IN
THE MATTER OF
the Utilities Commission Act, RSBC 1996, Chapter 473
and
Mandatory Reliability Standards Assessment Report No. 8
by British Columbia Hydro and Power Authority
Addressing Reliability Standards for Adoption in British Columbia
BEFORE: D. M. Morton, Panel Chair/Commissioner
H. G. Harowitz, Commissioner July 24, 2015
I. F. MacPhail, Commissioner
O R D E R
WHEREAS:
A. Pursuant to section 125.2(2) of the Utilities Commission Act (UCA), the British Columbia Utilities Commission (Commission) has exclusive jurisdiction to determine whether a “reliability standard” as defined in the UCA, is in the public interest and should be adopted in British Columbia (BC);
B. The Rules of Procedure for Reliability Standards in BC (ROP), adopted by Commission Order G-123-09, dated October 15, 2009, and amended by Commission Order R-33-15, states that a reliability standard does not include Compliance Provisions and defines Compliance Provisions as “the compliance-related provisions that accompany, but do not constitute part of, a Reliability Standard and that have been adopted by the Commission”;
C. Ministerial Order No. MO39 dated February 22, 2009, as amended, established a Mandatory Reliability Standards (MRS) Regulation, which prescribes the parties that are subject to reliability standards adopted under section 125.2(6) of the UCA;
D. In order to facilitate the Commission’s consideration of reliability standards, British Columbia Hydro and Power Authority (BC Hydro) is required, under section 125.2(3) of the UCA, to review each reliability standard established by a standard-making body such as the North American Reliability Corporation (NERC) and the Western Electricity Coordinating Council (WECC) and provide the Commission with a report (MRS Assessment Report) assessing:
a. any adverse impact of the reliability standard on the reliability of electricity transmission in BC if the reliability standard were adopted;
b. the suitability of the reliability standard for BC;
c. the potential cost of the reliability standard if it were adopted; and
d. any other matter prescribed by regulation or identified by order of the Commission;
E. Compliance Provisions, including effective dates, are not assessed by BC Hydro. This approach is consistent with that taken in previous MRS Assessment Reports;
F. In its October 29, 2014 letter to the Commission, BC Hydro requested an extension to allow certain reliability standards to be included in the MRS Assessment Report and to be assessed over a period of greater than a year pursuant to section 3(2) of the MRS Regulation. This extension request was approved by Commission Order R-57-14, and letter dated April 27, 2015;
G. On May 15, 2015, BC Hydro filed MRS Assessment Report No. 8 (Assessment Report) addressing 37 new and revised/replacement reliability standards. In the Assessment Report, BC Hydro used the date the reliability standard is adopted in the United States by the Federal Energy Regulatory Commission (FERC) as the date of regulatory approval to determine the reliability standards assessed during the Assessment Period (December 1, 2013 to November 30, 2014). BC Hydro assessed the reliability standards excluding the accompanying Compliance Provisions. If adopted, the 37 revised reliability standards would supersede existing reliability standards adopted in BC by Commission Orders G-67-09, G-167-10, G-162-11, R-1-13, R‑41-13 and R-32-14;
H. The reliability standards assessed by BC Hydro in the Assessment Report use defined terms contained in the Glossary of Terms Used in Reliability Standards dated October 1, 2014 (NERC Glossary). The Assessment Report included an assessment of 32 new and 18 revised defined glossary terms (Glossary Terms) included in the NERC Glossary;
I. In the Assessment Report, BC Hydro concludes that 34 reliability standards (10 new and 24 revised) and 45 glossary terms (27 new and 18 revised) are suitable for adoption in BC at this time;
J. To date, BC Hydro has acted as the Planning Authority/Planning Coordinator (PA/PC) for the BC Hydro asset footprint only. The PA/PC responsibilities for the province require clarification at this time. BC Hydro was unable to assess reliability standards MOD-032-1 and MOD-033-1 due to their reference to the PA/PC function and does not recommend these reliability standards for adoption in BC at this time. BC Hydro recommends that only those portions of PRC-023-3 that can be enforced without reliance on a PA/PC come into effect in BC at this time;
K. BC Hydro was unable to assess reliability standard TPL-001-4 within the time provided and requires additional time to complete a detailed planning study and full assessment. BC Hydro does not recommend this reliability standard for adoption in BC at this time and proposes to file a separate assessment report for TPL‑001‑4 within 18 months. BC Hydro suggests the Commission establish a stakeholder process to consider specific parameters pertaining to TPL-001-4;
L. BC Hydro recommends postponing the adoption of the new glossary terms “Bus-tie Breaker”, “Consequential Load Loss”, “Long-Term Transmission Planning Horizon”, “Non-Consequential Load Loss” and “Planning Assessment” as these terms are contained in TPL-001-4 to be assessed at a later date;
M. BC Hydro recommends that Cyber Infrastructure Protection (CIP) transition documentation to help industries transition directly from the currently enforceable CIP Version 3 reliability standards to CIP Version 5 reliability standards be implemented in BC in a similar manner as implemented in the United States. BC Hydro provided BC-specific versions of the CIP Transition Guidance, V3 to V5 Compatibility Tables and FERC-approved CIP V5 Implementation Plan as part of the Assessment Report for the Commission’s consideration;
N. BC Hydro recommends that, in connection with the recommendation for adoption of PRC-005-2, a BC-specific version of the FERC-approved PRC-005-2 Implementation Plan be implemented in BC. BC Hydro provided a BC-specific version of the PRC-005-2 Implementation Plan as part of the MRS Assessment Report for the Commission’s consideration;
O. Pursuant to subsection 125.2(5) of the UCA, the Commission posted the MRS Assessment Report on its website and, by Order R-33-15 dated May 29, 2015, directed BC Hydro to publish a Notice of Mandatory Reliability Standards Assessment Report No. 8 and Process for Public Comments and established the Regulatory Timetable for comments;
P. On June 11, 2015, FortisBC Inc. submitted comments to the Commission confirming its one-time and ongoing cost estimates to achieve compliance and stated that it agrees with BC Hydro that these expenditures are necessary. No other entities responded;
Q. On June 24, 2015, BC Hydro submitted it had no response to the comments received;
R. On June 30, 2015, BC Hydro submitted Errata 1 to the Assessment Report to correct some administrative errors and to include new versions of four reliability standards that were adopted by FERC within the Assessment Period. BC Hydro stated that the new versions (INT-004-3.1, INT-009-2.1, INT-010-2.1 and INT‑011-1.1) correct inconsistencies in the previous versions already assessed (INT-004-3, INT-009-2, INT‑010-2 and INT-011-1 respectively) and contain no changes to the requirements. BC Hydro recommends the Commission adopt the new versions with the effective dates as provided in Errata 1;
S. Pursuant to section 125.2(6) of the UCA, the Commission must adopt the reliability standards addressed in the Assessment Report if the Commission considers that the reliability standards are required to maintain or achieve consistency in BC with other jurisdictions that have adopted the reliability standards;
T. The Commission has reviewed and considered MRS Assessment Report No. 8, the Reliability Standards and Glossary Terms assessed therein, as well as the comments received and considers that the adoption of the recommendations in the report is warranted; and
U. Although not assessed by BC Hydro, the Commission considers the Compliance Provisions of the Reliability Standards informative for the compliance monitoring process in BC and finds it appropriate to provide effective dates for entities to come into compliance with the Reliability Standards and Glossary Terms adopted in this order.
NOW THEREFORE pursuant to subsections 125.2(3), 125.2(6) and 125.2(10) of the Utilities Commission Act:
1. The Commission adopts the 34 reliability standards recommended for adoption in MRS Assessment Report No. 8 and the four reliability standards considered in Errata 1 with the effective dates found in Table 1 of Attachment A to this order (the Effective Date) and each standard to be superseded by a standard adopted in this order shall remain in effect until the Effective Date of the standard superseding it. For clarity, Reliability Standards INT-004-3, INT-009-2, INT-010-2 and INT-011-1 are replaced immediately by INT‑004‑3.1, INT-009-2.1, INT-010-2.1 and INT-011-1.1 as recommended in Errata 1.
2. As a result of this order and Commission Orders G-67-09, G-167-10, G-162-11, G-175-11, R-1-13, R-11-13, R‑41-13 and R-32-14, the Reliability Standards listed in the table found in Attachment B to this order are in effect in BC as of the date shown (Effective Date). The Effective Dates for the Reliability Standards that are listed in the table found in Attachment B supersede the Effective Dates that were included in any similar list appended to any previous order. Attachment B to this order also includes those Reliability Standards with Effective Dates held in abeyance to be assessed at a later date.
3. Individual requirements within reliability standards that incorporate, by reference, reliability standards that have not been adopted by the Commission are of no force or effect in BC.
4. Individual requirements or sub-requirements within reliability standards, which the Commission has adopted but for which the Commission has not determined an effective date, are of no force or effect in BC.
5. The Commission adopts the North American Electric Reliability Corporation (NERC) Glossary of Terms Used in Reliability Standards, dated October 1, 2014, to define terms employed in the Reliability Standards (Glossary Terms). The Effective Date of each of the new or revised Glossary Terms adopted in this order is the date appearing in Table 2 of Attachment A to this order. Each Glossary Term to be superseded by a revised Glossary Term adopted in this order shall remain in effect until the Effective Date of the Glossary Term superseding it.
6. As a result of this order and Commission Orders G-67-09, G-167-10, G-162-11, G-175-11, R-1-13, R‑11‑13, R‑41-13 and R-32-14, the Glossary Terms listed in the tables found in Attachment C to this order are the Glossary Terms in effect in BC as of the dates indicated. The Effective Dates for the Glossary Terms that are listed in the tables found in Attachment C supersede the Effective Dates that were included in any similar list appended to any previous order.
7. The Commission directs that Glossary Terms within the NERC Glossary of Terms used in Reliability Standards, dated October 1, 2014, that do not include a United States Federal Energy Regulatory Commission approval date on or before November 30, 2014 are of no force or effect in BC.
8. The Commission directs that the Electric Reliability Council of Texas, Northeast Power Coordinating Council and Reliability First regional definitions listed at the end of the NERC Glossary of Terms used in Reliability Standards, dated October 1, 2014, are of no force or effect in BC.
9. The Commission adopts the Compliance Provisions, as defined in the Rules of Procedure for Reliability Standards in British Columbia, that accompany each of the adopted Reliability Standards, in the form directed by the Commission and as amended from time to time.
10. The Commission directs that the BC-specific versions of the CIP Transition Guidance, V3 to V5 Compatibility Tables, and CIP V5 Implementation Plan, in the form directed by the Commission and as amended from time to time, found in Attachment D to this order, be adopted and made effective in BC. The CIP Transition Guidance, V3 to V5 Compatibility Tables and CIP V5 Implementation Plan will be posted on the Western Electricity Coordinating Council website with a link to the Commission website.
11. The Commission directs that the BC-specific version of the PRC-005-2 Implementation Plan, in the form directed by the Commission and as amended from time to time, found in Attachment D to this order, be adopted and made effective in BC. The BC PRC-005-2 Implementation Plan will be posted on the Western Electricity Coordinating Council website with a link to the Commission website.
12. The Reliability Standards adopted in BC by the Commission will be posted on the Western Electricity Coordinating Council website with a link from the Commission website.
13. The Commission confirms that Entities subject to Mandatory Reliability Standards are required to report to the British Columbia Utilities Commission and may, on a voluntary basis, report to NERC as an Electric Reliability Organization or to the Federal Energy Regulatory Commission.
14. Attachment E to this order contains the text of the standards adopted by this order.
DATED at the City of Vancouver, in the Province of British Columbia, this 24th day of July 2015.
BY ORDER
Original Signed By:
D. M. Morton
Commissioner
Attachments