenda package, item 3.4, beginning on page 99, here:
Requirements and Measures
R1. Each Planning Coordinator and each of its Transmission Planners shall jointly develop steady-state, dynamics, and short circuit modeling data requirements and reporting procedures for the Planning Coordinator’s planning area that include: [Violation Risk Factor: Lower] [Time Horizon: Long-term Planning]
1.1. The data listed in Attachment 1. 1.2. Specifications of the following items consistent with procedures for building the Interconnection-wide case(s):
1.2.1. Data format;
1.2.2. Level of detail to which equipment shall be modeled;
1.2.3. Case types or scenarios to be modeled; and
1.2.4. A schedule for submission of data at least once every 13 calendar months.
1.3. Specifications for distribution or posting of the data requirements and reporting procedures so that they are available to those entities responsible for providing the data.
M1. Each Planning Coordinator and Transmission Planner shall provide evidence that it has jointly developed the required modeling data requirements and reporting procedures specified in Requirement R1.
R2. Each Balancing Authority, Generator Owner, Load Serving Entity, Resource Planner, Transmission Owner, and Transmission Service Provider shall provide steady-state, dynamics, and short circuit modeling data to its Transmission Planner(s) and Planning Coordinator(s) according to the data requirements and reporting procedures developed by its Planning Coordinator and Transmission Planner in Requirement R1. For data that has not changed since the last submission, a written confirmation that the data has not changed is sufficient. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M2. Each registered entity identified in Requirement R2 shall provide evidence, such as email records or postal receipts showing recipient and date, that it has submitted the required modeling data to its Transmission Planner(s) and Planning Coordinator(s); or written confirmation that the data has not changed.
R3. Upon receipt of written notification from its Planning Coordinator or Transmission Planner regarding technical concerns with the data submitted under Requirement R2, including the technical basis or reason for the technical concerns, each notified Balancing Authority, Generator Owner, Load Serving Entity, Resource Planner, Transmission Owner, or Transmission Service Provider shall respond to the notifying Planning Coordinator or Transmission Planner as follows: [Violation Risk Factor: Lower] [Time Horizon: Long-term Planning]
3.1. Provide either updated data or an explanation with a technical basis for maintaining the current data;
M3. Each registered entity identified in Requirement R3 that has received written notification from its Planning Coordinator or Transmission Planner regarding technical concerns with the data submitted under Requirement R2 shall provide evidence, such as email records or postal receipts showing recipient and date, that it has provided either updated data or an explanation with a technical basis for maintaining the current data to its Planning Coordinator or Transmission Planner within 90 calendar days of receipt (or within the longer time period agreed upon by the notifying Planning Coordinator or Transmission Planner), or a statement that it has not received written notification regarding technical concerns with the data submitted.
R4. Each Planning Coordinator shall make available models for its planning area reflecting data provided to it under Requirement R2 to the Electric Reliability Organization (ERO) or its designee to support creation of the Interconnection-wide case(s) that includes the Planning Coordinator’s planning area. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M4. Each Planning Coordinator shall provide evidence, such as email records or postal receipts showing recipient and date, that it has submitted models for its planning area reflecting data provided to it under Requirement R2 when requested by the ERO or its designee.
1. Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity in their respective roles of monitoring and enforcing compliance with the NERC Reliability Standards.
1.2. Evidence Retention
The following evidence retention periods identify the period of time an entity is required to retain specific evidence to demonstrate compliance. For instances where the evidence retention period specified below is shorter than the time since the last audit, the Compliance Enforcement Authority may ask an entity to provide other evidence to show that it was compliant for the full time period since the last audit.
The applicable entity shall keep data or evidence to show compliance with Requirements R1 through R4, and Measures M1 through M4, since the last audit, unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation.
If an applicable entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved, or for the time specified above, whichever is longer.
The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records.
1.3. Compliance Monitoring and Assessment Processes:
Refer to the NERC Rules of Procedure for a list of compliance monitoring and assessment processes.
1.4. Additional Compliance Information
MOD-032-01 – ATTACHMENT 1:MOD-032-2 - Attachment 1
Guidelines and Technical Basis
For purposes of jointly developing steady-state, dynamics, and short circuit modeling data requirements and reporting procedures under Requirement R1, if a Transmission Planner (TP) and Planning Coordinator (PC) mutually agree, a TP may collect and aggregate some or all data from providing entities, and the TP may then provide that data directly to the PC(s) on behalf of the providing entities. The submitting entities are responsible for getting the data to both the TP and the PC, but nothing precludes them from arriving at mutual agreements for them to provide it to the TP, who then provides it to the PC. Such agreement does not relieve the submitting entity from responsibility under the standard, nor does it make the consolidating entity liable for the submitting entities’ compliance under the standard (in essence, nothing precludes parties from agreeing to consolidate or act as a conduit to pass the data, and it is in fact encouraged in certain circumstances, but the requirement is aimed at the act of submitting the data). Notably, there is no requirement for the TP to provide data to the PC. The intent, in part, is to address potential concerns from entities that they would otherwise be responsible for the quality, nature, and sufficiency of the data provided by other entities.
The requirement in Part 1.3 to include specifications for distribution or posting of the data requirements and reporting procedures could be accomplished in many ways, to include posting on a Web site, distributing directly, or through other methods that the Planning Coordinator and each of its Transmission Planners develop.
An entity submitting data per the requirements of this standard who needs to determine the PC for the area, as a starting point, should contact the local Transmission Owner (TO) for information on the TO’s PC. Typically, the PC will be the same for both the local TO and those entities connected to the TO’s system. If this is not the case, the local TO’s PC can typically provide contact information on other PCs in the area. If the entity (e.g., a Generator Owner [GO]) is requesting connection of a new generator, the entity can determine who the PC is for that area at the time a generator connection request is submitted. Often the TO and PC are the same entity, or the TO can provide information on contacting the PC. The entity should specify as the reason for the request to the TO that the entity needs to provide data to the PC according to this standard. Nothing in the proposed requirement language of this standard is intended to preclude coordination between entities such that one entity, serving only as a conduit, provides the other entity’s data to the PC. This can be accomplished if it is mutually agreeable by, for example, the GO (or other entity), TP, and the PC. This does not, however, relieve the original entity from its obligations under the standard to provide data, nor does it pass on the compliance obligation of the entity. The original entity is still accountable for making sure that the data has been provided to the PC according to the requirements of this standard.
The standard language recognizes that differences exist among the Interconnections. Presently, the Eastern/Quebec and Texas Interconnections build seasonal cases on an annual basis, while the Western Interconnection builds cases on a continuous basis throughout the year. The intent of the standard is not to change established processes and procedures in each of the Interconnections, but to create a framework to support both what is already in place or what it may transition into in the future, and to provide further guidance in a common platform for the collection of data that is necessary for the building of the Interconnection-wide case(s).
The construct that these standards replace did not specifically list which Functional Entities were required to provide specific data. Attachment 1 specifically identifies the entities responsible for the data required for the building of the Interconnection-wide case(s).
During development of this standard, text boxes were embedded within the standard to explain the rationale for various parts of the standard. Upon BOT approval, the text from the rationale text boxes was moved to this section.
Rationale for R1:
This requirement consolidates the concepts from the original data requirements from MOD- 011-0, Requirement R1, and MOD-013-0, Requirement R1. The original requirements specified types of steady-state and dynamics data necessary to model and analyze the steady-state conditions and dynamic behavior or response within each Interconnection. The original requirements, however, did not account for the collection of short circuit data also required to perform short circuit studies. The addition of short circuit data also addresses the outstanding directive from FERC Order No. 890, paragraph 290.
In developing a performance-based standard that would address the data requirements and reporting procedures for model data, it was prohibitively difficult to account for all of the detailed technical concerns associated with the preparation and submittal of model data given that many of these concerns are dependent upon evolving industry modeling needs and software vendor terminology and product capabilities.
This requirement establishes the Planning Coordinator jointly with its Transmission Planners as the developers of technical model data requirements and reporting procedures to be followed by the data owners in the Planning Coordinator’s planning area. FERC Order No. 693, paragraphs 1155 and 1162, also direct that the standard apply to Planning Coordinators. The inclusion of Transmission Planners in the applicability section is intended to ensure that the Transmission Planners are able to participate jointly in the development of the data requirements and reporting procedures.
This requirement is also consistent with the recommendations from the NERC System Analysis and Modeling Subcommittee (SAMS) White Paper titled “Proposed Improvements for NERC MOD Standards”, available from the December 2012 NERC Planning Committee’s agenda package, item 3.4, beginning on page 99, here:
Aside from recommendations in support of strengthening and improving MOD-010 through MOD-015, the SAMS paper included the following suggested improvements:
1) reduce the quantity of MOD standards;
2) add short circuit data as a requirement to the MOD standards; and
3) supply data and models:
a. add requirement identifying who provides and who receives data;
b. identify acceptability;
c. standard format;
d. how to deal with new technologies (user written models if no standard model exists); and
4) These suggested improvements are addressed by combining the existing standards into two new standards, one standard for the submission and collection of data, and one for the validation of the planning models. Adding the requirement for the submittal of short circuit data is also an improvement from the existing standards, consistent with FERC Order No. 890, paragraph 290. In supplying data, the approach clearly identifies what data is required and which Functional Entity is required to provide the data.
5) The requirement uses an attachment approach to support data collection. The attachment specifically lists the entities that are required to provide each type of data and the steady-state, dynamics, and short circuit data that is required.
6) Finally, the decision to combine steady-state, dynamics, and short circuit data requirements into one requirement rather than three reflects that they all support the requirement of submission of data in general.
Rationale for R2:
This requirement satisfies the directive from FERC Order No. 693, paragraph 1155, which directs that “the planning authority should be included in this Reliability Standard because the planning authority is the entity responsible for the coordination and integration of transmission facilities and resource plans, as well as one of the entities responsible for the integrity and consistency of the data.”
Rationale for R3:
In order to maintain a certain level of accuracy in the representation of a power system, the data that is submitted must be correct, periodically checked, and updated. Data used to perform steady-state, dynamics, and short circuit studies can change, for example, as a result of new planned transmission construction (in comparison to as-built information) or changes performed during the restoration of the transmission network due to weather-related events. One set of data that changes on a more frequent basis is load data, and updates to load data are needed when new improved forecasts are created.
This requirement provides a mechanism for the Planning Coordinator and Transmission Planner (that does not exist in the current standards) to collect corrected data from the entities that have the data. It provides a feedback loop to address technical concerns related to the data when the Planning Coordinator or Transmission Planner identifies technical concerns, such as concerns about the usability of data or simply that the data is not in the correct format and cannot be used. The requirement also establishes a time-frame for response to address timeliness.
Rationale for R4:
This requirement will replace MOD-014 and MOD-015.
This requirement recognizes the differences among Interconnections in model building processes, and it creates an obligation for Planning Coordinators to make available data for its planning area.
The requirement creates a clear expectation that Planning Coordinators will make available data that they collect under Requirement R2 in support of their respective Interconnectionwide case(s). While different entities in each Interconnection create the Interconnection-wide case(s), the requirement to submit the data to the “ERO or its designee” supports a framework whereby NERC, in collaboration and agreement with those other organizations, can designate the appropriate organizations in each Interconnection to build the specific Interconnectionwide case(s). It does not prescribe a specific group or process to build the larger Interconnection-wide case(s), but only requires the Planning Coordinators to make available data in support of their creation, consistent with the SAMS Proposed Improvements to NERC MOD Standards (at page 3) that, “industry best practices and existing processes should be considered in the development of requirements, as many entities are successfully coordinating their efforts.” (Emphasis added).
This requirement is about the Planning Coordinator’s obligation to make information available for use in the Interconnection-wide case(s); it is not a requirement to build the Interconnectionwide case(s).
For example, under current practice, the Eastern Interconnection Reliability Assessment Group (ERAG) builds the Eastern Interconnection and Quebec Interconnection-wide cases, the Western Electricity Coordinating Council (WECC) builds the Western Interconnection-wide cases, and the Electric Reliability Council of Texas (ERCOT) builds the Texas Interconnectionwide cases. This requirement does not require a change to that construct, and, assuming continued agreement by those organizations, ERAG, WECC, and ERCOT could be the “designee” for each Interconnection contemplated by this requirement. Similarly, the requirement does not prohibit transition, and the requirement remains for the Planning Coordinators to make available the information to the ERO or to whomever the ERO has coordinated with and designated as the recipient of such information for purposes of creation of each of the Interconnection–wide cases.