On October 26, 2023, the Federal Energy Regulatory Commission (“Commission”) issued a Final Rule to retire 56 requirements from six different North American Electric Reliability Corporation (NERC) Reliability Standards. The retirement will go into effect on February 1, 2024. These Standards, often referred to as the MOD A Reliability Standards, consist of the following NERC Reliability Standards:
Overview of the Retired MOD Reliability Standards
- 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)
NERC Standards Efficiency Review – Background and Goals
This retirement concludes the last of the efforts identified under Phase 1 of the NERC Reliability Standards Efficiency Review Initiative that was first petitioned on June 7, 2019. NERC had assembled several working teams to identify potential compliance monitoring and enforcement efficiencies that could be achieved following the retirement or modification of various requirements from the INT, FAC, PRC, and MOD Reliability Standards families. Francis Esselman from PCS was an active contributor to one of these working teams. Under that initiative, NERC was able to retire 74 of 77 Reliability Standard requirements.
Commercial Implications of the Retired MOD Standards
The Commission was convinced that many of these requirements contained commercially focused elements facilitating interchange and frequency balance activities. These activities compliment, yet are independent, of reliability activities such as monitoring System Operating Limits and Real-time flows.
Overview of Related FERC Orders 676-J and WEQ-023
In 2021, the Commission did issue Order No. 676-J, a Final Rule that amended its regulations to incorporate by reference, with certain enumerated exceptions, the latest of the North American Energy Standards Board (NAESB) Wholesale Electric Quadrant (WEQ) Business Practice Standards. These standards are approved by an executive committee and adopted by WEQ members as mandatory enforceable requirements. The WEQ-023 Standard on Modeling addresses the technical issues that affect Available Transfer Capability (“ATC”) and Available Flowgate Capability (“AFC”) calculations for wholesale electric transmission services.
Using PCS’s SCIP Tool to Monitor NERC Standards
Clients of the PCS Standards Compliance Intelligence Portal (SCIP) were aware of the February 1, 2024, retirement a day after the announcement. SCIP is a web-based application that identifies standards in development and upcoming standards enforcement. The application is customized to each client’s needs and NERC registrations.
About Proven Compliance Solutions Inc.
Proven Compliance Solutions Inc. (PCS) provides a full range of consulting services regarding NERC and Regional Entity Reliability Standards. PCS continues to actively monitor how ongoing NERC initiatives and developments with each regulatory government agency, both the Commission in the United States and each Canadian province, can impact or potentially impact an entity’s Reliability Compliance Program. PCS is available to help entities navigate through the complexities of NERC Entity Registration and Compliance with
Reliability Standards, including those entities with Inverter-Based Resource (IBR) facilities that could become registered as Generator Owner Inverter-Based Resource (GO-IBR) or Generator Operator Inverter-Based Resource (GOP-IBR) by July 2026. For information on how PCS can support your organization’s NERC Reliability Standards compliance needs, please contact Dale Zahn at (509) 504-5496 or visit our website at www.provencompliance.com.
Frequently Asked Questions about FERC Order 902 and Retired MOD Standards
FERC Order No. 902 is a Final Rule that retires 56 requirements from six MOD Reliability Standards. The retirements took effect on February 1, 2024.
The order retires requirements from: MOD-001-1a, MOD-004-1, MOD-008-1, MOD-028-2, MOD-029-2a, and MOD-030-3 (the “MOD A” standards).
As part of NERC’s Standards Efficiency Review (Phase 1), the retired requirements were identified as commercially focused or duplicative of other controls, allowing compliance monitoring to be streamlined without undermining reliability.
Entities may see reduced compliance documentation and evidence burdens tied to MOD A requirements. However, they must still maintain reliability functions (e.g., monitoring System Operating Limits, real-time flows) and follow any applicable replacement guidance or related standards.
FERC Order 676-J incorporates updated NAESB WEQ business practice standards. WEQ-023 (Modeling) addresses technical inputs for ATC/AFC calculations used in wholesale transmission services—complementing reliability activities while covering commercial practice elements no longer in the MOD A set.
PCS’s Standards Compliance Intelligence Portal (SCIP) alerts clients to standards in development, upcoming enforcement, and changes like the MOD retirements, helping teams update procedures, evidence plans, and monitoring activities promptly.
Map retired MOD A evidence to current processes, update internal procedures and RSAW narratives as needed, confirm any dependencies on NAESB practices, and document how reliability monitoring continues without the retired requirements. Consider a targeted gap review or mock audit.
