CIIIJ/UlIl Off~
775 Main Si. Easl, Suite IR
Millon, Ontario, Canada L9T 3Z3
Offce: (905) 875-2075
Fax: (905) 875-2062
ç;i
Aeumen Engineere Solutions International Ine.
Uiiiled Slles Offce
7(88) Central Par\way_ Suik 1475
Atlunta, Georgia, USA, 30328
Ollee: (678) 320-1895
Fax: (770) 522-8115
e-mail: acsì(itJ:aesí~jnc.com
website: ",ww.aesi-inc,cOln
January 8,2010
Mtre Paule Hamelin
Gowling Lafleur Henderson LLP
Barristers & Solicitors 1 Patent & Trade Mark Agents
1 Place Vile Marie, 37lh Floor
Montréal (Québec), H3B 3P4, Canada
Re: . Hydro-Québec Direction- Contrôle des mouvements d'énergie's
application for adoption of reliabilty standards for electrIc power
transmission in Québec and for approval of the registries identifying
entities and installations subject to reliabilty standards and sanction
guidelines
. Régie de l'énergie: R-3699-2009
Dear Madam:
This letter and attached report is to be submitted to the Régie de l énergie (the "Régie") on
behalf of Énergie La Lièvre S.Ec. ("Lièvre") in connection with its High Falls, Dufferin and
Masson hydro-electric facilities and related installations! (the "Installations").
The attached report conveys our findings, positions and opinions regarding installations that
are simIlar to Lièvre; those of Rio Tinto Alcan lnc.'s ("RTA"), which is a joint party to this filng
and has agreed to share our findings with Lièvre. Lièvre has throughout the Régie proceedings,
been a strong advocate of the concerns conveyed within the report and shares the same views as
RTA.
More specifically, this letter is to convey Lièvre' s continuing concerns with'
1 Refer ta section (a) of AtLachment A.
Page 1
a) the proposed definition of "Main Transmission System" (Réseau de transport
principalF ("RTP") that is to be used to establish the registries of entities and
installations subject to reliabilty standards and sanction guidelines3 (the "Registry")
as currently proposed ; and
b) the appropriateness of the proposed assignment of NERC4 functional model entities
with respect to Lièvre Installations, as proposed in HQCMÉ's application.
The author of this letter and accompanying report is an Associate of AESI Acumen Engineered
Solutions International Inc. (" AESI"). AESI has, with respect to HQCMÉ's application currently
before the Régie, been retained by Lièvre and RTA, individually and jointly, to review
applicable documentation pertaining to fie R-3699-2009 and to submit our findings, positions
and opinions on three major aspects of HQCMÉ's application:
i) the appropriateness of HQCME' s proposaI for the use of RTP to establish the Registry
an "Bulk Power System" (Réseau (( bulk ,,)5 ("BPS"), which is used by
Northeast Power Coordinating Council, Ine. ("NPCC")6;
rather th
ii) a comparison of this proposed reliability model to those used in other jurisdictions;
and
iii) an evaluation of the reliability standards which would be applicable to Lièvre's
Installations and the assessment of their applicability.
Issues that are crimm to both parties Installations.
ln furtherance of Lièvre' s endorsement of the attached report, AESI was requested to i) review
Lièvre's Installations to establish if a commonality regarding impact on BPS reliability between
the Installations exits and ii) if so, prepare this letler that is to be filed with the Régie in support
of our findings, positions and conclusions outlined in the RT A report to be applicable to
Lièvre' s Installations as weIL.
2 R-3699-2009, HQCMÉ-2, Document 4, Revised 2009-11-23, Section 2.1, at page 3;
R-3699-2009, HQCMÉ -2, Document 10, Revised 2009-11-04, at page 35.
3 R-3699-2009, HQCMÉ -2, Document 4, Revised 2009-11-04, "Registre des entités visées par les normes de
jiabili té"
4 North American Electric Reliability Corporation ("NERC").
5 HQCMÉ -2, Document 10, Revised 2009-11-04, at page 34.
6 Northeast Power Coordination Council ("NPCC") is one of the eight (8) Regional Entities in North
America and consists of the jurisdictions of Québec, Ontario, Maritimes, New York and New England.
Page 2
Our review has concluded that the Lièvre Installations are clearly not, and cannot be construed
as being part of, the bulk power system ("BPS") of Québee. Therefore the opinions and
positions articulated in the attached report, created initially for RT A, equally apply to Lièvre' s
Installations with the necessary adaptations. More precisely and without limitation, the sections
of the report pertaining to the analysis of the use of BPS as opposed to RTP and the question of
the application of NERC reliability standards to the Installations equally apply to Lièvre, again
with the required adaptations. While HQCMÉ does not disagree with the fact that Lièvre's and
RT A' s Installations are not BPS, it is proposing to the Régie to extend the reach of the
NERC/NPCC CMEP umbrella to all facilities encompassed by its RTP definition.
As concluded in the report, HQCMÉ' s assertion that RTP facilities such as these Installations be
required to be subjected to QCMEP cannot be supported both on a technical analysis and a
comparative basis with the other NPCC Canadian jurisdictions.
We are concerned and support the view that extending the immensely administratively
burdensome program requirements under the NERC/NPCC CMEP umbrella, and its related
sanctions, to facilities that have NO impact to the BPS wil be costly, wil serve little benefit to
improving reliability and wil needlessly increase risks. ln addition, it wil tie up limited
resources that are already in short supply; these resources would be better served if focussed on
reliabilty matters that do have a direct impact to the reliability of the BPS.
Lièvre fully appreciates and understands the importance of, and remains committed to, helping
assure the reliability of its network and its interconnections with HQT and Ontario. It continues
to be our opinion that Québec and its customers would be better served if local area reliability
matters remained with HQCMÉ and was managed locally as per the existing practise.
ln conclusion, it is our view that extending the reach of NPCC and NERC enforcement
programs (CMEP) to RTP facilities, such as the Installations of Lièvre and RT A, is a substantial
expansion of scope and unwarranted departure from the original intent of the reliabilty
standards and the ERO's mandate, which is to main
tain the reliabilty of the interconnected
BPS.
Therefore, we respectfully submit to the Régie that:
Page 3
i) the defimtion of RTP should not be used for establishing the Registry;
ii) Lièvre and its Installations should not be designated as NERC functional model
entities, for purposes of monitoring and auditing by NPCC under QCMEP.
iii) The entities and their BPS installations that would be subject to the Québec reliability
standards and NPCC criteria should be distinguished, in the Registry, from the entities
and their non-BPS installations that would be subject to non-BPS reliability related
requirements and managed locally by HQCMÉ; and
iv) a two (2) tier QCMEP approach be implemented similar to other NPCC Canadian
jurisdictions (Ontario and New Brunswick).
Respectfully:
08/01/2010
x
~J
:f/.1fi
Ronald J. Falsetti, P.Eng.
Associate Senior Consultant
AESI Acumen Engineered Solutions International Inc.
775 Main Street East, Suite 1 B, Milton, Ontario, L9T 323
AESI-US Inc.
7000 Central Parkway, Suite 1475, Atlanta, Georgia, 30328
rjf alsetti (!cogeco. ca
Phone: (905) 469-2376
Mobile: (289) 888-1801
www.aesi-inc.com
Page 4
Attachmenl A
(a) Lièvre' s Installations
Lièvre's electricity generation in the Gatineau region consists of four (4) power plants, one (1) at
High Falls (109 MW), one at Masson (105 MW) one (1) at Dufferin (40 MW) and a small
embedded power plant, Rapide-des-Cèdres (9 MW), with a total capacity to produce, a
coincident peak of about 254 MW, excluding Rapide-des-Cèdres. The largest individual unit at
the power plants representing just over 28 MW.
ln addition, Lièvre owns and operates a modest transmission system, operated at 120 kV, in the
Gatineau region that was initially designed to transport power from Lièvre's three (3) larger
power plants in the region to service local area load and, subsequently permit ex
port of energy
through interconnections with HQT's network.
Additionally, Lièvre's Installations have the capacity to periodically export energy to Ontario by
segregating its' Installations from HQT's system7 or alternatively import energy from Ontario in
a segregated mode of Operation ("SMO")8, by directly connecting generators in Ontario to the
Lièvre system. At no time is the Ontario IESO-controlled grid ("ICG") and HQT's power
system in this area operated interconnected to each other during normal operation.
Notwithstanding the voltage level of the Installations' network, any faults and disturbances on
Lièvre network, as in RTA's circumstances, continue to have local impact implications only.
The same can be said when importing energy from Ontario in SMO (Ontario generators
connected to Lièvre system). While, operating connected to the ICG segregated from the HQT
system9 Brookfield Energy Marketing L.P. JO, as a registered market participant of the IAM (IESO
- administered markets), is bound by and subject to the Ontario market mles11.
7 To export energy into Ontario, Lièvre's Installation must first separate from the HQT system before
connecting to the Ontario IESO-controlled grid ("ICG") via the two (2) interties with Ontario, H9A and
D5A, which are operated at 120 kV and 230 KV respectively. At no times, with the exception of
providing assistance during emergencies, are the systems (HQT's and ICG) to be connected together
through these interties.
8 Segregated mode of operation (Ch.7 App. 7.7 - Radial lntertie Transilctions of the Market mIes), at
page 89, refers to a mode of operations whereby the Lièvre installations is physically interconnected ta
the Ontario integrated power system and separated from the HQT's network. That is totally separated
from the Québec integrated power system.
9 It is recognized by the IESO and Lièvre that the 230kV line D5A and the MTB3 Transformer is deemed
BPS when connected radial to Ontario segregated from the HQT system.
10 The Lièvre output is sold to Brookfield Energy Marketing L.P which is the registered market
participant with the IESO.
11 Ontario Market Rules http://www.ieso.ca/im h/pubs/marketRi ,,/mr markptRulps.pdf
Page 5
(b) List of additional Sources and Documents Reviewed:
To achieve the stated objectives of this letter and formulate our opinions and positions
regarding the commonality between the Installations, the information and documentation listed
below, in addition to those listed in Appendix B of the attached report, were reviewed.
i) The authors comprehensive knowledge of segregated mode of operation with Québec
interconnections and the interconnection agreement between the Independent
Electricity System Operator of Ontario and Hydro-Québec TransÉnergie; with respect
to:
a) Line D5A (230 kV), between the Masson substation in Québec and the Hawthorne
transformer station in Ontario; and
b) Line H9A (120 kV), between the Masson Substation ID Québec and Cumberland
Junction in Ontario:
ii) Detailed review with Lièvre's representatives of the Installations as well as their
planning, operational and facility data including its connections to Hydro-Québec's
transmission system;
iii) Review with Lièvre' s representatives of the operation
al arrangements between Lièvre
and Hydro Québec;
iv) Detailed review with Lièvre' s representatives of the current activities in support of
system reliability;
v) R-3625-2007, Decision D-2007-95 and R-3636-2007, Decision D-2008-074
vi) R-3699-2009, HQCMÉ-3, Document 2, "Réponses du Coordonnateur de fiabilité à la
demande de renseignements numéro 1 de ELL et EBMI"
vii) R-3636-2007 Pièces ELL-l "Schémas unifilaires préparés par la firme d'ingénieurs-
conseils Breton, Banvile & Associés s.e.n.e. démontrant l'évolution du système
d'Énergie La Lièvre s.e.c. de 1930 à 2007, en liasse" and ELL-2: "Graphique
démontrant les installations du système d'Énergie La Lièvre s.e.c.
Page 6
viii) Ontario market rule chapter 7; appendix 7.7 - Radial Intertie Transactions, at page 8912
(c) Affirmation and Statement of Independence
The information contained in this letter and attached report is based on information provided
by Lièvre and RT A and information contained in the list of sources and documents referred to
in Attachment A sub-section (b) (some documents were translated to English), and the
knowledge and extensive expertise of the author on the subject. This information is, to the best
of my knowledge, factually correct.
Further, AESI and the undersigned have no ties or associations with Lièvre, and have provided
these paid professional services at the request of Lièvre, as independent consultants with
established expertise in the electricity industry.
AESI Acumen Engineered Solutions International Inc.
~~~
~J
By: Ronald J. Falsetti, P.Eng.
Title: Associate Senior Consultant
12 http://www.ieso.ca/imoweb/pubs/marketRules/mr chapter7appx.pdf.
Page 7
CiilJilill Offce
775 Main Si. Easi. Suile lB
Milton. Ontario, Canad L9T 3Z3
Offce: (905) 875.2075
Fax: (90S) 875-2062
i
IJii/Jed Sltn OJl
700 Centrl Parkway, Suite 1475
Aeumen Engineere Solutions International Ine.
Atlanta, Geoia, USA, 30328
Offce: (678) 320-1895
Fax: (770) 522-81 i 5
e~mail: aesi(gaesi~inc.com
website: WVt"W,aei-inc,com
January 7, 2010
Mtre Pierre Grenier
FRASER MILNER CAS
GRAIN UP
1 Place Vile Marie, 39th Floor
Montréal QC H3B 4M7
Re: . Hydro-Québec Direction - Contrôle des mouvements d'énergie's
application for adoption of reliabilty standards for electric power
transmission in Québec and for approval of the registries identifying
entities and installations subject to reliability standards and sanction
guidelines
. Régie de l'énergie: R-3699-2009
Dear Sir:
The attached report is to be submitted to the Régie de l'énergie (the "Régie") on behalf
of Rio Tinto Alcan Ine. ("RT A") in connection with its Saguenay-Lac-Saint-Jean hydroelectric facilities and related installations (the "Installations").
The report conveys our findings, positions and opinions based on:
i) our knowledge and expertise regarding the implementation and application
of reliability standards in the electrical industry;
ii) our knowledge and understanding of the Installations (facilities,
configuration and electrical system), including its connections to HydroQuebec's transmission system; and
iii) our review and understanding of Hydro-Québec Direction Contrôle des
mouvements d'énergie's (" HQCMÉ,,) application to the Régie under fie R3699-2009.
More specifically, the report is intended to:
i) assess the rationality of HQCMÉ's proposaI, in its application, to qualify
RTA as an entity subject to reliability standards and sanction guidelines, and
Page 2
its Installations to Québec's proposed Compliance Monitoring &
Enforcement Program ("QCMEP");
ii) convey RTA's continuing concerns and provide arguments regarding the
consequences of HQCMÉ's proposaI; and
iii) provide an assessment of comparability of HQCMÉ' s proposed reliability
model with other jurisdictions, primarily those within the Northeast Power
Coordinating Council, Inc. ("NPCC"), regarding:
(a) the proposed definition of "Main Transmission System" (Réseau de
transport principal)l ("RTP") that is to be used to establish the Registries
of entities and installations subject to reli
ab
ilt
y standards and sanction
guidelines2 (the "Registry"); and
(b) the appropriateness of the proposed assignment of NERC3 functional
model entities with respect to the Installations, as proposed in HQCMÉ's
application; and
i) offer possible alternatives or enhancements where warranted to better
align with other NPCC Canadian jurisdictions.
For the reasons set out in our report, we do not support HQCMÉ' s assertion to the
Régie, as proposed in its application and related filings, that RT A should qualify as an
entity subject to reliability standards and sanction guidelines and that the Installations
should be subjected to the QCMEP. Implementation of HQCMÉ's proposaI wou
Id
subject the Installations, which are clearly not part of the "Bulk Power System" (Réseau
(( bulk ,,)4 ("BPS"), to significant and unjustified administrative constraints and costs as
well as sanctions proposed by NPCC for facilities that are not part of the BPS, i.e. those
facilities for which the reliabilty standards were truly intended for.
Moreover, we are concerned that extending the immensely administratively
burdensome program requirements under the NERC/NPCC Compliance Monitoring &
Enforcement Program (the "CMEP") umbrella to facilities that have NO impact to the
BPS wil be costly, wil serve little benefit to improving reliability, and wil needlessly
increase risks by tying up limited resources that are in short supply.
R-3699-2009, HQCMÉ-2, Document 4, Revised 2009-11-23, Section 2.1, at page 3;
R-3699-2009, HQCMÉ -2, Document 10, Revised 2009-11-04, at page 35.
R-3699-2009, HQCMÉ -2, Document 4, Revised 2009-11-04, "Registre des entités visées par les
normes de fiabilité"
North American Electric Reliability Corporation ("NERe").
R-3699-2009, HQCMÉ -2, Document 10, Revised 2009-11-04, at page 34.
Page 3
It is our expert opinion that the Province of Québec and its customers wou
Id be better
served if local area reliabilty matters remained within HQCMÉ and were managed
locally, similar to the other Canadian jurisdictions within NPCC. Extending the reach
of the CMEP to facilities such as the Installations, as proposed by HQCMÉ in its
application, is, in our view, a substantial and unwarranted departure from the original
intent of the reliabilty standards and the Electric Reliability Organization' s mandate,
which is to maintain the reliabilty of the interconnected BPS.
Therefore, we respectfully submit to the Régie in our report that:
i) the definition of RTP should not be used for establishing the Registry;
ii) RTA and the Installations should not be designated as NERC functional
model entities for the purposes of monitoring and auditing by NPCC under
the QCMEP;
iii) the entities and their BPS installations that would be subject to the Québec
reliabilty standards and NPCC criteria should be distinguished, in the
Registry, from the entities and their non-BPS installations that would be
subject to non-BPS reliability related requirements and managed locally by
HQCMÉ; and
iv) a two (2) tier QCMEP approach be implemented similar to other NPCC
Canadian jurisdictions (Ontario and New Brunswick).
Respectfully,
07/01/2010
x
~¡j
t¡-'"--.a;L¿
Ronald J. Falsetti, P.Eng.
Associate Senior Consultant
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INC.
775 Main Street East, Suite 1 B, Milton ON L9T 323
rjfalsettil1)cogeco.ca
Phone: (90S) 469-2376
Mobile: (289) 888-1801
www.aesi-inc.com
REVIEW OF THE QUÉBEC RELIABILITY STANDARDS AND
THE PROPOSED REGISTRIES OF ENTITIES AND INSTALLATIONS
SUBJECT TO THE STANDARDS
lN THE CONTEXT OF RIO TINTO ALCAN INC.'S SAGUENA Y-
LAC-SAINT-JEAN HYDRO-ELECTRIC FACILITIES AND
RELA TED INSTALLATIONS
RÉGIE DE L'ÉNERGIE
R- 3699-2009
Re: Hydro-Québec Direction Contrôle des mouvements
d'énergie's application for adoption of reliabilty
standards for electrIc power transmission in Québec and
for approval of the registries identifying entities and
installations subject to reliabilty standards and the
sanction guidelines
BY:
Ronald J. Falsetti, P.Eng.
AssocIate Senior Consultant
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INC.
JANUARY 7, 2010
T ABLE OF CONTENTS
AR TI CLE 1. TERMS OF REFERENCE ...............................................................................1
Section 1.02 List of Sources and Documents Reviewed to Develop Opinions.................
3
Section 1.03 Background ........................................................ ............... .... ............ .. ...... .. ..3
(a) HQCMÉ's application .....................................................................................3
(b) RTA's Installahons............................ ............ ....... ...... .. .... .. . ..... . ....... ..4
ARTICLE II. ANAL YSIS AND GENERAL COMMENTS.............................................5
ARTICLE III. BULK POWER SYSTEM (BPS) VS. MAIN TRANSMISSION
SYSTEM (R TP) ....... ............ ........... ............ ............ .......... ................... ...........17
ARTICLE IV. APPLICATION OF NERC RELIABILITY STANDARDS TO
THE lN S T A L LA TI 0 N S ........... ........... ................ ............. ............. ....... ........ 20
ARTICLE V. CON CL USIONS ............................................................ ............................... 21
AR TI CL E VI. APPEND 1 CE S ....... ............ ............. ................... .............. ...... ......................... 24
Section 6.01 Appendix A - Affirmation and Statement of Independence .................... 24
Section 6.02 Appendix B List of Sources and Documents Reviewed ..........................25
Section 6.03 Appendix C - Experts Background, Qualifications, Training and
Experience . .................. ..... ............. ................ .......... ....... .............................30
Section 6.04 Appendix D About AESI Acumen Engineered Solutions
International Ine. and AESI-US Ine. (" AESI").. .. .... .. .... . ..... .... .... ....... ..34
Section 6.05 Appendix E - AESI's NERC Standards Qualifications.................................
37
(a) NERC CLP Reliability Standards... ............ ....... ................. ....... ............ ..37
(b) NERC non-ClP Reliabilty Standards..........................................................
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
38
Page i
Article 1.
Terms of Reference
The following report is submitted to the Régie de l'énergie (the "Régie") on behalf of
Rio Tinto Alcan lnc. ("RT A"). It conveys our findings, positions and opinions based
on.
i) our knowledge and expertisel regarding the implementation and application
of reliability standards in the electrical industry;
ii) our knowledge and understanding of RTA's Saguenay-Lac-Saint-Jean hydro-
electric facilities and related installations (the "Installations")2 as well as its
facilities, configuration and electrical system, including its connections to
Hydro-Québec's transmission system; and
iii) our review and understanding of Hydro-Québec Direction Contrôle des
mouvements d'énergie's ("HQCMÉ") application to the Régie under file
R-3699-20093 for the adoption of the reliability standards and approval of the
registries identifying the entities and the installations that wil be subject to the
reliability standards and the sanctions guidelines in Québec.
This report is intended to:
i) assess the rationality of HQCMÉ's proposaI, in its application, to qualify RTA
as an entity subject to reliability standards and sanction guidelines, and its
Installations to Québec proposed Compliance Monitoring & Enforcement
Program ("QCMEP");
11
See Appendix C - Experts Background, Qualifications, Training and Experience.
See Section Section 1.03(b) RTA'~ Installations.
R-3699-2009, B-1- HQCMÉ's Application.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INC.
Page 1
ii) convey RTA's continuing concerns and pro
vide arguments regarding the
consequences of HQCMÉ' s proposaI;
iii) provide an assessment of comparability of HQCMÉ's proposed reliability
model with other jurisdictions, primarily those within the Northeast Power
Coordinating Council, lnc. ("NPCC"), regarding:
a) the proposed definition of "Main Transmission System" (Réseau de
transport principal)4 ("RTP") that is to be used to establish the registries
of entities and installations subject to reliability standards and sanction
guidelines5 (the "Registry"); and
b) the appropriateness of the proposed assignment of NERC6 functional
model entities with respect to the Installations, as proposed in
HQCMÉ' s application; and
iv) offer possible alternatives or enhancements to better align with other NPCC
Canadian jurisdictions.
The author of this report is an Associate of AESI Acumen Engineered Solutions
International Inc. (" AESI"). ln connection with HQCMÉ's application before the
Régie, AESI was retained by RT A to review applicable documentation pertaining to
fie R-3699-2009 and to submit our findings, positions and opinions on three major
aspects of HQCMÉ' s application:
HQCMÉ-2, Document 4, Revised 2009-11-23, Section 2.1, at page 3;
HQCMÉ-2, Document 10, Revised 2009-11-04, at page 35.
HQCMÉ-2, Document 4, Revised 2009-11-04, entitled Registre des entités visées par les
normes de fiabilité.
6
North American Electric Reliability Corporation ("NERC").
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 2
i) the appropriateness of HQCME's proposaI for the use of RTP to establish the
Registry rather than "Bulk Power System" (Réseau (( bulk "V ("BPS"), which is
used by Northeast Power Coordinating CounciI, Inc. ("NPCC");
ii) the comparison of this proposed reliabilty model to those used in other
jurisdictions; and
iii) the evaluation of the reliabilty standards which wou
Id be applicable to the
Installations and the assessment of their applicability.
Section 1.02
List of Sources and Documents Reviewed to Develop
Opinions
To achieve the stated objectives of this report and formulate our opimons and
positions, the information and documentation listed in Appendix Section 6.02 herein
were reviewed.
Section 1.03
Background
(a) HQCMÉ's application
On May 28, 2009, HQCMÉ, in its capacity as Reliability Coordinator for electric
power transmission in Québec, fied an application to the Régie seeking, amongst
other things:
i) the adoption of reliability standards; and
ii) the approval of the Registry in the Province of Québee.
HQCMÉ's application was submitted under sections 31(5), 85.2, 85.6, 85.7, 85.8 and
85.13 of the Act respecting the Régie de l'énergie (the "Act").
7 HQCMÉ -2, Document 10, Revised 2009-11-04, at page 34.
AESI ACUMEN ENG1NEERED SOLUTIONS INTERNATIONAL INe.
Page 3
ln its submissions to the Régie, HQCMÉ identifies RTA as an entity8 likely to be
subjected to the reliability standards and sanction guidelines.
On September 22, 20099, the Régie invited interested parties to submit comments to
HQCMÉ's application by November 20, 2009. This deadline was subsequently
extended by the Régie to January 8, 201 010 at the request of the interveners.
(b) RT A's Installations
RTA owns and operates an extensive distribution system, albeit at high tension
voltagesll, in the Saguenay-Lac-Saint-Jean region that was exclusively designed to
transport power from RTA's six (6) power plants in the region to service RTA's load.
Additionally, pursuant to agreements entered into between RTA and Hydro-Québec
TransÉnergie ("HQT"), RT A' s distribution system transports energy from HQT' s
network to service Hydro Québec's ("HQ") area load totallng some 200 MW on
average (530 MW peak).
RTA's electricity generation in the Saguenay region consists of six (6) power plants,
three (3) on the Péribonka River and three (3) on the Saguenay River. These
installations have the capacity to produce, on average, about 2000 MW representing
approximately 90% of RT As aluminum production power requirements for the
region. The balance of RTA's electrical needs is provided by HQ, through three (3)
interconnects with HQT. Occasionally, pursuant to the aforementioned agreements,
RT A wil sell energy to HQ during freshet and high water level periods, when
R-3699-2009, HQCMÉ-2, Document 3, Revised: 2009-11-23, at page 10 of IL.
9
R-3699-2009, Decision D-2009-121, dated September 22,2009.
10
R-3699-2009, (A-12) Letter from the Régie dated December 11, 2009.
11
RTA's distribution network consists primarily of an array of 161 kV facilities, with the
exception of the 345 kY transformer station between Chute-Des-Passes generation facility
and the vilage of Delisle.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 4
generation availability from the SiX (6) power plants exceeds RTA's own load
requirements.
Article II.
Analysis and General Comments
AESI acknowledges the Régie' s affrmative action in establishing a meaningful and
mandatory "reliability" framework in the Province of Québec, within the context of
Québec's le
gaI and regulatory environment. It also supports the Régie's consultative
approach with affected parties in determining the appropriate framework for Québec.
Moreover, AESI commends the Régie in taking a deliberate and cautious approach,
soliciting input from affected parties and weighing the various options accordingly
prior to making its final decision on HQCMÉ' s application, the Québec' s future Rules
of Procedure (QROP) for compliance services by the NERe, and the associated
QCMEP for implementation by NPCC.
Given the configuration of the Installations, we strongly believe that they should be
viewed no differently than a large indus
trial customer with load displacement
generation utilizing its own distribution network, irrespective of the voltage level of
its distribution system.
Furthermore, in its previous filngs to the Régiel2, HQCMÉ has been an advocate
supporting the view that the Installations have local area reliability impact only and,
for the most part, should not be subject to the NERC' s reliability standards.
We understand that RTA is concerned with the broad brush approach HQCMÉ has
now taken
its planned Registry. HQCMÉ's proposed definition of "Main
Transmission System" (Réseau de transport principal) ("RTP")3 used to establish the
12
R-3498-2002, HQT-6, Document 1, dated 2003-02-05, at R.21 page 5 of 11.
13
R-3699-2009, HQCMÉ-2, Document 4, Revised 2009-11-23, at page 3, section 2.1.
R-3699-2009, HQCMÉ-2, Document 10, Revised 2009-11-04, at page 35.
AESI ACUMEN ENGINEERED SOLUT!O:'S INTERNATIONAL INe.
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Registry goes far beyond any other Canadian jurisdictions within NPCC14 and is, in
our opinion, inconsistent with the NERC Statement of Compliance Registry Criteria15
that all other jurisdictions in North America are subject to. The term RTP is defined as
follows:
"Main Transmission System" (Réseau de transport principal) (RTP)16
(internaI translation) Grid system made up of facilities and lines generally
transporting large quantities of energy and the generating stations of 50 MY A
or more that are important for ensuring control of the following reliability
parameters:
. Maintaining load-generation - balance (Balance of the demands/offers);
· Frequency adjustment;
· Maintaining operating reserves;
· Y oltage adjustment of the network and of the interconnections;
· Maintaining transit stability within the limits of operation;
· Supervision and coordination of interchange transactions
(exports/imports );
· Supervision of the network' s automatic operations;
· Managing overloads on the network
The principal grid system is under the supervision of the Quebec Reliability
Coordinator (Direction Contrôle des mouvements d'énergie (CMÉ), HydroQuebec TransÉnergie).
(Main Transmission System)
Source: Direction Contrôle des mouvements d'énergie
More specifically, the proposed RTP definition is inconsistent with respect
to the NERC criteria for registering generation assets connected to non
Bulk ElectrIcal System ("Réseau de transport principal") ("BES")17
transmission facilities
With respect to the application of NERC and NPCC standards under the Federal Energy
Regulatory Commission (FERC) approved Uniform Compliance Monitoring &
Enforcement Programs (CMEP). NPCC represents the jurisdictions of New York,
New England, Ontario, Québec, New Brunswick and Nova Scotia.
15
Statement of Compliance Registry Criteria, Rev. 5, Sections m.c.1 and m.c.2;
http://www.p°.i(.ç.AT1 v;/Statemf'--nP1pliance Registry Criteria-V5-0.pdf
16
R-3699-2009, HQCMÉ-2, Document 10, Revised 2009-11-04, at page 35.
17
R-3699-2009, HQCMÉ-2, Document 10, Revised 2009-11-04, at page 35.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
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Further, the use of the proposed RTP definition to establish the Registry, wil result in
certain reliability standards being applicable to facilities well beyond the scope of
NPCC's definition of Bulk Power System (Réseau (( bulk ,,) (BPS)18, which are
enforceable through sanctions under a compliance program that is inconsistent with
the Uniform Compliance Monitoring & Enforcement Program ("CMEP") approved
by the Electric Reliability Organization (lfERO") and the Federal Energy Regulatory
Commission ("FERC") for the rest of North America.. The term BPS is defined as
follows:
"Bulk Power System" (Réseau (( Imlk ))) ("BPS")
Termsl9) as:
the NPCC Glossary of
A-IO, (C-I)
Bulk power system - The interconnected electrical systems within
northeastern North America comprised of system elements on which faults
or disturbances can have a significant adverse impact outside of the local
area.Jemphasis added)
However, for a specifie set of reliability standards, HQCMÉ is proposing to use the
BPS definition, rather than the definition for RTP, to establish their applicability to
installations and facilities owned by HQ (see examples of same at page 20 of this
report). ln effect, HQCMÉ is selectively applying different criterion for determining
which reliability standards are applicable to the RTP. This wil essentially affect how
non BPS facilties are treated for different reliability standardsi including a vast
assortrent of HQT's own facilities, under the QCMEP.
ln addition, the proposed RTP definition is, in our view, contrary to the agreement
entered into between the Régie, NERC and NPCC20 with respect to the application of
18
R-3699-2009, HQCMÉ-2, Document 0, Revised 2009-11-04, at page 34.
19
NPCC Glossary of Terms, Document A-07, at page 5;
http://www .npcc. org/ docu ments/regStandards/Cri teria. aspx.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
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reliability standards, which are specifically developed for BES facilties. More
specifically, as per Sections 3.2 and 4.3 of the agreement, the Régie is to retain the
services of NPCC and NERC as "experts in the application of the NERC reliability
standards" and requires them to implement a compliance program that is consistent
with NPCC's uniform compliance program and NERC rules of procedure. It is our
view that the QCMEP and the HQCMÉ application before the Régie proposing the
use of RTP to establish applicability is inconsistent with those stated objectives.
BES is defined as follows in the NERC Glossary of Terms Used in Reliability
Standards21 (the "NERC Glossary"):
As defined by the Regional Reliabilty Organization, the electrical
generation resources, transmission line
s, interconnections with neighbouring
systems, and associated equipment, generally operated at voltages of 100 kY
or higher. Radial transmission facilities serving only load with one
transmission source are generally not included in trus definition. (emphasis
added)
This definition has been accepted by the FERC in its Order 69322 issued in March 2007
and applied throughout North America through the implementation of each of the
Regional Entities' CMEP. ln the case of the NPCC, in its capacity as Regional Entity
for the North-East, the program is implemented in accordance with the NPCC
Implementation of the NERC CMEP (CP-01)23.
20
Agreement on the development of electric power transmission reliability standards and of
gram for the monitoring of the application for these standards for
procedures and pro
Québec entered into between the Régie de l'énergie, North American Electric Reliability
Corporation and Northeast Power Coordinating Council, lne. on May 8, 2009, at
Sections 3.2 and 4.3.
21
http://www.nere.com!fles/Glossary 12Feb08. pdf.
22
United State of America, Federal Energy Regulatory Commission, 18 CFR Part 40 (Docket
693), Mandatory Reliability Standards for the BulkNo. RM06-16-000; FERC Order No.
Power System, lssued March 16, 2007, at par. 6, 20, 50 and 51; http://www.fere.gov/whatsnew /comm-meet/2007 /031507 le-a pdf.
23
NPCC Implementation of the NERC Compliance Monitoring and Enforcement Program;
AEsr ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INC
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ln its final determination under Order 69324 the FERC agreed to retain the existing
NERC Glossary definition for the initial implementation of mandatory and
enforceable reliability standards. Specifically, in Order 693, the FERC concluded as
follows:
b. Commission Determination
75. The Commission agrees with commenters that, at least initially,
expanding the scope of facilities subject to the Reliability Standards could
create uncertainty and might di
vert resources as the ERO and Regional
Entities implement the newly created enforcement and compliance regime.
Further, we agree with commenters that unilaterally modifying the definition
of the term bulk electrie system is not an effective means to achieve our goal.
For these reasons, the Commission is not adopting the proposed
interpretation contained in the NOPR. Rather, for at least an initial period,
the Commission wil rely on the NERC definition of bulk electric system25 and
NERC's registration process to provide as much certainty as possible
regarding the applicability to and the responsibility of specifie entities to
comply with the Reliability Standards in the start-up phase of a mandatory
Reliability Standard regime. (underline added)
For the purposes of monitoring and enforcing NERC reliability standards and NPCC
criteria, NPCC, as the Regional Entity for the North-East, de
fines BES (referred to as
"bulk power system or BPS" in the NPCC Glossary of Terms26) as.
http://www .npcc.org/ documents/ compliance/ProgDoc.aspx.
24
25
See note 22, at par. 75 (FERC Order No. 693).
"As defined by the Regional Reliability Organization, the electrical generation resources,
transmission line
s, interconnections with neighbouring systems, and associated
equipment, generally operated at voltages of 100 kV or h1gher. Radial transmission
facilities serving only load with one transmission source are generally not included in this
definition."
26
NPCC Glossary of Terms, Document A-07, at page 5;
http://www .npcc. org/ documents/regSt;mdards/Cri teria. aspx.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
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A-10, (C-l)
Bulk power system - The interconnected electrical systems within
northeastern North America comprised of system elements on which faults
or disturbances can have a significant adverse impact outside of the local
area.jemphasis added)
More importantly, in the recent NPCC-NERC joint filing with the FERC further to it's
Order Directing the Submission of Data (Docket No. RC09-3-000)27, the Canadian
NPCC members, which include HQCMÉ, have taken a position to continue to use the
NPCC BPS definition for facilities within the Canadian portion of NPCC. ln that
filing dated September 21, 200928, NPCC and NERC have asserted to the FERC that:
D. BES Definition Among the Canadian Members
The Canadian members of NPCC believe that enforcing mandatory reliability
standards is essential for designing, maintaining and operating a reliable and
secure interconnected electricity grid. However, the application of NERC
reliability shndar-is should be limited to wide-area reliability without
expanding its scope to coyer local area reliability.
The Canadian members further believe a bright line, voltage-based definition
of BES, such as that being reviewed for the U.S. members of NPCC, would
result in NERC reliability standards being applied to facilities, 100 kV and
ab ove, which wil only impact local areas. Thp~"cilitie" do not have widearea impact and would not result in cascading outages.
The Canadian members of NPCC remain resolute in their belief that the
impact-based approach currently used by NPCC to determine the
applicability of NERC standards is the most efficient manner in which to
maintain reliability of the Bulk Electric System. The Canadian members of
NPCC strongly believe that significant additional costs wil be incurred
without identified reliability benefits if a bright line voltage-based definition
27
FERC Docket No. RC09-3-00; FERC's Order Directing the Submission of Data, lssued
December 18, 2008;
http://www.nerc.com/fles/OrderDirectingSubmissionOfDa ta- NPCC N ERC-12182008. pdf.
28
FERC Docket No. RC09-3-00; Compliance Filing and assessment of Bulk Electric System
definition report of the North American Electric Reliability Corporation and Northeast
Power Coordination Council, me. in response to the December 18, 2008 Commission
or
der; dated September 21,2009, at page 13;
http://www.nerc.cam/fies/FinaIPublic NERC-NPCC BES Report Camp Filing 9212009.pdf.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNA T10NAL INC
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were adopted across Canadian NPCC. Moreover. fuis exercise would result
in diverting funds and key expert resources from other higher value reliabilty
projects and activities.
The Canadian members do not expect Canadian provincial regulators to
support expenditures by their regulated entities to expand the applicability of
the NERC reliability standards if they are unable to demonstrate benefits to
reliability.
NPCC's Canadian entities further believe that there is no identified reliability
te definition of BES elements for
concem associated with maintaining a separa
Canadian and U.S. NPCC systems because the transmission facilities
participating in international power transfers that would be identified under
the developed NPCC BES bright line definition are already identified as BES
elements under the NPCC A-10 Criteria. (underline added)
Furthermore, in the same joint fiing, NPCC and NERC have asserted to the FERC
that29.
NPCC wil continue to utilize the methodology established under the A-lO
di an portion
criteria for application of NERC Reliability Standards in the Cana
of NPCC. (underline added)
Although NPCC has developed and presented in its joint filing a definition for U.s.
only registered entities within the NPCC footprint to be consistent with other U.s.
regions that have adopted a voltage-based BES definition30, it continues to believe
that the functional reliability impact-based approach provides an "Adequate Level of
Reliability"31:
NPCC continues to believe that its impact-based approach documented in the
A-lO Criteria document provides an "adequate level of reliability" assurance
on those elements that affect the reliability of the international, interconnected
system in the Northeast by identifying those elements that could cause
widespread outages. Ths approach also enables NPCC to focus its reliability
29
Ibid, at page Il.
30
Ibid, at pages 9 to Il
31
FERC Docket RR07-14, NERC informaI filing to FERC, See NERC definition of "adequate
level of reliability", dated May 5, 2008;
http://www.nerc.comlfles/Adequate Level of Reliability Defintion 05052008.pdf.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page Il
assurance efforts on these elements. Therefore, NPCC intends to continue its
utilzation of the A-lO Criteria in identifying those key facilities in both the
U.S and Canadian portions of NPCC to WhlCh the more stringent NPCC
Criteria wil apply and for identifying BES elements in the Canadian portion
of NPCC.32 (underline added)
This is a view equally shared by NPCC members, currently and in the past, which has
been articulated to the FERC on numerous occasions. For ex
ample, the New York
State Reliability Council ("NYSRC"), in a 2007 filing to the FERe, stated33:
The NYSRC strongly recommends that the application of ERO standards be
determined by a functional reliability impact approach. Under the current
NERC definition of bulk electric system, NPCC has used a functional
reliability impact approach to determine the bulk-power system facilities to
which NERC standards should apply. The functional reliability impact
approach identifies those facilities that materially impact the reliable
operation of the bulk power system, while recognizing that some facilities
have little impact of bulk power system reliability.
More recently, NYSRC took the same position in a filing to the FERC dated October
28, 2009 on the use of Topological and Impedance Element Ranking ("TIER") as an
alternative method for establishing facilities that need to be registered. The NYSRC
continues to defend the use of the functional reliabilty impact-based approach, as
defined by NPCC, to establish entities that ought to be subject to the reliabilty
standards, stating34:
32
See note 28, at page 7.
33
See Page 6, 1 paragrapli COMMENTS OF THE NEW YORK ST A TE RELIABILITY
COUNCIL LLC on; FERC Docket No. RM06-16-000 Mandatory Reliability Standards for
the Bulk-Power System and Docket No. RM07-3-000 Facilities Design, Connections and
Maintenance Reliability Standards); dated january 3, 2007;
http://elibrary . ferc. gOY /idmws/n ycommon/NV intf.asp ?slcfile list= 11218352 :0;
http://elibrary .ferc.goy /idm wS/5carch/fercad ysearch .asp , Accession Number: 20070103-5148.
34
FERC Docket RM-06-16-000, Mandatory Reliability Standards for the Bulk Power System,
Comments of the New York State Reliability Council, L.L.c., Dated October 28, 2009,
at page 5;
http://www .nysrc.org/pdf/MeetingMaterial/RRSMeetingMaterial/RRSA genda 125/Comme
nts%20of%20the%20NYSRC%20under%20RM06-16-000. pdf.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
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The NYSRC supports the development of a methodology for defining BPS
facilities that is performance-based and directly related to the fundamental
components of BPS reliability. ln its joint filing with NERC filed with the
Commission on September 21, 2009, the Northeast Power Coordinating
Council ("NPCC") stated that it "continues to believe that its impact-based
approach documented in the A-10 Criteria document provides an adequate
level of reliability assurance on those elements that affect the reliability of the
international, interconnected system in the Northeast by identifying those
elements that could cause widespread outages. NPCC also states that
"application of the developed BES ((Bulk Electric System)) bright-line
definition within NPCC would increase the number of facilities for which
NERC compliance would be required, resulting in economic and resource
impacts without identified increases in the overall reliability of the NPCC
international, interconnected power system. The NYSRC agrees with these
assessments by NPCC. The NYSRC also agrees with the conclusion of
Canadian members of NPCC that adoption of a bright-line test "would result
in diverting funds and key expert resources from other higher value reliability
projects and activities.
We urge the Commission, therefore, not to order the adoption of a bright-line
voltage based definition of BPS facilities, but to continue to allow the use of
performance-based methodologies, such as the A-JO criteria developed by
NPCC.
However, in its application, HQCMÉ, owing to its proposaI to use RTP rather than
BPS to establish the Québec entities that would be subjected to the reliability
standards, is in effect expanding the sc
ope of coverage well beyond what it has
recently agreed to with the NERC and the NPCC in their joint filing to FERC35. An
approach that HQCMÉ has clearly acknowledged is not used by any other
jurisdictions throughout North-America. ln its response to the Régie36 HQCMÉ
states:
(internaI translation) The "RTP" network as proposed by the Reliability
Coordinator is being considered for the application of the obligatory
Quebec reliability standards. It includes the network "Bulk", as defined
by the NPCC, which Hydro-Quebec TransÉnergie is member of. To the
35
See note 28, at page 13.
36
R-3699-2009, HQCMÉ-3, Document 1 1, Dated 2009-))-04 "Réponses du Coordonnateur de la
fiabilité à la demande de renseignements iiuméro 2 de la Régie de l'éiiergie", Section 1.1
AESI ACUMEN ENGINEERED Sm UTIONS INTERNATIONAL INe.
Page 13
knowledge of the reliability coordinator, the expression "RTP" as
proposed is not used in any other jurisdiction.
AESI supports the notion that comparability with the approach taken by the other
NPCC Canadian jurisdictions (Ontario and the Maritimes), and the FERC's approved
NERC registration criteria is paramount in establishing a level playing field.
For example, this approach brings consistency to the QCMEP with that of Ontario's,
which has been in place since 199837, and the compliance program for
New Brunswick38. Both compliance programs utilze a two (2) tier approach for
monitoring and enforcing compliance to NERC reliability standards and NPCC
criteria39
One process of the
se compliance programs is specific for entities having installations
and facilities that are deemed to be BPS; these installations and facilities are
monitored and enforced essentially in accordance with the NPCC CMEP.
The other process of these two (2) tier compliance programs is specific for entities
having installations and facilities that are deemed to be non BPS; these installations
and facilities are managed internally (locally) within the IESO and NBSO
respectively.
37
independent Electricity System Operator ("IESO") Reliability Compliance Program
("IRCP"); http://www.ieso.calimoweb/pubslircp/ERO/ERO-20060626- !RCP-Final. pdf;
The IRCP was managed by the author of this report from 1999 to September 2008.
38
- Memorandum of Understanding Between the New Brunswick System Operator and The
Northeast Power Coordination Council Inc. and The North American Electric Reliability
Corporation;
http://www.nbso.ca/Pu blic/ private/MOU%20(NBSO-%20N PCC - %20NERO.pdf;
- Market Procedure 8 - New Brunswick System Operator ("NBSO")'s compliance
program, Sections 2.5.4 and 3.1.2;
http://www.nbso.ca/Public/ private/MP -08. pdf.
39
IESO and NBSO are acting as Reliability Coordinat
or, Balancing Authority and
Transmission Operator for their respective jurisdictions.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
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Based on the Ontario compliance program's successful experience, this two (2) tier
approach could be implemented as follows:
i) The QCMEP would need to explicitly limit the reach of the NERC reliability
standards and the NPCC criteria to monitor and audit compliance to Québec
reliability standards for entities and their installations that are clearly defined
as BPS or assets connected to BPS as per Section 85.3 of the Act;
ii) The QCMEP wou
Id need to articulate that for all other non-BPS reliabilty
related requirements that would be suggested by HQCMÉ, the latter would
have the mandate to monitor compliance, and if necessary, seek enforcement
actions with the Régie, for failure to do so;
iii) The list of "other non-BPS reliability related requirements" for local area
reliability and the processes by which they would be achieved would be
jointly established between HQCMÉ and the impacted entities. Impacted
entities would be those established by the definition of RTP. As a result of this
consultation between HQCMÉ and the said entities, HQCMÉ would submit to
the Régie those non-BPS reliability standards related requirements for
approval;
iv) The entities and their BPS installations that would be subject to the Québec
reliability standards and NPCC criteria should be distinguished, in the
Registry, from the entities and their non-BPS installations that would be
subject to non-BPS reliability related requirements and managed locally by
HQCMÉ;
v) HQCMÉ would issue notifications to each affected entity identifying those
obligations.
AESI ACUMEN ENGINEERED SOLUTONS INTERNATIONAL INe.
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AESI and RTA are £Ully aware of and support the notion that a subset of reliabilty
standard requirements has and wil continue to apply to generation and transmission
facilties, such as the Installations, to main
tain local area reliabilty These reliability
standard requirements would continue to remain important to perform for local
reliability and include, namely:
i) transmission protection systems maintenance;
ii) generator under-frequency (U/F) protection maintenance4O;
iii) automatic voltage regulation (A VR) mode of operation;
iv) transmission and generation system modeling data; and
v) transmission line vegetation management41.
While this is not an exhaustive list, AESI and RTA recognize that these requirements
are important for local area reliability, with the exception of generator underfrequency protection maintenance, which is deemed to be for the "bulk" (BPS)
system. Further, they represent a sampling of those requirements for which RTA
already has policies, procedures, protocols and processes in place with HQT and
HQCMÉ to achieve the "intent" of the associated reliability standards.
40
Generator UjF protection for units within NPCC greater than 20 MY A and facilities
greater than 75 MY A, when installed, are deemed BPS, irrespective of connection ta BPS.
The Installations do not have generator UjF protections.
41
While the NERC vegetation management standard is applicable ta lines 200 kY and
above, it is intended explicitly for the protection of the BPS transmission lines. We
understand that RT A has a protocol for vegetation management, which is also appropriate
for local area reliability. RTA is therefore supportive of including this standard within the
scope of the QCMEP. Ths is similar to several other reliability standards that
shouldjcould be added on a case by case basis, through co-operative discussion between
HQCMÉ and its customers, and be approved by the Régie.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe
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a
Nonetheless, we respectfully disagree with HQCMÉ's current view that, for local are
reliabilty, this subset of standards needs to be incorporated into the QCMEP that is to
be managed and implemented by the NPCC. It is our view that local area reliability
should rather continue to be managed by the Reliability Coordinator - HQCMÉ as it
has in the past, similar to the approach taken in the other Canadian jurisdictions
within NPCC.
Article III. Bulk Power System (BPS) ys. Main Transmission System
(RTP)
ln HQCMÉ' s responses to the Régie42, HQCMÉ argues that the use of the Main
Transmission System (Réseau de transport principal) (RTP) is necessary due to the
"influence" the
se facilities have on real time operations. HQCMÉ submits that:
(internaI translation) ll1e "RTP" network is the network under the jurisdiction
of the Load Dispatching Center which performs and is responsible for, in
real-time, the Reliability Coordinator functions, the Balancing Authority's and
of the grid system's (Transmission Operator) functions, for the Transmission
change transactions (Interchange
Operator' s functions, as owner, and the inter
Authority) pursuant to the NERC functional modeL. Facilities belonging to
"RTP" network have an influence on the reliability of the network,
maintaining a balance of imports and exports on the interconnections, which
constitutes, in the opinion of the Reliability Coordinator, the network which
should be subjected to the obligatory of reliability standards in Québec.
(underline added)
While HQCMÉ's response provides an accurate account of its accountabilities under
the NERC functional model, it fails to provide a technically sound basis for the need
to expand the reach of the QCEMP to non-BPS facilities, other than to say it has an
"influence" on reliabihty and on load/generation balance of the interconnections with
its neighbours. This is a position, we respectfully submit, which cannot be supported
42 R-3699-2009, HQCMÉ-3, Document 1.1, Dated 2009-11-04 "Réponses du Coordonnateur de la
fiabilité à la demande de renseignements numéro 2 de la Régie de l'énergie" Sections 1.2 and 1.3.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAl INe.
Page 17
given that the Installations have local area impact only, as previously articulated by
HQCMÉ in its submissions to the Régie in fie R-3498-200243.
We further note that HQCMÉ, in its response to RT A in the Régie fie R-3498-200244,
confirmed that faults or disturbances on RT A' s network system wil not have
significant adverse impact on the reliability of the bulk system.
Further, we would argue that the most severe contingency, I.e. the worst case
scenario on the Installations, is the loss of a single 345 kV circuit between Chute-des-
Passes and Delisle, resulting in the loss of about 400 MW supply capability to the
region. This contingency would require the three (3) HQT interconnects to suddenly
increase its supply to the area to make up for the loss of local generation capabilty,
while RTA operators readjusted generation at other plants and/or shed load as
necessary.
This scenario IS substantially less than the worst loss of generation contingency
HQCMÉ must plan for. It has also been modeled and analyzed, jointly by HQT and
RTA and determined to have local impact only.
ln fact, it is our expert view that HQ's spinning reserves, which are required by the
reliability standards to be maintained for its first contingency, its automatic
generation control (AGq requirements and the normal generation frequency
response to deviations from the vast array of other generators on the HQT system,
including those of RT A, wil more than adequately restore the system frequency to
normal, in very short order.
More importantly, HQCMÉ goes on to further argue that certain reliabilty standards
should only apply to BPS. Specifically, in response to the Régie's Information
43
R-3498-2002, HQT-6, Document 1, dated 2003-02-05, at R1.2 and R2.1.
44
R-3498-2002, HQT-6, Document 1, dated 2003-02-05, at R2.1
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 18
Request #245, HQCMÉ notes that the following NERC reliabilty standards should
only apply to BPS, as defined by NPCC:
. PRC-004 - Disturbance Monitoring;
. PRC-005 - Protection System Maintenance; and
. TPL-OOl to TPL-004 System Performance Standards.
This position results in the exclusion of these requirements in the QCMEP for all
transmission facilities that are non "bulk" (BPS), including HQT's extensive network
of transmission facilities. We submit that these excluded requirements for non bulk
(BPS) transmission facilities have a greater "influence" on the reliability of the RTP
system than those that are listed in the Simplified Reliabilty Application Matrix46
(the "Registry of Applicable Standards"). ln its response, HQCMÉ states that:
(internaI translation) The NPCC has developed design plannng criteria that
applies to the "Bulk" network. HQ in its raIe as Planng Coordinator and
Transmission Planer, within the meanng of the NERC functional modeL, has
planned its grid system to respect these criteria, which also makes it possible
to respect the requirements of the standards PRC-005 and TPL-001 to TPL004.47
While we fully agree with the position HQCMÉ has taken with respect to the
applicability of the reliabilty standards PRC-004, PRC-005, and TPL-OOl to TPL-004
to the BPS only, we would equally argue that the same holds true for the other
45 R-3699-2009, HQCMÉ-3, Document 1., Dated 2009-11-04 "Réponses du Coordonnateur de la
fiabilité à la demande de renseignements numéro 2 de la Régie de l'énergie", Section 1.3.
R-3699-2009, HQCMÉ-2, Document 5, "Registre des installations visées par les normes de
fiabilité" 2009-11-04, at pages 14 and 15.
46 R-3699-2009, HQCMÉ-2, Document 7.1, Revised 2009-10-06, "Sirnplified Reliabilty
Application Matrix, dated October 6, 2009"; Ths matrix presents a registry of applicable
NERC reliability standards that would otherwise be applicable to the entities subject to
reliabilty standards and sanction guidelines.
47 See note 45 above.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 19
standards listed in the Registry of Applicable Standards, with respect to their
inclusion in the QCMEP that are to be monitored by NPCC.
Given the reasons and concerns raised above, we submit that HQCMÉ' s proposaI to
expand the applicability of "certain" reliability standards for Québec over and above
that of the other NPCC Canadian jurisdictions, within the context of the QCMEP,
cannot be supported or justified.
Article iv. Application of NERe reliabilty standards to the Installations
While we are of the view that HQCMÉ's expanded scope of coverage of the NERC
reliability standards to non BPS facilities under the proposed QCMEP is unjustified
and unwarranted, it is our understanding that RTA is fully aware of, recognizes the
tain system reliability, including local
importance of and supports the need to main
area reliability. Furthermore, it is our understanding that RTA accepts that many of
the requirements of the NERC reliability standards are equally important to
maintaining "local are
a" reliability.
Further, given the importance of system reliability to RTA, RTA already performs
many of the listed standards requirements to various degrees and wil continue to do
so in order to enhance local area reliabilty. Nonetheless, these requirements should
not be subject to the rigorous, administratively burdensome QCMEP and its related
sanctions that are to be managed by NPCC.
These requirements should rather be managed internally within Québec as they have
successfully been in the pasto It is therefore, in our view, unjustified and unwarranted
to expand the scope of the NERC's Rules of Procedures (RoP) and the CMEP to non
bulk (BPS) transmission facilties, su
ch as the Installations, solely for the Province of
Québec.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe
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Article V.
Conclusions
The Installations should be viewed no differently than a large industrial customer
with load dis
placement generation and an extensive distribution system, albeit a very
large industrial customer with significant generation for its installed load carried over
a "high tension" distribution network.
Notwithstanding the size and the voltage of the Installations' distribution network,
any faults and disturbances on this network continue to have local impact
implications only.
Therefore, the Installations are clearly not, and cannot be construed as being part of,
the bulk power system (BPS). While HQCMÉ does not disagree with that statement,
it is proposing to the Régie to extend the reach of the NERC/NPCC CMEP umbrella to
RTPs.
HQCMÉ's assertion that RTP facilities such as the Installations be required to be
subjected to QCMEP cannot be supported both on a technical analysis and a
comparative basis with the other NPCC Canadian jurisdictions.
Su
ch action would subject RT A to sanctions, proposed by NPCC, for facilities that are
clearly not part of the BPS.
RTA understands the importance of, and remains committed to, helping assure the
reliability of its distribution network and three interconnections with HQT. RT A
further recognizes that it is in its best interest to do so and has a long standing history
and proven track record of maintaining a reliable system in the Saguenay-
Lac-Saint-Jean region.
However, we remain concerned that extending the immensely administratively
burdensome program requirements under the NERC/NPCC CMEP umbrella, and its
related sanctions, to facilities that have NO impact to the BPS wil be costly, will serve
AESI ACU~EN ENGINEERED SOLUTIONS INTERNATIONAL ¡Ne.
Page 21
fit to improving reliability and wil needlessly increase risks. ln addition, it
little bene
wil tie up limited resources that are already in short supply; the
se resources would
be better served if focussed on reliability matters that do have a direct impact to the
reliability of the BPS.
It is our opinion that Québec and its customers would be better served if local area
reliabilty matters remained with HQCMÉ and was managed locally. A two (2) tier
approach, as described on page 15 of this report, such as those implemented ID
Ontario and New Brunswick, have been successful in addressing the concerns of
owners and opera
tors of non-BPS facilities relating to the implementation of NERC
reliabilty standards.
Extending the reach of NPCC and NERC enforcement programs (CMEP) to RTP
facilities, su
ch as the Installations, is a substantial step and unwarranted departure
from the original intent of the reliability standards and the ERO' s mandate, which is
to main
tain the reliability of the interconnected BPS.
Therefore, we respectfully submit to the Régie that:
i) the definition of RTP should not be used for establishing the Registry;
ii) RTA and the Installations should not be designated as NERC functional
model entities for the purposes of monitoring and auditing by NPCC under
the QCMEP;
iii) The entities and their BPS installations that would be subject to the Québec
reliability standards and NPCC criteria should be distinguished, in the
Registry, from the entities and their non-BPS installations that would be
subject to non-BPS reliability related requirements and managed locally by
HQCMÉ, and
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 22
iv) a two (2) tier QCMEP approach be implemented similar to other NPCC
Canadian jurisdictions (Ontario and New Brunswick).
Respectfully:
9\)
§~
Ronald J. Falsetti, P.Eng.
AssocIate - Senior Consultant
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INC.
775 Main Street East, Suite 1B, Milton, Ontario, L9T 3Z3
AESI-US INC.
7000 Central Parkway, Suite 1475, Atlanta, Georgia, 30328
rj falsettii?Pcogeco.ca
Phone' (905) 469-2376
Mobile: (289) 888-1801
www.aesi-inc.com
AESI ACUMEN ENCINEERED SOLUTIONS INTERNATIONAL INe.
Page 23
Article VI. Appendices
Section 6.01 Appendix A
Affirmation and Statement of
Independence
The information contained in this report is based on information provided by RTA
and information contained in the list of sources and documents referred to in
Appendix Section 6.02 (some documents were translated to English), and the
knowledge and extensive expertise of the author on the subject. This information is, to
the best of my knowledge, factually correct.
Further, AESI and the undersigned have no relationship or association with RT A, and
have provided these paid profession
al services at the request of RTA, as independent
consultants with established expertise in the electricity industry.
AESI Acumen Engineered Solutions International Inc.
¿( l -I l
g-~.
~J
By: Ronald J Falsetti, P.Eng.
Title: Associate Senior Consultant
AESI ACUMEN ENGINEERED SOLUTIDNS INTERNATIONAl INC.
Page 24
Appendix B - List of Sources and Documents
Section 6.02
Reviewed
1. Our comprehensive knowledge of (i) compliance programs within NPCC;
(ii) ISOIRTO Council (IRC) council members; (iii) registration requirements
and associated known issue with the NERC registration criterion, specifically
within the context of the BPS52;
2. Our comprehensive knowledge of NPCC's long standing history of defending
the application of reliability standards to the BPS only;
3. Detailed review with RT As representatives of the Installations as well as their
planning, operation
al and facility data;
4. Detailed review with RT A' s representatives of the operational
agreements/arrangements between RTA and Hydro-Québec and current
activities in support of system reliability;
5. R-3699-2009, B-l - HQCMÉ's application, Dated 2009-05-28;
6. R-3699-2009, HQCMÉ-2, Document 11, Dated 2009-05-28, "Liste des rencontres
avec les entités visées ",
7. R-3699-2009, HQCMÉ-2, Document 3, Revised 2009-11-23, "Liste des entités
siisceptibles d'être soumises aux normes de fiabili téff.
8. R-3699-2009, HQCMÉ-2, Document 4, Revised 2009-11-23, "Registre des entités
visées par les normes de fiabilité",
See Resume attached.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INC.
Page 25
9. R-3699-2009, HQCMÉ-2, Document 5, "Registre des installations visées par les
normes de fiabilité )), Dated 2009-11-04;
10. R-3699-2009, HQCMÉ-2, Document 10, "Glossaire des termes et des acronymes
relatifs aux normes de fiabilité" Revised 2009-11-04 .
11. R-3699-2009, Decision D-2009-121, dated September 22, 2009;
12. R-3699-2009, Decision D-2009-148, dated November 6, 2009;
13. R-3699-2009, HQCMÉ-3, Document 1.1, Dated 2009-11-04, "Réponses du
Coordonnateur de la fiabilité à la demande de renseignements numéro 2 de la Régie de
l'énergie" ;
14. R-3699-2009, HQCMÉ-2, Document 71, Revised 2009-10-06, "Simplified NERC
Reliability application Matrix",
15. R-3699-2009, HQCMÉ-3, Document 4, Dated 2009-10-30, Page 13 of 16,
"Réponses du Coordonnateur de la fiabilité à la demande de renseignements numéro 1
de Rio Tinto Alcan ¡nc."
16. R-3699-2009, HQCMÉ-3, Document 4.1, Dated 2009-11-27, Page 1 of 10,
"Réponses du Coordonnateur de la fiabilité à la demande de renseignements numéro 2
de Rio Tinto Alcan ¡nc. ".
17. R-3498-2002, HQT-6, Document 1, Dated 2003-02-05, "Réponses à la demande de
renseignements numéro 1 de Alcan Énergie Électrique'"
18. NPCC's Uniform Compliance Monitoring & Enforcement Programs (CMEP)
implementation Procedure; NPCC Document - CP-l,
19. NERC's Statement of Compliance - Registry - Criteria - v5;
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 26
20. Agreement on the development of electric power transmission reliabilty
standards and of procedures and a program for the monitoring of the
application for these standards for Québec entered into between the Régie de
l'énergie, North American Electric Reliability Corporation and Northeast
Power Coordinating CouncIl, Inc. on May 8, 2009;
21. Proposed Quebec Compliance Monitoring and Enforcement Program
(QCMEP) for Implementation by Northeast Power Coordinating Council, mc;
22. Proposed Quebec Rules of procedure (QROP) for Compliance Services by the
North American Electric Reliability Corporation;
23. United States of America, Federal Energy Regulatory Commission,
18 CFR Part 40 (Docket No. RM06-16-000; Or
der No.
693), Mandatory
Reliability Standards for the Bulk-Power System (Issued March 16, 2007)53;
24. NPCC Document A- NPCC Glossary of Terms54;
25. United States of America, Federal Energy Regulatory Commission, Docket
No. RC09-3-00, Compliance fiing and assessment of bulk electric System
definition report of the North American Electric Reliability Corporation and
Northeast Power Coordination Council, me., in response to the December 18,
2008 Commission order (Issued September 21, 2009) 55;
26.
53
NERC - Definition of "Adequate Level of Reliabilty" 56;
http://www.ferc.gov /whats-new/comm-meet/2007 /031507 /e-13.pdf.
http://www.nysrc.org/pdf/MeetingMateriaI/RRSMeetingMateriaI/RRSA genda98/ A -07. pdf.
55 http://www.nerc.com/fies/FinaIPublic NERC-NPCC BES Report Camp Filing 9212009.pdf.
54
56 http://www.nerc.com/docs/docs!bot/BOT Complete Agenda Package 0208.pdfAgendItem8.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe. Page 27
27. Federal Energy Regulatory Commission, InformaI Filing by North American
Electric Reliability Corporation on Adequate level of reliabilty, Docket
RR07-14, dated May 5,200857;
28. BPS vs. BES, Comments of the New York State Reliability Council LLC FERC
Docket No. RM06-16-000 Mandatory Reliability Standards for the Bulk-Power
System and Docket No. RM07-3-000 Facilities Design, Connections and
Maintenance Reliabilty Standards), Dated January 3, 200758;
29. Comments of the New York State Public Service Commission on Mandatory
Reliability Standards for the Bulk-Power System, Docket RM-06-16-000, Dated
January 3, 200759;
30.
Performance
Based Methodology - Comments of the New York State
Reliabilty COUNCII, LLC on an alternative approach to establish facilities to
register, Topological and Impedance Element Ranking (TIER), dated
October 28, 200960;
31. IESO Reliability Compliance Program (IRCP) (Part 2.6 Treatment of
Compliance Issues); The Ontario compliance monitoring program managed by
the author of this document from late 1999 to September 200861;
57 http://www.nerc.com/files/Adequate Leve) of Reliab¡lity Defintion 05052008.pdf
58 http://elibrary .ferc. goy /¡dm ws/nvcommon/NV¡ntf.asp ?slcfilelist= 11218352:0.
http://www.dps.state.ny.us/ferc/FERC 01 03 07.pdf.
59 http://www.dps.state.ny.us/ferc/FERC 01 03 07.pdf.
60 http://elibrary .ferc. goy /idm ws/nvcommon/NV ¡ntf.asp ?s)dilelist= 12183979:0
http://www.nysrc.org/pdf/MeetingMaterial/RRSMeetingMaterial/RRSAgenda 125/Commen
. ?I)thpo/~?() NYSR C%20undpr0l2QRNl0f1 1J,_(1l\l). pdf.
61 http://www.ieso.ca/imoweb/pubs/marketAdm¡n/ma CompIssues. pdf
AESI ACUMEN ENCINEERED SOLUTIONS INTERNATIONAL INC.
Page 28
32. IESO Reliabilty Compliance Program (IRCP) (Part 7.9 Reliability Compliance
Program) 62
33. Memorandum of Understanding (MOU) between the New Brunswick System
Operator (NBSO) and Northeast Power Coordination Council (NPCC) and
North American Electric Reliabilty Corporation (NERC) dated November 19,
200863;
34. Market Procedure 8 - New Brunswick System Operator (NBSO)'s compliance
program64.
62 http://www.ieso.ca/imoweb/pubs/systemOps/so ReliabilityCompProgram. pdf
63 http://www.nbso.ca/Public/ private/MOU%20(NBSO- 'Yo20N PCC- %20N ERC). pdf
64 htt://www.nbso.ca/Public/ private/Mp-oS.pdf.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL ¡Ne. Page 29
Section 6.03
Appendix C Experts Background,
Qualifications, Training and Experience
Ronald J. Falsett, P.Eng.
2197 Glengrove Cres
Oakvile, Ontario, L6M 3X5
Business (905) 469-2376
Mobile (289) 888-1801
EDUCATION
1973- 1977
BESc in Electrical Engineering, UNIVERSITY of
WESTERN ONTARIO
EMPLOYMENT HISTORY
Nov 2008- Current ASSOCIATE - SENIOR CONSULTANT
AESI Acumen Engineered Solutions International Inc.
1998-Sept 2008 INDEPENDENT ELECTRICITY SYSTEM OPERATOR
1999-2008 TEAM LEADER / SENIOR EXCHANGE ENGINEER
. Responsible for managing IESO Reliability Compliance Program (IRCP);
monitoring, assessing and reporting Ontario marker participant and its compliance
to North American Electric Reliability Corporation (NERC) standards and
Northeast Power Coordinating Council (NPCC) Inc. criteria
. Managed IESO reliability standards and criteria review program providing
consolidated comments to NERC and NPCC standards and criteria under
development
. Managed IESO readiness for NERC compliance audits and readiness reviews
. Chair of IESO Reliability Standards Standing Committee (RSSC); a stakeholder
forum designed to:
i) Notify stakeholders of reliability related information on new and developing
reliability standards, NPCC criteria and Electric Reliability Organization (ERO)
matters
ii) Discuss, provide advice and to the extent possible, develop consensus
comments on new and developing reliability standards and criteria
iii) Engage stakeholders in the standard development process of NPCC Inc. and
NERC
. IESO representative and Vice-Chair (2005-2008) of NPCC Compliance
Committee (formerly Compliance Monitoring and Assessment (CMAS)
Committee) charged with providing objective stakeholder policy input 10 1he
NPCC Compliance Monitoring and Enforcement Program (CMEP); with notable
responsibility to:
i) Review and approve of NPCC Compliance Staff procedures for implementing
the CMEP
ii) Review and endorse processes used, by NPCC Compliance Staff, for
noncompliance assessments and determination of sanctions
AESI ACUMEN ENCINEERED SOLUTIONS INTERNATIONAL INe. Page 30
iii) Provide final approval of compliance assessments done by NPCC Compliance
Staff related to NPCC Reliability Criteria, including approval of non-monetary
sanction recommendations
iv) Provide a pre-hearing forum for the resolution of contested compliance and lor
sanction determinations
v) Conduct annual evaluations of the NPCC Compliance Staffs CMEP
implementation
Chair ofNPCC Registration Sub-Committee, responsible for providing direction to
the Compliance Committee and NPCC Compliance staff on entity registration.
Specifically with respect to developing the strategy and registration methodology
for generator owners/operators and transmission owners/operators as it pertains to
NPCC definition of bulk power system
. IESO representative on the Regional Standards Committee. A committee of the
NPCC Board, charged with:
i) Management and maintenance of the NPCC Standards Development
Procedure and processes;
ii) Providing consolidated NPCC Regional review and comment to the existing
and proposed NERC standards; and participate in the NERC Reliability
Standards Development Process; and
iii) Identification of upcoming issues associated with new NERC reliability
standards and their potential impact to the NPCC Region, (i.e. Regional
difference). Proposing solutions or guide the development of the standards
through effective and timely comments and soliciting NPCC participation on
the standard authorization requests (SAR) and reliability standards drafting
teams
. ISO/RTO Council (IRC) representative on NERC Compliance and Certification
Committee; a committee of the NERC Board with a mandate to engage, support
and advise the Board and NERC Compliance staff regarding ail facets of the
NERC Compliance Monitoring and Enforcement Program (Compliance program),
Organization Registration program (Registration program) and Organization
Certification program (Certification program). Specifically:
i) Provides comments to NERC Board and Compliance staff with respect to
stakeholders' perception of the policies, practices and effectiveness of the
Compliance program, Registration program, and Certification program.
ii) Recommends revisions of the ERO Rules of Procedure related to the
Compliance program, Registration program, and Certification program to the
NERC Board
iii) Establishes and implements programs to monitor NERC's compliance with the
reliability standards that apply to NERe, the Compliance program' s adherence
to applicable NERC's Rules of Procedure and its compliance with the Section
306 of the Rules of Procedure regarding the Reliability Standards development
pro
cess
iv) Serves as the hearing body for any contest regarding findings of or penalties or
sanctions for violation(s) of reliability standard(s) where NERC is directly
dards (Registered Entity by
monitoring the entity for compliance with those sian
agreement with an Regional Entity or absent a delegation agreement; the Region
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 31
itself where approved standards are applicable to the region) as described in the
NERC Rules of Procedure
v) Serves as the mediator for any disagreements between NERC and the Regional
Entities concerning NERC performance audits of Regional Entities compliance
programs
vi) Provide assistance to NERC and the Regional Entities to implement the
Compliance and Organization Registration and Certification programs
. Responsible for coordinating System Operation' s strategie reliability and business
risk management process
. Account Manager (7-month rotation) accountable for managing and facilitating
market participants registration and market entry prior to market opening
. Project coordinator for NERC's Electronic lnterchange Transaction (e-tags)
implementation
1977-1998
ONTARIO HYDRO
1990-1998
ACCOUNT MANAGER! ADVISOR - Wholesale Power Division,
Western Region
. Responsible for key industrial & municipal utility accounts, providing regulatory,
financial and technical guidance to plant managers and utility Commissions and
for managing ove
rail customer relationship
Identified, developed and facilitated implementation of innovative energy
solutions and energy supply contracts with key Industrial & municipal utility
accounts
. Responsible for developing municipal utility rates cases for Ontario Hydro Board
approval
1977-1990
SITE ENERGY COORDINATOR, ELECTRICAL SYSTEMS &
PROCESS CONTROL ENGINEER, - BRUCE NUCLEAR POWER
COMPLEX
Responsible for HV AC & electrical systems commissioning, diagnostic and
maintenance programs for emergency power combustion turbine units, HP steam
system controls and site electrical protection system
Chair -"BNPD Strategie Operating Planning Committee" responsible for
developing optimum short & long-term energy production deployment objectives,
strategies, guidelines, plans and software applications to maximize site electrical
output based on bulk electrical system limitations impacting Bruce flows (Iocked
in energy and spring freshet)
TRAINING
. Coaching Skills and Cooperative Coordination
Slra1egic Account Management Training
Major Account Management Training 1 &II and Problem Solving
. Relay Protection, Control and Metering Training
. Combustion Turbine Control Logic; Industrial Application of Gas Turbines
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INc.
Page 32
. Sales Certification and Integrity Selling Training
. Effective Negotiating Ski
Ils; Key Account Business Relations and Effective
Team Building
. Financial & Transactional Analysis Training
. Developing Potential Supervisors; Presentation Techniques; Time
Management
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INe.
Page 33
Section 6.04
Appendix D - About AESI Acumen Engineered
Solutions International Inc. and AESI-US Inc.
('/ AESI")
AESI is a well-established engineering firm (founded in 1984) with its head office in
Milton, Ontario, Canada and with a wholly owned US. subsidiary based in Atlanta,
Georgia, USA. Its professional staff and associates offer a full range of engineering and
consulting services to Electrical Utilities, Industry and Governments.
Since its inception in 1984, AESI has met the needs of both domestic and international
(i.e. offshore) clientele through a portfolio of capabilties in five distinct areas:
. Power System Operations and Planning
. Distribution Utility Services
. Information & Communication Technology & System Automation Services
. Power System Facilities Design, Construction, Operations & Maintenance
. Regulatory Compliance Services
The bulk of AESI's engagements have been focussed on electrical utilities at the
Generation, Transmission, System Operations and the Distribution level. AESI's
cliente
le includes government owned utilities, Co-operatives, Municipal utility
organizations, Independent Power Producers (IPPs) and Investor Owned Utilities
(IOUs). Over the years, AESI has successfully completed over 600 projects, primarily
in the electrical utility sector.
AESI ACUMEN ENCINEERED SOLUTIONS INTERNATIO:'AL INe.
Page 34
AESI's engagements span the following key service areas:
.
.
.
Creation of a control areas
Definition, selection and
implementation of
EMS/SCADA systems
Communications systems
planning and
implementa
tion
.
Power con
.
Training
tract negotiation
AESI' s profession
.
.
Audits of power contracts
.
l mplemen ta tion/refurbishm
CI? Audits assessments
ent of Control Centres
.
Power supply planning
studies
.
Audits of power system
operation
.
Strategic planning
NERC Reliabilitij
Standards reviews NERC-
and action plans for
compliance
.
.
.
Cyber security assessments
Project management
Utilitij engineering
services
al staff and associates have extensive experience ln
the following
areas:
.
.
.
.
.
.
NERC Reliabilitij Standards
NERC -CIP
Assessmen tsl Audi ts
IPP Analysis & Power
Supply Contracting
Inter-Utilitij Operations.
Electric Power System
Planning,
Operational Auditing.
.
.
Distribution Utility
Management
IT-Strategic Planning and
Implementation
.
Information Management
Systems, Customer Billing,
.
.
.
Power System Protection Co-
ordination.
.
.
.
Utility Restructuring (Open
Access and Deregulation of
.
Power Exchanges)
.
.
North American Regulatonj
and Competitive Issues in the
areas of Generation,
Transmission and
Distribution of Electricitij
Power System Facilities
.
.
Distribution Utility
Planning
Distribution Utility
Engineering & Operations
Engineering Operations,
Work Management and
Material Management
.
Application Software
Development
Design and Implementation
.
Corpora te
Plan nin g/Insti tu tional
Industrial Plant
Automation
.
Supervisonj Control and
Data Acquisition
Telecom/Network
Communications
.
Instrumentation
.
Training Services
Distribution Automation
Energy Management
Systems (EMS)
.
.
Smart Grid
AMI Systems
Design Construction and
Operations & Maintenance
A more detailed profie on AESI is available on its web site at www.aesi-ine.com.
AESI ACLJMEN ENGINEERED SOLUTIONS INTERNATIO:\AL INe.
Page 35
AESI's four key senior staff members have over 120 years experience working in the
Electric Utility Industry. AESI knows the industry and have the credentials. AESI has
done extensive work in the area of NERC compliance readiness assessments, mock
audits throughout the U.S. and Canada and assisting Utilties in their Compliance
readiness efforts.
AESI's methodology and approach for performing NERC Reliabilty Standards
assessments is among the leading/best practices in the industry. AESI has successfully
completed 35 NERC Reliability compliance readiness assessments (NERC non-CIP and
NERC CIP Standards) for its clients in the generation, transmission and distribution
business.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL INl
Page 36
Section 6.05
Appendix E
AESI's
NERC
Standards
Qualifications
Sin
ce the introduction of the NERC Reliabilty Standards, AESI has assisted a number
of clients, which include Government owned Utilities, G&T Cooperatives, IPPs, IOUs,
Distribution Utilities, Member Cooperative associations, Transmission Companies,
Generation Companies and System Operating Companies with the following activities
to assess their readiness for NERC Compliance and for improving their related
infrastructure mate
rial and systems to support NERC Compliance
(a) NERC CIP Reliability Standards
. Developing Risk Based Assessment Methodology for assisting in
determining Critical Assets and Critical Cyber Assets;
. Conducting Risk Based Assessment to identify Critical Assets and
associated Critical Cyber Assets,
. NERC CIP GAP Analysis reviews of Transmission, Generation and
Control System Facilities for:
o Generating Facilties
o Transmission Facilities
o Energy Management Systems
o SCADA Systems
o Conduct Vulnerability Assessments of the clients cyber assets
located at the clients generating facilities, transmission facilities and
control centers and the interconnection between these facihties and
external networks e.g : Corporate, Internet, Vendors, etc
o Prepare Compliance Action Plan based on Gap Analysis to establish
Time Schedule and Budget estimate to bring facilities into
compliance.
o Implement Solutions to bring Facilities into CIP Compliance
AESI AClJMEN ENGINEERED SOLUIlONS INTERNATIONAL INe.
Page 37
o Develop the required documentation to demonstrate CIP
compliance
o Delivering Cyber Security Workshops and Seminars on CIP
Compliance Readiness Process
o Providing on-going annual professional services to assist Utilities
with their NERC CIP Compliance sustainment program
(b) NERC non-CIP Reliabilty Standards
. Creating and upgrading documentation to demonstrate NERC
compliance;
. Readiness reviews (and mock audits) for NERC compliance for aIl types
of NERC Functional Entities (GO, GOP, TO, TOP, DP, LSE, PSE, BA,
etc);
. Providing support to client during actual NERC compliance review;
. Development of Utility Compliance Plan to help Utility manage their
Compliance Program;
. Development of Training Programs to meet NERC requirements;
. Development of training material and delivering NERC Compliance
Training;
. Helping generation owners with fulfillng Power System Equipment
Modelling and Data Requirements and Verification of Equipment
Capabilities;
. Help establish NERC Compliance Tracking System;
. Providing on-going annual professional services to assist Utilities with
their NERC Compliance sustainment pro
gram,
AESI can provide a complete range of compliance services to the Electric Utility
Industry and is able to effectively provide support in this critical new topic because of
its in-depth knowledge of, and the direct experience of its staff in, electric utility
planning and operations. AESI and its associates have provided NERC Reliability
Standards consulting services in all of the NERC Regions.
AESI ACUMEN ENGINEERED SOLUTIONS INTERNATIONAL ¡Ne.
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