MOD-032 in the CAISO Footprint: Four Joint Processes, One Standard

How Southern California Edison, Pacific Gas and Electric, San Diego Gas & Electric, and Valley Electric Association implement NERC Reliability Standard MOD-032-1 with the California ISO — what is common, what differs, and what Generator Owners and Transmission Owners must deliver, when, in what format, and to whom

Executive Summary

NERC Reliability Standard MOD-032-1, Data for Power System Modeling and Analysis, is short: four requirements and a one-page attachment. Its purpose is to make sure that every steady-state, dynamics, and short-circuit model used to plan the bulk power system is built from data that the owners of the equipment actually supplied, in a format the planners can use, on a schedule that keeps the interconnection-wide cases current. The standard does not say what the data must look like. It delegates that to each Planning Coordinator and its Transmission Planners, who must jointly write the data requirements and reporting procedures for their planning area and post them where the data owners can find them.

In the California ISO footprint, the CAISO is the Planning Coordinator and Balancing Authority, and each Participating Transmission Owner is a Transmission Planner for its own system. The result is not one CAISO MOD-032 document but a family of joint process documents, one for each PTO. This guide examines the four that govern the largest share of generation and transmission in the CAISO area: the CAISO–SCE process (Version 1.8, December 2024), the CAISO–PG&E process (Version 7.0, July 2024), the CAISO–VEA process (Version 5.0, effective November 2025), and the CAISO–SDG&E process (Version 5, July 2026). Together they run to roughly 175 pages, and a Generator Owner with plants in more than one service territory, or a Transmission Owner interconnecting across a PTO boundary, must satisfy each of them.

The four documents share a common skeleton. All rely on the WECC Data Preparation Manual for the modeling rules themselves. All require data in GE PSLF format, apply the same 10 MVA individual and 20 MVA aggregate modeling thresholds, require steady-state and dynamic data to agree, and populate the CAISO market resource ID in the generator Long ID field. All incorporate the CAISO Transmission Planning Process Business Practice Manual Section 10 generator data review, under which the CAISO validates each generator's package, issues a compliance letter, and hands the validated data to the PTO within 60 days so it can be submitted to WECC in the next base case request. All repeat the 13-calendar-month submission ceiling, the written-confirmation shortcut for unchanged data, the CAISO Tariff Section 25.5 notice of 90 days before modifying a generating facility, the FAC-014-3 Requirement R6 tie between planning ratings and operating ratings, the CAISO sign-off sheet for WECC base case review, and four-year evidence retention.

The differences are in the details that determine whether a submission is accepted or bounced. The four PTOs sit in three different WECC areas with two different Area Coordinators. Their annual data deadlines fall in different months: November 15 for PG&E, February for VEA, and the end of the calendar year for SCE and SDG&E. Short-circuit data is required in ASPEN format by PG&E, is not part of the routine submittal at VEA and SDG&E, and is accepted in ASPEN or CAPE by SCE when it is not native to PSLF. The criteria for modeling a future generator range from "in construction" at PG&E to "executed interconnection agreement" at VEA to SDG&E's explicit statement that an executed GIA alone is not sufficient. Each PTO has its own base case architecture, its own internal source documents for ratings and voltage criteria, its own bus and zone ranges, and its own review checklist.

This guide walks through the standard, the CAISO structure, the common core, the differences, the end-to-end obligations of a Generator Owner and of a Transmission Owner, the WECC base case cycle and Anchor Data Set, the traps and internal inconsistencies we found in the documents, and closes with how Keentel Engineering supports Generator Owners and Transmission Owners through the MOD-032 and BPM Section 10 process, followed by a 25-question FAQ.

1. MOD-032-1 in Brief: What the Standard Requires

MOD-032-1 has four requirements. Requirement R1 obliges each Planning Coordinator and each of its Transmission Planners to jointly develop steady-state, dynamics, and short-circuit modeling data requirements and reporting procedures for the PC's planning area. The procedures must cover the data listed in Attachment 1, specify the data format, the level of detail to which equipment is modeled, the case types or scenarios to be modeled, and a schedule for submission of data at least once every 13 calendar months, and they must be distributed or posted so that the entities responsible for providing the data can find them. The four CAISO joint process documents are the R1 deliverable.

Requirement R2 turns the obligation around. Each Balancing Authority, Generator Owner, Load Serving Entity, Resource Planner, Transmission Owner, and Transmission Service Provider must provide steady-state, dynamics, and short-circuit modeling data to its Transmission Planner and Planning Coordinator according to the R1 procedures. Requirement R3 governs disputes: when the PC or TP gives written notice of a technical concern with submitted data, including the technical basis for the concern, the data owner must respond within 90 calendar days with either corrected data or a technical justification for keeping the existing data. Requirement R4 requires the PC, or its designee, to make models for its planning area available to the Electric Reliability Organization or its designee to support creation of the interconnection-wide cases. In the Western Interconnection that designee is WECC, and the models are delivered through WECC's annual base case compilation.



Attachment 1 is the minimum data list, organized in three columns and tagged with the functional entity responsible for each item. The steady-state column covers buses (TO), aggregate demand (LSE), generating units including real and reactive capability, station service, regulated bus and voltage set point, machine MVA base, step-up transformer, and type (GO, and RP for future planned resources), AC lines (TO), DC systems (TO), transformers including tap data (TO), shunt reactive compensation (TO), and static VAR systems (TO). The dynamics column covers generator, excitation system, governor, and power system stabilizer models (GO/RP), demand (LSE), wind turbine and photovoltaic data (GO), SVS and FACTS (GO/TO/LSE), and DC system models (TO); where a user-written model is substituted for a library model, block diagrams, parameter names and values, and a list of state variables must accompany it. The short-circuit column requires positive, negative, and zero sequence data for every applicable steady-state element (GO/RP/TO) and mutual line impedance data (TO). Every column ends with "other information requested by the PC or TP necessary for modeling purposes," which is the hook that lets a PC ask for more than the minimum.

Two features of the standard shape everything that follows. First, MOD-032 is a data-delivery standard, not a model-quality standard. Whether a generator's dynamic model actually matches the machine is the province of MOD-026 and MOD-027, whether its real and reactive capability has been verified is MOD-025, and whether its protection settings coordinate with ride-through is PRC-019, PRC-024, and now PRC-029. But because the CAISO joint processes fold the BPM Section 10 validation into the MOD-032 data path, a Generator Owner in California cannot in practice satisfy MOD-032 without a package that also satisfies those model-quality standards. Second, the standard names WECC's interconnection-wide process as the target. The WECC Data Preparation Manual, the Master Dynamics File, the approved dynamic model library, the Area Coordinator structure, and the annual compilation of roughly eleven base cases are therefore incorporated by reference into every CAISO document.

2. How the CAISO Organizes MOD-032: One Planning Coordinator, Four Joint Processes

The CAISO is the registered Planning Coordinator and Balancing Authority for the CAISO Balancing Authority Area. Each Participating Transmission Owner, defined as a Transmission Owner that has placed its facilities under CAISO operational control through a Transmission Control Agreement, acts as Transmission Planner for its own system. Rather than issuing a single PC-wide document, the CAISO has executed a separate joint process with each PTO, and each joint process also covers the non-PTO entities embedded in that PTO's WECC area. The four documents reviewed here are signed by the CAISO's Regional Transmission managers for the north and south and by the corresponding PTO planning managers, and each carries its own version history back to 2015, when MOD-032-1 became enforceable.

The geography matters for a data owner because it determines where the data goes and who compiles it. PG&E is its own Area Coordinator, so a PG&E-area Generator Owner's data travels GO → PG&E → WECC, with the CAISO copied and reviewing. SCE is the Southern California Area Coordinator, so an SCE-area GO's data travels GO → SCE → WECC. A VEA-area GO sends data to VEA, VEA submits to SCE, and SCE submits to WECC, so there are two Transmission Planner hand-offs before the data reaches the interconnection-wide case. SDG&E compiles its own Area 22 case and hands it to the Southern California Area Coordinator, and documents each upload to the CAISO with a screenshot. In every path the CAISO, as PC, reviews the area case during the WECC review window and issues comments on a standard sign-off sheet that the PTO must answer in writing.

3. What Is Common to All Four Processes

Underneath the different page counts and organizational styles, the four documents implement the same architecture. A Generator Owner or Transmission Owner that understands the common core has understood roughly three-quarters of every document.

3.1 The WECC Data Preparation Manual governs the modeling rules

Every joint process points to the latest approved WECC Data Preparation Manual as the source of the detailed modeling requirements, and every one says that where the process document and the DPM conflict, the DPM controls, with a short list of local exceptions. SCE reproduces the DPM data tables in its Appendix A; PG&E attaches the DPM as its Appendix B and lists exceptions; VEA and SDG&E incorporate it by reference. The DPM sections a data owner will actually use are the bus, generator, AC line, transformer, fixed and controlled shunt, load, DC line, and substation tables, the dynamic modeling procedure, and the contingency and Remedial Action Scheme file format.

3.2 GE PSLF is the format of record

All four require steady-state data in PSLF .epc or .sav and dynamics in PSLF .dyd. SDG&E accepts a text file where a submitter has no PSLF license, and PG&E notes that non-licensees may obtain the PSLF model documentation from the vendor under a non-disclosure agreement. In practice a Generator Owner's package is expected to initialize cleanly in PSLF, and the BPM Section 10 acceptance test requires screenshots proving the .epc and .dyd files initialize with a real and reactive power spread of less than 1 MW/MVAr or 1 percent over a ten-second no-disturbance run. PowerWorld and PSS/E models are useful for the owner's own studies but do not satisfy the CAISO submittal.

3.3 The 10 MVA / 20 MVA / 60 kV modeling thresholds and the collector-based exception

The DPM rule, restated in each document, is that an individual generating unit of 10 MVA or larger connected at 60 kV or higher must have its own steady-state and dynamic model; an aggregate of 20 MVA or larger at 60 kV or higher must be modeled by unit unless it is a collector-based facility, in which case wind, solar, and storage plants may be represented as a single-unit or multiple-unit equivalent generator behind an equivalent pad-mount transformer, an equivalent collector system, and the main step-up transformer, following the WECC wind and PV power plant modeling guides. Facilities below 10 MVA, or connected below 60 kV, may be modeled explicitly or aggregated. Utility-scale DER of 10 MVA or larger is modeled explicitly on the low side of its transformer with a dynamic model; smaller U-DER and all retail-scale DER go into the distributed-generation fields of the composite load model. Retired units may be deleted or have their unit ID changed to "R*".

3.4 Steady-state and dynamic data must agree

Bus number, bus name, unit ID, bus voltage, and machine MVA base must be identical between the power flow and the dynamics record. Pmax in the power flow may not exceed the governor model's capability. The sub-transient reactance in the power flow record must match the machine model. The base-load flag must be consistent. Generator step-up transformers are modeled explicitly, never through the internal GSU fields of the generator record. Station service of 1 MW or more is an explicit load with ID "SS". These consistency rules are the most frequent source of review comments.

3.5 The CAISO market resource ID in the Long ID field

A requirement added to all four documents in 2023–2024 is that the CAISO market resource identifier for every Participating Generator be populated in the PSLF generator Long ID field and maintained by the PTO in coordination with the CAISO. This ties the planning model to the market model and to the CAISO's Section 10 category and phase tracking, and it is now a checklist item in every review.

3.6 The BPM Section 10 generator data review is the front door

Since 2019 the CAISO and the PTOs have operated a joint generator data review that implements Section 10 of the CAISO Transmission Planning Process BPM. A Generator Owner submits its data template and supporting package to the CAISO; the CAISO validates it and issues a compliance letter; within 60 calendar days of that letter the CAISO posts the complete validated package to a per-generator folder on the Market Participant Portal and notifies the PTO; the PTO then submits the validated PSLF data to WECC in response to the next WECC base case data request letter (or the second one, if the first is due within 60 days); and both the CAISO and the PTO check during WECC review that the validated data actually made it into the compiled case and the Master Dynamics File. The validated package is the same in all four documents: equipment data including short-circuit data, the steady-state model in .epc, the dynamic model in .dyd, a single-line diagram, the real and reactive capability test report, the dynamic model validation test report, and an electromagnetic transient model where sub-synchronous resonance or other EMT studies apply.

All four documents also carry the same EMT exception: if the only element of the package that has not been received or validated is the EMT model, the PTO proceeds to submit the validated PSLF power flow and dynamic data to WECC rather than hold the whole package. SCE's version is slightly narrower in that SCE updates the master base case with the validated power flow data in that circumstance.

3.7 The 13-month clock, the unchanged-data confirmation, and the 90-day tariff notice

Every document restates the R1.2.4 rule that data be submitted at least once every 13 calendar months, and three of them (SCE, PG&E, SDG&E) translate it as "by the end of each calendar year, but not to exceed 13 months between submissions." All four accept a written confirmation that nothing has changed in place of a re-submission. All four remind Generator Owners that CAISO Tariff Section 25.5 requires notice to the CAISO and the PTO at least 90 calendar days before modifying a generating facility, which routes through the Generator Management BPM's material modification process and, where the change alters the model, back into Section 10.

3.8 FAC-014-3 Requirement R6: planning ratings must match operating ratings

Each document was amended in 2024 to state that the facility ratings, including their applicable time durations, that a Transmission Owner provides for planning models and the CAISO Transmission Register must be consistent with the ratings it provides to its Transmission Operator and RC West under the RC's System Operating Limit methodology and the CAISO Planning Standards, unless a technical rationale is provided. For a Transmission Owner this means that a rating change made for operations must flow into the planning submittal in the same cycle, and that the eight seasonal normal and emergency ratings in the model must be traceable to the same source as the operating ratings.

3.9 CAISO review, the sign-off sheet, and four-year evidence retention

During each WECC base case review window the CAISO reviews the PTO's area data and returns a case review sign-off sheet, a table of numbered deficiencies with recommended changes and a column for the PTO's response. The PTO must respond in writing, either confirming the change or explaining with a technical basis why the data stands, which is the R3 mechanism applied at the PTO level. The sheet flows PTO → Area Coordinator → WECC. All four documents commit the parties to retain compliance evidence for at least four years: the joint process itself and its posting, data request letters, correspondence establishing each entity's system representation, WECC submittal confirmations, review comments and responses, and signed checklists.

3.10 The CAISO review checklist, DER modeling, and the Anchor Data Set

VEA and SDG&E reproduce the CAISO's WECC base case review checklist, and SCE's Appendix C and PG&E's Appendix C perform the same function in a different layout. The checks are consistent: approved projects modeled at their latest in-service dates and cancelled projects removed; known outages of six months or longer modeled, with a footnote that TPL-001-5.1 planning assessments include outages by methodology rather than duration; ratings MVA1 and MVA2 greater than zero and no branch above 100 percent; Pmin below Pmax and Qmin below Qmax; reactive resources at reasonable output; validated Section 10 generator data present and interconnection facilities modeled to the point of interconnection; loads consistent with the CEC forecast and station service tagged "SS"; the .dyd initializing without errors and no missing generator models; the full WECC loop present; PSLF "dchk" clean against the NERC quality metrics; interties modeled as real facilities rather than fictitious generators; area swing within limits and outside the study area; and interchange summing to zero. All four adopt the same DER rule: in-front-of-the-meter DER as an aggregated generator, behind-the-meter self-generation as the DG component of the composite load model. And all four commit to coordinating the ten-year-out heavy summer case with the CAISO so that the WECC Anchor Data Set reflects the most recent CAISO transmission plan.

4. Where the Four Processes Differ

The differences fall into two groups: operational details a data owner must get right for a specific PTO, and structural differences in how each PTO builds and maintains its base cases. The comparison table covers the first group; the sections that follow describe each PTO's architecture.

4.1 SCE: master base cases and the Generation Interconnection Data Depository

SCE's process is built around two master base cases, a one-year-out and a five-year-out case, kept by a Regional Planning "master base case keeper." Every WECC base case and every Annual Transmission Reliability Assessment case is derived from a master case, and every discrepancy found during ATRA or generation interconnection work is routed back to the keeper by an email change request with EPC, EPCL, or DYD evidence attached. Generation interconnection planners maintain a Generation Interconnection Project Data Depository that is updated every time an interconnection customer supplies data at the interconnection request, modification, preliminary engineering, final engineering, and as-built stages, and they are responsible for reviewing the initial design, final engineering, and as-built data the customer supplies under its interconnection agreement. Any new or modified Remedial Action Scheme associated with a generation project must be reported in the WECC RAS file format. SCE's Appendix A reproduces the DPM data tables with SCE-specific sources: line ratings from the CAISO Transmission Registry, transformer ratings from SCE SOB No. 33, line impedances from SCE's Line Impedance Database, voltage criteria from SOB No. 17. SCE is the only PTO that reserves the right to extend WECC due dates by up to 15 calendar days.

4.2 PG&E: the four-round annual cycle and the Area Coordinator role

PG&E structures its year as four rounds running from October to May. Round 0 updates the prior cycle's starting case to present-day topology. Round 1 builds the Year 0 summer case with everything in service by June 1. Round 2 builds the next ten years, one on top of the other, adding CAISO-approved capacity projects, maintenance projects, generation, and load interconnections. Round 3 creates area 1-in-10 peak cases, full-loop cases for the CAISO and for dynamics, and non-peak cases such as spring high-hydro and evening no-solar scenarios. The full-loop case is made by cutting PG&E's area out of a representative WECC case and stitching the updated PG&E model in. PG&E is Area Coordinator for Area 30, so its Transmission Planner receives the WECC request letter, adjusts the TPP case, solicits municipal updates, coordinates tie flows with the north (ColumbiaGrid) and south (SCE), runs the WECC data checks (checkazo.p, Replog.p), reads in the latest masterg.dyd, and compiles the Load and Resource spreadsheet for WECC. PG&E's distinctive data asks are Qmax and Qmin at Pmin in text form (the model assumes the Pmax values, which is conservative), the number of no-load tap changer positions, and short-circuit data in ASPEN. PG&E uses load IDs "EE" for energy efficiency, "FS" for fuel substitution, "TE" for transportation electrification, and "D0/D1/D2" for demand response programs, and it names queued generator buses by their CAISO queue number with TP, SS, C1, and C2 suffixes until the project is operational.

4.3 VEA: a small Transmission Planner under the SCE Area Coordinator

Valley Electric Association is a Nevada cooperative whose transmission is under CAISO operational control; GridLiance West is a Transmission Owner within its territory. VEA's document is the shortest and the most prescriptive about what each functional entity must provide, with separate steady-state, dynamics, and short-circuit tables for the LSE, the Participating Generator Owner, and the Transmission Owner. Data owners submit during February for the ten years following the request. VEA validates and submits to SCE, copying the CAISO, and SCE carries the data to WECC. VEA uses a five-status project matrix — Conceptual, Proposed, Planned-Funded, In Service, Corrections — and models only the last three; for a generator, Planned-Funded means an executed Generator Interconnection Agreement with network upgrades. VEA is explicit about protection: generic relays are applied in simulation, but detailed models are required for the voltage and frequency ride-through capability of any generating facility that has it, for three-phase overcurrent relays where they are the primary protection, and for any relay the DPM requires. Dynamics are simulated over 0–20 seconds at a quarter-cycle step, and a detailed generator model must include the machine, exciter, governor, PSS, line-drop compensation, over-excitation limiter, and ride-through relays unless the device is absent or inactive. Short circuit is calculated in PSLF from the base case; VEA provides ASPEN data on request but does not submit separate files, noting that WECC does not build interconnection-wide short-circuit cases.

4.4 SDG&E: Grid Assessment base cases, operating standards, and the resource level system

SDG&E's Version 5, issued in July 2026, is the most recently revised of the four and the only one that is also explicitly written to support WECC's Anchor Data Set process. SDG&E builds Grid Assessment base cases annually across a scenario matrix — summer peak 1-in-10, spring off-peak near 75 percent, spring light load near 10–15 percent, winter peak near 85 percent, summer off-peak near 80 percent — with sensitivities for maintenance, stressed flows south and north of San Onofre, storage charging in load pockets, and heavy renewables with minimum gas. Its load model carries seven components per bus: the non-coincident distribution forecast ("Pk"), the coincident forecast scaled to the CEC 1-in-10 ("10"), and five CEC load modifiers for energy efficiency, transportation electrification, fuel substitution, data centers, and known loads. Ratings, voltage criteria, and reactor settings come from SDG&E Grid Operations documents (TMC1015a, TMC1005, TMC1105a, TMC1005c), impedance changes from Protection Engineering, and outage status from a long-term outage plan issued every two weeks. SDG&E maintains a single continuously updated Master Dynamics File rather than per-case .dyd files. Its resource inclusion rule is the strictest: Level 1 operational, Level 2 on the CPUC in-development list or with commenced construction or a PPA, and Level 3 generic IRP resources only in year 6 and beyond, with the statement that an executed GIA alone does not qualify. SDG&E's GO standards list adds PRC-029 to the MOD-025/026/027 and PRC-019/024 list the other three carry, and SDG&E commits to evaluating MOD-025-driven changes for materiality and notifying the CAISO when they are material.

5. The Generator Owner's Obligations, End to End

For a Generator Owner the four documents collapse into one sequence with a few PTO-specific parameters. The sequence begins before commercial operation and never ends.

5.1 The Section 10 categories

The CAISO sorts Participating Generators into five categories that determine the data template and the depth of testing evidence. Category 1 is Bulk Electric System units above 20 MVA individually or 75 MVA in aggregate; Category 2 is units at 60 kV and above that exceed 10 MVA individually or 20 MVA in aggregate but are not Category 1; Category 3 is 60 kV-and-above units below those thresholds; Category 4 is sub-60 kV resources that are individually modeled; Category 5 is sub-60 kV resources that are aggregated. Categories 1 and 2 must supply test reports verifying excitation, governor, and reactive capability, dated within ten years for dynamics and five years for capability, together with control–protection coordination documentation and, where applicable, geomagnetic disturbance and SSR/EMT data. Categories 3 and 4 supply manufacturer dynamic models from the WECC approved library and ride-through demonstrations under IEEE 1547 and Rule 21. The CAISO publishes a resource-ID-to-category list and three data templates.

5.2 The EMT dimension

The CAISO published Electromagnetic Transient Modeling Requirements in April 2021 and, in August 2026, an Inverter-Based Model Validation Procedure and an IBR Dynamic Model Review Guideline. For inverter-based resources the practical effect is that the Section 10 package increasingly includes a PSCAD model and evidence that the PSLF positive-sequence model has been benchmarked against it, in the same spirit as the PJM, ERCOT, and MISO EMT model requirements. The joint processes anticipate this: all four carry the EMT exception so that PSLF data can proceed to WECC while EMT validation continues, but none of them relieves the GO of delivering the EMT model.

6. The Transmission Owner's Obligations, End to End

Transmission Owners in the CAISO area fall into three groups with different burdens. The four PTOs are Transmission Owners and Transmission Planners at once and carry the full base case development obligation described in Section 4. Non-PTO Transmission Owners embedded in a PTO's WECC area — the southern California municipal utilities, MWD, CDWR, the northern municipalities, GridLiance West, Trans Bay Cable — provide their models and Loads-and-Resources data to the PTO on the WECC schedule and answer the PTO's and CAISO's review comments. Merchant transmission and generator-owned interconnection facilities are Transmission Owner data for the lines, transformers, and substations from the generator to the point of interconnection, and SDG&E's document adds a coordination step with SCE for merchant substations.

For a non-PTO Transmission Owner the operational rhythm is set by the WECC compilation schedule rather than by a fixed calendar date. Each WECC data request letter triggers a request from the Area Coordinator for the TO's interchange, pump load, load, and generation dispatch for the Loads-and-Resources spreadsheet and for any network model changes; each WECC review letter triggers a request for review comments. SCE's Appendix B walks through this for MWD, CDWR, VEA/GLW, and the cities, and PG&E's Appendix C does the same for the northern municipalities. The TO's evidence is the email trail: the request, the data, the confirmation of receipt, and the review response.

7. The WECC Base Case Cycle and the Anchor Data Set

WECC compiles approximately eleven base cases a year: about five operating cases for the following year (heavy and light summer, heavy and light winter, heavy spring) and several planning cases at the five- and ten-year horizons, typically heavy summer and heavy winter with variations. Each case runs through the same three-stage cycle, and each of the four joint processes describes its part of it.

The Anchor Data Set is WECC's ten-year-out heavy summer compilation of load, resource, and transmission topology used by the Western Planning Regions for regional plans and by production-cost and power-flow modelers alike. Because it must reflect statutory public policy such as the RPS and align with the most recent regional plan, the CAISO joint processes require that the ten-year WECC heavy summer case submitted under MOD-032 be coordinated with the CAISO's own ten-year TPP case, including the CPUC IRP portfolio resources, behind-the-meter PV, the CEC load modifiers, and demand response. VEA supplies incremental change files against the WECC seed case; SDG&E aligns its year-6-and-beyond Level 3 resources with the ADS; SCE and PG&E carry the CAISO's additional-resource list into the ten-year case. For a Generator Owner the ADS is invisible but consequential: a project that is in the CPUC portfolio but not yet validated under Section 10 will be represented by a generic model in the ADS until the validated data arrives.

8. Traps and Inconsistencies We Found in the Source Documents

Reading the four documents side by side exposes a number of places where a diligent data owner could be caught out, and a few where the documents themselves are internally inconsistent. None of these rises to the level of a compliance defect in the documents, but each is worth knowing.

9. Keentel Engineering MOD-032 Services for Generator Owners and Transmission Owners

Keentel Engineering supports Generator Owners and Transmission Owners through the full MOD-032 and CAISO BPM Section 10 data path, from the first interconnection-study model to the annual confirmation and the audit binder. Our compliance practice produces the technical evidence itself — models, settings, ratings, test-report interpretation — as well as running the submittal process, and our power system studies practice delivers studies on PSLF, PSS®E, PSCAD/EMTDC, DIgSILENT PowerFactory, ASPEN OneLiner, and ETAP across 4 kV to 765 kV.



9.1 For Generator Owners

9.2 For Transmission Owners

Keentel's compliance scope covers the NERC Operations and Planning standards. CIP cyber security is a separate discipline that we coordinate with the client's own cyber team rather than perform. Field testing of generators for MOD-025, MOD-026, and MOD-027 is performed by accredited testing contractors; Keentel specifies the tests, witnesses where the client requests, and converts the results into the models the CAISO and WECC require.



To discuss a MOD-032 or Section 10 scope, contact Keentel Engineering at (813) 389-7871 or contact@keentelengineering.com, or schedule a 15-minute call at calendly.com/keentel-engineering/15min.

References and Further Reading

Primary sources are listed first. Links were current at publication in September 2026.

NERC and WECC

• NERC Reliability Standard MOD-032-1, Data for Power System Modeling and Analysis, including Attachment 1. North American Electric Reliability Corporation. www.nerc.com
• NERC Reliability Standards MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-2, PRC-024-3, PRC-029-1, and FAC-014-3 (Requirement R6). North American Electric Reliability Corporation.
• WECC Data Preparation Manual for Interconnection-wide Cases; WECC Approved Dynamic Model Library; WECC Generating Unit Model Validation Policy and Generating Facility Data, Testing, and Model Validation Requirements; WECC Wind Power Plant and PV Plant Power Flow Modeling Guides; WECC Anchor Data Set. Western Electricity Coordinating Council. www.wecc.org

CAISO joint process documents reviewed

• California ISO and Southern California Edison, Joint Transmission Planning Base Case Preparation Process, NERC Reliability Standard MOD-032-1, Version 1.8, December 9, 2024.
• California ISO and Pacific Gas and Electric, Joint Transmission Planning Base Case Preparation Process, NERC Reliability Standard MOD-032-1, Version 7.0, July 30, 2024.
• California ISO and Valley Electric Association, Inc., Joint Transmission Planning Base Case Preparation Process, NERC Reliability Standard MOD-032-1, Version 5.0, effective November 3, 2025.
• California ISO and San Diego Gas & Electric, Joint Transmission Planning Base Case Preparation Process for Compliance with NERC Reliability Standard MOD-032-1 and WECC's Anchor Data Set Process, Version 5, July 2026.
• All four are posted by the CAISO under Transmission Planning → Submittal Requirements – Data for Power System Modeling and Analysis MOD-032-1. www.caiso.com

CAISO business practice and modeling requirements

• California ISO, Business Practice Manual for Transmission Planning Process, Section 10, Generator Data Submittal Requirements (Sections 10.4.3, 10.4.6, 10.4.7); Resource Category and Phase list; Data Templates for Categories 1–2, 3–4, and 5. bpmcm.caiso.com and www.caiso.com/library
• California ISO, Electromagnetic Transient Modeling Requirements, April 2021; ISO Inverter-Based Model Validation Procedure, August 2026; Inverter-Based Interconnection Requests Dynamic Model Review Guideline, August 2026.
• California ISO Tariff Section 25.5 and Business Practice Manual for Generator Management (material modification process).

Frequently Asked Questions

Disclaimer

This document is published by Keentel Engineering for general technical information and educational purposes. It summarizes and compares publicly posted CAISO–PTO joint process documents and related NERC, WECC, and CAISO materials as they stood in September 2026. It is not a substitute for those documents, for the NERC Reliability Standards, or for the CAISO Tariff and Business Practice Manuals, all of which are revised periodically and control over any summary here. Readers must verify every requirement, deadline, address, and threshold against the current controlling document before relying on it.

Nothing in this document constitutes a compliance determination, legal advice, or engineering services for any specific facility. Whether a particular Generator Owner or Transmission Owner is compliant with MOD-032-1 or with CAISO requirements depends on facts specific to that entity and is ultimately determined by the Compliance Enforcement Authority and the CAISO.

Keentel Engineering provides electrical engineering and NERC Operations and Planning compliance support services. CIP cyber security is a separate discipline coordinated with the client's own cyber team. Field testing of generating units is performed by accredited testing contractors. Some analysis platforms and work scopes may be carried by Keentel's subconsultants under Keentel's direction; Keentel does not share its study methodologies, workflows, or tool configurations.

Keentel Engineering is not affiliated with, endorsed by, or sponsored by the California Independent System Operator, Southern California Edison, Pacific Gas and Electric Company, San Diego Gas & Electric Company, Valley Electric Association, the Western Electricity Coordinating Council, the North American Electric Reliability Corporation, or any software vendor named. PSLF, PSS®E, PSCAD, PowerFactory, ASPEN OneLiner, PowerWorld, ETAP, and CAPE are trademarks of their respective owners and are named for identification only; Keentel adopts no vendor performance claim.

Keentel Engineering makes no warranty, express or implied, as to the accuracy, completeness, or fitness for any purpose of the information in this document, and accepts no liability for any loss arising from its use.

State of Florida — Registry No. 36853, KEENTEL LLC, DBA: KEENTEL ENGINEERING. Copyright 1995–2026 Keentel Engineering. All Rights Reserved. This document is original work of Keentel Engineering and may not be reproduced, distributed, or adapted without written permission, except for brief quotation with attribution.