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FERC Order 902 Retires Six NERC Modeling, Data and Analysis (MOD) Reliability Standards

In 2017, the North American Electric Reliability Corporation (NERC) launched an effort to evaluate NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of standards and requirements. Considering that many standards have been mandatory and enforceable for 15+ years in North America, the project sought to identify potential candidate requirements that were not essential for reliability, could be simplified or consolidated, thereby reducing regulatory obligations and/or compliance burdens on applicable registered entities. NERC assembled a team of ERO Enterprise (NERC and the six Regional Entities) staff and industry representatives to complete the project.

As a result, NERC submitted a petition (Docket RM19-17-000) to the Federal Energy Regulatory Commission (FERC or Commission) in June 2019 to retire approximately 77 requirements in the INT, FAC, PRC, and MOD operations and planning Reliability Standards.

FERC issued Order 873 in September 2020, retiring 18 Reliability Standard requirements because of the SER project. In 2021, FERC issued Order 676-J that revised regulations to incorporate by reference (with certain exceptions) the latest North American Energy Standards Board (NAESB) Wholesale Electric Quadrant (WEQ) Business Practice Standards. Version 3.3 (WEQ-023) of the WEQ business standards include Communication Protocols for Public Utilities — requirements also enforceable under the NERC MOD A Reliability Standards.

On October 27, 2023, FERC issued Order 902 approving the retirement of the following six MOD A Reliability Standards and 56 related requirements, effective February 1, 2024:

  • MOD-001-1a Available Transmission System Capability
  • MOD-004-1 Capacity Benefit Margin
  • MOD-008-1 Transmission Reliability Margin Calculation Methodology
  • MOD-028-2 Area Interchange Methodology
  • MOD-029-2a Rated System Path Methodology
  • MOD-030-3 Flowgate Methodology

The Commission’s rationale for retiring the above standards was to incorporate the requirements into the NAESB WEQ-023 standards, citing that the MOD A regulations were:

  • Primarily administrative in nature
  • Redundant with other Reliability Standards
  • Related to commercial or business practices (specifically commercially focused elements facilitating interchange and balancing of interchange)
  • No longer serving a reliability purpose
  • Not resulting in a reliability gap because system operators already maintain reliability through monitoring Real-time flows based on System Operating Limits (SOLs) and Interconnection Reliability Operating Limits (IROLs).

Order 905 shifts some NERC modeling compliance responsibilities from MRO registered entities and redeploys these requirements to the NAESB Business Practice Standards. It also signals closure of NERC’s SER project related to operating and planning requirements.

Additional details and information can be found in the Federal Register: Electric Reliability Organization Proposal To Retire Requirements in Reliability Standards Under the NERC Standards Efficiency Review

Mark Buchholz, Compliance Manager, Western Area Power Administration, and member of MRO’s CMEP Advisory Council


Mark Buchholz graduated with a Bachelor of Science Degree in Electrical Engineering from South Dakota State University. Since that time, he has been employed with the U.S. Department of Energy, Western Area Power Administration (WAPA), serving in various operations and maintenance positions at: WAPA’s Headquarters Office in Lakewood, Colorado; the WAPA-Upper Great Plains Region (WAPA-UGPR) South Dakota Maintenance Office; the WAPA-UGPR Maintenance Engineering Office; and the WAPA-UGPR Watertown Operations Office.

Since May 2010, Buchholz has served as a Compliance Manager for WAPA’s Upper Great Plains Region. He is a member of the NERC Compliance and Certification Committee, MRO’s CMEP Advisory Council, the Mid-Continent Compliance Forum (MCCF) Steering Committee, MRO’s Performance Risk Oversight Subcommittee; and the Southwest Power Pool (SPP) Reliability Compliance Advisory Council.

Buchholz’s duties as Compliance Manager include providing technical expertise to WAPA management and employees on NERC Reliability Standard compliance issues as they relate to power systems operation and maintenance, transmission planning, physical security, and cybersecurity. He serves as WAPA-UGPR’s technical expert on the NERC Reliability Standards and provides internal guidance and outreach to WAPA employees on the interpretation and application of standards to ensure WAPA-UGPR meets compliance with the requirements of the NERC Standards applicable to its registrations in the Eastern and Western Interconnections. Buchholz’s duties also include oversight of the WAPA-UGPR System Operators Training Program and Facility Management of the Watertown Operations Office Complex.