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Download Stakeholder Comment and Replies Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Alberta Reliability Standard
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Stakeholder Comment and Replies Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Alberta Reliability Standard – Alberta PRC-023-AB-1 Draft 2.1-Transmission Relay Loadability Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: 2011-09-28 2011-09-28 through 2011-10-21 COMPARISON BETWEEN NERC PRC-023-1 AND CURRENT ALBERTA PRC-023-AB-1 TRANSMISSION RELAY LOADABILITY NERC PRC-023-1 Purpose Protective relay settings shall not limit transmission loadability; not interfere with system operators’ ability to take remedial action to protect system reliability and; be set to reliably detect all fault conditions and protect the electrical network from these faults. Alberta PRC-023-AB-1 Draft 2 1 (From previous consultation) Purpose The purpose of this reliability standard is to ensure the protective relay settings do not limit transmission loadability, do not interfere with system operators ability to take remedial action to protect system reliability and, are set to reliably detect all fault conditions and protect the electrical network from these faults. Alberta PRC-023-AB-1 Draft 2.1 (Revised version for reconsultation) Purpose The purpose of this reliability standard is to ensure the protective relay settings do not limit transmission loadability, do not interfere with an operator’s ability to take remedial action to protect the reliability of the system, and are set to reliably detect all fault conditions and protect the electrical network from these faults. Differences between Alberta PRC-023-AB-1 Draft 2.1 and NERC PRC-023-1 New Stakeholder Comments (Insert comments here) AESO Replies AltaLink Clarified the purpose to align with the content of proposed PRC-023-AB-1 Draft 2.1. 1. AltaLink notes that this standard includes requirements which define certain guidelines for protection system settings (e.g. R1.12 requires the line protection MTA to be set to 90 degrees or maximum allowed by the relay manufacturer). AltaLink is seeking clarification as to whether or not this standard will be referenced in the AESO Protection Rules. 1. In accordance with the AESO’s Alberta reliability standards drafting principles, proposed ISO rules Section 502.3 Interconnected Electric System Protection Requirements will not duplicate authoritative content in proposed PRC-023-AB-1 Draft 2.1 and result in a “double jeopardy” situation. However, a note will be added in Information Document # 2012-004R 1 This column is for information only. 2012-09-06 AESO Reply Matrix PRC-023-AB-1 SCCR 08-30-2012 - Final.doc Protection System Information to ensure that market participants are aware of proposed PRC023-AB-1 Draft 2.1. AESO Replies to Stakeholder Comments: 2012-09-06 Page 2 of 23 ENMAX 2. Clarification: Will this standard supersede the NERC 8a standard for loadability, or will both s-Atandards be effective simultaneously? Applicability 4.1. Transmission Owners with load-responsive phase protection systems as described in Attachment A, applied to facilities defined below: 4.1.1 Transmission lines operated at 200 kV and above. 4.1.2 Transmission lines operated at 100 kV to 200 kV as designated by the Planning Coordinator as critical to the reliability of the Bulk Electric System. 4.1.3 Transformers with low voltage terminals connected at 200 kV and above. 4.1.4 Transformers with low Applicability This reliability standard applies to: TFOs with load-responsive phase protection systems, as described in Attachment A, and with any of the facilities defined below: o transmission lines operated at 200 kV and above. o transmission lines operated at 100 kV to 200 kV as identified by the ISO as critical to the reliability of the BES as required in requirement AESO Replies to Stakeholder Comments: 2012-09-06 Applicability This reliability standard applies to: (a) the legal owner of a transmission facility, (b) legal owner of a generating unit (c) legal owner of an aggregated generating facility with load-responsive phase protection systems, as described in Appendix 1 applied to any one of the facilities defined below: (i) transmission lines operated at 200 kV and above; 2. Proposed PRC-023AB-1 Draft 2.1 ensures that protection settings do not limit a facilities rating. NERC standard FAC-008-3 Facility Ratings (“NERC FAC-008-3”) ensures that facilities are properly determined. The AESO will review NERC FAC-008-3 as a separate initiative and adopt it for Alberta as appropriate. In the US both standards are effective. 3. Please refer to requirement R6 of proposed PRC-023AB-2 Protection and Control Transmission Relay Loadability (“PRC-023-AB-2”) and Information Document # 2012004RS PRC-023-AB R6 Identified Transmission Lines and Transformers, being consulted on separately, as they address the identified concerns. AltaLink The terms used to describe applicable entities in proposed PRC-023-AB-1 Draft 2.1 have been amended from the NERC version in order to correctly identify the applicable entities in Alberta and to align with terms included in the AESO’s Consolidated Authoritative Documents Glossary. New Amended Deleted The Applicability section in proposed PRC023-AB-1 Draft 2.1 has been amended to identify the responsible entities in Alberta. The legal owner of an electric distribution system was not included as all facilities in Alberta that apply to proposed PRC-023-AB-1 3. AltaLink recommends that the AESO include wording to the effect “as identified in the list as required in requirement R3, as published by the ISO on the AESO website and as amended from time to time by the ISO on notice to market participants;” and a direct reference to the name of the document containing the list be included in this standard (e.g. “ID# …”) for clarity. ATCO Power Page 3 of 23 voltage terminals connected at 100 kV to 200 kV as designated by the Planning Coordinator as critical to the reliability of the Bulk Electric System. 4.2. Generator Owners with load-responsive phase protection systems as described in Attachment A, applied to facilities defined in 4.1.1 through 4.1.4. 4.3. Distribution Providers with load-responsive phase protection systems as described in Attachment A, applied according to facilities defined in 4.1.1 through 4.1.4., provided that those facilities have bi-directional flow capabilities. 4.4. Planning Coordinators. R3. o transformers with low voltage terminals connected at 200 kV and above. o transformers with low voltage terminals connected at 100 kV to 200 kV as designated by the ISO as critical to the reliability of the BES. ISO (ii) transmission lines operated at 100 kV to 200 kV as identified by the ISO as critical to the reliability of the bulk electric system as required in requirement R3; (iii) transformers with low voltage terminals connected at 200 kV and above; or (iv) transformers with low voltage terminals connected at 100 kV to 200 kV as designated by the ISO as critical to the reliability of the bulk electric system as required in requirement R3; and (d) the ISO. Draft 2.1 are managed by a legal owner of a transmission facility, the legal owner of a generating unit, or legal owner of an aggregated generating facility. 4. ATCO Power suggests that legal owner of a generating unit and legal owner of an aggregated generating facility be removed from the applicability section of this standard. The removal of these entities would be consistent with the findings of NERC Order 733 which states in paragraph 342: The Reliability Standard applies to facilities 100 kV and above and to transformers with lowvoltage terminals 200 kV and above. Because there are no commercial generators with a terminal voltage as high as 100 kV and all generator step-up and auxiliary power transformers have lowvoltage windings well below 200 kV, PRC023-1 excludes generators and all generator step-up and auxiliary transformers. Therefore, no generator owner that is not also a transmission owner and/or a distribution provider will be subject to PRC-023-1. 4. In Alberta, legal owner of a generating unit and legal owner of an aggregated generating facility may own the switch yard and associated transmission line protections. As such, proposed PRC-023AB-1 Draft 2.1 must also apply to legal owners of generating units and aggregated facilities that own switch yards and associated transmission line protections. Please refer to the applicability section of proposed PRC-023AB-2as its requirements have been revised and, in the AESO’s opinion, address this concern. Furthermore, it is clear AESO Replies to Stakeholder Comments: 2012-09-06 Page 4 of 23 from item 3.4 in Attachment A that generating unit protection relays are excluded. Suncor Energy AESO Replies to Stakeholder Comments: 2012-09-06 5. For this standard, where exactly does the jurisdiction of generation facility owner ends and where does the jurisdiction of transmission facility owner begins? Suncor is especially concerned as much of the protection systems overlap. 5. In Alberta either a legal owner of a generating unit, legal owner of an aggregated generating facility, or legal owner of a transmission facility may own the transmission line protection systems. The responsibility of complying with proposed PRC-023AB-1 Draft 2.1 is placed upon the owner of those protection systems. 6. (ii): What are AESO’s guidelines for selection? Assuming AESO chooses to add an existing line to this category, will compliance requirements be retroactive? 6. The AESO’s guidelines for selection have been identified in proposed PRC-023-AB-2. Compliance will not be retroactive for existing transmission lines added to this category by the AESO. 7. (iv): What criteria will 7. Please see AESO Page 5 of 23 Effective Date 5.1. Requirement 1, Requirement 2: 5.1.1 For circuits described in 4.1.1 and 4.1.3 above (except for switch-on-to-fault schemes) —the beginning of the first calendar quarter following applicable regulatory approvals. 5.1.2 For circuits described in 4.1.2 and 4.1.4 above (including switch-on-to-fault schemes) — at the beginning of the first calendar quarter 39 months following applicable regulatory approvals. 5.1.3 Each Transmission Owner, Generator Owner, and Distribution Provider shall have 24 months after being notified by its Planning Coordinator pursuant to R3.3 to comply with R1 (including all subrequirements) for each facility that is added to the Planning Coordinator’s critical facilities list determined pursuant to R3.1. 5.2. Requirement 3: 18 months following applicable regulatory Effective Date For requirements R1 and R2 for transmission lines operated at 200kV and above and transformers with low voltage terminals connected at 200kV and above, except for switchon-to-fault schemes, the beginning of the first calendar quarter following ninety (90) days after the date of approval by the Commission. For requirements R1 and R2 for transmission lines operated at 100 kV to 200 kV as identified by the ISO as critical to the reliability of the BES and transformers with low voltage terminals connected at 100 kV to 200 kV as designated by the ISO as critical to the reliability of the BES, including switch-on-tofault schemes, on the first day th of the month after the 39 full month following the date of approval by the Commission. Requirement R3, the first day of th the month after the 18 full month following the date of approval by the Commission. AESO Replies to Stakeholder Comments: 2012-09-06 Effective Date For requirements R1 and R2 for transmission lines operated at 200kV and above and transformers with low voltage terminals connected at 200kV and above, except for switch-onto-fault schemes, on October 1, 2012. For requirements R1 and R2 for transmission lines operated at 100 kV to 200 kV as identified by the ISO as critical to the reliability of the bulk electric system and transformers with low voltage terminals connected at 100 kV to 200 kV as designated by the ISO as critical to the reliability of the bulk electric system, including switch-on-to-fault schemes, on July 1, 2015. Requirement R3, on January 1, 2014. New Amended Deleted The proposed effective date has been amended to October 1, 2012 in proposed PRC-023-AB-1 Draft 2.1 to allow a reasonable amount of time for Alberta entities to implement proposed PRC-023-AB-1 Draft 2.1. AESO used to determine this selection? Suncor currently has one transformer that fits the voltage guideline dictated. Will this transformer be selected for this requirement? AltaLink Reply 6 above. 8. AltaLink recommends R1 and R2 for transmission facilities at 100 kV to 200 kV as identified by the ISO as critical to the reliability of the bulk electric system become effective January 1, 2015 to be consistent with the timeframe required in R4. R4 allows market participants 2 years to be compliant with R1 after the addition of new lines to the list of critical lines between 100kV and 200kV. The proposed staggered approach allows for only 1.5 years after the initial list of critical lines has been compiled as per R3. ATCO Power 8. Please refer to proposed PRC-023AB-2 as the effective dates have been revised to allow for a reasonable amount of time for market participants to implement the requirements. 9. If the intention of this standard is to include generator interconnections 9. Please see AESO Reply 8 above. Page 6 of 23 approvals. facilities, given that some generator interconnection lines operate at more than 200 kV, and are sole use facilities for the purpose of connecting generating units to the AIES, changes to protection settings of these lines must be coordinated with unit turnaround schedules. Complying with the date of October 1, 2012 may be problematic if changes to these lines’ settings are required. ATCO Power suggests that the effective date be changed to July 1, 2015 for R1 and R2 regardless of voltage, for such circumstances. EDTI 10. EDTI recommends that all effective dates for this standard be consistent with requirement R4 for newly added facilities to the ISO’s critical facility list. Under requirement R4, newly added facilities to the critical facility list are permitted 2 years to comply with requirement R1. 11. For facilities 200kV AESO Replies to Stakeholder Comments: 2012-09-06 10. Please see AESO Reply 8 above. 11. Please see AESO Reply 8 above. Page 7 of 23 and above, EDTI recommends an effective date of 2 years after approval by the AUC. 12. For facilities operated between 100kV and 200kV that are designated by the ISO as critical to the BES, EDTI recommends that the effective date remains as stipulated in requirement R4, 2 years after being added to the ISO’s critical facilities list. Suncor Energy R1 . Each Transmission Owner, Generator Owner, and Distribution Provider shall use any one of the following criteria (R1.1 through R1.13) for any specific circuit terminal to prevent its phase protective relay settings from limiting transmission system loadability while maintaining reliable protection of the Bulk Electric System for all fault conditions. Each Transmission Owner, Generator Owner, and Distribution Provider shall evaluate relay loadability at 0.85 per unit voltage and a power factor angle of 30 degrees: [Violation Risk Factor: High] [Mitigation Time Horizon: Long Term Planning]. R1 Each TFO must use one of the criteria set out in requirements R1.1 through R1.13, inclusive, for each of its specific circuit terminals to prevent its phase protective relay settings from limiting transmission system loadability while maintaining reliable protection of the BES for all fault conditions; and evaluate relay loadability at 0.85 per unit voltage and a power factor angle of 30 degrees. AESO Replies to Stakeholder Comments: 2012-09-06 R1 Each legal owner of a transmission facility, legal owner of a generating unit and legal owner of an aggregated generating facility must use one of the criteria set out in requirements R1.1 through R1.13, inclusive, for each specific circuit terminal to prevent its phase protective relay settings from limiting transmission system loadability while maintaining reliable protection of the bulk electric system for all fault conditions and evaluate the above relay’s loadability at 0.85 per unit voltage and a power factor angle of 30 degrees. New Amended Deleted NERC requirement R1 has been amended for clarity and consistency and to identify the responsible entities in Alberta. NERC sub-requirements R1.3.1 and R1.3.2 have been amended in proposed PRC-023AB-1 Draft 2.1 to reflect their interrelationship. 12. Please see AESO Reply 8. No Comments AltaLink 13. AltaLink requests further clarity be added on R1.12. It is not clear which apparent impedance the AESO is referring to. Typically, if there is concern between line protection and line load capabilities, it is with the Zone 3 reach of the line protection. Is the AESO recommending that the zone reach causing concern be set to 125% of the apparent impedance of the line in question which could possibly 13. Yes, the impedance referred to is the line impedance. Pursuant to the requirement, if the transmission line capability is limited by protection then a setting of 125% is required subject to the three sub-conditions. Page 8 of 23 R1.1. Set transmission line relays so they do not operate at or below 150% of the highest seasonal Facility Rating of a circuit, for the available defined loading duration nearest 4 hours (expressed in amperes). R1.2. Set transmission line relays so they do not operate at or below 115% of the highest seasonal 15-minute 2 Facility Rating of a circuit (expressed in amperes). 2 When a 15-minute rating has been calculated and published for use in real-time operations, the 15-minute rating can be used to establish the loadability requirement for the protective relays. R1.1. Set transmission line relays so they do not operate at or below 150% of the highest seasonal facility rating of a circuit for the available defined loading duration nearest to four hours, expressed in amperes; R1.1. Set transmission line relays so they do not operate at or below 150% of the highest seasonal facility rating of a circuit for the available defined loading duration nearest to four (4) hours, expressed in amperes; R1.2. Set transmission line relays so they do not operate at or below 115% of the highest seasonal 15-minute facility rating of a transmission line expressed in amperes; R1.2. Set transmission line relays so they do not operate at or below 115% of the highest seasonal 15-minute facility rating of a circuit expressed in amperes; lead to a reduction in the desired zone reach? ATCO Power 14. R1.1: Please confirm that R1.1 applies to the transmission circuit thermal ratings and not the generator nameplate rating. Please verify that R1.1. refers to the transmission facility and not the generating facility. 14. Alberta requirement R1.1 applies to the transmission line. ATCO Power R1.3. Set transmission line relays so they do not operate at or below 115% of the maximum theoretical power transfer capability (using a 90degree angle between the sending-end and receiving-end voltages and either reactance or complex impedance) of the circuit (expressed in amperes) using one of the following to perform the power transfer calculation: R1.3. Set transmission line relays so they do not operate at or below 115% of the maximum theoretical power transfer capability (using a 90-degree angle between the sending-end and receiving-end voltages and either reactance or complex impedance) of the transmission line expressed in amperes, using one of the following to perform the power transfer calculation: R1.3. Set transmission line relays so they do not operate at or below 115% of the maximum theoretical power transfer capability, using a 90-degree angle between the sending-end and receiving-end voltages and either reactance or complex impedance, of the circuit expressed in amperes, using one of the following to perform the power transfer calculation: R1.3.1. An infinite source (zero source impedance) with a 1.00 per unit bus voltage at each R1.3.1. an infinite source (zero source impedance) with a 1.00 per unit bus voltage at each end R1.3.1. an infinite source, i.e. zero source impedance, with a 1.00 per unit bus voltage at AESO Replies to Stakeholder Comments: 2012-09-06 15. R1.6:Regarding R1.6, the requirement to ensure a 230% loadability margin for phase protection near generators is inconsistent with the loading philosophy used in the other options and appears to be misaligned with IEEE Std C37.1021006, the IEEE tutorial (95 TP 102), and the PSRC paper titled Performance of Generator Protection During Major System Disturbances, IEEE No. TPWRD-00370- 15. The AESO agrees with ATCO Power that this Alberta requirement differs from what was typically done in the past. For now, the AESO intends to adopt NERC’s requirement unless a specific reason is put forward regarding why it can’t be applied in Alberta. Page 9 of 23 end of the line. of the transmission line; or each end of the transmission line; or R1.3.2. An impedance at each end of the line, which reflects the actual system source impedance with a 1.05 per unit voltage behind each source impedance. R1.3.2. an impedance at each end of the transmission line, which reflects the actual system source impedance with a 1.05 per unit voltage behind each source impedance. R1.3.2. an impedance at each end of the transmission line, which reflects the actual system source impedance with a 1.05 per unit voltage behind each source impedance. R1.4. Set transmission line relays on series compensated transmission lines so they do not operate at or below the maximum power transfer capability of the line, determined as the greater of: - 115% of the highest emergency rating of the series capacitor. - 115% of the maximum power transfer capability of the circuit (expressed in amperes), calculated in accordance with R1.3, using the full line inductive reactance. R1.4. Set transmission line relays on series compensated transmission lines so they do not operate at or below the maximum power transfer capability of the transmission line, determined as the greater of: 115% of the highest emergency rating of the series capacitor, or 115% of the maximum power transfer capability of the transmission line (expressed in amperes), calculated in accordance with requirement R1.3, using the full transmission line inductive reactance; R1.4. Set transmission line relays on series compensated transmission lines so they do not operate at or below the maximum power transfer capability of the transmission line, determined as the greater of: (a) 115% of the highest emergency rating of the series capacitor, or (b) 115% of the maximum power transfer capability of the circuit (expressed in amperes), calculated in accordance with requirement R1.3, using the full transmission line inductive reactance; R1.5. Set transmission line relays on weak source systems so they do not operate at or below 170% of the maximum end-of-line three-phase fault magnitude (expressed in amperes). R1.5. Set transmission line relays on weak source systems so they do not operate at or below 170% of the maximum end-of-line three-phase fault magnitude, expressed in amperes; R1.5. Set transmission line relays on weak source systems so they do not operate at or below 170% of the maximum end-of-line three-phase fault magnitude, expressed in amperes; R1.6. Set transmission line relays applied on transmission lines connected to generation stations remote to load so they R1.6. Set transmission line relays applied on transmission lines connected to generating facilities remote to load so they R1.6. Set transmission line relays applied on transmission lines connected to a generating facility remote to load so they do AESO Replies to Stakeholder Comments: 2012-09-06 2003, which NERC’s application reference document, Determination and Application of Practical Relaying Loadiability Ratings Version 1, cites as a justification for this unusually conservative value. Based on NERC’s Technical Reference Document Power Plant and Transmission System Protection Coordination, Revision 1, NERC appears to be providing an unconventionally wide loadability margin to coordinate with exciter field forcing, but this is not clear from the standard, and may not be appropriate in the AIES. Suncor Energy 16. R1: What is the exact definition of BES for this specification? 16. BES is defined in the AESO’s Consolidated Authoritative Document Glossary located on the AESO website. Page 10 of 23 do not operate at or below 230% of the aggregated generation nameplate capability. do not operate at or below 230% of the aggregated generating unit(s) nameplate capability; not operate at or below 230% of the total nameplate capability of all the generating units at the generating facility; R1.7. Set transmission line relays applied at the load center terminal, remote from generation stations, so they do not operate at or below 115% of the maximum current flow from the load to the generation source under any system configuration. R1.7. Set transmission line relays applied at the load center terminal, remote from generating facilities, so they do not operate at or below 115% of the maximum current flow from the load to the generation source under any system configuration; R1.7. Set transmission line relays applied at the load center terminal, remote from a generating facility, so they do not operate at or below 115% of the maximum current flow from the load to the generation source under any system configuration; R1.8. Set transmission line relays applied on the bulk system-end of transmission lines that serve load remote to the system so they do not operate at or below 115% of the maximum current flow from the system to the load under any system configuration. R1.8. Set transmission line relays applied on the bulk system-end of transmission lines that serve load remote to the system so they do not operate at or below 115% of the maximum current flow from the system to the load under any system configuration; R1.8. Set transmission line relays applied on the systemend of transmission lines that serve load remote to the system so they do not operate at or below 115% of the maximum current flow from the system to the load under any system configuration; R1.9. Set transmission line relays applied on the load-end of transmission lines that serve load remote to the bulk system so they do not operate at or below 115% of the maximum current flow from the load to the system under any system configuration. R1.9. Set transmission line relays applied on the load-end of transmission lines that serve load remote to the BES so they do not operate at or below 115% of the maximum current flow from the load to the system under any system configuration; R1.9. Set transmission line relays applied on the load-end of transmission lines that serve load remote to the system so they do not operate at or below 115% of the maximum current flow from the load to the system under any system configuration; R1.10. Set transformer fault protection relays and transmission line relays on transmission lines terminated only with a transformer so that they do not operate at or below the greater of: R1.10. Set transformer fault protection relays and transmission line relays on transmission lines terminated only with a transformer so that they do not operate at or below the greater of: AESO Replies to Stakeholder Comments: 2012-09-06 R1.10. Set transformer fault protection relays and transmission line relays on transmission lines terminated only with a transformer so that they do not operate at or below the greater of: The typographical error made in Alberta requirement R1.10 of the previously proposed 17. In addition, can AESO clarify “shall evaluate relay loadability at 0.85 per unit voltage and a power factor angle of 30 degrees?” Does this mean assumption of 0.85pu voltage and 30 degrees load during loadability study? Does this requirement require Suncor to set our transmission relays according to 0.85pu voltage and 30 degrees load? 17. During system events, voltage depressions will occur. To meet these requirements, settings must be applied such that 0.85 per unit voltage does not cause a false trip. Load angles are assumed to be 30 degrees. 18. R1.1: Can AESO provide guidance on “nearest 4 hours?” Does relay settings have to be altered every 4 hours / every season? 18. The relay settings are to be based on the transmission lines four (4) hour rating not the short term emergency rating. At four (4) hours the AESO anticipates this will essentially be the steady state rating. 19. R1.2: Does this means AESO would require Suncor to reset all transmission relay every season? Can AESO define “15minute Facility Rating?” What if such data is not available? 19. As drafted, the legal owner is to use the highest seasonal rating such that the relay setting does not causes capacity constraints. By using the highest relay rating no season Page 11 of 23 - 150% of the applicable maximum transformer nameplate rating (expressed in amperes), including the forced cooled ratings corresponding to all installed supplemental cooling equipment. - 115% of the highest operator established emergency transformer rating. 115% of the applicable maximum transformer nameplate rating expressed in amperes, including the forced cooled ratings corresponding to all installed supplemental cooling equipment; or 115% of the highest operator established emergency transformer rating; (a) 150% of the applicable maximum transformer nameplate rating, expressed in amperes, including the forced cooled ratings corresponding to all installed supplemental cooling equipment; or (b) 115% of the highest established emergency transformer rating; R1.11. For transformer overload protection relays that do not comply with R1.10 set the relays according to one of the following: Set the relays to allow the transformer to be operated at an overload level of at least 150% of the maximum applicable nameplate rating, or 115% of the highest operator established emergency transformer rating, whichever is greater. The protection must allow this overload for at least 15 minutes to allow for the operator to take controlled action to relieve the overload. Install supervision for the relays using either a top oil or simulated winding hot spot temperature element. The setting should be no less than 100° C for the top oil or 140° C for the winding hot spot 3 temperature . 3 IEEE standard C57.115, Table 3, specifies that transformers are to be designed to withstand a R1.11. For transformer overload protection relays that do not comply with requirement R1.10 set the relays according to the following: Set the relays to allow the transformer to be operated at an overload level of at least 150% of the maximum applicable nameplate rating, or 115% of the highest emergency transformer rating, whichever is greater. The protection must allow this overload for at least 15 minutes to allow for the system operator to take controlled action to relieve the overload. Install supervision for the relays using either a top oil or simulated winding hot spot temperature element. The setting should be no less than 100°C for the top oil or 140°C for the winding hot spot temperature; R1.11. For transformer overload protection relays that do not comply with requirement R1.10 set the relays to allow the transformer to be operated at an overload level of at least 150% of the maximum applicable nameplate rating, or 115% of the highest emergency transformer rating, whichever is greater. The protection relay must allow this overload for at least fifteen (15) minutes to allow the system operator to take controlled action to relieve the overload. Install supervision for the relays using either a top oil or simulated winding hot spot temperature element. The setting should be no less than 100°C for the top oil or 140°C for the winding hot spot temperature; AESO Replies to Stakeholder Comments: 2012-09-06 PRC-023-AB-1 Draft 2 has been corrected in proposed PRC-023-AB-1 Draft 2.1 to reflect “150%” of the applicable maximum transformer nameplate rating which was incorrectly stated as “115%”. R1.3. Set transmission line relays so they do not operate at or below 115% of the maximum theoretical power transfer capability, using a 90-degree angle between the sending-end and receiving-end voltages and either reactance or complex impedance, of the circuit expressed in amperes, using one of the following to perform the power transfer calculation: R1.3.1. an infinite source, i.e. zero source impedance, with a 1.00 per unit bus voltage at each end of the transmission line; or R1.3.2. an impedance at each end of the transmission line, which reflects the actual system source impedance with a 1.05 per unit voltage behind each source impedance What is the rationale behind 115%? setting changes would be required. In Alberta, the legal facility owner is accountable for rating their facilities. The fifteen (15) minute rating is what some transmission facility owners have been providing as their emergency ratings. When the AESO reviews and implements NERC FAC-008-3 further detail regarding methodology will be developed. The 115% requirement provides 15% margin to ensure the settings do not restrict the lines capacity. 20. R1.3: Can AESO provide additional details such as diagrams to better explain the power transfer study described above. Does “90-degree angle between the sendingend and receiving-end voltages” indicates a phase shift of 90degree during transmission of each 20. R1.3 is intended to be a simple calculation using the theoretical maximum transfer limit. The following formula is the power transfer formula which may be used: P = V1 V2 sin (90)/ line X Page 12 of 23 winding hot spot temperature of 180 degrees C, and cautions that bubble formation may occur above 140 degrees C. phase? What significance does this implies if each phase is shifted by the same amount? R1.12. When the desired transmission line capability is limited by the requirement to adequately protect the transmission line, set the transmission line distance relays to a maximum of 125% of the apparent impedance (at the impedance angle of the transmission line) subject to the following constraints: R1.12. When the desired transmission line capability is limited by the requirement to adequately protect the transmission line, set the transmission line distance relays to a maximum of 125% of the apparent impedance (at the impedance angle of the transmission line) subject to the following constraints: R1.12. When the desired transmission line capability is limited by the requirement to adequately protect the transmission line, set the transmission line distance relays to a maximum of 125% of the apparent impedance (at the impedance angle of the transmission line) subject to the following constraints: R1.12.1. Set the maximum torque angle (MTA) to 90 degrees or the highest supported by the manufacturer. R1.12.1. Set the maximum torque angle (MTA) to 90 degrees or the highest setting supported by the manufacturer. R1.12.1. Set the maximum torque angle to ninety (90) degrees or the highest setting supported by the manufacturer. R1.12.2. Evaluate the relay loadability in amperes at the relay trip point at 0.85 per unit voltage and a power factor angle of 30 degrees. R1.12.2. Evaluate the relay loadability in amperes at the relay trip point at 0.85 per unit voltage and a power factor angle of 30 degrees; and R1.12.2. Evaluate the relay loadability in amperes at the relay trip point at 0.85 per unit voltage and a power factor angle of 30 degrees; and R1.12.3. Include a relay setting component of 87% of the current calculated in R1.12.2 in the Facility Rating determination for the circuit. R1.12.3. Include a relay setting component of 87% of the current calculated in requirement R1.12.2. in the facility rating determination for the circuit. R1.12.3. Include a relay setting component of 87% of the current calculated in requirement R1.12.2 in the facility rating determination for the circuit. R1.13. Where other situations present practical limitations on circuit capability, set the phase protection relays so they do not operate at or below 115% of such limitations. R1.13. Where other situations present practical limitations on circuit capability, set the phase protection relays so they do not operate at or below 115% of such limitations. R1.13. Where other situations present practical limitations on circuit capability, set the phase protection relays so they do not operate at or below 115% of such limitations. AESO Replies to Stakeholder Comments: 2012-09-06 An example would help eliminate any potential miscommunication regarding this requirement. 21. R1.4: Once again, will it be possible if AESO provide an example case study using the technique stated above. This will greatly assist in eliminating any inconstant assumptions from the original intent of AESO. 21. There are two series compensated lines planned in Alberta. The legal owners of these lines will need to determine the highest emergency rating of the series capacitor and the maximum power transfer capability of the circuit in order to meet this Alberta requirement R1.4. 22. R1.5: Can AESO provide definition on “weak source systems” and “maximum end ofline three-phase fault magnitude?” 22. The AESO does not intend to define this term as it is a commonly understood industry term. 23. R1.7: Please define “load center terminal.” 23. Please see AESO Reply 22 above. 24. R1.8 - 1.9: What is AESO’s definition of “load remote to the system?” 24. Please see AESO Reply 22 above. Page 13 of 23 AESO Replies to Stakeholder Comments: 2012-09-06 25. R1.12: Suncor requests AESO to define “distance relays.” Also, what is the requirement, if the impedance angle of the transmission line is not constant? 25. Please see AESO Reply 22 above. 26. R1.12.1: Suncor requests AESO to define maximum torque angle (MTA). 26. Please see AESO Reply 22 above. 27. R1.12.3: Suncor requests AESO to clarify this section. 27. Alberta requirement R1.12.3 requires a setting of 87% of the current rating calculated in Alberta requirement R1.12.2. Page 14 of 23 2 R2. The Transmission Owner, Generator Owner, or Distribution Provider that uses a circuit capability with the practical limitations described in R1.6, R1.7, R1.8, R1.9, R1.12, or R1.13 shall use the calculated circuit capability as the Facility Rating of the circuit and shall obtain the agreement of the Planning Coordinator, Transmission Operator, and Reliability Coordinator with the calculated circuit capability. [Violation Risk Factor: Medium] [Time Horizon: Long Term Planning] R2 A TFO that uses a circuit capability with the practical limitations described in requirements R1.6, R1.7, R1.8, R1.9, R1.12, or R1.13 must use the calculated circuit capability as the facility rating of the circuit and must obtain the agreement of the ISO to use the calculated circuit capability R2. A legal owner of a transmission facility, legal owner of a generating unit and legal owner of an aggregated generating facility that uses a circuit capability with the practical limitations described in requirements R1.6, R1.7, R1.8, R1.9, R1.12, or R1.13 must use the calculated circuit capability as the facility rating of the circuit and must obtain the agreement of the ISO to use the calculated circuit capability. New Amended Deleted R3. The Planning Coordinator shall determine which of the facilities (transmission lines operated at 100 kV to 200 kV and transformers with low voltage terminals connected at 100 kV to 200 kV) in its Planning Coordinator Area are critical to the reliability of the Bulk Electric System to identify the facilities from 100 kV to 200 kV that must meet Requirement 1 to prevent potential cascade tripping that may occur when protective relay settings limit transmission loadability. [Violation Risk R3. The ISO must identify which transmission lines operated at 100 kV to 200 kV and transformers with low voltage terminals connected at 100 kV to 200 kV are critical to the reliability of the BES in order to prevent potential cascade tripping that may occur when protective relay settings limit transmission loadability. In order to carry out this requirement, the ISO must do the following: R3. The ISO must identify which transmission lines operated at 100 kV to 200 kV and transformers with low voltage terminals connected at 100 kV to 200 kV are critical to the reliability of the bulk electric system in order to prevent potential cascading that may occur when protective relay settings limit transmission loadability. In order to carry out this requirement, the ISO must do the following: New Amended Deleted Suncor Energy NERC requirement R2 amended in proposed PRC-023-AB-1 Draft 2.1 to identify requirements of the responsible entities in Alberta. 28. R2: Suncor requests AESO to define or provide example of “out-of-step blocking elements.” 28. Please see AESO Reply 22 above. 2 Alberta Variance : The WECC Reliability Coordinator is not included in Alberta requirement R2. NERC requirement R2 states that agreement shall be obtained from the Planning Coordinator, Transmission Operator, and Reliability Coordinator. The AESO is the authority from which legal owners of transmission facilities, generating units and aggregated generating units will obtain agreement for the calculated circuit capability and the AESO will consult with the WECC Reliability Coordinator at its discretion. NERC requirement R3 has been amended in proposed PRC-023-AB-1 Draft 2.1 for clarity, consistency and to identify requirements of the responsible entities in Alberta. AltaLink 29. 5. Same comments as in the Applicability section. 29. Please AESO Reply 3 above. Deleted redundant NERC requirement in R3 that states, “These identified facilities must meet requirement R1” from Alberta requirement in proposed PRC-023-AB-1 Draft 2.1. An Alberta variance is a change from the US Reliability Standard that the AESO has determined is material. AESO Replies to Stakeholder Comments: 2012-09-06 Page 15 of 23 Factor: Medium] [Time Horizon: Long Term Planning] R3.1. The Planning Coordinator shall have a process to determine the facilities that are critical to the reliability of the Bulk Electric System. R3.1 The ISO must have a process to determine the facilities that are critical to the reliability of the BES and must consider input from adjoining planning coordinators and affected reliability coordinators. R3.1 The ISO must have a process to determine the facilities that are critical to the reliability of the bulk electric system and must consider input from adjoining planning coordinators and affected reliability coordinators. R3.2. The Planning Coordinator shall maintain a current list of facilities determined according to the process described in R3.1. R3.2 The ISO must maintain a current list of facilities determined according to the process specified in requirement R3.1. R3.2 The ISO must maintain a current list of facilities determined according to the process specified in requirement R3.1. R3.3. The Planning Coordinator shall provide a list of facilities to its Reliability Coordinators, Transmission Owners, Generator Owners, and Distribution Providers within 30 days of the establishment of the initial list and within 30 days of any changes to the list. R3.3 The ISO must provide a list of facilities maintained pursuant to requirement R3.2 to each TFO within 30 days of the establishment of the initial list and within 30 days of any changes to the list. R3.3 The ISO must provide a list of facilities maintained pursuant to requirement R3.2 to each legal owner of a transmission facility, legal owner of a generating unit and legal owner of an aggregated generating facility on such list within thirty (30) days of the establishment of the initial list and within thirty (30) days of any changes to the list. R4 TFOs must comply with requirement R1 for all new facilities added to the ISO’s list of facilities within 2 years of receipt from the ISO as contemplated in requirement R3.3 R4 The legal owner of a transmission facility, legal owner of a generating unit and legal owner of an aggregated generating facility must comply with requirement R1 for all facilities added to the ISO’s list of facilities, as contemplated in requirement R3.3, within two (2) years of receipt of such list. AESO Replies to Stakeholder Comments: 2012-09-06 New Amended Deleted Alberta requirement R4 added to in proposed PRC-023-AB-1 Draft 2.1 to address timelines for responsible entities to meet Alberta requirement R1 for new facilities added to the AESO list of facilities. This is consistent with the timelines in the effective date section of Capital Power 30. Capital Power appreciates the opportunity to comment on the proposed reliability standard. Capital Power notes that the level of impact 30. The AESO disagrees with Capital Power’s suggested amendment. Once a transmission line or transformer is identified as being important to the system, the AESO Page 16 of 23 the NERC reliability standard. for implementing this standard would require a comparison of the existing relay settings against those listed in Requirements R1.1 to R1.13. Evaluation of a setpoint modification required to conform with R1.1 to R1.13 and whether the existing relay could be modified, or if replacement would be required. The modifications may also require an outage, which may or may not fall within the timeline set by the AESO, and a facility’s current planned outage schedule and reevaluation of the protection system coordination. Capital Power requests the following wording to assist in managing the complexity of this implementation: believes that two (2) years is adequate time to comply with these requirements. Please review Alberta requirement R6.1 of proposed PRC-023AB-2. R4 The legal owner of a transmission facility, legal owner of a generating unit and legal owner of an aggregated generating facility must comply with requirement R1 for all facilities added to the AESO Replies to Stakeholder Comments: 2012-09-06 Page 17 of 23 ISO’s list of facilities, as contemplated in requirement R3.3, within two (2) years of receipt of such list, or as may otherwise be agreed to by the ISO. Suncor Energy No Comments M1. The Transmission Owner, Generator Owner, and Distribution Provider shall each have evidence to show that each of its transmission relays are set according to one of the criteria in R1.1 through R1.13. (R1) MR1. The TFO must have evidence to show that each of its transmission relays is set according to one of the criteria in requirements R1.1 through R1.13. M2. The Transmission Owner, Generator Owner, and Distribution Provider with transmission relays set according to the criteria in R1.6, R1.7, R1.8, R1.9, R1.12, or R.13 shall have evidence that the resulting Facility Rating was agreed to by its associated Planning Coordinator, MR2 The TFO with transmission relays set according to the criteria in requirements R1.6, R1.7, R1.8, R1.9, R1.12, or R.13 must have evidence that the ISO agreed to the resulting facility rating. Records of actual settings are within acceptable tolerances of the applicable criteria in requirements R1.1 through R1.13. AESO Replies to Stakeholder Comments: 2012-09-06 MR1. Evidence of using one of the criteria identified in requirements R1.1 through R1.13 as required in requirement R1 exists. Evidence may include spreadsheets or summaries of calculations to show that each of its transmission relays is set in accordance with requirement R1. MR2. Evidence of using and obtaining the agreement to use the calculated circuit capability as required in requirement R2 exists. Evidence may include: (a) facility rating spreadsheets or facility rating database to show that the calculated circuit capability was used as the facility rating of the Suncor Energy No Comments ATCO Power 31. ATCO Power suggests deleting MR2 (a), as MR2 (b) (dated correspondence from ISO) is necessary and sufficient to show compliance with R2. Suncor Energy 31. Please review the measures in proposed PRC-023-AB-2. Page 18 of 23 Transmission Operator, and Reliability Coordinator. (R2) circuit; and (b) dated correspondence to show that the calculated circuit capability was agreed to by the ISO. No Comments M3. The Planning Coordinator shall have a documented process for the determination of facilities as described in R3. The Planning Coordinator shall have a current list of such facilities and shall have evidence that it provided the list to the appropriate Reliability Coordinators, Transmission Operators, Generator Operators, and Distribution Providers. (R3) MR3. The measures for requirement R3 are identified in the sub-measures below. MR3.1 Evidence of having a process and considering input as required in requirement R3.1 exists. Evidence may include a documented process and documentation to show input from adjoining planning coordinators and affected reliability coordinators were considered. Suncor Energy MR3.1 Written process exists which includes input from adjoining planning coordinators and affected reliability coordinators and is of sufficient detail to meet requirements specified in requirement R3.1. MR3.2 List is complete and up to date as specified in requirement R3.2. MR3.2 Evidence of maintaining a current list of facilities as required in requirement R3.2 exists. Evidence may include a list published on the AESO website which identifies the issue date, version, and revision history. MR3.3 Confirmation that the ISO provided the list as specified in requirement R3.3. MR3.3 Evidence of providing a list of facilities as required in requirement R3.3 exists. Evidence may include email or mail to appropriate recipients. MR4 Evidence of complying with requirement R1 as required in requirement R4 exists. Evidence may include spreadsheets or summaries of calculations to show that each facility added to the ISO’s list is set in AESO Replies to Stakeholder Comments: 2012-09-06 No Comments Suncor Energy No Comments Page 19 of 23 accordance with requirement R1 and the date the protective relay setting changed, if required. Compliance To view the compliance section D of the NERC reliability standard follow this link: http://www.nerc.com/files/PRC023-1.pdf The Alberta reliability standards do not contain a compliance section. Compliance with all Alberta reliability standards is completed in accordance with the Alberta Reliability Standards Compliance Monitoring Program, available on the AESO website at: http://www.aeso.ca/loadsettlement/17189.html Regional Differences Regional Differences Regional Differences None identified. None identified. None identified. Attachment A / Appendix 1 COMPARISON BETWEEN NERC PRC-023-1 AND CURRENT ALBERTA PRC-023-AB-1 TRANSMISSION RELAY LOADABILITY NERC PRC-023-1 3 Alberta PRC-023-AB-1 Draft 2 3 (From previous consultation) Alberta PRC-023-AB-1 Draft 2.1 (Revised version for reconsultation) Attachment A Appendix 1 Appendix 1 1. This reliability standard includes any protective functions which could trip with or without time delay, on load current, including but not limited to: 1.1. Phase distance. 1.2. Out-of-step tripping. 1.3. Switch-on-to-fault. 1.4. Overcurrent relays. 1.5. Communications aided protection schemes including but not limited to: 1. This reliability standard includes any protective functions which could trip with or without time delay, on load current, including but not limited to: 1.1. Phase distance. 1.2. Out-of-step tripping. 1.3. Switch-on-to-fault. 1.4. Overcurrent relays. 1.5. Communications aided protection schemes including but not limited to: 1.5.1 Permissive 1. This reliability standard includes any protective functions which could trip with or without time delay, on load current, including: 1.1. Phase distance; 1.2. Out-of-step tripping; 1.3. Switch-on-to-fault; 1.4. Overcurrent relays; and 1.5. Communications aided protection schemes including: Differences between Alberta PRC-023-AB-1 Draft 2.1 and NERC PRC-023-1 Stakeholder Comments (Insert comments here) AESO Replies Suncor Energy 32. A1: How far does the association reaches? Does this include low / medium voltage distribution assets? 32. The Appendix is to be used in conjunction with the Applicability section. This includes transmission lines operated at or above 200kV and those facilities below 200kV identified by the AESO. This column is for information only. AESO Replies to Stakeholder Comments: 2012-09-06 Page 20 of 23 COMPARISON BETWEEN NERC PRC-023-1 AND CURRENT ALBERTA PRC-023-AB-1 TRANSMISSION RELAY LOADABILITY NERC PRC-023-1 1.5.1 Permissive overreach transfer trip (POTT). 1.5.2 Permissive under-reach transfer trip (PUTT). 1.5.3 Directional comparison blocking (DCB). 1.5.4 Directional comparison unblocking (DCUB). Alberta PRC-023-AB-1 Draft 2 3 (From previous consultation) overreach transfer trip (POTT). 1.5.2 Permissive underreach transfer trip (PUTT). 1.5.3 Directional comparison blocking (DCB). 1.5.4 Directional comparison unblocking (DCUB). 2. This reliability standard includes out-of-step blocking schemes which must be evaluated to ensure that they do not block trip for faults during the loading conditions defined within this reliability standard’s requirements. 2. This reliability standard includes out-of-step blocking schemes which must be evaluated to ensure that they do not block trip for faults during the loading conditions defined within this reliability standard’s requirements. 3. The following protection systems are excluded from the requirements of this reliability standard: 3. The following protection systems are excluded from the requirements of this reliability standard: 3.1. Relay elements that are only enabled when other relays or associated systems fail. For example: • Overcurrent elements that are only enabled during loss of potential 3.1. Relay elements that are only enabled when other relays or associated systems fail. For example: • Overcurrent elements that are only enabled during loss of potential conditions; AESO Replies to Stakeholder Comments: 2012-09-06 Alberta PRC-023-AB-1 Draft 2.1 (Revised version for reconsultation) 1.5.1 Permissive overreach transfer trip; 1.5.2 Permissive under-reach transfer trip; 1.5.3 Directional comparison blocking; and 1.5.4 Directional comparison unblocking. 2. This reliability standard includes out-of-step blocking schemes such that that they do not block trip for faults during the loading conditions defined within the requirements of this reliability standard. 3. The following protection systems are excluded from the requirements of this reliability standard: 3.1. Relay elements that are only enabled when other relays or associated systems fail. For example: • Overcurrent elements that are only enabled during loss of potential Differences between Alberta PRC-023-AB-1 Draft 2.1 and NERC PRC-023-1 Stakeholder Comments (Insert comments here) 33. A1.1 - 1.5: Suncor requests AESO to provide the specific definition of the following: AESO Replies 33. Please see AESO Reply 22 above. Phase distance. Out-of-step tripping. Switch-on-to-fault. Communications aided protection schemes Permissive overreach transfer trip. Permissive under reach transfer trip. Directional comparison blocking. Directional comparison unblocking. 34. R3.3: Please define “stable power swings.” 35. R3.4: Please clarify by providing examples. 36. R3.6: Does this statement refer to relays which allows minimum of 15 34. Please see AESO Reply 22 above. 35. All generator protection systems will need to be reviewed by the legal owner. Examples may include any phase overcurrent or distance relay which would have to be closely examined. 36. Section 3.6 of Appendix 1 to relays Page 21 of 23 COMPARISON BETWEEN NERC PRC-023-1 AND CURRENT ALBERTA PRC-023-AB-1 TRANSMISSION RELAY LOADABILITY NERC PRC-023-1 conditions; or • Elements that are only enabled during a loss of communications. Alberta PRC-023-AB-1 Draft 2 3 (From previous consultation) or • Elements that are only enabled during a loss of communications. Alberta PRC-023-AB-1 Draft 2.1 (Revised version for reconsultation) conditions; or • Elements that are only enabled during a loss of communications. 3.2. Protection systems intended for the detection of ground fault conditions. 3.2. Protection systems intended for the detection of ground fault conditions. 3.2. Protection systems intended for the detection of ground fault conditions. 3.3. Protection systems intended for protection during stable power swings. 3.3. Protection systems intended for protection during stable power swings. 3.3. Protection systems intended for protection during stable power swings. 3.4. Generating unit protection relays that are susceptible to load. 3.4. Generating unit protection relays that are susceptible to load. 3.5. Relay elements used only for RASs applied and approved in accordance with reliability standards PRC-015AB-0, PRC-016-AB-0 and PRC-017-AB-0. 3.5. Relay elements used only for remedial action schemes identified in the ISO RAS database as published by the ISO on the AESO website, and as amended from time to time by the ISO on notice to market participants. 3.6. Protection systems that are designed only to respond in time periods which allow operators 15 minutes or greater to respond to overload conditions. 3.6. Protection systems that are designed only to respond in time periods which allow operators fifteen (15) minutes or greater to respond to 3.4. Generating unit protection relays that are susceptible to load. 3.5. Relay elements used only for Special Protection Systems applied and approved in accordance with NERC Reliability Standards PRC-012 through PRC-017. 3.6. Protection systems that are designed only to respond in time periods which allow operators 15 minutes or greater to respond to overload AESO Replies to Stakeholder Comments: 2012-09-06 Differences between Alberta PRC-023-AB-1 Draft 2.1 and NERC PRC-023-1 Stakeholder Comments (Insert comments here) minutes of overload before tripping? Or does the statement mean something else? Please clarify. 37. R3.7: Please clarify by providing example. AESO Replies that operate in fifteen (15) minutes or longer for overload conditions. 37. An examples would be where a transmission facility owner might use a SEL-049 relay and dynamically rate a transmission line. Page 22 of 23 COMPARISON BETWEEN NERC PRC-023-1 AND CURRENT ALBERTA PRC-023-AB-1 TRANSMISSION RELAY LOADABILITY NERC PRC-023-1 Alberta PRC-023-AB-1 Draft 2 3 (From previous consultation) conditions. Alberta PRC-023-AB-1 Draft 2.1 (Revised version for reconsultation) overload conditions. 3.7. Thermal emulation relays which are used in conjunction with dynamic Facility Ratings. 3.7. Thermal emulation relays which are used in conjunction with dynamic Facility Ratings. 3.7. Thermal emulation relays which are used in conjunction with dynamic facility ratings. 3.8. Relay elements associated with DC lines. 3.8. Relay elements associated with DC lines. 3.8. Relay elements associated with direct current lines. 3.9. Relay elements associated with DC converter transformers. 3.9. Relay elements associated with DC converter transformers. 3.9. Relay elements associated with direct current converter transformers. AESO Replies to Stakeholder Comments: 2012-09-06 Differences between Alberta PRC-023-AB-1 Draft 2.1 and NERC PRC-023-1 Stakeholder Comments (Insert comments here) AESO Replies Page 23 of 23