Part 7.9: Reliability Compliance Program

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1 PUBLIC IMO_PRO_0033 Market Manual 7: System Operations Part 7.9: Reliability Compliance Program Issue 5.0 This Market Manual describes the Ontario Reliability Compliance Program, and the associated procedures to detect and mitigate reliability noncompliance. Public

2 Disclaimer The posting of documents on this Web site is done for the convenience of market participants and other interested visitors to the IESO Web site. Please be advised that, while the IESO attempts to have all posted documents conform to the original, changes can result from the original, including changes resulting from the programs used to format the documents for posting on the Web site as well as from the programs used by the viewer to download and read the documents. The IESO makes no representation or warranty, express or implied that the documents on this Web site are exact reproductions of the original documents listed. In addition, the documents and information posted on this Web site are subject to change. The IESO may revise, withdraw or make final these materials at any time at its sole discretion without further notice. It is solely your responsibility to ensure that you are using up-to-date documents and information. This Market Manual may contain a summary of a particular market rule. Where provided, the summary has been used because of the length of the market rule itself. The reader should be aware, however, that where a market rule is applicable, the obligation that needs to be met is as stated in the Market Rules. To the extent of any discrepancy or inconsistency between the provisions of a particular market rule and the summary, the provision of the market rule shall govern. Document ID Document Name IMO_PRO_0033 Part 7.9: Reliability Compliance Program Issue Issue 5.0 Reason for Issue Issue released for Baseline 16.0 Effective Date September 13, 2006

3 Part 7.9: Reliability Compliance Program Document Change History Document Change History Issue Reason for Issue Date 1.0 Approved for Baseline 6.6 November 26, Issue released as update to Baseline 7.0 April 26, Document changed from Market Manual 2: Market Administration Part 2.4: Reliability Compliance Program to Market Manual 7: System Operations Part 7.9: Reliability Compliance Program December 10, Issue released as update to Baseline 12.1 December 08, Issue released for Baseline 16.0 September 13, 2006 Related Documents Document ID Document Title Issue 5.0 September 13, 2006 Public

4 Document Control IMO_PRO_0033 Public Issue 5.0 September 13, 2006

5 Part 7.9: Reliability Compliance Program Table of Contents Table of Contents Table of Contents...i List of Figures...ii List of Tables...iii Table of Changes...iv Market Manuals...1 Market Procedures Introduction Purpose Scope Overview Roles and Responsibilities Contact Information Procedural Work Flow Diagrams Provision and Processing of Reliability Compliance Related Information Planning and Conducting Corrective Measures to Remedy Non- Compliance Procedural Steps Provision and Processing of Reliability Compliance Related Information Planning and Conducting Corrective Measures to Remedy Non- Compliance...16 Appendix A: Forms...A 1 Appendix B: Historical Background...B 1 References 1 Issue 5.0 September 13, 2006 Public i

6 List of Figures IMO_PRO_0033 List of Figures Figure 1-1: Overall Reliability Compliance Model...5 Figure 2-1: Procedural Work Flow Diagram for the Provision and Processing of Reliability Information...10 Figure 2-2: Procedural Work Flow for Planning and Conducting Corrective Measures to Remedy Non-Compliance...11 ii Public Issue 5.0 September 13, 2006

7 Part 7.9: Reliability Compliance Program List of Tables List of Tables Table 2-1: Legend for Procedural Work Flow Diagrams...9 Table 3-1: Procedural Steps for the Provision and Processing of Reliability Compliance Related Information...13 Table 3-2: Procedural Steps for Planning and Conducting Corrective Measures to Remedy Non-Compliance...16 Issue 5.0 September 13, 2006 Public iii

8 Table of Changes IMO_PRO_0033 Table of Changes Reference (Section and Paragraph) Document Appendix B Description of Change Name change throughout document from IMO to IESO as well as changes stemming from last year s organizational changes. Changes made to the historical background to better align with the Ontario reliability framework. iv Public Issue 5.0 September 13, 2006

9 Part 7.9: Reliability Compliance Program Market Manuals Market Manuals The market manuals consolidate the market procedures and associated forms, standards, and policies that define various market and power system operating domains within the IESO-administered markets. Market procedures provide more detailed descriptions of the requirements for various activities than is specified in the Market Rules. Where there is a discrepancy between the requirements in this Market Manual and the Market Rules, the Market Rules shall prevail. Standards and policies are either appended to, or referenced in, these procedures to provide a supporting framework. Market Procedures This Market Manual provides the procedures under Volume 2: System Operations, Part 7.9: Reliability Compliance Program. All other component Parts of Volume 2 are listed in Part 2.0: Market Administration Overview, Section 2: About This Manual. Structure of Market Procedures This Market Manual is composed of the following main sections: 1. Introduction, which contains general information about the procedures, including an overview, a description of the purpose and scope of the procedures, and information about the roles and responsibilities of the parties involved in the procedures. 2. Procedural Work Flow, which contains a graphical representation of the steps and flow of information within the procedures. 3. Procedural Steps, which contains a table that describes each step in the procedures, and provides other details related to each step. 4. Appendices, which may include such items as forms, standards, policies, agreements. Conventions The market manual standard conventions are as defined in the Market Manual Overview document. Issue 5.0 September 13, 2006 Public 1

10 Market Procedures IMO_PRO_ Public Issue 5.0 September 13, 2006

11 Part 7.9: Reliability Compliance Program 1. Introduction 1. Introduction 1.1 Purpose The purpose of this Market Manual is to outline a compliance program along with the associated compliance procedures in order to assist market participants in meeting the reliability compliance related requirements which in turn helps to maintain Ontario's power system reliability. This program, shall be carried out by market participants in conjunction with the IESO, and provides procedures for monitoring and measuring the extent to which reliability standards are being adhered to, for detecting reliability non-compliance, and for planning, conducting and enforcing corrective measures to remedy instances of non-compliance. 1.2 Scope This Market Manual outlines the specific procedural requirements for the provision and processing of reliability information as required by standards authorities. It further stipulates procedures for enforcement and mitigation measures to correct instances of non-compliance with reliability standards. The procedures in this Market Manual complement and support the procedures in Volume 2: Market Administration Manual, Part 2.6: Treatment of Compliance Issues through monitoring and reporting of market participant compliance with the reliability standards, and through the management of measures to mitigate instances of non-compliance. The respective obligations, roles and responsibilities of market participants and the IESO are outlined, and work flows and associated procedural steps for carrying out reliability monitoring, reporting, and non-compliance detection and mitigation are covered. 1.3 Overview The interconnected bulk electric grid is highly integrated throughout the North American continent. An unforeseen event on one part of the grid, due to unreliability, may have a significant negative impact on electricity markets and on safe, secure operation of other parts of the grid. Avoidable unreliability places markets and end-use customers at undue financial risk, and jeopardizes the security of the interconnected electricity systems. Competition in the electricity industry exacerbates tensions between market economics and the costs of maintaining reliability. Reliability is essential to ensure a robust power system infrastructure for the electricity marketplace, and to protect the health, welfare and safety of the public. Hence, NERC, as the overall reliability standard authority for the North American electricity industry, has advocated that compliance with its reliability standards must be mandatory and enforceable. Issue 5.0 September 13, 2006 Public 3

12 1. Introduction IMO_PRO_0033 NPCC represents the interests of power system utilities throughout the northeastern part of the North American continent (including Ontario and all provinces east of Ontario). As a member of NERC, NPCC has adopted NERC s reliability standards and associated compliance requirements. NPCC has expanded on NERC s standards in order to meet the unique reliability needs of the electricity systems in the northeast. The IESO as the Ontario control area operator and reliability coordinator and as a member of NPCC and a signatory of the NPCC Membership Agreement, has adopted NERC, NPCC and IESO specific reliability standards and compliance requirements for application in Ontario. IESO reliability related information requirements, set forth in the market rules, are listed in Market Manual 7: System Operations. Part 7.5: Reliability Information Catalogue. Appendix B includes further background on the historical development of the reliability standards and compliance program adopted in Ontario. The reliability standards and the associated measurement and compliance requirements are prescribed in the form of templates and certification forms. Each template and certification form defines: 1. a specific enforceable reliability standard; 2. appropriate measure(s) associated with that standard; 3. reporting requirements, including reporting timeframes 4. roles and responsibilities; and, 5. sanction levels associated with observed non-compliance. The details of the IESO Reliability Compliance Program and related background material are available on the IESO Web site: ( To facilitate the submission of reliability compliance related information and associated data by market participants to the IESO, a dedicated link to the IESO Reliability Compliance Program has been established for ing the information to IESO via IRCP@ieso.ca. The IESO Reliability Compliance Program, encompassed by this Market Manual 7: System Operations, Part 7.9: Reliability Information Catalogue and Market Manual 2: Market Administration, Part 2.6: Treatment of Compliance Issues, provides procedures for the following three domains: 1. COMPLIANCE This domain provides specific procedures for monitoring, measuring, assessing and reporting on the extent to which the reliability standards stipulated in reliability standards templates have been met. 2. ENFORCEMENT This domain provides specific procedures for enforcing the obligations set out in the market rules, including the application of sanctions for breaches. This includes failures to meet reliability standards, and for failures to follow the compliance and mitigation procedures called for in the market manuals. 3. MITIGATION This domain provides specific procedures for ensuring that non-compliance is resolved through the submission, completion and enforcement of plans and timetables to mitigate instances of reliability non-compliance. 4 Public Issue 5.0 September 13, 2006

13 Part 7.9: Reliability Compliance Program 1. Introduction These domains are depicted in the reliability compliance model in Figure 1-1 below. IESO provides market participants with access to reliability standards templates IESO reports on status of reliability compliance and corrective measures to NPCC and IMO Board of Directors. ( Market Manual 7.9 ) Market participant carries out corrective measures. ( Market Manual 7.9 ) YES Market participant submit reliability compliance related information as per templates. IESO reviews and assesses reliability performance against reliability standards templates. ( Market Manual 7.9 ) Compliance ( Market Manual 7.94 ) NO IESO applies noncompliance sanctions. ( Market Manual 2.6 ), Figure 1-1: Overall Reliability Compliance Model Market Manual 2: Market Administration, Part 2.6: Treatment of Compliance Issues covers the procedural requirements for the enforcement of all aspects of operation of the IESO administered markets. This Market Manual 7.9 complements and supports the procedures in Market Manual 2.6 by providing information on the detection of reliability non-compliance, on failures to implement timely mitigation measures, and on failures to adhere to the procedures in the IESO Reliability Compliance Program. 1.4 Roles and Responsibilities Responsibility for carrying out the reliability compliance procedures in this Market Manual 7.9 is shared among: Market Participants, who are responsible for: planning, designing, operating and maintaining their registered facilities in accordance with all applicable reliability standards : (Chapter 4, Sections and of the market rules); carrying out the procedures in the IESO Reliability Compliance Program as encompassed in Market Manual 7.9 (Chapter 5, Sections to and 3.3.3, Chapter 4 Section 5 of the market rules); notifying the IESO if the market participant breaches a reliability standard (Chapter 3, Section 6.2 and Chapter 5, Section of the market rules); complying with relevant reliability orders and directions, and reliability related requirements, issued by the IESO (Chapter 5, Sections 14 and 3, and Chapter 4, Sections 1 to 5 of the market rules). responding to a notification of an alleged breach of the reliability standards (Chapter 3, Section 6.2 of the market rules); providing additional information to, or meeting with, the IESO if required (Chapter 3, Section 6.2 and Chapter 5, Section 14 of the market rules); and Issue 5.0 September 13, 2006 Public 5

14 1. Introduction IMO_PRO_0033 carry out corrective measures to remedy non-compliance (Chapter 3, Sections 6.2.6, and of the market rules). The IESO which is responsible for: adopting NERC, NPCC and IESO specific reliability standards (Chapter 1, Section and Chapter 11, Section and 361 of the market rules); making the reliability standards and reliability standards templates, certification forms and associated schedules available to market participants (Chapter 5, Sections and of the market rules); monitoring and assessing market participant performance in complying with the reliability standards and associated compliance procedures, identifying and reporting compliance issues (Chapter 3, Section and Chapter 5, Section of the market rules): taking immediate action if security or reliability is or may be compromised by a reliability non-compliance issue (Chapter 5, Section 5.1 and Chapter 3, Section and of the market rules): requesting information in addition to that called for in the reliability standards templates, where needed for a compliance investigation, and meeting with the market participant if required (Chapter 3, Sections 6.2.5, 6.2.3, and of the market rules); relevant reliability orders and directions, and reliability related requirements, issued by the IESO (Chapter 5, Sections 3.2 and 3.3, Chapter 4, Sections 1 to 5 of the market rules); conducting investigations and determining the appropriate actions in response to a noncompliance issue (Chapter 3, Section and Section of the market rules); notifying the market participant of investigation findings and evaluating market participant responses (Chapter 3, Section and Section of the market rules); recommending corrective measures to non-compliant market participants, and monitoring the progress of their mitigation activities (Chapter 3, Section and Section of the market rules); reporting to NERC, NPCC and the IESO Board of Directors on: (Chapter 5, Section , 3.2.2, and of the market rules); and the extent of Ontario's compliance with the reliability standards; and the status of Ontario's corrective measures to mitigate reliability non-compliance. acting as a repository for information concerning breaches of reliability standards and compliance procedures for future use in compliance investigations (Chapter 5, Section and Chapter 3, Section of the market rules). 6 Public Issue 5.0 September 13, 2006

15 Part 7.9: Reliability Compliance Program 1. Introduction 1.5 Contact Information As part of the market participant authorization and registration process, applicants are required to identify a range of contacts within their organizations that address specific areas of market operations. The IESO will seek to contact these individuals for activities documented within this procedure, unless alternative arrangements have been established between the IESO and the market participant. If a market participant has not identified a specific contact, the IESO will seek to contact the Main Contact as indicated in the Participant Life Cycle (PLC) tool, that is established during the participant authorization process, unless alternative arrangements have been established between the IESO and the market participant. If the market participant wishes to contact the IESO, the market participant can contact IESO Customer Relations via at customer.relations@ieso.ca or via telephone, mail or courier to the numbers and addresses given on the IESO s Web site ( or click on Contact Us to go to the Contacting the IESO page). If the IESO Customer Relations office is closed, telephone messages or s may be left in relevant voice or electronic IESO mailboxes, which will be answered as soon as possible by Customer Relations staff. End of Section Issue 5.0 September 13, 2006 Public 7

16 1. Introduction IMO_PRO_ Public Issue 5.0 September 13, 2006

17 Part 7.9: Reliability Compliance Program 2. Procedural Work Flow Diagrams 2. Procedural Work Flow Diagrams The diagrams in this section represent the flow of work and information between the market participants and the IESO. The workflow illustrated in the diagrams in this section are described in more detail in the procedural steps in section 3. Table 2-1: Legend for Procedural Work Flow Diagrams Oval Legend Task Box Solid horizontal line Solid vertical line Broken line Description An event that triggers task or that completes task. Trigger events and completion events are numbered sequentially within procedure (01 to 99) Shows reference number party responsible for performing task (if other party ), and task name or brief summary of task. Reference number (e.g., 1A.02) indicates procedure number within current Market Manual (1), sub-procedure identifier (if applicable) (A), and task number (02) Shows information flow between the IESO and external parties Shows linkage between tasks Links trigger events and completion events to preceding or succeeding task Issue 5.0 September 13, 2006 Public 9

18 2. Procedural Work Flow Diagrams IMO_PRO_ Provision and Processing of Reliability Compliance Related Information Market Participant 01 Requirement to assess reliability performance as stipulated in each template. 4A.1 IESO Provide market participants with access to the reliability standards templates and schedules. 4A.2 Provide IESO with reliability information as called for in each template. 4A.3 2 Verify market participants reliability information is complete. 02 Information incomplete 03 Information Complete 4A.5 Submit missing information to IESO. 4A.4 4 Request market participant to supply missing information. 4A.6 Review reliability measure in manner called for in template. 4A.7 Assess if measure violates reliability standard in template. 4A.8 04 Measure is in compliance with standard. Inform market participant of favourable results of compliance assessment. 05 Measure violates standard. Proceed to Event 01, Fig. 2.2 of MM 7.9, and to Event 6A.02, Fig. 2-1 of MM A.9 Report results to NPCC and the IESO Board of Directors Figure 2-1: Procedural Work Flow Diagram for the Provision and Processing of Reliability Information 10 Public Issue 5.0 September 13, 2006

19 Part 7.9: Reliability Compliance Program 2. Procedural Work Flow Diagrams 2.2 Planning and Conducting Corrective Measures to Remedy Non-Compliance Market Participant IESO 01 Requirement to initiate corrective measures to mitigate non-compliance with any reliability standard. 4B.2 Prepare a mitigation plan, including timetable, and submit to IESO for approval. 4B.1 Request market participant to prepare and submit a mitigation plan for IMO approval. 4B.3 Review mitigation plan/ timetable. 4B.5 Re-submit revised plan/ timetable to IESO. 02 Plan not acceptable. 03 Plan acceptable. 4B.4 Inform market participant of plan deficiencies, and request re-submission. 4B.7 Implement mitigation plan. 4B.8 Submit periodic status reports to IESO until completion of mitigation activities. 4B.6 4B.9 Review status of mitigation activities against agreed corrective measures and due dates. 04 Mitigation activities not expected to be completed as required. Proceed to Event 6B.01, Fig 2.2, MM B.11 Report results to NPCC and the IESO Board of Inform market participant of approved mitigation plan, and advise to proceed. 4B Mitigation activities completed, and on time. Inform market participant of IESO concurrence with completed mitigation activities. Figure 2-2: Procedural Work Flow for Planning and Conducting Corrective Measures to Remedy Non-Compliance End of Section Issue 5.0 September 13, 2006 Public 11

20 2. Procedural Work Flow Diagrams IMO_PRO_ Public Issue 5.0 September 13, 2006

21 Part 7.9: Reliability Compliance Program 3. Procedural Steps 3. Procedural Steps 3.1 Provision and Processing of Reliability Compliance Related Information Table 3-1: Procedural Steps for the Provision and Processing of Reliability Compliance Related Information Ref. Task Name Task Detail When Resulting Information Method Completion Events 4A.1 IESO provides market participants with access to the reliability standards templates and schedules. IESO s templates or posts them on the IESO Web site At all times. Current reliability standards and compliance requirements. or IESO Web site Market participant s accessibility to the reliability standards and compliance requirements. 4A.2 Market participants provide IESO with reliability information called for in each reliability standards template. Market participant reference template for information required, Send required information and certification of compliance to IESO Send complete submission to IESO prior to due date posted in the IRCP. Market participant reliability information & certification form for use by IESO to assess reliability performance measure(s) in template. Letter, Fax or at: IRCP@ieso.ca IESO in receipt of market participant s certification of reliability information. 4A.3 IESO verifies completeness of reliability information & supporting documentation supplied by market participants IESO assesses reliability information received against template requirements. IESO flags errors or omissions in market participant s submission. After step 4A.2 Complete and accurate market participant submission for subsequent assessment, or identification of omissions. Check off Supplied submission checked off as either complete or incomplete. Issue 5.0 September 13, 2006 Public 13

22 3. Procedural Steps IMO_PRO_0033 Ref. Task Name Task Detail When Resulting Information Method Completion Events 4A.4 IESO requests market participant for missing information. 4A.5 Market participant re-submits missing information to IESO. 4A.6 IESO assesses reliability measure(s) in manner called for in templates. 4A.7 IESO assesses if submission is in compliance with reliability standards requirements in template. 4A.8 IESO informs market participant of favorable results of compliance assessment. IESO sends market participant a request to provide missing or correct information. Market participant sends corrected submission or missing information to IESO. IESO assesses submission against performance measure(s) as per template. IESO assess submission against reliability standards and measures in template. IESO sends market participant formal acknowledgement of observed compliance with standard. Within 5 business days after receipt of market participant s initial submission Within 5 business days after IESO request. Within 2 business days following receipt of complete submission from market participant. After step 4A.5. If step 4A.7 indicates compliance. Errors or omissions in market participant s submission. Telephone, Fax or Same as for 4A2 above. Letter, Fax or E- Mail at: Compliance assessment of Market Participant for particular template. Positive or negative variance in performance. Favorable indication to market participant that they are in compliance with the particular reliability standards in question (i.e. particular template) for the period assessed. IRCP@ieso.ca Market participant receives IESO request. Revised submission forwarded to IESO. As per template. Finalized Compliance assessment of Market Participant. Computed quantitative variance. Establish qualitative variance. Letter, Fax or Indication of compliance or noncompliance with standard. If noncompliance, proceed to Event 01 in Figure 2-2 of Market Manual and Event 6A.03 in Figure 2-1 of Market Manual Part 2.6. Favorable assessment completed for market participant s compliance with a particular reliability standards (template) for particular time period. 14 Public Issue 5.0 September 13, 2006

23 Part 7.9: Reliability Compliance Program 3. Procedural Steps Ref. Task Name Task Detail When Resulting Information Method Completion Events 4A.9 IESO reports results to NPCC and the IESO Board of Directors. Reports submitted in accordance with NPCC and IESO reporting requirements. As required by NPCC and the IESO Board of Directors. Indications of the extent to which Ontario market participants and the IESO have complied with reliability standards and compliance requirements. In accordance with NPCC and IESO reporting requirements. NPCC and the IESO Board of Directors in receipt of information on Ontario compliance with reliability standards. Issue 5.0 September 13, 2006 Public 15

24 3. Procedural Steps IMO_PRO_ Planning and Conducting Corrective Measures to Remedy Non-Compliance Table 3-2: Procedural Steps for Planning and Conducting Corrective Measures to Remedy Non-Compliance Task Name Task Detail When Resulting Information Method Completion Events 4B.1 Request market participant to prepare and submit a mitigation plan and timetable for IESO approval. 4B.2 Market participant prepare a mitigation plan, and submit to IESO for approval. 4B.3 IESO review market participant s mitigation plans/timetable. 4B.4 IESO informs market participant of plan deficiency (ies), and requests re-submission. IESO inform market participant of requirement to prepare a mitigation plan, and request a plan and timetable to be submitted for IESO approval. Market participant informs IESO of mitigation actions they will implement along with a plan. The IESO will provide guidance as appropriate IESO review market participant s plan/timetable to assess if it will restore required reliability compliance. IESO send request for revised plan/timetable. Upon IESO identification of a non-compliant event. With initial submission indicating non-compliant or within 10 business days of receipt of IESO s assessment of noncompliance. After steps 4B.2. If step 4B.3 results in an assessment that the plan/timetable is unacceptable, inform market participant of same within one business day. Need for a mitigation plan, including the specific reliability standards that must be addressed. Proposed mitigation plan and timetable. Determination of viability of plan/timetables to mitigation noncompliance situation. Indication of deficiencies and a request for revised plan/timetable. Letter, Fax or Letter, Fax or at: IRCP@ieso.ca Assessment Letter, Fax or Market participant in receipt of IESO request. IESO in receipt of market participants mitigation plan and timetable. Plan/timetable either acceptable or not acceptable. Market participant in receipt of IESO s request for revision. 16 Public Issue 5.0 September 13, 2006

25 Part 7.9: Reliability Compliance Program 3. Procedural Steps Ref. Task Name Task Detail When Resulting Information Method Completion Events 4B.5 Market participant re-submits revised plans/timetables. 4B.6 IESO informs market participant of acceptability of revised plans, and informs market participant to proceed. 4B.7 Market participant implements mitigation plan. 4B.8 Market participant submits periodic status reports to IESO until completion of mitigation activities. 4B.9 IESO reviews status of mitigation activities against agreed corrective measures and due date. Market participant modifies plan/timetable to correct errors or omissions and sends revised plan/timetable to IESO. IESO sends notification of acceptability of plan and advises market participant to proceed. Market participant puts plan into effect. Market participant sends monthly reports to IESO. IESO continually review market participant s mitigation activities. Market participant submits revised plan/timetable within two business days of IESO s request. After assessment of plan acceptability in step 4B.3. After step 4B.6. As per template and plan milestones During Step 4B.8 Mitigation plan/timetable with errors or omissions resolved by market participant Indication of IESO approval to proceed with mitigation plan. Approved mitigation plan initiated. Periodic indications of plan status. Indications of completeness of market participant s mitigation activities. Letter, Fax or at: IRCP@ieso.ca Letter, Fax or As per mitigation plan Letter, Fax or at: IRCP@ieso.ca Assessment IESO in receipt of corrected plan/timetable. Market participant in receipt of IESO approval to proceed with plan/timetable. Mitigation plan underway IESO in receipt of status of mitigation plan. IESO assessment that mitigation plan will or will not be completed as approved and on time. If not completed, proceed to Event 6B.01 in Fig 2-2 of Market Manual 2.6. Issue 5.0 September 13, 2006 Public 17

26 3. Procedural Steps IMO_PRO_0033 Ref. Task Name Task Detail When Resulting Information Method Completion Events 4B.10 IESO inform market participant of IESO concurrence with completion of mitigation plans 4B.11 IESO reports results to NPCC and the IESO Board of Directors. If IESO assessment in Step 4B.9 is that market participant has completed the mitigation plan as required, IESO will send the market participant an acknowledgement of completion. IESO will perform routine reliability performance assessment in next template, as per Fig 2-1 and Table 3-1. Reports submitted in accordance with NPCC and IESO reporting requirements. After favorable assessment in Step 4B.9 that mitigation plan has been successfully completed. As required by NPCC and the IESO Board of Directors. Indication to market participant that IESO deems the mitigation activities are completed as per originally agreed plan/timetable. Indication of the mitigation plans/schedules that are underway in Ontario, and their status. Letter, Fax, or In accordance with NPCC and IESO reporting requirements. Market participant in receipt of IESO confirmation of completion of mitigation plan. NPCC and the IESO Board of Directors in receipt of information on mitigation plans/schedules in Ontario. End of Section 18 Public Issue 5.0 September 13, 2006

27 Part 7.9: Reliability Compliance Program Appendix A: Forms Appendix A: Forms There are no forms for this procedure. End of Section Issue 5.0 September 13, 2006 Public A 1

28 Appendix A: Forms IMO_PRO_0033 A 2 Public Issue 5.0 September 13, 2006

29 Part 7.9: Reliability Compliance Program Appendix B: Historical Background Appendix B: Historical Background Over the past number of years the electrical power system industry in North America has been evolving from vertically integrated to competitive, market driven structures. The North American Electric Reliability Council (NERC), and its Regional Councils, have emphasized the importance of maintaining the reliability of the electrical power systems during and following this transition To maintain this focus on reliability, NERC reviewed and modified its reliability standards, and strengthened the reliability compliance requirements. As part of this initiative, NERC defined key reliability compliance standards and measures. NERC also stipulated the organizations within the industry responsible for achieving, assessing, enforcing and reporting on compliance. In January 1998, NERC initiated a program for compliance and enforcement of its reliability standards among all members of NERC. This program, called the NERC Pilot Compliance Program, has four phases with Phase I initiated in The Northeast Power Coordinating Council (NPCC - a member of NERC) introduced a reliability compliance program of its own in accordance with the NERC Pilot Compliance Program. In addition, NPCC formed a subcommittee to manage reliability compliance among its members (Ontario is a member of NPCC). The NERC compliance program as it affects Ontario is largely conducted by NPCC through its reliability compliance programs (the Program). The annual NPCC compliance program include the requirements of the NPCC reliability compliance and enforcement program (RCEP) and compliance monitoring requirements of the NPCC reliability assessment program (NRAP). As part of the Program, NPCC annually adopts the NERC compliance enforcement program (CEP). The NPCC Compliance Monitoring and Assessment Subcommittee (CMAS) and its Enforcement Panel (EP) were established to develop processes and perform compliance monitoring, assessment and enforcement among the NPCC Control Areas. CMAS assigned to each Control Area responsibility for developing their own processes for monitoring and enforcing reliability compliance, including reporting to NPCC to those criteria and standards for which the control areas have the reporting responsibility. The IESO as the Ontario control area holds this responsibility. In addition, NPCC has identified that the market participants within each Control Area are accountable for reporting on the reliability standards in the templates. The NPCC program is designed with the concept that compliance assessment and enforcement is most effectively accomplished by the entities that are closest to the complying party. The following assessment model was established for the NPCC compliance program: NERC assesses and enforces compliance to those standards for which the Regions have the reporting responsibilities; NPCC assesses and enforces compliance to those standards for which the control areas have the reporting responsibilities; and The control areas assess and enforce compliance to those standards for which the control area market participants have reporting responsibility; Issue 5.0 September 13, 2006 Public B 1

30 Appendix B: Historical Background IMO_PRO_0033 During evolution of the NERC and NPCC Programs, the IESO as the Ontario control area operator has adopted and customized NERC, NPCC and IESO specific programs for application in Ontario. The IESO continually evolves the IESO Reliability Compliance Program (IRCP) to ensure a safe and reliable integrated power system infrastructure for effective and efficient operation of the Ontario electricity markets. The IESO Reliability Compliance Program defines the processes and provides the mechanisms for aligning with and assuring that the reliability requirements of NERC and NPCC and the province of Ontario are met. These reliability requirements are embedded in the market rules for the Ontario Electricity Market. The IESO introduced its 2001 Reliability Compliance Program at a February 13, 2001 workshop sponsored by NPCC. This Program is enforceable under the authority of Energy Act (1998) and the Market Rules. IESO's Program received unanimous NPCC approval on November 9, 2000, which marked the first application of enforceable NERC and NPCC reliability compliance and enforcement programs in Ontario. The IESO Program initially established eight specific enforceable reliability standards. Since its inception though, additional standards and criterion have subsequently been added, as appropriate, with some 45 plus reliability standards and criterion covering aspects of reliability through power system planning and operation, now assessed annually. The IESO reliability compliance program requirements are reviewed and updated annually to capture changes in the NPCC RCEP, NRAP programs and the NERC CEP program respectively as well as changes to /addition of IESO specific requirements. Based on the sets of requirements selected for the annual programs, the IESO then publishes its IRCP program reporting requirements, schedules and responsibilities on the IRCP page of the IESO web page. Moreover, IESO reliability related information requirements, set forth in the market rules, are listed in Market Manual 7: System Operations. Part 7.5: Reliability Information Catalogue. Reliability Information Catalogue is designed to advise market participants on the reliability-related information requirements and needs, and to assist them in meeting their obligations for maintaining the reliability of the IESO-controlled grid. The IESO Reliability Compliance Program is designed to ensure compliance with NERC, NPCC and IESO reliability standards in the Ontario Control Area. This Program identifies, catalogues and proceduralizes the reliability compliance and enforcement requirements in one Ontario location. It is aligned with the obligations and accountabilities assigned to various classes of market participants defined in the Market Rules and the Electricity Act (1998). Business procedures supporting the reliability compliance obligations set forth in the market rules, and in the various NERC, NPCC and IESO reliability compliance programs, are being carried out by way of the Market Manual 7.9: Reliability Compliance Program. An updated Web site version of IESO Reliability Compliance Program provides the information on the Reliability Compliance Program and the related background material. This is available on the IESO Web site: ( In order to facilitate market participants in the submission of the IESO reliability compliance related information and associated data, a dedicated link to the IESO Reliability Compliance Program has been established for electronically ing the information via IRCP@ieso.ca. B 2 Public Issue 5.0 September 13, 2006

31 Part 7.9: Reliability Compliance Program Appendix B: Historical Background End of Section Issue 5.0 September 13, 2006 Public B 3

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33 Part 7.9: Reliability Compliance Program References References Document Title Electricity Act, 1998 Market Manual 2: Market Administration, Part 2.6: Treatment of Compliance Issues Market Manual 7: System Operations. Part 7.5: Reliability Information Catalogue Market Rules for the Ontario Electricity Market Agreement For Regional Compliance And Enforcement Programs (February 13, 2001). Document ID n/a MDP_PRO_0022 IMP_CAT_0001 MDP_RUL_0002 NERC NPCC Reliability Compliance and Enforcement Program NPCC A-8 NPCC Guidelines for the Implementation of the Reliability Compliance and Enforcement Program (RCEP) NPCC B-22 Review Process for NPCC Reliability Compliance Program NPCC C-32 NPCC Membership Agreement (November 9, 2000) NPCC - End of Document - Issue 5.0 September 13, 2006 Public References 1