NERC Case Notes: Reliability Standard MOD-025-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard MOD-025-2

NERC Case Notes: Reliability Standard MOD-025-2

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City of Lake Worth (LWU), FERC Docket No. NP18-10 (April 30, 2018)

Reliability Standard: MOD-025-2

Requirement: R1, R1.2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: Florida Reliability Coordinating Council, Inc. (FRCC)

Issue: During a compliance spot check conducted by FRCC from February 27 to March 2, 2017, it was determined that LWU, a GO, was in violation of MOD-025-2 R1.2. FRCC identified that LWU did not verify at least 40 percent of its Facilities as set forth by the Implementation Plan. LWU failed to submit testing information for the Real Power capability of its Facilities to the Transmission Planner within 90 days of completing the test, as required. FRCC found that the violation was largely attributable to a lack of management oversight, originating from prior management staff that did not sufficiently monitor and incorporate new implementation policies.

Finding: FRCC found the violation constituted a minimal risk to BPS reliability and did not pose a serious or substantial risk to the BPS. By failing to inform the Transmission Planner, the capability model for the entire Region could have been compromised. Such inaccuracies could have negatively affected preparedness in emergency scenarios, as the misrepresentation of power resources available (or not available) could have exacerbated such a scenario. However, the total generation output from LWU in violation of MOD-025-2 represented a minimal proportion for the Region (only 0.0014 percent). The duration of the violation was from September 28, 2016 (when LWU failed to submit the required testing information to the Transmission Planner, per the 90-day timeframe as instituted in the Implementation Plan) through February 13, 2017 (when LWU notified the Transmission Planner). FRCC considered prior noncompliance with MOD-025-2, ultimately finding that the noncompliance history of LWU warranted consideration as an aggravating factor. Following the violation, LWU purchased asset management software and a third-party vendor to improve systematic tracking of NERC standards. LWU has now established a quarterly meeting schedule to discuss and review applicable deadlines and implementation measures.

Penalty: $60,000 (combined with other violations)

FERC Order: Issued April 30, 2018 (no further review)