April 5, 2016
To:
Market Participants and Other Interested Parties
Re:
Letter of Notice:
a) Proposed New ISO Rules Definitions Related to Proposed New Section 304.7 of the ISO
rules, Event Reporting (“New Section 304.7 Definitions”); and
b) Proposed New ISO Rules Definition “system element” (“New system element
Definition”)
Pursuant to Section 2 of Alberta Utilities Commission (“AUC” or “Commission”) Rule 017, the Alberta
Electric System Operator (“AESO”) is providing notice and seeking feedback from market participants and
other interested parties on the proposed New Section 304.7 Definitions and the proposed New system
element Definition.
Consistent with the AESO’s drafting principles for authoritative documents, the AESO has determined
that it is appropriate for defined terms used in the ISO rules to go through the same notification and
feedback process as the ISO rules themselves. The proposed New Section 304.7 Definitions and the
proposed New system element Definition will be incorporated into the AESO’s Consolidated Authoritative
Document Glossary (“CADG”).
Overview
The AESO is issuing the following four letters concurrently:

this Letter of Notice regarding the proposed New ISO Rules Definitions related to the proposed
New Section 304.7 of the ISO rules, Event Reporting (“New Section 304.7”) and the proposed
New system element Definition for use in the ISO rules;

a Letter of Notice regarding the proposed 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 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; and

a Consultation Letter regarding the proposed new Alberta reliability standard definition “system
element”.
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
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
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 the proposed New Section 304.7 is to ensure that events that have impacted the
operation of the transmission system or generating units are reported to the AESO, the NERC and other
organizations as appropriate.
While drafting the proposed New Section 304.7, the AESO determined that the proposed New
Section 304.7 Definitions and the proposed New system element Definition should be incorporated
into the AESO’s CADG for use in the ISO rules.
Accordingly, the purpose of this Letter of Notice is to:
(a) provide notice and seek feedback on the adoption of three new defined terms, currently approved
for use in the Alberta reliability standards, for use in the ISO rules; and
(b) provide notice and seek feedback on the adoption of the New system element Definition for use
in the ISO rules, and to propose the amendment of certain ISO rules to incorporate the proposed
new defined term “system element”.
Summary of the Proposed New Section 304.7 Definitions
The following new defined terms and related definitions are currently in effect for use in the Alberta
reliability standards and are being proposed for adoption for use in the ISO rules:
a) bulk electric system; and
b) misoperation.
The following new defined term and related definition was developed and approved by the Commission in
conjunction with the new Critical Infrastructure Protection Alberta Reliability Standards Terms and
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Definitions (“CIP ARS Terms and Definitions”), which will come into effect on October 1, 2017 for use in
the Alberta reliability standards. The defined term and related definition are being proposed for adoption
for use in the ISO rules:
a) control centre.
Summary of the Proposed New System Element Definition
The following new defined term and related definition are being proposed for incorporation into the
AESO’s CADG for use in the ISO rules:
a) system element.
The NERC uses 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
defined term defined for use in the ISO rules and Alberta reliability standards for the same reason.
Summary of Proposed Amendments to ISO Rules
The term “element” is used in several ISO rules where it is intended to have its plain language
meaning. The defined term “system element” is proposed to be used in the proposed New Section 304.7,
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Decision 3442-D01-2015, AESO Application regarding Alberta reliability standards definitions, September 15, 2015.
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Section 306.4 of the ISO rules, Transmission Planned Outage Reporting and Coordination
(“Section 306.4”) and Section 502.3, Interconnected Electric System Protection Requirements
(“Section 502.3”) to distinguish this defined term from the common use of the term “element”.
Accordingly, in addition to the use of the defined term “system element” in the proposed New
Section 304.7, amendments to Section 306.4 and Section 502.3 are proposed to incorporate the
bolded defined term “system element”. An additional administrative amendment was made to
subsection 32 of Section 502.3 to provide clarity.
Request for Comments
Please use the attached Stakeholder Comment Matrices when submitting comments to the AESO. Only
written comments will be considered in finalizing the proposed New Section 304.7 Definitions and the
proposed New system element Definition. Stakeholders 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 ISO rules comment 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 comments is limited to the proposed New Section 304.7 Definitions, the New system
element Definition and the associated proposed amendments to Section 306.4 and Section 502.3. Any
comments received that are outside of this scope will not be considered by the AESO.
The AESO will publish all comments received in April 2016.
AESO Reply to Comments
In accordance with Section 8 of AUC Rule 017, the AESO is required to provide replies to comments received
regarding the proposed New Section 304.7 Definitions, the proposed New system element Definition and the
associated proposed amendments to Section 306.4 and Section 502.3. The AESO expects to publish the
replies in May 2016.
If the AESO does not receive comments regarding the proposed New Section 304.7 Definitions, New
system element Definition and the associated proposed amendments to Section 306.4 and Section 502.3,
the AESO will proceed, pursuant to AUC Rule 017, to file the final proposed New Section 304.7
Definitions, the proposed New system element Definition and the associated proposed amendments to
Section 306.4 and Section 502.3 with the Commission no sooner than three days after the deadline for
comments as specified in this Letter of Notice.
In accordance with Section 20.4 of the Electric Utilities Act, market participants may object to ISO rules
filed with the Commission within 10 days of the publication of the Notice of Filing.
Attachments to Letter of Notice
In accordance with Section 4 of AUC Rule 017, the following documents are attached to this Letter of
Notice:
1.
Copy of a Stakeholder Comment Matrix, which includes a clean version of the proposed New
Section 304.7 Definitions;
2.
Copy of a Stakeholder Comment Matrix, which includes a clean version of the proposed New system
element Definition;
3.
Blackline and clean copies of Section 306.4;
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4.
Blackline and clean copies of Section 502.3; and
5.
Copy of the Stakeholder Comment Matrix for the proposed amended ISO rules.
Sincerely,
"Original Signed By"
Gillian Barnett
Regulatory Legal Counsel
Phone: 403-539-2920
Email: [email protected]
Attachments
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