April 5, 2016
To:
Market Participants and Other Interested Parties
Re:
Consultation Letter – Proposed New Alberta Reliability Standard Definition “system element”
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” or “Commission”) for review along with the AESO’s recommendation that
the Commission approve or reject them.
Consistent with the AESO’s drafting principles for authoritative documents, the AESO has determined that it is
appropriate for defined terms used in the Alberta reliability standards to go through the same consultation
process as the Alberta reliability standards themselves. Accordingly, the AESO is providing notice and
seeking comments from market participants on the attached proposed new system element definition.
Overview
The AESO is issuing the following four letters concurrently:

this Consultation Letter regarding the proposed new Alberta reliability standard definition of
“system element”;

a Letter of Notice regarding the proposed new Section 304.7 of the ISO rules, Event Reporting
(“New Section 304.7”) and the proposed amendment of existing Operating Policy and Procedure
1304, System Event Monitoring and Disturbance Reporting (“Existing OPP 1304”);

a Letter of Notice regarding the proposed New ISO Rules Definitions related to the proposed New
Section 304.7 and the proposed new ISO rules definition of “system element”; and

a Consultation Letter regarding the proposed new Alberta reliability standard EOP-004-AB-2,
Event Reporting (“New EOP-004-AB-2”) and the proposed retirement of existing Alberta reliability
standards EOP-004-AB2-1, Disturbance Reporting and CIP-001-AB1-1, Sabotage Reporting.
The combined purpose of these letters is as follows:

to propose for adoption the requirements of North American Electric Reliability Corporation (“NERC”)
EOP-004-2, Event Reporting (“NERC EOP-004-2”), in Alberta through both the proposed New EOP004-AB-2 and the proposed New Section 304.7, including Alberta variances or administrative
amendments as appropriate;

to propose the adoption of three definitions for use in the ISO rules that have been previously
approved for use in the Alberta reliability standards and are used in the proposed New Section 304.7;

to propose the adoption of the definition of “system element”, which is used in the proposed New
Section 304.7, for use in both the ISO rules and the Alberta reliability standards; and

to propose the amendment of certain ISO rules and Alberta reliability standards to incorporate the
proposed new defined term “system element” or to unbold the previously defined term “element”.
Background
The purpose of this Consultation letter is to consult on the adoption of the definition of system element for
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use in the Alberta reliability standards, and to propose the amendment of certain Alberta reliability
standards to incorporate the proposed new defined term “system element” or to unbold the previously
defined term “element”.
The NERCuses the defined term “element” to describe multi component devices on the electric system,
such as a generator, transformer, circuit breaker, bus section, or transmission line, as opposed to any
one of their many subcomponents. It has been determined that the AESO should have an equivalent term
defined for use in the Alberta reliability standards for the same reason.
Previously, a definition of the term “element” was included in the AESO’s Consolidated Authoritative
Document Glossary (“CADG”). In 2014, the defined term “element” was removed from the CADG in
favour of the plain language meaning. However, the defined term is still bolded a number of Alberta
reliability standards. The proposed new defined term “system element” is proposed to be incorporated
into the CADG for use in the Alberta reliability standards to distinguish the use of the defined term from
the common use of the term “element”. The proposed definition for “system element” can be found in the
attached Market Participant Comment Matrix.
Summary of the Proposed Definition
The AESO proposes to incorporate the following proposed new defined term, along with its related
definition, into the AESO’s CADG for use in the Alberta reliability standards:
a) system element.
When reviewing the attached proposed new system element definition, stakeholders should note that all
defined terms appear in bold. Stakeholders are encouraged to refer to the CADG when reviewing definitions
to ensure they have an accurate understanding of those defined terms.
Summary of the Proposed Related Amendments to Alberta Reliability Standards
The term “element” is used in several Alberta reliability standards where it is intended to have its plain
language meaning. The following Alberta reliability standards are proposed to be amended to unbold the
term “element”:
a) CIP-003-AB-5, Cyber Security - Security Management Controls;
b) CIP-004-AB-5.1, Cyber Security - Personnel & Training;
c) CIP-005-AB-5, Cyber Security - Electronic Security Perimeter(s);
d) CIP-006-AB-5, Cyber Security - Physical Security of BES Cyber Systems;
e) CIP-007-AB-5, Cyber Security - System Security Management;
f)
CIP-008-AB-5, Cyber Security - Incident Reporting and Response;
g) CIP-009-AB-5, Cyber Security - Recovery Plans for BES Cyber Systems;
h) CIP-010-AB-5, Cyber Security - Configuration Change Management and Vulnerability
Assessments; and
i)
CIP-011-AB-1, Cyber Security - Information Protection.
The following Alberta reliability standards are proposed to be amended to incorporate the bolded defined
term “system element”:
a) FAC-010-AB-2.1, System Operation Limits Methodology for the Planning Horizon;
b) FAC-014-AB1-2, Establish and Communicate System Operating Limits;
c) IRO-002-AB-2, Reliability Coordination - Facilities;
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d) IRO-005-AB-3.1a, Reliability Coordination - Current Day Operations;
e) PRC-004-WECC-AB1-1, Protection System and Remedial Action Scheme Misoperation
(“PRC-004-WECC-AB1-1”);
f)
PRC-018-AB-1, Disturbance Monitoring Equipment Installation and Data Reporting;
g) TPL-001-AB-0, System Performance Under Normal Conditions (“TPL-001-AB-0”);
h) TPL-002-AB-0, System Performance Following Loss of a Single BES Element (“TPL-002-AB-0”);
i)
TPL-003-AB-0, System Performance Following Loss of Two or More BES Elements
(“TPL-003-AB-0”); and
j)
TPL-004-AB-0, System Performance Following Extreme BES Events (“TPL-004-AB-0”).
Alberta reliability standard CIP-002-AB-5.1, Cyber Security - BES Cyber System Categorization is
proposed to be amended to unbold the term “element” in some instances and to incorporate the bolded
defined term “system element” in other instances.
Note that the AESO made additional administrative amendments to Alberta reliability standards
PRC-004-WECC-AB1-1, TPL-001-AB-0, TPL-002-AB-0, TPL-003-AB-0 and TPL-004-AB-0 in order to
transition these Alberta reliability standards into the current Alberta reliability standard format.
Request for Comments
Please use the attached Market Participant Comment Matrices when submitting comments to the AESO. Only
written comments will be considered in finalizing the proposed new system element definition. Market
participants should ensure that comments provided represent all interests within their organization.
Please provide comments or questions no later than April 25, 2016, to [email protected]. Adherence
to deadlines is essential to the integrity of the AESO consultation process. As such, any comments received
after April 25, 2016, may not be published, replied to, or otherwise considered by the AESO. The scope of this
consultation is limited to the proposed new system element definition and associated changes to the attached
Alberta reliability standards. Any comments received that are outside of this scope will not be considered by
the AESO.
The AESO will be publishing all comments received in April 2016.
AESO Reply to Comments
The AESO expects to publish its replies to comments received in May 2016.
If the AESO does not receive comments regarding the proposed new system element definition, the AESO
expects to forward the final proposed new system element definition to the Commission in conjunction with
the filing of proposed New Section 304.7.
Attachments to Consultation Letter
The following documents are attached:
1. Market Participant Comment Matrix , which includes a clean version of the proposed new system
element definition;
2. Blackline and clean copies of CIP-002-AB-5.1, Cyber Security - BES Cyber System Categorization;
3. Blackline and clean copies of CIP-003-AB-5, Cyber Security - Security Management Controls;
4. Blackline and clean copies of CIP-004-AB-5.1, Cyber Security - Personnel & Training;
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5. Blackline and clean copies of CIP-005-AB-5, Cyber Security - Electronic Security Perimeter(s);
6. Blackline and clean copies of CIP-006-AB-5, Cyber Security - Physical Security of BES Cyber
Systems;
7. Blackline and clean copies of CIP-007-AB-5, Cyber Security - System Security Management;
8. Blackline and clean copies of CIP-008-AB-5, Cyber Security - Incident Reporting and Response;
9. Blackline and clean copies of CIP-009-AB-5, Cyber Security - Recovery Plans for BES Cyber
Systems;
10. Blackline and clean copies of CIP-010-AB-5, Cyber Security - Configuration Change Management
and Vulnerability Assessments;
11. Blackline and clean copies of CIP-011-AB-1, Cyber Security - Information Protection;
12. Blackline and clean copies of FAC-010-AB-2.1, System Operation Limits Methodology for the
Planning Horizon;
13. Blackline and clean copies of FAC-014-AB1-2, Establish and Communicate System Operating Limits;
14. Blackline and clean copies of IRO-002-AB-2, Reliability Coordination - Facilities;
15. Blackline and clean copies of IRO-005-AB-3.1a, Reliability Coordination - Current Day Operations;
16. Blackline and clean copies of PRC-004-WECC-AB1-1, Protection System and Remedial Action
Scheme Misoperation;
17. Blackline and clean copies of PRC-018-AB-1, Disturbance Monitoring Equipment Installation and
Data Reporting;
18. Blackline and clean copies of TPL-001-AB-0, System Performance Under Normal Conditions;
19. Blackline and clean copies of TPL-002-AB-0, System Performance Following Loss of a Single BES
Element;
20. Blackline and clean copies of TPL-003-AB-0, System Performance Following Loss of Two or More
BES Elements;
21. Blackline and clean copies of TPL-004-AB-0, System Performance Following Extreme BES Events;
and
22. Market Participant Comment Matrix for the proposed amendments to Alberta reliability standards in
regards to the proposed new defined term “system element”.
Sincerely,
"Original Signed By"
Gillian Barnett
Regulatory Legal Counsel
Phone: 403-539-2920
Email: [email protected]
Attachments
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