Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
2012-08-30
Proposed New ISO Rules Section 502.8 Supervisory Control and Data Acquisition Requirements (“New ISO Rules Section 502.8”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
Comments From:
2012/08/30
2012/08/30
through 2012/09/28
Company Name
Contact:
Company Contact
Phone:
Contact Phone Number
E-mail:
Date [yyyy/mm/dd]:
Listed below is the summary description of changes for the proposed new, removed or amended sections of the ISO rules. Please refer back to the Letter of Notice under the “Attachments to Letter of
Notice” section to view the actual proposed content changes to the ISO rules. Please place your comments / reasons for position underneath (if any).
1. ISO Rules
(a) Purpose of New ISO Rule
Stakeholder Comments and/or Alternate Proposal
AESO Replies
Comment #1: Insert Comments / Reason for Position (if
any)
New ISO Rules Section 502.8 sets out the minimum supervisory control and data
acquisition (“SCADA”) requirements for a market participant when designing and
constructing new facilities or modifying existing facilities.
In developing the New ISO Rules Section 502.8 the AESO has redrafted and
relocated authoritative content from the existing AESO SCADA Standard. In
addition, in developing New ISO Rules Section 502.8 the AESO is proposing
amendments as outlined below, that resulted from a the review performed with an
industry workgroup and internal AESO personnel.
In the AESO’s opinion, these proposed changes are necessary for improved
visibility of facilities for the safe and reliable operation of the interconnected electric
system.
The AESO is seeking comments from stakeholders with regard to the following
matter:
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1. Do you agree or disagree that proposed New ISO Rules Section 502.8 reflects
the relocated authoritative content from AESO SCADA Standard and that the
AESO has clearly and adequately represented the key changes in proposed
New ISO Rules Section 502.8? If you disagree please provide your reasons
and suggestions for improvement.
2. Are there any subsections where stakeholders feel that the language does not
clearly articulate the requirement either for the AESO or a market participant? If
yes, please indicate the subsection and suggest language that would more
clearly articulate the requirement.
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(b) Proposed Changes
Comment #2: Insert Comments / Reason for Position (if
any)
Proposed Change
Reference to the
Subsections in
Proposed New ISO
Rules Section 502.8
1. Applicability.
Subsection 1 –
Applicabililty
The AESO is proposing two changes to the
applicability subsection:
a. The AESO is proposing that proposed New ISO
Rules Section 502.8 apply to the legal owner of a
generating unit connected to the electric
distribution system or multiple generating units
connected to the same metering point on the
electric distribution system where the output of
such generating unit or multiple generating units
is greater than or equal to five (5) MW measured
at the metering point on the electric distribution
system. In the AESO’s opinion, visibility is
needed for the larger generators as these can
impact the safe and reliable operations of the
interconnected electric system.
b. The AESO is proposing to remove the total
output rating of 5 MVA threshold for generating
units connected or aggregated generating
facilities connected to the transmission system.
In the AESO’s opinion, generating units and
aggregating generating facilities connected to
the transmission system are greater than 5 MVA
and therefore a threshold is not required.
2. Functional Specifications.
The AESO is proposing to include subsections clarifying
compliance requirements to functional specifications
Issued for Stakeholder Consultation: 2012-08-30
Subsections 2 –
Facility with Functional
Specifications Issued
On or After the
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issued prior to and after proposed New ISO Rules 502.8
becoming effective. In the AESO’s view, it is important to
provide clarity with respect to the functional
specifications.
Effective Date,
Subsection 3 - Facility
with Functional
Specifications Issued
Prior to the Effective
Date, Subsection 4 Functional
Specification, and
Subsection 5 Successor to Prior
Requirements.
3. The existing SCADA Standard has thresholds
relating to time synchronization and time stamped
events and only those facilities meeting the
thresholds are required to have an external global
positioning system and communicate time stamped
transactions. In proposed New ISO Rules Section
502.8 the AESO is proposing to remove the
thresholds; all facilities, on a go forward basis are
required to have global positioning systems and
communicate time stamped transactions.
In the AESO’s opinion, accurate time synchronization of
SCADA is important to the safe and reliable operations
of the Alberta interconnected electric system.
Subsection 8 - Data
Acquisition, provisions
(11) and (12)
4. The AESO is proposing to remove the options for a
market participant to use direct connection via
modem or dial up modem connection to the AESO’s
primary and backup control centres. In proposed
New ISO Rules Section 502.8 the AESO allows for
either an internet connection or a dedicated
telecommunications link to the AESO’s primary and
backup control centres.
Subsection 9 –
Supervisor Control and
Data Acquisition
Communications,
provision (1).
In the AESO’s opinion, modem and dial up modem
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technology is obsolete and new technology is more cost
effective and reliable.
5. The AESO is proposing to require a market
participant to select a communication diagram from
a set of diagrams provided by the AESO; rather than
having a market participant develops its own
communication block diagram.
In the AESO’s opinion, it is more efficient for the AESO
to create a set of generic communication block diagrams
rather than having every market participant create its
own.
Subsection 9 –
Supervisor Control and
Data Acquisition
Communications,
provision (6).
6. The AESO is proposing to add requirements for the
market participant with regard to notifying the AESO
if communications become unavailable.
In the AESO’s opinion, notification of unavailability is
important to the safe and reliable operations of the
interconnected electric system.
Subsection 10 –
Notification of
Unavailability
7. The AESO is proposing to add requirements
regarding the potential failure of a remote terminal
unit.
In the AESO’s opinion, notification of potential failures is
necessary for the safe and reliable operations of the
Alberta interconnected electric system.
Subsection 11 –
Potential Failure of a
Remote Terminal Unit
8. The AESO is proposing to add requirements for
routine operational testing of remote terminal units.
The existing SCADA standard discussed testing but did
not clarify any requirements. In the AESO’s opinion, it is
important to clarify the specific requirements.
Subsection 12 –
Routine Operational
Testing
9. The AESO is proposing to add a subsection
clarifying the compliance exceptions.
In the AESO’s opinion, adding this subsection provides
clarity for market participants.
Subsection 13 –
Compliance
Exceptions
10. The AESO is proposing the following changes for
power plants and generating units:
a. Adding requirements for net real power and net
reactive power of summated generation if the
facility is offering as a single market participant.
Appendix 1 –
Supervisor Control and
Data Acquisition
Requirements for
Generating Units
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b. Adding a requirement for automatic voltage
regulation setpoint.
c. Adding requirements for automatic voltage
regulation in service and controlling voltage.
d. Adding requirements for facilities with a remedial
action scheme.
e. Adding requirements for a generating unit
connected to the distribution system where the
total turbine nameplate rating is greater than 5
MW.
f. Adding a new requirement for the ambient
temperature.
In the AESO’s opinion these proposed changes improve
visibility of the facilities and ultimately the safe and
reliability operations of the Alberta interconnected electric
system.
11. The AESO is proposing the following changes for
wind aggregated generating facilities:
a. Relocating the SCADA requirements from
subsections 24 and 25 of ISO rules Section
502.1 Wind Aggregated Generating Facilities
Technical Requirements.
b. Adding requirements for facilities with a remedial
action scheme.
c. Adding requirements for aggregate generating
facilities connected to the distribution system
where the total turbine nameplate rating is
greater than 5 MW.
With respect to 8(a) above, in the AESO’s opinion, it is
easier for stakeholders to understand all the SCADA
requirements if the requirements are consolidated into
one location, that being proposed New ISO Rules 502.8
rather than being dispersed across multiple ISO rules.
Appendix 2 Supervisor Control and
Data Acquisition
Requirements for Wind
Aggregated Generating
Facilities
With respect the (b) and (c) above, in the AESO’s
opinion, these proposed changes improve visibility of the
facilities and ultimately the safe and reliability operations
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of the Alberta interconnected electric system
12. The AESO is proposing the following changes for
industrial complexes and load facilities:
a. Adding requirements for facilities with a remedial
action scheme.
In the AESO’s opinion these proposed changes improve
visibility of the facilities and ultimately the safe and
reliability operations of the Alberta interconnected electric
system.
Appendix 3 Supervisor Control and
Data Acquisition
Requirements for
Industrial Complexes
and Load Facilities
13. The AESO is proposing the following changes for
substations and transmission line taps:
a. Adding requirements for facilities with a remedial
action scheme.
In the AESO’s opinion these proposed changes improve
visibility of the facilities and ultimately the safe and
reliability operations of the Alberta interconnected electric
system.
Appendix 4 Supervisor Control and
Data Acquisition
Requirements for
Substations and
Transmission Line
Taps
14. The AESO is proposing the following changes for
facilities providing ancillary services:
a. Amending the availability percentage from 99.7%
to 99.8% for consistency with the availability
requirement in the AESO’s Ancillary Services
Technical Requirements documents.
b. Amending the accuracy level from zero to +/- 2%
of dispatched signal for the analogue signals for
resources providing load shed service for
imports.
c. Adding thresholds for latency and availability
requirements for resources providing blackstart
services.
With respect to 15(a) above, in the AESO’s opinion, the
availability requirement in proposed New ISO Rules
502.8 should be consistent with the availability
requirement in the AESO’s Ancillary Services Technical
Requirements documents.
Appendix 5 Supervisor Control and
Data Acquisition
Requirements for
Facilities Providing
Ancillary Services
With respect to 15(b) above, in the AESO’s opinion, a
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market participant may be processing the signal received
from the AESO and as such it may be impractical to
expect a zero percent accuracy.
With respect to 15(c) above, in the AESO’s opinion the
additional clarity will assist in the safe reliable operation
of the Alberta interconnected electric system.
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(c) Other Changes
In redrafting and relocating authoritative content from the AESO’s SCADA Standard
to proposed New ISO Rules 502.8, the AESO has amended language to improve
clarity.
Comment #3: Insert Comments / Reason for Position (if
any)
(d) Content Relocated into an Information Document
Comment #4: Insert Comments / Reason for Position (if
any)
In developing proposed New ISO Rules Section 502.8, the AESO determined that
some content was informational in nature and not appropriate for relocation into
proposed New ISO Rules Section 502.8. However, the AESO believes that this
non-authoritative content is helpful to stakeholders and as such the AESO has
developed the supporting Information Document #2012-013R Supervisory Control
and Data Acquisition (“ID #2012-013R”).
The AESO is seeking comments from stakeholders with regard to the following
matter:
1. Do stakeholders agree with the content the AESO is proposing to relocate
into ID #2012-013R? If you disagree, please provide comments please
indicate the specific content you believe is not appropriate for the ID #2012013R and your rationale for this.
(e) Content Not Relocated to either Proposed New ISO rules 502.8 or ID#
2012-013R
In developing proposed ISO Rules 502.8 the AESO determined that certain
sections in the AESO SCADA Standard were not required in either proposed New
ISO Rules Section 502.8 ID #2012-013R. These sections are listed below.
Comment #5: Insert Comments / Reason for Position (if
any)
1. Section 3.1 – Definitions. All definitions approved by the Alberta Utilities
Commission, for use in ISO rules are represented in the AESO’s
Consolidated Authoritative Documents Glossary. Therefore, the AESO has
not relocated the definitions into proposed New ISO Rules Section 502.8. For
clarity, this does not mean that the AESO does not refer to defined terms in
proposed New ISO Rules Section 502.8, only that the definitions are not held
in proposed New ISO Rules Section 502.8.
2. Section 3.4 – Interconnections to Power Systems Outside AIES. This section
states that the AESO will determine SCADA points for interconnections to
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power systems located outside the Alberta Control Area on a case-by-case
basis. The AESO develops interconnections agreements with parties with
facilities external to the interconnected electric system, but need to connect
those facilities to the interconnected electric system. The AESO is not
relocating this section because no specific requirements are being set out in
proposed New ISO Rules Section 502.8 for these interconnecting parties.
3. Section 1.4 – Modifications. This section discusses protocols with respect to
modifications to the AESO SCADA Standard. In the AESO’s opinion, this
section is obsolete with respect to proposed New ISO Rules section 502.8
and supporting ID #2012-013R and therefore this content has not been
relocated.
4. Section 1.5 – Requirement for Review. This section sets out a five (5) year
mandatory review of the AESO SCADA Standard. In the AESO’s opinion, this
section is obsolete with respect to proposed New ISO Rules section 502.8
and supporting ID #2012-013R and therefore it has not been relocated.
5. Section 1.6 – Document Change History. This section sets out the revision
history for the AESO SCADA Standard. In the AESO’s opinion, this section is
obsolete with respect to proposed New ISO Rules section 502.8 and
supporting ID #2012-013R and therefore this content has not been relocated.
However, the AESO wishes to point out that proposed New ISO Rules section
502.8 and supporting ID #2012-013R will each have their own revision history
section.
6. Section 6.8 – IPP Use of TFO Communication Systems. The AESO is
presently discussing the use of TFO Communication Systems with
transmission facility owners and as such this section has not been relocated
to either proposed New ISO Rules section 502.8 or supporting ID #2012013R.
7. Section 8.1 – Designated Party. This section contemplates that a
transmission facility owner may contract with another entity to perform certain
functions and if it does the TFO should communicate that to the AESO in
writing. In the AESO’s opinion, it is up to the transmission facility owner if it
wants to contract with another entity to perform certain functions. The AESO
will communicate with those personnel in the same was it communicates with
employees of the transmission facility owner. For example, if there are
contract personnel in the transmission facility owner’s control centre the
AESO will communicate with those personnel the same way it communicates
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with employees in the control centre. Therefore, the AESO has not relocated
this section.
8. Section 8.2 Responsibilities of the Designated Party. Proposed New ISO
Rules section 502.8 are applicable to the legal owner of a facility. In the
AESO’s opinion, if a facility owner chooses to contract out functions it is up to
the legal owner to appropriately train those personnel to meet all the
appropriate requirements in ISO rules and other AESO authoritative
documents. It is not up to the AESO to instruct those personnel to meet all
the appropriate requirements in ISO rules and other AESO authoritative
documents. Therefore, the AESO has not relocated this section.
The AESO is specifically seeking comments from stakeholders on the following
specific statements:
1. Do stakeholders agree with the content the AESO is proposing to not relocate
into either proposed New ISO Rules 502.8 or ID #2012-013R? If you disagree,
please provide comments please indicate the specific content you believe
should be retained and if it should be retained in proposed New ISO Rules
502.8 or ID #2012-013R.
(f) Other
(Stakeholders wishing to comment on specific provisions are requested to copy the
provision into this area and provide comments)
Comment #6: Insert Comments / Reason for Position (if
any)
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