NERC Case Notes: Reliability Standard MOD-010-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard MOD-010-0

NERC Case Notes: Reliability Standard MOD-010-0

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This page contains the NOP (Notice of Penalty) and ACP (Administrative Citation of Penalty) summaries. Click here to read the FFT (Find, Fix and Track) summaries.

Nevada Power Company, FERC Docket No. NP10-54-000 (March 1, 2010)

Reliability Standard: MOD-010-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Nevada Power was late in submitting its modeling and simulation data in October 2007 and then again in September 2008. Duration of violation from August 27, 2007, when the October 2007 data was due, through March 26, 2009.

Finding: The violation was deemed not to pose a serious or substantial risk to bulk power system reliability.

Penalty: $52,000 (aggregate for multiple violations)

FERC Order: Issued March 31, 2010 (no further action)

Northern California Power Agency (NCPA), FERC Docket No. NP12-10 (December 30, 2011)

Reliability Standard: MOD-010-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: NCPA was conducting an internal review of its compliance with Reliability Standards and found it had violations of MOD-010-0 R1 and R2. NCPA, as a GO, was not giving or reviewing data from its RC, Pacific Gas and Electric (PG&E), because no procedure or process to ensure compliance was in place. NCPA did not give complete equipment characteristics and system data or the review of that data as required by the Standard (R1). Regarding R2, data that was submitted to PG&E, as the area coordinator, was not reviewed for accuracy prior to its submission as required by the Standard. Also, NCPA did not coordinate the development of the data requirements and reporting procedures with PG&E. Therefore, NCPA self-report non-compliance with MOD-010-0.

Finding: The violation constituted a minimal risk to BPS reliability because, although the data was not processed as required prior to sending it to the RC, NCPA’s system characteristics had no changes nor were there changes to the load data that would have caused the neet to change NCPA’s network model. Not coordinating the reporting and data procedures with the RC had no affect on the reliability of the data submitted. The duration of the violation was June 18, 2007 through November 23, 2011. In determining the appropriate penalty, WECC considered NCPA’s compliance program, the fact that NCPA voluntarily took steps to ensure future compliance, and there was no evidence NCPA attempted to hide the violations. In addition, no aggravating factors were present.

Penalty: $1,000 (aggregate for four violations)

FERC Order: Issued January 27, 2012 (no further review)

Sierra Pacific Power Company, FERC Docket No. NP11-87-000 (January 31, 2011)

Reliability Standard: MOD-010-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: Sierra Pacific Power Company (SPPC), a Transmission Operator, Transmission Planner, Generator Owner and Resource Planner, self-reported that it did not submit comments to WECC on the 2014 HS3 Base Case (considered by WECC to be “steady-state modeling and simulation data”) by the scheduled deadline.

Finding: WECC determined that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because the late comments only extended WECC's final release date by a few days. The NERC Board of Trustees Compliance Committee (BOTCC) assessed a $6,000 penalty for the violation. In determining the penalty, the NERC BOTCC considered that the violation was SPCC's first occurrence of violation of the subject Reliability Standard; the violation was self-reported; SPCC cooperated during the compliance enforcement process; SPCC had a compliance program at the time of the violation; and there was no evidence SPCC attempted to conceal the violation.

Penalty: $6,000

FERC Order: Issued March 2, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-205-000 (June 29, 2011)

Reliability Standard: MOD-010-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: The Registered Entity self-reported that it had not filed its comments on a specific base case by the December 24, 2009 deadline specified by WECC.

Finding: WECC and the Registered Entity entered into a settlement agreement to resolve multiple violations, whereby the Registered Entity agreed to pay a penalty of $22,000 and to undertake other mitigation measures. WECC found that the MOD-010-0 violation constituted only a minimal risk to bulk power system reliability since the late-filed comments only pushed back WECC’s final release date by a short period and WECC was still able to issue preliminary versions on time. The duration of the MOD-010-0 violation was from December 24, 2009 through January 14, 2010. In approving the settlement agreement, NERC found that the violation of MOD-010-0 was self-reported; the Registered Entity was cooperative during the enforcement proceeding and did not conceal the violations; there was a compliance program in place (which was evaluated as a mitigating factor); and there were no additional aggravating or mitigating factors.

Penalty: $22,000 (aggregate for 4 violations)

FERC Order: Issued July 29, 2011 (no further review)

Utah Associated Municipal Power Systems, FERC Docket No. NP10-36-000 (February 1, 2010)

Reliability Standard: MOD-010-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: Utah Associated Municipal Power Systems (UAMP) self-certified non-compliance with the standard because it could not confirm that all of its members with behind-the-meter facilities were reporting their steady-state data as required by the standard. UAMP and its Balancing Authority (PacifiCorp) could not confirm that the small generation facilities located behind-the-meter on the 10 MW or above netting criteria level were submitting the required data and were being modeled in the WECC modeling database.

Finding: Duration of the violations was from June 18, 2007, when the standard became enforceable, through December 29, 2008, when UAMP completed a mitigation plan. In reaching its determination, WECC considered the following mitigating factors: (1) there was a minimal risk to the reliability of the bulk power system because the generating facilities missing the required data were small in individual and total group capacity. UAMP failed to provide less than or equal to 25% of the appropriate equipment characteristics, system data, and existing and future Interchange Schedules in compliance with its respective Interconnection Regional steady-state modeling and simulation data requirements and reporting procedures as defined in the standard; (2) the violations constituted UAMP's first occurrence of non-compliance with the applicable standard; (3) UAMP was cooperative throughout the evaluation and enforcement process; and (4) there was no evidence that UAMP's violations were intentional.

Penalty: $4,000 (aggregate for multiple violations)

FERC Order: Issued March 3, 2010 (no further review)