DC hydro m FOR GENERATIONS Janet Fraser Chief Regulatory Officer Phone: 604-623-4046 Fax: 6.04-623-4407 [email protected]
September 19, 2012
Dokie General Partnership Toba Montrose General Partnership Attention: Brandon Woudzia Attention: Brandon Woudzia [email protected] [email protected]
Attention: Paul Rapp Attention: Jay Sutton [email protected] [email protected]
Attention: Walter MacFarlane Attention: Tony Nott [email protected] [email protected]
Attention: Sophie Pilkington Attention: Stacie Crane [email protected] [email protected]
TransCanada Energy Sales Ltd. Catalyst Paper Attention: Gordon Bartels; Ron Adam Attention: Carlo Dal Monte [email protected] [email protected]
Attention: Bob Lindstrom [email protected]
FortisBC Energy Inc. lnnergex Renewable Energy Inc. Attention: Janice Barkey (formerly Cloudworks Energy Inc.) [email protected] Attention: John D. Miller
[email protected] Attention: Jaime Chiang [email protected]
Shell Energy North America Tembec CRS/LAP (Canada) Inc. and Shell Energy Attention: Alan Scalet North America (US), L.P [email protected] Attention: Paul Kerr [email protected] Attention: Chris Lague
[email protected] Attention: Robert Reilley robert.reilley@shell .com Attention: Elroy Switlishoff
Dear Sir or Madam:
RE: British Columbia Utilities Commission (BCUC)
Powell River Energy Inc. Attention: Bryan Lacey Bryan. Lacey@brookfield renewable. com
Attention: Tracy Brason [email protected]
Attention: Walter DiCesare [email protected]
Attention: Andrew Burmaster Andrew. Bu rmaster@brookfieldrenewable. com
Fortis BC Inc. Attention: Dennis Swanson
Curtis Klashinsky; Lavern Humphrey
[email protected] [email protected] [email protected] [email protected]
Powerex Attention: Jeff Lam [email protected]
British Columbia Hydro and Power Authority (BC Hydro) Mandatory Reliability Standards (MRS) Assessment Report No. 5 Compliance with BCUC Order No. R-54-12
As one of the entities who provided comments regarding the Mandatory Reliability Standards assessed in the above-noted report (Report), BC Hydro writes to advise you
British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3 www.bchydro.com
543 Pages B-2
markhudsBC HYDRO – MRS Report No 5
September 19, 2012 Mandatory Reliability Standards (MRS) Assessment Report No. 5 Compliance with BCUC Order No. R-54-12
BChgdro
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that the Report was filed with the BCUC on April 19, 2012 and Errata No. 1 to the Report was filed on May 3, 2012. Electronic copies of the Report and Errata No. 1 were provided to you at the time the documents were filed. For convenience of review, the Report and Errata No. 1 are attached in electronic format to this letter (Attachment 1).
Pursuant to Order No. R-54-12, the BCUC has established a regulatory process for review of the report and has directed BC Hydro to notify you of such. A copy of this order is attached for your information (Attachment 2). Please note that the date for submitting written comments to the BCUC and BC Hydro is October 19, 2012.
For further information, please contact Sandra Jones at 604-623-4315 or by e-mail at [email protected].
Yours sincerely,
(for}Al_9A t Fraser LChief Regulatory Officer
ch/ma
Enclosures (2)
Copy to: British Columbia Utilities Commission Attention: Erica Hamilton commission [email protected]
Mandatory Reliability Standards (MRS) Assessment Report No. 5
Compliance with BCUC Order No. R-54-12 Directive 5
Attachment 1
BC Hydro MRS Assessment Report No. 5 April 19, 2012
and Errata No. 1 – May 3, 2012
British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3
www.bchydro.com
Janet Fraser
Chief Regulatory Officer Phone: 604-623-4046 Fax: 604-623-4407 [email protected] May 3, 2012 Ms. Alanna Gillis Acting Commission Secretary British Columbia Utilities Commission Sixth Floor – 900 Howe Street Vancouver, BC V6Z 2N3 Dear Ms. Gillis: RE: British Columbia Utilities Commission (BCUC)
British Columbia Hydro and Power Authority (BC Hydro) Mandatory Reliability Standards (MRS) Assessment Report No. 5 Errata to Table 3
BC Hydro is writing to the BCUC to provide a correction to its MRS Assessment Report No. 5 (Report) dated April 2012 that was submitted to the BCUC on April 19, 2012. In the attached revised report pages, BC Hydro has corrected and clarified entries that were made within Table 3 of the Report. These relate to BC Hydro’s final assessment of the adverse impacts and suitability of standards assessed in the Report. The corrections and clarification are in response to comments provided to BC Hydro, with copy to the BCUC, from Shell Energy North America (Canada) Inc./Shell Energy North America (U.S.) L.P. (together Shell Energy) by email on April 20, 2012 following the filing and distribution of the Report. Specifically, Shell is concerned that its comments regarding the suitability of certain requirements contained in standards EOP-005-3a, TOP-005-2a and VAR-001-2 were not fully addressed in the Report. Although BC Hydro had considered stakeholders’ perspectives, including Shell’s in reaching its final assessment of these and all the other standards included in the Report, the details provided in Table 3 were not clear in this regard which have led to the revisions noted above.
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May 3, 2012 Ms. Alanna Gillis Acting Commission Secretary British Columbia Utilities Commission Mandatory Reliability Standards (MRS) Assessment Report No. 5 Errata to Table 3 Page 2 of 2
For further information, please contact Sandra Jones at 604-623-4315 or by e-mail at [email protected]. Yours sincerely,
Janet Fraser Chief Regulatory Officer ch/ma Enclosure (1) Copy to:
[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
MRS Assessment Report No. 5 Compliance with BCUC Order No. R-54-12 Directive 5
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Mandatory Reliability Standards (MRS) Assessment Report No. 5
Page 1
Mandatory Reliability Standards (MRS) Assessment Report No. 5 Errata No. 1 – May 3, 2012
From the Original MRS Assessment Report No. 5 dated April 19, 2012:
REMOVE INSERT
Pages 20 to 22 Pages 20 to 22 Revision 1 – May 2, 2012
MRS Assessment Report No. 5 Compliance with BCUC Order No. R-54-12 Directive 5
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British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3
www.bchydro.com
Janet Fraser
Chief Regulatory Officer Phone: 604-623-4046 Fax: 604-623-4407 [email protected] April 19, 2012 Ms. Alanna Gillis Acting Commission Secretary British Columbia Utilities Commission Sixth Floor – 900 Howe Street Vancouver, BC V6Z 2N3 Dear Ms. Gillis: RE: British Columbia Utilities Commission (BCUC)
British Columbia Hydro and Power Authority (BC Hydro) Mandatory Reliability Standards (MRS) Assessment Report No. 5
BC Hydro is writing to the BCUC to provide its MRS Assessment Report No. 5 (Report) dated March 2012, pursuant to section 125.2(3) of the Utilities Commission Act (UCA). BC Hydro is providing an electronic copy of the Report to parties involved in consultation for the purpose of preparing the Report. Overview of Report The Report covers the reporting period of December 1, 2010 to November 30, 2011 and presents the reliability impacts, suitability, and potential costs of adopting three new reliability standards, seven replacement reliability standards and 21 revised reliability standards (three of which were revised twice during the reporting period), for the bulk electric system in British Columbia (B.C.). BC Hydro has included a proposed process for the BCUC’s adoption of the standards assessed in the Report. Appendix D of the Report includes a draft order and a table summary of the new, replacement and revised standards that would be in force in B.C. if the BCUC adopts all of the standards assessed in the Report. The draft order also includes BC Hydro’s recommendations for effective dates of the new, replacement and revised standards. Additional Comments BC Hydro would like to take this opportunity to comment on the adoption without prior assessment by BC Hydro of the following provisions:
the NERC Glossary of Terms (August 4, 2011 version); and
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April 19, 2012 Ms. Alanna Gillis Acting Commission Secretary British Columbia Utilities Commission Mandatory Reliability Standards (MRS) Assessment Report No. 5 Page 2 of 3
the Compliance Provisions, as defined by the Rules of Procedure for Reliability Standards in British Columbia, that accompany each of the adopted British Columbia reliability standards.
BC Hydro has not assessed the reliability impacts, suitability, and potential cost of these provisions, or made recommendations regarding their approval. Additional detail with respect to each circumstance is provided below. NERC Glossary of Terms BC Hydro assessed the April 20, 2010 version of the NERC Glossary of Terms in Assessment Report No. 3. The BCUC subsequently adopted the August 4, 2011 version of the Glossary (which had not been assessed by BC Hydro), in Order No. G-162-11 dated September 1, 2011. BC Hydro subsequently reviewed the August 4, 2011 version of the Glossary and determined that, in this particular case, there were likely no material impacts to BC Hydro or other MRS registered entities in B.C. related to its adoption. However, BC Hydro is of the view that changes in Glossary terms have the potential to materially impact reliability, suitability and potential cost aspects of adopted standards. In addition, adoption of certain definitions (e.g., the revised definition of the bulk electric system that has been proposed by NERC), could create seams issues in B.C. (e.g., if the exclusion provisions of the NERC rules of procedure are not also incorporated). BC Hydro therefore respectfully requests that only versions of the Glossary that have been included in the assessment reports be considered for adoption. Compliance Provisions The analytical approach taken to evaluate reliability standards has not changed from that used in previous MRS assessment reports. In those reports, it was determined that the compliance-related provisions included in the NERC and WECC reliability standards were not applicable to the meaning of “reliability standards” defined in section 125.2 of the UCA. As a result, BC Hydro has never assessed the compliance-related provisions that accompany the reliability standards that are assessed in the MRS assessment reports. Accordingly, a strike-through of Section D – Compliance – for each standard included in the Report has been performed. The BCUC has endorsed this analytical approach by separately adopting the Compliance Provisions, as defined by the Rules of Procedure for Reliability Standards in B.C., that accompany each of the adopted B.C. reliability standards. However, on the WECC website, there is no strike-through of Section D – Compliance – for each standard that is posted. BC Hydro is concerned that the absence of strike-through could lead to the erroneous impression that the Compliance Provisions have been assessed by BC Hydro, when they have not. BC Hydro respectfully requests that to avoid any confusion, the BCUC clarify that the Compliance Provisions have not been assessed by BC Hydro by directing WECC to either:
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April 19, 2012 Ms. Alanna Gillis Acting Commission Secretary British Columbia Utilities Commission Mandatory Reliability Standards (MRS) Assessment Report No. 5 Page 3 of 3
(1) retain the strike-through of the Compliance Provisions in respect of the standards that have been assessed and adopted in B.C.; or
(2) include an explanation on the WECC website that the compliance-related provisions found in Section D – Compliance that accompany each standard have not been assessed by BC Hydro.
For further information, please contact Sandra Jones at 604-623-4315 or by e-mail at [email protected]. Yours sincerely,
Janet Fraser Chief Regulatory Officer ch/ma Enclosure (1) Copy to: [email protected]; [email protected]; [email protected];
[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
MRS Assessment Report No. 5 Compliance with BCUC Order No. R-54-12 Directive 5
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Mandatory Reliability Standards (MRS) Assessment Report No. 5
April 2012
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Table of Contents
1 Introduction ........................................................................................................ 1 1.1 Purpose of Report ..................................................................................... 1 1.2 Summary ................................................................................................... 2 1.3 Contents of the Report .............................................................................. 4 1.4 Proposed Process ..................................................................................... 5
2 Standards Assessment Process used in the Report .......................................... 6 2.1 Identification of Standards for Review and Inclusion in MRS
Assessment Report No. 5 ......................................................................... 6 2.2 Consultation .............................................................................................. 7
3 Assessment of Individual Standards .................................................................. 9 3.1 Analytical Approach to Assessment of Reliability Impact, Suitability
and Cost of Adoption ............................................................................... 10 3.1.1 Analytical Approach in Assessing Adverse Reliability
Impacts ..................................................................................... 10 3.1.2 Analytical Approach for the Suitability Assessment .................. 11 3.1.3 Analytical Approach for the Cost Assessment .......................... 11
3.2 Initial Screening of the Standards for Adverse Reliability Impacts and Suitability ................................................................................................. 12
3.3 Summary of Final Assessment of the Standards Assessed in the Report ..................................................................................................... 19
4 NERC Glossary of Terms and NERC Functional Model ................................... 22 5 Future Assessment Reports ............................................................................. 23 6 Conclusions ...................................................................................................... 24
List of Tables
Table 1 B.C. MRS Program Registered Entity List .......................................... 8 Table 2 Initial Screening for Adverse Reliability Impact and Suitability ......... 13 Table 3 Final Assessment Summary ............................................................. 20
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List of Appendices
Appendix A-1 List of Standards to be Assessed, FERC Approval and Effective Date Appendix A-2 NERC and WECC Standards Assessed by BC Hydro Appendix B NERC Glossary of Terms Used in Reliability Standards, Updated
December 13, 2011 Appendix C Consultation Materials Appendix D Draft Order
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1 Introduction
1.1 Purpose of Report
Pursuant to the requirements of section 125.2(3) of the Utilities Commission Act (the
UCA), British Columbia Hydro and Power Authority (BC Hydro) provides this
Mandatory Reliability Standards (MRS) Assessment Report No. 5 (the Report) to the
British Columbia Utilities Commission (BCUC) regarding the reliability impacts,
suitability, and potential costs of adopting three new standards, seven replacement
standards and 21 revised reliability standards, for the bulk electric system in British
Columbia (B.C.).
The three new reliability standards assessed in the Report are North American
Electric Reliability Corporation (NERC) standards that relate to interconnection
reliability operations and coordination.
The seven replacement reliability standards assessed in the Report consist of one
NERC standard, and six Western Electricity Coordinating Council (WECC)
standards developed for the Western Interconnection. The seven replacement
standards entirely supersede eight BCUC approved reliability standards adopted in
B.C. by Order No. G-67-09. Specifically, one of the six WECC standards
supersedes two BCUC approved standards; and the NERC replacement standard
supersedes one BCUC approved standard in its entirety, and certain requirements
of another BCUC approved standard, both on a staged basis.
The 21 revised reliability standards, three of which have been revised twice during
the Assessment Period, are revisions to 21 BCUC approved reliability standards
adopted in B.C. by Orders No. G-67-09, G-167-10 and G-162-11. The final
versions of the 21 revised standards assessed in the Report entirely supersede
21 existing BCUC approved standards. The revisions contained in the interim
versions of the three twice revised standards are entirely contained within the final
versions of the standards. For these standards, BC Hydro has reviewed the overall
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revision to the approved reliability standards and has not assessed the interim
versions separately.
All 31 standards assessed in the Report have been approved by the United States
(U.S.) Federal Energy Regulatory Commission (FERC), and became enforceable in the
U.S. during the period covered by this Report – December 1, 2010 to November 30,
2011 (the Assessment Period).
The Draft Order attached to the Report as Appendix D identifies the 31 standards that
would be in force in B.C., should the BCUC adopt the three new standards,
seven replacement standards, and final versions of the 21 revised standards assessed
in the Report.
The Draft Order also includes a table that lists: the three new standards; the seven
replacement standards; the final versions of the 21 revised standards; the interim
versions of the three twice-revised standards; and the 29 BCUC approved standards
being superseded by the replacement or revised standards assessed in the Report. In
addition, in order to provide registered entities sufficient time to adjust business
processes to achieve and maintain compliance, the table includes recommended
effective dates for each of the 31 standards assessed in the Report.
NERC and WECC are continuously developing new and revised standards. Pursuant to
section 125.2(3) of the UCA, BC Hydro has an ongoing obligation to report on NERC
and WECC reliability standards once they are adopted by FERC and become
enforceable in the U.S. As outlined in the previous MRS Assessment Reports, any
NERC or WECC standard adopted by FERC and becoming enforceable in the U.S.
within an annual assessment period of December 1 to November 30 of the following
year will be reported on by BC Hydro in its annual MRS Assessment Report.
1.2 Summary
Using the same methodology that was employed in previous MRS Assessment Reports,
BC Hydro has concluded that the standards assessed in the Report will preserve or
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enhance the reliability of the bulk electric system in B.C., and thus are in the public
interest and are suitable for adoption in B.C.
BC Hydro has assessed its estimated incremental one-time and ongoing annual costs
of achieving and maintaining compliance with the adoption of the 31 reliability standards
assessed in the Report as mandatory in B.C.
Consistent with the approach taken in previous MRS Assessment Reports, BC Hydro
has sought input from B.C. MRS registered entities regarding their estimated
incremental one-time and annual ongoing costs associated with achieving and
maintaining compliance with the 31 standards assessed in the Report, provided that the
registered entities were not otherwise subject to equivalent requirements by virtue of
pre-existing reliability obligations.1
A complete list of the registered entities with whom BC Hydro consulted is provided in
Table 1, section 2.2 of the Report. A detailed breakdown of the estimated incremental
one-time and ongoing costs reported by BC Hydro and the registered entities is
provided in Table 3, section 3.3 of the Report. Registered entities’ responses are
reproduced in full in Appendix C.
On the basis of BC Hydro’s own assessment and the responses received from those
registered entities providing cost estimates, BC Hydro estimates that the cumulative
cost for B.C. registered entities to achieve and maintain compliance with the
31 reliability standards assessed in the Report will be in the order of $1,634,000 with
respect to one-time costs, and $95,000 in costs on an annual ongoing basis:
BC Hydro reported estimated incremental one-time costs of $1,000 and minimal
annual ongoing costs;
1 BC Hydro has adopted the assumption used in previous MRS Assessment Reports; namely that costs associated
with achieving compliance with requirements currently in place in B.C. ought to be excluded, as they are attributable to an existing compliance gap as opposed to adopting the NERC and WECC standards as mandatory in B.C.
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Catalyst Paper Corporation (Catalyst) (Crofton, Elk Falls, Port Alberni, and Powell
River Divisions) reported estimated incremental one-time costs of up to $1,060,000
depending on the extent to which Critical Cyber Asset (CCA) reliability standards
are applicable to Catalyst, and $70,000 annual ongoing costs;
FortisBC reported estimated incremental one-time costs of $570,000 and $25,000
annual ongoing costs; and
Powell River Energy Inc. (PREI) reported estimated incremental one-time costs of
$3,000 and $0 annual ongoing costs.
While not insignificant, BC Hydro is of the view that these expenditures are necessary,
given that the major portion of the costs incurred relate to identifying CCAs associated
with the Critical Assets that support the reliable operation of the bulk electric system.
BC Hydro recommends the adoption of the standards assessed in this report.
1.3 Contents of the Report
The Report is organized as follows:
Section 2 explains BC Hydro’s standards assessment process, including its consultation
with stakeholders.
Section 3 summarizes BC Hydro’s analytical approach to assessing reliability standards
and the results of that assessment in the case of the 31 standards considered.
Section 4 describes how BC Hydro will proceed with the assessment of future reliability
standards.
The Appendices to the Report are as follows:
Appendix A-1 List of Standards Assessed, FERC Approval and Effective Date
Appendix A-2 NERC and WECC Standards Assessed by BC Hydro
Appendix B NERC Glossary of Terms used in Reliability Standards, Updated
December 13, 2011
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Appendix C Consultation Materials
Appendix D Draft Order
1.4 Proposed Process
This is the fifth MRS Assessment Report to be submitted to the BCUC. The BCUC is
obligated by section 125.2(5) of the UCA to make the Report publicly available and to
consider any comments it receives in respect of the Report.
BC Hydro would shortly thereafter respond to any comments. The BCUC would then
determine whether all the issues raised in the comment process had been dealt with to
its satisfaction. If so, no further process would be required. If not, then a written process
could be established to deal with any outstanding issues. Upon completion of the
process, the BCUC would determine whether the standards assessed in the Report
should be adopted in B.C.
With respect to the approval for adoption in B.C. of the replacement standards and final
versions of the revised standards, in order to avoid duplication BC Hydro suggests that
the BCUC approved standards being superseded by replacement or revised standards
be ordered to remain in effect until superseded on the recommended effective dates by
the corresponding replacement standard or final version of the revised standard
assessed in the Report.
The following is suggested specifically with respect to the adoption of replacement
standard PER-005-1 and revised standard PER-004-2:
PER-005-1: BCUC approved standard PER-002-0, and BCUC approved standard
PER-004-1 Requirements 2, 3 and 4, be ordered to remain in effect until
superseded in stages by replacement standard PER-005-1.
PER-004-2: BCUC approved standard PER-004-1 Requirements 1 and 5 be
ordered to remain in effect until superseded by revised standard PER-004-2.
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With respect to the three revised standards with interim versions, BC Hydro proposes
that an appropriate process to follow in these circumstances would be for the BCUC to
adopt and simultaneously order that the interim versions of these standards shall not
become effective, being superseded by the final versions of these revised standards.
This process is essentially the same as that which was followed for the eight
twice-revised CIP standards covered by MRS Assessment Report No. 3.
2 Standards Assessment Process used in the Report
2.1 Identification of Standards for Review and Inclusion in MRS Assessment Report No. 5
There is often a lapse in time between the date upon which a NERC or WECC standard
is approved by FERC and the effective date upon which the standard becomes
mandatory and enforceable under U.S. law. BC Hydro is required under the MRS
Regulation to report on a reliability standard within one year of the date the reliability
standard is “adopted by the regulatory body [i.e., FERC] with jurisdiction over the
standard-making body that established the regulatory standard”. The approach that was
taken in previous MRS Assessment Reports and will be used for this Report is to
interpret “adopted” in the MRS Regulation as meaning those standards that are FERC
approved, mandatory and enforceable under U.S. law during the Assessment Period.
In this Report, BC Hydro is assessing a total of 31 reliability standards that became
enforceable in the U.S. during the Assessment Period: three new standards, seven
replacement standards, and 21 revised standards. With respect to the interim versions
of the three twice revised standards, BC Hydro is recommending in the Draft Order
(refer to Appendix D) that the interim versions be adopted but not become effective,
being superseded by the final version of the standards (which are asterisked in
Attachment A to Appendix D).
A list of all of the standards assessed in the Report (including the interim versions of the
three twice-revised standards) is provided in Appendix A-1, and includes a reference to
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the FERC Order approving them, along with the date of the Order; and the effective
date on which the standard became enforceable in the U.S.
Appendix A-2 includes a summary of the NERC version history for the standards that
are assessed in this Report, and for the interim versions of the three twice revised
standards, as well as clean and black-lined copies of the new, replacement and revised
standards. The black-lined copies of the three twice-revised standards include the
changes contained in both the interim versions and final versions of these standards.
For this Report, BC Hydro has designated the cut-off date for the Assessment Period as
November 30, 2011. This cut-off is required to allow time for BC Hydro to assess the
standards identified in the Report and consult with stakeholders regarding any impacts
to them in achieving compliance with those standards. This same approach was used in
previous MRS Assessment Reports.
2.2 Consultation
BC Hydro consulted with the registered entities listed below in Table 1. These
registered entities include independent power producers (IPPs), industrial generators,
transmission voltage customers, marketers and municipal distribution utilities, based on
the BCUC registered entity list dated January 18, 2012.
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Table 1 B.C. MRS Program Registered Entity List
Bear Mountain Wind Limited Partnership Powerex Corp.
British Columbia Hydro and Power Authority Prince George Pulp & Paper Mill
Cariboo Pulp & Paper Company Rio Tinto Alcan
Catalyst Paper ‐ Crofton Division Shell Energy North America (Canada) Inc.
Catalyst Paper ‐ Elk Falls Division Shell Energy North America (US) L.P.
Catalyst Paper ‐ Port Alberni Division Teck Metals Ltd
Catalyst Paper ‐ Powell River Division Tembec CRS - Skookumchuk
Cloudworks Energy Inc. Tembec LAP – Chetwynd
Clowhom Power L.P. Terasen Gas Inc.
Dokie General Partnership Dowland Industrial Works Ltd.
Domtar Kamloops Toba Montrose General Partnership
FortisBC Inc. Tolko Industries Limited
FortisBC Energy Inc. TransAlta Energy Marketing Corp
Intercontinental Pulp Mill TransCanada Energy Sales Ltd.
Northwood Pulp Mill V.I. Power Limited Partnership
Powell River Energy Inc. Zeballos Lake Hydro Limited Partnership
Each registered entity on the list was sent a letter and a survey form on
January 18, 2012 (refer to Appendix C). Entities were asked to complete and return the
survey form to BC Hydro by February 10, 2012. The entities were asked to provide
information for each standard as follows:
(a) Develop and describe a list of incremental activities required to reach compliance.
(b) For each incremental activity, assign incremental estimated costs and state the
assumptions used in developing this estimate. Only consider the following costs:
Activities where a one‐time capital cost will incur (e.g., for the purchase of new
assets);
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Activities where a one‐time cost will incur for external assistance (e.g.,
consulting services) to reach compliance; and
Activities where there are exceptional ongoing annual costs associated with
compliance (e.g., compliance would require the hiring of additional staff or
similar resources).
(c) Include an assessment of the amount of time reasonably required to come into
compliance with the standard once adopted by the BCUC.
Including BC Hydro, a total of 32 registered entities were contacted, and 15 responses
were received. Catalyst Paper Corporation’s Crofton, Elk Falls, Port Alberni, and Powell
River Divisions provided a single consolidated survey response, as did Shell Energy
North America (Canada) Inc. and Shell Energy North America (U.S.) LP. Powerex
Corp.’s response has been consolidated with BC Hydro’s comments. Registered
entities’ responses are attached in full in Appendix C.
3 Assessment of Individual Standards
As noted previously, the three new, seven replacement and 21 revised standards, are
provided in Appendix A-2.2 BC Hydro has assessed these reliability standards against
the criteria stipulated by legislation in B.C. (section 125.2(3) of the UCA).
Section 3.1 summarizes BC Hydro’s approach to addressing these criteria. Section 3.2
provides a description of each standard that is assessed and an explanation of the
reliability and suitability issues along with BC Hydro’s conclusions. Section 3.3
addresses the cost assessment and summarizes BC Hydro’s final assessment of all the
standards considered in the Report.
2 Appendix A-2 also includes the interim versions of the three twice-revised standards, which have not been
separately assessed.
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3.1 Analytical Approach to Assessment of Reliability Impact, Suitability and Cost of Adoption
The analytical approach taken to evaluate reliability standards identified in the Report
against the legislated assessment criteria has not changed from that used in previous
MRS Assessment Reports. In those reports, it was determined that the
compliance-related provisions included in the NERC and WECC reliability standards are
not applicable to the meaning of “reliability standards” defined in section 125.2 of the
UCA. As a result, BC Hydro did not assess the compliance-related provisions
associated with the NERC reliability standards that are being assessed in the Report.
Accordingly, a strike-through of Section D – Compliance – for each standard included in
Appendix A-2 has been performed.
In addition, BC Hydro is of the opinion that the effective dates stated in the standards
included in the NERC and WECC reliability standards are likewise not applicable.
Accordingly, a strike-through of Section A.5 – Effective Date – for each standard
included in Appendix A-2 has been performed.
3.1.1 Analytical Approach in Assessing Adverse Reliability Impacts
BC Hydro has used the same approach in assessing adverse reliability impacts that
was used in prior MRS Assessment Reports. This approach relies on a determination
that those NERC and WECC standards that have either (i) performance requirements
that are not currently employed in B.C., or (ii) requirements as stringent as, or more
stringent, than requirements or practices currently employed in B.C. that will, by
definition, have neutral or positive impacts on the reliability of the bulk electric system in
B.C. Consequently, BC Hydro’s approach is to identify performance requirements
associated with new, or revisions to, NERC and WECC reliability standards that are less
stringent than the existing reliability standards already adopted in B.C., or practices
otherwise mandated in utility tariffs or Business Practices approved or endorsed by the
BCUC.
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3.1.2 Analytical Approach for the Suitability Assessment
The Report uses the same criteria to assess the suitability of new, replacement and
revised reliability standards that were developed for the previous MRS Assessment
Reports. The two criteria used for this analysis are set out below:
(a) "Administrative suitability" means that the requirements in the standard are fit and
appropriate for implementation in light of the policy and regulatory framework in
B.C. The requirements can be implemented without requiring the ongoing
involvement of NERC, the U.S. Government, or other extra‐jurisdictional entities in
such a manner as would impair the operation and enforcement of the requirement
in B.C. If one or more of the requirements in the standard incorporate by reference
reliability standards not yet adopted in other jurisdictions, the remaining
requirements in the standard can still be implemented presently in B.C. without
giving effect to the particular requirement(s) containing the cross reference.
(b) "Technical suitability" means that the requirements in the standard are fit and
appropriate for implementation in B.C., taking into consideration the unique
geographical, structural, design, and functional aspects of the B.C. bulk electric
system and the assets that support the reliable operation of this system.
3.1.3 Analytical Approach for the Cost Assessment
BC Hydro’s approach to assess the potential costs of the new, replacement and revised
reliability standards in the Report is consistent with the approach used to assess
standards in previous MRS Assessment Reports. The objective is to provide an
estimate of the costs of adopting NERC and WECC reliability standards in B.C.
sufficient to inform the BCUC’s public interest assessment. Accordingly, only the costs
that B.C. entities will potentially incur in order to achieve full compliance with the
standards were assessed. Any costs associated with B.C. entities attaining compliance
with pre-existing reliability requirements in B.C. were excluded.
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3.2 Initial Screening of the Standards for Adverse Reliability Impacts and Suitability
In terms of the assessment of the standards against the reliability and suitability criteria,
BC Hydro first performed an initial screening of the three new standards, seven
replacement standards, 21 revised standards, and the interim versions of the three
twice-revised standards, against the criteria described in section 3.1 to identify issues
for further examination. This initial screening does not purport to be BC Hydro’s
eventual assessment of the new, replacement and revised standards.
The results of BC Hydro’s initial screening of the standards for potential issues
regarding adverse reliability impacts and suitability are summarized below in Table 2,
which includes:
the “Standard” column, which identifies all 31 standards assessed in the Report
and the interim versions of the three twice-revised standards;
the “Adverse Impact” column, which identifies potential issues relating to adverse
reliability impact (of which there were none reported); and
the “Changed from BCUC Approved Standard” column, which identifies potential
suitability issues related to the replacement or revised standards superseding
approved BCUC standards.
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Table 2 Initial Screening for Adverse Reliability Impact and Suitability
Standard Adverse Impact
Suitability Issues
Requires NERC Approval/ Participation
Requires Provisions of Information to NERC or WECC
Refers to Standard not yet FERC Approved
Other Suitability Issues
Changed from BCUC Approved
Standard To NERC To WECC
BAL-006-2 No No No No No No Yes
CIP-001-1a 1 No No No No No No Yes
CIP-001-2a No No No No No No Yes
CIP-005-3a No No No No No No Yes
EOP-002-3 No No No No No No Yes
FAC-002-1 No No No No No No Yes
FAC-501-WECC-1 No No No No No No Yes1
INT-003-3 No No No No No No Yes
IRO-002-2 No No No No No No Yes
IRO-004-2 No No No No No No Yes
IRO-005-2a 1 No No No No No No Yes
IRO-005-3a No No No No No No Yes
IRO-006-5 No No No No No No Yes
IRO-006-WECC-1 No No No No No No Yes2
IRO-008-1 No No No No No No No
IRO-009-1 No No No No No No No
IRO-010-1a No No No No No No No
MOD-021-1 No No No No No No Yes
PER-004-2 No No No No No No Yes
PER-005-1 No No No No No No Yes3
PRC-004-1a No No No No Yes4
(PRC-003-1)
No Yes
PRC-005-1a No No No No No No Yes
PRC-004-WECC-1 No No No No No No Yes2
TOP-001-1a No No No No No No Yes
TOP-002-2b No No No No No No Yes
TOP-003-1 No No No No No No Yes
TOP-005-1.1a 1 No No No No Yes4 No Yes
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Standard Adverse Impact
Suitability Issues
Requires NERC Approval/ Participation
Requires Provisions of Information to NERC or WECC
Refers to Standard not yet FERC Approved
Other Suitability Issues
Changed from BCUC Approved
Standard To NERC To WECC
(PRC-012-0)
TOP-005-2a No No No No Yes4
(PRC-012-0) No
Yes
TOP-006-2 No No No No No No Yes
TOP-007-WECC-1 No No No No No No Yes2
TPL-002-0b No No No No No No Yes
VAR-001-2 No No No No No No Yes
VAR-002-WECC-1 No No No No No No Yes2
VAR-501-WECC-1 No No No No No No Yes2
1. Indicates an interim version. 2. Indicates a replacement standard. 3. Standard PER-005-1 supersedes BCUC Approved Standard PER-002-0 in its entirety and Requirements 2, 3
and 4 of BCUC Approved Standard PER-004-1. 4. Individual Requirements within standards that incorporate by reference standards, that have not been assessed
by BC Hydro and adopted by the BCUC, should be of no force or effect.
Described in more detail below are the new, replacement and revised standards
assessed in the Report.
New Standards:
The new Standard IRO-008-1 - Reliability Coordinator Operational Analyses and
Real-time Assessments - deals with the prevention of instability, uncontrolled
separation, or cascading outages that adversely impact the reliability of the
interconnection by ensuring that the bulk electric system is assessed during the
operations horizon.
The new Standard IRO-009-1 - Reliability Coordinator Actions to Operate Within
Interconnection Reliability Operating Limits (IROL) - deals with the prevention of
instability, uncontrolled separation, or cascading outages that adversely impact the
reliability of the interconnection by ensuring prompt action to prevent or mitigate
instances of exceeding interconnection reliability operating limits.
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The new Standard IRO-010-1a - Reliability Coordinator Data Specification and
Collection - deals with the prevention of instability, uncontrolled separation, or
cascading outages that adversely impact the reliability of the interconnection by
ensuring the reliability coordinator has the data it needs to monitor and assess the
operation of its reliability coordinator area.
Replacement Standards:
The replacement standard PER-005-1 - System Personnel Training - deals with
ensuring that System Operators performing real-time, reliability-related tasks on
the North American bulk electric system are competent to perform those reliability-
related tasks. It supersedes, on a staged basis, Requirements 2, 3 and 4 of BCUC
approved standard PER-004-1 (which deals with Reliability Coordination Staffing)3;
and BCUC approved standard PER-002-0 (which deals with Operating Personnel
Credentials) in its entirety, as follows:
PER-005-1 Requirements 1 and 2 supersede:
PER-004-1 Requirements 3 and 4; and
PER-002-0 Requirements 1, 2 and 3.
PER-005-1 Requirement 3 supersedes:
PER-004-1 Requirement 2; and
PER-002-0 Requirement 4
The replacement standard FAC-501-WECC-1 - Transmission Maintenance -
supersedes BCUC approved standard PRC-STD-005-1 and deals with
maintenance and inspection planning and documentation for major WECC transfer
paths in the bulk electric system.
The replacement standard IRO-006-WECC-1 - Qualified Transfer Path
Unscheduled Flow (USF) Relief - supersedes BCUC approved standard IRO-STD-
3 PER-004-1 Requirements 1 and 5 are superseded by PER-004-2.
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006-0 and deals with the mitigation of transmission overloads due to unscheduled
line flow on qualified transfer paths.
The replacement standard PRC-004-WECC-1 - Protection System and Remedial
Action Scheme Misoperation - supersedes two BCUC approved standards –
PRC-STD-001-1 and PRC-STD-003-1 – and deals with the analysis and mitigation
of misoperations and remedial action schemes for transmission and generation
protection systems.
The replacement standard TOP-007-WECC-1 - System Operating Limits -
supersedes BCUC approved standard TOP-STD-007-0 and deals with time limits
for when actual flows on Major WECC transfer paths exceed system operating
limits.
The replacement standard VAR-002-WECC-1 - Automatic Voltage Regulators
(AVR) - supersedes BCUC approved standard VAR-STD-002a-1 and deals with
ensuring that automatic voltage regulators on synchronous generators and
condensers are kept in service and controlling voltage.
The replacement standard VAR-501-WECC-1 - Power System Stabilizer (PSS) -
supersedes BCUC approved standard VAR-STD-002b-1 and deals with ensuring
that power system stabilizers on synchronous generators are kept in service.
Revised Standards
The revised standard BAL-006-2 supersedes BCUC approved standard
BAL-006-1.1 and deals with Inadvertent Interchange.
The revised standard CIP-001-2a supersedes BCUC approved standard
CIP-001-1, dealing with Sabotage Reporting. Revisions contained in CIP-001-1a,
the interim version of this standard are included in the assessment of CIP-001-2a.
The revised standard CIP-005-3a supersedes BCUC approved standard CIP-005-3
and deals with Cyber Security — Electronic Security Perimeter(s).
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The revised standard EOP-002-3 supersedes BCUC approved standard
EOP-002-2.1 and deals with Capacity and Energy Emergencies.
The revised standard FAC-002-1 supersedes BCUC approved standard
FAC-002-0 and deals with Coordination of Plans for New Generation,
Transmission, and End-User.
The revised standard INT-003-3 supersedes BCUC approved standard INT-003-2
and deals with Interchange Transaction Implementation.
The revised standard IRO-002-2 supersedes BCUC approved standard IRO-002-1
and deals with Reliability Coordination — Facilities.
The revised standard IRO-004-2 supersedes BCUC approved standard IRO-004-1
and deals with Reliability Coordination — Operations Planning.
The revised standard IRO-005-3a supersedes BCUC approved standard
IRO-005-2, dealing with Reliability Coordination — Current Day Operations.
Revisions contained in IRO-005-2a, the interim version of this standard are
included in the assessment of IRO-005-3a.
The revised standard IRO-006-5 supersedes BCUC approved standard
IRO-006-4.1 and deals with Reliability Coordination — Transmission Loading
Relief (TLR).
The revised standard MOD-021-1 supersedes BCUC approved standard
MOD-021-0.1 and deals with Documentation of the Accounting Methodology for
the Effects of Demand-Side Management in Demand and Energy Forecasts.
The revised standard PER-004-2 supersedes BCUC approved standard
PER-004-1 Requirements 1 and 5, and deals with Reliability Coordination —
Staffing.4
4 PER-004-1 Requirements 2, 3 and 4 are superseded by PER-005-1.
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The revised standard PRC-004-1a supersedes BCUC approved standard
PRC-004-1 and deals with Analysis and Mitigation of Transmission and Generation
Protection System Misoperations.
The revised standard PRC-005-1a supersedes BCUC approved standard
PRC-005-1 and deals with Transmission and Generation Protection System
Maintenance and Testing.
The revised standard TOP-001-1a supersedes BCUC approved standard
TOP-001-1 and deals with Reliability Responsibilities and Authorities.
The revised standard TOP-002-2b supersedes BCUC approved standard
TOP-002-2a and deals with Normal Operations Planning.
The revised standard TOP-003-1 supersedes BCUC approved standard
TOP-003-0 and deals with Planned Outage Coordination.
The revised standard TOP-005-2a supersedes BCUC approved standard
TOP-005-1.1, dealing with Operational Reliability Information. Revisions contained
in TOP-005-1.1a, the interim version of this standard are included in the
assessment of TOP-005-2a.
The revised standard TOP-006-2 supersedes BCUC approved standard
TOP-006-1 and deals with Monitoring System Conditions.
The revised standard TPL-002-0b supersedes BCUC approved standard
TPL-002-0a and deals with System Performance Following Loss of a Single Bulk
Electric System Element (Category B).
The revised standard VAR-001-2 supersedes BCUC approved standard
VAR-001-1 and deals with Voltage and Reactive Control.
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3.3 Summary of Final Assessment of the Standards Assessed in the Report
BC Hydro’s final assessment of the 31 standards assessed in the Report, based on
internal and external B.C. responses from registered entities, is summarized below in
Table 3, which includes:
BC Hydro’s final assessment as to whether the adoption of the 31 standards
assessed in the Report will give rise to adverse reliability consequences;
BC Hydro’s final assessment as to the suitability of the 31 standards assessed in
the Report, based on the criteria described in section 3.1.2;
BC Hydro’s and registered entities’ estimated incremental one-time and ongoing
annual costs to achieve and maintain compliance associated with the 31 standards
assessed in the Report; and
BC Hydro’s recommended effective dates, based on comments made by
registered entities who responded to the stakeholder survey, for the 31 standards
assessed in the Report. BC Hydro recommends that these recommended effective
dates be adopted by the BCUC to replace Section A.5-Effective Date in each of the
standards listed in Table 3.
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Table 3 Final Assessment Summary
Standard Adverse Impact
Suitability Issues
One-time Cost ($)
Ongoing Cost ($/year)
Recommended Effective Date
BAL-006-2 No None reported
No None reported
None reported None reported
3 months after BCUC approval
CIP-001-2a * 1 No None reported
No None reported
None reported None reported Immediately after BCUC approval.
CIP-005-3a No None reported
No None reported
Catalyst Paper - $1,000,000 to implement an Electronic Security Perimeter (ESP) if CCAs are identified.
Catalyst Paper - $50,000 to implement an ESP if CCAs are identified.
6 months after BCUC approval
EOP-002-3 No None reported
No None reported
None reported None reported 6 months after BCUC approval
FAC-002-1 No None reported
No None reported
Catalyst Paper - $50,000 dependent on confirmation that the interconnection has been evaluated against TPL-002-0 and TPL-003-0 will need to be sought from Transmission Planner (BC Hydro).
None reported
6 months after BCUC
approval
FAC-501-WECC-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
INT-003-3 No None reported
No None reported
None reported None reported 3 months after BCUC approval
IRO-002-2 No None reported
No None reported
None reported None reported 3 months after BCUC approval
IRO-004-2 No None reported
No None reported
None reported None reported 3 months after BCUC
approval
IRO-005-3a *1 No None reported
No2 None reported.
None reported. None reported. 3 months after BCUC approval
IRO-006-5 No None reported
No None reported
None reported None reported 3 months after BCUC approval
IRO-006-WECC-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
IRO-008-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
IRO-009-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
IRO-010-1a No None reported
No None reported
BC Hydro -
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Standard Adverse Impact
Suitability Issues
One-time Cost ($)
Ongoing Cost ($/year)
Recommended Effective Date
MOD-021-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
PER-004-2 No None reported
No None reported
None reported None reported Immediately after BCUC approval.
PER-005-1 No None reported
No None reported
FortisBC - $170,000
FortisBC - $15,000
Catalyst Paper – $20,000. Would need to audit BC Hydro procedures as Catalyst does not "operate" transmission assets nor does it have "System Operators"
R1, R2 - 24 months after BCUC approval.
R3 - 18 months after BCUC approval.
R3.1 - 36 months after BCUC approval.
PRC-004-1a No None reported
No None reported
None reported None reported 3 months after BCUC approval
PRC-005-1a No None reported
No None reported
None reported None reported 3 months after BCUC approval
PRC-004-WECC-1 No None reported
No None reported
None reported None reported 6 months after BCUC approval.
TOP-001-1a No None reported
No None reported
None reported None reported Immediately after BCUC approval
TOP-002-2b No None reported
No None reported
None reported None reported Immediately after BCUC approval
TOP-003-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
TOP-005-2a * 1 No None reported
No3 None reported
None reported None reported 3 months after BCUC approval
TOP-006-2 No None reported
No None reported
None reported None reported 3 months after BCUC approval
TOP-007-WECC-1 No None reported
No None reported
None reported None reported 3 months after BCUC approval
TPL-002-0b No None reported
No None reported
None reported None reported Immediately after BCUC approval
VAR-001-2 No None reported
No4 None reported
None reported None reported 6 months after
BCUC approval
VAR-002-WECC-1
No None reported
No None reported
FortisBC - $400,000 in conjunction with VAR-501-WECC-1 due to Requirement 2
FortisBC - $10,000 in conjunction with VAR-501-WECC-1 due to Requirement 2
12 months after BCUC approval
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Standard Adverse Impact
Suitability Issues
One-time Cost ($)
Ongoing Cost ($/year)
Recommended Effective Date
VAR-501-WECC-1 No None reported
No None reported
FortisBC - $400,000 in conjunction with VAR-002-WECC-1 due to Requirement 2
FortisBC - $10,000 in conjunction with VAR-002-WECC-1 due to Requirement 2
3 months after BCUC approval
* Indicates final version of twice-revised standard. 1. Indicates final version of twice revised standard. 2. Shell Energy North America (Canada) Inc./Shell Energy North America (U.S.) L.P. (together Shell Energy) raised
suitability concerns (refer to Appendix C – Attachment C4-7 at page 2) however BC Hydro concluded that standard IRO-005-3a is suitable for adoption in B.C.
3. Shell Energy raised suitability concerns (refer to Appendix C – Attachment C4-7 at page 5) however BC Hydro concluded that standard TOP-005-2a is suitable for adoption in B.C.
4. Shell Energy raised suitability concerns (refer to Appendix C – Attachment C4-7 at page 5) however BC Hydro concluded that standard VAR-001-2 is suitable for adoption in B.C.
BC Hydro’s assessment is that all of the new, replacement and revised standards will either
maintain or promote the reliability of the bulk electric system in B.C.
The total cost required to adopt these reliability standards in B.C. is estimated to be $1,634,000
for their implementation, with ongoing annual costs of $95,000 to maintain compliance (both
cumulative). The cost estimates are those of the stakeholders and BC Hydro and are presented
in the Report without comment.
4 NERC Glossary of Terms and NERC Functional Model Past practice has been for the BCUC to adopt the NERC Glossary of Terms Used in Reliability
Standards (the NERC Glossary of Terms) in conjunction with reliability standards.
The April 20, 2010 version of the NERC Glossary of Terms was attached as Appendix B to MRS
Assessment Report No. 3, and as Appendix B to MRS Assessment Report No. 4. However, the
BCUC adopted the August 4, 2011 version of the Glossary of Terms by
BCUC Order No. G-162-11.
The three new standards, seven replacement standards and the final versions of the 21 revised
standards have been assessed by BC Hydro based on definitions contained in the the NERC
Glossary of Terms dated December 13, 2011. Consequently, the BCUC approved NERC
Glossary of Terms is out of date. BC Hydro is attaching the NERC Glossary of Terms dated as of
December 13, 2011, to this Report as Appendix B. As identified within the document, the
December 13, 2011 version of the NERC Glossary of Terms contains seventeen definitions that
have been adopted by NERC but have not been approved by FERC and hence are not effective
in the U.S.,
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and should not become effective in B.C., and six definitions that have been remanded
or retired.
The updated December 13, 2011 version of the NERC Glossary of Terms is integral to
the reliability standards, and should be adopted by the BCUC in conjunction with the
standards assessed in this Report in order to achieve and maintain consistency with
NERC standards going forward. Any definitions in the NERC Glossary of Terms that are
not approved by FERC should not become effective in B.C.
5 Future Assessment Reports
Consistent with the procedure adopted in prior MRS Assessment Reports, once new
reliability standards have been approved by FERC and become enforceable in the U.S.
(such that the standards are applicable in the Western Interconnection), BC Hydro will
conduct its assessment of those reliability standards as required by legislation. For
efficiency’s sake, BC Hydro will endeavour to batch standards for periodic assessment
reports, rather than submit a separate assessment report with the BCUC on each
standard as it is adopted in other jurisdictions. Should BC Hydro or the BCUC determine
that a particular standard is sufficiently critical to reliability that it warrants immediate
implementation, BC Hydro will file a standard-specific assessment report and not wait
until its next “batch” assessment report, as was the case for the standards assessed in
MRS Assessment Report No. 4 which supported BC Hydro’s application to amend
Attachment C of its Open Access Transmission Tariff.
Any updates or revisions to the NERC Glossary of Terms will be reported on in future
assessment reports. Specifically, the February 8, 2012 was issued after BC Hydro
consulted on the Report. This revision and any subsequent revisions to the NERC
Glossary of Terms will be reviewed in future MRS Assessment Reports as appropriate.
The February 8, 2012 version contains a revision to the term Protection System, and
the definition of Bulk Electric System is expected to be revised in a future version.
These revisions may have material impacts on the suitability, and potential costs of
adopting reliability standards in B.C.
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6 Conclusions
BC Hydro has assessed three new standards, seven replacement standards and final
versions of 21 revised standards, inclusive of interim versions where applicable, that
were developed by NERC and WECC and became effective in the U.S. during the
Assessment Period. BC Hydro has concluded that the standards assessed in the
Report will preserve or enhance the reliability of the bulk electric system in B.C., and
thus will serve the public interest and are suitable for adoption in B.C. based on the
criteria applied in the assessment of these standards. BC Hydro recommends that the
standards that have been assessed in the Report be adopted by the BCUC.
BC Hydro recommends that the three new standards, seven replacement standards and
the final versions of the 21 revised standards should have effective dates that are based
on the recommended effective dates included in Table 3, section 3.3.
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Mandatory Reliability Standards Assessment Report No. 5
Appendix
A-1
List of Standards Assessed, FERC Approval and Effective Date
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Rel
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Page 1 of 4
MRS Assessment Report No. 5 Compliance with BCUC Order No. R-54-12 Directive 5
Attachment 1
Page 35 of 534
Stan
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Doc
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D11
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MRS Assessment Report No. 5 Appendix A-1
Page 2 of 4
MRS Assessment Report No. 5 Compliance with BCUC Order No. R-54-12 Directive 5
Attachment 1
Page 36 of 534
Stan
dard
St
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A
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Doc
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D11
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tem
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Doc
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M09
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Ord
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51 -
Apr
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Doc
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TOP
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Info
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Doc
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M10
-15-
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Ord
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48 -
Mar
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TOP
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Mon
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RM
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748
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17,
201
1 01
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-11
Rev
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TO
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Doc
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M09
-14-
000;
Ord
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o. 7
52 -
Apr
il 21
, 201
1 01
-Jul
-11
Rep
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Doc
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M10
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Ord
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54 -
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MRS Assessment Report No. 5 Appendix A-1
Page 3 of 4
MRS Assessment Report No. 5 Compliance with BCUC Order No. R-54-12 Directive 5
Attachment 1
Page 37 of 534
Stan
dard
St
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A
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1 U
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