Justified” Provision “Technically P 51. The Commission that technical justification provision is not workable in MOD-027-1 because “the 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 The 57. 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: the model is not useable, the [transmission planner] shall provide a technical description of “If 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 a violation severity level that addresses a transmission “submit 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
“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
RSAW%20MOD-027-1_2014_v1.docx