Alberta Electric System Operator

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Hector Howard Cooper
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1 Decision D Rejection of Reliability Standard MOD November 5, 2018

2 Alberta Utilities Commission Decision D Rejection of Reliability Standard MOD Proceeding Application A001 November 5, 2018 Published by the: Alberta Utilities Commission Eau Claire Tower, 1400, 600 Third Avenue S.W. Calgary, Alberta T2P 0G5 Telephone: Fax: Website:

3 Contents 1 Introduction Background Commission findings and decision... 2 List of Tables Table 1. Reliability standard filed September 20, Decision D (November 5, 2018) i

5 Alberta Utilities Commission Calgary, Alberta Decision D Rejection of Reliability Standard Proceeding MOD Application A001 1 Introduction 1. In a forwarding notice dated September 20, 2018, the (AESO) 1 recommended that the Alberta Utilities Commission assess the reliability standard identified in Table 1 as not applicable in Alberta and approve its rejection pursuant to Section 19 of the Transmission Regulation. The AUC registered this filing as Application A001 and designated it as Proceeding Table 1. Reliability standard filed September 20, 2018 Reliability standard category Reliability standard Reliability standard name Proposed action Modeling, Data, and Analysis (MOD) MOD Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions Reject 2. In Alberta, the AESO fulfils the role and obligations of Independent System Operator (ISO) as defined in the Electric Utilities Act. For the purposes of this decision, AESO and ISO are used interchangeably. 3. Pursuant to Section 19(4) of the Transmission Regulation, before adopting or making reliability standards, the ISO must consult with those market participants that it considers are likely to be directly affected and it must forward the reliability standards to the Commission for review, along with the ISO s recommendation that the Commission either approve or reject each of them. 4. Pursuant to sections 19(5) and 19(6) of the Transmission Regulation, the Commission must approve or refuse to approve each reliability standard in accordance with the recommendation of the ISO, unless an interested person satisfies the Commission that the ISO s recommendation is: (a) technically deficient, or (b) not in the public interest. 5. On September 25, 2018, the Commission issued a notice of filing and notice for objection for the reliability standard identified in Table 1, by uploading the notice to the Commission s efiling System. 6. No objections were filed with the Commission before the October 9, 2018 deadline specified in the notice of filing and notice for objection. 1 The Independent System Operator (ISO) is established under Section 7(1) of the Electric Utilities Act and operates under the trade name AESO. Decision D (November 5, 2018) 1

6 Rejection of Reliability Standard MOD Background 7. In its forwarding notice, the AESO submitted that the purpose of the North American Electric Reliability Corporation (NERC) reliability standard MOD (the NERC MOD Standard) is fulfilled by existing ISO rules, in particular Section Generating Unit Technical Requirements, Section Generating Unit Operating Requirements and the associated Generating unit functional document submission form. The AESO also identified that the existing ISO rules have broader application and are more stringent in relation to testing requirements than the NERC MOD Standard; a number of timelines for similar requirements are shorter in the ISO rules as compared with the NERC MOD Standard; and the NERC MOD Standard would impose a reporting requirement on legal owners of generating units, something that the AESO submits is already done on a voluntary basis. For all these reasons, the AESO recommended that the NERC MOD Standard be assessed as not applicable in Alberta and rejected. 8. Regarding consultation, the AESO expressed the view that market participants are not likely to be directly affected by the proposed rejection of the NERC MOD Standard. The AESO stated that, accordingly, no formal consultation with market participants was undertaken. 9. The AESO attached a copy of the NERC MOD Standard, and submitted that its recommendation that the Commission reject the NERC MOD Standard for adoption in Alberta complies with the requirements of the Transmission Regulation, is not technically deficient and is in the public interest. 3 Commission findings and decision 10. The Commission accepts and relies on the assertion of the ISO that no market participant is likely to be affected by the rejection of the NERC MOD Standard and that no formal consultation was therefore required. Based on that, the Commission finds that the ISO complied with Section 19(4)(a) of the Transmission Regulation. 11. Pursuant to sections 19(5) and 19(6) of the Transmission Regulation the Commission must follow the recommendation of the ISO to either approve or reject proposed reliability standards unless an interested person satisfies the Commission that the recommendation is technically deficient or not in the public interest: Reliability Standards [ ] 19(5) Subject to subsection (6), the Commission must approve or refuse to approve the reliability standards, agreements, criteria or directives, and must inform the ISO of its decision. (6) The Commission must follow the recommendation of the ISO that the Commission approve or reject the proposed reliability standards, agreements, criteria or directives unless an interested person satisfies the Commission that the ISO s recommendation is (a) technically deficient, or (b) not in the public interest. 2 Decision D (November 5, 2018)

7 Rejection of Reliability Standard MOD The ISO forwarded the NERC MOD Standard to the AUC with a recommendation that the Commission reject it. 13. No interested party filed an objection with the AUC indicating that the ISO s recommendation is technically deficient, or not in the public interest. 14. Accordingly, pursuant to Section 19(6) of the Transmission Regulation and based on the recommendation of the ISO, the Commission rejects the adoption in Alberta of reliability standard MOD Dated on November 5, Alberta Utilities Commission (original signed by) Carolyn Hutniak Commission Member Decision D (November 5, 2018) 3

Alberta Electric System Operator

Decision 2011-501 Alberta Electric System Operator Approval of Alberta reliability standard BAL-002-AB-1 December 20, 2011 The Alberta Utilities Commission Decision 2011-501: Alberta Electric System Operator