Stakeholder Comparison Comment Rationale Matrix 2012-03-06 AESO AUTHORITATIVE DOCUMENT PROCESS
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Stakeholder Comparison Comment Rationale Matrix 2012-03-06 AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Comparison Comment Rationale Matrix 2012-03-06 AESO AUTHORITATIVE DOCUMENT PROCESS Alberta Reliability Standard – COM-002-AB-2 Communications and Coordination Draft 2.1 Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: Comments From: TransAlta Date [yyyy/mm/dd]: 2012/03/30 2012-03-06 2012-03-06 Issued for Stakeholder Consultation: 2012-03-06 through 2012-03-30 Contact: Cristina Papuc Phone: 403-267-2077 E-mail: [email protected] 1 NERC COM-002-2 1 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 Purpose To ensure Balancing Authorities, Transmission Operators, and Generator Operators have adequate communications and that these communications capabilities are staffed and available for addressing a real-time emergency condition. To ensure communications by operating personnel are effective. Purpose The purpose of this reliability standard is to ensure the ISO, the operator of a transmission facility, the legal owner of an aggregated generating facility and the operator of a generating unit have adequate and effective communications and response capabilities available for addressing a real-time system emergency condition. Purpose To ensure the ISO, and entities subject to this reliability standard have adequate communications and that these communications capabilities are staffed and available for addressing a real-time emergency condition. To ensure communications by operating personnel are effective. Applicability 4.1. Reliability Coordinators. 4.2. Balancing Authorities. 4.3. Transmission Operators. 4.4. Generator Operators. Applicability This reliability standard applies to: the operator of a transmission facility; the legal owner of an aggregated generating facility; the operator of a generating unit; and the ISO . Applicability This reliability standard applies to: (a) the legal owner of a generating unit that is: (i) directly connected to the transmission system or to transmission facilities within the City of Medicine Hat; and AESO Replies Modified the purpose to align with the Alberta reliability framework. The term used to describe applicable entities in proposed COM-002-AB-2 Draft 2.1 has been amended from the NERC version in order to correctly identify the applicable entities in Alberta and to align with terms included in the AESO Consolidated Authoritative Documents Glossary. TransAlta has the following comments in regards to the applicability section. 1. TransAlta requests removal of legal owner of generating unit and aggregated generating facilities, i.e. (a) and (c) in the applicability section. The reasons are, a. TransAlta still believes that this This column is informational only. Issued for Stakeholder Consultation: 2012-03-06 2 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 standard applies to (ii) not part of an the operator, not the aggregated legal owner. The generating facility; AESO reply states (b) the operator of a that “the legal owner generating unit that is: rather than the (i) directly connected to operator is the transmission responsible for the system or to addition, transmission replacement, facilities within the maintenance, etc. of City of Medicine Hat; physical assets”. and However, to address (ii) not part of an a real-time aggregated emergency condition generating facility; is performed by the (c) the legal owner of an operators, not by the aggregated generating owners. The owner facility that is directly has no involvement connected to the in the real-time transmission system operation activities. or to transmission TransAlta recognizes facilities within the City that the “physical of Medicine Hat; assets” must be in (d) the operator of an place so the aggregated generating operators can have facility that is directly the communication connected to the capabilities. But, how transmission system to establish these or to transmission capabilities is an Issued for Stakeholder Consultation: 2012-03-06 AESO Replies 3 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 agreement between facilities within the City the owner and of Medicine Hat; operator. This is (e) the operator of a outside the scope of transmission facility; this standard. As (f) the operator of an long as the physical electric distribution assets for system; and communication are (g) the ISO. in place, the operators can address the real-time emergency. If there is any concern about the physical assets for the communication, the operator can discuss the issue with the owner, or even terminate the agreement and stop operating the generating unit or aggregated generating facilities based on the commercial agreement. In this case, the owner would have to take Issued for Stakeholder Consultation: 2012-03-06 AESO Replies 4 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 the generating unit or aggregate generating facilities offline because of its own concerns about the assets. Thus, TransAlta does not think there is any reliability gap if the legal owner was removed from the applicability section as long as the adequate communication is established between the operators. How to establish this is not in the scope of this standard. AESO Replies b. The AESO reply sates that “the AESO replied that it was of the opinion that the legal owner rather than the operator is responsible for the addition, replacement, Issued for Stakeholder Consultation: 2012-03-06 5 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 maintenance, etc. of the physical assets.” “of the opinion” is the AESO‘s opinion. With all due respect to the AESO’s opinion, it was not validated or affirmed by the industry. AESO Replies c. Since the last consultation in 2010, in a couple of the AESO working group meetings, AESO said that for going forward, one of the guidelines to develop Alberta reliability standards is that the Alberta reliability standard shall not be more stringent than the NERC standards. The NERC standard only applies to the operators while Alberta reliability standard applies to both the owners and Issued for Stakeholder Consultation: 2012-03-06 6 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 operators. By expanding the applicability to more functional entities, Alberta reliability standard is more stringent than the NERC standard. So adding the legal owners in the applicability section is not consistent with the approach that the AESO communicated to the working group before. AESO Replies 2. TransAlta would like clarification as to what capacity of generating units and aggregated generating facilities this standard should apply to, as the applicability section does not clearly specify an MW threshold and the definition of generating unit in the Act has no capacity thresholds. Without stating a minimum Issued for Stakeholder Consultation: 2012-03-06 7 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 capacity of generating units and aggregated generating facilities in the applicability section TransAlta is concerned that we would need to interpret it as having to apply to all generators, even those below 5 MVA, which we do not believe is the AESO’s intent. For the purposes of this standard TransAlta believes a threshold of 18 MW for a single generating unit and 67.5MW for an aggregated generating facilities (or whatever it should be) would be appropriate. AESO Replies 3. TransAlta requests that the AESO clarify whether or not switchyards are included in the definition of transmission facility for this standard. TransAlta believes that for this standard the switchyards should be excluded. TransAlta requests the AESO also provide an information Issued for Stakeholder Consultation: 2012-03-06 8 NERC COM-002-2 Effective Date January 1, 2007 R1. Each Transmission Operator, Balancing Authority, and Generator Operator shall have communications (voice and data links) with appropriate Reliability Coordinators, Balancing Authorities, and Transmission Operators. Such communications shall be staffed and available for addressing a real-time emergency condition. COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 document providing definitions and explanations of how the AESO will be handling the inclusion or exclusion of switchyards in the applicability section of all of the Alberta reliability standard standards. TransAlta will agree to the April 1, To allow a reasonable Effective Date Effective Date 2013 effective date under the April 1, 2013 amount of time for Alberta One hundred and eighty (180) condition that the standard is filed to entities to implement days after the date the AUC by Q2 2012, i.e. submission to proposed COM-002-AB-2 Commission approves it. AUC at minimal three quarters Draft 2.1 before the effective date. R1 Each legal owner of an aggregated generating facility must have voice and data communication between its operator and any operator of a transmission facility to which it is connected and with the ISO. R1 Each legal owner of a generating unit and each legal owner of an aggregated generating facility must have voice and data communications with any operator of a transmission facility that is part of the bulk electric system to which it is directly connected and with the ISO. R2 The ISO, each operator of a R2 The ISO, each operator Issued for Stakeholder Consultation: 2012-03-06 New Amended Deleted Drafted Alberta requirement R1 in accordance with the reliability standards drafting principles to add clarity to the requirement. NERC requirement R1 has been amended by removing AESO Replies For R1, besides the comments mentioned in the applicability section, TransAlta also has the following comments specific to this requirement. 1. The present industry practice for the real-time operation communication is among the operators. R1 says “legal owner…must have voice and data communication with any operator…” Does this mean 9 NERC COM-002-2 R1.1. Each Balancing Authority and Transmission Operator shall notify its Reliability Coordinator, and all other potentially affected Balancing Authorities and Transmission Operators through predetermined communication paths of any condition that could threaten the reliability of its area or when firm load shedding is anticipated COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 that the legal owner must the requirement of the legal of a transmission facility, transmission facility and each communicate verbally and owner of a transmission each operator of an operator of a generating unit exchange data with the facility and the AESO to must have personnel available aggregated generating operator of transmission for all hours of the day, seven facility, and each operator have communications as the facilities and the ISO? If yes, requirement is contained in of a generating unit must (7) days a week, to receive and what kind of information will have personnel available for proposed reliability standard address any voice or data be communicated among COM-001-AB-1.1 Draft 2.1. communication regarding a real- all hours of the day, seven the legal owner of a (7) days a week, to receive time system emergency generating unit, the operator and address any voice or condition. of transmission facilities and data communications the ISO, specifically for the regarding a real-time real-time operation? system emergency condition. 2. As written, the R1 would be interpreted to require the R3 The ISO must notify the R3 The ISO must notify the legal owner of a generating WECC Reliability WECC Reliability Coordinator, unit to install extra Coordinator, adjacent adjacent interconnected equipment even though the transmission operators and interconnected operator of the same affected adjacent balancing transmission operators generating unit has already and affected adjacent authorities through had the equipment for the predetermined communication balancing authorities communication with the through predetermined paths of any threat to the operator of transmission communications paths: reliability of the interconnected facility and with the ISO. (i) of any threat to the electric system or if the ISO TransAlta does not believe reliability of the anticipates shedding firm load. this is the intent of this interconnected electric standard. system; or 3. Thus, TransAlta requests (ii) if the ISO anticipates the legal owner be replaced shedding firm load. with the operator. Issued for Stakeholder Consultation: 2012-03-06 AESO Replies 10 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 AESO Replies For the numbering in the standard, TransAlta request the numbering is the same as those in the NERC standards (having R1, R1.1 and R2). The reasons are: 1. TransAlta manages the reliability standards compliance across the fleet in the US and Canada. All other Canadian provinces adopt the NERC reliability standards without any changes. If the numbering in the Alberta reliability standard is different from the NERC version, TransAlta will have a specific internal compliance program for Alberta. This will incur the cost just because of numbering difference. TransAlta believes this cost is not necessary and does have the reliability benefits. 2. TransAlta believes that it is also possible for the Alberta reliability standard to have the same numbering as the Issued for Stakeholder Consultation: 2012-03-06 11 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 NERC version, i.e. only having R1, R1.1 and R2 requirement in Alberta version. For example, AESO Replies a. The R2 requirement can be added to the end of R1 requirement as a second sentence. b. The R3 requirement can be renumbered as R1.1 c. The R4 requirement can be renumbered as R2. d. The R5 requirement shall be removed as explained in the comment section for R5. Issued for Stakeholder Consultation: 2012-03-06 12 NERC COM-002-2 R2. Each Reliability Coordinator, Transmission Operator, and Balancing Authority shall issue directives in a clear, concise, and definitive manner; shall ensure the recipient of the directive repeats the information back correctly; and shall acknowledge the response as correct or repeat the original statement to resolve any misunderstandings. COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 R4 The ISO must give a verbal directive to an operator of a transmission facility, legal owner of an aggregated generating facility and operator of a generating unit in a clear, concise and definitive manner. If the recipient of the verbal directive does not respond by repeating the information in the directive as specified in requirement R5, then the ISO must request the recipient to repeat the information in the directive. If the information is repeated correctly, the ISO must verbally acknowledge this to the recipient. If the information in the response is not correct, the ISO must repeat the verbal directive and the above process until the ISO is satisfied that the recipient understands the information in the directive. R4 The ISO must, when issuing a verbal directive to an operator of a transmission facility, operator of an aggregated generating facility, operator of a generating unit or an operator of an electric distribution system, do so in a clear, concise and definitive manner, identify the instruction as a directive and: New Amended Deleted AESO Replies TransAlta requests that the R4 requirement be renumbered as R2 as explained above. Drafted Alberta requirement R4 in accordance with the reliability standard drafting principles to add clarity to the requirement. (i) if the recipient of the directive does not respond by repeating the information in the directive as specified in requirement R5, then the ISO must request the recipient to repeat the information in the directive; (ii) if the information is repeated correctly, the ISO must acknowledge this to the recipient; and (iii) if the information in the response is not correct, the Issued for Stakeholder Consultation: 2012-03-06 13 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 ISO must repeat the directive and the above process until the ISO is satisfied that the recipient understands the information in the directive. R5 Each person who receives a verbal directive from the ISO must repeat the information in the verbal directive back to the ISO correctly, either in response to the initial verbal directive or in response to the ISO’s repetition of the verbal directive. 2 R5 Each operator of a transmission facility, each operator of an aggregated generating facility, each operator of a generating unit and each operator of an electric distribution system who receives a directive from the ISO in accordance with requirement R4 must repeat the information in the directive back to the ISO, either in response to the initial directive or in response to the ISO’s repetition of the directive. New Amended Deleted Alberta Variance2: The AESO recognizes that the responsibility to repeat the information in an AESO directive back to the AESO rests with the recipient of the directive. A new Alberta requirement, R5, has been added to COM-002-AB-2 Draft 2.1 to address this responsibility. AESO Replies TransAlta requests the R5 requirement be removed. The reason is: Since the last consultation in 2010, in a couple of AESO working group meetings, AESO said for going forward, one of the guidelines to develop Alberta reliability standards is that the Alberta reliability standards shall not be more stringent than the NERC standards. In the NERC standard R2 requires the issuer of directives to ensure the recipient repeats back. The recipient does not have any compliance obligation to repeat the directives back. In the Alberta reliability standard as written in the An Alberta variance is a change from the US Reliability Standard that the AESO Issued for Stakeholder Consultation: 2012-03-06 14 NERC COM-002-2 M1. Each Transmission Operator, Balancing Authority and Generator Operator shall have communication facilities (voice and data links) with appropriate Reliability Coordinators, Balancing Authorities, and Transmission Operators and shall have and provide as evidence, a list of communication facilities or other equivalent evidence that confirms that the communications have been provided to address a realtime emergency condition. (Requirement 1, part 1) COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 R5 requirement, the recipient will have the obligation of repeating back. Thus by adding this requirement, the Alberta reliability standard is more stringent than the NERC standard, which is not consistent with the approach that the AESO communicated to the working group before. MR1 Evidence exists of voice and data communication as specified in requirement R1, such as a list of voice and data communication devices. MR2. Where a real-time system emergency condition has occurred, evidence exists that demonstrate any voice or data communications were addressed, such as voice recordings and operator logs. Issued for Stakeholder Consultation: 2012-03-06 AESO Replies MR1 Evidence of having voice and data communications as required in requirement R1 exists. Evidence may include a list of communication devices and documentation including an overview, purpose, diagrams and network connectively for each data and voice communication system. MR2 Evidence of having personnel available as required in requirement R2 exists. Evidence may include operator logs, timesheets, on-call lists, or shift schedules. 15 NERC COM-002-2 M2. The Balancing Authority and Transmission Operator shall have and provide upon request evidence that could include but is not limited to, operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it notified its Reliability Coordinator, and all other potentially affected Balancing Authorities and Transmission Operators of a condition that could threaten the reliability of its area or when firm load shedding was anticipated. (Requirement 1.1) COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 MR3 Evidence exists to confirm notification as specified in requirement R3, such as voice recordings, operator logs and email records. MR3 Evidence of notifying as required in requirement R3 exists. Evidence may include operator logs or voice recordings. MR4 Evidence exists to verify the requirement as specified in requirement R4 such as, voice recordings, operator logs and email records. MR4 Evidence of giving directives as required in requirement R4 exists. Evidence may include voice recordings or, where voice recordings are not available, operator logs that indicate the recipient repeated the information back correctly. AESO Replies MR5 Evidence of repeating information in the directive Issued for Stakeholder Consultation: 2012-03-06 16 NERC COM-002-2 COMPARISON BETWEEN NERC COM-002-2 AND CURRENT ALBERTA COM-002-AB-2 COMMUNICATIONS AND COORDINATION Reason for Differences COM-002-AB-2 Draft 2.1 between COM-002-AB-2 Stakeholder Comments COM-002-AB-2 Draft 2 (From (Revised version for reDraft 2.1 and NERC (Insert comments here) previous consolation)1 consultation) COM-002-2 as required in requirement R5 exists. Evidence may include voice recordings or, where voice recordings are not available, operator logs that indicate the recipient repeated the information back. AESO Replies The Alberta reliability standards do not contain a compliance section. Compliance with all Alberta reliability standards is completed in accordance with the Alberta Reliability Standards Compliance Monitoring Program, available on the AESO website at: http://www.aeso.ca/loadsettl ement/17189.html Compliance To view the compliance section D of the NERC reliability standard follow this link: http://www.nerc.com/files/CO M-002-2.pdf Regional Differences Regional Differences Regional Differences None identified. None identified. None identified. Issued for Stakeholder Consultation: 2012-03-06 17 New Definitions Stakeholder Comments (Insert comments here) AESO Replies None Issued for Stakeholder Consultation: 2012-03-06 18