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Mandatory Reliability FAQ

    According to Policy Action #14 of the 2007 Energy Plan, all “owners, users and operators” of the bulk power system are potentially subject to mandatory reliability standards.  NERC has developed some general criteria to identify which industry participants are subject to which standards.  These groups are known as “functions” and within each function thresholds have been developed to capture those entities that are likely to have an impact on the reliability of the bulk power system.
    It should be noted that the above describes the industry approach developed by NERC and some variation in BC is possible.
    For example, the following criteria have been developed by NERC for Generator Owners or Operators based on their potential impact on the bulk power system:
    Generator owner/Generator Operator
    1. A individual generating unit greater than 20 MVA and directly connected to the bulk power system, or;
    2. A generating plant/facility greater than 75 MVA or an entity responsible for any facility consisting of one or more units that are connected to the bulk power system at a common bus with total generation above 75 MVA
    3. Any generator, regardless of size, that is a black start unit material to, and designated as part of, a transmission operator entity’s restoration plan
    4. Any generator, regardless of size, that is determined by the regional entity or CBRE to be material to the reliability of the bulk power system.
    For a description of other NERC functions, their definitions and a list of associated standards, please see Mandatory Reliability Definitions and Standards (link to definitions page)


    Radial lines serving only load with one transmission source are generally excluded from MRS. 


    The Energy Plan Policy Action 14 identifies the British Columbia Utilities Commission as the entity that will determine, set and enforce reliability standards in the province. 
    BC industry participants do not have to register with NERC or WECC, unless they are doing business in the United States.  The standards applicable to any user, owner and operator will be defined by the Commission.


    As defined in the Utilities Commission Act, the Commission currently has the authority to issue penalties of no more than $10,000 per day per offence. 


    For IPPs, forecast costs would be priced into the call bids.  What will be done, if anything, for IPPs that have existing contracts or for unexpected costs from new standards is still an open question.  Our work to date and our expectations are that the costs to existing IPPs for existing standards are relatively low.


    A: The current Standard Generation Interconnection Agreement requires IPPs to comply with Applicable Reliability Standards, which is defined as:
    Applicable reliability standards shall mean the requirements of and guidelines of NERC, WECC, the Applicable Reliability Council and the Control Area of the Transmission System.
    Therefore, IPPs should be aware that BC’s electricity policy contemplates adding new industry reliability standards and that BCTC’s interconnection agreements will require IPPs to comply with those standards, or others as may be determined in BC.


    MRS provides a clear set of approved performance standards, which should reduce the potential for inadvertent non-compliance.  It is not the purpose or intent of Mandatory Reliability Standards to change or re-assign liability among existing industry participants. 


    This will depend on what definition is adopted.  Many in the industry are pushing for the development of objective criteria that could be applied.  In this case, an IPP would know as they designed and developed their facility if they would be designated as “critical” or “material” to bulk system reliability. It is expected that NERC and/or WECC will continue to provide additional guidance as to the materiality and critical facility criteria through case decisions.  These decisions, as well as any other clarification of the terminology provided by NERC and/or WECC, would be of assistance in interpreting any similar criteria in the province of BC.

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