Entities subject to reliability standards may submit questions regarding current standards or instructions to the Reliability Coordinator.
These questions and the Reliability Coordinator’s answers are published here for information purposes. Please note that entities subject to reliability standards are solely responsible for ensuring their activities comply with these standards, and it is the Régie de l’énergie which is responsible for monitoring and enforcing compliance.
The answers provided below reflect the Reliability Coordinator’s interpretations, which are not necessarily approved or recognized by the Régie de l’énergie.
I have a question regarding CIP standards. We are the wind farm [name of wind farm], and I wonder whether we are exempt from CIP standards. Could you clarify what you mean by:
“no generating unit at the facility may be synchronized with a neighboring system”.
In the Québec context, the term “neighboring system” refers to a system outside the Québec Interconnection.
As wind farm owners and operators, we already send HQDAE a delivery schedule based on the hourly available power of our equipment in MW. This delivery schedule is then fed into a model developed by HQDAE, which calculates a generation output based on wind forecasts. Does this meet the requirement [R15 of the TOP-002-2.1b standard]?
NERC TOP-002-2.1b requirement R15 stipulates that wind farms must, at the request of the Balancing Authority or Transmission Operator, provide a forecast in accordance with the terms and conditions set out in schedule QC-TOP-002-2.1b.
Furthermore, since you send your delivery schedule to the HQDAE team, the latter already takes care of preparing the required forecasts and forwarding them to the Reliability Coordinator to allow it to perform its functions as Balancing Authority and Transmission Operator.
Thus, we do not currently ask wind farms to provide us with forecasts, neither in our role as Balancing Authority or as Transmission Operator.
Therefore, until further notice, you do not need to provide us with forecasts so long as you continue to send HQDAE your delivery schedule based on the hourly available power of your facilities.
Entities’ questions regarding compliance with MOD-025-2
Considering the large number of questions received regarding the effective date of MOD-025-2, the Reliability Coordinator has decided to publish its response on its Web site.
According to the implementation plan put forward by the North American Electric Reliability Council (NERC), registered entities have two calendar years between the adoption date and the first implementation date. Based on the US effective date proposed by NERC for the standard, the Reliability Coordinator recommended a first implementation date at least one year after its adoption by the Régie. In accordance with the consultation process approved by the Régie de l’énergie in decision D-2011-139, paragraph 63, the Reliability Coordinator held public consultation QC-2015-01 over a 60-day period (see the summary), soliciting registered entities’ comments on the relevance and impact of the MOD-025-2 standard. No entities commented on this matter.
In decision D-2017-110 paragraphs 378, 383 and 387, the Régie set January 1, 2018 as the first implementation date, giving about a three month delay. By this first standard implementation date, all registered entities must have verified at least 40 percent or 15 percent of their generating stations, depending on the type of connection to the Main Transmission System (RTP).
The Reliability Coordinator can neither express an opinion on the compliance of entities with reliability standards in effect, nor interpret the Régie’s decisions regarding entity compliance. In particular, the Reliability Coordinator cannot express an opinion on a given entity’s compliance with the implementation dates set out in decision D-2017-110. If entities wish to know how these dates are to be interpreted, they may contact the Compliance Monitor (secretariat-pscaq@regie-energie.qc.ca) and ask for clarifications regarding standard compliance deadlines.
The Reliability Coordinator has also received requests for clarifications regarding MOD-025-2 testing requirements. In particular, entities sought to find out how they might comply with the following point: “The first verification for each applicable Facility under this standard must be a staged test.” Entities wished to know whether they could use data from staged tests carried out prior to the effective date of the standard to meet this requirement. Again, the Reliability Coordinator cannot interpret a standard in effect or comment on an entity’s compliance with its requirements. Entities are responsible for validating their interpretation of the standard by communicating with the Compliance Monitor as suggested above.
In light of the Compliance Monitor’s interpretation, entities may request that the standard be revised. To do so, they may contact the Secretariat of the Régie (secretariat@regie-energie.qc.ca) to share their concerns and discuss any future steps.