Report of Comments on 118/46/CD
Circulation Date: 2014-12-26 / Closing Date: 2015-02-27
IEC 62746-10-2 Ed. 1.0 IEC 62746-10-2 Ed1: OASIS Energy Interoperation Version 1.0 Specification
Country / Status / Comments / Received
Australia / P
Austria / O / Y / 2015-02-26
Belarus / - / N / 2015-02-27
Belgium / - / N / 2015-02-03
Brazil / O / N / 2015-02-27
Canada / O / N / 2015-02-17
China / P / N / 2015-02-16
Czech Republic / O
Denmark / P
Egypt / P
France / P / Y / 2015-02-20
Germany / P / Y / 2015-02-27
Greece / - / N / 2015-02-26
India / P / N / 2015-01-02
Israel / O
Italy / P / N / 2015-02-26
Japan / P / N / 2015-02-17
Korea, Republic of / P / N / 2015-01-12
Luxembourg / O
Malaysia / O
Netherlands / O / N / 2015-02-10
Norway / O
Poland / P / N / 2015-02-27
Portugal / - / N / 2015-02-27
Romania / - / N / 2015-02-27
Russian Federation / P / N / 2015-02-27
Singapore / O
Slovenia / - / N / 2015-02-27
South Africa / O
Spain / P / N / 2015-02-27
Sweden / P
Switzerland / P / Y / 2015-02-26
United Kingdom / P / Y / 2015-02-11
United States of America / P
P-members / O-members / Non-members / Total
Y : comments received / 4 / 1 / 0 / 5
N : no comments / 8 / 3 / 6 / 17
- : no response / 5 / 7 / 0 / 12
Notes
P-members with no response: Australia; Denmark; Egypt; Sweden; United States of America
*Comments rejected because they were not submitted in the IEC Comment form.

Page 1 of 32

Date / Document / Project Nr.
118/46/CD
MB/NC / Line number
(e.g. 17) / Clause/ Subclause
(e.g. 3.1) / Paragraph/ Figure/ Table/
(e.g. Table 1) / Type of comment / Comments / Proposed change / Observations of the secretariat
AT1 / ge / The Austrian NC is strongly against the adoption of OASIS Energy Interoperation Version 1.0 Specification.
The OASIS Energy Interoperation Version 1.0 Specification used mainly in USA competes with the IEC standard series IEC 61970 and IEC 61768 defining the Common Information Model (CIM) as core standards for smart Grid.
AT2 / ge / The Austrian NC expects that IEC committees respect the work being carried out in the other groups of IEC and not try to define parallel standards.
Consistency of the standard framework is a major success factor of IEC. Especially in the domain of power system management and smart grid interoperability the confusion of the market by overlapping standards should be avoided.
Therefore adoption requests should be carefully analyzed if there are overlaps.
In this case the OASIS Energy Interoperation Version 1.0 overlaps with existing IEC standards or work in progress within TC 57.
AT3 / ge / The Austrian NC expects that PC118 considers TC57 “Principle for evaluating requests from parties external to the IEC” (57/1287/DC, 57/1345/INF) as the document from an external source obviously affects TC57 portfolio, program of work and reference architecture.
These principles have been endorsed by national committees.
AT4 / Copyright / Page 3 / ge / The Austrian NC expects that externaldocuments to be adopted by IEC are compliant to the Common Patent Policy for ITU-T/ITU-R/ISO/IEC / Clarification and Statement that the document is compliant to Common Patent Policy for ITU-T/ITU-R/ISO/IEC
AT5 / ge / The document uses extensively specifications and definitions of documents outside IEC standardisation (EMIX and TEMIX). / All references to EMIX and TEMIX specifications shall be replaced by appropriate IEC 61968, IEC 61970, IEC 62325 definitions
AT6 / 248 / 1.8 / 18 / ge / “This document relies on roles and interactions as defined in the OASIS Standard Reference Model for Service Oriented Architecture”. This is not compliant with the TC 57 reference architecture. / Needs to be harmonized with TC57 reference architecture, roles and interactions.
AT7 / 2023 / 13.3 / ge / Security requirements are referred through a external non IEC reference (PMRM). / A references to PMRB and security shall be replaced by appropriate IEC definitions
CH / The Swiss National Committee PK 118 does not support the integration of OASIS Interop into the family of IEC standards.
Reason:
Afirst attempt to harmonize OASIS Energy Interop with CIM failed between OASIS und TC57. It makes no sense for PC118 to try another attempt due to the fact that the PC118 business plan targets address “harmonization with” and not “replacement of” existing standards.
The previous harmonization failed due to the broader range of energy markets being addressed by Energy Interop. OASIS may better address this in becoming a publication under ISO.
However, PC118 is supportive of an activity of OASIS for the generation of a definition of an adapter to the CIM data model.
Grid data models must follow the CIM definitions as the IEC family of standards for the system definitions is a guarantee for grid stability.
The Swiss committee is committed to keep this stability as this is significant for the whole economy system.
DE-1 / ge / German NC is strongly against the adoption of OASIS Energy Interoperation Version 1.0 Specification.
The German NC sees no benefit in adopting OASIS Energy Interoperation Version 1.0 Specification used mainly in USA and is not aligned with the IEC framework (especially CIM: IEC 61968, IEC 61970 and IEC 62325).
Furthermore it is seen sufficient to refer to external documents where appropriate only (e.g. in case of IEC/PAS 62746-10-1 (OpenADR)) instead of their adoption.
DE-2 / ge / The German NC expects that IEC committees and liaison organizations respect the work being carried out in the other groups of IEC and not try to define parallel standards.
Consistency of the standard framework is a major success factor of IEC. Especially in the domain of power system management and smart grid interoperability confusing the market by overlapping standards should be avoided. Therefore adoption requests should be carefully analyzed if there are overlaps.
In this case it is crucial that before accepting external specifications it needs to be ensured that there is no overlap with existing IEC standards or work in progress as well as that the submission is compliant with the IEC framework and supplements existing reference architectures.
DE-3 / It is expected that a liaison organization which introduces an external specification to IEC moves copyright, maintenance and future development completely to IEC and closes the work in the external organization. Otherwise it could be understood that a requesting organization is intending to get the IEC label only.
DE-4 / ge / In general requesting organizations should be obliged to proof that there is no overlap with existing IEC work before adoption themselves. It is not acceptable that IEC experts have additional efforts by analyzing of external documents regarding potential overlaps.
DE-5 / ge / The German NC understands that OpenADR has been introduced as IEC/PAS 62746-10-1 with the argument to address the market need for demand response. Inconsistencies with the IEC framework have been accepted by starting a joint PC118 / TC57 project on CIM-OpenADR harmonization.
The current adoption request is understood that the OpenADR inconsistencies with the IEC framework are intended to be compensated by introducing an additional external specification – itself consistent to the OpenADR PAS document - but again inconsistent with the IEC framework.
What is the rationale? A clarification is required.
DE-6 / ge / It has been indicated that the document is of relevance for TC57. The German NC expects that TC57’s “Principle for evaluating requests from parties external to the IEC” (57/1287/DC, 57/1345/INF) are applied.
These principles have been endorsed by national committees. Therefore it is expected that PC118 and the liaison organization together with TC57 answer the following questions and report those to national committees:
Initial questions for the requesting party to consider and keep in mind:
  1. Does the proposed document, in general, cover topics in the TC57 domain? What other TC domains are also covered?
  2. Has the Reference Architecture been reviewed for applicable sections to the proposed document? If no, then should it be reviewed? If yes, was the RA found to cover the space? If yes but no coverage found, is the RA lacking in this area?
  3. Have there been any timelines, due dates and deliverables established? If yes, then the TC57 CAG and possibly WG19 need to be notified and coordination on any architectural issues needs to be established.
  4. Is there a contact person to assist in clarification of questions regarding the proposal (technical and formal)
For existing work (or resulting new work as a result of using existing work) to be considered for use in IEC TC57 standards, the following questions must be answered with a ‘YES’:
  1. Is there sufficient international interest, where experts from at least five participating IEC TC57 countries would be nominated?
  2. Is the work well aligned with either the CIM or IEC 61850, or identifies a clear gap that can be addressed by extensions to the CIM or IEC 61850 (IEC TC57 Strategy).
  3. Is the work free of conflicts with existing IEC TC57 (and related areas) standards or work items?
  4. Is the existing or planned work encumbered by intellectual property restrictions?
  5. Would experts from the proposing organization actively participate in the IEC work, which includes consistent attendance and contribution at working group meetings which includes international meetings.
  6. Is there an appreciation that work submitted to the IEC for standardization will likely be modified prior to adoption as a standard?
  7. Are there vendors that would build products using the IEC standard and participate in related interoperability tests?
If the answer to any of the above questions is NO, the work may not be appropriate for standardization within the IEC.
DE-7 / Copyright / Page 3 / ge / The German NC expects that external documents to be adopted by IEC are compliant to the Common Patent Policy for ITU-T/ITU-R/ISO/IEC
“OASIS takes no position regarding the validity or scope of any intellectual property or other rights that might be claimed to pertain to the implementation or use of the technology described in this document or the extent to which any license under such rights might or might not be available; neither does it represent that it has made any effort to identify any such rights
This is not acceptable for an implementation; all these impacts shall be duly taken into account; especially when this kind of standards is implemented by end users.” / Clarification and Statement that the document is compliant to Common Patent Policy for ITU-T/ITU-R/ISO/IEC
DE-8 / ge / The document uses extensively specifications and definitions of further non-IEC documents EMIX and TEMIX. / All references to EMIX and TEMIX specifications shall be replaced by appropriate IEC 61968, IEC 61970, IEC 62325 definitions
DE-9 / 248 / 1.8 / 18 / Ge / “This document relies heavily on roles and interactions as defined in the OASIS Standard Reference Model for Service Oriented Architecture” / Needs to be harmonized with TC57 reference architecture, roles and interactions.
DE-10 / 2023 / 13.3 / Security requirements are referred through a external non IEC reference (PMRM). An adoption should require a consistency with IEC security requirements and concepts. / All references to PMRB and security shall be replaced by appropriate IEC definitions
FR1 / ge / It appears that this work is duplicated with NWIP or existing standards from IEC.
The French NC does not support this document.
FR2 / Introductory note / 3rd paragraph / ge / The French NC would have appreciated a three month period for the comments, in particular:
  • When the CD document is issued in Christmas period.
  • When the document has more than 150 pages of text.

FR3 / Introductory note / Background / ge / The French NC is rather surprised learning that CIM DR extensions are based on EI. CIM DR extensions shall be discussed at least in the following IEC TC 57 WG16 and WG21.
This information was not provided at least in IEC TC 57 WG 16.
FR4 / Introductory note / Background / ge / It is stated that “EI was developed with collaboration of ....”.
Could we have the position of North American representatives of IEC TC 57 WG 16; and in particular what about the IEC 62325-452-n series?
FR5 / Introductory note / Background / ge / It is stated that “Demand Response, Registration and Enrolment Services in EI were submitted to IEC TC 57 as CIM extensions for Demand Response (in progress in WG16 and Wg 21)””.
Could we have the date of such submission, and at which physical meeting these points were discussed?
FR6 / Introductory note / Background / ge / Could you state what the definition of “facility domain” is?
FR7 / Introductory note / Technical Comments Requested / ge / The market model underlying this document is based on the North American market model.
Thus this model does not apply to other market such as the European market.
In addition, a lot of the work submitted here is defined in existing standards in particular on the “transactive service, bids, offers, reporting, etc.”. Please check the IEC 62325-451-n series of standards (such as IEC 62325-451-2, IEC 62325-451-3, IEC 62325-451-4, IEC 62325-451-5 and IEC 62325-451-6)
In addition it should be pointed that the IEC 62325 series of standard which is related to energy market is not mentioned in this document.
FR8 / 40 / 1 / te / “Providers and customers”, these are roles of a market participant.
FR9 / 56 / 1.2 / ge / As stated, by approving this document, EMIX becomes also an IEC standard?
This is not acceptable, all the documents for a standard are to be submitted together and without an implicit approval.
FR10 / 63 / 1.2 / ge / As stated, by approving this document, SOA-RM becomes also an IEC standard?
This is not acceptable, all the documents for a standard are to be submitted together and without an implicit approval.
FR11 / 65 / 1.2 / ge / As stated, by approving this document, WS-Calendar becomes also an IEC standard?
This is not acceptable, all the documents for a standard are to be submitted together and without an implicit approval.
FR12 / 91 / 1.3 / te / IEC 61968-11 shall be a normative standard and not only an informative
FR13 / 93 / 1.3 / te / IEC 61970-301 shall be a normative standard and not only an informative
FR14 / 116 / 1.3 / te / IEC CIM standards (IEC 61968-11, IEC 61970-301 and IEC 62325-301) shall be normative standards and not only an informative
FR15 / 147 / 1.4 / te / All the contributions are from NAESB (North American Energy Standards Board) about the energy market model, what about the European style and in particular the European Regulations?
FR16 / 319 to 324 / 2.1 / te / We do not agree with a view of a theoretical information model not linked to the market agreements and market products to be traded.
Interactions between market participants are depending upon market rules and market products.
Transactions are not the same for “over the counter” trade, for power exchanges, etc.
FR17 / 325 / 2.2 / ge / A lot of the items listed are already defined in IEC standards from the 62325 series.
FR18 / 370 to 373 / 2.3 / ge / Only NAESB reference, these are not the single model.
FR19 / 379 / 2.4 / te / “Locational market price”, it seems that the model used is a nodal model. This may be of interest in North America countries but it is not the only model; zonal model is also to be handled.
FR20 / 563 / 3.1.5 / te / “From one location to another” here also there is a reference to the nodel model of NAESB.
Over the counter transaction or power exchanges transactions may be independent of the source-sink concept.
FR21 / 575 / 3.2.1 / te / The concept of “virtual” is not appropriate; in a market, all these interactions are defined through contracts/market agreements a thus are “real” ones.
What is really the benefit of these two roles?
The market participant role shall be sufficient.
FR22 / 668 / 3.3.1 / te / It is stated that “With that PartyID, the Actor can implement and interact using the Party Role in the Transactive Services”.
The FR NC agrees with such a statement, and the role shall be linked to the electricity market business processes.
However, in lines 1021 to 1026 (UML class diagram of Party ID), the roles described are not linked to European energy market roles.
FR23 / 755 / 4.1.2 / te / The Si symbol for kW is not “KW” (in all the document) / Use the correct SI symbol.
FR24 / ge / We would like to have a clear description of EI profiling method that results in OpenADR specifications. Could we consider that OpenADR is a strict subset of EI?
Is all OpenADR material/feature extracted from EI specifications?
FR25 / Background section / ge / “EI was developed with collaboration and participation of CIM experts” : please precise since when and why this work has not been developed in the context of IEC TC57 working groups (wg14) where other international experts would have participated.
FR26 / Background section / ge / Xtensible Systems is not known. It is Xtensible Solutions (provide URL of these firms for non US experts) ? Do the representatives of these companies agree with OASIS EI concept and is EI fully harmonised with IEC CIM standards?
FR27 / te / IEC CIM standards (IEC 61968-100) shall be indicated as normative standards
GB / Ge / GB considers that the content of
OASIS Energy Interoperation Version 1.0 Specification
is not suitable for adoption as an IEC standard. The OASIS document offers some points of view on energy interoperation. From a technical perspective, however, the document fails to recognise that the key issue can often be the regulatory environment that is in place in a particular country. Therefore, this document should be rejected as a standard.

Page 1 of 32

Page 1 of 32