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2010-04.1 MOD-031 FERC Order No. 804 Directives | MOD-031-2

Description:

Start Date: 07/31/2015
End Date: 09/18/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2010-04.1 MOD-031 FERC Order No. 804 Directives MOD-031-2 IN 1 ST 2010-04.1 MOD-031 FERC Order No. 804 Directives MOD-031-2 08/03/2015 08/31/2015 09/09/2015 09/18/2015
2010-04.1 MOD-031 FERC Order No. 804 Directives MOD-031-2 Non-binding Poll IN 1 NB 2010-04.1 MOD-031 FERC Order No. 804 Directives MOD-031-2 Non-binding Poll 08/03/2015 08/31/2015 09/09/2015 09/18/2015

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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We appreciate the SDT’s efforts on clarifying the obligations to provide data to Regional Entities and the obligations of an applicable entity upon receipt of a data request seeking confidential information.  We agree the proposed modifications provide sufficient clarity.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 4, 9/18/2015

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Other Answers

John Fontenot, 8/10/2015

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Thomas Foltz, AEP, 5, 8/18/2015

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The ISO/RTO Standards Review Committee (ERCOT abtaining) agrees with the proposed revisions.

ISO Standards Review Committee, Segment(s) 2, 8/28/2015

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While the revisions provide clarity about the provision of data, they create ambiguity regarding how a BA or RC as the responsible entity responds to a data request for data that they do not and have not collected under related requirements in MOD-031.  More specifically, Requirement R3 requires a BA or PC to provide data listed in Requirements R1.3 through R1.5 in response to a request by a Regional Entity; however, it does not consider that such entity might not collect all listed data.  Accordingly, Requirement R3 could be read to require an entity to collect such data (whether they need to do so or not) solely for the purposes of responding to a Regional Entity request, which activity would be administratively burdensome and would provide no benefit to reliability - especially considering that the Regional Entity could directly request data not collected by a BA or PC from those entities from whom the BA or PC would be required to collect the data.

christina bigelow, 8/31/2015

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Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

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Leonard Kula, Independent Electricity System Operator, 2, 9/9/2015

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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Please refer to ERCOT's responses provided in response to the MOD-031-1 survey.

christina bigelow, 9/10/2015

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John Fontenot, 9/14/2015

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John Fontenot, 9/14/2015

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Given the stongly suppported rationale for deactivating the LSE registration function under the Risk-Based Registration initiative, Requirement 2 and Requirement 4 should be revised to remove the reference to LSE.

Bob Thomas, 9/15/2015

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Teresa Czyz, 9/15/2015

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The NSRF recommends that R4 bulleted items be updated to reflect the below changes. Our biggest concern is that all three bulleted items must be accomplished since there is an “and” at the end of the first and second bullet. The new wording allows entities the flexibility, which the NSRF believes is the intent of the bulleted items. The NSRF recommends:

  • Shall provide the requested data within 45 calendar days of the written request, subject to part 4.1 of this requirement, unless,
  • The requested data, if provided, would conflict with Applicable Entity’s confidentiality, regulatory, or security requirements
  •   Shall not be required to alter the format in which it maintains or uses the data.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 9/9/2015

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While the revisions provide clarity about the provision of data, they create ambiguity regarding how a BA or RC as the responsible entity responds to a data request for data that they do not and have not collected under related requirements in MOD-031.  More specifically, Requirement R3 requires a BA or PC to provide data listed in Requirements R1.3 through R1.5 in response to a request by a Regional Entity; however, it does not consider that such entity might not collect all listed data.  Accordingly, Requirement R3 could be read to require an entity to collect such data (whether they need to do so or not) solely for the purposes of responding to a Regional Entity request, which activity would be administratively burdensome and would provide no benefit to reliability - especially considering that the Regional Entity could directly request data not collected by a BA or PC from those entities from whom the BA or PC would be required to collect the data.

Tom Reedy, Florida Municipal Power Pool, 6, 9/16/2015

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While the revisions provide clarity about the provision of data, they create ambiguity regarding how a BA or RC as the responsible entity responds to a data request for data that they do not and have not collected under related requirements in MOD-031.  More specifically, Requirement R3 requires a BA or PC to provide data listed in Requirements R1.3 through R1.5 in response to a request by a Regional Entity; however, it does not consider that such entity might not collect all listed data.  Accordingly, Requirement R3 could be read to require an entity to collect such data (whether they need to do so or not) solely for the purposes of responding to a Regional Entity request, which activity would be administratively burdensome and would provide no benefit to reliability - especially considering that the Regional Entity could directly request data not collected by a BA or PC from those entities from whom the BA or PC would be required to collect the data.

 

Christina Bigelow, Electric Reliability Council of Texas, Inc., 2, 8/31/2015

Elizabeth Axson, 9/16/2015

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Molly Devine, 9/17/2015

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Given that NERC has requested removal of LSE (docket # RR15-4-000) from NERC Registry Criteria, Dominion suggests removal in this standard.

NCP and Nash, Segment(s) 1, 3, 5, 6, 9/17/2015

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Additional comments :

 

  • Hydro-Québec TransÉnergie’s Compliance staff recently questioned a TP, BA, LSE and an entity from a neighbouring Interconnection on how to calculate Integrated demands (see 1.3.1 and 1.3.2 of MOD-031) and  received 4 different answers.  We recommend adding these terms to the NERC glossary with a mathematical formula or adding the formulae to an Appendix of MOD-031.

 

  • Requested change to Implementation Plan:

Considering the nature of proposed changes to MOD-031 e.g.  ensuring that the obligation to share data under  Requirement R4 does not supersede or otherwise modify any of the Applicable Entity’s existing confidentiality obligations, we believe that version 2  does not require any delay for implementation and is easier to implement than version 1.  Therefore, we suggest that the implementation calendar be modified to read:

“MOD‐031‐2 shall become effective as follows:

The later of the effective date of MOD‐031‐1 or the first day of the first calendar quarter after the date that this standard is approved by applicable regulatory authorities 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, the standard shall become effective on the later of the effective date of MOD‐031‐1 or the first day of the first calendar quarter after the date the standard is adopted bythe NERC Board of Trustees or as otherwise provided for in that jurisdiction.”

Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie, NA - Not Applicable, Segments 2

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Bob Solomon, 9/18/2015

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Requirement is spelled incorrectly in the opening sentence of the second paragraph in the Rationale for R4.  

NPCC--Project 2010-04.1 MOD-031 FERC Order No. 804 Directives - MOD-031-2, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/18/2015

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We disagree with the proposed change to strike the word “collected” and change it to “listed” in R3.  The data in R1.3 – R1.5 is allowed to be determined to be collected by Planning Coordinator and Balancing Authority “as necessary” per R1.  By changing the word in Requirement R3 to “listed”, the data is inferred to be ‘forced to be collected’ since it is in the R1.3-1.5 list rather than determined to be ‘necessary to be collected’.

We would also suggest removing the term ‘Load-Serving Entity’ from the applicability section of the requirement.

SPP Standards Review Group, Segment(s) 1, 3, 5, 9/18/2015

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Duke Energy agrees with the proposed changes, and thanks the drafting team for their efforts.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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Texas RE noticed the VSLs for R3 references R2, rather than the requirement language which references “R1 Parts 1.3 through 1.5”.

Texas RE is concerned the terms listed under R4, “confidentiality, regulatory, or security requirements”, are vague.  This language allows a registered entity to fail to respond to a data request by citing any source of confidentiality, regulatory, or security requirements, regardless of its legitimacy or importance.  Texas RE request that the SDT provide examples of confidentiality provisions of an Open Access Transmission Tariff or a contractual arrangement that would prevent an Applicable Entity from providing data included in parts 1.3‐1.5 of Requirement R1.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 9/18/2015

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However, the use of "Applicable Entity" throughout the Standard is problematic as it is not a NERC defined term. 

Michiko Sell, 9/18/2015

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Hydro One Networks Inc. suggests that the wording “applicable entity in its area” (R1), and “applicable Regional Entity” (R3) be revised to add more clarity.  The current wording is also ambiguous in specifying what data is required, and the requirement may be left open to any requests for data collection.  For clarity, the standard should also specify minimum requirements.   Further, the standard’s applicability to Load Serving Entities should be removed, given NERC’s intention to remove this functional entity from its list of available functional registrations. 

Oshani Pathirane, 9/18/2015

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