NERC Case Notes: Reliability Standard MOD-006-0
Reliability Standard: MOD-006-0
Violation Risk Factor: Lower
Violation Severity Level: Severe
Issue: In December 2008, the City of Tallahassee (TAL) self-reported that, as a Transmission Service Provider, it had not made its Capacity Benefit Margin (CBM) use procedure available on a website that was accessible to the Regional Entities, NERC and transmission users. TAL had switched to a new Open Access Same-Time Information System (OASIS) vendor on June 28, 2007, and the CBM document was not posted online during the setup and migration to the new OASIS system.
Finding: FRCC and TAL entered into a settlement agreement to resolve multiple alleged violations, whereby TAL neither admitted nor denied the violations but agreed to pay a penalty of $5,000 and to undertake other mitigation measures. The duration of the alleged MOD-006-0 violation was from June 18, 2007 to December 8, 2007, when TAL discovered the problem and uploaded the CBM use procedure in order to make it available to the required entities. FRCC found that the alleged violation of MOD-006-0 did not create a serious or substantial risk to bulk power system reliability since TAL did actually have a CBM use procedure in place. In addition, the CBM use procedure was available before June 28, 2007 on a website accessible by the Regional Entities, NERC and transmission users and, afterwards, was available upon request. Furthermore, NERC considered the fact that the alleged violations were TAL's first violation of the relevant Reliability Standards; the alleged violations were self-reported; TAL was cooperative during the enforcement process and did not attempt to conceal the alleged violations; TAL had a positive compliance program; and there were no additional mitigating or aggravating factors.
Penalty: $5,000 (aggregate for multiple violations)
FERC Order: Issued August 27, 2010 (no further review)