WECC Position Paper for the additional ballot and non-binding poll of Project
2012-05 – ATC Revisions (MOD A), being balloted November 8-18, 2013
NERC is conducting an additional ballot of Project 2012-05 – ATC Revisions (MOD A), comprised
of standard MOD-001-2 from November 8-18, 2013.
Members of the Project 2012-05 – ATC Revisions (MOD A) Ballot Pool are encouraged to vote
YES on MOD-001-2.
Proposed MOD-001-2, if approved, would replace the following currently effective standards,
referred to as the MOD A standards:
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MOD-001-1a – Available Transmission System Capability
MOD-004-1 – Capacity Benefit Margin
MOD-008-1 – Transmission Reliability Margin Calculation Methodology
MOD-028-2 – Area Interchange Methodology
MOD-029-1a – Rated System Path Methodology
MOD-030-2 – Flowgate Methodology
The purpose of MOD-001-2 is to reorient the MOD A standards to focus on the reliability-related
aspects of Available Transfer Capability (ATC) and to address directives in Order No. 729.
Industry subject matter experts had questioned whether certain requirements in the MOD A
standards addressed market or competitive issues rather than reliability issues. The proposed
MOD-001-2 requirements address only the reliability-related impact of ATC and Available
Flowgate Capability (AFC) calculations, such as the need for Transmission Service Providers
(TSPs) to implement their ATC calculations in a consistent manner and share ATC data with
neighboring TSPs or other entities who need such data for reliability purposes.
WECC staff has reviewed MOD-001-2 and concluded that as drafted the proposed standard is a
significant improvement over the current versions of the MOD A standards. MOD-001-2 contains
six requirements that are necessary for reliability while doing away with the 56 requirements in
the current MOD A standards, many of which address market or competitive issues and how
calculations must be made. WECC staff members participated in the informal development
process for this standard and are unanimous in their support for the revised approach to this
standard.
During the last ballot and comment period, commenters identified an error in Requirement R5.
Commenters indicated that the responsibility for providing the Transmission Reliability Margin
Implementation Document (TRMID) and the Capacity Benefit Margin Implementation Document
(CBMID) had been assigned to the wrong entities. The drafting team concurred and this error has
been corrected in the current version being balloted.
For the reasons identified above WECC will be casting and affirmative vote on MOD-001-2.
A complete copy of the proposed standard and associated materials can be viewed at:
http://www.nerc.com/pa/Stand/Pages/Project201205MODAAvailableTransferCapability.
aspx
A document titled Compliance Input is included on the project page identified above. This
document is the result of the NERC Compliance Department working with the MOD A drafting
team to address specific questions asked by the MOD A drafting team during development of the
standard.
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If you determine that you will vote no, it is important that you provide a comment with your vote
indicating the reason(s) why you voted no and suggested modifications that would make the
standard acceptable. Recent revisions to the NERC Standards Processes Manual require that
negative ballots be accompanied by comments explaining the reason for the no vote for the vote
to be counted in the determination of consensus. Balloters wishing to submit comments with
their ballot must do so via the electronic comment form available from the project page identified
above.
In addition to the ballot, a non-binding poll of the Violation Risk Factors (VRFs) and Violation
Severity Levels (VSLs) is being conducted. WECC staff is not aware of any concerns with the
proposed VRFs and VSLs.
If you determine that you will vote no on the non-binding poll of VRFs and VSLs, it is important
that you provide a comment with your vote indicating the reason(s) why you voted no and
suggested modifications that would make the VRFs/VSLs acceptable.
All WECC entities that are registered in the Project 2012-05 – ATC Revisions (MOD A) Ballot
Pool are urged to cast their ballots prior to the close of the ballot period.
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