Attendance
Participant Name / Company Name / Attendance StatusAndrew Burmaster / Brookfield Renewable Power / Present
Ben Li / IESO / Present
Cristian Dragnea / MACD / Present
Dave Kwon / OPG / Present
David Barrett / IESO / Present
David Kiguel / Observer / Present
David Peterson / OPG / Present (on the phone)
David Ramkalawan / OPG / Present
David Robitaille / IESO / Present
Deanne Stene / TransAlta Energy / Present (on the phone)
Des Ngunangwa / Bruce Power / Present
Esia Giaouris / Hydro One / Present
George Fatu / MACD / Present
Gordon Bartels / TransCanada / Present (on the phone)
Helen Lainis / IESO / Present
James Cook / Great Lakes Power (Transmission) / Present (on the phone)
Janis Gartshore / Great Lakes Power (Transmission) / Present (on the phone)
Jay Jayaraman / Enbridge / Present
Jian Zhang / TransAlta Energy / Present (on the phone)
John Bridges / Enbridge / Present
Jon Veldhuizen / Northland Power Inc. / Present
Khaqan Khan / IESO / Present
Laurie Reid / Ontario Energy Board / Present
Monica Adam / MACD / Present (on the phone)
Nimesh Shah / Goreway Station Partnership / Present
Norm Dang / IESO / Present
Paul Malozewski / Hydro One / Present
Ralph Kothe / Bruce Power / Present
Ron J. Falsetti / AESI / Present
Scott Berry / IESO / Present
Shahid khan / Northland Power Inc. / Present (on the phone)
Soon Chua / Portlands Energy Centre / Present (on the phone)
Vlad Stanisic / TransCanada / Present
Scribe: Adnan Jabbar, : Please report any corrections, additions or deletions to scribe.
All meeting materials are available on the IESO’s RSSC webpage at:
References:
IESO MACD page:
IESO Reliability Standards Compliance page:
NERC Standards page:
NPCC Regional Standards/Criteria page:
FERC Electric page:
Action Item Summary as of the 29th Meeting# / Date / Action / Status
1 / Feb 05, 2015 / MACD (C. Dragnea) to provide a high-level side-by-side comparison of the compliance framework in Ontario vs. NERC RAI / Completed
2 / Feb 05, 2015 / IESO (A. Jabbar) to circulate “lessons learned” notifications amongst the RSSC members / Completed
3 / Feb 05, 2015 / IESO (A. Jabbar) to circulate these “NERC Alerts” amongst the RSSC members / Completed
4 / Feb 05, 2015 / IESO (H. Lainis) to set up a meeting to discuss misalignments between the Transmission System Code requirements, and Reliability Standards / Completed
5 / Apr 29, 2015 / IESO (A. Jabbar) to get clarity from NPCC on the Quarterly Mis-operation reporting of system elements (whether BES or BPS elements). / initiated
- Welcome and Introductions
The thirtieth RSSC meeting commenced at 9:30 a.m. with brief introductions by each participant.
- Administrative Issues
a)The agenda for the meeting was reviewed and no new agenda items were added
b)The minutes of the twenty-ninth meeting was reviewed (page by page). No major concerns were raised. Motions to adopt the meeting minutes as final were made by A. Burmaster and P. Malozewski
c)Updates on the open action item were provided as follows:
- Action item 1: MACD (C. Dragnea) to provide a high-level side-by-side comparison of the compliance framework in Ontario vs. NERC RAI
- Action item 2: IESO (A. Jabbar) to circulate “lessons learned” notifications amongst the RSSC members
- Action item 3: IESO (A. Jabbar) to circulate these “NERC Alerts” amongst the RSSC members
- Action item 4: IESO (H. Lainis) to set up a meeting to discuss misalignments between the Transmission System Code requirements, and Reliability Standards
These items have been completed. There were no comments or questions from members.
d)RSSC Roster updates:A. Jabbar confirmed that some updates were made to the RSSC roster list that are now reflected in version 50(excel spreadsheet). The list was circulated amongst the committee members by email prior to the face-to-face meeting.
- MACD perspectives on Ontario CMEP
C. Dragnea presented the Risk-Based Compliance Monitoring and Enforcement Program (RB-CMEP). His agenda consisted of the following items: RB-CMEP definition, Risk concepts, Risk: market rules, Risk: NERC/FERC, Enforcement discretion, and RAI vs. ORCP comparison.
He began the presentation by briefly describing the concept of Risk-Based Compliance Monitoring and Enforcement Program (RB-CMEP). He mentioned that the RB-CMEP is a risk management process that provides reasonable assurance by identifying, correcting and mitigating non-compliance.It uses a risk hierarchy to prioritize issues based on actual and potential impact. C. Dragnea mentioned that this Risk management process modulates the scope of compliance monitoring based on regional and entity risks; where “Risks” are identified and prioritized based on the potential impact to the reliability of the BPS/BES, and the likelihood, that such an impact might be realized.
Furthermore, he mentioned that the RB-CMEP generates better signals for strengthening compliance and reducing risks to reliability and provides greater assurance that critical issues are addressed in a timely manner. He then briefly walked through the definitions of a few Risk concepts and tied it in with how MACD views risks in Ontario. Next C. Dragneaspent a fair portion of the time discussing NERC’s impact scale which defines three levels of impact: serious and substantial, moderate, and minimal. He mentioned that similar to NERC, MACD also utilizes an identical scale to “serious and substantial” when reviewing an event. MACD tries to understand (not just the event but) the value of various standards/requirements, and evaluates the impact of each requirement from a reliability perspective. Thus, in essence MACD has moved beyond just the Violation Risk Factors (VRFs) and created a model to capture the associated risk factors and impacts of each requirement.
C. Dragneathentalked about how the term “Risk” is used and perceived in the market rules; more specifically related to ch.3 s.6.6.6A, which covers the financial penalties greater than $10k. He shared specifics on how the range of these penalties is determined in fixing the financial amounts (severity of the breach, actual or potential impact of the breach,immediacy of the threat that the breach poses to reliability etc.). He then talked about how the term “Risk” is used with FERC and NERC in sanctioning, choosing an enforcement treatment, and/or choosing a monitoring regime.
Finally,C. Dragneacompared the RAI framework against what is implemented under the ORCP for the following two elements: Monitoring (tools: self-certifications, spot checks, audits), and enforcement (compliance exceptions, FFTs, self-logging). He covered each of the elements and sub-elements in great detail. To conclude the presentation C. Dragneaasked the RSSC participants to think about other elements in addition to NERC’s RB-CMEP that should be adopted by MACD to enhance the CMEP in Ontario.
- NERC Lessons Learned – Incremental 2
S. Berry presented updates on the NERC Lessons Learned. He mentioned that the principal goal of the Electric Reliability Organization (ERO) is to promote the reliability of the bulk power system in North America. This goal is directly supported by evaluating bulk power system events, undertaking appropriate levels of analysis to determine the causes of the events, promptly assuring tracking of corrective actions to prevent recurrence, and providing lessons learned to the industry. S. Berrybriefly talked about the lessons learned posted late April 2015 that highlighted the record rainfall within a metropolitan area which caused severe localized flooding at two large transmission substations, rendering the stations and all terminating circuits unavailable.
- NERC Industry Advisory (FAC-003 Clearances)
S. Berryalso presented NERC Advisory updates, which are intended to alert registered entities to issues or potential problems. He mentioned that as part of its normal course of business, NERC often either discovers, identifies, or is provided with information that is critical to ensuring the reliability of the bulk power system in North America. NERC utilizes “alerts” to relay this information (by email) to users, owners, and operators of the bulk power system in North America.
S. Berryshared an example of a recently posted NERC Alert related to “FAC-003-3 Minimum Vegetation Clearance Distances”, where the intent of the advisory was to provide Transmission Owners (TOs) and Generator Owners (GOs) information about preliminary testing results and anticipated adjustments to the Minimum Vegetation Clearance Distances (MVCDs) specified in NERC Reliability Standard FAC-003-3. He mentioned that NERC will undertake additional tests to finalize the preliminary gap factor determinations, file a final report with FERC by June 30, 2015, and initiate a Standard Authorization Request (SAR).
- CIP Version 5 Status Update
NERC initiated a program in 2014 to help the industry transition directly from the currently enforceable CIP Version 3 standards to CIP Version 5. The goal of the transition program was to improve industry’s understanding of the technical security requirements for CIP Version 5, as well as the expectations for compliance and enforcement. The CIP Version 5 transition program will be in place through the implementation period of the CIP V5 standards and beyond.
N. Dang provided members with an update, as he sits in the CIP Forum to discuss the actual CIP standards and how they could be interpreted.N. Danginformed members that the CIPstandards forum recently met to discuss the MACD audit findings of CIP V3 (on twelve Market Participants). He also mentioned that NERC filed a petition with FERC for the approval of proposed Critical Infrastructure Protection ("CIP") Reliability Standards CIP-003-6, CIP-004-6, CIP-007-6, CIP-009-6, CIP-010-2, and CIP-012. Notably under CIP-003-6 standard, some of the dates associated with low-impact assets were changed but for Cyber coordinates program and the cyber security instant response, the date remains to be April 01, 2017. He further mentioned that the only dates that were subject to change under CIP-003-6 standard were for the physical security controls and electronic security controls (due to feedback from MPs – now due in September 01, 2018).
R.Falsettiinquired about a recent NERC posting published on the April 23, 2015 which discussed control centers and the functional obligations under CIP standard from a NERC’s perspective of what they deem a control center to be. He mentioned that a particular section of the posting talked about an asset owner that operates a breaker under the direction of a transmission operator would still be considered a TOP function and therefore the control center wouldn’t be required to meet the CIP standard. He mentioned thatthis is concerning to a lot of folks in the north east and would appreciate some input from the IESO.
Numerous discussions took place on this topic. S. Berryinformed RSSC members that this is something that will require further review before the IESO is in a position to answerspecific questions. He also mentioned that there have been a lot of activities in the CIP transitional area, especially in parts that have been identified as BES; any questionsor inquiries regarding CIP updates or future CIP meetings, can be brought toN. Dang’s attention.
- NERC Risk Based Registration (RBR) Phase 2 Update
H. Lainis presented updates on the NERC Risk Based Registration (RBR). She mentioned that in addition to NERC’s Risk Based compliance monitoring enforcement program; which was covered in the last RSSC meeting; NERC had also been working on the Risk based registration which was part of the Reliability Assurance Initiative (RAI). NERC launched the Risk-Based Registration (RBR) Initiative to ensure that the right entities are subject to the right set of applicable Reliability Standards, using a consistent approach to risk assessment and registration across the ERO. The goal is to develop enhanced registry criteria, including the use of thresholds and specific Reliability Standards applicability, where appropriate, to better align compliance obligations with material risk to Bulk Electric System reliability.
She mentioned that Phase 1 of the RBR removed from NERC Compliance Registration functions that are commercial in nature, such as: Purchase Selling Entity (PSE), Interchange Authority (IA), Load-Serving Entity (LSE), and creates a UFLS-only Distribution Provider (DP). However, long before NERC launched its Risk-Based Registration (RBR) Initiative, the IESO had already adopted this risk- based approach to its applicability criteria. She mentioned that the IESO’s Applicability Criteria is similar to NERC’s Compliance Registry; where it applies to Ontario Market Participants, is largely consistent with NERC’s compliance registry and does not apply any reliability standards to the functions of PSE and LSE.
Next H. Lainisdiscussed details pertaining to the Risk-Based Registration – Phase 2. She mentioned that NERC is considering the development of a “tier” system – subset of Reliability Standards obligations for:
•Dispersed power producing resources and small generators
•Low risk TO/TOP category
She mentioned that the IESO also considered a low risk TO/TOP category but no Ontario transmitter met the criteria. Finally, she talked about the complex considerations involving Phase 2 and how there is a need to better understand the impact of the sub-set classes of generation facilities in relation to the unique characteristics of each power system. H. Lainisconcluded the presentation by mentioning that the IESO is going to be following the RBR progress very closely.
- Ontario Reliability Compliance Program Updates
A. Jabbar presented the updates to the 2015 Ontario Reliability Compliance Program. At a high-level he underlined some of the updates/completed itemsin the2014 Self-certification schedule since the last RSSC meeting:
•All Self-certs for NERC Reliability Standards under Set 2: [completed ]
•All Self-certs for NERC Standards under Set 3: [completed]
•2014 ORCP schedule spreadsheet was updated (ver. 9) to reflect all completions and posted on the IESO ORCP public page.
He mentioned that the 2015 ORCP (Preliminary) Schedule wasalso posted online and gave a brief overview on some of the items that were included:
•Directory#12 UFLS Annual Survey – Forms 1718/1719; applicable to TO, GO, LSE, DP
•Quarterly Protection System Operation/Misoperation Reporting; applicable to Market Participants identified as BPS (A-10)
•Emergency Preparedness/Restoration planning – Form 1608/1609; applicable to those market participants identified by the IESO as Restoration Participants
•Transmission Vegetation Management Program – Form 1527; applicable to TO and GO
D. Ramkalawaninquired about the Quarterly Protection System Operation/Misoperation Reporting as to whether the reporting applies to BES or BPS elements. He mentioned that in his exchange with the NPCC personnel the reporting should be on the BES elements above 100 kV. To which S. Berry mentioned that the BES applicability based on the new (subjugation of) BES definition is not enforceable until July 01, 2016. However, the IESO can check with NPCC and provide some clarity (Action Item 5).
Lastly, A. Jabbar(as an awareness piece)mentioned that a request for 2015 Q1 of Protection System Operation/Misoperation reporting was issued on April 1st 2015, and is due on May 1st 2015.
< Lunch Break >
- Standards Enforcement Dates Update
A. Jabbar presented updates on the NERC standards that have now been approved by FERC since the last RSSC meeting in Feb 2015 and their determined Ontario enforcement dates:
•MOD-031-1 (Demand and Energy Data) – Enforceable on Jul 1, 2016will respectively supersede five existing Reliability Standards: MOD-016-1.1, MOD-017-0.1, MOD-018-0, MOD-019-0.1, and MOD-021-1
•PRC-006-2 (Automatic Underfrequency Load Shedding) – Enforceable on Jan 1, 2016will respectively supersede PRC-006-1
•COM-001-2 (Communications)– Enforceable on Oct. 1, 2015will respectively supersede COM-001-1.1 Requirements R1, R2, R3, R5 and R6
•COM-002-4 (Operating Personnel Communications Protocols) – Enforceable on Jul 1, 2016will respectively supersede COM-001-1.1 Requirements R4, COM-002-2, and COM-002-3
•BAL-001-2 (Real Power Balancing Control Performance) – Enforceable on Jul 1, 2016will respectively supersede BAL-001-1
He informed members that all relevant Enforcement and Retirementdates will appear in version 6.0 of the “Milestones in Reliability Standard Development and Lifecycle” spreadsheet (available on the IESO public page). Participants were also encouraged to refer to the implementation plan (for each respective standard), which consists of supplementary details regarding the enforcement dates of requirements and sub-requirements.
- Current NERC/NPCC/FERC Activities
10a) 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 the IESO is responsible for communicating any new or amended reliability standards and criteria to market participants that may be subject to the Ontario Energy Board's (OEB) review. She mentioned that:
•The IESO posts briefings (summaries on NERC filings with FERC) on new or amended reliability standards on its public page within seven days of it being notified by the standards authority.
•There is a 21-day window for any market participant, including the IESO, to request an OEB review of the posted reliability standard. The OEB would also be able to initiate its own review within 120 days.
•If there is no review, the standard would go into effect under the Market Rules upon the enforcement date of the reliability standard.
•If reviewed, the OEB has the authority to stop the standard from applying in Ontario and to refer it back to the standards authority
There were numerous discussions related to the cost implications within the briefings. H. Lainismentioned that at the time of the briefings some of the associated costs are unknown; hence they are left blank. However for standards that fall under the functional model of a Balancing Authority (BA), Reliability Coordinator (RC), and/or Transmission Operator (TOP); the IESO conducts an internal gap analysis which, at times, reveals a potential cost factor. The cost implications for standards that fall outside of those functional models are typically left with the applicable entities, to conduct their own assessment. In addition, K. Khan mentioned that if costs associated with certain standards are concerning, there are numerous opportunities to influence the process at the standards development stage (through commenting/voting), or during the OEB review period, where participants have 21 days to request a remand on a standard.