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]:
2014/02/07
2013/12/12
through
2014/02/07
Comments From:
EPCOR Distribution & Transmission Inc. (EDTI)
Date [yyyy/mm/dd]:
2014/02/07
Contact:
Travis Robinson
Phone:
780-412-3079
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.
2. Do market participants have any concerns that CIP-PLAN-AB-1 is not capable
of being applied in Alberta? If appropriate, please indicate the specific section
of CIP-PLAN-AB-1 and describe the concern.
Market Participant Comments and/or Alternative
Proposal
Comment # 1: EDTI requests some clarity regarding
the effective date of the CIP standards, particularly for
those requirements that require data retention. As an
example, CIP-006-AB-5, R1.8 requires entities to log
the entry of all individuals into each physical security
perimeter, and R1.9 requires the retention of those log
records for at least ninety days. In order to comply
with R1.9 by the effective date, entities will be required
to comply with R1.8 90 days prior to that effective date.
Can the AESO confirm that this assumption is correct?
AESO Replies
AESO Reply # 1: AESO to provide
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 CIP-PLAN-AB-1, describe the concern and suggest
alternative language.
Issued for Market Participant Consultation: 2013-12-12
Page 1 of 2
b) Other
[Note to Market Participants: please copy and paste the section of CIP-PLAN-AB-1
being commented on here]
Issued for Market Participant Consultation: 2013-12-12
Comment # 1: Insert Comments / Reason for Position
(if any)
AESO Reply # 1: AESO to provide
Page 2 of 2