FERC-725L supporting statement-Final

CUI

FERC-725L (OMB Control No. 1902-0261)

Supporting Statement

FERC-725L, Mandatory Reliability Standards for the Bulk-Power System: MOD Reliability Standards

(Three-year extension requested)

The Federal Energy Regulatory Commission (FERC or Commission) requests that the Office of Management and Budget (OMB) review and renew the information collection requirements in FERC-725L under OMB Control No. 1902-0261. This supporting statement covers the requirements of the FERC-725L information collection. The reporting requirements in the FERC-725L are also contained in FERC’s regulations in 18 Code of Federal Regulations (CFR) Part 40.

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

On August 8, 2005, The Electricity Modernization Act of 2005, which is Title XII of the Energy Policy Act of 2005 (EPAct 2005), was enacted into law. EPAct 2005 added a new Section 215 to the Federal Power Act (FPA), which requires a Commission-certified Electric Reliability Organization (ERO) to develop mandatory and enforceable Reliability Standards, which are subject to Commission review and approval. Once approved, the Reliability Standards may be enforced by the ERO, subject to Commission oversight. In 2006, the Commission certified the North American Electric Reliability Corporation (NERC) as the ERO pursuant to FPA section 215.¹

On May 30, 2013, the North American Electric Reliability Corporation (NERC) filed a petition explaining that the reliability of the Bulk-Power System benefits from “good quality simulation models of power system equipment,” and that “model validation ensures the proper performance of the control systems and validates the computer models used for stability analysis.” NERC further stated that the Reliability Standards will enhance reliability because the tests performed to obtain model data may reveal latent defects that could cause “inappropriate unit response during system disturbances.” Subsequently, on March 20, 2014,² the Commission approved Reliability Standards MOD-025-2, MOD-026-1, and MOD-027-1. RD20-4 is modifying two standards for this renewal: Reliability Standard MOD 31-3 (formerly 31-2) and Reliability Standard MOD 33-2 (formerly 33-1). These Standards are intended to address generator verifications needed to support Bulk-Power System reliability that would also ensure that accurate data is verified and made available for planning simulations.³

On May 1, 2014,⁴ the Commission approved Reliability Standards MOD-032-1 and MOD-033-2. These Standards were to address “system-level modeling data and validation requirements necessary for developing planning models and the Interconnection-wide cases that are integral to analyzing the reliability of the Bulk-Power System”.

MOD-025-2, MOD-026-1, MOD-027-1, MOD-031-3, MOD-032-1 and MOD-033-2 are all currently approved within the FERC-725L information collection.

MOD Reliability Standards ensure that generators remain in operation during specified voltage and frequency excursions, properly coordinate protective relays and generator voltage regulator controls, and ensure that generator models accurately reflect the generator’s capabilities and equipment performance.

2. HOW, BY WHOM, AND FOR WHAT PURPOSE THE INFORMATION IS TO BE USED AND THE CONSEQUENCES OF NOT COLLECTING THE INFORMATION

The FERC-725L information collection contains six reliability standards:

• MOD-025-2;

• MOD-026-1;

• MOD-027-1;

• MOD-031-3;

• MOD-032-1; and

• MOD-033-2.

The Commission approved MOD-025-2, MOD-026-1, and MOD-027-1 Reliability Standards in the Final Rule in Docket RM13-16-000⁵. The purpose of these generator verification Reliability Standards⁶ is to ensure:

• generators remain in operation during specified voltage and frequency excursions; properly coordinate protective relays and generator voltage regulator controls; and

• generator models accurately reflect the generator’s capabilities and equipment performance.

Reliability Standard MOD-025-2

Requirements

R1. Each Generator Owner shall provide its Transmission Planner with verification of the

Real Power capability of its applicable Facilities as follows:

1.1. Verify the Real Power capability of its generating units in accordance with Attachment 1.

1.2. Submit a completed Attachment 2 (or a form containing the same information as

identified in Attachment 2) to its Transmission Planner within 90 calendar days of

either (i) the date the data is recorded for a staged test; or (ii) the date the data is

selected for verification using historical operational data.

R2. Each Generator Owner shall provide its Transmission Planner with verification of the

Reactive Power capability of its applicable Facilities as follows

2.1. Verify, in accordance with Attachment 1, (i) the Reactive Power capability of its

generating units and (ii) the Reactive Power capability of its synchronous

condenser units.

2.2. Submit a completed Attachment 2 (or a form containing the same information as

identified in Attachment 2) to its Transmission Planner within 90 calendar days of

either (i) the date the data is recorded for a staged test; or (ii) the date the data is

selected for verification using historical operational data.

R3. Each Transmission Owner shall provide its Transmission Planner with verification of

the Reactive Power capability of its applicable Facilities as follows:

3.1. Verify, in accordance with Attachment 1, the Reactive Power capability of its

synchronous condenser units.

3.2. Submit a completed Attachment 2 (or a form containing the same information as

identified in Attachment 2) to its Transmission Planner within 90 calendar days of

either (i) the date the data is recorded for a staged test; or (ii) the date the data is

selected for verification using historical operational data.

Measures

M1. Each Generator Owner will have evidence that it performed the verification, such as a

completed Attachment 2 or the Generator Owner form with the same information or

dated information collected and used to complete attachments, and will have evidence

that it submitted the information within 90 days to its Transmission Planner; such as

dated electronic mail messages or mail receipts in accordance with Requirement R1.

M2. Each Generator Owner will have evidence that it performed the verification, such as a

completed Attachment 2 or the Generator Owner form with the same information, or

dated information collected and used to complete attachments and will have evidence

that it submitted the information within 90 days to its Transmission Planner; such as

dated electronic mail messages or mail receipts in accordance with Requirement R2.

Reliability Standard MOD-031-3 purpose is to provide authority for applicable entities to collect Demand, energy and related data to support reliability studies and assessments and to enumerate the responsibilities and obligations of requestors and respondents of that data. provides planners and operators access to actual and forecast demand and energy data as needed to perform resource adequacy studies.

M3. Each Transmission Owner will have evidence that it performed the verification, such as

a completed Attachment 2 or the Transmission Owner form with equivalent

information or dated information collected and used to complete attachments, and will

have evidence that it submitted the information within 90 days to its Transmission

Planner; such as dated electronic mail messages or mail receipts in accordance with

Requirement R3.

Evidence Retention

The following evidence retention periods identify a period of time an entity is

required to retain specific evidence to demonstrate compliance. For instances

where the evidence retention specified below is shorter than the time since the last

compliance audit, the Compliance Enforcement Authority may ask an entity to

provide other evidence to show that it was compliant for the full time period since

the last audit.

The Generator Owner and Transmission Owner shall each keep the data or

evidence to show compliance as identified below, unless directed by its

Compliance Enforcement Authority to retain specific evidence for a longer period

of time as part of an investigation:

• The Generator Owner shall retain the latest MOD-025 Attachment 2 and

the data behind Attachment 2 or Generator Owner form with equivalent

information and submittal evidence for Requirements R1 and R2,

Measures M1 and M2 for the time period since the last compliance

audit.

• The Transmission Owner shall retain the latest MOD-025 Attachment 2

and the data behind Attachment 2 or Transmission Owner form with

equivalent information and submittal evidence for Requirement R3,

Measure M3 for the time period since the last compliance audit.

If a Generator Owner or Transmission Owner is found noncompliant, it shall keep

information related to the noncompliance until mitigation is complete or for the

time specified above, whichever is longer.

The Compliance Enforcement Authority shall keep the last audit records and all

requested and submitted subsequent audit records.

Reliability Standard MOD 26-1

Requirements

R1. Each Transmission Planner shall provide the following requested information to the Generator Owner within 90 calendar days of receiving a written request:

• Instructions on how to obtain the list of excitation control system or plant volt/var control function models that are acceptable to the Transmission Planner for use in dynamic simulation,

• Instructions on how to obtain the dynamic excitation control system or plant volt/var control function model library block diagrams and/or data sheets for models that are acceptable to the Transmission Planner, or

• Model data for any of the Generator Owner’s existing applicable unit specific excitation control system or plant volt/var control function contained in the Transmission Planner’s dynamic database from the current (in-use) models, including generator MVA base.

R2. Each Generator Owner shall provide for each applicable unit, a verified generator excitation control system or plant volt/var control function model, including documentation and data (as specified in Part 2.1) to its Transmission Planner in accordance with the periodicity specified in MOD-026.

R3. Each Generator Owner shall provide a written response to its Transmission Planner within 90 calendar days of receiving one of the following items for an applicable unit:

• Written notification from its Transmission Planner (in accordance with Requirement R6) that the excitation control system or plant volt/var control function model is not usable,

• Written comments from its Transmission Planner identifying technical concerns with the verification documentation related to the excitation control system or plant volt/var control function model, or

• Written comments and supporting evidence from its Transmission Planner indicating that the simulated excitation control system or plant volt/var control function model response did not match the recorded response to a transmission system event.

The written response shall contain either the technical basis for maintaining the current model, the model changes, or a plan to perform model verification3 (in accordance with Requirement R2).

R4. Each Generator Owner shall provide revised model data or plans to perform model verification4 (in accordance with Requirement R2) for an applicable unit to its Transmission Planner within 180 calendar days of making changes to the excitation control system or plant volt/var control function that alter the equipment response characteristic.

R5. Each Generator Owner shall provide a written response to its Transmission Planner, within 90 calendar days following receipt of a technically justified6 unit request from the Transmission Planner to perform a model review of a unit or plant that includes one of the following:

• Details of plans to verify the model (in accordance with Requirement R2), or

• Corrected model data including the source of revised model data such as discovery of manufacturer test values to replace generic model data or updating of data parameters based on an on-site review of the equipment.

R6. Each Transmission Planner shall provide a written response to the Generator Owner within 90 calendar days of receiving the verified excitation control system or plant volt/var control function model information in accordance with Requirement R2 that the model is usable (meets the criteria specified in Parts 6.1 through 6.3) or is not usable.

6.1. The excitation control system or plant volt/var control function model initializes to compute modeling data without error,

6.2. A no-disturbance simulation results in negligible transients, and

6.3. For an otherwise stable simulation, a disturbance simulation results in the excitation control and plant volt/var control function model exhibiting positive damping.

If the model is not usable, the Transmission Planner shall provide a technical description of why the model is not usable.

Measures

M1. The Transmission Planner must have and provide the dated request for instructions or data, the transmitted instructions or data, and dated evidence of a written transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) as evidence that it provided the request within 90 calendar days in accordance with Requirement R1.

M2. The Generator Owner must have and provide dated evidence it verified each generator excitation control system or plant volt/var control function model according to Part 2.1 for each applicable unit and a dated transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) as evidence it provided the model, documentation, and data to its Transmission Planner, in accordance with Requirement R2.

M3. Evidence for Requirement R3 must include the Generator Owner’s dated written response containing the information identified in Requirement R3 and dated evidence of transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) of the response.

M4. Evidence for Requirement R4 must include, for each of the Generator Owner’s applicable units for which system changes specified in Requirement R4 were made, a dated revised model data or plans to perform a model verification and dated evidence (e.g., electronic mail message, postal receipt, or confirmation of facsimile) it provided the revised model and data or plans within 180 calendar days of making changes.

M5. Evidence for Requirement R5 must include the Generator Owner’s dated written response containing the information identified in Requirement R5 and dated evidence (e.g., electronic mail message, postal receipt, or confirmation of facsimile) it provided a written response within 90 calendar days following receipt of a technically justified request.

M6. Evidence of Requirement R6 must include, for each model received, the dated response indicating the model was usable or not usable according to the criteria specified in Parts 6.1 through 6.3 and for a model that is not usable, a technical description; and dated evidence of transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) that the Generator Owner was notified within 90 calendar days of receipt of model inform

Data Retention

The following evidence retention periods identify the period of time an entity is required to retain specific evidence to demonstrate compliance. For instances where the evidence retention period specified below is shorter than the time since the last audit, the Compliance Enforcement Authority may ask an entity to provide other evidence to show that it was compliant for the full time period since the last audit.

The Generator Owner and Transmission Planner shall each keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation:

• The Transmission Planner shall retain the information/data request and provided response evidence of Requirements R1 and R6, Measures M1 and M6 for three calendar years from the date the document was provided.

• The Generator Owner shall retain the latest excitation control system or plant volt/var control function model verification evidence of Requirement R2, Measure M2.

• The Generator Owner shall retain the information/data request and provided response evidence of Requirements R3 through R5, and Measures M3 through M5 for three calendar years from the date the document was provided.

If a Generator Owner or Transmission Planner is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete or approved or for the time specified above, whichever is longer.

The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records.

Reliability Standard for MOD 27-1

The purpose is to verify that the turbine/governor and load control or active power/frequency control model and the model parameters, used in dynamic simulations that assess Bulk Electric System (BES) reliability, accurately represent generator unit real power response to system frequency variations.

Requirements

R1. Each Transmission Planner shall provide the following requested information to the Generator Owner within 90 calendar days of receiving a written request:

• Instructions on how to obtain the list of turbine/governor and load control or active power/frequency control system models that are acceptable to the Transmission Planner for use in dynamic simulation,

• Instructions on how to obtain the dynamic turbine/governor and load control or active power/frequency control function model library block diagrams and/or data sheets for models that are acceptable to the Transmission Planner, or

• Model data for any of the Generator Owner’s existing applicable unit specific turbine/governor and load control or active power/frequency control system contained in the Transmission Planner’s dynamic database from the current (in-use) models.

R2. Each Generator Owner shall provide, for each applicable unit, a verified turbine/governor and load control or active power/frequency control model, including documentation and data (as specified in Part 2.1) to its Transmission Planner in accordance with the periodicity specified in MOD-027 Attachment 1.

R3. Each Generator Owner shall provide a written response to its Transmission Planner within 90 calendar days of receiving one of the following items for an applicable unit.

• Written notification, from its Transmission Planner (in accordance with Requirement R5) that the turbine/governor and load control or active power/frequency control model is not “usable,”

• Written comments from its Transmission Planner identifying technical concerns with the verification documentation related to the turbine/governor and load control or active power/frequency control model, or

• Written comments and supporting evidence from its Transmission Planner indicating that the simulated turbine/governor and load control or active power/frequency control response did not approximate the recorded response for three or more transmission system events.

The written response shall contain either the technical basis for maintaining the current model, the model changes, or a plan to perform model verification4 (in accordance with Requirement R2).

R4. Each Generator Owner shall provide revised model data or plans to perform model verification5 (in accordance with Requirement R2) for an applicable unit to its Transmission Planner within 180 calendar days of making changes to the turbine/governor and load control or active power/frequency control system that alter the equipment response characteristic.

R5. Each Transmission Planner shall provide a written response to the Generator Owner within 90 calendar days of receiving the turbine/governor and load control or active power/frequency control system verified model information in accordance with Requirement R2 that the model is usable (meets the criteria specified in Parts 5.1 through 5.3) or is not usable.

Measures

M1. The Transmission Planner must have and provide the dated request for instructions or data, the transmitted instruction or data, and dated evidence of a written transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) as evidence that it provided the request within 90 calendar days in accordance with Requirement R1.

M2. The Generator Owner must have and provide dated evidence it verified each generator turbine/governor and load control or active power/frequency control model according to Part 2.1 for each applicable unit and a dated transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) as evidence it provided the model, documentation, and data to its Transmission Planner, in accordance with Requirement R2.

M3. Evidence for Requirement R3 must include the Generator Owner’s dated written response containing the information identified in Requirement R3 and dated evidence of transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) of the response.

M4. Evidence for Requirement R4 must include, for each of the Generator Owner’s applicable units for which system changes specified in Requirement R4 were made, dated revised model data or dated plans to perform a model verification and dated evidence of transmittal (e.g., electronic mail message, postal receipt, or confirmation of facsimile) within 180 calendar days of making changes.

M5. Evidence of Requirement R5 must include, for each model received, the dated response indicating the model was usable or not usable according to the criteria specified in Parts 5.1 through 5.3 and for a model that is not useable, a technical description is the model is not usable, and dated evidence of transmittal (e.g., electronic mail messages, postal receipts, or confirmation of facsimile) that the Generator Owner was notified within 90 calendar days of receipt of model information in accordance with Requirement R5

Data Retention

The following evidence retention periods identify the period of time an entity is required to retain specific evidence to demonstrate compliance. For instances where the evidence retention period specified below is shorter than the time since the last audit, the Compliance Enforcement Authority may ask an entity to provide other evidence to show that it was compliant for the full time period since the last audit.

The Generator Owner and Transmission Planner shall each keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation:

• The Transmission Planner shall retain the information/data request and provided response evidence of Requirements R1 and R5, Measures M1 and M5 for 3 calendar years from the date the document was provided.

• The Generator Owner shall retain the latest turbine/governor and load control or active power/frequency control system model verification evidence of Requirement R2, Measure M2.

• The Generator Owner shall retain the information/data request and provided response evidence of Requirements R3, and R4 Measures M3 and M4 for 3 calendar years from the date the document was provided.

If a Generator Owner or Transmission Planner is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved or for the time specified above, whichever is longer.

The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records.

MOD-031-3 contains four requirements:

R1. Each Planning Coordinator or Balancing Authority that identifies a need for the

collection of Total Internal Demand, Net Energy for Load, and Demand Side

Management data shall develop and issue a data request to the applicable entities in

its area.

1.1. A list of Transmission Planners, Balancing Authorities, and Distribution Providers

that are required to provide the data (“Applicable Entities”).

1.2. A timetable for providing the data. (A minimum of 30 calendar days must be

allowed for responding to the request).

1.3. A request to provide any or all of the following actual data, as necessary:

1.3.1. Integrated hourly Demands in megawatts for the prior calendar year.

1.3.2. Monthly and annual integrated peak hour Demands in megawatts for the

prior calendar year.

1.3.2.1. If the annual peak hour actual Demand varies due to weather related

conditions (e.g., temperature, humidity or wind

speed), the Applicable Entity shall also provide the weather

normalized annual peak hour actual Demand for the prior

calendar year.

M1. The Planning Coordinator or Balancing Authority shall have a dated data request,

either in hardcopy or electronic format, in accordance with Requirement R1.

R2. Each Applicable Entity identified in a data request shall provide the data requested by

its Planning Coordinator or Balancing Authority in accordance with the data request

issued pursuant to Requirement R1.

M2. Each Applicable Entity shall have evidence, such as dated e-mails or dated transmittal

letters that it provided the requested data in accordance with Requirement R2.

R3. The Planning Coordinator or the Balancing Authority shall provide the data listed

under Requirement R1 Parts 1.3 through 1.5 for their area to the applicable Regional

Entity within 75 calendar days of receiving a request for such data, unless otherwise

agreed upon by the parties.

M3. Each Planning Coordinator or Balancing Authority, shall have evidence, such as dated

e-mails or dated transmittal letters that it provided the data requested by the

applicable Regional Entity in accordance with Requirement R3.

R4. Any Applicable Entity shall, in response to a written request for the data included in

parts 1.3-1.5 of Requirement R1 from a Planning Coordinator, Balancing Authority,

Transmission Planner or Resource Planner with a demonstrated need for such data in

order to conduct reliability assessments of the Bulk Electric System, provide or

otherwise make available that data to the requesting entity. This requirement does

not modify an entity’s obligation pursuant to Requirement R2 to respond to data

requests issued by its Planning Coordinator or Balancing Authority pursuant to

Requirement R1.

• shall not be required to alter the format in which it maintains or uses the data;

• shall provide the requested data within 45 calendar days of the written

request.

M4. Each Applicable Entity identified in Requirement R4 shall have evidence such as dated

e-mails or dated transmittal letters that it provided the data requested or provided a

written response specifying the data that is not being provided and the basis for not

providing the data in accordance with Requirement R4.

Evidence Retention

The following evidence retention periods identify the period of time an entity is

required to retain specific evidence to demonstrate compliance. For instances

where the evidence retention period specified below is shorter than the time

since the last audit, the Compliance Enforcement Authority may ask an entity to

provide other evidence to show that it was compliant for the full time period

since the last audit.

The Applicable Entity shall keep data or evidence to show compliance with

Requirements R1 through R4, and Measures M1 through M4, since the last audit,

unless directed by its Compliance Enforcement Authority to retain specific

evidence for a longer period of time as part of an investigation.

If an Applicable Entity is found non-compliant, it shall keep information related

to the non-compliance until mitigation is complete and approved, or for the time

specified above, whichever is longer.

The Compliance Enforcement Authority shall keep the last audit records and all

requested and submitted subsequent audit records.

Reliability Standards MOD-032-1 and MOD-033-3 were approved by the Commission in an Order in Docket No. RD14-5-000⁷. Both standards were designed to replace, consolidate and improve upon existing MOD standards, “in addressing system-level modeling data and validation requirements necessary for developing planning models and the Interconnection-wide cases that are integral to analyzing the reliability of the Bulk-Power System.”⁸

MOD-032-1 Reliability Standard contains four requirements:

• Requirement R1 mandates that each planning coordinator and each of its transmission planners shall jointly develop steady-state, dynamics, and short circuit modeling data requirements and reporting procedures for the planning coordinator’s planning area;

• Requirement R2 mandates that each balancing authority, generator owner, load serving entity, resource planner, transmission owner, and transmission service provider shall provide steady-state, dynamics, and short circuit modeling data to its transmission planner(s) and planning coordinator(s) according to the data requirements and reporting procedures developed by its planning coordinator and transmission planner in Requirement R1. For data that has not changed since the last submission, a written confirmation that the data has not changed is sufficient;

• Requirement R3 mandates that upon receipt of written notification from its planning coordinator or transmission planner regarding technical concerns with the data submitted under Requirement R2, including the technical basis or reason for the technical concerns, each notified balancing authority, generator owner, load serving entity, resource planner, transmission owner, or transmission service provider shall respond to the notifying planning coordinator or transmission planner as follows:

  • Provide either updated data or an explanation with a technical basis for maintaining the current data;

  • Provide the response within 90 calendar days of receipt, unless a longer time period is agreed upon by the notifying planning coordinator or transmission planner.

• Requirement R4 mandates that each planning coordinator shall make available models for its planning area reflecting data provided to it under Requirement R2 to the Electric Reliability Organization (ERO) or its designee to support creation of the Interconnection-wide case(s) that includes the planning coordinator’s planning area.

MOD-033-2 Reliability Standard contains two requirements:

Purpose is to establish consistent validation requirements to facilitate the collection of accurate data and building of planning models to analyze the reliability of the interconnected transmission system.

R1. Each Planning Coordinator shall implement a documented data validation process

1.1. Comparison of the performance of the Planning Coordinator’s portion of the

existing system in a planning power flow model to actual system behavior,

represented by a state estimator case or other Real-time data sources, at least

once every 24 calendar months through simulation;

1.2. Comparison of the performance of the Planning Coordinator’s portion of the

existing system in a planning dynamic model to actual system response, through

simulation of a dynamic local event, at least once every 24 calendar months (use

a dynamic local event that occurs within 24 calendar months of the last dynamic

local event used in comparison, and complete each comparison within 24

calendar months of the dynamic local event). If no dynamic local event occurs

within the 24 calendar months, use the next dynamic local event that occurs;

1.3. Guidelines the Planning Coordinator will use to determine unacceptable

differences in performance under Part 1.1 or 1.2; and

1.4. Guidelines to resolve the unacceptable differences in performance identified

under Part 1.3.

M1. Each Planning Coordinator shall provide evidence that it has a documented validation

process according to Requirement R1 as well as evidence that demonstrates the

implementation of the required components of the process.

R2. Each Reliability Coordinator and Transmission Operator shall provide actual system

behavior data (or a written response that it does not have the requested data) to any

Planning Coordinator performing validation under Requirement R1 within 30 calendar

days of a written request, such as, but not limited to, state estimator case or other

Real-time data (including disturbance data recordings) necessary for actual system

response validation.

M2. Each Reliability Coordinator and Transmission Operator shall provide evidence, such

as email notices or postal receipts showing recipient and date that it has distributed

the requested data or written response that it does not have the data, to any Planning

Coordinator performing validation under Requirement R1 within 30 days of a written

request in accordance with Requirement R2; or a statement by the Reliability

Coordinator or Transmission Operator that it has not received notification regarding

data necessary for validation by any Planning Coordinator.

Evidence Retention

The following evidence retention periods identify the period of time an entity is required to retain specific evidence to demonstrate compliance. For instances where the evidence retention period specified below is shorter than the time since the last audit, the Compliance Enforcement Authority may ask an entity to provide other evidence to show that it was compliant for the full time period since the last audit. The applicable entity shall keep data or evidence to show compliance with Requirements R1 through R2, and Measures M1 through M2, since the last audit, unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation. If an applicable entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved, or for the time specified above, whichever is longer. The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records.

3. DESCRIBE ANY CONSIDERATION OF THE USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE THE BURDEN AND TECHNICAL OR LEGAL OBSTACLES TO REDUCING BURDEN

This collection does not require industry to file the information with the Commission. However, FERC-725L does contain information collection and record retention requirements for which using current technology is an option.

The information technology to meet the information collection requirements is not specifically covered in the Reliability Standard.

4. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION AND SHOW SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE PURPOSE(S) DESCRIBED IN INSTRUCTION NO. 2

The Commission periodically reviews filing requirements concurrent with OMB review or as the Commission deems necessary to eliminate duplicative filing and to minimize the filing burden. The Commission is unaware of any other source of information related to bulk-electric system physical security.

5. METHODS USED TO MINIMIZE THE BURDEN IN COLLECTION OF INFORMATION INVOLVING SMALL ENTITIES

In general, small entities may reduce their burden by taking part in a joint registration organization or a coordinated functional registration. These options allow a small entity to share the compliance burden with other entities and, thus, to minimize their own compliance burden. Detailed information regarding these options is available in NERC’s Rule of Procedure at Sections 507 and 508⁹.

6. CONSEQUENCE TO FEDERAL PROGRAM IF COLLECTION WERE CONDUCTED LESS FREQUENTLY

The Reliability Standard provides consistent documentation and information sharing practices for demand and energy data while promoting efficient planning practices across industry and supporting identification of necessary system reinforcements. As stated earlier, all of this would be hindered if this collection of information were discontinued or conducted less frequently.

7. EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION COLLECTION

There are no special circumstances related to the FERC-725L information collection.

8. DESCRIBE EFFORTS TO CONSULT OUTSIDE THE AGENCY: SUMMARIZE PUBLIC COMMENTS AND THE AGENCY’S RESPONSE

The ERO process to establish Reliability Standards is a collaborative process with the ERO, Regional Entities, and other stakeholders developing and reviewing drafts and providing comments.¹⁰ The NERC-approved Reliability Standards were then submitted by NERC to the FERC for review and approval.

In accordance with OMB requirements, the Commission published a 60-day notice¹¹ and a 30-day notice¹² to the public regarding this information collection on April 8, 2021 and June 14, 2021 respectively. Within the public notices, the Commission noted that it would be requesting a three-year extension of the public reporting burden. The Commission received no comments from the public in response to the 60-day notice regarding the FERC-725L information collection.

9. EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS

There are no payments or gifts to respondents associated with this collection.

10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

According to the NERC Rule of Procedure¹³, “…a Receiving Entity shall keep in confidence and not copy, disclose, or distribute any Confidential Information or any part thereof without the permission of the Submitting Entity, except as otherwise legally required.” This serves to protect confidential information submitted to NERC or Regional Entities.

Responding entities do not submit the information collected under these Reliability Standards to FERC. Rather, they maintain it internally and provide information collected to applicable Regional Entities. Since there are no submissions made to FERC, FERC provides no specific provisions in order to protect confidentiality.

11. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE, SUCH AS SEXUAL BEHAVIOR AND ATTITUDES, RELIGIOUS BELIEFS, AND OTHER MATTERS THAT ARE COMMONLY CONSIDERED PRIVATE.

There are no questions of a sensitive nature in the reporting requirements.

12. ESTIMATED BURDEN OF COLLECTION OF INFORMATION

The burden for the FERC-725L information collection includes estimates related to each of the six previously approved Reliability Standards.

Estimate of Annual Burden¹⁴: The Commission estimates the annual public reporting burden¹⁵ and cost for the information collection as:

RD20-4:

• Elimination of the burden associated with the load-serving entity (LSE) function in Requirement R1 of Reliability Standard MOD-031-3.¹⁶ The NERC petition states as the load-serving entity is no longer a NERC registration category, NERC proposes to remove this entity from the applicability section of proposed Reliability Standard MOD-031-3 and remove reference to this entity in Requirement R1, Part 1.1, where it is listed as an “Applicable Entity” for purposes of Requirements R2 and R4.¹⁷

Additionally, NERC proposes to strike the term “Planning Authority” from the applicability section of the standard and the explanatory text that follows. The preferred terminology for the responsible entity that coordinates and integrates transmission facilities and service plans, resource plans, and protection systems is “Planning Coordinator.”¹⁸ This is a terminology change and will not result in a change in burden.

• Modification of the term “Planning Authority” to “Planning Coordinator” in Reliability Standard MOD-033-2.¹⁹ In the petition, NERC proposes to strike the term “Planning Authority” from the applicability section of the standard and the explanatory text that follows. The proposed change is intended to promote consistent use of “Planning Coordinator” throughout the Reliability Standards.²⁰ This is a terminology change and will not result in a change in burden.

• Reliability Standard MOD-031-3 (Demand and Energy Data)

• Reliability Standard MOD-033-2 (Steady-State and Dynamic System Model Validation)

Proposed Changes to Burden Due to Docket No. RD20-4-000 Adjustments and Clarifications21
Reliability Standard & Requirements	No. of Respondents & Type of Entity (1)	Annual No. of Responses per Respondent (2)	Annual No. of Responses (1)*(2)=(3)	Average Burden Hrs. Per Response (4)	Total Annual Burden Hours (3)*(4)=(5)
RD20-4 Net Changes to FERC-725L, OMB Control No. 1902-0261
MOD-031-3 (Demand and Energy Data) Develop summary in accordance w/ R1, Subparts 1.5.4 and 1.5.5.—program decrease & adjustment / clarification22	-561 (DP, LSE, TP & BA)23	1	-561	8 hrs.	-4,488 hrs.
MOD-031-3 (Demand and Energy Data) Develop data request in accordance w/ R1 and R3 & Evidence Retention—adjustment / clarification24	113 (PC & BA)	1	113	8 hrs.	904 hrs.
MOD-031-3 (Demand and Energy Data) Develop and provide data in accordance w/ R2 and R4 & Evidence Retention—adjustment / clarification23	381 (TP, BA & DP)	1	381	8 hrs.	3,048 hrs.
MOD-033-2 (Steady-State Dynamic System Model Validation) R2 Data Submittal [for R2]—adjustment	-14 (RC & TOP) 25	1	-14	8 hrs.	-112 hrs.;
MOD-033-2 (Steady-State Dynamic System Model Validation),R1-R2, Evidence Retention, adjustment	-14 (PC, RC & TOP) 26	1	-14	1 hr.	-14 hrs.
Net Changes for FERC-725L due to RD20-4			-95 (net reduction)		-662 hrs.; (net reduction)

MOD-025-2 (Verification and Data Reporting of Generator Real and Reactive Power Capability and Synchronous Condenser Reactive Power Capability)
	Number of Respondents27 (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
Attachment 2	1003 (GO)	1	1003	6 hrs.; $502.0228	6,018 hrs.; $503,526.06	$502.02
Evidence Retention	1003 (GO)	1	1003	1 hr.; $34.7929	1003 hrs.; $34,894.07	$34.79
TOTAL					7,021 hrs.; $538,420.07

MOD-026-1 (Verification of Models and Data for Generator Excitation Control System or Plant Volt/Variance Control Functions)
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
Instructions for obtaining excitation control system or plant voltage/variance control function model	201 (TP)	1	201	8 hrs.; $669.3628	1,608 hrs.; $134,541.36	$669.36
Documentation on generator verification	501 (GO)	1	501	8 hrs.; $669.3628	4,008 hrs.; $335,349.36	$669.36
Evidence Retention	668 (GO and TOP)	1	668	1 hr.; $34.7929	668 hrs.; $23,239.72	$34.79
TOTAL					6,284 hrs.; $493,130.44

MOD-027-1 (Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions)
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
Instructions for obtaining excitation control system or plant voltage/variance control function model	201 (TP)	1	201	8 hrs.; $669.3628	1,608 hrs.; $134,541.36	$669.36
Documentation on generator verification	501 (GO)30	1	501	8 hrs.; $669.3628	4,008 hrs.; $335,349.36	$669.36
Evidence Retention	668 (GO and TP)	1	668	1 hr.; $34.7929	668 hrs.; $23,239.72	$34.79
TOTAL					6,284 hrs.; $493,130.44

MOD-031-3 (formerly MOD-031-2) (Demand and Energy Data), included in FERC-725L
Reliability Standard MOD-031-3	Number and Type of Respondents (1)		Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Avg. Burden & Cost Per Response31 (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent (5)÷(1)
(On-going) Develop summary in accordance with Requirement R1, Subparts 1.5.4 and 1.5.5.	616 (DP, TP and/or BA)		1	616	8 hrs.; $561.52	4,928 hrs.; $345,896.32	$561.52
MOD-031-3 Net Changes in RD20-4 (in the first table above)				-67		-536 hrs.; $37,621.84
New Total for MOD-031-3 for Renewal				549		4,392 hrs.; $308,274.48

MOD-032-1 (Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions)
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
Data Submittal	1,418 (BA, GO, PA/PC, RP, TO, TP, and TSP)	1	1,418	8 hrs.; $561.5220	11,344 hrs.; $796,235.36	$561.52
Evidence Retention	1,418 (BA, GO, PA/PC, RP, TO, TP, and TSP)	1	1,418	1 hr.; $34.7929	1,418 hrs.; $49,332.22	$34.79
TOTAL					12,762 hrs.; $998,484.70

MOD-033-2 (formerly MOD-033-1) (Steady-State and Dynamics System Model Validation)
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)		Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
Data Submittal	178 (RC and TOP)	1	178		8 hrs.; $669.36	1,424 hrs.; $119,146.08	$669.36
Evidence Retention	243 (PA/PC, RC, and TOP)	1	243		1 hr.; $34.7929	243 hrs.; $8,453.97	$34.79
MOD-033-2 Net Changes in RD20-4 (in the first table above)			-28			-126
New Total for MOD-033-2 Renewal			393			1,541 hrs.; $128,935.47

The total annual estimated burden and cost for the FERC-725L information collection is 38,724 hours and $2,960,375.60 respectively.

13. ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS

There are no non-labor costs currently associated with the FERC-725L.

All of the costs are associated with burden hours (labor) and described in #12 and 15.

14. ESTIMATED ANNUALIZED COST TO FEDERAL GOVERNMENT

The Regional Entities and NERC do most of the data processing, monitoring and compliance work for Reliability Standards; the burden and cost are included under the FERC-725 collection (OMB Control No. 1902-0225) and are not part of this request or package. Any involvement by the Commission is covered under the FERC-725 collection (OMB Control No. 1902-0225) and is not part of this request or package.

The estimated annualized cost to the Federal Government for FERC-725L follows:

	Number of Employees (FTE)	Estimated Annual Federal Cost
FERC-725L Analysis and Processing of filings	0	$0
PRA32 Administrative Cost		$6,475
FERC Total		$6,475

Responding entities do not submit the information collected under these Reliability Standards to FERC. Rather, they maintain it internally and provide information collected to applicable Regional Entities. Since there are no submissions made to FERC, the Commission estimates no federal costs associated with analysis and processing of filings.

The PRA Administrative Cost is a Federal Cost associated with preparing, issuing, and submitting materials necessary to comply with the Paperwork Reduction Act (PRA) for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection. This average annual cost includes requests for extensions, all associated rulemakings, and other changes to the collection.

15. REASONS FOR CHANGES IN BURDEN INCLUDING THE NEED FOR ANY INCREASE

The burden for the FERC-725L information collection is experiencing both reductions and increases.

• The reductions are due to RD20-4 (program decrease) associated with modifications made to Reliability Standards MOD-033-2 and MOD-031-3. Two reliability standards (MOD-031-3 and MOD-033-2 experienced decreases (adjustments) to their respective annual burdens due to RD20-4).

• Three reliability standards had increases to their respective annual burdens (MOD-025-2, MOD-026-1, and MOD-027-1) due to adjustments to the number of affected respondents (due to normal industry fluctuations, e.g., companies entering/leaving the industry, or merging/splitting).

FERC-725L	Total Request	Previously Approved	Change due to Adjustment in Estimate	Change Due to Agency Discretion
Annual Number of Responses	4,538	4,187	393	-42
Annual Time Burden (Hr.)	38,284	35,208	3,329	-253
Annual Cost Burden ($)	0	0	0	0

16. TIME SCHEDULE FOR PUBLICATION OF DATA

FERC does not publish any data associated with this collection.

17. DISPLAY OF EXPIRATION DATE

The PRA information (including expiration dates and OMB Control Nos.) is posted at http://www.ferc.gov/docs-filing/efiling.asp

.

18. EXCEPTIONS TO THE CERTIFICATION STATEMENT

There are no exceptions.

1 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g & compliance, 117 FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).

2 Final Rule in Docket No. RM13-16-000; https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20No.%20796%20Generator%20Verfication.pdf

3 Letter Order for Approval of two Proposed Reliability Standards MOD-031-3, MOD-033-2 October 20, 2020. https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/RD20-4-000_AD_Signature.pdf

4 Order in Docket No. RD14-5-000 https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/May_1_2014_Order_Aprpving_MOD_B_Standards.pdf

5 Order No. 796 issued on 3/20/2014 (published at 79 FR 17011, 3/27/2014).

6 In conjunction with Reliability Standards PRC-019-1 and PRC-024-1. The reporting requirements for PRC-019-1 and PRC-024-1 Reliability Standards are contained in the FERC-725G information collection (OMB Control No. 1902-0252).

7 Approved by the Commission in the Order in Docket No. RD14-5-000 (issued 5/1/2014).

8 NERC Petition for MOD-032-1 at paragraph 2.

9 http://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/NERC_ROP_Effective_20161031.pdf

10 Details of the ERO standards development process are available on the NERC website at http://www.nerc.com/pa/Stand/Documents/Appendix_3A_StandardsProcessesManual.pdf.

11 86 FR 18279

12 86 FR 31494

13 Section 1502, Paragraph 2, available at NERCs website.

14 “Burden” is defined as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. For further explanation of what is included in the information collection burden, reference 5 Code of Federal Regulations 1320.3.

15 Each of the five MOD standards in the FERC-725L information collection previously contained “one-time” components to their respondent burden. These one-time burden categories consisted primarily of activities related to establishing industry practices and developing data validation procedures tailored toward these reliability standards and their reporting requirements. None of the one-time burdens apply any longer, so they are being removed from the FERC-725L information collection.

16 The burden associated with the current version of this standard, MOD-031-2, is included in FERC-725L.

17 Standards Alignment with Registration Petition at 10.

18 Standards Alignment with Registration Petition at 10.

19 The burden associated with the current version of this standard, MOD-033-1, is included in FERC-725L.

20Standards Alignment with Registration Petition at 11.

21 The adjustments, due to normal industry fluctuations, are based on figures in the NERC registry as of April 10, 2020.

22 The estimates reflect a program decrease of 63 de-registered LSEs (and corresponding program decrease of 504 hrs.) related to Docket No. RD20-4-000, and an adjustment/clarification (decrease) of 498 DPs, TPs, and BAs (and corresponding decrease of 3,984 hrs.), not related to Docket No. RD20-4-000. The updated number of 381 DPs, TPs and BAs is listed in a new row clarifying their applicability with Requirements R2 and R4. Requirement R2 requires applicable entities to develop and provide data pursuant with Requirement R1.

23 Planning Coordinator (PC), Transmission Planners (TP), Transmission Owner (TO), Generator Owner (GO), Distribution Provider (DP), Load-Serving Entity (LSE)

24 The 113 PCs and BAs were originally estimated in FERC-725A due to Order No. 693. However, the estimates and descriptions were not clearly spelled out, so we are clarifying them. [Some of this burden may still be in FERC-725A (and double counted temporarily).]

25 The estimate is changing to 174 (from 188) due to normal industry fluctuation.

26 The estimate is changing to 188 (from 194) due to normal industry fluctuation.

27 The number of respondents for MOD-025-2/ MOD-026-1/ MOD-027-1/ MOD-31-3/ MOD-032-/ MOD-033-2 are from the NERC compliance registry February 5, 2021.

28 This wage figure uses the average hourly wage (plus benefits) for electrical engineers (Occupation Code: 17-2071, $70.19/hour) and managers (Occupation Code: 11-0000, $97.15/hour) obtained from the Bureau of Labor Statistics (BLS) (from https://www.bls.gov/oes/current/naics2_22.htm). The average used the following calculation: [$70.19/hour + $97.15/hour] ÷ 2 = $83.67/hour.

29 The estimate uses the hourly average wage (plus benefits) for file clerks obtained from the Bureau of Labor Statistics: $34.79/hour (BLS Occupation Code: 43-4071).

30 It is estimated that the applicable numbers of generator owner respondents used to calculate the public reporting burden for these standards MOD-026-1, MOD-027- 1, MOD-032-1 and MOD-033-1 is half of total numbers of GO (501=1003/2) due to the higher applicability threshold for those Reliability Standards.

31 The estimate uses the average hourly wage (plus benefits) of $70.19/hour for electrical engineers (Occupation Code: 17-2071) from the Bureau of Labor Statistics.

32 Paperwork Reduction Act of 1995 (PRA)

19