NERC Case Notes: Reliability Standard MOD-018-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard MOD-018-0

NERC Case Notes: Reliability Standard MOD-018-0

White & Case NERC Database

Colorado Springs Utilities, FERC Docket No. NP10-190-000 (September 30, 2010)

Reliability Standard: MOD-018-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Colorado Springs self-reported its failure to address whether its report of forecast and actual demand data included the data of nonmember entities within its metered bounds as required by R1. Moreover, it did not have formal documentation of the assumptions, methods, and manner in which uncertainties are treated in forecasts of aggregate peak demands and Net Energy for Load.

Finding: It was determined by WECC that the violation did not constitute a serious or substantial risk to the bulk power system because the only other entity with load in its metered boundary was a network transmission service customer with a small peak load. Duration of the violations was from June 18, 2007 through September 24, 2008. In determining the penalty amount, WECC also considered that this was Colorado Springs’ first violation of the standard, and that it had self-reported or self-certified 6 of the 9 violations that gave rise to the penalty.

Penalty: $31,000 (aggregate for multiple violations)

FERC Order: Issued October 29, 2010 (no further review)

Farmington Electric Utility System, FERC Docket No. NP10-40-000 (February 1, 2010)

Reliability Standard: MOD-018-0

Requirement: R1/1.2

Violation Risk Factor: Medium/Lower

Violation Severity Level: Not provided

Region: WECC

Issue: Farmington Electric Utility System ("FEUS") self-reported that, while it was compiling the required data, it did not have documentation regarding assumptions, methods, and manner in which uncertainties are treated in the forecasts of aggregated peak demands and Net Energy for Load. Duration of the violation was from June 18, 2007 when the standard became enforceable through June 30, 2008.

Finding: Penalty was deemed appropriate because these were FEUS' first violations of the applicable standards, FEUS self-reported eleven of the violations, and FEUS is a small generation and transmission system that had made a substantial commitment of financial and personnel resources to NERC compliance relative to its size.

Penalty: $40,250 (aggregate for multiple violations)

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

Unidentified Registered Entity, FERC Docket No. NP11-2-000 (October 7, 2010)

Reliability Standard: MOD-018-0

Requirement: R1/1.2

Violation Risk Factor: Medium

Violation Severity Level: N/A

Region: WECC

Issue: An Unidentified Regional Entity (URE) self-reported a violation for not providing documentation on its demand data as required because it could not produce peak demand and energy load growth rates documentation for its East area.

Finding: The violation did not pose a serious or substantial risk to the reliability of the bulk power system because it was a documentation issue. The URE’s report of actual and forecast demand data addressed assumptions, methods, and the manner in which uncertainties are handled in the forecasts of aggregate peak demands and Net Energy of Load as required for the East area.

Penalty: $9,000 (aggregate for multiple violations)

FERC Order: Issued November 5, 2010 (no further review)