Market Participant Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS

Market Participant Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Market Participant Consultation Draft
2013-12-12
Consultation on Proposed New Critical Infrastructure Protection (“CIP”) Alberta Reliability Standard:
CIP-PLAN-AB-1 Implementation Plan for Version 5 CIP Security Standards (“CIP-PLAN-AB-1”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
Comments From:
ATCO Electric
Date [yyyy/mm/dd]:
2014/02/05
2014/02/07
2013/12/12
through
2014/02/07
Contact:
Glen Sutton
Phone:
780-420-7675
E-mail:
[email protected]
Listed below is the summary description for the proposed new sections of the Alberta reliability standards. Please refer back to the Consultation Letter under the “Attachments” section to view the
actual proposed content to the Alberta reliability standards. Please place your comments/reasons for position underneath (if any).
1. CIP-PLAN-AB-1
a) New
The AESO is seeking comments from market participants with
regard to the following matters:
1. Are there any requirements contained in CIP-PLAN-AB-1
that are not clearly articulated? If yes, please indicate the
specific section of CIP-PLAN-AB-1, describe the concern
and suggest alternative language.
Market Participant Comments and/or Alternative Proposal
ATCO - Comment # 1:
AESO Replies
AESO Reply # 1: AESO to provide
Initial Performance of Certain Periodic Requirements:
ATCO Electric does not support the removal of the Initial Performance of
Certain Periodic Requirements in Section 4 of the Implementation Plan for
Version 5; ATCO Electric has the following requirements:
1. Keep the original Initial Performance of Certain Periodic Requirements
as is.
2. Do market participants have any concerns that CIP-PLANAB-1 is not capable of being applied in Alberta? If
appropriate, please indicate the specific section of CIPPLAN-AB-1 and describe the concern.
3. Do market participants disagree with any CIP-PLAN-AB-1
Alberta variances that are contained in CIP-PLAN-AB-1? If
appropriate, please indicate the specific section of CIPPLAN-AB-1, describe the concern and suggest alternative
language.
Issued for Market Participant Consultation: 2013-12-12
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b) Other
[Note to Market Participants: please copy and paste the section
of CIP-PLAN-AB-1 being commented on here]
ATCO - Comment # 1:
AESO Reply # 1: AESO to provide
Technical Feasibility Exception (TFE) Process:
AESO must draft and provide the TFE process in conjunction with AUC
approval. Entities must be consulted during the development of the TFE
process. This will ensure entities have adequate time strategize, implement
and document compensating measures for TFEs.
ATCO - Comment # 2:
Requirement Standard Audit Worksheet (RSAW):
AESO must draft and provide the RSAWs in conjunction with AUC
approval. This will ensure entities have clarity of audit expectations and
provide adequate time for entities to align their CIP Programs.
ATCO - Comment # 3:
Removal of Background, Technical Basis and Guidelines sections:
ATCO Electric wants written confirmation from AESO that these valuable
resources are valid reference material for Alberta entities.
Issued for Market Participant Consultation: 2013-12-12
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