12
October 21, 2014 Public Page 1 of 12 Reliability Standards Standing Committee Date held: Oct 21 st , 2014 Time held: 9:30 AM – 3:00 PM Location held: IESO’s Boardroom, 4 th Floor 655 Bay Street, Toronto Invited/Attended Company Name Attendance Status Andrew Burmaster Brookfield Renewable Power Present John Fish TransCanada Present (on the phone) Ayesha Sabouba Hydro One Present David Kiguel Observer Present Esia Giaouris Hydro One Present Wayne Zhang N-Dimension Solutions Inc. Present Laurie Reid Ontario Energy Board Present David Peterson OPG Present David Ramkalawan OPG Present John Falsey Invenergy Present (on the phone) Soon Chua Portlands Energy Centre Present Gordon Bartels TransCanada Present (on the phone) Jian Zhang TransAlta Energy Corporation Present (on the phone) James E. Cook GLP Present (on the phone) Janis Gartshore TransCanada Present (on the phone) Adnan Jabbar (Scribe) IESO Present Ben Li IESO Present David Robitaille IESO Present Khaqan Khan IESO Present Scott Berry IESO Present Helen Lainis IESO Present Dalia Hussein IESO Present Norm Dang IESO Present Jason Grbavac IESO Present Griselda Matos IESO Present Abigail Miner IESO Present David Berry IESO Present Cristian Dragnea MACD Present (on the phone) Scribe: Adnan Jabbar, [email protected]: Please report any corrections, additions or deletions to scribe. Reliability Standards Standing Committee (RSSC) Minutes of Meeting #28

Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

  • Upload
    others

  • View
    3

  • Download
    0

Embed Size (px)

Citation preview

Page 1: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 1 of 12

Reliability Standards Standing Committee

Date held: Oct 21st, 2014 Time held: 9:30 AM – 3:00 PM Location held: IESO’s Boardroom, 4th Floor 655 Bay Street, Toronto

Invited/Attended Company Name Attendance Status

Andrew Burmaster Brookfield Renewable Power Present

John Fish TransCanada Present (on the phone)

Ayesha Sabouba Hydro One Present

David Kiguel Observer Present

Esia Giaouris Hydro One Present

Wayne Zhang N-Dimension Solutions Inc. Present

Laurie Reid Ontario Energy Board Present

David Peterson OPG Present

David Ramkalawan OPG Present

John Falsey Invenergy Present (on the phone)

Soon Chua Portlands Energy Centre Present

Gordon Bartels TransCanada Present (on the phone)

Jian Zhang TransAlta Energy Corporation Present (on the phone)

James E. Cook GLP Present (on the phone)

Janis Gartshore TransCanada Present (on the phone)

Adnan Jabbar (Scribe) IESO Present

Ben Li IESO Present

David Robitaille IESO Present

Khaqan Khan IESO Present

Scott Berry IESO Present

Helen Lainis IESO Present

Dalia Hussein IESO Present

Norm Dang IESO Present

Jason Grbavac IESO Present

Griselda Matos IESO Present

Abigail Miner IESO Present

David Berry IESO Present

Cristian Dragnea MACD Present (on the phone)

Scribe: Adnan Jabbar, [email protected]: Please report any corrections, additions or deletions to scribe.

Reliability Standards Standing Committee (RSSC)

Minutes of Meeting #28

Page 2: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 2 of 12

Reliability Standards Standing Committee

All meeting materials are available on the IESO’s RSSC webpage at: http://www.ieso.ca/Pages/Participate/Stakeholder-Engagement/Standing-Committee/Reliability-Standards-Standing-Committee.aspx

References: IESO MACD page: http://www.ieso.ca/Pages/Participate/Market-Oversight/Compliance-Enforcement.aspx

IESO Regulatory Affairs page: http://www.ieso.ca/Pages/About-the-IESO/Corporate-Accountability.aspx

NERC Standards page: http://www.nerc.com/page.php?cid=2

NPCC Regional Standards/Criteria page: https://www.npcc.org/Standards/default.aspx

FERC Electric page: http://www.ferc.gov/industries/electric.asp

Action Item Summary as of the 28th Meeting

# Date Action Status Comments

1 Jun 5, 2014 Provide L. Reid with a summary of the pre and post contingency issues (re: Revision to TOP/IRO standards).

Completed H. Lainis to provide

2 Oct 21, 2014 A. Jabbar to review the ORCP schedule and divide the self certs issue dates

New A. Jabbar to provide

Page 3: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 3 of 12

Reliability Standards Standing Committee

Record of Meeting: 1. Welcome and Introductions The twenty-eighth RSSC meeting commenced at 9:31 a.m. with brief introductions by each participant. 2. Administrative Issues

a) The agenda for the twenty-eighth meeting was reviewed and no new agenda items were added. b) The minutes of the twenty-seventh meeting was reviewed (page by page). No concerns were

raised. Motions to adopt the meeting minutes as final were made by D. Peterson and A. Burmaster

c) Updates on the open action item were provided as follows:

Action item 4: H. Lainis to Provide L. Reid with a summary of the pre and post contingency issues (re: Revision to TOP/IRO standards).

This item has been completed. There were no comments or questions from members.

d) RSSC Roster updates can be found on the RSSC contact list. A. Jabbar confirmed that some

updates were made to RSSC roster that are reflected in version 44 of the RSSC contact list which was circulated with this quarter’s meeting agenda. D. Peterson mentioned that he had noticed some misalignments with the contact names to their respective company. S. Berry informed that the roster will be updated and re-circulated to all committee members.

3. CIP Version 5 Forum Update

S. Berry delegated N. Dang to provide members with an update, as he had been intimately involved in the Forum and had agenda details for the next meeting. N. Dang informed the members that the focus of the first few meetings had been to discuss the actual CIP standards and how they could be interpreted; this phase is almost completed. The next phase involves working with Market Participants to discuss the applicability of some of these standards and what some of the typical implementations may look like. The team is also looking at creating an artifact from the meetings to identify a set of best practices for implementation vs. actual recommendations of how things can be applied. S. Berry informed RSSC members that the next meeting for CIP version 5 is scheduled for Oct 22 at Clarkson (IESO) at 09:00 AM in the viewing gallery, and the call-in number for the meeting will also be emailed out shortly by N. Dang. S. Berry also presented the agenda and advised members that the CIP forum is not an officially posted forum at the IESO but the information is available to those who wish to attend, thru a portal. It is an informal discussion group and a venue for members to come up with whiteboard ideas. B. Li was curious to know after looking at the agenda, if there was an RAI update, and why was it specifically dedicated to the CIP standard and not generically. S. Berry informed B. Li that there will be an RAI update provided by this group sometime near the end of this year or the beginning of next year, as they are trying to consolidate yet get to a point where that threshold of information is common. Information regarding how the RAI is interpreted in the CIP world will be provided by D. Robitaille and also together with MACD, there will be a report out shortly.

Page 4: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 4 of 12

Reliability Standards Standing Committee

Lastly S. Berry mentioned that members who have been identified as a BES asset owner under the new definition and have not yet received a letter from the IESO concerning the impact assessment of their assets in relation to CIP version 5; letters will be going out possibly by the end of October 2014 to all applicable participants. To that point, A. Burmaster inquired whether it was up to the entity or the IESO to perform an assessment. S. Berry informed A. Burmaster that under attachment 1 of CIP version 5, the IESO as a RC & PC has the obligation to perform an assessment for Criteria 2.3, 2.6 and 2.9, and afterwards it is a self-assessment by individual participants. 4. Standards Enforcement Dates Update D. Hussein presented updates on the NERC standards that have now been approved by FERC since the last RSSC meeting in June 2014 and their determined Ontario enforcement dates:

• VAR-001-4 (Voltage and Reactive Control) Jan. 1, 2015 • VAR-002-3 (Generator Operation for Maintaining Network Voltage Schedules). Jan. 1, 2015. • PER-005-2 Operations Personnel Training Oct. 1, 2016 • EOP-010-1 Geomagnetic Disturbance Operations April 1, 2015 • INT-004-3 Dynamic Transfers Jan. 1, 2015 • INT-006-4 Evaluation of Interchange Transactions Jan. 1, 2015 • INT-009-2 Implementation of Interchange Jan. 1, 2015 • INT-010-2 Interchange Initiation & Modification for Reliability Jan. 1, 2015 • INT-011-1 Intra Balancing Authority Transaction Identification Jan. 1, 2015

She informed members that the standards and enforcements dates will appear in the next version of the “milestones in reliability development and lifecycle” which is available on the IESO public page. It was also noted that for standard PRC-023-3, specifically R1, R2, R3, R5 and R6, the enforcement dates may vary from Oct 1, 2014, and members were encouraged to always refer to the implementation plan for enforcement updates. For PRC-025-1, which had been approved by FERC in September 2014, the Ontario Enforcement Date was set for October 1, 2014. Market Participants were again reminded to refer to the standards implementation plan and decide their implementation date. Lastly D. Hussein talked about the errata changes that included the capitalized version of “Protection System” in NUC-001-2.1 & PRC-001-1.1. These modifications to the definition of “Protection System” were approved by FERC in February 2013 and had the Ontario enforcement date of April 1, 2013. A. Sabouba inquired about why the information on enforcement dates is not kept current, and how soon is it expected to be updated. D. Hussein informed A. Sabouba that the current version on the IESO website is version 3.2, and version 4 is coming soon (by the end of November). However the standards that have been approved since version 3.2 is included in the presentation and will appear in the next version (version 4) In addition S. Berry also mentioned that the IESO had agreed to offer this service of providing enforcement date updates to Market Participants in conjunction with our base lining as best we could, and since the base lining happens once every quarter, the IESO, with the best of intensions, will endeavour to keep its commitment of updating this information quarterly. Since standard changes are so frequent throughout the year, it does not seem like an efficient practise to update the spreadsheet every time a standard changes.

Page 5: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 5 of 12

Reliability Standards Standing Committee

5. Ontario Reliability Compliance Program Updates A. Jabbar presented the updates to the 2014 Ontario Reliability Compliance Program as follows:

• 2014 ORCP schedule updates

- As part of our 2014 schedule, an under frequency load shedding data request went out to all Market Participants between late June to early July. Form 1718 was sent to all generators and Form 1719 was sent to all applicable Transmitters, Distributors and wholesale customers. All submissions were received by our set deadline (Aug 31/2014).

- Next scheduled self-certifications are Emergency Preparedness Planning (Form 1608) and Emergency Restoration Planning (Form 1609) which are applicable to those market participants identified by the IESO as Restoration Participants. Forms will be issued on Dec 01/2014.

- All other NERC related self-certification forms for 2014 will be completed by the first quarter of 2015. For more information please refer to the ORCP schedule.

• Changes to Self-certification schedule

- A proposal was made at the last RSSC meeting to divide the MP related self-certifications into three sets and have static due dates to align ourselves with NPCCs common self-certification reporting schedule.

• Request for Q3 submissions of protection system misoperations

- Market participants were reminded to submit their quarterly reports before the due date of

Oct 31, 2014

- Any questions and/or inquiries related to the ORCP are to be sent to [email protected]

A. Burmaster asked if we were still using the Reliability Compliance Tool for submissions, since the last data request for Under Frequency Load Shedding (UFLS) came through email. A. Jabbar informed A. Burmaster that the compliance tool is limited to Market Participants (generator, transmitter, distributor, retailer, and/or wholesale customer) that are BPS-impactive. The UFLS data request on the other hand, irrespective of the BPS status, was sent to all generators (Form 1718), transmitters, distributors and wholesale customers (Form 1719) to collect Under-frequency protection settings from Market Participants that have UFLS equipment and/or capability. The email method seemed to be the most practical and consistent approach for this type of request. Since the majority of the self certs were to be issued on Feb 04/2014, it was also decided to split the certifications in to smaller subsections scheduled to be issued for Dec, Jan, and Feb – all targeted to be due by the end of March 2015. A. Jabbar to review the ORCP schedule and divide the self certs issue dates (Action Item 2). 6. Current NERC/NPCC/FERC Activities

Page 6: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 6 of 12

Reliability Standards Standing Committee

6a) Update on Reliability Standards under Development and Coming into Effect in Ontario

H. Lainis presented updates on the current NERC/NPCC/FERC activities. She talked about the OEB process and mentioned that since the last meeting, there had been a few standards that NERC filed for regulatory approvals with FERC which are now becoming enforceable in Ontario. The closing dates/status for these standards is as follows:

• VAR-001-4 – Voltage and Reactive Control (closed) • VAR-002-3 – Generator Operation for Maintaining Network Voltage Schedules (closed) • FAC-001-2 – Facility Interconnection Requirements (closing date: December 27, 2014) • FAC-002-2 – Facility Interconnection Studies (closing date: December 27, 2014) • PRC-004-3 – Protection System Misoperation Identification and Correction (closing date: January

13, 2015) • NUC-001-3 – Nuclear Plant Interface Coordination ( closing date: January 13, 2015)

IESO's briefings to the OEB regarding these standards are available on IESO’s Reliability Standards Compliance page under the heading “OEB Review of a New or Amended Reliability Standard”.

6b) Update on NERC Standards Committee Activities

B. Li presented updates on the NERC Standards Committee Activities. He mentioned that there had been two face to face meetings and two conference calls since the June 2014 RSSC meeting. He also discussed some of the major issues: First that there had been too many draft standards posted in any one period and the SMEs particularly in the protection system area have been overwhelmed (H. Lainis and A. Sabouba in agreement). Some of these concerns are being addressed by the Standards Committee’s Project Management and Oversight Subcommittee (PMOS). B. Li shared some of his past experience and informed members that the Standards Committee used to develop standards development plan for the upcoming years with consideration of NERC and industry resources to avoid overburdening NERC staff and industry participants. But recently, under the new leadership in the standards committee, there have been far too many standards posed for approval to the board. For some this is seen as being a great leap in standards development process but many disagree with this approach. Since resources are already limited; with an addition influx of added standards, the quality suffers. On that point B. Li also mentioned that since the SMEs are faced with so many standards to comment on, it becomes very difficult to get genuine and constructive comments back. B. Li informed members that he will continue to push forward and persuade the board to have this process changed. S. Berry asked if we are the only dissenting voice in this matter, and what is everyone else’s position. B. Li informed S. Berry that ISO/RTO council fully supports this cause, but unfortunately despite this, are still a minority in the Standards committee. D. Ramkalawan inquired that since there in an influx of standards coming in all the time, would H. Lainis be able to provide some explanation outside the RSSC meeting on the development of these standards. H. Lainis agreed to look into setting up conference calls to discuss a proposed standard during the NERC comment period with RSSC members. B. Li asked to be included as well, as he is usually the one to draft the first set of comments. L. Reid offered her assistance to push the federal/provincial/territorial/trilateral routes thru the staff side of NERC to request to bring those comments back as the industry is very overwhelmed.

Page 7: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 7 of 12

Reliability Standards Standing Committee

Proceeding with the presentation, B. Li spoke on the issue of the Quality Review (QR) process that has been dropped by the standards committee. He informed members that no separate QR process is being implemented on any draft standards, which not only affects the quality of the standard but also restricts introducing diverse perspectives which are vital for standards development. B. Li added that this might explain some of the ambiguous language and non-corresponding requirements/measures existent in the draft standards. A. Sabouba commented that if any member has an opportunity to speak with NERC regarding the volume of standards review, it is important to mention that it is not just the volume that is a concern but also the associated additional documents (whitepapers etc.). B. Li agreed and shared an example of the recent TOP standard posting, which requires one to pay very close attention to its associated mapping document; which can otherwise result in a major reliability gap. D. Kiguel asked if there is another initiative that is associated with the cost effectiveness of the standards since there are far too many standards being developed that require significant expenses on the part of the entities, but resulting in very little reliability. B. Li mentioned that a cost effectiveness analysis process is being proposed, but so far NERC staff has been reluctant to accept it, since it requires resources for data collection, and that effort will add additional time to the standards project. B. Li added that they will just have to figure out a way to raise these issues in front of the board and will also have to effectively communicate these issues with board members to gain their support. B. Li also mentioned that several waivers are being requested, to meet regulatory deadline:

• TOP-001-3, FERC has asked for receiving the proposed standard by the end of the year. • PRC-026-1, stable power swing • TPL-007-1, Geomagnetic Disturbance

Another item worth noting is that there will be a special election to replace the vice-chair, who has stepped down unexpectedly. Several tasks are being perused by the Process Subcommittee (SCPS):

• Developing a process for consensus building and SAR development - In an informal stage prior to official launch of a standard development project

• Revised charter approved

- Subcommittee may elect its officers (before it was appointed by the standards committee to make it consistent)

- Added a task to communicate new process/deliverables

Project Monitoring and Oversight Subcommittee (PMOS):

• Revised charter approved to be consistent with the other charters. • Developing proposal to spread out posting – working on it.

Functional Model Advisory Group (FMAG):

• Charter is being developed (5th version of the model which appears to be in a very stable state now). The idea is to disband that functional model working group but turn it into an advisory group

<Break>

S. Berry asked D. Robitaille to brief members on IESO’s recent activities with NPCC. D. Robitaille informed

Page 8: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 8 of 12

Reliability Standards Standing Committee

members that the IESO was audited the end of Sept 2014 for two weeks on both operational and planning standards (from TOP to IRO, EOP to CIP) which turned out to be very successful. He mentioned that these tri-annual comprehensive audits usually take three years as sort of an on-going process.

D. Kiguel asked whether the IESO and/or MACD is monitored and eventually audited in its activities related to compliance enforcement to Market Participants. C. Dragnea mentioned to D. Kiguel that the IESO and MACD have been peer-reviewed in 2009 by NPCC with respect to their compliance monitoring and enforcement program. Moreover, there were recommendations to implement an audit program in Ontario and the IESO/MACD has implemented an audit program in 2011. More recently IESO/MACD has kept in touch with NERC/NPCC, and invited them to conduct a peer-review of our investigation/audit processes related to reliability standard enforcement (invitation is still open with NERC). C. Dragnea also emphasized that there are no formal or cyclic review processes for our compliance enforcement activities as we remain transparent to both NERC and NPCC with our activities.

6c. NERC Standards Development

B. Li informed RSSC members that there have been a lot of standards posted for comments recently but he had picked several major ones to discuss:

• Geomagnetic Disturbance, TPL-007-1, which is in a second stage of a 2-stage project to address a FERC directive to develop Standards that are: - Applicable entities to conduct assessments of the potential impact of benchmark GMD events

on their systems. - Applicable entity to develop and implement a plan to mitigate the risk of instability,

uncontrolled separation, or Cascading. • The IESO again voted Negative in view of a couple of major issues:

- The standard does not require a process to compare simulations with measurements to get the right level of confidence that predictions can be made to enable good planning and operation decisions.

- There lacks a solid technical basis for the 15 Amp threshold - a one-size-fits-all approach. IESO has measurements that show much higher than 15A has not been a problem.

A. Sabouba mentioned that Hydro One voted affirmative under the view that one needs a starting place and this is what the SDT is proposing. D. Kiguel voted negative with the view that there hasn’t been a serious cost benefit analysis and the benchmark that is proposed, is for 1 occurrence in 100 years. D. Kiguel also mentioned that for such a low frequency, perhaps some moderate non-consequential load shedding could be more acceptable without having to drain resources in complying with this standard. H. Lainis mentioned that this standard would affect the northern regions more compared to the southern ones and it is understandable as to why some entities would be reluctant to invest their resources for a benchmark that has not been studied extensively.

On a different point K. Khan also added that being the confidential nature of this standard, it will be the Reliability coordinator (RC) or the Planning committee (PC) that will have access to all area wide views and the associated data; which will have to be coordinated with the asset owners. K. Khan also mentioned that there was a discussion in the last RSSC meeting that a coordination effort with asset owners is to be implemented for some of these targeted standards and the IESO SMEs have been talking to Market Participants to provide further clarifications and will continue this collaborative effort in the future, if

Page 9: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 9 of 12

Reliability Standards Standing Committee

required.

B. Li proceeded on to the topic of Disturbance Monitoring, PRC-002-2 which:

• Has been revised to combine PRC-002-1 and PRC-018-1 • Will replace the fill-in-blank requirements and remove Regional Reliability Organizations from the

applicability list.

B. Li mentioned that this standard appears to be rather clear and reasonable. However, a couple of issues:

• R1 and R5 make reference to the Implementation Plan, which is a one-of thing. Hence, these two requirements will be out of sync sometime in the future. IESO plans to support the standard despite this issue.

Stable Power Swing, PRC-026-1:

• Third phase of a three-phase standard development project to address FERC’s concern over the unintended operation of protective relays due to stable power swings.

• The current draft appears to be quite clear and reasonable. • IESO voted Negative in view of a concern over the unintended provision that: asset owners may

remove the distance relay tripping abilities for unstable power swings, which may in turn prevent successful self-generating islands to form, making the restoration process much more difficult.

• The IESO propose that the standard impose a requirement for asset owners to consult with the Planning Coordinator prior to taking such action.

PRC-005-X: Protection System Maintenance for Sudden Pressure Relays:

• To address a directive in FERC Order No. 758, to include sudden pressure relays, which trip for fault conditions, and also to propose minimum maintenance activities for such devices & maximum maintenance intervals.

• IESO’s previous concern over the requirement for BA to notify others of the largest generating unit in its area (to aid determination of applicability) in Section 4.2.6.1 has been removed

• IESO voted Affirmative (A. Sabouba and D. Kiguel also voted affirmative) • Standard received 76% approval rate and we can expect this standard to be posted for

recirculating ballot soon

B. Li also mentioned that at the approval of PRC-005, the proposal is to drop NPCC Directory 3.

PRC-004-3 (Protection System Misoperations) received industry’s final approval, which is at about 80%:

• Hydro One voted Affirmative. • IESO voted Negative under the view that the introduction of a new term “Composite Protection

System” is unnecessary and redundant. Also that the omission of Under-voltage Load Shedding (UVLS) scheme in the list of Facilities under the Application Section is inconsistent with the inclusion of Underfrequency Load Shedding (UFLS) scheme.

Revision to Multiple TOP/IRO Standards is a project initiated to address concerns raised in the November 2013 FERC NOPR. FERC proposes to remand the NERC petitioned TOP-001-2, -002-3 and -003-2 standards and IRO-001-3, -002-3, -005-4 and -014-2 standards.

• A total of 9 standards are being revised/added, along with a proposal to retire 5 IRO standards and 6 TOP/PRC standards (all requirements absorbed by or redundant with the 9 proposed standards).

Page 10: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 10 of 12

Reliability Standards Standing Committee

• IESO supports most of the standards except IRO-014-3 in view of a change from “affected RC” to “adjacent RC” which may not fully address reliability concerns.

• IESO objects to the proposed retirement of TOP-004-2, Requirement R4, which requires RC and TOP to develop limits when in an unknown state. On this point B. Li added that the SDT disagrees, and they hold the view that there is no possibility to get in to an unknown state. B. Li contended that from time to time one can enter into a state which has not been studied before and that can be deemed an unknown state. In view of this issue, B. Li recommended a NO vote for TOP-001-3 (IESO voted affirmative in the past) and informed members that a conference call will be set-up with Kyle Russell, who is on the SDT, to talk about this further. B. Li also noted that the standards committee has asked for a waiver on TOP-001-3.

H. Lainis presented revisions to Version 5 CIP Standards and mentioned that FERC has approved version 5 of the CIP standards, and has also directed NERC to make the following modifications:

• Modify or remove the “identify, assess, and correct” language in 17 CIP version 5 requirements. IESO agreed with this approach and voted AFFIRMATIVE

• Create a definition of “communication networks” and develop new or modified standards that address the protection of communication networks. The IESO agreed with the requirement approach and voted AFFIRMATIVE

• Develop modifications to the CIP standards to address the security controls for Low Impact assets and develop requirements that protect transient electronic devices. The IESO voted NEGATIVE in the view that comments centred around the structure of the requirements (i.e., should be in the body of the standard and not in the attachments); wording correction (i.e., use “transferring rather than “transmitting”) and term BES Cyber Assets should be used in conjunction with BES Cyber Systems

S. Berry inquired if there had been any talks about aligning the enforcement dates of CIP version 5 to the enforcement dates of the BES definition, as they are both dependant on each other. He was concerned that entities may have a 3 month gap where you might be BES element and would not be subjected to CIP version 5 but rather have to show compliance to CIP version 3. He also mentioned that the enforcement to CIP version 5 is April 01/2016 and July 01/2016 for the BES definition. To S. Berry’s point E. Giaouris mentioned that in this specific case entities may have the alternative of opting for the CIP version they want to be audited on. S. Berry added that perhaps this can be clarified by NPCC.

Next, B. Li presented slides on Physical Security Standard – CIP-014-1; which is developed to address reliability concerns caused by physical security vulnerability. This standard received 85.61% approval and FERC issued a NOPR in July proposing to approve the standard, and directing NERC to:

• Develop a modification to the physical security Reliability Standard to allow applicable governmental authorities (i.e., the Commission and any other appropriate federal or provincial authorities) to add or subtract facilities from an applicable entity’s list of critical facilities under Requirement R1,

• Modify the physical security Reliability Standard to remove the term “widespread.”

B. Li mentioned that the first issue has raised some concerns with regards to giving the government authority to add or remove assets. Many including the CEA submitted comments objecting to this directive. He mentioned that the standard is very clear that the asset owners after determining its set of critical facilities, has an appointed verifier (either RC or another entity) and despite having someone inspect the initial list, the NOPR appoints veto authority to a governmental body to further modify the critical asset list, if need be (which suggests a bit of a political push/pull in the background). In addition to B. Li’s comments, D. Kiguel mentioned that this standard had received clear approval from the industry when it

Page 11: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 11 of 12

Reliability Standards Standing Committee

was balloted and in his opinion; is poorly crafted. It consists of requirements that are not possible to measure and due to the short deadline to file the standard; NERC ignored many of the valuable and constructive inputs in the last round of industry comments.

Next B. Li talked about the NOPR on COM-001-2 and COM-002-4. He mentioned that the COM-001-2 (Communications) was approved by the industry in 2013 and COM-002-4 (Operating Personnel Communications Protocols) was approved by the industry in 2014. For COM-001-2, FERC seeks industry’s views on:

• Whether the proposed COM-001-2 should be modified to address internal communication capability requirements, or to address testing requirements for distribution providers and generator operators;

• Clarifications regarding the scope and meaning of the proposed definitions of Interpersonal Communication and Alternative Interpersonal Communication as the proposed definitions do not state explicitly a minimum expectation of communication performance such as speed and quality; and,

• Whether the definition of Interpersonal Communications includes mediums used directly to exchange or transfer data.

There has been no decision yet by the ISO/RTO Council or the IESO on whether to submit comments addressing the above. For COM-002-4, FERC raises questions/concerns over:

• Whether operating entities communicate operating instructions to Transmission Owners and Generator Owners?

• If so, if 3-part communication is not performed, who should be responsible (if something goes wrong)?

The IESO (and some ISOs/RTOs) do communicate to TOs and GOs that are not TOP/GOP and some possible means to ensure compliance is to:

• Have internal process to enforce 3-part communication. Or, • Include TOs and GOs in the COM-002-4 applicability section. Or, • Surrogate TOP and GOP to be responsible and have their internal agreements with the owners

knowing who to pass liabilities to if errors occur.

6d. NPCC Standards and Criteria Development Lastly B. Li presented updates on directory #3, and mentioned that NPCC has proposed to retire this directory following regulatory approval of NERC PRC-005-2 standard. The IESO supports and have voted affirmative to the proposed retirement on the basis that NPCC needs to ensure that each entity will include in the NERC BES facilities list those NPCC BPS elements that would not fall within the new revised NERC BES definition. He also mentioned that NPCC has confirmed that BPS elements will become part of BES and must adhere to NERC reliability standards. B. Li concluded with informing members that upon approval of MOD-025-02, Directory 9 and 10 are possibly the next set of directories to retire. 7. Other items L. Reid shared some updates:

• NERC and FERC, as a joint effort, will be sending out a survey to the industry to review 9 entities for recovery plans and will also put out a report sometime in mid-2015 for recommendations of improvements in standards.

Page 12: Reliability Standards Standing Committee (RSSC) · 10/21/2014  · Reliability Standards Standing Committee 5. Ontario Reliability Compliance Program Updates A. Jabbar presented the

October 21, 2014 Public Page 12 of 12

Reliability Standards Standing Committee

• CIP version 5 will be up for ballot and if it fails, some parts may be balloted separately. • Regarding the EPA-111-d requirements (proposal to reduce carbon CO 2 pollution from existing

power Plants) NERC is currently doing is a review on the effectiveness of their reliability, and have not yet submitted any comments

• GridEx III planning is underway and the report for GridEx II is now available online. • Lastly, the Regie de l'energie, NERC and NPCC have signed a new MOU. Alberta and BC are in the

talks of becoming their own Reliability Coordinator (RC) following more of the Ontario model and will most likely have their own MOUs as well.

8. Next Meeting The 29th RSSC meeting (Q4 for 2014) is scheduled for Thursday January 15, 2015 at the IESO Boardroom. No further items were brought up and the meeting ended at 12:30 PM. Motion to adjourn was made by A. Sabouba and K. Khan.