Stakeholder Comment and Reply Matrix AESO AUTHORITATIVE DOCUMENT PROCESS

Stakeholder Comment and Reply Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
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]:
2012/08/30
2012/08/30
through 2012/09/28
1. ISO Rules
(a) Purpose of New ISO Rule
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:
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.
Stakeholder Comments and/or Alternate Proposal
AESO Replies
ATCO Electric
1.
1. Agree with minor exceptions:
Appendix 4 – SCADA Requirements for
Transmission Facilities.
- The second status point for each facility
“Communications failure indication between an
intelligent electronic device and any remote
terminal unit acting as a data concentrator” was
proposed for removal at the industry working
group.
1. Intelligent electronic device is not defined in
the Consolidated Authoritative Document
Glossary. Does it refer to relays,
communications processors, and/or remote
terminal unit peripherals?
2. At larger facilities, there are over twenty of
these alarms. Does AESO wish to receive all of
these individual alarms? Or, would a single
grouped communications alarm for each facility
suffice?
1.
It is the AESO’s opinion that the status of the
Communications is essential to the safe and
reliable operations of the Alberta Interconnected
Electric System and as a result is not being
removed.
Yes, an intelligent electronic device includes
relays, communications processors, and/or
remote terminal unit peripherals. In the AESO’s
opinion, intelligent electronic device is a
commonly understood term by industry. As a
reference, for additional information, a market
participant can refer to “Authoritative Dictionary
of IEEE Standard Terms”.
With regard to the alarms, the intent is to capture
the need to monitor the primary communications
links between the AESO, owners of transmission
facilities and owners of generating facilities,
control systems and not every device within a
facility. A grouped alarm is sufficient.
AESO Replies to Stakeholder Comments: 2012-12-11
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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.
2.
-The third analogue point for transformers:
“Voltage regulation setpoint if the transformer has a
load tap changer.” This is a new requirement
which is not in the existing SCADA standard and
was not discussed at the industry working group.
This is not an analogue value which we report back
to our control centre. Considerable effort would be
required to change our engineering standards in
order to provide this value at new facilities. This
value cannot be provided at existing facilities
without significant retrofits. We request AESO’s
perspective on the value this analogue provides.
This ISO Rule is applicable on a go forward basis
and therefore retrofitting existing facilities is not
required, unless the AESO determines that a
modification is required for reliability reasons. If
such modifications are required, the requirement
to provide the additional data point will be clearly
identified in the AESO Functional Specification.
In the AESO’s opinion the provision of the
voltage regulation setpoint assists the AESO in
the safe reliable operation of the AIES. These
values are used by the AESO network
applications to verify the AIES system model and
in the Dispatcher Training Simulator advanced
applications.
Therefore, the AESO has not amended final
proposed New ISO Rules Section 502.8 as a
result of this comment.
3.
- Remedial Action Scheme (RAS) – In section 1.3
of the existing SCADA standard, underfrequency
and undervoltage load shedding is excluded from
the definition of special protection systems
(SPS/RAS). Furthermore, it was confirmed during
the industry working group that underfrequency
and undervoltage load shedding is not considered
a RAS. On this basis, we object to the inclusion of
the following status points: remedial action scheme
operated on under-frequency load shed, and
remedial action scheme operated on under-voltage
load shed.
4.
Subsection 3(2) – In the event the ISO determines
that the legal owner must be comply with this new
rule for an existing facility, how will the legal owner
be notified? And what timeframe will the legal
owner have to comply with the directive? We
request this clarification to assist with determining
the impact to our organization.
2. The AESO agrees with ATCO Electric’s comment
and has removed the requirement to report the
underfrequency and undervoltage load shedding
status points in Appendix 4 of final proposed ISO
Rules Section 502.8
3. If the AESO identifies the need to a legal owner of
an existing facility to modify its facilities in order to
comply with certain provisions of ISO Rules
Section 502.8, once in effect, the AESO will notify
the owner and subsequently initiate a project,
consistent with current AESO practices. The
timeframe regarding the modifications and
AESO Replies to Stakeholder Comments: 2012-12-11
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compliance is determined on a project by project
basis.
4. It is the AESO’s responsibility to assign slave
device addresses and has amended final
proposed New ISO Rules Section 502.8 to clarify
this.
5.
Subsections 8(2) & (3) – Sections 6.4-6.7 of the
existing SCADA standard require the ISO shall
provide addressing for the slave device. The new
rule is not clear on who is responsible for assigning
slave device addresses. We suggest adding this
clarity to the new rule.
6.
Subsection 8(4) – Deadbands for report-byexception are typically set at each slave device,
which are configured by the legal owners. The
wording does not seem to assign responsibility to
the legal owners to configure the deadband values
on their systems. We suggest adding this clarity to
the new rule.
5. The AESO agrees that it is the responsibility of
the legal owners to configure deadbands and has
amended final proposed New ISO Rules Section
502.8 to provide this clarity.
7.
Subsections 8(6) & (7) – There was significant
discussion on this at the industry working group.
The proposed wording is still unclear. What does
nominal equipment rating refer to? The transducer
itself or the line/transformer for which the analogue
values are being measured? What about situations
where transducers are not used and the analogue
values are being provided via a microprocessor
relay? We suggest rewording these subsections
and possibly adding and example to the new
Information Document to add clarity.
6. The nominal voltage is the normal operating
range of the specified equipment that is being
monitored, (i.e. the transformer).
8.
Subsection 8(9) – The wording “except for those
situations where all source measurements are
positive polarity” is not clear. We request either
rewording it or providing a clear example in the
new Information Document.
With regard to an analogue value being provided
via a microprocessor, the value shall be the true
value of the point being monitored.
To provide additional guidance, the AESO has
included additional information and an example
in supporting Information Document #2012013R Supervisory Control and Data Acquisition
(“ID #2012-013R”).
The AESO has not amended final proposed New
ISO Rules Section 502.8 as a result of this
comment.
7. The AESO agrees with ATCO Electric’s
suggested change and has included an example
in supporting ID #2012-013R as a result of this
comment.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 3 of 35
9.
Subsection 8(10) – For additional clarity, we
propose adding a requirement to report MVAR
measurements from a capacitor as a positive
polarity.
10. Subsection 9(6) – We request additional clarity for
the last portion of this subsection, “with any
variations as appropriate.” The text accompanying
the two diagrams in the new Information Document
Appendix suggests that scan rates should be
provided on a project-by-project basis. Is this a
requirement of the rule, or simply a suggestion? If
it is a requirement, we request it be clearly stated
as such in the rule.
11. Subsections 12(1) & (2) – We request additional
clarity around the definition of routine operational
testing. As an example, if a TFO is taking a remote
terminal unit out of service to program additional
points for a 25kV circuit breaker addition, does the
TFO have to notify AESO within the timeframes
listed in subsection (2)? Or, was the intent to
address situations where the TFO is performing
regular testing on transducer equipment which
would impact the analogue values which are
reported to AESO, as was discussed at the
industry working group?
12. All Appendices – Under the Accuracy Level
9. The AESO agrees with ATCO Electric’s
suggestion and has amended final proposed
New ISO Rules Section 502.8 as a result of this
comment.
10. In the AESO’s view, there are no new
requirements being introduced in the information
document. The latency times are specified in the
appendices of proposed New ISO Rules Section
502.8.
For each project, the legal owner is required to
provide the AESO with the generic
communication diagram that best depicts the
communication systems. If there are any
variations, such as, use of a different/unlisted
protocol, then the AESO requires that the legal
owner identify and communicate the variations to
the AESO in accordance with subsection 9(6) of
proposed New ISO Rules Section 502.8.
The AESO has not amended final proposed New
ISO Rules Section 502.8 or ID #2012-013R as a
result of this comment.
11. After review of this comment and further review
of subsection 10 Notice of Unavailability
(“subsection 10”) and subsection 12 Routine
Operational Testing (“subsection 12”), it is the
AESO’s opinion that subsection 12 is not
required. If a legal owner decides to perform
operational testing of a remote terminal unit
which will result in the unplanned removal of that
remote terminal unit then the legal owner must
notify the AESO of the unavailability of the
remote terminal unit in accordance with
requirements set out in subsection 10.
Therefore the AESO has amended final
proposed ISO Rules Section 502.8 and removed
subsection 12.
12. The AESO has amended proposed ISO Rules
AESO Replies to Stakeholder Comments: 2012-12-11
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column, the term “full scale” is used frequently.
This term is not defined in the Consolidated
Authoritative Document Glossary. We request
clarification and suggest an example be included in
the new Information Document.
13. Appendix 4 – Transformer Winding analogues
Real power and reactive power is required on the
high side terminal of the transformer. This implies
that on 240/144kV transformers, only the power
measurements at the 240kV terminal are required.
Please confirm.
14. Information Document – Sections 4-6 have been
excluded. Please confirm this is an oversight in the
numbering of the sections.
15.
Information Document Section 7 – The text
accompanying the figure is unclear:
“Interconnected Electric System (or transmission
system?” We request clarity on this.
16. Information Document Section 8 – The statement
“If, after informing the AESO of the communication
path, the communication path changes, then the
legal owner should inform AESO of those changes”
conflicts with subsection 9(7) of the rule which
states “A legal owner…must, if it changes its
communication protocols, communicate these
changes to the ISO in writing ninety (90) business
days prior to changing the protocols.” We request
resolution of this discrepancy.
ENMAX Power Corporation
17. ENMAX Power Corporation (“EPC”) appreciates
the opportunity to comment on the proposed new
ISO Rule. EPC agrees with the proposed new rule
however makes the following suggestions in
comments 2-4 below to add clarity.
Section 502.8 subsections 8.6, 8.7 and 8.8 to
include the term “full scale” to improve clarity. In
addition, the AESO has included an example in
the information document for additional guidance.
13. AESO requires only the 240Kv power
measurement (MW and MVAR) across the
transformer. Power flow measurements on the
low voltage side of the transformers are identified
in the transmission line section of the
appendices.
14. With regard to Section 4-6 being excluded from
ID #2012-013R, this was a numbering error
rather than an exclusion of content and the
numbering has been corrected in the information
document.
15. The text in subsection 7 of ID #2012-013R
should read the “interconnected electric system”.
The reference to the “transmission system” has
been removed.
16. The AESO agrees with ATCO Electric’s
suggestion and has amended the language in
subsection 8 of ID #2012-013R for alignment with
final proposed ISO Rules Section 502.8.
17. With regard to Comment #2, the AESO agrees
the provision should read “universal time code
minus seven hours.
Therefore, the AESO has amended final
proposed New ISO Rules Section 502.8 as a
result of this comment.
AESO Replies to Stakeholder Comments: 2012-12-11
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Comment #2: Section 8(11) – The mountain
standard time zone is UTC -7 hours. Wording
should read “universal time code minus seven
hours”.
Comment #3: Section 9(4) – The Rule could be
improved by making a statement around facilities
greater than 1000 MW that have both primary and
backup Control Centres. Presumably, both facilities
should provide two communications circuits to each
of the ISO’s primary and backup coordination
centre.
Comment #4: The wording in Section 10(1) is
vague when viewed from the perspective of a TFO.
EPC suggests changing the wording from “the
communications circuits” to “the communications
circuits with the ISO”. This removes ambiguity with
respect to the communications circuits between a
TFO Control Centre and its own RTUs.
With regard to Comment #3, the AESO agrees
with Enmax’s suggestion. Therefore the AESO
has amended proposed New ISO Rules Section
502.8 as a result of this comment.
With regard to Comment #4, The AESO believes
that the communication between the remote
terminal unit and the owner of a transmission
facility’s control centre affects the safe operation
of the system and as such the unavailability of
these components should be reported to the
AESO. Therefore the AESO has not amended
proposed New ISO Rules Section 502.8 as a
result of this comment.
AESO Replies to Stakeholder Comments: 2012-12-11
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TransAlta
18. The language in Subsection 13 is unclear. What
does “any particular piece of equipment” refer to?
We note 13(b) focuses on the RTU. We also note
that subsections 11 and 12 focus on RTUs. Is
Subsection 13 solely focused on the RTU? If not,
we suggest rewording for clarity.
19. It is unclear in the Appendices when “Availability” is
used whether it is referring to Subsection 10 of
Rule 502.8 which deals with the availability of
communication circuits. Please clarify.
18. Subsection 13 is specific to remote terminal units
and the AESO agrees that the language can be
reworded for clarity. Therefore, final proposed
New ISO Rules Section 502.8 has been
amended as a result of this comment.
19. The term “availability” in the appendices does not
refer to the communication circuits but rather the
overall availability requirements to provide
SCADA to the AESO. For example, if a legal
owner is designing and constructing a generating
unit directly connected to the transmission
system, then the legal owner should be designing
and constructing the generating unit such that its
SCADA is available 98% of the time with an
expected mean time to repair of 48 hours.
(b) Proposed Changes
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
AESO Replies to Stakeholder Comments: 2012-12-11
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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 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.
Subsections 2 – Facility with Functional
Specifications Issued On or After the
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.
AltaLink Management Ltd
20. AltaLink recommends that more details be provided
regarding the application of the Rule on existing
facilities.
A. AltaLink notes that ‘facility’ is central to the
proposed rule yet is undefined and the
definition of transmission facility is overly
broad for this purpose as it can include all
equipment as a single facility. AltaLink
recommends that, for the purposes of rule
502.8, facility be defined as: “One or more
pieces of power carrying equipment connected
sequentially so as to carry power from one
location to another and including the
associated insulators, supporting structures,
20. (A) The AESO has adopted the meaning of
transmission facility from the Electric Utilities Act.
The term “transmission facility” is used
extensively throughout legislation and throughout
ISO Rules, Alberta Reliability Standards and the
ISO Tariff.
In addition, the AESO has used plain language
text when referring to a “facility” throughout ISO
Rules, Alberta Reliability Standards and the ISO
Tariff. The use of the word facility maybe used
in a variety of contexts depending on the
document in which it is referenced. For this
reason, the AESO has chosen not to develop a
definition for facility.
AESO Replies to Stakeholder Comments: 2012-12-11
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protection devices, telecommunication and
control devices as well as supporting services
such as HVAC, battery banks, generators,
chargers, etc. as required for safe operation of
the facility. The exact grouping of power
equipment to be specified in the AESO
Functional Specification which lead to its’
design and construction.”
B. AltaLink interprets AESO practices in writing
Functional Specifications to mean that a single
RTU may provide visibility and control for
multiple facilities (as defined above). AltaLink
requests the AESO confirm that under
provision 3(3), existing facilities do not
automatically become compliant with rule 502.8
when another facility, which is reported by the
same RTU, must be compliant with rule 502.8.
E.g.: When adding a new 240kV line to an
existing substation, the new line, breaker,
disconnects, protections associated
telecommunications, etc. must be compliant
with rule 502.8 while the pre-existing
equipment and facilities must remain compliant
with the standard they were built to unless
AESO designates they become compliant with
rule 508.2 under provision 3(2).
C. AltaLink recommends that subsection 3(3) be
revised to provide further clarification that it
does not apply to maintenance activities
related to the repair or replacement existing
supervisory control and data acquisition
systems.
ATCO Electric
(B) The functional specification identifies any new
requirements which a legal owner of a transmission
facility may need to include in its estimate. For
example, if the legal owner of a transmission facility is
connecting a new line into an existing substation, and
the remote terminal unit is at capacity, then the needs
identification document, the supporting facilities
application, and the functional specification will
identify that a new remote terminal unit is required
and as such will be included in project costs and
detailed design. It is the AESO’s intent to address
project specific requirements on a case by case basis,
which is consistent with current practices.
(C) With regard to repair or replacement, if a remote
terminal unit is being replaced in its entirety, the
AESO’s expectation is that the new remote terminal
unit meets the requirements of proposed New ISO
Rules Section 502.8. If there are exceptional
circumstances and the requirements cannot be met,
then the legal owner can request, with supporting
reasons, an exemption for the rule.
The AESO has amended the wording in final
proposed New ISO Rules Section 502.8 subsection
3(3)(b) to “upgrade or alter the functionality of its
supervisory control and data acquisition system” to
improve clarity.
21. It is not the AESO’s intent to force unnecessary
upgrades or costs to existing facilities. If the
AESO Replies to Stakeholder Comments: 2012-12-11
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21. Item 2 – Functional Specifications
Subsection 3(3)(a) requires that a legal owner must
comply if it is modifying its facilities to increase its
Rate DTS or Rate STS contract capacity. In many
cases, this requires an addition of a 25kV circuit
breaker or transformer upgrade, but no changes to
the SCADA hardware. Requiring a legal owner to
comply with the new rule in such cases would incur
significant cost with minimal net value. We
propose addressing such cases with the ISO on a
case-by-case basis via the functional specification
as was proposed at the industry working group.
existing SCADA hardware has capacity to
facilitate the addition then no upgrade is
necessary.
If a legal owner is adding facilities to increase
capacity then the AESO will initiate a project
consistent with current practices. When
developing the functional specifications for the
facility, if there is a need to upgrade the SCADA
hardware, it will be determined at that time by
either the AESO or the legal owner or both.
Therefore it is the AESO’s intent to address
project specific requirements on a case by case
basis, as suggested by ATCO Electric, which is
consistent with current practices.
The AESO agrees that the language in
subsection 3(3) can be clarified to allow for a
determination on a project by project basis in
addition to the criteria set out in proposed New
ISO Rules Section 502.8. Therefore final
proposed New ISO Rules Section 502.8 has
been amended as a result of this comment.
ATCO Power
22. Regarding section 3(1) – “…the provisions of this
section 502.8 do not apply to a facility with a functional
specification the ISO issued prior to the effective date of
this section 502.8, but the facility must remain in
compliance with that functional specification including
all of the standards and requirements set out in that
functional specification.”
ATCO Power is of the view that this language
should be changed to reflect the fact that some
older facilities were approved and constructed
under ad hoc standards and that functional
specifications in the sense intended in the new rule
were not always issued. All such facilities were
built and are now operated according to approved
22. The AESO recognizes that the facilities that
connected several years ago may not have
functional specifications. The AESO’s
expectation is that a market participant adhere to
the technical requirements or standards in effect
at the time it the facilities connected the facilities
to the transmission system.
The AESO agrees subsection 3(1) be amended
to reference “technical standards” and therefore
final proposed New ISO Rules Section 502.8 has
been amended as a result of this comment.
AESO Replies to Stakeholder Comments: 2012-12-11
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standards and those standards should govern their
present operation.
TransAlta
23. We find the combination of subsections 3(1), 3(2)
and 5 to be confusing as it implies grandfathering
potentially overridden by a notwithstanding
condition and then combined with phrasing which
states that earlier standards will no longer be in
force. If a facility is acceptable under an earlier
technical standard then that standard must remain
in force. Please clarify
24. We also observe that subsection 3(3)(a) does not
have a threshold of change and literally a 1 MW
change could trigger compliance with Rule 502.8
for an older facility. We would suggest that a
change greater than 10% would be a reasonable
threshold. Please clarify.
TransCanada Energy Ltd
23. The AESO agrees subsection 5 is confusing and
unnecessary and as such can be removed.
Therefore final proposed New ISO Rules Section
502.8 has been amended as a result of this
comment.
24. Please refer to AESO Reply #21 above.
25. Please refer to AESO Reply #23 above.
25. Section 3(1)
TCE is concerned with the AESO’s proposal to
repeal previous versions of ISO technical
standards (as provided for under Section 5 of this
rule) and instead require that the legal owners of
existing facilities comply only with requirements
included in the approved functional specification for
these existing facilities.
26. It is TCE’s view that older generation facilities
were approved and constructed pursuant to ISO
technical standards in effect at that time and may
not have “functional specifications” that are
consistent with, or comparable to, the functional
specifications that are issued under the AESO’s
current connection process.
27. TCE believes that the ISO technical standards
applicable at the time these facilities were
approved and constructed may not contain all of
the relevant information that may be necessary for
26. Please refer to AESO Reply #22 above.
27. The AESO recognizes that the older technical
standards may not be as robust as ISO rules;
however the AESO is not intending to revise the
language in existing technical standards.
AESO Replies to Stakeholder Comments: 2012-12-11
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monitoring and ensuring compliance.
28. Therefore TCE submits that further consultation is
required to implement a process to ensure that
development or completion of “functional
specifications” for existing facilities before repealing
the various existing ISO technical standards such
as the AIES SCADA Standard effective September
5th, 2005.
29. Section 3(2)
TCE understands that it may be necessary for the
AESO require that existing facilities comply with
specific provisions of ISO Rule Section 502.8 in
order to maintain the safe and reliable operation of
the system.
30. However, TCE is concerned that section 3(2) lacks
a description of the criteria (and the reasons behind
the selection of any criteria) that the AESO would
use in making such a determination applicable on a
retroactive basis. As a result, it is not clear to TCE
under what circumstances its existing facilities
could become subject to Section 502.8.
31. TCE submits that the AESO should consult with
stakeholders on the criteria the AESO should apply
in making a determination under section 3(2) and
provide further clarity with respect to how the
AESO will apply such criteria.
32. In addition, TCE is concerned that section 3(2)
does not appear to contemplate the need for a
28. It is not the AESO’s intent to “repeal” the existing
AESO SCADA technical standards. These
technical standards will remain on the AESO
website as those market participants that
connected under these technical standards are
expected to remain in compliance with those
technical standards.
29. Yes TCE’s interpretation is correct. There may
be times when the AESO requires existing
facilities to comply with specific provisions of ISO
Rules Section 502.8 in order to maintain the safe
and reliable operation of the system.
30. If existing facilties need to be modified the
decision is based on the safe, reliable and
economic operation of the system. Consistent
with current practices, the AESO performs
studies based on the planning requirements
established in Alberta Reliability Standards. If an
issue is identified, the AESO assesses options to
address the issue which could result in a
modification to an existing facility.
If existing
facilities need to be modified the AESO initiates
discussions with the legal owner and
subsequently initiates a project to implement the
required modifications. The specific
modifications and the timing of those
modifications are likely different for each project
and as such are determined on a case by case
basis.
31. Please refer to AESO Reply #30 above.
32. Please refer to AESO Reply #4 and Reply #30
above.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 12 of 35
process under which the AESO would consult with
the legal owners of existing facilities should the
AESO determine that upgrades are needed. TCE
submits section 3(2) should set out the process
under which the AESO would work with existing
facilities to achieve compliance with the new
standard.
33. Section 3(3)
As discussed above TCE is concerned with the
application of this new rule to existing facilities.
TCE recommends that AESO adapt the rule
language to reflect that the application to existing
facilities undergoing uprates to their DTS and STS
contract capacity be made on a case by case basis
and that not all uprates would trigger the
application of this rule. For example, market
participants could achieve increases in their output
and hence their STS contract level by simply
finding efficiencies that reduce on site load
requirements thus resulting in an increase in the
MW’s that could be offered to the market.
Alternatively, there could be increases in output as
a result of turbine efficiency upgrades that allow
existing generators to produce more power. In both
instances it is not obvious that changes to the
SCADA system would be necessary or practicable.
34. Section 4
TCE requests that the AESO clarify whether its
practice going forward will be to specify in the ISO
Rules the requirements for the functional
specifications. If so, does the AESO intend to
consolidate in one location the requirements for
functional specifications so that new facilities can
easily determine what the functional specifications
will include?
35. Section 5
33. Please refer to AESO Reply #21 above.
34. All projects in the recent past and on a go
forward basis will have functional specifications
in accordance with the AESO’s Connection
process and System Projects process. While
many elements in a functional specification are
consistent from project to project, the functional
specification is also the document that sets out
variances to accommodate project specific
requirements. It is not the AESO intent to
develop a rule that sets out the requirements for
a functional specification.
35. Please refer to AESO Reply #28 above.
As discussed above TCE is concerned with the
AESO’s proposal to repeal the AIES SCADA
AESO Replies to Stakeholder Comments: 2012-12-11
Page 13 of 35
Standard and require that existing facilities to
comply only with the requirements set out in the
existing facility’s functional specification.
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)
AltaLink Management Ltd
36. AltaLink supports with wording suggestions.
AltaLink recommends that subsections 8(11) and
(12) be re-worded to:
(11) A legal owner of a generating unit, legal
owner of an aggregated generating facility,
legal owner of a transmission facility and
legal owner of a load must install one (1)
millisecond accurate time sources for all
facilities which must be compliant with section
502.8. Where they have a global positioning
system clock, use the coordinated universal
time as the base time and report time stamped
events in one of:
36. The AESO agrees with AltaLink that additional
clarification is needed. The AESO has amended
subsection 11 of final proposed New ISO Rules
Section 502.8 as a result of this comment. The
AESO did not see a need to amend subsection
12 of final proposed New ISO Rules Section
502.8 as a result of this comment
(a) Universal Coordinated Time;
(b) Mountain Standard Time; or,
(c) Mountain Time including automatic time
zone shifts at the start and end of daylight
savings time.
(12) A legal owner of a generating unit, legal
owner of an aggregated generating facility,
legal owner of a transmission facility and
legal owner of a load must ensure that time
stamped events are reported with one (1)
millisecond accuracy.
The reference to a global positioning system clock
has been removed so that the method of achieving
the accuracy is left to the discretion of the legal
owner. In addition, the proposed wording only
required that existing clocks be used without
requiring an accurate time source be installed for
new facilities.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 14 of 35
ATCO Electric
37. Item 3 – Data Acquisition
Regarding AESO’s interpretation from this
document: “all facilities, on a go forward basis are
required to have global positioning systems and
communicate time stamped transactions.”
1. The wording in subsection 8(11) “A legal
owner…must, if they have a global positioning
system clock…” does not align with AESO’s
interpretation
2. There are no subsections within the rule which
imposes a requirement on a legal owner to
communicate time stamped transactions.
38. Furthermore, the industry working group did not
feel that communicating time-stamped at the
source transactions to AESO is practical and raised
the following issues which remain unaddressed:
37. (1) The AESO agrees that the language should
be amended to correctly articulate the need to
have global positioning system clocks on a go
forward basis. Therefore final proposed New
ISO Rules Section 502.8 has been amended as
a result of this comment.
(2) The rule only requires that a GPS has an
accuracy of 1 millisecond. There is no
requirement for the legal owner to provide a time
stamped transaction from the GPS to the AESO’s
coordination centre.
38. Consistent with AESO Reply #30 above the
AESO reaffirms there is no requirement to
provide time stamping from existing field devices
directly to the AESO.
Communication of time stamped events is
obtained through data streaming of PMU data as
required.
1. Time-stamps are only critical for post-event
analysis, which is addressed already under
OPP1304.
2. Existing infrastructure at some TFO Control
Centres is not capable of transmitting the
timestamp from the intelligent electronic device
at the substation all the way through to the
AESO System Coordination Centre
We support the installation of GPS clocks to
provide accurate time-stamping of data for postevent analysis. We do not support communicating
these time-stamps from the source to AESO as
part of real-time data.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 15 of 35
TransCanada Energy Ltd
40. Section 8(11)&(12)
Can the AESO confirm whether facilities are
required to install a global positioning system
clock?
41. TCE is concerned that the requirement to ensure
that the GPS is accurate to one millisecond may be
overly onerous and is concerned that the potential
for compliance violations with this subsection of
ISO Rule 502.8 is significant.
42. Further, TCE finds sections 8(11) and 8(12)
confusing the AESO indicates the base time
should be pacific standard time (PST) rather than
mountain standard time (MST). However, in section
8(12) when referring to daylight savings time it is
not clear if the AESO is referring to pacific daylight
savings time (PDT) or mountain daylight savings
time (MDT). TCE suggests that for clarity and ease
it would be preferable to use standard time whether
that be MST or PST.
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.
40. Proposed New ISO Rules Section 592.8 states “if
installing a global positioning clock…. “. If the
AESO determines that a global positioning clock
is required then the AESO will specific this in the
functional specification.
41. Global positioning system clocks come with one
(1) millisecond functionality and as such this
requirement is not overly onerous.
42. The AESO agrees with TCE and will reference
Mountain Standard Time. Please refer to AESO
reply #30 above.
Subsection 9 – Supervisor Control and
Data Acquisition Communications,
provision (1).
In the AESO’s opinion, modem and dial
up modem technology is obsolete and
new technology is more cost effective
and reliable.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 16 of 35
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).
AltaLink Management Ltd
43. AltaLink supports with language changes.
1. AltaLink requests that the location of the
diagrams be stated in provision 9(6) and
suggests an appendix to the rule as an
appropriate location.
2. AltaLink requests that the diagrams be
individually titled to prevent confusion in
correspondence.
AltaLink supports with language suggestions:
(7) A legal owner of a generating unit, legal owner of
an aggregated generating facility, legal owner of a
transmission facility and legal owner of a load must,
if it changes the communication protocols used between
itself and the AESO, communicate these changes to the
ISO in writing ninety (90) business days prior to
changing the protocols.
43. (1) The AESO discussed the location of the
diagram with the workgroup and determined that
the supporting ID #2012-013R was an
appropriate location for the diagrams and as such
has included the diagrams in supporting ID
#2012-013R. As part of the AESO’s principles, it
does not include references to information
documents in the ISO Rules. Therefore final
proposed New ISO Rules Section 502.8 has not
been amended as a result of this comment.
(2) The AESO agrees with Altalink’s suggestion
regarding the titles and has amended the titles of
the documents in supporting ID #2012-013R.
The AESO agrees with AltaLink’s suggestion
regarding changes to subsection 9(7). Therefore
the AESO has amended final proposed New ISO
Rules Section 502.8 as a result of this comment.
The italicized words have been added to reduce the
number of notices that would need to be sent to the ISO
for changes which are strictly internal to facility owner
equipment. The method of achieving and sustaining the
Functional Specification for a specific facility should be
left to the discretion of the facility owner.
ATCO Electric
44. Item 5 – We support the idea of choosing from
standard communication diagrams provided by
AESO, however, the diagrams provided in
Appendix 1 of the new Information Document has
embedded requests for further information
(protocols, scan rates) which is over and above
selecting a standard diagram.
44. The AESO has amended final proposed New ISO
Rule Section 502.8 subsection 9(7) to clarify that
the requirement for protocols and scan rates is
only applicable to communications between a
legal owner and the AESO. For example, this
means that if a transmission facility owner
changes a protocol between itself and the
generating facility owner’s intelligent electronic
device, then the transmission facility owner is not
required to notify the AESO of this change as long
as this change has no impact to the AESO.
Therefore the AESO has amended final
proposed New ISO Rules Section 502.8
AESO Replies to Stakeholder Comments: 2012-12-11
Page 17 of 35
subsection 9(7) as a result of this comment.
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
AltaLink Management Ltd
45. AltaLink suggests re-wording to clearly segregate
the design and construction provisions from
operational provisions and relocating the
operational provisions to an OPP.
46. A. AltaLink suggests re-wording provision 10(1) to:
45. The AESO recognizes that there are operational
requirements in proposed New ISO Rules
Section 502.8. For practicality and efficiency
reasons, the AESO has consolidated both the
design and build requirements and the
operational requirements into one rule. The
AESO has not relocated the operating
requirements into a separate ISO rule however it
has amended the title of final proposed New ISO
Rules Section 502.8 to clearly state that the rule
contains both technical and operating
requirements.
46 The AESO is proposing changes to subsection 10.
Please refer to AESO Replies #47 and #48 below.
10(1) A legal owner of a generating unit, legal
owner of an aggregated generating facility, legal
owner of a transmission facility and legal owner
of a load must design and construct the facility and
the communication system to AESO so that, if any
measurement required by Annexes 1 through 5
becomes unavailable, the ISO will be notified
immediately after determining such unavailability.
The change supports the designed operation of
high-reliability systems (i.e.: switching to an
alternate path) in the event of predictable
disruptions such as path fading. It also aligns
reporting with events which affect the ISO.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 18 of 35
47. B. AltaLink requests that provisions 10(3), 10(4)
and 10(5) be re-located to an OPP. The provisions
are operational in nature and do not fit within the
stated focus of rule 502.8: “…the design and build
domain.” And they can’t be complied in the timeline
specified in subsection 2. Specifically:
“… [owners] must ensure the facility meets the
minimum supervisory control and data acquisition
requirements of this section 502.8 prior to
commissioning and energization of the new
facility.”
48. C. AltaLink suggests that the re-located provisions
be re-worded to:
(3) A legal owner of a generating unit, legal
owner of an aggregated generating facility,
legal owner of a transmission facility and
legal owner of a load must provide the ISO
with:
(a) the cause of any unavailability reported
pursuant to section 10(1);
(b) in the event of an equipment failure: a plan,
to repair the failed equipment, including testing;
and
(c) the expected date and time when the
required measurements will be restored.
(4) The legal owner of a generating unit, legal
owner of an aggregated generating facility,
legal owner of a transmission facility and
legal owner of a load must, if the required
measurements are not restored by the expected
data and time, notify the ISO with the revised
date and time and the reason why the
communication system was not repaired.
(5) The legal owner of a generating unit, legal
owner of an aggregated generating facility,
legal owner of a transmission facility and
legal owner of a load must notify the ISO once
the required measurements are restored.
47. With regard to the relocation of content please
refer to AESO Reply #45 above.
With regard to the comment of not being able to
comply with the timeline the AESO has amended
final proposed New ISO Rules Section 502.8
subsection 2 to clarify that a market participant
must design and build facilities based on the
requirements and must verify that the facilities
meets the requirements during commissioning
and energization of the facilities.
48. With regard to the suggested relocation of
subsection 10, please refer to AESO Reply 47
above.
The AESO agrees with AltaLink’s suggestions
regarding, subsection 10(3)(b), 10(3)(c), 10(4)
and 10(5) and has amended final proposed New
ISO Rules Section 502.8 as a result of this
comment.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 19 of 35
The changed wording separates handling of
equipment failures (which can be repaired) from
other causes which can’t be repaired and provides
the ISO with a projected return to service time
regardless of the cause.
49. AltaLink requests that the AESO confirm that the
capabilities already in use over the connection
between existing control centers in the form of
quality flags associated with each measurement
meet the design requirements of this subsection.
ATCO Electric
50. Item 6 – We propose changing the reporting
requirements to match what is already required by
R3 of PRC-001-AB-1:
“R3. Each TFO must do the following if a protective
relay or any equipment fails and such failure
reduces transmission system reliability on the BES.
R3.1. Notify the ISO…as soon as possible, but no
longer than 24 hours after the earlier of receiving
knowledge of such failure.
49. Proposed New ISO Rules Section 502.8 applies
on a go forward basis. The AESO expects that
existing facilities remain in compliance with the
AESO SCADA standard or other technical
standards referenced in the functional
specification issued for the specific project subject
to any modifications that may be required in
accordance with subsection 3(2) of proposed New
ISO Rules Section 502.8.
50. The AESO appreciates the concern for
consistency however, in certain circumstances
the AESO will need to know about the loss of a
communication circuit within 24 hours. For
example, if a communication circuit providing
regulating reserves or that has a remedial action
scheme, then the AESO needs to know about
these failures immediately.
The AESO has not amended final proposed New
ISO Rules Section 502.8 as a result of this
comment.
R3.2. Commence as soon as possible and proceed
diligently thereafter, to correct such failure unless
otherwise directed by the ISO.”
The rationale for this request is we already have a
reporting process in place for teleprotection circuit
failures under PRC-001 and believe it would be
efficient to follow the same process for
unavailability of the SCADA communication circuits
and remote terminal units.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 20 of 35
EPCOR Distribution & Transmission Inc
51. EDTI wishes to understand the AESO’s view of a
potential failure of a Remote Terminal Unit. EDTI
does not actively monitor its RTUs for potential
failures, other than for the availability of the
devices, which is covered in subsection 10. Can
the AESO provide clarification of the phrase
“potential failure with a remote terminal unit”?
Given that subsection 10 addresses all situations
when any component in a communication circuit
becomes unavailable, EDTI believes that
subsection 11 is redundant and/or unnecessary.
TransCanada Energy Ltd
52. Section 10 & 11
The Rule does not specify how the AESO is to be
notified pursuant to section 10 and 11. TCE
requests that the AESO set out how the
notifications contemplated in sections 10 and 11
should be communicated to the AESO. TCE
recommends that when notification is required
under these subsections that the market
participants are required to notify the AESO via
email of the system or facility becoming
unavailable, failing or being repaired. TCE submits
that 24 hours is a reasonable time frame.
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
AltaLink Management Ltd
51. There are circumstances where a remote terminal
unit is available but there is reason to believe that
the data being provided is deficient or unreliable.
If the AESO or a market participant identifies such
a circumstance then this information needs to be
communicated to/from the AESO and the market
participant such that the issue can be investigated
and addressed accordingly.
In the AESO’s opinion, the language did not
clearly represent the intent and as such the AESO
has amended final proposed New ISO Rules
Section 502.8 as a result of this comment.
52. The AESO agrees that the contact information is
necessary. The AESO’s practice with regard to
notification/contact information is to include this
information in the supporting information
document. The AESO has included the contact
information in supporting ID #2012-013R.
53. Please refer to AESO Reply #51 above.
53. AltaLink requests further description of the potential
failures which the AESO envisions would be
covered by this subsection, how they could be
identified in the design and build domain and how a
plan separate from good engineering design and
project management practices would be required
within the design and build domain.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 21 of 35
54. AltaLink suggests that the subsection belongs in an
OPP as the provisions are operational in nature
and can’t be complied in the timeline specified in
subsection 2. Specifically:
54. Please refer to AESO Replies #47 and #55
above.
“… [owners] must ensure the facility meets the
minimum supervisory control and data acquisition
requirements of this section 502.8 prior to
commissioning and energization of the new facility.”
ATCO Electric
55. Item 7 – In addition to the comment previously
stated for Item 6, the industry working group
agreed that this was a more reasonable strategy in
lieu of measuring the existing availability statistics
required by section 8.3 of the existing SCADA
standard. The availability numbers are still
included in the Appendices to the rule. We
propose moving them to the new Information
Document instead, as they are useful targets for
engineering and design, but difficult to track and
compile for compliance
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
AltaLink Management Ltd
55. The AESO discussed section 8.3 with the
working group and there was discussion on
whether the availability targets should or should
not remain in the rule and the conclusion was
that these targets should remain in the rule as
they are design targets. The group further
discussed that specific provisions would be
included in the rule to set out notification and
repair requirements should a unit become
unavailable.
The AESO has not amended final proposed New
ISO Rules Section 502.8 as a result of this
comment.
56. Please refer to AESO Replies #11 above.
56. AltaLink requests further description of the routine
testing which the AESO envisions would be
covered by this subsection within the design and
build domain.
57. AltaLink suggests that the subsection belongs in an
OPP as the provisions are operational in nature
and can’t be complied in the timeline specified in
subsection 2. Specifically:
57. Please reply to AESO Reply #47 above.
“… [owners] must ensure the facility meets the
minimum supervisory control and data acquisition
requirements of this section 502.8 prior to
commissioning and energization of the new facility.”
AESO Replies to Stakeholder Comments: 2012-12-11
Page 22 of 35
ATCO Electric
58. Item 8 – Has AESO considered how this
subsection ties into OPP601 and OPP1306? We
foresee situations where a TFO may be required to
report the same information multiple times which is
undesirable and inefficient.
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.
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.
Appendix 1 – Supervisor Control and
Data Acquisition Requirements for
Generating Units
AltaLink Management Ltd
59.
58. The AESO has removed subsection 12 Routine
Operational Testing, in final proposed New ISO
Rules Section 502.8. Please refer to AESO Reply
#11 above.
59. Please reply to AESO Reply #47 above.
AltaLink suggests that the subsection belongs in
an OPP as the provisions are operational in
nature and can’t be complied in the timeline
specified in subsection 2. Specifically:
“… [owners] must ensure the facility meets the
minimum supervisory control and data
acquisition requirements of this section 502.8
prior to commissioning and energization of
the new facility.”
AESO Replies to Stakeholder Comments: 2012-12-11
Page 23 of 35
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 of the Alberta interconnected
TransAlta
60.
60. The AESO thanks TransAlta for this general
information.
In regard to proposed change #11 we note that
this includes Subsection 25 of Rule 502.1 which is
intended to provide information for wind
forecasting. As the AESO is aware the data in
Subsection 25 is being provided to the forecaster
via the internet to the AESO for wind forecasting.
Certain SCADA requirements for wind speed and
direction are a residual of the old wind technical
rule. At present this information is being provided to
the AESO by two separate methods.
61. We do not consider that the availability required of
wind forecasting related data should be the same
as for other key data indicated in Appendix 2. Wind
speed and direction from a meteorological tower is
not critical to the operation of the wind farm which
uses wind speed and direction from each wind
turbine to control operations.
62. Our review of Subsection 25 of Rule 502.1 and of
Appendix 2 of proposed rule 502.8 shows many
differences in the requirements between the two
rules. We note, for example, that the anemometer
units per Subsection 25 are in m/s whereas in Rule
502.8 it says km per hour. How does the AESO
plan on reconciling such differences?
63. We note the accuracies on wind speed and wind
direction and we offer the observation that such
accuracies are possible under normal operation but
would not be possible under adverse winter
weather conditions.
61. In the AESO’s opinion, the wind speed and
direction from a meteorological tower is critical to
the reliable operations of the system. The AESO
has not amended final proposed New ISO Rules
Section 502.8 as a result of this comment.
62. The AESO has reviewed Appendix 2 and has
amended the km per hour in Appendix 2 of final
proposed New ISO Rules Section 502.8 to align
with ISO Rules Section 502.1.
63. The AESO thanks TransAlta for this general
information.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 24 of 35
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
AltaLink Management Ltd
AltaLink supports with wording changes.
64. A. AltaLink notes that “facility” is not defined and
suggests that “For each facility” be changed to “For
each substation”.
65. B. AltaLink requests that the term RTU be added to
the glossary and defined based on IEEE C37.2,
2011
66. C. AltaLink requests that the first point description
be re-worded to
”Communications failure alarm for the channel
between each RTU reporting on a facility meeting
the requirements of provision 6(4) and a
transmission facility control centre” and that
64. The AESO has reviewed this comment and
agrees that it is appropriate to use the word
substation rather than facility in the first column
of Appendix 4. Therefore the AESO has
amended final proposed New ISO Rules Section
502.8 as a result of this comment.
65. In the AESO’s view, the meaning of “remote
terminal unit” has been well understood for
several years without a definition. As a
reference, for additional information, a market
participant can refer to “Authoritative Dictionary
of IEEE Standard Terms”.
Therefore, the AESO has not amended final
proposed New ISO Rules Section 502.8 as a
result of this comment.
66. In the AESO’s view, proposed New ISO Rules
Section 502.8, subsection 6(4) clearly states that
a legal owner must meet the requirements set
out in Appendix 4 if it meets at least one of the
criteria listed in subsection 6(4), and as such, it is
not necessary to cross reference the
requirements in Appendix 4 back to subsection
AESO Replies to Stakeholder Comments: 2012-12-11
Page 25 of 35
requirements for generating unit communications
be moved to/left in Annexes specific to generating
units.
67. D. AltaLink suggests rewording “Communications
failure indication between an intelligent electronic
device and any remote terminal unit acting as a
data concentrator” to:
6(4). Therefore, the AESO has not amended
final proposed New ISO Rules Section 502.8 as
a result of this comment.
67. The AESO agrees with Altalink’s suggestion and
has amended final proposed New ISO Rules
Section 502.8 as a result of this comment.
“Communication failure indication between any IED
and each RTU which is reporting to a control
center. (There will be a separate status from each
RTU in sites with multiple RTUs.)”
as the current wording has several possible
interpretations.
68. E. The phrase ‘full scale’ as used in Analog
Accuracy Level needs to be defined. Provision
8(6) states scaling requirements with respect to
nominal value without defining “full scale”.
69. F. The Analog Accuracy Level needs to be defined
with respect to the point in the load curve where it
is measured. AltaLink suggests the mid-point of
the reporting range used.
70. G. AltaLink requests that the 0.5% resolution
requirement be calculated on nominal value.
Alternatives include: the range defined in
subsection 8(6) or the physical range of the
measuring device.
68. Please refer to AESO Reply #12 above.
69. The AESO has included an example in the ID
#2012-013R which illustrates the point in the load
curve where the accuracy level is measured.
This example uses the mid-point, as Altalink
suggested.
70. Please refer to AESO Reply #12 above.
The AESO confirms that calendar year is correct
The period used to calculate the “mean time to
repair” is undefined. AltaLink suggests that it be a
calendar year.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 26 of 35
71. H. AltaLink notes that ‘availability’ is never defined
to include or exclude planned outages nor is the
period used in the calculation stated. AltaLink
suggests that availability be calculated from
unplanned outages for each calendar year.
72. I. The service description for transmission lines
below 200kV reads “…less than or equal to 60kV
and less than 200kV.” To distinguish medium
voltage transmission lines it should read “…more
than or equal to 100kV and less than 200kV.” As
written, this requirement includes elements of the
electric distribution system.
73. AltaLink requests the AESO confirm that the
requirement for BUS measurements in this
appendix apply only to transmission facilities.
ATCO Electric
71. The AESO agrees that the availability for
unplanned outages is based on a.calendar year;
which is consistent with WECC. The AESO has
not amended final proposed New ISO Rules
Section 502.8 as a result of this comment.
72. The AESO has amended Appendix 4 in final
proposed New ISO Rules Section 502.8 to
indicate more than or equal to 60kV and less
than 200kV.
73. The AESO confirms that all of the requirements
in Appendix 4 apply only to transmission
facilities.
74. Please refer to AESO Reply #3 above.
74. Item 13 – Our objection to underfrequency and
undervoltage load shedding was noted above in
response to 1(a).
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.
Appendix 5 - Supervisor Control and
Data Acquisition Requirements for
Facilities Providing Ancillary Services
AltaLink Management Ltd
75. AltaLink requests clarification of the resources
described as “… providing black start services”.
Does this include only the generating units with
black start capability or does it also include the
transmission facilities identified in black start
paths?
75. Appendix 5 applies only to the resources providing
ancillary services. Blackstart restoration activities
for transmission facility owners are identified in the
AESO’s System Restoration Plan and are not
included in Section 502.8 because they are in the
Blackstart restoration plan.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 27 of 35
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.
With respect to 15(b) above, in the
AESO’s opinion, a 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.
(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.
(d) Content Relocated into an Information Document
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”).
AltaLink Management Ltd
76.
AltaLink requests that the focus stated in the
Informational document also be stated in rule
502.8.
76. In 2009, the AESO worked with a group of
stakeholders to develop a standard template for
ISO rules. The outcome of that work was that
the template should only have sections for
“applicability”, “requirements” and any
“appendices” required. In essence stakeholders
felt that the content of ISO Rules should be
focused on the binding requirements and not
contain any informational content. The AESO
AESO Replies to Stakeholder Comments: 2012-12-11
Page 28 of 35
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.
ATCO Electric
77. Agreed, with the proposed addition of the following
items as noted in earlier responses:
1. Example for transducer scaling
2. Example for ‘full scale’
Availability design targets
(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.
ATCO Electric
has been using this template for all documents
transitioned to date and will continue to use this
template such that there is consistency across
the ISO rules. Therefore, the AESO has not
amended final proposed ISO Rules Section
502.8 as a result of this comment.
77. The AESO has included examples to illustrate
the concepts of transducer scaling and full scale
in supporting ID #2012-013R. As mentioned
above in AESO Reply #56 above, the AESO has
not relocated the “availability” design targets to
supporting ID #2012-013R. Therefore, the AESO
has not amended final proposed New ISO Rules
Section 502.8 as a result of this comment.
78. No reply required.
79. No reply required.
78. Agreed.
79. Please refer to the responses provided earlier in
this document. (answer to question)
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
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
AESO Replies to Stakeholder Comments: 2012-12-11
Page 29 of 35
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
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
AESO Replies to Stakeholder Comments: 2012-12-11
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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)
AltaLink Management Ltd
80. Subsection 6 – Supervisory Control and Data
Acquisition Requirements
AltaLink requests that the term ‘bus’ as used in
provision 6(4)(a) and Appendix 4 be defined in the
glossary. Does a bus with a manually operated
switch allowing the bus to be split into two parts
which can be energized from separate
transformers count as one or two busses for the
purposes of this provision and appendix? What if
the switch is controllable?
81. Subsection 7 – Dual Meters
AltaLink has several sites with AESO accepted
configurations where the load is measured on the
low side only. Will the next project to add a feeder
be required to install high-side PTs, CTs and
metering to remain compliant with ISO rule 502.8?
In a site with a single transformer, would the
addition of a second transformer be required to
80. In the AESO’s opinion the term “bus” has been a
well understood term for several years and the
AESO does not believe there is a need to define
the term bus now. As a reference, for additional
information, a market participant can refer to
“Authoritative Dictionary of IEEE Standard Terms”
also.
Where one bus is split into two parts each part
should be modeled as a bus.
Therefore, the AESO has not amended final
proposed New ISO Rules Section 502.8 as a
result of this comment.
81. AESO’s intent is to review the requirements on a
case by case basis.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 31 of 35
install PTs, CTs, and metering for both
transformers?
82. Subsection 8 - Data Acquisition, provision (1)
AltaLink requests that provision 8(1) be re-worded
to:
82. The AESO agrees with AltaLink and has
amended final proposed New ISO Rules Section
502.8 to reflect the suggested changes.
“The ISO must initiate all supervisory control
and data acquisition communications with a
legal owner‘s equipment directly connected to
the ISO to acquire supervisory control and data
acquisition data from a legal owner and must
do so using the following means:”
The proposed wording effectively forbids the use of
unsolicited reporting internal to facility owners’
systems. The method of achieving a functional
specification which is internal to a facility should be
left to the discretion of the legal owner of each
facility.
83. Subsection 9 – Supervisor Control and Data
Acquisition Communications, provision (2).
AltaLink requests subsection 9(1) be revised to:
9(1) A legal owner of a generating unit, legal
owner of an aggregated generating facility,
legal owner of a transmission facility and
legal owner of a load must implement one (1)
of the following communication methods
between its facility and the ISO:
(a) an internet connection , if the legal owner
has a latency time requirement of thirty (30)
seconds or greater;
83. In the AESO’s opinion the suggested changes
are not required. The clarifications being
requested are included in ISO Rules 502.4
Automated Dispatch and Messaging System and
Voice Communication System Requirements.
Therefore, the AESO has not amended final
proposed New ISO Rules Section 502.8 as a
result of this comment.
(b) a dedicated telecommunications link, if the
legal owner has a latency time less than thirty
(30) seconds;
(c) use the ISO provided connection point if the
legal owner uses an ICCP connection to pass
information to the ISO.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 32 of 35
This change reflects the practice of the AESO
providing the connection point for all ICCP
connections.
84. Subsection 9 – Supervisor Control and Data
Acquisition Communications, provision (4).
AltaLink requests the AESO clarify if TFOs should
be added to this provision:
(4) A legal owner of a generating unit, legal
owner of an aggregated generating facility and
legal owner of a load must, if it owns a facility with
the capability of combined load and generation
greater than one thousand (1000) MW, provide two
(2) communication circuits to each of the ISO’s
primary system coordination centre and the ISO’s
backup system coordination centre.
85. Subsection 9 – Supervisor Control and Data
Acquisition Communications, provision (7).
AltaLink supports with language suggestions:
84. No this provision should not be directed at owners
of transmission facilities. They are obligated to
provide communications circuits between
themselves and the AESO in ISO Rules Section
502.4 Automated Dispatch and Messaging
System and Voice Communication System
Requirements.
85. AESO agrees with AltaLink suggested wording
and has amended final proposed New ISO Rules
Section 502.8 to reflect the suggested changes.
(7) A legal owner of a generating unit, legal
owner of an aggregated generating facility, legal
owner of a transmission facility and legal owner
of a load must, if it changes the communication
protocols used between itself and the AESO,
communicate these changes to the ISO in writing
ninety (90) business days prior to changing the
protocols.
The italicized words have been added to reduce
the number of notices that would need to be sent to
the ISO for changes which are strictly internal to
facility owner equipment. The method of achieving
and sustaining the Functional Specification for a
specific facility should be left to the discretion of the
facility owner.
ENMAX Power Corporation
86. Section 9(4) – The Rule could be improved by
86. The AESO agrees with Enmax’s suggestion and
has amended final proposed New ISO Rules
Section 502.8 as a result of this comment.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 33 of 35
making a statement around facilities greater than
1000 MW that have both primary and backup
Control Centres. Presumably, both facilities should
provide two communications circuits to each of the
ISO’s primary and backup coordination centre.
TransAlta
87. In general TransAlta makes the following requests:
1] That the AESO, after approval of the rule by the
AUC and prior to the effective date of the rule,
provide a training or information session open to
market participants to communicate the
requirements of the rule. For a technical rule this
should include appropriate AESO technical
personnel. We consider it insufficient to provide a
new or revised rule without providing an
information or training session to market
participants so they are conversant with the
requirements and can take any needed steps in
order to be compliant by the effective date.
88. 2] That the effective date of a rule after approval of
the rule by the AUC should be no less than 90
business days from the date of approval so as to
provide market participants with adequate time to
communicate the requirements within their
organizations and to implement any processes
including documentation and training needed to
ensure compliance. We note that for Alberta
Reliability Standards longer periods are provided
for these and similar reasons.
TransCanada
89. Section 8(8) It appears that the requirement is that
the minimum values must be between 120% and
200% of the lowest operating condition for a
87. The AESO reiterates that proposed New ISO
Rules Section 502.8 applies on a go forward
basis subject to the need for existing facilities to
undergo modifications for reliability reasons; refer
to AESO Reply #30 above. New facilities or
modifications to existing facilities will be subject
to the AESO’s Connection process or the System
Projects process. In the AESO’s opinion there is
sufficient time in these processes to allow for any
training that may be required. In addition, the
majority of the supervisory control and data
acquisition requirements in proposed New ISO
Rules Section 502.8 have been in place for
several years and as such market participants
should be very familiar with the concept of
providing supervisory control and data acquisition
data to the AESO. Therefore, In the AESO’s
view, a separate information or training session
should not be required. If TransAlta would like its
own information or training session it can make
the request directly to the AESO.
88. Proposed New ISO Rules Section 502.8 is on a
go forward basis and as such the ninety day lead is
not required, in the AESO’s view.
89. Subsection 8.8 addresses scaling of the specified
equipment. The 120% to 200% is the full scale
value of that equipment based on its nominal
voltage.
AESO Replies to Stakeholder Comments: 2012-12-11
Page 34 of 35
synchronous condenser or motor. Could the AESO
please confirm that 120% to 200% is the minimum
range only and please confirm what the maximum
range is?
In addition, for additional guidance the AESO has
added an example in ID #2012-013R.
AESO Replies to Stakeholder Comments: 2012-12-11
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