Frequently Asked Questions Alberta Reliability Standards Compliance Version 1.0 – Effective April...

Frequently Asked QuestionsAlberta Reliability Standards Compliance

Version 1.0 – Effective April 30, 2013(Please visit the website to download the latest version)

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Frequently Asked QuestionsAlberta Reliability Standards (ARS)Compliance

The purpose of this interactive presentation is to provide answers to frequently asked questions received by ARS Compliance. This main menu is meant to help you filter questions and answers by section. You can return to this main menu by clicking on the “MAIN”

button found in the bottom right corner of every page.

Please select the appropriate section by clicking on one of the blue buttons on the left below .

Questions and answers are updated frequently. Answers or clarifications are added to the appropriate guides as required and remove from this presentation.

Please download the latest presentation or appropriate guide by visiting our website at www.aeso.ca > COMPLIANCE.

If you cannot find the answer to your question in either this presentation or the appropriate guide, please email [email protected].

General / CMP

Registration

Self-Certification

Audits

RSAWs

FAQs related to the Compliance Monitoring Program (CMP).

Applicability Assessments

FAQs related to registering for the CMP and the Alberta Reliability Standards Registry.

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FAQs related to how you would self-assess applicability or how to request an applicability assessment.

FAQs related to the self-certification and the self-certification template.

FAQs related to compliance monitoring audits.

DDP FAQs related to the DDP (Designation of Documentation Provider) used to designate another entity to provide CMP documentation.

FAQs related to the use of Reliability Standards Audit Worksheets (RSAWs) and their use.

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Q1. What is the Compliance Monitoring Program (CMP)?

Q2. Who can provide assurances that I am compliant with a reliability standard?

Q3. Who determines whether a standard is applicable or not applicable to me?

Q4. Have the roles of the AESO and the Market Surveillance Administrator (MSA) been clearly defined?

Q5. As a registered market participant we receive a number of requests from the AESO from a variety of departments. Can someone at the AESO tell us all the requests that have been made of us in the past year and whether we have provided the information required?

General / Compliance Monitoring Program (CMP)

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General / Compliance Monitoring Program (CMP)Q1 of 5

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Q1. What is the CMP?





Answer:The Compliance Monitoring Program (or CMP) is the processes and procedures set up

by the AESO to monitor market participant compliance to Alberta Reliability Standards as legislated by the Electric Utilities Act. The CMP is composed of three monitoring elements: Reporting, self-certification and compliance monitoring audits. For more information on each of these elements please visit the AESO website at www.aeso.ca under COMPLIANCE.


Answer:The Compliance Monitoring Program (or CMP) is the processes and procedures set up

by the AESO to monitor market participant compliance to Alberta Reliability Standards as legislated by the Electric Utilities Act. The CMP is composed of three monitoring elements: Reporting, self-certification and compliance monitoring audits. For more information on each of these elements please visit the AESO website at www.aeso.ca under COMPLIANCE.

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Answer:Compliance to a reliability standard is determined at the time of an assessment and is

not pre-determined. AESO staff cannot provide any assurances of compliance prior to the formal assessment. Standard owners cannot tell you if evidence that you have prepared is sufficient or compliant with the standard.


Answer:Compliance to a reliability standard is determined at the time of an assessment and is

not pre-determined. AESO staff cannot provide any assurances of compliance prior to the formal assessment. Standard owners cannot tell you if evidence that you have prepared is sufficient or compliant with the standard.

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Answer:A market participant self-assesses whether a standard is applicable or not. If a market

participant self-assesses that a standard or requirement is not applicable, they will be asked during an audit to provide evidence of why they believe it does not apply.

If a market participant is unsure as to whether a standard or requirement applies to their organization or not, they should complete an applicability assessment application form and submit it to [email protected]. The AESO will inform the market participant of the results within 90 days. A confirmation letter that the standard or requirement is not applicable may be used as evidence during an audit.


Answer:A market participant self-assesses whether a standard is applicable or not. If a market

participant self-assesses that a standard or requirement is not applicable, they will be asked during an audit to provide evidence of why they believe it does not apply.

If a market participant is unsure as to whether a standard or requirement applies to their organization or not, they should complete an applicability assessment application form and submit it to [email protected]. The AESO will inform the market participant of the results within 90 days. A confirmation letter that the standard or requirement is not applicable may be used as evidence during an audit.

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Answer:The roles and responsibilities of the AESO are defined under the

Alberta Electric Utilities Act Division 2. Section 17 (l.1) of the act defines the AESO’s responsibility for monitoring compliance of the registered market participants to ARS.

The roles and responsibilities of the MSA are defined under Division 2 of the Alberta Utilities Commission Act.


Answer:The roles and responsibilities of the AESO are defined under the

Alberta Electric Utilities Act Division 2. Section 17 (l.1) of the act defines the AESO’s responsibility for monitoring compliance of the registered market participants to ARS.

The roles and responsibilities of the MSA are defined under Division 2 of the Alberta Utilities Commission Act.

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Answer:Registered market participants are required to maintain their own records and track requests

made of them by the ISO and other market participants. The AESO suggests that:

Where and when requests have been received, save a copy as evidence.

Where and when requests have been responded to, save a copy as evidence.

When providing data to the AESO, request confirmation from the AESO that the data was received and was acceptable to the AESO in meeting the intent of the request.

Copies of soft confirmations be retained and filed as evidence.


Answer:Registered market participants are required to maintain their own records and track requests

made of them by the ISO and other market participants. The AESO suggests that:

Where and when requests have been received, save a copy as evidence.

Where and when requests have been responded to, save a copy as evidence.

When providing data to the AESO, request confirmation from the AESO that the data was received and was acceptable to the AESO in meeting the intent of the request.

Copies of soft confirmations be retained and filed as evidence.

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Registration

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There are currently no frequently asked questions for this section.

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Related documents to registration can be found on the AESO Website at:

www.aeso.ca under COMPLIANCE

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Applicability Assessments

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Q1. How long will the AESO take to review an applicability assessment request?

Q2. Is a registered market participant required to request an applicability assessment to an ARS each year?

Q3. Will the AESO be updating the registry as the results of the applicability assessments?

Q4. Will past “Exemptions” or assessments be acceptable?

Q5. If the result of the AESO’s assessment indicates that a requirement is applicable to my entity, what date will monitoring activities start at?

Q6. What happens if I am not ready to comply?




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Applicability AssessmentsQ1 of 6

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Answer:As per section 4.2-3 of the Alberta Reliability Standards Registration Guide (Version

2.1), notification of the results will be sent within 90 days of the request.


Answer:As per section 4.2-3 of the Alberta Reliability Standards Registration Guide (Version

2.1), notification of the results will be sent within 90 days of the request.

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Q2. Is a registered market participant required to request an applicability assessment each year?

Answer:If there is no change to the original application, there is no need to submit an

applicability assessment request each year. When you complete your annual self-certification letter, you should note the following:

- In the column titled “Applicability”, select “Not Applicable –AESO CMP review”.

- In the additional comments column, indicate the date of the confirmation from the AESO and indicate that no changes have occurred which could require a revisit of the applicability assessment.

Q2. Is a registered market participant required to request an applicability assessment each year?

Answer:If there is no change to the original application, there is no need to submit an

applicability assessment request each year. When you complete your annual self-certification letter, you should note the following:

- In the column titled “Applicability”, select “Not Applicable –AESO CMP review”.

- In the additional comments column, indicate the date of the confirmation from the AESO and indicate that no changes have occurred which could require a revisit of the applicability assessment.

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Answer:The result of an applicability assessment will not change the

Alberta Reliability Standards Registry. The ARS registry is based on functional entity types as defined in the Functional Model. An applicability request will only identify whether or not a registered market participant will be monitored by the AESO for a specific standard or individual requirement within a standard.


Answer:The result of an applicability assessment will not change the

Alberta Reliability Standards Registry. The ARS registry is based on functional entity types as defined in the Functional Model. An applicability request will only identify whether or not a registered market participant will be monitored by the AESO for a specific standard or individual requirement within a standard.

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Answer:There is no need to re-submit an applicability assessment request if a previous request

was accepted. As indicated in the answer to question 2 above, you should, on your annual self-certification letter, indicate each requirement that is non-applicable, reference the past applicability assessment and indicate that there have been no changes since the decision.


Answer:There is no need to re-submit an applicability assessment request if a previous request

was accepted. As indicated in the answer to question 2 above, you should, on your annual self-certification letter, indicate each requirement that is non-applicable, reference the past applicability assessment and indicate that there have been no changes since the decision.

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Answer:All standards are monitored from the effective date of the requirement. The

requirement is not monitored during the applicability assessment process.

If the standard or requirement was in effect prior to the applicability assessment request and you find that your entity may not have been in compliance, you should file a self-report with the MSA.

Similarly, if the result of the AESO’s assessment indicates that a requirement is not applicable, the decision will be applied historically and include the time period prior to the applicability assessment request.


Answer:All standards are monitored from the effective date of the requirement. The

requirement is not monitored during the applicability assessment process.

If the standard or requirement was in effect prior to the applicability assessment request and you find that your entity may not have been in compliance, you should file a self-report with the MSA.

Similarly, if the result of the AESO’s assessment indicates that a requirement is not applicable, the decision will be applied historically and include the time period prior to the applicability assessment request.

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Answer:If a market participant requires additional time to become compliant, the AESO

suggests filing a self-report with the MSA.


Answer:If a market participant requires additional time to become compliant, the AESO

suggests filing a self-report with the MSA.

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Designation of Documentation Provider (DDP)

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Q1. Are there differences in the types of referral to the MSA – an administrative referral vs. a technical referral?

Q2. What are the consequences when a registered market participant files an administratively complete self-certification letter but is technically assessed by the AESO during a subsequent compliance audit that the registered market participant is in non-compliance with the ARS requirement/s?

Q3. Will the MSA request for information in addition to what the AESO has submitted on referrals by the AESO to suspected violation of an ARS requirement by a registered market participant?

Q4. Will a registered market participant be considered in non-compliance when the registered market participant’s self-certification letter identifies non-compliance with one requirement within an ARS, or non-compliance with an entire ARS?

Q5. Can a registered market participant submit their self-certification letter early?

Q6. What are the consequences if registered market participant submit their self-certification letter late?

Q7. Will deficiencies discovered on the original self-certification letter submitted by a registered market participant be notified to the MSA as suspected violations or will the registered market participant be given the opportunity to revise the original self-certification prior to any notification of suspected violation to the MSA?

Self-Certification (1 of 2)

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Self-CertificationQ1 of 14

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Answer:No. The referral process follows ISO Rule 103.12, and the administrative and technical

assessments are ways through which the AESO becomes aware of possible non-compliance to the ARS.


Answer:No. The referral process follows ISO Rule 103.12, and the administrative and technical

assessments are ways through which the AESO becomes aware of possible non-compliance to the ARS.

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Answer:All suspected violations are referred by the AESO to the MSA as per “

ISO Rule 103.12 11(1)”. In addition, “ISO Rule 103.12 11(2)” requires the AESO to notify the registered market participants when a matter is referred to the MSA.


Answer:All suspected violations are referred by the AESO to the MSA as per “

ISO Rule 103.12 11(1)”. In addition, “ISO Rule 103.12 11(2)” requires the AESO to notify the registered market participants when a matter is referred to the MSA.

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Answer:The MSA has the authority to request, at their discretion, additional documentary

evidence on any compliance and enforcement matters under investigation by the MSA. It may be in addition to evidence already submitted to the AESO by the registered market participant. The right for the MSA to request for such evidence is given under Section 46 (1) of the Alberta Utilities Commission Act.




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Answer:All assessments are made at the ARS requirement level; suspected non-compliance to ARS

requirements is considered as suspected violations. Where an entire ARS is in non-compliance, each requirement of the ARS is considered as a suspected violation. Suspected violations are referred to the MSA.

Where a market participant has self-assessed they are non-compliant with either one requirement or an entire ARS, during the administrative review additional information will be sought by the AESO’s Compliance group. This step may assist in determining whether a technical review is required to confirm the suspected contravention, whether a report to the MSA of the suspected non-compliance is required, or both.


Answer:All assessments are made at the ARS requirement level; suspected non-compliance to ARS

requirements is considered as suspected violations. Where an entire ARS is in non-compliance, each requirement of the ARS is considered as a suspected violation. Suspected violations are referred to the MSA.

Where a market participant has self-assessed they are non-compliant with either one requirement or an entire ARS, during the administrative review additional information will be sought by the AESO’s Compliance group. This step may assist in determining whether a technical review is required to confirm the suspected contravention, whether a report to the MSA of the suspected non-compliance is required, or both.

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Answer:Self-certification letter should only be submitted within the self-certification submittal

period of the registered market participant’s assigned cycle. Early submission would signal an incomplete self-certification as it would not cover the entire self-certification period. The registered market participant will be considered in non-compliance to all the ARS requirements that the registered market participant is to attest compliance on.


Answer:Self-certification letter should only be submitted within the self-certification submittal

period of the registered market participant’s assigned cycle. Early submission would signal an incomplete self-certification as it would not cover the entire self-certification period. The registered market participant will be considered in non-compliance to all the ARS requirements that the registered market participant is to attest compliance on.

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Answer:Where a self-certification letter is submitted after the self-certification submittal period

of the registered market participant’s assigned cycle, the registered market participant will be considered in non-compliance to all the ARS requirements that the registered market participant is to attest compliance on.


Answer:Where a self-certification letter is submitted after the self-certification submittal period

of the registered market participant’s assigned cycle, the registered market participant will be considered in non-compliance to all the ARS requirements that the registered market participant is to attest compliance on.

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Answer:No, the deficiencies identified on the original self-certification letter are not referred to the MSA as non-compliance. The registered

market participant is given the opportunity to resubmit the self-certification letter.

The original deficiencies are listed on a deficiency notification letter and sent to the registered market participant to correct and file an amended self-certification letter. The registered market participant is given five (5) business days to revise their submission. Where the AESO has verified that the revised self-certification letter is administratively complete, no further action will be taken by the AESO. Where the AESO has determined that the revised submission by the registered market participant is administratively incomplete, the AESO will refer the matter to the MSA as suspected violations.

Where the AESO has determined that a registered market participant has shown best efforts in preparing their self-certification letter but has inadvertently submitted the incorrect information, the AESO will make all effort to guide the registered market participant in revising and submitting a corrected self-certification letter within the five (5) business days after issue of notification letter identifying the registered market participant’s deficiencies


Answer:No, the deficiencies identified on the original self-certification letter are not referred to the MSA as non-compliance. The registered

market participant is given the opportunity to resubmit the self-certification letter.

The original deficiencies are listed on a deficiency notification letter and sent to the registered market participant to correct and file an amended self-certification letter. The registered market participant is given five (5) business days to revise their submission. Where the AESO has verified that the revised self-certification letter is administratively complete, no further action will be taken by the AESO. Where the AESO has determined that the revised submission by the registered market participant is administratively incomplete, the AESO will refer the matter to the MSA as suspected violations.

Where the AESO has determined that a registered market participant has shown best efforts in preparing their self-certification letter but has inadvertently submitted the incorrect information, the AESO will make all effort to guide the registered market participant in revising and submitting a corrected self-certification letter within the five (5) business days after issue of notification letter identifying the registered market participant’s deficiencies

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Q8. What process does the AESO follow in circumstances where the registered market participant has declared non-compliance with an ARS requirement and the AESO deems the registered market participant to be in-compliance?

Q9. How does the AESO define “officer” who is required to sign the self-certification letter?

Q10. Is it possible to have someone else sign the self-certification letter other then the “Officer” of the company?

Q11. Should a registered market participant submit their self-certification letter if a compliance audit is being conducted during the registered market participant’s self-certification period?

Q12. Can the effective date of an ARS influence the period for which a registered market participant has to self-certify?

Q13. Should technical information be included with the self-certification letter?

Q14. Is the officer’s signature required in the self-certification letter provided in the Excel format?

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Answer:The AESO will notify the registered market participant in writing that the registered

market participant is in-compliance with the ARS requirement. No other action will be taken.


Answer:The AESO will notify the registered market participant in writing that the registered

market participant is in-compliance with the ARS requirement. No other action will be taken.

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Answer:An “officer” holds a position of authority and trust in their organizations. The officer has

the ability to bind his/her corporation/s and make representations and warranties on behalf of their corporation/s. One of the hallmark features of an “officer” is the shared legal liability of the “office” with his/her company's actions.


Answer:An “officer” holds a position of authority and trust in their organizations. The officer has

the ability to bind his/her corporation/s and make representations and warranties on behalf of their corporation/s. One of the hallmark features of an “officer” is the shared legal liability of the “office” with his/her company's actions.

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Answer:The “officer” has the right to delegate the authority where they see fit, defined under the

Alberta compliance monitoring process related to the Alberta reliability standards. The officer is required to issue a letter to the AESO indicating the delegation of authority, specifying the name, title and contact information of the delegated party.


Answer:The “officer” has the right to delegate the authority where they see fit, defined under the

Alberta compliance monitoring process related to the Alberta reliability standards. The officer is required to issue a letter to the AESO indicating the delegation of authority, specifying the name, title and contact information of the delegated party.

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Answer:Yes. All registered market participants are required to self-certify in accordance with

the AESO self-certification schedule.

Where a registered market participant has had a spot-check compliance audit conducted during their self-certification period, the AESO will not conduct a second spot-check audit of the reliability standards verified.


Answer:Yes. All registered market participants are required to self-certify in accordance with

the AESO self-certification schedule.

Where a registered market participant has had a spot-check compliance audit conducted during their self-certification period, the AESO will not conduct a second spot-check audit of the reliability standards verified.

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Answer:Yes. All assessment for compliance to an ARS is made considering the effective dates of the standard:

In cases where the ARS is in effect during the entire self-certification period, the registered market participant must self-certify for the entire self-certification period;

In cases where the ARS goes into effect during the self-certification period, the registered market participant must self-certify from the effective date of the standard to the last day of the self-certification period;

In cases where the ARS effective end date is during the self-certification period, the registered market participant must self-certify from the first day of the self-certification period to the effective end date of the ARS;

In cases where there is more than one version of an ARS, the registered market participant must assess its compliance to all versions in effect during the self-certification period.


Answer:Yes. All assessment for compliance to an ARS is made considering the effective dates of the standard:

In cases where the ARS is in effect during the entire self-certification period, the registered market participant must self-certify for the entire self-certification period;

In cases where the ARS goes into effect during the self-certification period, the registered market participant must self-certify from the effective date of the standard to the last day of the self-certification period;

In cases where the ARS effective end date is during the self-certification period, the registered market participant must self-certify from the first day of the self-certification period to the effective end date of the ARS;

In cases where there is more than one version of an ARS, the registered market participant must assess its compliance to all versions in effect during the self-certification period.

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Answer:No. Technical information should not be submitted with the self-certification letter. The registered market

participant should retain the evidence used to determine compliance with the ARS for the self-certification period. Evidence for compliance to ARS is retained for a statutory period of six (6) years.


Answer:No. Technical information should not be submitted with the self-certification letter. The registered market

participant should retain the evidence used to determine compliance with the ARS for the self-certification period. Evidence for compliance to ARS is retained for a statutory period of six (6) years.

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Answer:An officer’s signature is not required in the “Signature” field of the “Officer’s Certificate”

on the Excel submitted format.


Answer:An officer’s signature is not required in the “Signature” field of the “Officer’s Certificate”

on the Excel submitted format.

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Audits

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Reliability Standard Audit Worksheets

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Q1. What are RSAWs used for?

Q2. Through the audit process the AESO will gather evidence from my organization and document its audit findings on the RSAW. Will the MSA request additional information from the registered market participant on a suspected violation of an ARS requirement, other than that provided by the AESO through the referral process?

Q3. Are Professional Engineer (P.Eng.) stamps required on the registered market participant evidentiary documents and will it be identified on the RSAW as an evidentiary requirement?

Q4. When looking at the RSAW for TOP-005-AB-1, it is not clear whether the AESO will be looking for multiple letters or a single letter when conducting an audit?




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Answer:Reliability Standards Audit Worksheets (RSAWs) are a tool used by the compliance

monitor to document audit assessments.

The RSAW must be filled out by the market participant and submitted to the compliance monitor with the evidence files. For each applicable requirement request, the registered market participant must provide a hyperlink(s) to the individual evidence document(s). The hyperlink should be placed in the “Evidence column. Although a hyperlink is preferred, the document may also be embedded.


Answer:Reliability Standards Audit Worksheets (RSAWs) are a tool used by the compliance

monitor to document audit assessments.

The RSAW must be filled out by the market participant and submitted to the compliance monitor with the evidence files. For each applicable requirement request, the registered market participant must provide a hyperlink(s) to the individual evidence document(s). The hyperlink should be placed in the “Evidence column. Although a hyperlink is preferred, the document may also be embedded.

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Answer:A P.Eng. Stamp is not required in demonstrating compliance under the assessment

section of an RSAW unless it is specifically documented within the requirements or measures of an approved Alberta reliability standard.


Answer:A P.Eng. Stamp is not required in demonstrating compliance under the assessment

section of an RSAW unless it is specifically documented within the requirements or measures of an approved Alberta reliability standard.

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Answer:In the event of an audit on TOP-005-AB-1 R2 or R5, the registered market participant

would be responsible to produce the letter provided by the AESO. The registered market participant would have 30 days to provide the letter to the auditor. To confirm compliance to TOP-005-AB-1 - R2 or R5; the auditor will simply confirm that the registered market participant has the letter from the AESO on file. If multiple years are included in the audit scope, then the AESO would be looking for one letter for each of the years included in the audit.


Answer:In the event of an audit on TOP-005-AB-1 R2 or R5, the registered market participant

would be responsible to produce the letter provided by the AESO. The registered market participant would have 30 days to provide the letter to the auditor. To confirm compliance to TOP-005-AB-1 - R2 or R5; the auditor will simply confirm that the registered market participant has the letter from the AESO on file. If multiple years are included in the audit scope, then the AESO would be looking for one letter for each of the years included in the audit.

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