Reliability Standards Standing Committee (RSSC)
Minutes of Meeting #30
Apr 29th, 2015 | 9:30 AM – 3:00 PM | IESO’s Boardroom, 16th Floor, 120 Adelaide St. W., Toronto
Attendance
Participant Name
Company Name
Attendance Status
Andrew Burmaster
Brookfield Renewable Power
Present
Ben Li
IESO
Present
Cristian Dragnea
MACD
Present
Dave Kwon
OPG
Present
David Barrett
IESO
Present
David Kiguel
Observer
Present
David Peterson
OPG
Present (on the phone)
David Ramkalawan
OPG
Present
David Robitaille
IESO
Present
Deanne Stene
TransAlta Energy
Present (on the phone)
Des Ngunangwa
Bruce Power
Present
Esia Giaouris
Hydro One
Present
George Fatu
MACD
Present
Gordon Bartels
TransCanada
Present (on the phone)
Helen Lainis
IESO
Present
James Cook
Great Lakes Power (Transmission)
Present (on the phone)
Janis Gartshore
Great Lakes Power (Transmission)
Present (on the phone)
Jay Jayaraman
Enbridge
Present
Jian Zhang
TransAlta Energy
Present (on the phone)
John Bridges
Enbridge
Present
Jon Veldhuizen
Northland Power Inc.
Present
Khaqan Khan
IESO
Present
Laurie Reid
Ontario Energy Board
Present
Monica Adam
MACD
Present (on the phone)
Nimesh Shah
Goreway Station Partnership
Present
Norm Dang
IESO
Present
Paul Malozewski
Hydro One
Present
Ralph Kothe
Bruce Power
Present
Ron J. Falsetti
AESI
Present
Scott Berry
IESO
Present
Shahid khan
Northland Power Inc.
Present (on the phone)
Soon Chua
Portlands Energy Centre
Present (on the phone)
Vlad Stanisic
TransCanada
Present
Scribe: Adnan Jabbar, rssc@ieso.ca: Please report any corrections, additions or deletions to scribe.
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All meeting materials are available on the IESO’s RSSC webpage at:
http://www.ieso.ca/Pages/Participate/Stakeholder-Engagement/Standing-Committee/Reliability-StandardsStanding-Committee.aspx
References:
IESO MACD page: http://www.ieso.ca/Pages/Participate/Market-Oversight/Compliance-Enforcement.aspx
IESO Reliability Standards Compliance page: http://www.ieso.ca/Pages/Participate/ReliabilityRequirements/Reliability-Standards-Compliance.aspx
NERC Standards page: http://www.nerc.com/page.php?cid=2
NPCC Regional Standards/Criteria page: https://www.npcc.org/Standards/default.aspx
FERC Electric page: http://www.ferc.gov/industries/electric.asp
Action Item Summary as of the 29th Meeting
#
Date
1
Feb 05, 2015 MACD (C. Dragnea) to provide a high-level side-by-side comparison of the compliance
framework in Ontario vs. NERC RAI
Feb 05, 2015 IESO (A. Jabbar) to circulate “lessons learned” notifications amongst the RSSC
members
Completed
Feb 05, 2015 IESO (A. Jabbar) to circulate these “NERC Alerts” amongst the RSSC members
Feb 05, 2015 IESO (H. Lainis) to set up a meeting to discuss misalignments between the
Transmission System Code requirements, and Reliability Standards
Apr 29, 2015 IESO (A. Jabbar) to get clarity from NPCC on the Quarterly Mis-operation reporting of
system elements (whether BES or BPS elements).
Completed
Completed
2
3
4
5
Action
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Completed
initiated
1.
Welcome and Introductions
The thirtieth RSSC meeting commenced at 9:30 a.m. with brief introductions by each participant.
2.
Administrative Issues
a) The agenda for the meeting was reviewed and no new agenda items were added
b) The minutes of the twenty-ninth meeting was reviewed (page by page). No major concerns were
raised. Motions to adopt the meeting minutes as final were made by A. Burmaster and P.
Malozewski
c)
Updates on the open action item were provided as follows:

Action item 1: MACD (C. Dragnea) to provide a high-level side-by-side comparison of the compliance
framework in Ontario vs. NERC RAI

Action item 2: IESO (A. Jabbar) to circulate “lessons learned” notifications amongst the RSSC members

Action item 3: IESO (A. Jabbar) to circulate these “NERC Alerts” amongst the RSSC members

Action item 4: IESO (H. Lainis) to set up a meeting to discuss misalignments between the Transmission
System Code requirements, and Reliability Standards
These items have been completed. There were no comments or questions from members.
d) RSSC Roster updates: A. Jabbar confirmed that some updates were made to the RSSC roster list that
are now reflected in version 50 (excel spreadsheet). The list was circulated amongst the committee
members by email prior to the face-to-face meeting.
3.
MACD perspectives on Ontario CMEP
C. Dragnea presented the Risk-Based Compliance Monitoring and Enforcement Program (RB-CMEP). His
agenda consisted of the following items: RB-CMEP definition, Risk concepts, Risk: market rules, Risk:
NERC/FERC, Enforcement discretion, and RAI vs. ORCP comparison.
He began the presentation by briefly describing the concept of Risk-Based Compliance Monitoring and
Enforcement Program (RB-CMEP). He mentioned that the RB-CMEP is a risk management process that
provides reasonable assurance by identifying, correcting and mitigating non-compliance. It uses a risk
hierarchy to prioritize issues based on actual and potential impact. C. Dragnea mentioned that this Risk
management process modulates the scope of compliance monitoring based on regional and entity risks;
where “Risks” are identified and prioritized based on the potential impact to the reliability of the
BPS/BES, and the likelihood, that such an impact might be realized.
Furthermore, he mentioned that the RB-CMEP generates better signals for strengthening compliance and
reducing risks to reliability and provides greater assurance that critical issues are addressed in a timely
manner. He then briefly walked through the definitions of a few Risk concepts and tied it in with how
MACD views risks in Ontario. Next C. Dragnea spent a fair portion of the time discussing NERC’s impact
scale which defines three levels of impact: serious and substantial, moderate, and minimal. He mentioned
that similar to NERC, MACD also utilizes an identical scale to “serious and substantial” when reviewing an
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event. MACD tries to understand (not just the event but) the value of various standards/requirements,
and evaluates the impact of each requirement from a reliability perspective. Thus, in essence MACD has
moved beyond just the Violation Risk Factors (VRFs) and created a model to capture the associated risk
factors and impacts of each requirement.
C. Dragnea then talked about how the term “Risk” is used and perceived in the market rules; more
specifically related to ch.3 s.6.6.6A, which covers the financial penalties greater than $10k. He shared
specifics on how the range of these penalties is determined in fixing the financial amounts (severity of the
breach, actual or potential impact of the breach, immediacy of the threat that the breach poses to
reliability etc.). He then talked about how the term “Risk” is used with FERC and NERC in sanctioning,
choosing an enforcement treatment, and/or choosing a monitoring regime.
Finally, C. Dragnea compared the RAI framework against what is implemented under the ORCP for the
following two elements: Monitoring (tools: self-certifications, spot checks, audits), and enforcement
(compliance exceptions, FFTs, self-logging). He covered each of the elements and sub-elements in great
detail. To conclude the presentation C. Dragnea asked the RSSC participants to think about other
elements in addition to NERC’s RB-CMEP that should be adopted by MACD to enhance the CMEP in
Ontario.
4.
NERC Lessons Learned – Incremental 2
S. Berry presented updates on the NERC Lessons Learned. He mentioned that the principal goal of the
Electric Reliability Organization (ERO) is to promote the reliability of the bulk power system in North
America. This goal is directly supported by evaluating bulk power system events, undertaking appropriate
levels of analysis to determine the causes of the events, promptly assuring tracking of corrective actions
to prevent recurrence, and providing lessons learned to the industry. S. Berry briefly talked about the
lessons learned posted late April 2015 that highlighted the record rainfall within a metropolitan area
which caused severe localized flooding at two large transmission substations, rendering the stations and
all terminating circuits unavailable.
5.
NERC Industry Advisory (FAC-003 Clearances)
S. Berry also presented NERC Advisory updates, which are intended to alert registered entities to issues or
potential problems. He mentioned that as part of its normal course of business, NERC often either
discovers, identifies, or is provided with information that is critical to ensuring the reliability of the bulk
power system in North America. NERC utilizes “alerts” to relay this information (by email) to users,
owners, and operators of the bulk power system in North America.
S. Berry shared an example of a recently posted NERC Alert related to “FAC-003-3 Minimum Vegetation
Clearance Distances”, where the intent of the advisory was to provide Transmission Owners (TOs) and
Generator Owners (GOs) information about preliminary testing results and anticipated adjustments to the
Minimum Vegetation Clearance Distances (MVCDs) specified in NERC Reliability Standard FAC-003-3. He
mentioned that NERC will undertake additional tests to finalize the preliminary gap factor determinations,
file a final report with FERC by June 30, 2015, and initiate a Standard Authorization Request (SAR).
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6.
CIP Version 5 Status Update
NERC initiated a program in 2014 to help the industry transition directly from the currently enforceable
CIP Version 3 standards to CIP Version 5. The goal of the transition program was to improve industry’s
understanding of the technical security requirements for CIP Version 5, as well as the expectations for
compliance and enforcement. The CIP Version 5 transition program will be in place through the
implementation period of the CIP V5 standards and beyond.
N. Dang provided members with an update, as he sits in the CIP Forum to discuss the actual CIP standards
and how they could be interpreted. N. Dang informed members that the CIP standards forum recently
met to discuss the MACD audit findings of CIP V3 (on twelve Market Participants). He also mentioned that
NERC filed a petition with FERC for the approval of proposed Critical Infrastructure Protection ("CIP")
Reliability Standards CIP-003-6, CIP-004-6, CIP-007-6, CIP-009-6, CIP-010-2, and CIP-012. Notably under
CIP-003-6 standard, some of the dates associated with low-impact assets were changed but for Cyber
coordinates program and the cyber security instant response, the date remains to be April 01, 2017. He
further mentioned that the only dates that were subject to change under CIP-003-6 standard were for the
physical security controls and electronic security controls (due to feedback from MPs – now due in
September 01, 2018).
R. Falsetti inquired about a recent NERC posting published on the April 23, 2015 which discussed control
centers and the functional obligations under CIP standard from a NERC’s perspective of what they deem a
control center to be. He mentioned that a particular section of the posting talked about an asset owner
that operates a breaker under the direction of a transmission operator would still be considered a TOP
function and therefore the control center wouldn’t be required to meet the CIP standard. He mentioned
that this is concerning to a lot of folks in the north east and would appreciate some input from the IESO.
Numerous discussions took place on this topic. S. Berry informed RSSC members that this is something
that will require further review before the IESO is in a position to answer specific questions. He also
mentioned that there have been a lot of activities in the CIP transitional area, especially in parts that have
been identified as BES; any questions or inquiries regarding CIP updates or future CIP meetings, can be
brought to N. Dang’s attention.
7.
NERC Risk Based Registration (RBR) Phase 2 Update
H. Lainis presented updates on the NERC Risk Based Registration (RBR). She mentioned that in addition to
NERC’s Risk Based compliance monitoring enforcement program; which was covered in the last RSSC
meeting; NERC had also been working on the Risk based registration which was part of the Reliability
Assurance Initiative (RAI). NERC launched the Risk-Based Registration (RBR) Initiative to ensure that the
right entities are subject to the right set of applicable Reliability Standards, using a consistent approach to
risk assessment and registration across the ERO. The goal is to develop enhanced registry criteria,
including the use of thresholds and specific Reliability Standards applicability, where appropriate, to
better align compliance obligations with material risk to Bulk Electric System reliability.
She mentioned that Phase 1 of the RBR removed from NERC Compliance Registration functions that are
commercial in nature, such as: Purchase Selling Entity (PSE), Interchange Authority (IA), Load-Serving
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Entity (LSE), and creates a UFLS-only Distribution Provider (DP). However, long before NERC launched its
Risk-Based Registration (RBR) Initiative, the IESO had already adopted this risk- based approach to its
applicability criteria. She mentioned that the IESO’s Applicability Criteria is similar to NERC’s Compliance
Registry; where it applies to Ontario Market Participants, is largely consistent with NERC’s compliance
registry and does not apply any reliability standards to the functions of PSE and LSE.
Next H. Lainis discussed details pertaining to the Risk-Based Registration – Phase 2. She mentioned that
NERC is considering the development of a “tier” system – subset of Reliability Standards obligations for:
•
Dispersed power producing resources and small generators
•
Low risk TO/TOP category
She mentioned that the IESO also considered a low risk TO/TOP category but no Ontario transmitter met
the criteria. Finally, she talked about the complex considerations involving Phase 2 and how there is a
need to better understand the impact of the sub-set classes of generation facilities in relation to the
unique characteristics of each power system. H. Lainis concluded the presentation by mentioning that the
IESO is going to be following the RBR progress very closely.
8.
Ontario Reliability Compliance Program Updates
A. Jabbar presented the updates to the 2015 Ontario Reliability Compliance Program. At a high-level he
underlined some of the updates/completed items in the 2014 Self-certification schedule since the last
RSSC meeting:
•
All Self-certs for NERC Reliability Standards under Set 2: [completed ]
•
All Self-certs for NERC Standards under Set 3: [completed]
•
2014 ORCP schedule spreadsheet was updated (ver. 9) to reflect all completions and posted on
the IESO ORCP public page.
He mentioned that the 2015 ORCP (Preliminary) Schedule was also posted online and gave a brief
overview on some of the items that were included:
•
Directory#12 UFLS Annual Survey – Forms 1718/1719; applicable to TO, GO, LSE, DP
•
Quarterly Protection System Operation/Misoperation Reporting; applicable to Market
Participants identified as BPS (A-10)
•
Emergency Preparedness/Restoration planning – Form 1608/1609; applicable to those market
participants identified by the IESO as Restoration Participants
•
Transmission Vegetation Management Program – Form 1527; applicable to TO and GO
D. Ramkalawan inquired about the Quarterly Protection System Operation/Misoperation Reporting as to
whether the reporting applies to BES or BPS elements. He mentioned that in his exchange with the NPCC
personnel the reporting should be on the BES elements above 100 kV. To which S. Berry mentioned that
the BES applicability based on the new (subjugation of) BES definition is not enforceable until July 01,
2016. However, the IESO can check with NPCC and provide some clarity (Action Item 5).
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Lastly, A. Jabbar (as an awareness piece) mentioned that a request for 2015 Q1 of Protection System
Operation/Misoperation reporting was issued on April 1st 2015, and is due on May 1st 2015.
< Lunch Break >
9.
Standards Enforcement Dates Update
A. Jabbar presented updates on the NERC standards that have now been approved by FERC since the last
RSSC meeting in Feb 2015 and their determined Ontario enforcement dates:
•
MOD-031-1 (Demand and Energy Data) – Enforceable on Jul 1, 2016 will respectively supersede
five existing Reliability Standards: MOD-016-1.1, MOD-017-0.1, MOD-018-0, MOD-019-0.1, and
MOD-021-1
•
PRC-006-2 (Automatic Underfrequency Load Shedding) – Enforceable on Jan 1, 2016 will
respectively supersede PRC-006-1
•
COM-001-2 (Communications) – Enforceable on Oct. 1, 2015 will respectively supersede COM001-1.1 Requirements R1, R2, R3, R5 and R6
•
COM-002-4 (Operating Personnel Communications Protocols) – Enforceable on Jul 1, 2016 will
respectively supersede COM-001-1.1 Requirements R4, COM-002-2, and COM-002-3
•
BAL-001-2 (Real Power Balancing Control Performance) – Enforceable on Jul 1, 2016 will
respectively supersede BAL-001-1
He informed members that all relevant Enforcement and Retirement dates will appear in version 6.0 of
the “Milestones in Reliability Standard Development and Lifecycle” spreadsheet (available on the IESO
public page). Participants were also encouraged to refer to the implementation plan (for each respective
standard), which consists of supplementary details regarding the enforcement dates of requirements and
sub-requirements.
10. Current NERC/NPCC/FERC Activities
10a) Update on Reliability Standards under Development and Coming into Effect in Ontario
H. Lainis presented updates on the current NERC/NPCC/FERC activities. She talked about the OEB process
and mentioned that the IESO is responsible for communicating any new or amended reliability standards
and criteria to market participants that may be subject to the Ontario Energy Board's (OEB) review. She
mentioned that:
•
The IESO posts briefings (summaries on NERC filings with FERC) on new or amended reliability
standards on its public page within seven days of it being notified by the standards authority.
•
There is a 21-day window for any market participant, including the IESO, to request an OEB
review of the posted reliability standard. The OEB would also be able to initiate its own review
within 120 days.
•
If there is no review, the standard would go into effect under the Market Rules upon the
enforcement date of the reliability standard.
•
If reviewed, the OEB has the authority to stop the standard from applying in Ontario and to refer
it back to the standards authority
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There were numerous discussions related to the cost implications within the briefings. H. Lainis
mentioned that at the time of the briefings some of the associated costs are unknown; hence they are left
blank. However for standards that fall under the functional model of a Balancing Authority (BA), Reliability
Coordinator (RC), and/or Transmission Operator (TOP); the IESO conducts an internal gap analysis which,
at times, reveals a potential cost factor. The cost implications for standards that fall outside of those
functional models are typically left with the applicable entities, to conduct their own assessment. In
addition, K. Khan mentioned that if costs associated with certain standards are concerning, there are
numerous opportunities to influence the process at the standards development stage (through
commenting/voting), or during the OEB review period, where participants have 21 days to request a
remand on a standard.
10b) Update on NERC Standards Committee Activities
B. Li presented updates on the NERC Standards Committee Activities. He mentioned that there had been
one face to face meeting and three conference calls since the Feb 2015 RSSC meeting. He also highlighted
some of the major issues:
•
Special election held to replace vice-chair, who has stepped down unexpectedly.
•
Special election held to fill two vacant positions. Segment 8 vice-chair, who stepped down
unexpectedly and Segment 9 created by an incumbent’s resignation.
•
SC Chair canceled the June face-to-face meeting in favor of a conference call. This was based on
the expectation that the agenda was only an hour long. This Proposal was made two days after
NERC’s announcement of confirming a meeting location.
B. Li talked briefly about two sub-committees that report to the standards committee; one being the
Process Sub-committee (SCPS), which focuses on maintaining the documents that support the standards
development process. He mentioned that the SCPS Subcommittee:
•
Developed a process for consensus building and SAR development, which is in the informal
stage. This is prior to the official launch of a standard development project to enhance
effectiveness and formality of standards development. The current status is stalemate.
•
Elected 3 new members to fill vacancies.
The other subcommittee B. Li talked about was the Project Management and Oversight Subcommittee
(PMOS), which works with NERC staff to support industry subject matter experts (SMEs) in all aspects of
standard development. He mentioned that the PMOS Subcommittee:
•
Has a newly elected chair (Ron Parsons) and a newly elected Segment 6 vice-chair (Brenda
Hampton)
10c) NERC Standards Development
On the next item, B. Li shared numerous updates on Reliability Standards recently posted for
Comment/Ballot, a select few of which are highlighted below:
•
Revision to Multiple Standards to address obligations for Disperse Generation following the
adoption of Phase 2 BES Definition (i.e., Inclusion I4):
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“I4 - Dispersed power producing resources with aggregate capacity greater than 75 MVA (gross aggregate
nameplate rating) utilizing a system designed primarily for aggregating capacity, connected at a common point at a
voltage of 100 kV or above”
Since the last RSSC meeting NERC had initiated a series of projects to insert wording into a
number of standards to exempt small generating units from having to meet those requirements
that apply to >20MVA units. The following standards have been revised and have received high
approval rate: PRC-001, PRC-004, PRC-005, PRC-019, PRC-024 and VAR-002.
•
Physical Security Standard CIP-014-2, where FERC approved the CIP-014-1 standard, but directed
NERC to revise the standard to remove the word “widespread”. The IESO assessed that this
removal had no material impacts on the standard’s intent or applicable entities’ obligations.
•
Revision to Multiple TOP/IRO Standards; a project initiated to address concerns raised in the
November 2013 FERC NOPR. A total of 9 standards were revised/added, along with a proposal to
retire 5 IRO standards and 6 TOP/PRC standards (all requirements absorbed by or redundant
with the 9 proposed standards). All standards passed final ballots.
10d) NPCC Standards/Criteria Development
Lastly B. Li presented an overview of the proposed revisions to NPCC Directory #4 (System Protection
Criteria). He mentioned that NPCC proposes to revise this Directory to:
•
Clarify the design criteria for the new protection systems that use IEC 61850 communication
protocol.
•
The proposed criteria will help the protection systems owners in designing protection systems
that meet security and redundancy criteria required by BPS elements following regulatory
approval of NERC PRC-005-2 standard.
He mentioned that the IESO generally supported the proposed revisions and that at present, there are no
such protection systems deployed in Ontario. Any or all changes to Directory #4 are intended to add
clarity without any material impacts on the current criteria.
11. Other Items
Towards the end of the meeting S. Berry shared some information on NERC’s Self‐Report User Guide that
is intended to provide guidance to assist Registered Entities with the submission of self‐reports. He also
shared information on NERC’s ERO Mitigation User Guide, which provides guidance to registered Entities
on proper steps to take, and items to consider, when creating Mitigation Plans.
12. Next Meeting
The 31st RSSC meeting (Q3 for 2015) is scheduled for Monday September 14, 2015 at the new corporate
address: 120 Adelaide Street West (downtown Toronto).
No further items were brought up and the meeting ended at 03:00 PM. Motion to adjourn was made by J.
Jayaraman and V. Stanisic.
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