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:
TransAlta
Date [yyyy/mm/dd]:
2014/02/07
2014/02/07
2013/12/12
through
2014/02/07
Contact:
Jian Zhang
Phone:
403-267-7319
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.
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
Market Participant Comments and/or Alternative
Proposal
Comment # 1:
AESO Replies
AESO Reply # 1: AESO to provide
The Alberta version removes the section about “Initial
Performance of Certain Periordic Requirements” from
the NERC version. We believe this is an important part
of implementation. Without this section, it is not clear
when the initial task as required by the standards
should be completed.
For example in the NERC version, it says “Within 14
calendar days after the Effective Date of the Version 5
CIP Cyber Security Standards for the following
requirements:
• CIP-007-5, Requirement R4, Part 4.4”.
The CIP-007-5 Requirement R4, Part 4.4 requires the
entity review the logged events at interval no greater
than 15 calendar days. Since the standard requires
logging the events only on and after the effective date
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as per CIP-007-5 Requirement R4 part 4.1, the initial
review as per Part 4.4 can only be performed after
these events are logged.That’s why the NERC version
says “within 14 days after the Effective Date”.
Thus, it is recommended

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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]
Issued for Market Participant Consultation: 2013-12-12
retaining the section about “Initial Performance
of Certain Periodic Requirements”
adding the relevant languages in the purpose
section of the CIP-Plan-AB-1 standard.
retaining “with additional time to comply for
requirements in the same manner as those
timelines specified in the section Initial
Performance of Certain Periodic
Requirements above” in the last paragraph of
Page 4 and the first paragraph of Page 5 in
the blackline version of CIP-PLAN-AB-1.
Comment # 1: Insert Comments / Reason for Position
(if any)
AESO Reply # 1: AESO to provide
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