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Document 2244096
July 15, 2015 To: Market Participants and Other Interested Parties Re: Consultation Letter on Proposed New Alberta Reliability Standard PER-005-AB-2, System Personnel Training ("New PER-005-AB-2"). Section 19 of the Transmission Regulation requires the Alberta Electric System Operator ("AESO") to consult with market participants likely to be directly affected by the AESO's adoption or making of Alberta reliability standards, and also requires the AESO to forward the proposed Alberta reliability standards to the Alberta Utilities Commission ("AUC") for review along with the AESO's recommendation that the AUC approve or reject them. Accordingly, the AESO is providing notice and seeking comments from market participants on the attached proposed New PER-005-AB-2. Applicability The proposed New PER-005-AB-2 is applicable to the AESO and to the operators of transmission facilities. Background Effective January 1, 2014, under its mandate set out in Section 17(h) of the Electric Utilities Act, the AESO assumed the additional responsibilities that relate to the functions of a Reliability Coordinator (“RC”). The proposed New PER-005-AB-2 is one of the reliability standards that are applicable to the RC function. In taking on the RC function, the AESO’s operating personnel must be capable of performing certain reliability-related tasks. The purpose of the proposed New PER-005-AB-2 is to ensure that personnel performing or supporting real-time operations on the bulk electric system are trained using a systematic approach. Summary of the Proposed Alberta Variances In developing the proposed New PER-005-AB-2, the AESO determined that certain Alberta variances are required to ensure the North American Electric Reliability Corporation ("NERC") PER-005-2 is capable of being applied in Alberta and does not require a material change in the framework for the market for electric energy. A summary of these Alberta variances is as follows: The NERC PER-005-2 “Applicability” section has been modified as, under Alberta market rules, centrally located dispatch centres relay dispatch instructions without making any modifications to those instructions. Also, the role assigned to a transmission facility owner in NERC PER-005-2 is covered by the operator of a transmission facility in Alberta; Requirement R1 of NERC PER-005-2 has been modified to clarify that it is the AESO’s and each operators’ responsibility to define and develop a documented methodology for determining a company specific real-time reliability-related task; Requirement R2 of NERC PER-005-2 has been removed as in Alberta this requirement applies only to the AESO and the operator of a transmission facility. Therefore, Requirement R2 is covered in Requirement R1 of the proposed New PER-005-AB-2 (in accordance with the amendments to the Applicability section); Requirement R4 of NERC PER-005-2 has been modified as this requirement only applies to the AESO in Alberta; and Page 1 Public Information Requirement R6 of NERC PER-005-2 is not required under Alberta market rules (in accordance with the amendments to the Applicability section); therefore this requirement has not been included in proposed New PER-005-AB-2; In addition to these Alberta variances, the AESO made amendments to ensure consistent use of defined terms as included in the AESO's Consolidated Authoritative Document Glossary (“CADG”). Administrative changes, such as formatting and some grammatical corrections, have also been made in the proposed New PER-005-AB-2. Defined Terms When reviewing the attached draft Alberta reliability standard, market participants should note that all defined terms are emphasized in “bold”. Market participants and other interested parties are encouraged to refer to the AESO's CADG when reviewing the draft Alberta reliability standard to ensure they have an accurate understanding of those defined terms. The proposed new operations support personnel definition was developed in conjunction with the drafting of the proposed New PER-005-AB-2, and is proposed for inclusion in the AESO’s CADG. Implementation of Alberta Reliability Standards All Alberta reliability standards proposed for approval or rejection by the AESO are based on the reliability standards and definitions developed, or approved, and enforced by NERC. NERC was certified as the Electric Reliability Organization ("ERO") for the United States by the Federal Energy Regulatory Commission ("FERC") under the United States Energy Policy Act of 2005. NERC has been granted recognition as the ERO by the Minister of Energy in Alberta. In accordance with Section 19 of the Transmission Regulation, the reliability standards that apply in Alberta are those of the ERO or any other reliability standards to the extent that such reliability standards are adopted by the AESO after consultation with market participants and after receipt of AUC approval. For more information on the AESO's reliability standards visit our website at www.aeso.ca and follow the path Rules & Standards > Alberta Reliability Standards. Request for Comments from Market Participants Please use the attached Market Participant Comment Matrix when submitting comments to the AESO on the proposed New PER-005-AB-2. Only written comments will be considered in finalizing proposed New PER-005-AB-2. Please ensure that comments provided with respect to the proposed New PER-005-AB-2 represent all interests within each market participant’s organization. Please provide market participant comments or questions no later than August 10, 2015, to [email protected]. Adherence to deadlines is essential to the integrity of the AESO's consultation on the proposed New PER-005-AB-2. As such, any market participant comments received after August 10, 2015, may not be published, replied to, or otherwise considered by the AESO. The AESO will be publishing all market participant comments received for industry review in August, 2015. The AESO expects to publish the AESO’s replies to the comments on the final proposed New PER-005-AB-2 in October, 2015. If the AESO does not receive comments from market participants regarding the proposed New PER-005-AB-2, the AESO expects to forward the final proposed New PER-005-AB-2 to the AUC in October or November, 2015, along with its recommendation that the AUC approve the final proposed New PER-005-AB-2, to become effective the first day of the month that follows eight (8) full calendar quarters after approval by the AUC. Page 2 Attachments The following documents are attached: 1. Market Participant Comment Matrix for proposed New PER-005-AB-2; and 2. Clean copy of proposed New PER-005-AB-2. Sincerely, "Original Signed By" Gillian Barnett Regulatory Legal Counsel Phone: 403-539-2920 Email: [email protected] Attachments Page 3