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Individual or group.  (47 Responses)
Name  (28 Responses)
Organization  (28 Responses)
Group Name  (19 Responses)
Lead Contact  (19 Responses)
Question 1  (43 Responses)
Question 1 Comments  (47 Responses)
Question 2  (41 Responses)
Question 2 Comments  (47 Responses)
Question 3  (42 Responses)
Question 3 Comments  (47 Responses)
Question 4  (42 Responses)
Question 4 Comments  (47 Responses)
Question 5  (41 Responses)
Question 5 Comments  (47 Responses)
Question 6  (42 Responses)
Question 6 Comments  (47 Responses)
Question 7  (43 Responses)
Question 7 Comments  (47 Responses)
Question 8  (40 Responses)
Question 8 Comments  (47 Responses)
Question 9  (42 Responses)
Question 9 Comments  (47 Responses)
 
Group
Northeast Power Coordinating Council
Guy Zito
Yes
The collection of this data is already addressed through tariffs, Market Rules, and Interconnection Agreements. The Standard should be retired. Although data can be reliability related sufficient data is collected as dictated by other standards. NERC staff should coordinate and ensure that the collection of this data is incorporated in existing standards projects.
Yes
The collection of this data is already addressed through tariffs, Market Rules, and Interconnection Agreements. The Standard should be retired. Although data can be reliability related sufficient data is collected as dictated by other standards. NERC staff should coordinate and ensure that the collection of this data is incorporated in existing standards projects.
Yes
The collection of this data is already addressed through tariffs, Market Rules, and Interconnection Agreements. The Standard should be retired. Although data can be reliability related sufficient data is collected as dictated by other standards. NERC staff should coordinate and ensure that the collection of this data is incorporated in existing standards projects.
Yes
 
Yes
 
Yes
 
No
 
No
The collection of this data is already addressed through tariffs, Market Rules, and Interconnection Agreements. The Standard should be retired. Although data can be reliability related sufficient data is collected as dictated by other standards. NERC staff should coordinate and ensure that the collection of this data is incorporated in existing standards projects.
No
 
Individual
Ray Phillips
AMEA
No
The two questions the SDT asked on question 1 could have two different answers. I answered no to the additional data and yes to retire this standard. The MOD-024-2 draft removes the regions and entities like the Planning Coordinator from the decision making ability as to which generators are material to the BES but instead provides a blanket approach that will include generators that are and are not material to the BES.
No
The MOD-024-2 draft removes the regions and entities like the Planning Coordinator from the decision making ability as to which generators are material to the BES but instead provides a blanket approach that will include generators that are and are not material to the BES. The many of the regions have identified generators connected below 100 kV that are material to the BES and likewise have identified generators connected at or above 100 kV that are not material to the BES.
No
The MOD-024-2 draft removes the regions and entities like the Planning Coordinator from the decision making ability as to which generators are material to the BES but instead provides a blanket approach that will include generators that are and are not material to the BES.
Yes
The MOD-024-2 draft removes the regions and entities like the Planning Coordinator from the decision making ability as to which generators are material to the BES but instead provides a blanket approach that will include generators that are and are not material to the BES.
No
The MOD-024-2 draft removes the regions and entities like the Planning Coordinator from the decision making ability as to which generators are material to the BES but instead provides a blanket approach that will include generators that are and are not material to the BES.
No
The MOD-024-2 draft removes the regions and entities like the Planning Coordinator from the decision making ability as to which generators are material to the BES but instead provides a blanket approach that will include generators that are and are not material to the BES.
Yes
The current MOD-024-1 allows the regions to determine which generators must provide the requied data. Regions like SERC have developed regional supplemental standards that identifies such generators. The draft MOD-024-2 contradicts SERC's regional supplemental standards and totally removes SERC and other regions from the decision making process.
Yes
Since SERC's supplemental standards have not yet been approved by FERC I consider them proposed standards. The current MOD-024-1 allows the regions to determine which generators must provide the requied data. Regions like SERC have developed regional supplemental standards that identifies such generators. The draft MOD-024-2 contradicts SERC's regional supplemental standards and totally removes SERC and other regions from the decision making process. The draft MOD-024-2 conflicts with the new CIP standards regarding the size of significant generators.
Yes
The draft MOD-024-2 removes the decision making ability of the only entities (PC, regions, etc.) that actually know which generators are material to the BES. Instead the draft uses a blanket approach to basically include all generators 20 MVA and above connected at 100 kV and above. This approach will reduce the reliability of the BES due to distraction caused by the deluge of data from a multitude of generators that are not material to the BES and will exempt material generators that are connected below 100 kV.
Individual
Scott McGough
Oglethorpe Power Corporation
 
 
Yes
 
 
Yes
 
 
 
 
Yes
 
Group
Generators Supporting Elimination of MOD-024
Thomas J Bradish
No
The generator owner/operator provides unit real power capability in six standards other than in MOD-024 plus the TOP/RC/BA/ISO see a unit’s real time output via their EMS. MOD-024 is duplicative and, as such, unnecessary. Planners on the RFC MOD-024 draft standard drafting team argued that they needed to know what a unit could consistently produce over a 7-24 hour period when running their reliability models. They were not interested in knowing short-term unit capability. Another reason for not using the unit’s output under a stressed condition is that it is not at a level of reliable output. A unit can generate the real power during a test but many times not under actual system conditions. These tests are conducted at the most favorable time for unit performance and are only indicative of unit performance at that point in time. They are no guarantee of future performance. This results in system operators not getting the real power output that they thought was available to them. This shortage of real power occurs during system emergencies when system operators need the mega-watts the most. Because of this, these mega-watts have been called paper mega-watts. Requiring a test actually fosters a situation counter to ALR. Every unit’s output must be metered and its output is monitored in real time in the TOP, RC and/or ISO Energy Management System (EMS). The EMS would have a history of a units output. This data is the most accurate representation of a unit’s capability under actual system conditions and is a true representation of actual unit capability. This actual unit production data can be made available to the transmission planners. The transmission planners can analyze EMS data and use that period of unit performance that meets their requirements. If they are interested in a unit’s performance during the period of highest demand, they can analyze unit output during the most recent or previous peak demand period. By using actual data, the paper mega-watt’s issue goes away. If the planner has any issues, they can discuss these directly with the generator operator/owner. Requiring the planner to analyze EMS data may have another benefit. It will force the planner to become more engaged and communicate more strongly with the real-time system operators. The planner will become more aware of real-time issues that will enable them to incorporate these anomalies into their system models. Another benefit to using actual unit data is that it will eliminate running the unit to perform the MOD-024 verification. Not having to run a unit that is not needed to meet system demand will result in fewer emissions and fuel consumption yielding a higher level of environmental stewardship. As a nation, we are supposed to be concerned about greenhouse gases and efficient use of carbon-based fuels. Forcing units to run is contrary to these national goals. Unit real power capability is specified in the units interconnection agreement with the TO. The GOP is required to report unit de-rates to the TOP, RC, BA or ISO immediately after they occur. Real power reporting requirements currently appear in six (6) standards as follows: FAC-002-0: R1. The GO, TO, Distribution Provider (DP), and Load-Serving Entity (LSE) seeking to integrate generation facilities, transmission facilities, and electricity end-user facilities shall each coordinate and cooperate on its assessments with its Transmission Planner and Planning Authority. The assessment shall include: R1.1. Evaluation of the reliability impact of the new facilities and their connections on the interconnected transmission systems. R1.4. Evidence that the assessment included steady-state, short-circuit, and dynamics studies as necessary to evaluate system performance in accordance with Reliability Standard TPL-001-0. MOD-010-0 Applicability 4.3. GO specified in the data requirements and reporting procedures of MOD-011-0 R1. MOD-011-0 R1.2. Generating Units (including synchronous condensers, pumped storage, etc.): location, minimum and maximum Ratings (net Real and Reactive Power), regulated bus and voltage set point, and equipment status. TOP-002-2a R13. At the request of the Balancing Authority or Transmission Operator, a Generator Operator shall perform generating real and reactive capability verification that shall include, among other variables, weather, ambient air and water conditions, and fuel quality and quantity, and provide the results to the Balancing Authority or Transmission Operator operating personnel as requested. R14. Generator Operators shall, without any intentional time delay, notify their Balancing Authority and Transmission Operator of changes in capabilities and characteristics including but not limited to: R14.1. Changes in real and reactive output capabilities. (Retired August 1, 2007) R14.1. Changes in real output capabilities. (Effective August 1, 2007) R15. Generation Operators shall, at the request of the Balancing Authority or Transmission Operator, provide a forecast of expected real power output to assist in operations planning (e.g., a seven-day forecast of real output). TOP-003-1 R1. Generator Operators and Transmission Operators shall provide planned outage information. Each Generator Operator shall provide outage information daily to its Transmission Operator for scheduled generator outages planned for the next day (any foreseen outage of a generator greater than 50 MW). The Transmission Operator shall establish the outage reporting requirements. Such information shall be available by 1200 Central Standard Time for the Eastern Interconnection and 1200 Pacific Standard Time for the Western Interconnection. R2. Each Transmission Operator, Balancing Authority, and Generator Operator shall plan and coordinate scheduled outages of system voltage regulating equipment, such as automatic voltage regulators on generators, supplementary excitation control, synchronous condensers, shunt and series capacitors, reactors, etc., among affected Balancing Authorities and Transmission Operators as required. R3. Each Transmission Operator, Balancing Authority, and Generator Operator shall plan and coordinate scheduled outages of telemetering and control equipment and associated communication channels between the affected areas. TOP-006-2 R1` Each Transmission Operator and Balancing Authority shall know the status of all generation and transmission resources available for use. R1.1 Each Generator Operator shall inform its Host Balancing Authority and the Transmission Operator of all generation resources available for use. Because the generator owner/operator provides unit real power capability in six standards plus the TOP/RC/BA/ISO see a unit’s real time output via their EMS reporting the generator testing and reporting contemplated under MOD-024 is unnecessary. In addition, MOD-026 and 027 have not been considered in this discussion but are anticipated to be approved over the course of the next two years would cause further duplication. Thus, MOD-024 is clearly unnecessary.
NA. This standard is not needed for reliability.
NA. This standard is not needed for reliability.
NA. This standard is not needed for reliability.
NA. This standard is not needed for reliability.
NA. This standard is not needed for reliability.
No
 
NA. This standard is not needed for reliability.
NA. This standard is not needed for reliability.
Individual
Martin
Bauer
No
The changes in this standard duplicate and conflict the requirement specific under TOP002. Originally this standard was for verification procedures which were used to meet TOP-002. The verification procedures defined in this standard should be incorporated into TOP-002 if this standard is retired.
Yes
 
No
The intent of the requirement of the previous version was to provide realistic summer and winter generator capability. For hydro units, the process detailed in this version only provides a vague assessment of normal and most likely not be the realistic capability of the generator. The process requires the units to be operated “normally” which is undefined and to adjust the MW to reflect forecasted (summer or winter) reservoir conditions. Hydro units may be “normally” operated throughout their operating range. Without specific guidance that the operation should utilize a normal “full load” condition, the true summer capability may not be known. Specifically, if a generator , at some time other than summer is, operated at 50% gate during the operational snap shot produces xx MW, then the xx MW at 50% gate will be indexed for the summer reservoir level. The true capability of the generator at 100% gate (normal full load) during summer would actually be much higher. The language would need to ensure that the full load would reflect limitations other than those introduced by head.
No
It is not appropriate to consider the variability of wind generating stations comparable to the operation of a run of the river hydro. Run of the river hydro tends to be less variable and pose a lower regulation burden on the BES than wind generation. We justify this position in that the operator can estimate the energy produced during a month and even schedule the capacity at which the generator is operated, whereas wind cannot. As such an operator is able to provide a verification of the capability of our run of the river plants.
Yes
 
No
This standard is not consistent with the NERC functional model in that it requires the submission of information is not consistent with the role of the Resources Planner. The Resource Planner’s role is to develop a long term plan for resource adequacy of specific loads within a Resource Planners area. The information furnished under this requirement would be valid for less than one year. Forecast reservoir operations are notoriously inaccurate at more than 9 months. The forecast seasonal variation is relevant for TOP and BA functions. Resource Planners would interested in average seasonal variations and any physical changes to generator capability (e.g. de-rating, up-rating, etc).
 
Yes
This standard conflicts with TOP-002
Yes
The requirement will result in continuous reporting by the Generator Owner for its hydro units. The capability of hydro units can vary seasonally by more than 50 MW in less than 6 months. It is unclear what reliability purpose is served by this requirement. As stated in the general comment section, Generation capability is forecast, adjusted, and provided to TOP’s and BA’s under TOP-002-2.
Individual
Jonathan Appelbaum
Long island power Authority
Yes
 
No
Units below 100 kV may in the future be registered with NERC under the materiality clause. LIPA suggests relying on the MVA rating only. Additionally, LIPA requests that in the Applicability section a statement clarifying that the point of interconnection may not be a BES element.
Yes
 
Yes
 
Yes
 
Yes
 
No
 
No
 
No
 
Individual
Russell A. Noble
Cowlitz County PUD
Yes
Yes the Standard should be retired. This standard appears to duplicate and complicate FAC-008 and FAC-009. If this standard remains, then should generator rating be removed from FAC-008 and FAC-009?
Yes
This approach makes it easy for the owner to know when compliance is necessary. However, 20 MVA redline across the board for any single unit seems too low. Any significant generation will be connected at 100 kV or greater, but not all generation is significant just because it is connected at a certain voltage. A simple redline is easy to manage, but is new small generation development being discouraged with this low bar? I am not dead set against this applicable level, but I think some research into discovering the unintended consequences should be made.
Yes
 
Yes
Wind generation can’t buttress reliability in a pinch, therefore should not be included. Agree with the run-of-river argument. However, there are other generation plants that are limited by FERC license to the maximum cubic feet per minute of water permitted to flow through the tail race. Such generation will have name plate ratings well above the allowed possible power generation considering the available prime mover. Therefore the limiting factor is not the ambient temperature, or the thermal aspects of the generation units, but the efficiency of the generation plant to convert the maximum allowed prime mover into electrical power. This efficiency will not change much, if at all, over time. Such units should also be exempt except for a single test at maximum allowed flow.
Yes
 
Yes
As long as it does not conflict with operational constraints of the generation plant.
No
 
Yes
Maximum hydraulic flow constraints by operation license can legally prevent maximum name plate capacity verification tests.
Yes
Ambient temperature correction calculation requirements may incur significant compliance costs with little return for the effort. Will the Planner be asking for operation output vs. ambient temperatures way beyond normal levels? If the required ambient temperature is beyond the operational testing ability (i.e. 500 year high), how will the engineering analysis be established and verified?
Individual
Edwin Thompson
Consolidated Edison Co. of New York
Yes
There is a need to test the gross and net real power capability because it is a key operating and planning horizon requirement to maintain system reliability. Unit testing is critical to System Operations and their ability to respond to contingencies. Even now, there are concerns with interconnection frequency responses and units not responding to AGC signals as noted in the 2-11-2010 NERC Industry Advisory on interconnection frequency response. In addition, as more and more wind generation is installed, generation capability issues will become more important to System Operators. The standard should not be retired, but the requirements should be incorporated into a new FAC standard or included in FAC-008.
No
SDT should not make reference to a specific voltage level. The SDT should indicate that verification should be performed on units that are connected to the Bulk Electric System as determined by the Region.
No
The SDT should change the verbiage to “a minimum of one continuous hour of normal operation” to avoid confusion that the unit can be ramping up to full load during the test.
No
All units meeting the voltage level and output level as specified in Section 4.2 should be tested. From both an operating horizon and planning horizon, it is important to have an accurate model of the system.
No
Please see response to question 4. In addition, terms such as “identical significant control systems settings” and “similar verified capabilities” are ambiguous. Section 4.4 of Attachment 1 should be removed.
Yes
In addition, different regions of the country may have summer or winter peaking periods and will schedule tests accordingly.
No
 
No
 
Yes
MOD-024-2 requires bi-annual testing, while at the same time exempted intermittent units (e.g. wind generators) and stations with multiple units (section 4.4). A reliability standard should support reliability; therefore, all units should be tested at the same frequency. The DT should consider a reliability standard that has an annual test requirement only that tests all generation units, regardless of type (including intermittent units or stations with multiple units). A region can also develop bi-annual requirements for a summer and winter test if they see a reliability benefit and/or have a market requirement. Concerning R1: The requirement does not specifically state who should receive the generator unit capability data. The PC? The RP?
Individual
Baj Agrawal
Arizona Public Service Co.
No
There is no reliability need for this standard and it should be retired. It does not serve any purpose and no body uses this data.
No
There is no need to go down to registry level of 20 MVA. The variation in capacity of these small generators has no measurable impact on the grid planning study results. The studies have onsiderable more uncertainties due to other more significant variables. The minimum size should be 100 MVA for each unit or 250 MVA for a plant.
No
Our experience is that 30 minutes are adequate to reach steady state conditions. There are no benefits to be derived by going beyond 30 minutes.
Yes
 
Yes
 
Yes
The need for verification should also be left on the Planning Coordinator.
No
 
No
 
Yes
This standard is contradictory to new NERC policy of “results-based reliability standards." NERC should not be developing a standard which it will have to withdrawa in a future review. If it is decided to go ahead with the standard, the reliabiltity benefits should be expalined.
Group
NERC Standards Review Subcommittee
Carol Gerou
Yes
Please review the possibility of redundancy within the following NERC standards: FAC-001-0; R1.1, Connection requirements for Generation facilities R2.1.3, Voltage level and MW and MVAR capacity or demand at point of connection. FAC-008-1; R1, GO shall each document its current methodology used for determining Facility Ratings… FAC-009-1; R1, GO shall each establish Facility ratings… MOD-010-0; R1, GOPs shall provide this steady-state modeling and simulation data… MOD-012-0; R1, GOPs shall provide appropriate equipment characteristics and system data… TOP-002-2a; R14, GOP shall notify the BA and TOP of changes in capabilities and characteristics… R14.1, Changes in real output capabilities
Yes
 
Yes
 
Yes
 
Yes
Please revise 4.4 of Attachment 1 4.4. Alternatively for multiple units installed at the same site where the units have identical designs, identical major components, identical significant control system settings and similar “tested” verified capabilities “per MOD-024”: 4.4.1 Verify approximately 20 percent of all such units annually with all units being verified over a five year period. 4.4.2 Verify at least one unit each year if fewer than five units meet the criteria in 4.4.
Yes
R2 should be redacted to include variables and not be so constrained to temperature since there might be other variables besides temperature. These variables would be specified at the Planning Coordinator and Resource Planner discretion.
No
N/A
No
N/A
Yes
Requirement R1 – The requirement should be clarified that in the case of Joint-owned-units, the Operator of the unit is responsible for verifying the capability of the unit. For R1, R2, & R3, we propose a Violation Risk Factor of “Lower” and a Time Horizon of “Operations Planning, Long-Term Planning”. We propose “Lower” for the VRF because more accurate real power capability values will be assured by this requirement, but reasonably accurate values are likely without this requirement. We propose “Operations Planning, Long-Term Planning” for the TH because RCs and TOPs will use this data in their operations planning studies and PCs and TPs will use this data in their transmission planning studies. For R2, replace “desired temperature to which the data” with “desired ambient coolant temperature to which the summer and winter data” for added clarity. In Attachment 1, 3.2; replace “ambient air temperature” with “ambient coolant (air, water, etc.) temperature” because the capability of different types of generators is affected by the temperature of different cooling medium. In addition, consideration may need to be given to the average pressure level of generating units that use hydrogen for equipment cooling. Introduction, Section 4.2 - As written, small diesel generators at applicable Generating Facilities could be expected to be tested as part of this standard, even if these small generators are intended only for local site power, and are only capable of reaching a 100 KV interconnection by back-feeding through local site distribution circuits and auxiliary transformers. Based on the MVA metrics provided, it would appear their inclusion is not the intent, but the standard is ambiguous as written. On the Implementation Plan for MOD-024-2 for units that are to be verified every five years, they state the verification “will begin five years after the compliance implementation date for annual units.” Wouldn’t it make more sense to make them verify in the first year after the MOD-24-02 is adopted or approved and then do it every five years after that? On page 2 of 10, A.5. Effective Date, it seems unclear when they say verification “will begin 30 calendar days following the first summer or winter peak period” . For example, if the summer peak occurs in June and you expect a higher peak in July or August and it doesn’t occur, then you would be in violation. The same applies for the winter period. They don’t define the summer and winter period. On page 5 of 10, MOD-024-2 Attachment 1. 2. Verify generating unit winter gross Real Power generating capability as follows: 2.1. They don’t define the winter period and what the conditions should be for the verification test period. Please Clarify. On page 5 of 10, MOD-024-2 Attachment 1. 2. Verify generating unit winter gross Real Power generating capability as follows: 2.4. “by making a temperature correction to the most recent summer gross Real Power generating capability verification.” Under what conditions can temperature corrections be made?
Group
We Energies
Howard Rulf
No
We feel this requirement could be retired do to the fact that the data is collected and reported under several other standards as well as many market rules. For example, the Midwest ISO has established testing requirements for generators under Module E of the Midwest ISO Open Access Transmission, Energy and Operating Reserve Markets Tariff. We also feel that having multiple different testing and reporting requirements can potentially lead to confusion and errors in reporting. If it is determined to not retire this standard, a provision should be made that if generator testing information is provided to a RTO following prescribed testing standards of the RTO, the submittal of the information to the RTO would meet the requirements of MOD-024-2. There is also a concern regarding the different applicability requirements between MOD-024-2 (Generator Owner, Planning Coordinator, and Resource Planner) and the recently passed MOD-024-RFC-01 (Generator Operator and Planning Coordinator) which further illustrates the problem of consistency of requirements.
 
 
Yes
 
 
No
To the extent there are multiple reporting requirements for generator capacity data, a standard timeframe for reporting the information should be developed in order to minimize the potential for conflicting data on the same generator from being used for similar modeling purposes. In addition, to the extent that generator capability data will be adjusted based upon ambient conditions, the requirement to verify the summer gross Real Power generating capability only during the summer period is overly restrictive. Current standards for generator testing allows the results from any period of time to be used as long as the results are adjusted based upon ambient conditions at the time of the test to the ambient conditions that would exist during the summer.
 
 
Yes
Under requirement R3, we question the necessity of reporting a 50 MW reduction in a unit within 15 calendar days of the determination that the reduction is expected to last more than 6 months. Given the current wording, this requirement would need to be understood by a very broad base of individuals who may not typically be aware of this reporting requirement (e.g. a maintenance supervisor evaluating the impact of damage to a mill) and the current wording is unclear as to when the 15 day clock would begin. Prior to making this a requirement, an evaluation should be done to determine how big of a problem this is currently causing to any system modeling, what the risks are of waiting until the next test date to report the issue, and whether or not the concerns change if a RTO has an annual testing requirement.
Group
GO/GOP
Silvia Parada Mitchell
No
No, we do not feel additional empirical data is necessary as we believe this version should include data required in Version 1 as this version gave a better description of what is happening with a generating unit during a test. Yes, we do feel this standard should be retired. We believe this standard is unnecessary since real power verification can and should be handled by generation and transmission agreements. The Generator Owner (GO) & Generator Operator (GOP) provide generation unit real power capability in seven standards other than in MOD-024 plus the Transmission Operator (TOP), Reliability Coordinator (RC), Balancing Authority (BA) and Regional Transmission Organization (RTO) / Independent System Operator (ISO) see a unit’s real time output via their Energy Management System (EMS). Therefore, the generator testing and reporting contemplated under MOD-024 is unnecessary. In addition, MOD-026 and 027 have not been considered in this discussion but are anticipated to be approved over the course of the next two years would cause further duplication. Thus, MOD-024 is clearly unnecessary.
Yes
 
No
We feel that one hour is too short. We recommend verfication be performed one hour after the unit has reached steady state operation since some units may take different lengths of time to reach steady state.
Yes
 
Yes
 
No
We do not agree with this approach. Validation should be performed during a period which is mutually agreed upon by both the GO and TOP to take into account seasonality. For the other periods, validations should not be required.
Yes
Different regions have different peak seasons depending on the climate.
No
 
Yes
We believe this standard should be retired in its entirety.
Group
Exelon Generation Co LLC
David P Belanger
No
The standard should be retired there is presently an number of different standards the require Generators to provide the same information.
 
No
Short duration testing conducted when conditions are the most favorable do not provide an accurate indication of unit preformance under all conditions.
Yes
 
No
By using information already gathered through the EMS during unit operations for market reasons would elimiate the need for "testing only" runs redusing unnecessary fuel, emmissions and start up stresses on units.
No
Using real time data from EMS would allow planners to have access to dat for anytime of year and system conditions elimiating the need to schedule testing.
No
 
No
 
No
 
Individual
Greg Mason
Dynegy Inc
Yes
Planning related entities (i.e. Planning Coordinator, Resource Planner and Transmission Planner) need the maximum (normalized)demonstrated capability of generating units for inclusion in their planning models. No other Standard requires this data to be accumulated and reported to these entities. Also, historical EMS data that reflects economic dispatch and regulating requirements is not an alternative source for this data.
Yes
 
Yes
 
Yes
 
Yes
 
No
The Transmission Planner also needs this generator data. These planning entities should not be required to provide the desired temperature to which the data needs to be adjusted. Generator Owners should simply adjust the actual test data using average temperature data from a location near the plant. This provision has been incorporated in the related RFC Regional Standard MOD-024-RFC-01.
No
 
No
 
Yes
1. Applicability 4.1- Transmission Planner needs to be added as a Functional Entity. All Planning related entities (i.e. Planning Coordinator, Resource Planner and Transmission Planner) need the maximum demonstrated capability of generating units for inclusion in their planning models. 2. Requirement R2- Adjustment of generating verification data should not be dependent on a request from a planning entity. This data should be adjusted to an average temperature in all cases and recorded on Attachment 2. 3. Attachment 1, Item 3.4.5- Modify this item to correspond to recommended changes in Requirement R2 (see above comment #2). 4. Attachment 1, Item 4.5- The phrase “does not run with the periodicity described in 4.1 through 4.4” ” is ambiguous. No “periods” are included in Items 4.1 through 4.4 in Attachment 1. The intent of this provision needs to be clarified.
Group
Electric Market Policy
Mike Garton
No
We agree that a standard for Verification of Generator Gross and Net Real Power Capability is needed. We support the data being requested in standard MOD-024-2, Attachment 1 and 2.
Yes
 
Yes
 
Yes
 
Yes
 
Yes
 
No
We are not aware of any regional variances, but are aware that regional standards are under development.
No
 
Yes
1. Requirement R1 states to “submit” the Real Power generating capability: however Requirement R2 appears to suggest that the data be submitted only when requested by the Resource Planner and/or Planning Coordinator. Therefore, we suggest you remove the words “and submit” from R1. Requirement R2 – the first bullet should be revised to indicate “desired condition” to which the data is to be adjusted. 2. “Summer period” and “summer season” appear to be used interchangeably in Attachment 1. The same comment applies for winter.
Individual
Jon Kapitz
Xcel Energy
Yes
We believe there is a reliability need for the Megawatt data collected per this standard and consequently this standard should not be retired.
Yes
 
Yes
While we agree that one hour of data is adequate to verify the capability, in our experience it takes at least 30 minutes for a steam turbine unit to stabilize if it has been operating at a lower load. We believe the criteria should take into consideration of an applicable "stabilization period" prior to data collection.
Yes
 
No
We are in agreement with the concept as long as the caveats that the major components and control systems are identical and that the verified capabilities are similar remain in the wording.
Yes
 
Yes
Some Regional Entities have developed their own requirements as directed under MOD-024-1. These would presumably take precedence over MOD-024-2. Some RTO’s (e.g. MISO) have their own requirements for capability verification.
No
 
Yes
With regard to Attachment 2, the only ambient condition that is required to be reported is ambient air temperature. This has a significant impact on combustion turbines, but little effect on steam turbines. Condenser cooling water temperature has much more impact on steam turbine capability and we feel this should be recorded for that type of prime mover. Also, we would like to request that a description of the process for performing ambient compensation be included either in Attachment 1 or in a separate Technical Guideline to improve the quality and consistency of the information that is reported.
Individual
Kenneth D. Brown
Public Service Electric and Gas Company
No
The standard should be retired. There are several other standards pursuant to which the GO and/or GOP provides real power capability to those parties needing that data. Also, the RTOs, ISOs, in their role as TOP, RC and BA receive actual data continuously via the EMS. Likewise, those entities performing the same functions in non-ISO areas also receive the data. The actual operating data collected through EMS systems is far superior in quality to that resultant from compliance with MOD-024, both presently and as proposed. Imposing duplicate burdens on generators with no commensurate benefit to reliability should be avoided. Hence, MOD-024 is not necessary.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
No
N/A as MOD-024 should be retired as demonstrated by PSE&G response to Question 1.
Individual
James H. Sorrels, Jr.
American Electric Power
No
 
Yes
 
Yes
 
No
AEP believes that it is important to have intermittent, variable, and limited energy units to be in compliance with this standard. Technical assumptions made for studies are important, but it is important to ensure that the stated capabilities for such units are verified.
Yes
 
Yes
 
No
There are no additional variations known beyond those variations already accommodated in the draft standard.
No
No known conflicts.
No
 
Individual
Marty Berland
Progress Energy
Yes
Yes - there is a reliability need. No, the standard should not be retired.
Yes
 
No
We agree with the approach as stated in Question 3 but have selected NO here because the proposed standard itself does not reflect the approach stated. For Attachment 1, Sections 1.1, 1.2, 2.1, and 2.2, these should be changed to say “for at least one continuous hour…”
No
While we have indicated that we disagree with the exemption, it may be more appropriate to address testing of “intermittent” resources separately due to their different use in planning and operational studies. However, we think the basis for exemption by the SDT is incorrect. The SDT has confused the issue of rating with how that rating is used in planning studies. There are two fundamental questions that must be answered for each resource in any planning study: (1) what is the resource capable of producing under some standard set of conditions, and (2) how much will it produce under the conditions assumed in a planning study. Historically, these two questions are merged for resources which are dispatchable and controllable to a sustained output level. In other words, if we test a conventional fossil or nuclear generator and determine it can produce X MW under the test conditions, we assume it can produce X MW under study conditions like peak demand, off-peak or shoulder load conditions. However, we might model the unit as producing zero or something less than its capability due to economic or some other dispatch consideration. We do not try and represent some average value of its production over time. When intermittent resources are considered, we still need to know how much a unit is capable of producing at its maximum output. We would not size the interconnection for “average” output. We need to know what it might produce under ideal conditions. Taken further, we know that at some point in its operation, the intermittent resource will produce at its tested value, and it will be up to the planner to determine if that condition needs to be studied. For example, 100 MW of nameplate generation may produce 30 MW on the average over a year’s time, but it might produce the full 100 MW at an off-peak hour, and that may need to be studied. How do we assure ourselves that the 100 MW of nameplate is actually capable of 100 MW? While intermittent resources may not make up a significant portion of supply in most regions at this time, future development may result in significant portions of supply being made up of these resources, and relying on design or nameplate values will be as inappropriate for these units as it is for existing generation. The standard should focus on determining the appropriate generator ratings to be supplied to the planning processes, not how they are ultimately used. As the standard itself states: 3. Purpose: To ensure that planning entities have accurate generator Real Power capability modeling data used in system planning studies
Yes
 
Yes
 
No
 
No
 
Yes
COMMENT 1-The first bullet item under R2 should be revised as follows: • the desired temperature to which the data is to be adjusted for conditions normally experienced for summer and winter periods. COMMENT 2- R3 should be revised as follows: "Each Generator Owner shall report to its Resource Planner and Planning Coordinator any change that is greater than 50 MW in the gross Real Power generating capability of any unit compared with the last verification submittal that is expected to last more than six months. The Generator Owner shall make such report within 15 calendar days of the determination that the change in capability is expected to last more than 6 months." COMMENT 3- For Attachment 1, Section 4.3, in “For each individual generating units…” change “units” to “unit”. COMMENT 4- Attachment 2, Requirement 3 provides for the RP and PC to provide the GO “the desired temperature to which the data is to be adjusted”. Attachment 2 provides a blank to record that value for adjustment in each of the Summer and Winter Verification Data sections stated as: “The recorded MW values were adjusted for the following average temperature conditions:” We suggest removing the word "average” which is inconsistent with R3. COMMENT 5- In Footnote 1, revise as follows for clarification: 1- If the winter verification is based on Summer data, provide only the date of the “summer” verification “used” not the start and end times. COMMENT 6- The standard does not address validation of initial Real Power Capability for new units.
Individual
Scott Berry
Indiana Municipal Power Agency
No
IMPA is anwering no to the question "Do you feel that there is a relaiblity need for this additional empirical data", and answering yes to the question "should this standard be retired". The reporting of megawatt data in other reliability standards and in market testing requirements for units is enough.
Yes
IMPA agrees that the standard should be consistent with the current Compliance Registry and supports how units are verified in the standard.
Yes
IMPA agrees with the one hour testing and the reasoning that the SDT used to decide on this time period.
No
If these units cannot sustain continuous operation, then they can report/record the highest hour or an average output for the hour.
Yes
 
Yes
IMPA agrees with this approach as long as it is for only receiving the verified information and not allowing these entities to specify any type of testing period or requirements outside of this standard.
No
 
Yes
This standard conflicts with the RFC approved standard, MOD-024-RFC-01. The NERC draft version of MOD-024 has the Generator Owner submitting reports to the proper entities. This conflicts with the RFC standard which has the Generator Operator submitting the reports to the proper entities. IMPA believes that NERC should resolve this issue by having the RFC standard agree with the NERC MOD-024 standard and the Functional Model. The SDT may not be able to resolve this issue, but it needs to be resolved or two different entities could be in non-compliance in the RFC region if a report is not submitted.
Yes
A clarification under number five, the effective date is needed. Under effective date, both sentences need to be clarified. Is the effective date the first day of the first calendar quarter after or part of the six months after applicable regulatory approval. For example, if regulatory approved is received on June 28, 2011 and then six months after is December 28, 2011, is the standard effective on January 1, 2012 (first day of the first calendar quarter after six months) or a date in the six months (before December 28, 2011).
Individual
Armin Klusman
CenterPoint Energy
 
No
CenterPoint Energy disagrees with having this Standard be applicable to all units connected to facilities 100 kV and above. CenterPoint Energy recommends it should only be applicable to units interconnected to Bulk Electric System facilities - not all facilities 100 kV and above are considered to be part of a Bulk Electric System.
 
No
CenterPoint Energy disagrees with exempting certain types of generation resources from Requirement 1 and Requirement 3; therefore, CenterPoint Energy recommends deleting 4.2.3 “Variable energy units such as wind generators, solar, and run of river hydro are exempt from the requirements of this Standard.” CenterPoint Energy agrees that oftentimes such generation resources are represented with “on average” or “discounted” values. However, all planning models do not use “on average” or “discounted” values as there are needs to study expected generation patterns. For example, wind generation typically peaks in the early morning hours in west Texas and should be modeled at a lower output in planning models which represent the peak load hour which occurs in the summer, typically around 5 PM. Transmission planners would need to ensure that there is adequate transmission when west Texas wind is operating at its peak output in the early morning hours. For this purpose, there is a need for a planning model with all wind generation operating at peak output. In addition, wind generation typically reaches a peak coincident with the peak load hour in the Gulf Coast area. So, this generation would be modeled at peak output in a planning model representing the peak load hour. In both of these cases, planning models need the net real power capability of wind units verified by actual unit testing.
 
 
 
 
 
Group
E.ON U.S.
Brent Ingebrigtson
Yes
obtaining the additional empirical data is helpful. The data required in Version 1 as established by the Regions gives a better description of what is happening with a generating unit during a test; this version only requires capability, auxiliary power usage, and temperatures—which does not give one a picture of what is occurring during a test and why the capabilities might have been the way they were.
Yes
 
No
One hour is too short. This period could allow a company to provide more of an "optimum" or "maximum" capability, rather than an average capability (e.g., during one hour soot blowers might not have to be run, etc.). The current 4-hour average test is more reasonable/reliable. Attachment 1 should be revised to specify a verification period of "at least 1 hour." The use of the term "normal operation" in Attachment 1 is not specific enough and is open to interpretation. Since generating capacity has market value, Gen Owners may desire to maximize the verified/reported capability of their units - even if such performance can only be attained for a single hour. This would not be consistent with the notion of dependable or continuous capacity which should be the basis used for reliability planning purposes.
Yes
E.ON U.S. believes that this is reasonable at the present time but with the proposed massive build-out of wind generation this may need to be re-visited in the future.
Yes
The language of 4.4 isn’t clear –E.ON U.S. suggests revising to “If 5 or more units are at a single site, verify….”. Does “approximately 20 percent” imply rounding to the closest whole number? If 2 identical units are at the same site – no annual test is required but both units need to be verified within a 5 year interval?
No
The fundamental concept is correct; but, rather than ambient temperature, seasonal back pressure is much more appropriate to use for corrective factors. (e.g. with temperatures – is it wet bulb/dry bulb; humidity or not; how clean are the condenser/cooling tower?) All of these factors are satisfied by correcting to back-pressure conditions).
No
Summer peaking regional requirements are different than winter peaking regional requirements
No
This information requires some duplicate reporting. For example, the Kentucky Public Service Commission requires resource adequacy planning and reporting of the same data.
Yes
The first bullet under R2 should be modified as follows: “the desired temperature and/or backpressure to which the data is to be adjusted.” Other criteria may also be required during the test. (e.g. MVARs, etc.) Clarify R3 language that 50MW is the change in unit rating – not any unit greater than 50MW. E.ON U.S. questions whether a 50MW threshold for capability change is less meaningful than using a percent of unit capacity threshold. Is the need to report such changes to NERC consistent with any Regional requirement? On Attachment 2, are data measuring points A,B,C and D to be reported as peak or average (over the verification period) values? MOD-024 and MOD-025 are linked and the STD has decided to revise each standard independently. This makes compliance difficult to maintain and test while the two linked standards are undergoing revision.
Group
Luminant
Rick Terrill
Yes
Luminant believes the verification of capability is needed to ensure unit capabilities utilized for resource planning, operating reserves and real time operations are accurate. “Paper Megawatts” can have a detrimental effect on grid reliability.
Yes
 
No
Luminant would prefer 30 minutes at full load, as this approach has been utilized effectively in ERCOT for several years.
Yes
 
Yes
 
No
Luminant believes the test results should be submitted within 30 days of completion of the annual verification. Luminant submits the following modification to Requirements R1 and R2 to address this issue. R1. Each Generator Owner shall verify the summer and winter Real Power generation capability for each of its units in accordance with MOD-024-02 Attachment 1, Verification of Sumer and Winter Generating Unit Capability,and record and submit the verification information via MOD-024-02 Attachment 2, One-line Diagram, Table and Summary for Verification Information Reporting (or similar diagram and form), to the Resoruce Planner and Planning Coordinator within 30 calendar days of the completion of the Real Power capability verification. R2. Each Resourc Planner and Planning Coordinator that seeks verified generating unit Real Power capability data shall provide each Generator Owner: - the desired temperature to which the data is to be adjusted - the calendar dates that encompass the summer period and winter period.
No
 
No
 
Yes
Upon approval of MOD-024, Verification of Real Power and the companion standard MOD-025, Verification of Reactive Power, the applicability to Generator Owners and/or Generator Operators needs to be removed from FAC-008 and FAC-009. With actual verification of Real and Reactive Power, the FAC-008 and FAC-009 requirements become redundant for generators. Attachment 1 verbage needs to be consistent between the words "period" and "season". They are currently used interchangeably. Attachment 1, section 4.5, needs to be expanded so that when a lessor utilized unit is started up, it does not necessarily have to immediately run a maximum capacity test. The unit could have been brought online for capacity and the BA may not allow it to run at maximum output. Emergency situations may preclude running the test. This type of unit should be tested based on a schedule coordinated with the BA. All references to Attachment 2 should also include the "or similar diagram and form" language.
Group
FirstEnergy
Sam Ciccone
Yes
We believe that there is a need for this standard. The argument that "megawatt data is currently collected and reported under several other standards as well as many market rules" is not well founded. All Standard Drafting Teams assigned to revise existing standards that include some form of generator verification are proposing to retire their respective requirements because they intended that MOD-024-2 include these requirements. A specific example is the RTO SDT (Project 2007-03) which has proposed to remove requirements dealing with Real Power generator verification in TOP-002 (R13, R14, and R15) because they believe these requirements should be addressed by this GV SDT. The second part of the argument that these verifications are required by "many market rules" is also problematic because not every entity across the continent participates in a market and market rules are not enforceable Reliability Standard requirements.
Yes
We agree with the proposed thresholds because they are consistent with the NERC compliance registry.
No
We do not agree that one hour is sufficient for Fossil and Nuclear units (per Attachment 1 Sec. 1.1 and 2.1). The SDT should consider at least 4 hours or, at a minimum, require that the unit demonstrates it has reached equilibrium.
No
We believe that capabilities of intermittent units such as wind and solar can be adequately verified by testing, tracking of operational data, or calculations if testing or operational data is not possible or incomplete. Furthermore, it has been forecasted that utilization of these types of units will expand and most states will have Renewable Energy requirements of 20-25% of generation in the future. This would represent a large percentage of generating unit Real Power Capability not being verified. Excluding these units from verifying their capability will not improve reliability but will reduce it. The goal of this standard is to determine the capabilities of all generating units. The Generator Owner of intermittent units should provide their maximum capability through verification, test or calculation along with capacity factor data. This information could then be used by the Transmission Planner to plan for a reliable system based on the Transmission Planner's engineering judgment and considering other factors as the units Interconnection Agreement contractual arrangements (i.e. energy only unity, participates in a capacity market, etc.) Therefore, we suggest that this SDT incorporate requirements to verify intermittent, variable, and limited energy units. We also suggest the SDT should consider language similar to RFC standard MOD-024-RFC-01 Requirement R2.2.3 to accomplish verification of intermittent, variable, and limited energy unit capabilities.
No
Item 4.4 of Attachment 1 should begin with the statement "For units that require annual verification ..." This would better clarify that the identical unit exemption is aimed at units that qualify under item 4.1 and 4.2. We agree that not all identical units should be required to be verified annually . However, the proposal should include a statement by the Generator Owner annually confirming which units that are deemed identical when providing annual verification updates for one of the identical units. Also, the wording proposed in 4.4, "approximately 20%", is ambiguous and up for interpretation in an audit. We suggest 4.4.1 be removed. We suggest replacing items 4.4.1 and 4.4.2 with the following: "The Generator Owner of identical generator units shall verify unit capability of at least one unit annually, such that all units are verified over a five year period."
No
It is unclear if R2 is intended to be a one-time submission of temperature adjustment information and schedule by the RP and PC or if this is something that is required each and every time the RP and PC would "seek" the data. Requirement R2 brings into question if the GO is simply holding verification data until requested to provide by an entity who "seeks" the data. Also, as written the RP and PC could provide conflicting temperature data and schedule expectations that would needlessly overburden the GO. As described in our item 4 in our Q9 response, FE suggests that R1 is ambiguous in regards to who the GO is to provide data to on an annual or every 5 year basis. FE suggests the team modify requirement R1 or Attachment 2 to clarify the intended recipients for either annual or 5-year generation verification data. In our opinion the GO should automatically provide the data to the intended recipients. Additionally, we propose the team to set a firm expectation that summer and winter verifications would be provide to the appropriate entities within 90 days of the conclusion of the applicable summer or winter peak period. In regards to temperature adjustment, the GO should simply provide any applicable temperature adjustment data used for the data provided and respond to inquiries from data recipients as needed and upon request. If the team elects to accept FE's proposed changes it is our opinion that R2 can be removed from the standard.
Yes
Our preference is that RFC retire their regional standard for Real Power verification (MOD-024-RFC-01) upon completion of this continent-wide standard. However, if RFC believes their standard is still needed after this NERC standard is completed, then there may be potential regional variances required as follows: 1. The threshold for periodicity of verification for RFC is 85 MVA; NERC is proposing 75 MVA. The gap between 75 and 85 MVA would need to be addressed. 2. RFC explicitly allows for testing, including commissioning tests for new units, in lieu of operational tracking. 3. The applicability for RFC is the Generator Operator while NERC proposes applicability to the Generator Owner. 4. RFC explicitly allows for exemptions and delays in verifications when system conditions or generator issues prevent verification.
No
 
Yes
FirstEnergy offers the following additional suggestions and comments: 1. We question the applicability to the Generator Owner (GO) instead of the Generator Operator (GOP). We believe the standard should apply to the GOP because the operation of the unit (operational verification and testing) impacts reliability more directly than ownership. In addition multiple ownership confuses responsibility and compliance. Only one GOP will operate a unit and perform the required verification, testing and data reporting. 2. The proposed requirements in this standard do not specifically allow for testing in lieu of operational tracking. We suggest the team add testing as an explicit alternative. 3. Several terms used in this standard should be defined to alleviate any varying interpretations; we suggest the following definitions: a. Summer/Winter Peak Period – For the summer season, the Peak Period extends from the first day of June to the last day of August. For the winter peak season, the Peak Period extends from the first day of December to the last day of February. b. Peak Period Hours – The four summer hours ending at 3 PM, 4 PM, 5 PM and 6 PM. The four winter hours ending 8 AM, 9 AM, 7 PM and 8 PM. c. Capacity Factor (expressed as a percent) - Is the net actual energy generation (MW-hours) divided by the product of the period (hours) and the net max capacity rating (MW) 4. R1 - It is not clear to whom the GO must submit this information. We suggest that the SDT add language in R1 that states the GO be required to submit verification information "as requested, in accordance with a predetermined schedule and format specified by a requesting Resource Planner, Planning Coordinator, or Transmission Planner". 5. R2 - First Bullet – The phrase "The desired temperature" is too broad; we suggest a change to "The desired ambient temperature". 6. R2 – If R2 is retained (see proposal to remove in our response to Q6), FE suggests the phrase "that seeks" be replaced with "having a reliability need for" since as written could have the unintended meaning that any RP or PC could request information of a particular generator unit owner. 7. R3 - Regarding the 50MW level, it should be clear that this would be for situations where the MW level decreased by more than 50 MW. Significant increases in MW levels could violate interconnection agreements and be used by an entity to sidestep the required studies for facility uprates 8. Att. 2 - Diagram - The transformer downstream from the GSU should be the Start-Up Transformer, not Aux Transformer as currently shown. 9. In the background information provided by the SDT on pg.2 it states "... the SDT has taken the approach that the Transmission Planner needs to communicate the conditions under which the Generator Owner is to provide verified values..". It is not clear how this standard requires the TP to communicate the conditions. Was it the SDT’s intent to say the PC or RP needs to communicate the conditions as stated in R2?
Individual
Greg Rowland
Duke Energy
Yes
While data is reported under MOD-010, MOD-024 provides for validation of the data.
Yes
 
No
Need to reword Attachment 1, section 2.1 to add clarity. Suggested rewording: For nuclear and fossil units, record data for at least one continuous hour of normal operation during the winter period. More time may be required or used to achieve stable conditions.
Yes
 
Yes
 
Yes
 
No
 
No
 
Yes
Industry guidance is needed on how to adjust recorded test data in Requirement R2 and Section 3.4.5 on Attachment 1. It’s unclear what is being sought by “adjusting” data to a desired temperature. Ambient air temperature may not impact output nearly as much as coolant temperature, when the machine is not air cooled. Also, Section 3.4.5 should be expanded to allow for adjusting of data for factors other than ambient air temperature (e.g. steam leaks, condenser cooling water temperature, out of service reheaters, condenser fouling, turbine blade wear….). Planners need to model to the unit’s expected sustained capability. If tests are conducted under degraded plant or equipment conditions the test results need to be adjusted. Otherwise planners could plan the system for less than the full capability of the unit, which would yield a non-conservative result. Guidance is needed on how to report (i.e. actual data, adjusted data and a prognosis for sustained capability that may be achieved). The test should represent the actual condition of the equipment. If it is degraded then the unit would have less capability. However capability could be restored during a repair or outage, and demonstrated with another test.
Group
Electric Power Supply Association (EPSA)
Jack Cashin
 
 
 
 
 
 
Yes
See answer to question 9.
 
Yes
EPSA agrees with many of the SDT’s findings in its review of current verification and data reporting practices. Entities that use generator real power capability data already receive and depend on the necessary data. The SDT’s review confirms that capability data is often already being provided due to existing requirements that should reduce the frequency for real power capability testing set forth in MOD-024. While planners have asserted the need for the data to improve modeling accuracy – the SDT review of different planning models finds that they have inconsistent needs and don’t facilitate a standard that supports reliability. EPSA respectfully requests that the SDT recognize the following objectives in crafting a standard that is responsive to FERC’s directives in Order No. 693 (see 1310): 1. MOD-24 should not preempt or duplicate the real power verification procedures that already exist in the organized markets. 2. the frequency of real power verification in the organized market regions is driven by the annual capacity markets. System planning is a longer-term endeavor and as such real power verification for system planning purposes does not require the same annual frequency or level of precision. Thus, annual verification should not be required for any units, but rather all units should verify their real power capability on a longer cycle – i.e., the five (5) year cycle currently proposed for certain smaller and low capacity factor units. A longer verification cycle reduces the need for unnecessary fuel burn and the uniformity results in better clarity as well as ease of implementation for Generator Operators.(note below) The SDT in its review also found that enhanced communication between entities will best facilitate the exchange of generator capability data. Further, it is worth noting that the Transmission Operator (TOP), Reliability Coordinator (RC), Balancing Authority (BA) and Regional Transmission Organization (RTO) / Independent System Operator (ISO) have access to a unit’s real time output through their Energy Management System (EMS). The EMS provides updated information on a real-time basis, making further testing and reporting under MOD-24 duplicative and unnecessary. In addition, the GOP is required by other reliability standards to report unit de-rates to the TOP, RC, BA or ISO immediately after they occur, again making more frequent testing and data reporting under MOD-24 unnecessary. In addition, several existing Standards require the GOP to provide data related to generating unit capability status. Note: The capacity factor limitation simply may not be implementable if a unit has a capacity factor that fluctuates from year (i.e., if a 25 MVA unit has a CF less than 5% in years 1&2, but then exceeds 5% in year 3, then it needed to be tested annually and is non-compliant).
Individual
Jason Shaver
American Transmission Company
Yes
The requirements of this standard will provide empirical data that will improve system reliability.
Yes
The generating unit qualifications are consistent with the presently Compliance Registry criteria.
Yes
 
Yes
 
Yes
 
Yes
 
No
 
No
 
Yes
For R1, R2, & R3, we propose a Violation Risk Factor of “Lower” and a Time Horizon of “Operations Planning, Long-Term Planning”. We propose “Lower” for the VRF because more accurate real power capability values will be assured by this requirement, but reasonably accurate values are likely without this requirement. We propose “Operations Planning, Long-Term Planning” for the TH because RCs and TOPs will use this data in their operations planning studies and PCs and TPs will use this data in their transmission planning studies. For R2, replace “desired temperature to which the data” with “desired ambient coolant temperature to which the summer and winter data” for added clarity. In Attachment 1, 3.2; replace “ambient air temperature” with “ambient coolant (air, water, etc.) temperature” because the capability of different types of generators is affected by the temperature of different cooling medium. In addition, consideration may need to be given to the average pressure level of generating units that use hydrogen for equipment cooling. Requirement 1: ATC believes that some additional clarity is needed as to those entities that will receive the information. Suggestion: “…submit to the Resource Planner and/or Planning Coordinator the information view MOD-024-2 Attachment 2…” General Comment: It should be made clear that a GO validating and reporting a change in a unit’s gross Real Power capability, in particular an increase in output, to comply with this standard, does not enable or give a GO the right to inject said incremental output onto the transmission system. Any MW increase (regardless of duration or ambient conditions) must be formally considered via separate mechanisms for study and verification of the BES’s ability to reliably support any such increase beyond that previously approved and included in a generation-transmission interconnection agreement.
Group
SERC Generation Subcommittee (GS)
Joe Spencer (SERC staff) / Jose Medina (NextEra-GS Chair)
The SERC Generation Subcommittee (GS) could not answer this definitively yes or no. The GS believes that reporting on MOD-024 is duplicative with other standards and may be retired. While this data is important, it is covered under: FAC-008/009, TOP-002, MOD-010/011, etc.
Yes
Stated or assigned values should be sufficient for modeling purposes for units having nameplate ratings < 75 MVA. This should apply to many regions. If the BA or TOP needs validated data on a smaller unit or group of units then these requirements can be made known to the GOP per TOP-002-2 R13.
No
We agree with the approach as stated in the questions but have selected NO here because the standard does not reflect the approach stated. For Attachment 1, Sections 1.1, 1.2, 2.1, and 2.2, these should be changed to say “for at least one continuous hour…” to assure stable conditions.
No
While intermittent resources may not make up a significant portion of supply in most regions at this time, future development may result in significant portions of supply being made up of these resources, and relying only on design or nameplate values, for the purposes of transmission planning, will be as inappropriate for these units as it is for existing generation. The standard should focus on determining the appropriate generator ratings to be supplied to the planning processes, not how they are ultimately used.
Yes
 
Yes
 
Yes
The SERC Region is a summer peaking load region. Since unit capability (excluding hydro) is either independent of seasonal differences or will exhibit increased capacity for non summer periods, winter validation is not necessary. This would apply to summer peaking entities or regions.
No
 
Yes
Assuming this standard is not retired, the first bullet item under R2 should be deleted. If it is not, it should be revised as follows: • The data is to be adjusted for conditions normally experienced for summer and winter peak periods, as applicable. Industry guidance is needed on how to adjust recorded test data in Requirement R2 and Section 3.4.5 on Attachment 1. Section 3.4.5 should be expanded to allow for adjusting of data for factors other than ambient air temperature. It’s unclear what is being sought by “adjusting” data to a desired temperature. For steam turbines, ambient air temperature may not impact output nearly as much as coolant temperature, when the machine is not air cooled.
Individual
Kasia Mihalchuk
Manitoba Hydro
Yes
If FAC-008 and FAC-009 are based upon design data and Engineering Analysis, a standard is required to complete field verification of the unit real power capability. There should be clear distinctions between these standards.
Yes
Agree to include units connected to 100 KV and above.
Yes
One hour testing is sufficient, and does not expose the unit to unnecessary stress or take excessive time to complete.
Yes
Wind generation and run of the river hydro units should be exempted.
Yes
Can the verification frequency of units be lowered to less than 20% for indentical units. Can it be 10% of identical uinits, as deterioration of unit real capacity is a very slow process unless a failure occurs (and failures are picked up by other standards)
Yes
State clearly who provides a schedule to whom. Is it Planning coordinator will provide a schedule to Resource planner for verified capability information of units? We would prefer that the requirement be to complete the testing at the required frequency, and to delete the requirement for creation and submission of a plan.
Yes
Regions with considerable hydraulic generation require verification of unit output that will be modified by calculation for rated head output for comparison. Exempting run of river plants removes this need for exemption.
No
MAPP was requiring unit capability tests in MRO region prior to MOD-024 NERC standard. The overlap with FAC-008 and FAC-009 should be carefully examined to avoid confusion.
Yes
The requirement R1 should be rewritten to include derivation of Summer and Winter ratings for Thermal units, and measured capacity corrected to design net head for Hydraulic units. R3 should be clarified to ensure it is only changes greater than 50MW that must be reported, not "any change for units that are greater than 50MW".
Individual
James Sharpe
South Carolina Electric and Gas
No
This standard appears to be redundant with TOP-002 R13. Also, Generator ratings are established in FAC-008. If a verification run by MOD-024-2 contradicts a rating established in FAC-008, which rating should an entity use? If the rating established by verification were used, would this not alter an entity's facility rating methodology?
Yes
 
Yes
 
Yes
 
No
Even though units may be identical in nature, variables such as actual in service time could lead to deratings and make two identical units unique. If the intent of the standard is to ensure unit generating capabilities are correct for studies, then shouldn't verification be made for all units?
Yes
 
No
 
No
 
No
 
Individual
Richard Kafka
Pepco Holdings, Inc
Yes
Planning Coordinators and Planning Authorities need the data
No
There is no need to define what already exists in BES definitions and in the compliance registry rules.
No
A Planning Coordinator should be afforded the right to request periods other than one continuous hour as needed for ad hoc evaluations e.g. for Ancillary Service evaluations over a 15 minute period or for special case studies e.g. fuel disruption analysis. The default period may be agreed to as one continuous hour but that should not be the mandated period.
No
Providing the Planning Coordinator with the flexibility for designing tests “needed” for verification provides the opportunity to handle all units the same way (i.e. how the PC asked).
No
Identically designed units will not necessarily perform the same.
Yes
 
No
 
Yes
As noted in Question 1, this data is already being collected under other standards and in various organized markets. Coordination will be required to avoid conflicts
No
 
Individual
Roger Champagne
Hydro-Québec TransÉnergie (HQT)
No
The SDT is asking two question at the same time, with possible contradicting answer. There is reliability need to collect this data. NERC staff should coordinate and ensure that the collection of this data is incorporated in existing standards. If it is, the Standard (MOD-024) should be retired. If it is not done in other Standards this project should be pursued. Even if the collection of this data is already addressed through tariffs, Market Rules, and Interconnection Agreements, in what way would the compliance and sanction be addressed? If there is a Standard that make it obligatory to respect tariffs, Market Rules, and Interconnection Agreements, this project could be retired.
No
See answer to Q1. HQT believes that there are some plants/facilities that are not connected to 100 kV but are material to reliability. These facilities should be subject to data collection, be it in this project Standard or in other existing Standards. The importance of generation to reliability is more related to its power than to its connecting voltage.
Yes
See answer to Q1.
Yes
 
Yes
 
Yes
 
No
 
No
 
No
 
Individual
Michael Ayotte
ITC Holdings
No
 
Yes
Comments: The 100 kV reporting for this requirement is consistent with other NERC reporting requirements.
Yes
None
No
Comments: A one hour typical rating/capability should be provided by the generators for run of river hydros.
Yes
None
Yes
None
No
None
No
None
No
None
Individual
Joylyn Faust
Consumers Energy
Yes
 
No
The MVA ratings should be based on Net Demonstrated Capabilities (NDC) rather than nameplate. There is no correlation between reliability and nameplate ratings.
Yes
 
Yes
 
 
No
Testing is arranged around scheduled unit outages. Unit ratings can be normalized to specific temperatures/conditions so results can be sent at any time.
No
 
No
 
 
Individual
Michael R. Lombardi
Northeast Utilities
Yes
Standard should be retired. The collection of this data is already addressed through tariffs, Market Rules, and Interconnection Agreements. The Standard should be retired. Although data can be reliability related sufficient data is collected as dictated by other standards. NERC staff should coordinate and ensure that the collection of this data is incorporated in existing standards projects.
 
 
 
 
 
No
 
 
 
Individual
Fred Meyer
The Empire District Electric Company
No
This standard should be retired
No
I believe it is redundant to require both summer and winter ratings. Your summer raitings will be your "worst case" for understanding the maximum equipment output. Requireing winter ratings will only waste money and equipment wear.
No
The nameplate reating should be sufficient for determining output. In this day of being environmentally friendly, why would we as a country want to subject each generator to these types of tests using precious fuel and expelling pollutants when nameplate ratings have been sufficient for years?
Yes
 
No
Nameplate data should be sufficient and verification is an overburdon to industry.
Yes
 
No
 
Yes
I am aware the state of Kansas has a current law that forbids units that start on Diesel fuel. This could cause some issues with smaller generators in the state of Kansas.
No
 
Group
Southern Company Transmission/Generation
Stephen Mizelle
No
We feel this standard is unnecessary since real power verification can and should be handled by generation and transmission agreements. Most traditional utilities already have a process in place to validate and/or certify unit capabilities. In the case of an IPP, this requirement can be addressed in the Transmission Interface documents. If this standard moves forward, then TOP-002-2 R13 must be deleted or at a minimum, revised to indicate that it addresses short term equipment issues in the operations horizon.
No
We recommend limiting the unit size requiring real power capability validation in paragraph 4.2 to the following: “Generating Facilities connected at the point of interconnection at 100kV or above, containing an individual generating unit greater than or equal to 75MVA (individual gross nameplate rating)”, for the following reasons: • Including only units > 75MVA will represent the vast majority of the total (cumulative) connected MW sources in the country • This cumulative MW class represents the units that are capable of having the largest impact to the stability and reliability of the BES • Excluding the smaller units will avoid unnecessary waste in time and money on the smaller units which individually do not appreciably affect the stability and reliability of the BES. • Stated or assigned values should be sufficient for modeling purposes for units having nameplate ratings < 75 MVA. If the BA or TOP needs validated data on a smaller unit or group of units then these requirements can be made known to the GOP per TOP-002-2 R13.
Yes
 
No
We recommend all hydro units be excluded since capability is dependent on available water levels. GOP's with appreciable hydro capacity have established procedures or processes to predict the capability of these units.
Yes
 
Yes
We agree with this requirement.
Yes
The SERC Region is a summer peaking load region. Since unit capability (excluding hydro) is either independent of seasonal differences or will exhibit increased capacity for non summer periods, winter validation is not necessary.
No
 
Yes
1. The subject standard should not require annual staged full load capability demonstration for verifying MW capability. There are many factors such as system load, economic dispatch, etc that determine if a unit is expected to be called to full load. This is especially true for the smaller (<75 MVA) units. 2. The requirement for ambient temperature monitoring during the verification period is unreasonable. The ambient temperature is not needed for unit operation, and may not be tracked, and in some cases may not be reliable. In these cases, either inaccurate data would be collected or added investment would be required. (The official ratings mentioned above are based on performance data taken at or adjusted to specified ambient conditions.) 3. Allowances for different reporting format from that in attachment 2 should be permitted. We prefer a tabular reporting method due to the number of units in our fleet. An allowance for tabular reporting of the same information as indicated in attachment 2 should be permitted. 4. In Paragraph 3 of Page 5, we recommend replacing “Number” with “Paragraph”. 5. The following comments relate to Attachment 2: a. On Page 7 we recommend the following: • moving the “Date of Report” and the associated blank line to the same line as “Unit No”. • changing “Auxiliary Transformer(s)” below point A to “Unit Auxiliary Transformer(s)” • changing “Auxiliary Transformer(s)” below point C to “Station Auxiliary Transformer(s)” • splitting the bus just below the “Point of Interconnection” and eliminating the single line diagram associated with point D. • adjusting single line diagram to fit on the page (displayed on a PC monitor) • change “MW (tertiary load, if any)”, to “MW (GSU tertiary load, if any)” at the bottom of the page b. On Page 8, we recommend the following: • delete the point D measurement line from page 8 c. On Page 9 (Summer Verification Data), we recommend the following: • Insert a blank line between the “Date of Verification…” line and the “Verification End Time…” line.- in other words, make the summer and winter verification forms identical with respect to the Date of Verification, Verification Start Time, Verification End Time d. On Page 9 & 10 (Summer and Winter Verification Data), we recommend the following: • specify if the Aux Power (MW*) column in the table is “the sum of the auxiliary loads shown on page 7” 6. R2 is not a requirement as currently written. It is a choice that the RP or PC makes. If he seeks verfied data, then he must provide certain things to the GO. If he chooses to not seek verified data, then he is not required to do anything. This means that M2 is wrong. The RP and PC should not be required to have evidence if they chose not to seek the data. 7. R1 requires the GO to submit information but it does not indicate to whom the data should be submitted. 8. R3: The threshhold for reporting a change in MW output is too high. A change of 10 to 50 MW in a generator's output could have an impact to system stability. The threshhold should be 10 MW. 9. Paragraph 2.4 in Att 1: The first word grouping is not a sentence and reads awkwardly. It is suggested that the words "an acceptable value can be obtained" be place in front of the words "by making a temperature". 10. Paragraph 3.4.2 in Att 1: Replace the word "since" with "if" for better clarity. 11. Paragraph 3.4.4 in Att 1: Move the words "in Attachment 2" to the position just after the word "flows". This will make it clear that the sentence refers to flows in Attachments 2 rather than units in Attachment 2.
Individual
Laura Zotter
ERCOT ISO
Yes
ERCOT ISO believes there is a need for this data. The verification methodologies, including the scheduling and timing of verification testing, should be left to the discretion of the relevant NERC functional entities – e.g. the Planning Coordinator / Transmission Planner.
No
ERCOT ISO disagrees with this aspect of the proposal. Although, as a general matter, the relevant set of supply resources for reliability will be interconnected at 100 kV or greater, that is not an absolute rule. In fact, in the ERCOT Region there is a good amount of generation connected at 69 kV. The SDT should not preclude application of the proposed Standard to supply resources connected to facilities below 100 kV. 100 kV can be the default, but the requirement should provide for adequate flexibility to encompass other supply resources the methodology established by the relevant NERC functional entity includes such resources. Furthermore, this is consistent with the NERC Registry methodology, which accommodates facilities below 100 kV where they are necessary for/affect reliability of the Bulk Electric System.
No
ERCOT ISO disagrees with this aspect of the proposal. The methodology for verification should be left to the relevant NERC functional entities. As noted by the SDT, the Transmission Planner needs to communicate the conditions under which the resource is required to verify its real-power capability. This discretion afforded the TP should apply to all aspects of the verification, including the time period the unit must run. At a minimum, the proposed one-hour time period should be a default and the requirement should provide for alternative time periods to accommodate regional differences and different testing purposes – e.g. for ancillary services.
No
ERCOT ISO disagrees with this aspect of the proposal because the performance/capability of all resources, including variable output resources, effects system planning and operations. Accordingly, contrary to the position of the SDT, the data from variable energy resources (e.g. intermittent renewable) is also needed for reliability. Although these resources are subject to the variability in terms of their fuel source (e.g. wind), there are methods of estimating the capacity and energy from these resources. These estimates provide value for the purposes of this standard. Variable energy resources should not be exempt from this requirement. The Standard should include these resources, provided that they are subject to rules that reflect the variability of their production. The verification methodologies established by the respective NERC functional entities can accommodate variable resources in a manner that is consistent with the practices within their respective regions.
No
ERCOT disagrees with this aspect of the proposal. The assumption that all units of similar type at a plant are going to perform identically is not valid in all situations. Accordingly, to ensure any potential variances between similar units at the same site are accurately captured all such units should be required to provide verification annually.
Yes
ERCOT ISO supports this aspect of the proposal. The verification methodology and timing should be left to the discretion of the relevant NERC functional entities. As noted by the SDT, the needs for different Resource Planners and Planning Coordinators may vary. The Standard should enable the relevant entities to respect those needs, including the timing of the verification tests. By simply stating these entities should provide a schedule, the proposal provides adequate flexibility to respect regional differences. To accommodate the potential need for ad hoc testing, the requirement should provide for testing pursuant to the contemplated schedules “or as requested by the RP or PC”.
No
As discussed above, ERCOT ISO believes that there may be regional differences in the planning and operational studies where this information provides value. However, if the Standard is drafted to prescribe the reliability “end” result or obligation, and it provides for adequate flexibility with respect to how the means implemented by the relevant entities to comply with the obligation, there should not be a need for regional differences. Revising the Standard in accordance with this general principle and the specific comments provided herein should affect this result and obviate, or at least mitigate to a great extent, the need for regional variances.
See response to Question 7 – if the Standard provides adequate flexibility with respect to the means for complying with the reliability end prescribed by the requirements, this should mitigate any potential conflict.
Yes
ERCOT ISO believes R1 should clearly state to whom the Generator Owner of the Attachment 1 and Attachment 2 data should be submitted.
Group
PacifiCorp
Sandra Shaffer
No
: Information required under the proposed standard is currently submitted with FERC Form 1 and for FAC-008 compliance. This standard is redundant and should be retired.
Yes
 
No
: Sufficient detail on the data requirements during the one hour sampling period required under the proposed standard has not been provided. Please provide some direction on the required sampling rate and acceptable methods for data collection. It is unreasonable to require that a maximum boiler capacity test be performed twice a year to validate the unit real power capability. Biannual capture of historical data would be the preferred method of unit capability validation. Water resource impacts on hydroelectric facility capability have not been addressed sufficiently by the proposed standard. Please provide clarification on expectations for data collection at hydro facilities when water resources do not support operation at unit capability.
Yes
 
No
Current policies within the WECC require a testing interval of five years. This interval has been sufficient for stability studies to date. We suggest incorporation of a five year interval for generator real power capability validation in the proposed standard.
No
: Scheduling of generator capability verification should be set by the generator owner and generator operator within the five year cycle suggested in the Item 5 comments.
No
 
Yes
: Again, water resource impacts on hydroelectric facility capability have not been addressed sufficiently by the proposed standard and may result in conflict with other regulatory standards. Please provide clarification on expectations for data collection at hydro facilities when water resources do not support operation at unit capability.
Yes
: Suggest language in Section 2.2 to read “the resource planner will assess the stated winter generating capability based on a test hour of generation corrected for actual vs forecasted water elevations and flows.”
Group
Florida Municipal Power Agency and Some Members
Frank Gaffney
Yes
There are two potential reasons for the need to test generator capability related to the standards: 1) MOD-010-0 for accuracy of modeling purposes; and 2) for a potential standard on resource adequacy in the planning horizon (Project 2009-05?).
Yes
There is no need to expand the scope of the standard beyond the registration criteria. As the SDT has pointed out, only about 4% of the power system capacity is connected below 100 kV. Most of these generators are modeled, and many are already tested beyond the scope of the standard. So, causing regulation of generator verification to these generators may only improve accuracy for a small portion of the 4%. Such gain in accuracy at < 100 kV is easily overwhelmed by the inaccuracy of load forecasts, and by the variation of generator output with ambient conditions (e.g., temperature, humidity, barometric pressure, etc.) outside of forecasted ambient conditions. So, such effort is wasted because any supposed gain in accuracy by going below 100 kV is illusory and lost as compared to other forecast inaccuracies outside the control of anyone (e.g., the weather). If anything, the level of verification required in the standards could be reduced for smaller units (e.g., less frequent), even more so than as described in the standard. However, this would create a complex “tiered” standard difficult to understand and monitor. Hence, we congratulate the SDT on developing a balanced perspective that truly focuses on what is important to maintain the reliability of the BES.
Yes
 
Yes
 
No
Degradation of capacity depends on more factors than design parameters, such as hours of run-time, time from last major maintenance, etc.
Yes
 
No
 
No
 
 
Group
SERC Planning Standards Subcommittee
Philip R. Kleckley
Yes
There is a reliability need to verify real power capability for larger units on the system as discussed in our response to Question 2 below.
No
In general there is no reliability need to verify MW values for small units because they don't significantly affect the reliability of the system. The criteria should be to verify individual units which are 75 MVA or larger or aggregates of units which are 75 MVA or larger. Also provision could be made for the TP or PC to request verification of units which are smaller than 75 MVA for the rare case in which they do impact the reliability of the system.
Yes
 
Yes
 
Yes
 
Yes
 
No
 
No
 
Yes
R2 is not a requirement as currently written. It is a choice that the RP or PC makes. If he seeks verfied data, then he must provide certain things to the GO. If he chooses to not seek verified data, then he is not required to do anything. This means that M2 is wrong. The RP and PC should not be required to have evidence if they chose not to seek the data. This situation can be fixed by revising R2 to read: "Each Resource Planner and Planning Coordinator shall request verified generating unit Real Power capability data and shall provide each Generator Owner…" R1 requires the GO to submit information but it does not indicate to whom the data should be submitted. We recommend that R1 be changed to read: "Each Generator Owner shall verify the summer and winter Real Power generating capability for each of its units in accordance with MOD-024-2 Attachment 1 - Verification of Summer and Winter Generating Unit Capability and record and submit the information to its Resource Planner and Planning Coordinator via MOD-024-2 Attachment 2 - One-line Diagram, Table and Summary for Verification Information Reporting." R3: The threshhold for reporting a change in MW output is too high. A change of 10 to 50 MW in a generator's output could have an impact to system stability. The threshhold should be a 10 MW change or greater. Paragraph 2.4 in Att 1: The first word grouping is not a sentence and reads awkwardly. It is suggested that the words "an acceptable value can be obtained" be place in front of the words "by making a temperature". Paragraph 3.4.2 in Att 1: Replace the word "since" with "if" for better clarity. Paragraph 3.4.4 in Att 1: Move the words "in Attachment 2" to the position just after the word "flows". This will make it clear that the sentence refers to flows in Attachments 2 rather than units in Attachment 2. The comments expressed herein represent a consensus of the views of the above named members of the SERC Planning Standards Subcommittee only and should not be construed as the position of SERC Reliability Corporation, its board or its officers.
Individual
Catherine Koch
Puget Sound Energy
Yes
Note: The way the question is worded with two opposite ideas makes it difficult to determine which box to check. Puget Sound Energy feels that this standard should be retired. This standard duplicates information required by other standards, including MOD-010, MOD-012, TOP-002 (R13), as well as FAC-009. Our Transmission Planners already request temperature related Real Power information for generating units through these other standards. Unit derates (proposed R3) are covered under TOP-002 R14, TOP-003, and TOP-006 R1.1. These other standards allow the Transmission Planners to customize their verification needs from the GO/GOP and not have a one-size fits all solution imposed on them as prescribed in this proposed standard.
Yes
Puget Sound Energy agrees with being consistent with the Compliance Registry. It seems that the compliance registry criteria would determine whether an entity has to comply with any of the NERC standards including this one and then the current BES definition would establish what facilities are applicable. The need to describe the Faclities under section 4.2 is not clear. We assume that any approved regional definition of the BES would dictate applicability ultimately. Regarding the verification requiremetns as proposed, it is unclear why annual verification (for most units) is necessary as much of the data will not change over an annual timeframe and most change that may occur would likely not cause a reliablity impact as it relates to the study work the Planning Coordinator or Resource Planner uses this information for. We would request that the testing be done on a 5 year cycle which follows other practices for providing data (i.e., WECC has been using a 5 year cycle for testing since 1997, and the results have proven to be entirely adequate).
Yes
 
Yes
 
Yes
However, we encourage this approach to test over a 5 year period for more that just identical units as discussed in our response to question 1. A 5 year cycle for testing is adequate.
No
While R2 allows flexibility in determining when the data is submitted, the Resource Planner/Planning Coordinator may not need this information each year. If that is the case, this annual requirement imposes an unnecessary burden on Planners and Generators to provide this information more frequently than necessary.
Yes
The WECC may want to continue using a 5 year cycle for testing. From the WECC experience testing annually for most units would be unnecessarily frequent.
No
 
No
 
Individual
James Manning, Bob Beadle, Dave Sofra
North Carolina Electric Membership Corporation
Yes
While we agree that there is a reliability need to verify real power capability for larger units on the system, we are of the opinion that the SDT should direct the verification at units that significantly affect the reliability of the BES.
No
In general there is no reliability need to verify MW values for small units because they don't significantly affect the reliability of the system. The criteria should be to verify individual units which are at least 100 MVA or larger or aggregates of units which are 100 MVA or larger and units that are connected to the transmission at 200 kV and above unless the generating units have been deemed by the Planning Coordinator as critical to the reliability of the BES. This is similar to what has been proposed in the PRC-023 standard under development. All other generators that do not meet this critieria should be exempt.
Yes
 
No
Peaking units that have a limited cumulative energy per year (i.e. low capacity factor below 5%) should be provided the same treatment. The SDT should consider providing the PC with the flexibility for designing tests “needed” for verification such that all units are either handled in the same way.
No
The SDT should not be concerned with administrative details.
No
The concept that regular period-specific verification is not necessary. If the SDT is insistent on such a schedule established by the RP/PC, we would ask the SDT to consider circumstances where the same GO owns generators in multiple operating areas thus having to comply with varying requirements by multiple PCs. This would potentially result in the GO having to comply with different schedules of these multiple PCs which could be very difficult for the GO to comply with.
No
 
No
 
Yes
R2 is not a requirement as currently written. It is a choice that the RP or PC makes. If he seeks verfied data, then he must provide certain things to the GO. If he chooses to not seek verified data, then he is not required to do anything. This means that M2 is wrong. The RP and PC should not be required to have evidence if they chose not to seek the data. This situation can be fixed by revising R2 to read: "Each Resource Planner and Planning Coordinator shall request verified generating unit Real Power capability data and shall provide each Generator Owner…" R1 requires the GO to submit information but it does not indicate to whom the data should be submitted. We recommend that R1 be changed to read: "Each Generator Owner shall verify the summer and winter Real Power generating capability for each of its units in accordance with MOD-024-2 Attachment 1 - Verification of Summer and Winter Generating Unit Capability and record and submit the information to its Resource Planner and Planning Coordinator via MOD-024-2 Attachment 2 - One-line Diagram, Table and Summary for Verification Information Reporting." Paragraph 2.4 in Att 1: The first word grouping is not a sentence and reads awkwardly. It is suggested that the words "an acceptable value can be obtained" be place in front of the words "by making a temperature". Paragraph 3.4.2 in Att 1: Replace the word "since" with "if" for better clarity. Paragraph 3.4.4 in Att 1: Move the words "in Attachment 2" to the position just after the word "flows". This will make it clear that the sentence refers to flows in Attachments 2 rather than units in Attachment 2.
Individual
Dan Rochester
Independent Electricity System Operator
Yes
Accurate data for real power output of a generating unit/plant is critical to system modeling for resource adequacy and transmission reliability analyses. Unless other standards already cover the requirement for this data, this standard needs to be retained but some of the details for the additional empirical data are not necessary. Please see our comments under Q9.
Yes
This is a simple approach that should be supported. Notwithstanding our response and consistent with our reply to Q1, where the provision of this information is already required in other standards, those requirements should not be duplicated here.
Yes
 
Yes
We do not have any concern with the proposed approach. Individual Regions or markets that identify a need to verify such units to meet local requirements can establish regional specific criteria and market rules as they see appropriate.
Yes
 
No
We agree with the RPs and PCs to specify the schedule for receiving verified information to suit their needs. However, we have concerns with the applicability which relates to the purpose of the standard. a. The purpose of the existing MOD-024-1 is: “To ensure accurate information on generator gross and net Real Power capability is available for steady-state models used to assess Bulk Electric System reliability.” This implies that the data is also used for accurate modeling of the BES which the TPs, TOPs and RCs use to assess transmission system performance. The purpose of the proposed MOD-024-2 appears to have been changed somewhat: “To ensure that planning entities have accurate generator Real Power capability modeling data used in system planning studies.” This change was not mentioned in the SAR for the project (posted for comment in April 2007). We have two concerns with this change and the corresponding requirements: (i) The data is not only used for planning, it is also used for operational planning and near-term adequacy assessments (ii) If the intent of the existing standard is to continue, then the data is used for transmission reliability assessment as well. Other applicable entities need to be added. We suggest the SDT to assess the intended users of the generator’s real power capability data. Is the data used for resource adequacy assessment only, or is it also used for system model for transmission reliability/adequacy assessment? If it is the former, then RPs and PCs would be the only users. If it’s the latter, then TPs, TOPs, and RCs can be the other users. b. In the Background Information section of the comment form, the SDT indicates that it “has taken the approach that the Transmission Planner needs to communicate the conditions under which the Generator Owner is to provide verified values.” The proposed requirement does not include TPs. We wonder if the Background Information quoted the incorrect entities, or the standard is missing the TP as an applicable entity.
No
 
No
 
Yes
The detailed requirements in Attachment 1 are overly prescriptive. Specifically, the requirements listed in Item 3 are too detailed, and most of them are not needed for reliability. We believe Attachment 1 needs only to specify the sustainability (Items 1 and 2), periodicity (Item 4) and the ambient conditions of the verification (some of Item 3). Using the form and the one-line diagram do not contribute to reliability. A requirement to ask for both gross and net capability would suffice.
Group
Bonneville Power Administration
Denise Koehn
Yes
BPA suggests reducing the frequency of data collection ... not sure it needs to be every 5 years, it is just more onerous documentation for something that does not change a lot.
Yes
 
Yes
 
Yes
It seems like Wind and Solar should do a report for their peak generation for Summer and Winter on a periodic basis.
Yes
 
Yes
 
No
 
No
 
Yes
Attachment 2 needs modification: Attachment 2 should have a measurement point on their diagram for the gross generator output, and the table should specify what values to use in the calculation of each column (Gross capability power = new point F, Aux power = A+B+C+D, Net Power = F-A-B-C-D) Because this standard is paired with MOD-025(reactive), BPA believes they should be commented together.
Group
IRC Standards Review Committee
Ben Li
Yes
The SRC agrees that there is a need for a verification requirement. Given that the GOs are responsible for submitting real power data, there should be a corresponding requirement to verify that data on an as-requested basis. This approach provides the Planners with data that is valid for producing viable forecasts and assessments.
No
There is no need for the SDT to impose a requirement / limitation on what is or is not subject to a NERC standard. The FERC has established those boundaries. To the extent that a PC needs or does not need verification of generators that fall outside those FERC-identified conditions, must be justified on a reliability need or settled outside the NERC-standard process.
No
A Planning Coordinator should be afforded the right to request periods other than one continuous hour as needed for ad hoc evaluations e.g. for Ancillary Service evaluations over a 15 minute period or for special case studies e.g. fuel disruption analysis. The default period may be agreed to as one continuous hour but that should not be the mandated period.
 
No
The SDT should not be concerned with administrative details. The PC should be responsible for requesting verification when verification is needed as opposed to mandating artificial (i.e. one test for all conditions) verification for the sake of artificial verification.
No
The SRC believes with the concept that regular period-specific verification is not necessary, but does not agree with the SDT’s requirement. Rather the SRC would propose that R1 and R2 be replaced by the following 3 requirements: R.1. Each Planning Coordinator that requires validation of a Generator Owner’s reported generator capability for use in a NERC-mandated assessment shall submit a request to the Generator Owner specifying the applicable conditions. These conditions may include such parameters as: • Gross or Net data • Time (season) required • Boundary conditions (temperature, wind if appropriate) R.2. Each Generator Owner shall verify the Real Power generating capability for each of its units in accordance with requests from their Planning Coordinator. R.3. The Planning Coordinator shall distribute the verified data to the Resource Planners that request the data, or are known by the PC to use that data. Note: CAISO does not support the proposed R3.
No
 
Yes
Certain Regional Entities are currently developing or have developed standards to comply with MOD-024-1 and close coordination will be necessary to ensure that no compliance conflicts are created with the approval of this updated standard.
No
 
Group
Calpine Corporation
Duncan Brown
No
The reliability need has not been adequately demonstrated and the standard should be retired. It's not clear that it's necessary to require a high degree of accuracy on one segment of generation, when another segment (variable generation) is not addressed and loads levels used in studies are estimates.
Yes
We agree with the demarcation but recommend it be reworded to exclude generation units interconnected at voltages below 100 kV and units below 20 MVA to avoid unnecessary discussion of registration criteria.
Yes
 
No
If there's truly a reliability need for verification of capability, this segment of generation needs to be addressed.
Yes
 
Yes
 
No
 
No
 
Yes
Combined cycle power plants are often built with peaking capability such as steam injection for power augmentation. The term "normal operation" should be defined and include a statement that peaking capability is included only if the unit routinely operates in this mode. Combined cycle plants are sensitive to a variety of ambient conditions in addition to temperature, such as relative humidity. The standard should be revised to include other ambient data required by the generator to adjust output.