R5 Supporting Evidence and Documentation Each Transmission Planner 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. The turbine/governor and load control or active power/frequency control function model initializes to compute modeling data without error, A no-disturbance simulation results in negligible transients, and For an otherwise stable simulation, a disturbance simulation results in the turbine/governor and load control or active power/frequency control model exhibiting positive damping. If the is not usable, the Transmission Planner shall provide a technical description of why the model is not usable. 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. Question: Did the entity receive verified model information from a Generator Owner in accordance with Requirement R2 during the compliance monitoring period? Yes No If Yes, provide a list of the verified model information received and verify submission of evidence to demonstrate compliance. If No, provide a description of the process used to ascertain that verified model information was not received. [Note: A separate spreadsheet or document may be used. If so, provide the document reference below.] Registered Entity Response (Required): Compliance Narrative: Provide a brief explanation, in your own words, of how you comply with this Requirement. References to supplied evidence, including links to the appropriate page, are recommended.
Registered Entity Evidence (Required): The following information is requested for each document submitted as evidence. Also, evidence submitted should be highlighted and bookmarked, as appropriate, to identify the exact location where evidence of compliance may be found. File Name Document Title Revision or Version Document Date Relevant Page(s) or Section(s) Description of Applicability of Document Audit Team Evidence Reviewed (This section to be completed by the Compliance Enforcement Authority): Compliance Assessment Approach Specific to MOD-027-1, R5 This section to be completed by the Compliance Enforcement Authority Evaluate if the entity provided a written response to the Generator Review the list of received verified model information in accordance with R2 Verify the entity written responses to the Generator Owner state whether the model was “usable:” (5.1) The model initializes to compute modeling data without error, (5.2) A no-disturbance simulation results in negligible transients, and (5.3) For an otherwise stable simulation, a disturbance simulation results in the exhibiting positive damping. If model was “not usable,” verify the entity written response provided a technical description of why the model was not usable. Verify the response was provided within 90 calendar days or receiving the verified model information Note to Auditor: A “turbine/governor and load control” applies to conventional synchronous generators. An “active control” applies to inverter connected generators often found at variable energy facilities such as wind and solar farms. Auditor
“Technically Justified” Provision P 51. The Commission that “the technical justification provision is not workable in MOD-027-1 because there is more subjectivity involved in verifying the data pertaining to turbine/governors, the equipment subject to the modeling verification requirements of MOD-027-1.” The Commission stated that “determining whether the difference between a model response and a measured response reflects a model defect is subjective and, therefore, the technical justification provision is inappropriate for MOD-027-1.” Violation Severity Level for MOD-027-1, Requirement R5 P 57. The Commission summarized its concern expressed in the NOPR regarding the proposed violation severity for Requirement R6 of MOD-026-1 and Requirement R5 of MOD-027-1. Specifically, the Commission indicated that NERC did not propose any violation severity level for a violation of the last sentence of these requirements: “If the model is not useable, the [transmission planner] shall provide a technical description of why the model is not useable.” The Commission noted in the NOPR that compliance with this obligation is no less important than compliance with the other obligations of these requirements. The Commission further stated that the lack of a violation severity level for this type of violation is inconsistent with the Commission’s Violation Severity Level Guideline 3, because the proposed violation severity level does not address all of the obligations in these requirements. P 58. The Commission directed NERC to “submit a violation severity level that addresses a transmission planner’s obligation to provide a technical description of why a model submitted by a generation owner is not usable for Requirement R6 of MOD-026-1 and Requirement R5 of MOD-027-1.” Revision History for RSAW Version Date Reviewers Revision Description 1 06/12/2014 RSAW Task Force New Document