MOD-031-1 NERC (exhibits)

MOD-031-1 NERC (exhibits).pdf

FERC-725L (Order in RD16-1) Mandatory Reliability Standards for the Bulk-Power System: MOD Reliability Standards

MOD-031-1 NERC (exhibits)

OMB: 1902-0261

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Exhibit A
Proposed Reliability Standard

MOD-031-1 — Demand and Energy Data

A. Introduction
1.

Title: Demand and Energy Data

Number:

Purpose: 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.

Applicability:

MOD-031-1

4.1. Functional Entities:
4.1.1 Planning Authority and Planning Coordinator (hereafter collectively
referred to as the “Planning Coordinator”)
This proposed standard combines “Planning Authority” with “Planning
Coordinator” in the list of applicable functional entities. The NERC
Functional Model lists “Planning Coordinator” while the registration
criteria list “Planning Authority,” and they are not yet synchronized. Until
that occurs, the proposed standard applies to both “Planning Authority”
and “Planning Coordinator.”
4.1.2 Transmission Planner
4.1.3 Balancing Authority
4.1.4 Resource Planner
4.1.5 Load-Serving Entity
4.1.6 Distribution Provider
5.

Effective Date
5.1. MOD-031-1 shall become effective on the first day of the first calendar quarter
that is twelve months after the date that this standard is approved by applicable
regulatory authorities or as otherwise provided for in a jurisdiction where
approval by an applicable governmental authority is required for a standard to
go into effect. Where approval by an applicable governmental authority is not
required, the standard shall become effective on the first day of the first
calendar quarter that is twelve months after the date the standard is adopted by
the NERC Board of Trustees or as otherwise provided for in that jurisdiction.

Background:
To ensure that various forms of historical and forecast Demand and energy data and
information is available to the parties that perform reliability studies and
assessments, authority is needed to collect the applicable data.
The collection of Demand, Net Energy for Load and Demand Side Management data
requires coordination and collaboration between Planning Authorities (Planning
Coordinators), Transmission and Resource Planners, Load-Serving Entities and

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MOD-031-1 — Demand and Energy Data

Distribution Providers. Ensuring that planners and operators have access to complete
and accurate load forecasts – as well as the supporting methods and assumptions
used to develop these forecasts – enhances the reliability of the Bulk Electric System.
Consistent documenting and information sharing activities will also improve efficient
planning practices and support the identification of needed system reinforcements.
Furthermore, collection of actual Demand and Demand Side Management
performance during the prior year will allow for comparison to prior forecasts and
further contribute to enhanced accuracy of load forecasting practices.
B. Requirements and Measures
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. The data request shall include: [Violation Risk Factor: Medium] [Time
Horizon: Long-term Planning]
1.1. A list of Transmission Planners, Balancing Authorities, Load Serving Entities, 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 weatherrelated 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.

1.3.3. Monthly and annual Net Energy for Load in gigawatthours for the prior
calendar year.
1.3.4. Monthly and annual peak hour controllable and dispatchable Demand
Side Management under the control or supervision of the System
Operator in megawatts for the prior calendar year. Three values shall be
reported for each hour: 1) the committed megawatts (the amount under
control or supervision), 2) the dispatched megawatts (the amount, if any,
activated for use by the System Operator), and 3) the realized megawatts
(the amount of actual demand reduction).
1.4. A request to provide any or all of the following forecast data, as necessary:

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MOD-031-1 — Demand and Energy Data

1.4.1. Monthly peak hour forecast Total Internal Demands in megawatts for the
next two calendar years.
1.4.2. Monthly forecast Net Energy for Load in gigawatthours for the next two
calendar years.
1.4.3. Peak hour forecast Total Internal Demands (summer and winter) in
megawatts for ten calendar years into the future.
1.4.4. Annual forecast Net Energy for Load in gigawatthours for ten calendar
years into the future.
1.4.5. Total and available peak hour forecast of controllable and dispatchable
Demand Side Management (summer and winter), in megawatts, under
the control or supervision of the System Operator for ten calendar years
into the future.
1.5. A request to provide any or all of the following summary explanations, as
necessary,:
1.5.1. The assumptions and methods used in the development of aggregated
Peak Demand and Net Energy for Load forecasts.
1.5.2. The Demand and energy effects of controllable and dispatchable Demand
Side Management under the control or supervision of the System
Operator.
1.5.3. How Demand Side Management is addressed in the forecasts of its Peak
Demand and annual Net Energy for Load.
1.5.4. How the controllable and dispatchable Demand Side Management
forecast compares to actual controllable and dispatchable Demand Side
Management for the prior calendar year and, if applicable, how the
assumptions and methods for future forecasts were adjusted.
1.5.5. How the peak Demand forecast compares to actual Demand for the prior
calendar year with due regard to any relevant weather-related variations
(e.g., temperature, humidity, or wind speed) and, if applicable, how the
assumptions and methods for future forecasts were adjusted.
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. [Violation Risk Factor: Medium] [Time Horizon:
Long-term Planning]

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.

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MOD-031-1 — Demand and Energy Data

R3.

The Planning Coordinator or the Balancing Authority shall provide the data collected
under Requirement R2 to the applicable Regional Entity within 75 calendar days of
receiving a request for such data, unless otherwise agreed upon by the parties.
[Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]

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. Unless otherwise agreed upon, the Applicable Entity: [Violation Risk
Factor: Medium] [Time Horizon: Long-term Planning]
x

shall provide the requested data within 45 calendar days of the written
request, subject to part 4.1 of this requirement; and

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

4.1. If the Applicable Entity does not provide data requested under this requirement
because (1) the requesting entity did not demonstrate a reliability need for the
data; or (2) providing the data would conflict with the Applicable Entity’s
confidentiality, regulatory, or security requirements, the Applicable Entity shall,
within 30 calendar days of the written request, provide a written response to the
requesting entity specifying the data that is not being provided and on what
basis.
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.

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MOD-031-1 — Demand and Energy Data

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority
As defined in the NERC Rules of Procedure, “Compliance Enforcement Authority”
means NERC or the Regional Entity in their respective roles of monitoring and
enforcing compliance with the NERC Reliability Standards.
1.2. 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.
1.3. Compliance Monitoring and Assessment Processes:
Compliance Audit
Self-Certification
Spot Checking
Compliance Investigation
Self-Reporting
Complaint
1.4. Additional Compliance Information
None

Page 5 of 10

Time Horizon

Long-term
Planning

N/A

OR
The Applicable Entity,
as defined in the data
request developed in
Requirement R1, failed
to provide one of the
requested items in
Requirement R1 part

OR
The Applicable Entity,
as defined in the data
request developed in
Requirement R1,
provided the data
requested in
Requirement R1, but

The Applicable Entity,
as defined in the data
request developed in
Requirement R1, failed
to provide one of the
requested items in
Requirement R1 part
1.3.1 through part
1.3.4

Moderate VSL

The Applicable Entity,
as defined in the data
request developed in
Requirement R1, failed
to provide two of the
requested items in
Requirement R1 part

The Applicable Entity,
as defined in the data
request developed in
Requirement R1, failed
to provide two of the
requested items in
Requirement R1 part
1.3.1 through part
1.3.4

N/A

High VSL

Violation Severity Levels
Lower VSL

Medium The Applicable Entity,
as defined in the data
request developed in
Requirement R1, failed
to provide all of the
data requested in
Requirement R1 part
1.5.1 through part
1.5.5

Medium

VRF

Table of Compliance Elements

MOD-031-1 — Demand and Energy Data

Page 6 of 10

The Applicable Entity, as
defined in the data request
developed in Requirement
R1, failed to provide three
or more of the requested
items in Requirement R1
part 1.4.1 through part
1.4.5

The Applicable Entity, as
defined in the data request
developed in Requirement
R1, failed to provide three
or more of the requested
items in Requirement R1
part 1.3.1 through part
1.3.4

The Planning Coordinator
or Balancing Authority
developed and issued a
data request but failed to
include either the entity(s)
necessary to provide the
data or the timetable for
providing the data.

Severe VSL

Long-term
Planning

Medium The Planning
Coordinator or
Balancing Authority, in
response to a request
by the Regional Entity,
made available the
data collected under
Requirement R2, but

did so after the date
indicated in the
timetable provided
pursuant to
Requirement R1 part
1.2 but prior to 6 days
after the date
indicated in the
timetable provided
pursuant to
Requirement R1 part
1.2.

MOD-031-1 — Demand and Energy Data

The Applicable Entity,
as defined in the data
request developed in
Requirement R1,
provided the data
requested in
Requirement R1, but
did so 11 days after
the date indicated in
the timetable provided
pursuant to
Requirement R1 part
1.2 but prior to 15
days after the date
indicated in the
timetable provided
pursuant to
Requirement R1 part
1.2.

The Applicable Entity,
as defined in the data
request developed in
Requirement R1,
provided the data
requested in
Requirement R1, but
did so 6 days after the
date indicated in the
timetable provided
pursuant to
Requirement R1 part
1.2 but prior to 11
days after the date
indicated in the
timetable provided
pursuant to
Requirement R1 part
1.2.
The Planning
Coordinator or
Balancing Authority, in
response to a request
by the Regional Entity,
made available the
data collected under
Requirement R2, but

The Planning
Coordinator or
Balancing Authority, in
response to a request
by the Regional Entity,
made available the
data collected under
Requirement R2, but

1.4.1 through part
1.4.5

Page 7 of 10

The Planning Coordinator
or Balancing Authority, in
response to a request by
the Regional Entity, failed
to make available the data
collected under
Requirement R2 prior to 91

The Applicable Entity, as
defined in the data request
developed in Requirement
R1, failed to provide the
data requested in the
timetable provided
pursuant to Requirement
R1 prior to 16 days after
the date indicated in the
timetable provided
pursuant to Requirement
R1 part 1.2.

Long-term
Planning

The Applicable Entity failed
to provide or otherwise
make available the data to
the requesting entity
within 60 days from the
date of the request

The Applicable Entity
provided or otherwise
made available the
data to the requesting
entity but did so after
55 days from the date
of request but prior to
61 days from the date
of the request
OR
The Applicable Entity
that is not providing
the data requested
provided a written
response specifying
the data that is not
being provided and on
what basis but did so
after 40 days of the
written request but
prior to 46 days of the
written resquest.

The Applicable Entity
provided or otherwise
made available the
data to the requesting
entity but did so after
50 days from the date
of request but prior to
56 days from the date
of the request
OR
The Applicable Entity
that is not providing
the data requested
provided a written
response specifying
the data that is not
being provided and on
what basis but did so
after 35 days of the
written request but
prior to 41 days of the
written resquest.

Medium The Applicable Entity
provided or otherwise
made available the
data to the requesting
entity but did so after
45 days from the date
of request but prior to
51 days from the date
of the request
OR
The Applicable Entity
that is not providing
the data requested
provided a written
response specifying
the data that is not
being provided and on
what basis but did so
after 30 days of the
written request but
prior to 36 days of the
written resquest.

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The Applicable Entity that
is not providing the data
requested failed to provide
a written response
specifying the data that is
not being provided and on
what basis within 45 days
of the written resquest.

days or more from the
date of the request.

did so after 85 days
from the date of
request but prior to 91
days from the date of
the request.

did so after 80 days
from the date of
request but prior to 86
days from the date of
the request.

did so after 75 days
from the date of
request but prior to 81
days from the date of
the request.

MOD-031-1 — Demand and Energy Data

D. Regional Variances
None.
E. Interpretations
None.
F. Associated Documents
None.

Version History

Version

Date

May 6,
2014

Action

Change Tracking

Adopted by the NERC Board of
Trustees.

Page 9 of 10

Application Guidelines
Rationale
During development of this standard, text boxes were embedded within the standard to explain
the rationale for various parts of the standard. Upon Board of Trustees approval, the text from
the rationale text boxes was moved to this section.
Rationale for R1:
Rationale for R1: To ensure that when Planning Coordinators (PCs) or Balancing Authorities
(BAs) request data (R1), they identify the entities that must provide the data (Applicable Entity
in part 1.1), the data to be provided (parts 1.3 – 1.5) and the due dates (part 1.2) for the
requested data.
For Requirement R1 part 1.3.2.1, if the Demand does not vary due to weather-related
conditions (e.g., temperature, humidity or wind speed), or the weather assumed in the forecast
was the same as the actual weather, the weather normalized actual Demand will be the same
as the actual demand reported for Requirement R1 part 1.3.2. Otherwise the annual peak hour
weather normalized actual Demand will be different from the actual demand reported for
Requirement R1 part 1.3.2.
Balancing Authorities are included here to reflect a practice in the WECC Region where BAs are
the entity that perform this requirement in lieu of the PC.
Rationale for R2:
This requirement will ensure that entities identified in Requirement R1, as responsible for
providing data, provide the data in accordance with the details described in the data request
developed in accordance with Requirement R1. In no event shall the Applicable Entity be
required to provide data under this requirement that is outside the scope of parts 1.3 - 1.5 of
Requirement R1.
Rationale for R3:
This requirement will ensure that the Planning Coordinator or when applicable, the Balancing
Authority, provides the data requested by the Regional Entity.
Rationale for R4:
This requirement will ensure that the Applicable Entity will make the data requested by the
Planning Coordinator or Balancing Authority in Requirement R1 available to other applicable
entities (Planning Coordinator, Balancing Authority, Transmission Planner or Resource Planner)
unless providing the data would conflict with the provisions outlined in Requirement R4 below.
The sharing of documentation of the supporting methods and assumptions used to develop
forecasts as well as information-sharing activities will improve the efficiency of planning
practices and support the identification of needed system reinforcements.

Page 10 of 10

Exhibit B
Implementation Plan

Implementation Plan
Project 2010-04 Demand and Energy Data
Implementation Plan for MOD-031-1 – Demand and Energy Data
Approvals Required
MOD-031-1 – Demand and Energy Data
Prerequisite Approvals
There are no other standards that must receive approval prior to the approval of this standard.
Revisions to Glossary Terms
Demand Side Management: All activities or programs undertaken by any applicable entity to
achieve a reduction in Demand.
Total Internal Demand: The Demand of a metered system, which includes the Firm Demand,
plus any controllable and dispatchable DSM Load and the Load due to the energy losses
incurred within the boundary of the metered system.
The defined term “Demand Side Management” is incorporated in the NERC approved standards listed
in Attachment 1 of this document. After reviewing the standards incorporating the term “Demand
Side Management,” it is not anticipated that the proposed revision will have any effect on the
standards.
Applicable Entities
Planning Coordinator and Planning Authority
Transmission Planner
Resource Planner
Balancing Authority
Load-Serving Entity
Distribution Provider
Applicable Facilities
N/A

Conforming Changes to Other Standards
None
Effective Dates
MOD-031-1 shall become effective as follows:
The first day of the first calendar quarter that is twelve months after the date that this standard is
approved by applicable regulatory authorities or as otherwise provided for in a jurisdiction where
approval by an applicable governmental authority is required for a standard to go into effect. Where
approval by an applicable governmental authority is not required, the standard shall become effective
on the first day of the first calendar quarter that is twelve months after the date the standard is
adopted by the NERC Board of Trustees or as otherwise provided for in that jurisdiction.
Justification
The 12-month implementation period will provide sufficient time for the applicable entities to develop
the necessary process to implement this standard.
Retirements
MOD-016-1.1, MOD-017-0.1, MOD-018-0, MOD-019-0.1, and MOD-021-1 shall be retired at 11:59:59
p.m. of the day immediately prior to the effective date of MOD-031-1 in the particular jurisdiction in
which the new standard is becoming effective.
The current definition of Demand Side Management (DSM) in the NERC Glossary of Terms shall be
retired at 11:59:59 p.m. of the day immediately prior to the effective date of MOD-031-1 in the
particular jurisdiction in which the new standard is becoming effective.

Project 2010-04 Demand and Energy Data Implementation Plan

Attachment 1
Approved Standards Incorporating the Term “Demand-Side Management”

BAL-502-RFC-02 — Planning Resource Adequacy Analysis, Assessment and Documentation
EOP-002-3.1 — Capacity and Energy Emergencies
IRO-006-EAST-1 — TLR Procedure for the Eastern Interconnection
MOD-016-1.1 — Actual and Forecast Demands, Net Energy for Load, Controllable DSM
MOD-017-0.1 — Aggregated Actual and Forecast Demands and Net Energy for Load
MOD-018-0 — Reports of Actual and Forecast Demand Data
MOD-019-0.1 — Forecasts of Interruptible Demands and DCLM Data
MOD-020-0 — Providing Interruptible Demands and DCLM Data
MOD-021-1 — Accounting Methodology for Effects of DSM in Forecasts

Approved Standards Pending Regulatory Approval Incorporating the Term “Demand-Side
Management”

BAL-002-WECC-2 — Contingency Reserve
TPL-001-2 — Transmission System Planning Performance Requirements
TPL-001-3 — System Performance Under Normal Conditions
TPL-001-4 — Transmission System Planning Performance Requirements
TPL-002-2b — System Performance Following Loss of a Single BES Element
TPL-003-2a — System Performance Following Loss of Two or More BES Elements
TPL-003-2b — System Performance Following Loss of Two or More BES Elements
TPL-004-2 — System Performance Following Extreme BES Events
TPL-004-2a — System Performance Following Extreme BES Events
TPL-006-0 — Assessment Data from Regional Reliability Organizations
TPL-006-0.1 — Assessment Data from Regional Reliability Organizations

Project 2010-04 Demand and Energy Data Implementation Plan

Exhibit C
Order No. 672 Criteria

EXHIBIT C
Order No. 672 Criteria
In Order No. 672, 1 the Commission identified a number of criteria it will use to analyze
Reliability Standards proposed for approval to ensure they are just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The discussion below identifies these
factors and explains how the proposed Reliability Standard has met or exceeded the criteria:
1. Proposed Reliability Standards must be designed to achieve a specified reliability
goal and must contain a technically sound means to achieve that goal. 2
Proposed Reliability Standard MOD-031-1 achieves the specific reliability goal of
ensuring that Demand and energy data necessary to support reliability assessments conducted by
the ERO and Bulk-Power System planners and operators is available to such entities. The
proposed Reliability Standard enumerates the responsibilities of applicable entities with respect
to the provision and/or collection of Demand and energy data. By providing for consistent
documentation and information sharing practices for the collection and aggregation of such data,
proposed Reliability Standard MOD-031-1 promotes efficient planning practices and supports
the identification of needed system reinforcements. Furthermore, the requirement in the
proposed Reliability Standard to report historical Demand, Net Energy for Load and DemandSide Management data will allow for comparison to prior forecasts and further contribute to
enhanced accuracy of load forecasting practices. These activities ultimately enhance the
reliability of the Bulk Electric System.

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).

Order No. 672 at PP 321, 324.

2. Proposed Reliability Standards must be applicable only to users, owners and
operators of the bulk power system, and must be clear and unambiguous as to what
is required and who is required to comply. 3
The proposed Reliability Standard is clear and unambiguous as to what is required and
who is required to comply, in accordance with Order No. 672. The proposed Reliability
Standard applies to Planning Coordinators, Transmission Planners, Balancing Authorities,
Resource Planners, Load Serving Entities and Distribution Providers. The proposed Reliability
Standard clearly articulates the actions that such entities must take to comply with the standard.
3. A proposed Reliability Standard must include clear and understandable
consequences and a range of penalties (monetary and/or non-monetary) for a
violation. 4
The Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”) for the
proposed Reliability Standard comport with NERC and Commission guidelines related to their
assignment. The assignment of the severity level for each VSL is consistent with the
corresponding requirement and the VSLs should ensure uniformity and consistency in the
determination of penalties. The VSLs do not use any ambiguous terminology, thereby
supporting uniformity and consistency in the determination of similar penalties for similar
violations. For these reasons, the proposed Reliability Standard includes clear and
understandable consequences in accordance with Order No. 672.

Order No. 672 at PP 322, 325.

Order No. 672 at P 326.

4. A proposed Reliability Standard must identify clear and objective criterion or
measure for compliance, so that it can be enforced in a consistent and nonpreferential manner. 5
The proposed Reliability Standard contains measures that support each requirement by
clearly identifying what is required to demonstrate compliance. These measures help provide
clarity regarding the manner in which the requirements will be enforced, and help ensure that the
requirements will be enforced in a clear, consistent, and non-preferential manner and without
prejudice to any party.
5. Proposed Reliability Standards should achieve a reliability goal effectively and
efficiently — but do not necessarily have to reflect “best practices” without regard
to implementation cost or historical regional infrastructure design. 6
The proposed Reliability Standard achieves the reliability goal effectively and efficiently
in accordance with Order No. 672. The proposed Reliability Standard clearly enumerates the
responsibilities of applicable entities with respect to the provision and/or collection of Demand
and energy data necessary to support reliability assessments. Proposed MOD-031-1 consolidates
and streamlines the Existing MOD C Standards to more efficiently address the collection and
aggregation of Demand and energy data.
6. Proposed Reliability Standards cannot be “lowest common denominator,” i.e.,
cannot reflect a compromise that does not adequately protect Bulk-Power System
reliability. Proposed Reliability Standards can consider costs to implement for
smaller entities, but not at consequences of less than excellence in operating system
reliability. 7
The proposed Reliability Standard does not reflect a “lowest common denominator”
approach. To the contrary, the proposed Reliability Standard contains significant benefits for the

Order No. 672 at P 327.

Order No. 672 at P 328.

Order No. 672 at P 329-30.

Bulk-Power System. The requirements of the proposed Reliability Standard help ensure that
entities that conduct reliability assessments, which are fundamental to analyzing the reliability of
the grid, have access to complete and accurate data necessary to conduct those assessments.
7. Proposed Reliability Standards must be designed to apply throughout North
America to the maximum extent achievable with a single Reliability Standard while
not favoring one geographic area or regional model. It should take into account
regional variations in the organization and corporate structures of transmission
owners and operators, variations in generation fuel type and ownership patterns,
and regional variations in market design if these affect the proposed Reliability
Standard.8
The proposed Reliability Standard applies throughout North America and does not favor
one geographic area or regional model. In fact, the proposed Reliability Standard supports the
various ways in which Demand and energy data is collected across the continent.
8. Proposed Reliability Standards should cause no undue negative effect on
competition or restriction of the grid beyond any restriction necessary for
reliability. 9
The proposed Reliability Standard has no undue negative impact on competition. The
proposed Reliability Standard requires the same performance by each of the applicable
Functional Entities in the provision or collection of Demand and energy data. The standard does
not unreasonably restrict the available transmission capability or limit use of the Bulk-Power
System in a preferential manner.

8
9

Order No. 672 at P 331.

Order No. 672 at P 332. As directed by section 215 of the FPA, FERC itself will give special attention to the effect
of a proposed Reliability Standard on competition. The ERO should attempt to develop a proposed Reliability
Standard that has no undue negative effect on competition. Among other possible considerations, a proposed
Reliability Standard should not unreasonably restrict available transmission capability on the Bulk-Power System
beyond any restriction necessary for reliability and should not limit use of the Bulk-Power System in an unduly
preferential manner. It should not create an undue advantage for one competitor over another.

9. The implementation time for the proposed Reliability Standard is reasonable. 10
The proposed effective date for the standard is just and reasonable and appropriately
balances the urgency in the need to implement the standard against the reasonableness of the time
allowed for those who must comply to develop necessary procedures, software, facilities, staffing
or other relevant capability. This will allow applicable entities adequate time to ensure compliance
with the requirements. The proposed effective date is explained in the proposed Implementation
Plan, attached as Exhibit B.
10. The Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development
process. 11
The proposed Reliability Standard was developed in accordance with NERC’s
Commission-approved, ANSI- accredited processes for developing and approving Reliability
Standards. Exhibit F includes a summary of the Reliability Standard development proceedings,
and details the processes followed to develop the Reliability Standards. These processes
included, among other things, comment and balloting periods. Additionally, all meetings of the
drafting team were properly noticed and open to the public. The initial and additional ballots
achieved a quorum and exceeded the required ballot pool approval levels.
11. NERC must explain any balancing of vital public interests in the development of
proposed Reliability Standards. 12
NERC has identified no competing public interests regarding the request for approval of
the proposed Reliability Standard. No comments were received that indicated the proposed
Reliability Standard conflicts with other vital public interests.

Order No. 672 at P 333.

Order No. 672 at P 334.

Order No. 672 at P 335.

12. Proposed Reliability Standards must consider any other appropriate factors. 13
No other negative factors relevant to whether the proposed Reliability Standard is just
and reasonable were identified.

Order No. 672 at P 323.

Exhibit D
Mapping Document

Standard: MOD-016-1.1 – Documentation of Data Reporting Requirements for Actual and Forecast Demands, Net Energy for Load,
Controllable Demand-Side Management
Requirement in
Transitions to the below Requirement in
Description and Change Justification
Approved Standard
New Standard or Other Action
The pro forma standard requires the Planning Coordinator or Balancing
MOD-016-1a R1
Requirement R1
Authority to develop and issue a data request as necessary.
MOD-010 through MOD-015 does not depend on these standards for
their data (they collect the data needed). TPL-005 and TPL-006 are not
MOD-016-1a R1.1
Requirement R1
FERC approved standards but the data is available for their use. The
standard will require the Planning Coordinator or Balancing Authority
to identify the format for providing data.
MOD-016-1a R2
Requirement R1
See comments on Requirement R1.
The standard requires the Planning Coordinator or Balancing Authority
MOD-016-1a R2.1
Requirement R1 part 1.2
to provide a timeline for providing the data.
MOD-016-1a R3
Requirement R1
See comments on Requirement R1.
The Planning Coordinator or Balancing Authority must respond within
MOD-016-1a R3.1
Requirement R3
the time allotted by the Electric Reliability Organization (ERO) or
Regional Entity (RE).

Transition of MOD-016-1.1, MOD-017-0.1, MOD-018-0, MOD-019-0.1, and MOD-0211 to MOD-031-1

Project 2010-04 Mapping Document

MOD-017-0.1 R1.4

MOD-017-0.1 R1.3

MOD-017-0.1 R1.2

MOD-017-0.1 R1.1

MOD-017-0.1 R1

Requirement in
Approved Standard

Standard: MOD-017-0.1 – Aggregated Actual and Forecast Demands and Net Energy for Load
Transitions to the below Requirement in
Description and Change Justification
New Standard or Other Action
Requirements R2 and R4 of the standard will require entities to provide
Requirements R2 and R4
data as outlined in Requirement R1 parts 1.1 through 1.5.
The standard will require entities to provide integrated hourly demands
Requirement R1 part 1.3.1
in megawatts (MW) for the prior year.
The standard will require entities to provide monthly and annual peak
Requirement R1 part 1.3.2
hour actual demands in MW and Net Energy for Load in gigawatthours
(GWh) for the prior year.
The standard will require entities to provide monthly peak hour
Requirement R1 part 1.4.1
forecast demands in MW and Net Energy for Load in GWh for the next
two years.
The standard will require entities to provide peak hour forecast
Requirement part R1 part 1.4.2
demands (summer and winter) in MW and annual Net Energy for load
in GWh for ten years into the future.

Standard: MOD-018-0 – Treatment of Nonmember Demand Data and How Uncertainties are Addressed in the Forecasts of Demand and Net
Energy for Load
Requirement in
Transitions to the below Requirement in
Description and Change Justification
Approved Standard
New Standard or Other Action
MOD-018-0 R1
Omitted
This requirement serves no direct purpose other than as a bridge to the
sub-requirements below.
This is no longer need now that all registered entities within each
MOD-018-0 R1.1
Omitted
region is a member of that region.
The standard will require entities to provide the assumptions and
MOD-018-0 R1.2
Requirement R1 part 1.5.1
methods used in the development of aggregated peak demand and Net
Energy for Load forecasts.
This is now a part of the data reporting request developed in
MOD-018-0 R1.3
Requirement R1
Requirement R1.
The standard will require entities to provide the data requested in
MOD-018-0 R2
Requirements R2 and R4
Requirement R1 parts 1.1 through 1.5.

MOD-019-0.1 R1

Requirement in
Approved Standard

Standard: MOD-019-0.1 – Reporting of Interruptible Demands and Direct Control Load Management
Transitions to the below Requirement in
Description and Change Justification
New Standard or Other Action
The standard will require entities to provide forecasts of Interruptible
Load and Direct Control Load Management (DCLM) for at least five
Requirements R1 part 1.4.3
years and up to ten years into the future, as requested, for summer and
winter peak system conditions.

Standard: MOD-021-1 – Documentation of the Accounting Methodology for the Effects of Demand-Side Management in Demand and Energy
Forecasts
Requirement in
Transitions to the below Requirement in
Description and Change Justification
Approved Standard
New Standard or Other Action
The standard will require entities to provide the Demand and energy
MOD-021-1 R1
Requirements R1 part 1.5.2
effects of Interruptible and Direct Control Load Management.
The standard will require entities to provide how DSM measures are
MOD-021-1 R2
Requirements R1 part 1.5.3
addressed in the forecasts of its Peak Demand and annual Net Energy
for Load.
The standard will require entities to provide the requested data by a
MOD-021-1 R3
Requirements R1 part 1.2
certain date.

Exhibit E
Analysis of Violation Risk Factors and Violation Security Levels

A requirement that, if violated, could directly affect the electrical state or the capability of the Bulk Electric System, or the ability to effectively
monitor and control the Bulk Electric System. However, violation of a medium risk requirement is unlikely to lead to Bulk Electric
System instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency,
abnormal, or restorative conditions anticipated by the preparations, directly and adversely affect the electrical state or capability of the Bulk
Electric System, or the ability to effectively monitor, control, or restore the Bulk Electric System. However, violation of a medium risk
requirement is unlikely, under emergency, abnormal, or restoration conditions anticipated by the preparations, to lead to Bulk Electric
System instability, separation, or cascading failures, nor to hinder restoration to a normal condition.

Medium Risk Requirement

A requirement that, if violated, could directly cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of
failures, or could place the Bulk Electric System at an unacceptable risk of instability, separation, or cascading failures; or, a requirement in a
planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly
cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of failures, or could place the Bulk Electric
System at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition.

High Risk Requirement

NERC Criteria - Violation Risk Factors

This document provides the Standard Drafting Team’s (SDT) justification for assignment of violation risk factors (VRFs) and violation severity
levels (VSLs) for each requirement in MOD-031-1 – Demand and Energy Data. Each requirement is assigned a VRF and a VSL. These elements
support the determination of an initial value range for the Base Penalty Amount regarding violations of requirements in FERC-approved
Reliability Standards, as defined in the Electric Reliability Organizations (ERO) Sanction Guidelines. The SDT applied the following NERC criteria
and FERC Guidelines when proposing VRFs and VSLs for the requirements under this project.

MOD-031-1 – Demand and Energy Data

Violation Risk Factor and Violation Severity Level Justifications

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

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The Commission seeks to ensure that Violation Risk Factors assigned to Requirements of Reliability Standards in these identified areas
appropriately reflect their historical critical impact on the reliability of the Bulk-Power System. In the VSL Order, FERC listed critical areas (from
the Final Blackout Report) where violations could severely affect the reliability of the Bulk-Power System:

Guideline (1) – Consistency with the Conclusions of the Final Blackout Report

FERC Violation Risk Factor Guidelines

A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical
state or capability of the Bulk Electric System, or the ability to effectively monitor and control the Bulk Electric System; or, a requirement that
is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or
restorative conditions anticipated by the preparations, be expected to adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System.

Lower Risk Requirement

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

NERC Criteria - Violation Severity Levels
Violation Severity Levels (VSLs) define the degree to which compliance with a requirement was not achieved. Each requirement must have at
least one VSL. While it is preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of
noncompliant performance and may have only one, two, or three VSLs.

Where a single Requirement co-mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such
Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability
Standard.

Guideline (5) –Treatment of Requirements that Co-mingle More Than One Obligation

Guideline (4) was developed to evaluate whether the assignment of a particular Violation Risk Factor level conforms to NERC’s definition of
that risk level.

Guideline (4) – Consistency with NERC’s Definition of the Violation Risk Factor Level

The Commission expects the assignment of Violation Risk Factors corresponding to Requirements that address similar reliability goals in
different Reliability Standards would be treated comparably.

Guideline (3) – Consistency among Reliability Standards

The Commission expects a rational connection between the sub-Requirement Violation Risk Factor assignments and the main Requirement
Violation Risk Factor assignment.

Guideline (2) – Consistency within a Reliability Standard

Severe VSL
The performance or product
measured does not substantively
meet the intent of the
requirement.

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

Guideline 4 – Violation Severity Level Assignment Should Be Based on a Single Violation, Not on a Cumulative Number of
Violations
. . . unless otherwise stated in the requirement, each instance of non-compliance with a requirement is a separate violation. Section 4 of the
Sanction Guidelines states that assessing penalties on a per violation per day basis is the “default” for penalty calculations.

Guideline 3 – Violation Severity Level Assignment Should Be Consistent with the Corresponding Requirement
VSLs should not expand on what is required in the requirement.

Guideline 2 – Violation Severity Level Assignments Should Ensure Uniformity and Consistency in the Determination of
Penalties
A violation of a “binary” type requirement must be a “Severe” VSL.
Do not use ambiguous terms such as “minor” and “significant” to describe noncompliant performance.

Guideline 1 – Violation Severity Level Assignments Should Not Have the Unintended Consequence of Lowering the Current
Level of Compliance
Compare the VSLs to any prior levels of non-compliance and avoid significant changes that may encourage a lower level of compliance than
was required when levels of non-compliance were used.

FERC Order of Violation Severity Levels
FERC’s VSL guidelines are presented below, followed by an analysis of whether the VSLs proposed for each requirement in the standard meet
the FERC Guidelines for assessing VSLs:

Violation severity levels should be based on NERC’s overarching criteria shown in the table below:
Lower VSL
Moderate VSL
High VSL
The performance or product
The performance or product
The performance or product
measured almost meets the full
measured meets the majority of measured does not meet the
intent of the requirement.
the intent of the requirement.
majority of the intent of the
requirement, but does meet
some of the intent.

All of the parts within Requirement R1 are consistent with one another and considered a medium VRF.
Guideline 3 – Consistency among Reliability Standards:
The Medium VRF is consistent with the prior version of this Requirement in the currently effective version of the
standard.
Guideline 4 – Consistency with NERC Definitions of VRFs:
The VRF is consistent with the NERC definition. A violation of this requirement is unlikely to lead to Bulk Electric
System (BES) instability, separation, or a cascading sequence of failures; or, a requirement in a planning time frame
that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly
and adversely affect the electrical state or capability of the bulk electric system, or the ability to effectively monitor,
control, or restore the BES.
Guideline 5 – Treatment of Requirements that Co-mingle More Than One Obligation:

FERC VRF G2 Discussion

FERC VRF G3 Discussion

FERC VRF G4 Discussion

FERC VRF G5 Discussion

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

This VRF has one objective – to collect data.

It is difficult to argue that a failure to collect the data will directly lead to instability, separation, or Cascading.
NERC staff believes that the Medium VRF assignment was appropriate.
Guideline 2 – Consistency within a Reliability Standard:

FERC VRF G1 Discussion

A VRF of medium is consistent with the NERC VRF definition. Requirement R1 prescribes data that may be collected
for analysis.

Medium
Consistent with NERC’s VRF Guidelines.

Additionally, the Medium VRF is consistent with the prior versions of this Requirement in the currently effective
version of the standard.
Guideline 1 – Consistency with Blackout Report:

Proposed VRF
NERC VRF Discussion

VRF Justification – MOD-031-1 Requirement R1

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

Guideline 2b: VSL
Assignments that contain
ambiguous language
FERC VSL G3:

Guideline 2a: The single VSL
assignment category for
“Binary” Requirements is
not consistent

FERC VSL G1:
Violation Severity Level
Assignments Should Not
Have the Unintended
Consequence of Lowering
the Current Level of
Compliance
FERC VSL G2:
Violation Severity Level
Assignments Should Ensure
Uniformity and Consistency
in the Determination of
Penalties

NERC VSL Guidelines

The proposed VSL is consistent with the corresponding requirement.

Guideline 2b: The proposed VSL does not use ambiguous terms, supporting uniformity and consistency in the
determination of similar penalties for similar violations.

Guideline 2a: The proposed VSL is binary and therefore has on VSL, severe.

The proposed VSL is written to ensure uniformity and consistency in the determination of penalties.

The current level of compliance is not lowered with the proposed VSL.

VSL Justification – MOD-031-1 Requirement R1
Consistent with NERC’s VSL Guidelines. The Requirement is binary and therefore has one VSL.

FERC VRF G2 Discussion

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

FERC VRF G1 Discussion

A VRF of medium is consistent with the NERC VRF definition. Requirement R2 ensures that once data is collected, it
is passed on to the appropriate entity.

VRF Justification – MOD-031-1 Requirement R2
Medium
Consistent with NERC’s VRF Guidelines.

The proposed VSL is not based on a cumulative number of violations.

Additionally, the Medium VRF is consistent with the prior versions of this Requirement in the currently effective
version of the standard.
Guideline 1 – Consistency with Blackout Report:

Proposed VRF
NERC VRF Discussion

Violation Severity Level
Assignment Should Be
Consistent with the
Corresponding
Requirement
FERC VSL G4:
Violation Severity Level
Assignment Should Be
Based on A Single Violation,
Not on A Cumulative
Number of Violations

The VRF is consistent with the NERC definition. A violation of this requirement is unlikely to lead to Bulk Electric
System (BES) instability, separation, or a cascading sequence of failures; or, a requirement in a planning time frame
that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations,
directly and adversely affect the electrical state or capability of the bulk electric system, or the ability to effectively
monitor, control, or restore the BES.
Guideline 5 – Treatment of Requirements that Co-mingle More Than One Obligation:

FERC VRF G4 Discussion

FERC VRF G5 Discussion

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

FERC VSL G1:
Violation Severity Level
Assignments Should Not
Have the Unintended
Consequence of Lowering
the Current Level of
Compliance
FERC VSL G2:

NERC VSL Guidelines

The Medium VRF is consistent with the prior version of this Requirement in the currently effective version of the
standard.
Guideline 4 – Consistency with NERC Definitions of VRFs:

FERC VRF G3 Discussion

The proposed VSL is written to ensure uniformity and consistency in the determination of penalties.

The current level of compliance is not lowered with the proposed VSL.

VSL Justification – MOD-031-1 Requirement R2
Consistent with NERC’s VSL Guidelines. The VSL describes degrees of noncompliant performance in an
incremental manner.

This Requirement has one objective – to ensure that data is collected.

All of the parts within Requirement R2 are consistent with one another and considered a medium VRF.
Guideline 3 – Consistency among Reliability Standards:

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

Guideline 2a: The single VSL
assignment category for
“Binary” Requirements is
not consistent
Guideline 2b: VSL
Assignments that contain
ambiguous language
FERC VSL G3:
Violation Severity Level
Assignment Should Be
Consistent with the
Corresponding
Requirement
FERC VSL G4:
Violation Severity Level
Assignment Should Be
Based on A Single Violation,
Not on A Cumulative
Number of Violations

Violation Severity Level
Assignments Should Ensure
Uniformity and Consistency
in the Determination of
Penalties

The proposed VSL is not based on cumulative number of violations.

The proposed VSL is worded consistently with the corresponding requirement.

Guideline 2b: The proposed VSL does not use ambiguous terms, supporting uniformity and consistency in the
determination of similar penalties for similar violations.

Guideline 2a: The proposed VSL is not binary

All of the parts within Requirement R3 are consistent with one another and considered a medium VRF.
Guideline 3 – Consistency among Reliability Standards:
The Medium VRF is consistent with the prior version of this Requirement in the currently effective version of the
standard.
Guideline 4 – Consistency with NERC Definitions of VRFs:
The VRF is consistent with the NERC definition. A violation of this requirement is unlikely to lead to Bulk Electric
System (BES) instability, separation, or a cascading sequence of failures; or, a requirement in a planning time frame
that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations,
directly and adversely affect the electrical state or capability of the bulk electric system, or the ability to effectively
monitor, control, or restore the BES.
Guideline 5 – Treatment of Requirements that Co-mingle More Than One Obligation:

FERC VRF G2 Discussion

FERC VRF G3 Discussion

FERC VRF G4 Discussion

FERC VRF G5 Discussion

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

This Requirement has one objective – to ensure that data is collected.

FERC VRF G1 Discussion

A VRF of medium is consistent with the NERC VRF definition. Requirement R3 ensures that once data is collected, it
is passed on to the appropriate entity.

Medium
Consistent with NERC’s VRF Guidelines.

Additionally, the Medium VRF is consistent with the prior versions of this Requirement in the currently effective
version of the standard.
Guideline 1 – Consistency with Blackout Report:

Proposed VRF
NERC VRF Discussion

VRF Justification – MOD-031-1 Requirement R3

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

NERC VSL Guidelines

The proposed VSL is worded consistently with the corresponding requirement.

Guideline 2b: The proposed VSL does not use ambiguous terms, supporting uniformity and consistency in the
determination of similar penalties for similar violations.

Guideline 2a: The proposed VSL is not binary

The proposed VSL is written to ensure uniformity and consistency in the determination of penalties.

The current level of compliance is not lowered with the proposed VSL.

VSL Justification – MOD-031-1 Requirement R3
Consistent with NERC’s VSL Guidelines. The VSL describes degrees of noncompliant performance in an
incremental manner.

FERC VRF G3 Discussion

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

All of the parts within Requirement R4 are consistent with one another and considered a medium VRF.
Guideline 3 – Consistency among Reliability Standards:

FERC VRF G2 Discussion

The Medium VRF is consistent with the prior version of this Requirement in the currently effective version of the

FERC VRF G1 Discussion

A VRF of medium is consistent with the NERC VRF definition. Requirement R4 ensures that neighboring entities
have the ability to collect data.

Medium
Consistent with NERC’s VRF Guidelines.

VRF Justification – MOD-031-1 Requirement R4

The proposed VSL is not based on cumulative number of violations.

Additionally, the Medium VRF is consistent with the prior versions of this Requirement in the currently effective
version of the standard.
Guideline 1 – Consistency with Blackout Report:

Proposed VRF
NERC VRF Discussion

Corresponding
Requirement
FERC VSL G4:
Violation Severity Level
Assignment Should Be
Based on A Single Violation,
Not on A Cumulative
Number of Violations

FERC VRF G5 Discussion

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

NERC VSL Guidelines

FERC VRF G4 Discussion

Guideline 2a: The proposed VSL is not binary

The proposed VSL is written to ensure uniformity and consistency in the determination of penalties.

The current level of compliance is not lowered with the proposed VSL.

VSL Justification – MOD-031-1 Requirement R4
Consistent with NERC’s VSL Guidelines. The VSL describes degrees of noncompliant performance in an
incremental manner.

This Requirement has one objective – to ensure that data is collected.

standard.
Guideline 4 – Consistency with NERC Definitions of VRFs:

MOD-031-1 – Demand and Energy Data
VRF and VSL Justifications

The proposed VSL is worded consistently with the corresponding requirement.

Guideline 2b: The proposed VSL does not use ambiguous terms, supporting uniformity and consistency in the
determination of similar penalties for similar violations.

Exhibit F
Summary of Development History and Record of Development

Summary of Development History
The development record for proposed Reliability Standard MOD-031-1 is summarized
below.
I.

Overview of the Standard Drafting Team
When evaluating a proposed Reliability Standard, the Commission is expected to give

“due weight” to the technical expertise of the ERO. 1 The technical expertise of the ERO is
derived, in part, from the standard drafting team. For this project, the standard drafting team
consisted of industry experts, all a diverse set of experiences. A roster of the standard drafting
team members is included in Exhibit F.
II.

Standard Development History
A. Standard Authorization Request Development
A Standard Authorization Request (“SAR”) was submitted to the Standards Committee

(“SC”) on July 18, 2013 and accepted by the SC on July 18, 2013.
B. First Posting
Proposed Reliability Standard MOD-031-1 was posted for a 45-day formal comment
period from July 24, 2013 through September 4, 2013. There were 45 sets of responses,
including comments from approximately 110 different people from approximately 100
companies representing 8 of the 10 industry segments. The proposed Reliability Standards
received a quorum of 81.96% and an approval of 55.76%.
The standard drafting team considered stakeholder comments regarding proposed
Reliability Standard MOD-031-1 and made the following observations and modifications based
on those comments:

Section 215(d) (2) of the Federal Power Act; 16 U.S.C. §824(d) (2) (2006).

Purpose Statement and Definitions
x

In response to comments on the NERC Glossary term “Demand Side
Management,” the standard drafting team revised the definition to provide
additional clarity.

In response to comments that it was not clear as to what Demand data was subject
to the proposed standard, the standard drafting team developed a definition for
Total Internal Demand.

A commenter stated that the purpose statement and the title of the proposed
standard only referenced Demand data but the requirement also requested energy
data. In response, the standard drafting team modified the title as well as the
purpose statement to address their concern. The standard drafting team also
modified the Purpose Statement to remove ambiguity and provide clarity that the
intent of the standard is to define the responsibilities of both the requestor of the
data and the respondent to the request as well as the data that could be requested.

Requirement R1
x

The standard drafting team modified the Requirement R1 to clarify the entities
that may request data and the types of data such entities could request.

A commenter stated that Requirement R1 was open ended such that the data being
requested may not be able to be collected within the time allowed. In response,
the standard drafting team modified the requirement to limit the data that could be
collected to only that which was outlined in the sub-parts. The standard drafting
team also modified the language to allow for “any or all” of the data to be
requested.

The standard drafting team modified the language in the sub-parts to provide
additional clarity as to the type of data being requested.

The standard drafting team removed the sub-requirement for an entity to identify
entities within their footprint that were not part of their region.

Requirement R2
x

The standard drafting team modified Requirement R2 to clearly identify to whom
the data owners should respond to for data requests developed under Requirement
R1.

The standard drafting team removed the language from Requirement R2 allowing
other neighboring entities to request data as it was felt that there were ambiguity
in the language concerning who was requesting data and what data could be
requested. The standard drafting added a new requirement (Requirement R4) to

address this issue and clearly identify the neighboring entities that could request
data.
Requirement R3
x

The standard drafting team modified the language in Requirement R3 to clearly
state that the Planning Coordinator or Balancing Authority had an obligation to
provide data collected to the Regional Entity when the Regional Entity requested
the data.

The standard drafting team added a minimum time frame for responding to a data
request from a Regional Entity.

Requirement R4
x

The standard drafting team removed the language from Requirement R2 that dealt
with allowing neighboring entities the right to request data and created
Requirement R4 to allow for this situation.

C. Second Posting
Proposed Reliability Standard MOD-031-1 was posted for a second 45-day formal
comment period from October 9, 2013 through November 22, 2013. There were 43 sets of
responses, including comments from approximately 144 different people from approximately 94
companies representing 9 of the 10 industry segments. The proposed Reliability Standards
received a quorum of 80.54% and an approval of 57.59%.
The standard drafting team considered stakeholder comments regarding proposed
Reliability Standard MOD-031-1 and made the following modifications based on those
comments:
Purpose Statement and Definitions
x

In response to comments regarding the NERC Glossary term Demand Side
Management (DSM), the standard drafting team revised the definition to provide
clarity that DSM can be achieved through a request or other means such as
incentive programs or a market signal/mechanism.

The standard drafting team made modifications to the definition of Total Internal
Demand to provide additional clarity.

The standard drafting team modified the purpose statement to clarify the
reliability purpose of the standard. Specifically, the standard drafting team
modified the purpose statement to reflect that the standard provides authority for
entities that may otherwise lack authority to collect the specific reliability data.

Requirement R1
x

In response to comments concerning the use of the term “may” within the
requirement, the standard drafting team modified the requirement.

The standard drafting team modified the requirement to include the term
“calendar year”.

The standard drafting team removed the footnote related to PC/BA areas.

The standard drafting team modified the requirement to clearly identify that only
those entities whose Demand varies due to weather-related conditions would need
to provide weather normalized data.

Requirement R2
x

The standard drafting team modified Requirement R2 to clearly identify
applicable Entities that would be responsible for responding to a data request.

Requirement R3
x

In response to comments that the second sentence in the requirement did not
provide any additional clarity, the standard drafting team modified the
requirement and removed the sentence.

Requirement R4
x

In response to comments disagreeing with having LSE or DP be compliant with
Requirement R4, the standard drafting team modified the requirement. The
standard drafting team revised the requirement to remove the LSE and DP from
those entities that can request data but they would be required to provide data on
request.

D. Third Posting
Proposed Reliability Standard MOD-031-1 was posted for a 45-day public comment
period from February 25, 2014 through April 10, 2014. There were 33 sets of comments,
including comments from approximately 119 different people from approximately 73 companies

representing 9 of the 10 industry segments. The proposed Reliability Standards received a
quorum of 76.92% and an approval of 83.40%.
The standard drafting team considered stakeholder comments and made no revisions to
the proposed Reliability Standard MOD-031-1 based on those comments.
E. Final Ballot
Proposed Reliability Standard MOD-031-1 was posted for a 10-day final ballot period
from April 25, 2014 through May 5, 2014. The proposed Reliability Standards received a
quorum of 80.37% and an approval 90.00%.
F. Board of Trustees Approval
Proposed Reliability Standard (MOD C) MOD-031-1 was approved by NERC Board of
Trustees on May 6, 2014.

Record of Development

If you have any questions, please contact [email protected].

Although a pure data reporting standard would be a candidate for retirement under Paragraph 81, the data being collected has a reliability purpose in the
development of future assessments for resource adequacy. It was decided to present a pro forma standard that consolidates the remaining five MOD C standards
into a single standard. Creating a single standard provides a means of ensuring data will be collected and shared among the necessary parties (LSEs, BAs, TPs,
etc.) in both the United States and Canada.

NERC initiated an informal development process to address directives in Order No. 693 to modify certain aspects of the MOD C standards. The first informal
meeting was held in February 2013 at NERC’s Washington, D.C. office. Participants were industry subject matter experts (SMEs), NERC staff, and staff from
FERC’s Office of Electric Regulation. The small ad hoc group of SMEs participated in discussions about the outstanding FERC directives and possible resolutions to
address the directives. The group also discussed the six standards (MOD-016 through MOD-021) and identified issues with the present standards. The group very
quickly identified MOD-020 as dealing with the operational time frame and concluded that it should not be addressed with the other standards at this time since
they were applicable to the planning horizon.

Background:
NERC Reliability Standards MOD-016, -017, -018, -019, and -021 (referred to herein as the “MOD C” standards), were approved in the Federal Energy Regulatory
Commission’s (“FERC” or “Commission”) Order No. 693. Collectively, the MOD C standards pertain to the collection of data necessary to analyze the resource
needs to serve peak demand while maintaining a sufficient margin to address operating events as follows:
xMOD-016-1.1 - Documentation of Data Reporting Requirements for Actual and Forecast Demands, Net Energy for Load, Controllable
Demand-Side Management
o Is the umbrella standard that contains the documentation required for the data collection requirements.
xMOD-017-0.1 - Aggregated Actual and Forecast Demands and Net Energy for Load
o Provides for the data requirements for actual and forecast peak demand and net energy for load.
xMOD-018-0 - Treatment of Nonmember Demand Data and How Uncertainties are Addressed in the Forecasts of Demand and Net Energy for Load
o Provides for the treatment of nonmember demand data and how uncertainties are addressed in the forecasts of demand and net energy for load.
xMOD-019-0.1 - Reporting of Interruptible Demands and Direct Control Load Management
o Provides for the collection of interruptible demands and direct control load management.
xMOD-021-1 - Documentation of the Accounting Methodology for the Effects of Demand-Side Management in Demand and Energy Forecasts
o Provides for the documentation of how Demand-Side Management demands are accounted for in demand and energy forecasts.

Status:
A final ballot for MOD-031-1 – Demand and Energy Data concluded at 8 p.m. Eastern on Monday May 5, 2014. The standard achieved a quorum and
received sufficient votes for approval. Voting statistics can be found via the link below. The standard will be submitted to the Board of Trustees for adoption and
then filed with the appropriate regulatory authorities.

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MOD-031-1 — Demand Data

Standard Development Timeline

This section is maintained by the drafting team during the development of the standard and will
be removed when the standard becomes effective.

Development Steps Completed
1.

Description of Current Draft
This is the first posting of the proposed draft standard. This proposed draft standard will be
posted for a 45-day formal comment period.
Anticipated Actions

Anticipated Date

45-day SAR Informal Comment Period

July/August 2013

45-day Comment Period with Parallel Initial Ballot

July/August 2013

Recirculation ballot

October 2013

BOT adoption

November 2013

Draft #1: July 18, 2013

Page 1 of 11

MOD-031-1 — Demand Data

Effective Dates
MOD-031-1 shall become effective on the first day of the first calendar quarter that is twelve
months beyond the date that this standard is approved by applicable regulatory authorities.
In those jurisdictions where regulatory approval is not required, MOD-031-1 shall become
effective on the first day of the first calendar quarter that is twelve months beyond the date this
standard is approved by the NERC Board of Trustees, or as otherwise made effective pursuant to
the laws applicable to such ERO governmental authorities.

Version History

Version

Date

TBD

Draft #1: July 18, 2013

Action

Change
Tracking

Adopt MOD-031-1

Page 2 of 11

File Type	application/pdf
File Title	MOD-031-1 NERC petition long.pdf
Author	Phillip Yoffe
File Modified	2015-02-27
File Created	2015-02-27