May 19, 2005 AESO 2003 Deferral Account Reconciliation Dear Stakeholder:

May 19, 2005
Sent via e-mail
Interested Parties
AESO 2003 Deferral Account Reconciliation
Dear Stakeholder:
Re:
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
AESO 2006 Prospective Deferral Account Rider Methodology
On March 7, 2005, the Alberta Electric System Operator (AESO) initiated a consultation process
with stakeholders regarding a process for its 2004 Deferral Account to respond to the concerns
brought forward by interveners respecting the deferral account cut-off date and the treatment of
post cut-off adjustments. The process was expected to be complete in early April with the
AESO’s determination of its position for the 2004 deferral account reconciliation application.
Issues arose during the consultation, however, which could not be addressed by early April. As
the cut-off date for the reconciliation was agreed with parties to be August 31, 2005, and as the
remaining issues relate to allocation after the cut-off date, the AESO believed further
consultation would not delay the process. The AESO therefore invites parties to participate in
further consultation regarding these outstanding issues.
In the fall of 2004 the AESO also held a consultation process regarding the methodology to be
used for deferral account reconciliations for 2004 and future years. Although there was not
unanimous support for continuation of a retrospective reconciliation process, on December 16,
2004, the AESO filed an application for a deferral account rider methodology for 2004 and 2005
based on retrospective reconciliation. The AESO also proposed a further consultation process
in mid-2005 to address remaining concerns for a prospective deferral account rider
methodology for 2006. As the AESO expects parties will likely be interested in both the 2004
post cut-off adjustment process and the 2006 prospective methodology, the initial consultation
meetings for both topics will take place in Calgary on the same day.
The AESO proposes the following consultation processes for interested parties to review in
detail the outstanding issues around the treatment of post cut-off adjustments and the
prospective deferral account rider methodology. Parties who wish to participate in the
consultation process should indicate their intent to do so, as well as which session(s) they will
attend, by 4:00 pm on Friday, June 3, 2005 to Maureen Winslow at
[email protected] or (403) 539-2463. The AESO welcomes comments from parties on
the proposed schedule and notes that it is subject to change, should any urgent matter not
related to this consultation arise.
2500, 330 - 5th Ave SW Calgary, Alberta T2P 0L4
t (403) 539-2450 | f (403) 539-2949 | www.aeso.ca
—2—
2004 Cut-off Date and Post Cut-off Adjustment Consultation Process
The AESO believes the following issues have been identified and remain to be resolved with
respect to deferral account reconciliation cut-off date and post cut-off adjustments:
1. What amounts should be considered material and potentially require more detailed
treatment than non-material amounts, for both AESO costs and AESO revenue?
2. How should material adjustments which occur within a certain time after the cut-off date be
handled, and what is that time period (prior to EUB Decision, prior to close of record, or
prior to reconciliation application)?
3. How should material adjustments which occur after the time period in (2) above be handled?
4. How should any adjustment (material or non-material) which relates to a year prior to the
deferral account reconciliation year be handled?
The AESO proposes an initial meeting to discuss these issues with stakeholders, followed by a
written consultation process according to the following schedule:
1. May 18, 2005
Schedule and process letter (this letter) distributed.
2. Jun 7, 2005
Consultation meeting (morning) with interested parties to discuss
outstanding issues regarding materiality threshold and post cut-off
adjustments. This meeting will take place at the AESO’s offices (2500,
330 – 5th Ave SW) from 9:00 am – 11:30 am.
3. Jun 16, 2005
Discussion paper distributed by including draft position regarding the
materiality threshold and treatment of post cut-off adjustments based on
comments provided from parties at June 7 consultation meeting.
4. Jun 29, 2005
Stakeholder comments to be provided on the AESO’s June 16
discussion paper.
5. Jul 6, 2005
Comment matrix distributed by AESO as summary of views expressed
in June 29 stakeholder comments.
6. Jul 13, 2005
Stakeholder comments to be provided with any additional comments in
response to the AESO summary, other parties’ comments, or based on
stakeholders’ own positions.
7. Jul 22, 2005
AESO proposal distributed to advise parties of the AESO’s position for
the materiality threshold and handling post cut-off adjustments.
2006 Prospective Deferral Account Rider Methodology:
The AESO believes the following issues have been identified and remain to be resolved with
respect to a prospective deferral account rider methodology:
1. Given that the cost of losses will be recovered from generators utilizing a prospective
calibration factor in accordance with the Transmission Regulation, and that all other
2500, 330 - 5th Ave SW Calgary, Alberta T2P 0L4
t (403) 539-2450 | f (403) 539-2949 | www.aeso.ca
—3—
transmission costs (except regulated generating unit connection costs) will be recovered
from load customers, do load customers prefer the current retrospective reconciliation
methodology or a prospective rider methodology?
2. If a prospective rider is implemented, how should transition occur from the current
retrospective reconciliation methodology to a prospective methodology?
3. If a prospective rider is implemented, over what period should the deferral account rider be
calculated to refund or recover variances from forecast?
4. If a prospective rider is implemented, how should the deferral account rider account for and
recover or refund larger-than-normal variances from forecast?
5. If a prospective rider is implemented, what would be an appropriate threshold for
determining a variance from forecast is “larger than normal”?
The AESO proposes an initial meeting to discuss these issues with stakeholders, followed by a
written consultation process according to the following schedule:
1. May 18, 2005
Schedule and process letter (this letter) distributed.
2. Jun 7, 2005
Consultation meeting (afternoon) with interested parties to discuss
outstanding issues regarding a prospective deferral account rider
methodology. This meeting will take place at the AESO’s offices (2500,
330 – 5th Ave SW) from 1:30 pm – 4:00 pm.
3. Jun 16, 2005
Discussion paper distributed by including draft position regarding the
prospective deferral account rider methodology based on comments
provided from parties at June 7 consultation meeting.
4. Jun 29, 2005
Stakeholder comments to be provided on the AESO’s June 16
discussion paper.
5. Jul 6, 2005
Comment matrix distributed by AESO as summary of views expressed
in June 29 stakeholder comments.
6. Jul 13, 2005
Consultation meeting with interested parties to discuss outstanding
issues and matters raised by other parties in June 29 stakeholder
comments. This meeting will take place at the AESO’s offices (2500,
330 – 5th Ave SW) from 9:00 am – 12:00 noon.
7. Aug 3, 2005
Stakeholder comments to be provided on matters discussed at the
July 13 consultation meeting.
8. Aug 17, 2005
Comment matrix distributed by AESO as summary of views expressed
in August 3 stakeholder comments.
9. Aug 31, 2005
AESO application filed for a 2006 prospective deferral account rider
methodology based on stakeholder comments and providing the AESO’s
position on a prospective methodology.
2500, 330 - 5th Ave SW Calgary, Alberta T2P 0L4
t (403) 539-2450 | f (403) 539-2949 | www.aeso.ca
—4—
For parties’ reference, attached to this letter are two documents:
(a) the AESO discussion paper and issues list on outstanding issues from the 2004 Deferral
Account Cut-Off Date and Post Cut-Off Adjustment Process consultation; and
(b) an AESO letter and stakeholder comments on the Prospective Deferral Account Rider
Methodology consultation held in the fall of 2004.
Additional background is available on the AESO’s web page at www.aeso.ca by following Quick
Links > Current Regulatory Activities, in the “AESO 2004 Deferral Account Cut-Off Date and
Related Issues Consultation,” “2004-2005 Deferral Account Rider Methodology,” and “AESO
Decision 2003-099 Compliance Filing - Deferral Account Rider Evaluation” sections.
If you have any comments or questions on this process or on the attached information, please
contact me at (403) 539-2465 or [email protected], or Randeep Nota at (403) 539-2468 or
[email protected].
Yours truly,
[Original signed]
John Martin
Manager, Regulatory
cc: Jamie Cameron, Alberta Energy and Utilities Board
Rob Senko, AESO
Randeep Nota, AESO
Carol Moline, AESO
Roxanne Moeskops, AESO
Attachments
2500, 330 - 5th Ave SW Calgary, Alberta T2P 0L4
t (403) 539-2450 | f (403) 539-2949 | www.aeso.ca
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Discussion Paper
March 24, 2005
Background
On March 16th, 2005, the Alberta Electric System Operator (AESO) held a stakeholder
consultation meeting to discuss its 2004 deferral account cut-off date and the subsequent post
cut-off adjustment process. The meeting was held in response to the AESO’s filing of its 2003
Deferral Account Application (Application No. 138574) with the Alberta Energy and Utilities
Board (EUB), in which the AESO committed in both Argument and Reply Argument to develop
a process for its 2004 Deferral Account to respond to the concerns brought forward by
interveners (in particular, Encana) respecting the deferral account cut-off date and the treatment
of post-cut-off adjustments.
Discussion at the meeting proposed that selection of a cut-off date and post cut-off adjustment
process should be assessed on the basis of the following principles:
•
Accuracy — Will deferral account amounts be allocated to customers in accordance with
EUB-approved principles?
•
Consistency — Will treatment of a deferral account amount be the same whether the amount
occurred before or after the cut-off date?
•
Materiality — What amounts should be considered material and potentially require more
detailed treatment than non-material amounts?
The following discussion assumes the deferral account will be reconciled on a production month
(rather than an accounting month) basis in a retrospective process. The AESO notes it expects to
file an application later this year for a prospective deferral account rider to be effective for 2006.
Cut-Off Date
A major factor when reconciling the deferral account is the cut-off date beyond which revenue
and cost amounts will not be included in the reconciliation for that particular year, and will be
included in the subsequent year’s deferral reconciliation. To date, the AESO has used a cut-off
date for a given year’s deferral account of January 31 of the following year. Following a review
of amounts related to 2003 and prior years’ production months but which occurred in 2004,
stakeholders suggested the following:
1.
The cut-off date for revenue and cost amounts relating to a particular year’s deferral
account reconciliation would be August 31 of the following year.
An August 31 cut-off date would include all revenue and cost adjustments received to that date.
An August 31 cut-off date would also include final transmission system losses for the deferral
account year.
— Page 1 of 5 —
The AESO anticipates that it would require two and a half months after the cut-off date to
prepare a deferral account reconciliation application. Therefore:
2.
A particular year’s deferral account reconciliation would be filed in mid-November of the
following year.
The AESO would file the application earlier if possible.
The AESO is particularly interested in the views of any parties who desire an application earlier
than mid-November.
Materiality
The issue of materiality was discussed with stakeholders at the March 16 meeting. There are two
aspects to materiality:
• What would constitute a “material” adjustment?
• How would the handling of material adjustments occurring after the cut-off date differ from
the handling of non-material adjustments?
Discussion at the meeting suggested the following materiality thresholds for post cut-off
adjustments:
3.
For AESO costs, an adjustment would be considered material if it exceeded 1% of the
AESO’s annual revenue requirement, which would equate to approximately ±$7.6
million for 2004.
4.
For AESO revenue, an adjustment would be considered material if it exceeded
±$250,000 for a single customer or a single billing period.
The AESO has further considered the materiality thresholds, and proposes the following
alternatives for the thresholds discussed on March 16. Material thresholds for post cut-off
adjustments would be:
3-A.
For AESO costs, a cumulative post cut-off adjustment for a single cost component
(wires, ancillary services, losses, or “own costs”) would be considered material if the
cumulative amount exceeded 1% of the AESO’s annual revenue requirement, which
would equate to approximately ±$7.6 million for 2004.
4-A.
For AESO revenue, a cumulative post cut-off adjustment for a single revenue component
(wires, ancillary services, losses, or “own costs”) would be considered material if the
cumulative amount exceeded 1% of the AESO’s annual revenue requirement, which
would equate to approximately ±$7.6 million for 2004.
The AESO proposes the additional detail in 3-A to clarify that amounts are cumulative and to
recognize that separate cost components are reconciled separately in the deferral account and
therefore should not be considered to offset each other. For example, a +$8.0 million adjustment
to wires costs should not be netted against a –$7.0 million adjustment to ancillary services costs.
— Page 2 of 5 —
The AESO proposes the change in 4-A because, while an individual customer would be rebilled
to reflect the revenue adjustment, the AESO considers the impact to be immaterial for other
individual customers when as little as $250,000 is allocated over all AESO customers. The
AESO has concluded that the materiality threshold for revenue should therefore be similar to the
materiality threshold for costs.
Post Cut-Off Adjustments
Discussion at the meeting identified two post cut-off periods during which material adjustments
could be handled differently.
Next Year’s
Cut-Off
Filing
Decision
Cut-Off
Period A
Period B
Aug 31
mid-Nov
May
Aug 31
Material Period A Adjustments
Material adjustments during Period A were suggested to be handled as follows:
5.
If a material adjustment occurred during Period A (after the cut-off date and prior to the
EUB issuing its decision), the AESO would refile its deferral account reconciliation
based on a new cut-off date which would include the material adjustment.
The AESO has further considered the handling of post cut-off adjustments, and is concerned
with refiling after the close of the written record in a proceeding (typically the filing of reply
argument) anytime up to the EUB issuing its decision. In particular, such a process seems
inefficient if the material adjustment arises just before the EUB issues its decision. The AESO
therefore proposed the following alternatives to the periods identified above:
Cut-Off
Filing
5
5-A
5-B
Close of
Record
Period A
Decision
Period B
Period A
Period A
Aug 31
mid-Nov
Next Year’s
Cut-Off
Period B
Period B
Mar
May
Aug 31
These alternatives to item 5 can be described as follows:
5-A.
If a material adjustment occurred during Period A (after the cut-off date and prior to the
close of the written record), the AESO would refile its deferral account reconciliation
based on a new cut-off date which included the material adjustment.
5-B.
If a material adjustment occurred during Period A (after the cut-off date and prior to the
AESO’s filing of its deferral account reconciliation), the AESO would delay filing its
— Page 3 of 5 —
deferral account reconciliation until it could accommodate a new cut-off date which
included the material adjustment.
The AESO believes either alternatives 5-A or 5-B would allow for an efficient regulatory review
and decision process, and would still capture material adjustments that occur for some months
after the initial cut-off date. (Please note that the dates provided in the above timeline are
illustrative only.)
The AESO notes that discussion on March 16 contemplated a refiling of the 2003 deferral
account reconciliation, consistent with item 3 above. In an initial discussion, the EUB was not
fully supportive of such a refiling and instead suggested a separate one-time filing of any
material adjustments relating to 2003 might be more appropriate. However, the EUB was
interested in hearing stakeholder comments on the proposed process.
The AESO also notes that alternatives 5-A and 5-B would not require a refiling of the 2003
deferral account reconciliation, and addresses this matter in the following section.
Material Period B Adjustments
Discussion on March 16 contemplated the following approach for material adjustments during
Period B:
6.
If a material adjustment occurred during Period B (after the EUB issued its decision and
prior to the next year’s cut-off date), the AESO would include the adjustment in a “13th
month” in its next year’s deferral account reconciliation application.
In its 2003 refiling, the AESO accumulated any adjustments which related to pre-2003
production months in a “13th month” and allocated those adjustment to customers based on the
total of 2003 annual revenue (including pre-2003 revenue adjustments) by component by
customer. Item 6 above proposes that the process for material adjustments which occur in Period
B (after a EUB decision) would be handled in a similar manner.
Although the AESO is not opposed to such treatment if stakeholders support it, the AESO
suggests as an alternative a second level of materiality for Period B adjustments. The AESO
suggests it may be inappropriate to propose that any adjustment, no matter how large, after a
particular date established by any method (even after a EUB decision is issued) should be treated
the same as smaller non-material adjustments. The AESO therefore proposes a second tier of
materiality for Period B adjustments as follows:
6-A.
For AESO costs, a Period B adjustment for a single cost component (wires, ancillary
services, losses, or “own costs”) would be considered material if the amount exceeded
2.5% of the AESO’s annual revenue requirement (approximately ±$19 million for 2004)
and would trigger a separate application to reconcile the adjustment.
6-B.
For AESO revenue, a Period B adjustment for a single revenue component (wires,
ancillary services, losses, or “own costs”) would be considered material if the amount
— Page 4 of 5 —
exceeded 2.5% of the AESO’s annual revenue requirement (approximately ±$19 million
for 2004) and would trigger a separate application to reconcile the adjustment.
An adjustment which occurs in Period B and which exceeds the Period B materiality thresholds
in items 6-A or 6-B would trigger a separate application to reconcile those adjustments. Such
application would more closely correspond to how the amount would have been allocated had it
been included in the respective year’s deferral account, and is appropriate for amounts larger
than the suggested Period B materiality thresholds.
The AESO notes that alternatives 6-A and 6-B would trigger a separate application to reconcile
an adjustment relating to 2003 and prior years.
Non-Material Adjustments
Discussion at the March 16 meeting suggested the following handling of non-material post cutoff adjustments:
7.
If a refiling is required by a material Period A adjustment, non-material adjustments
which occur in Period A would be included in that refiling.
8.
If no refiling is required by a material Period A adjustment, non-material adjustments
which occur in Period A would be accumulated in a “13th month”.
9.
Non-material Period B adjustments would be accumulated in a “13th month”.
10.
Non-material adjustments accumulated in a “13th month” would be allocated to
customers based on the subsequent year’s annual revenue (except for losses which would
be allocated on volumes times pool price), similar to the process used for pre-2003
adjustments in the 2003 deferral account reconciliation refiling.
The AESO notes the following additional “13th month” accumulation which was not raised at
the March 16 meeting but which is consistent with the AESO’s 2003 deferral account
reconciliation application:
11.
Portions of any adjustments (material or non-material) that relate to a year prior to the
deferral account would also be allocated on a “13th month” basis for the deferral account
year.
For example, if a material adjustment of $10 million occurred in April 2005 with $6 million
related to 2004 production months and $4 million related to 2003 production months, the $6
million would be allocated by production month as part of the 2004 deferral account while the $4
million would be allocated as a “13th month” amount based on 2004 annual revenue.
Comments
The AESO invites interested parties to comment on the above items using the attached comment
template, by April 1, 2005.
— Page 5 of 5 —
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Comment Matrix
April 7, 2005
Item
Detail
Comments
ATCO Power
EnCana
FIRM
TransCanada
AESO
Recommendation
Support – FIRM
Customers desire
accuracy in the deferral
account process in the
shortest time-frame to
ensure flow-through of
refunds/charges to
DISCO end-use
customers in a timely
fashion. An extended cutoff date to August 31
rather than the present
Jan 31 should capture
major adjustments for the
prior year and final load
settlement issues.
Support – With a cut-off
date of August 31 FIRM
Customers would
encourage the AESO to
complete the filing earlier
than mid-Nov if possible.
Support
All parties were in
agreement with the
proposed cut-off
date. Therefore, the
AESO will accept
August 31as the cutoff date.
Support
All parties were in
agreement of a filing
date of midNovember.
Therefore, the AESO
will accept this date
and file by midNovember, or earlier,
if possible.
Cut-off Date
1
Cut-off date of August 31
See comments
below.
Support – See
comments regarding
mid-November filing
date.
2
Filing date of midNovember
See comments
below.
Support – A
retrospective deferral
account reconciliation
(“DAR”) is intended to
assign accurately the
deferral amounts based
on an alignment of
historical revenue and
costs. An August 31
data cut-off date and a
mid-November filing
with accurate input data
Page 1 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
EnCana
FIRM
TransCanada
AESO
Recommendation
Support – Agree that
stating the threshold on a
cost component basis
eliminates compensating
positive and negative
effects.
Oppose – The
change
recommended by the
AESO effectively
substantially raises
the level of materiality
since 1% of the
revenue requirement
remains the
materiality test, but is
test is applied to one
of the four
components, which
on average would be
25% of the revenue
requirement.
TransCanada agrees
with the logic of the
The AESO accepts
EnCana’s position as
this addresses the
materiality issue.
is more likely to result
in the filing of a single
DAR calculation, with
much smaller
probability of
corrections and
refilings. If the input
data could be acquired
sooner than as
presently available
(especially losses),
certainly a more timely
filing date is
reasonable.
Materiality Threshold
3-A
For cumulative
adjustments for a single
cost component, ±1% of
AESO annual revenue
requirement
Comment Matrix
See comments
below.
Support – Test should
apply to any single cost
component and to a
cumulative of single
components. Material if
any single cost
component adjustment
≥ ±1% (±7.6 MM);
material if sum of single
cost components
adjustments ≥ ±1%
(±7.6 MM)
April 7, 2005
Re: Comments by
TransCanada – The
AESO considers the
+1% to be material
(i.e. significant) and
feels that anything
less than this would
not be cost (the cost
for readjusting the
deferral account
would be greater than
the amount identified
in the recalculation)
Page 2 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
4
4-A
Detail
For revenue, ±$250,000
per customer or billing
period
For cumulative
adjustments for a single
Comment Matrix
Comments
ATCO Power
See comments
below.
See comments
below.
EnCana
Support
Oppose – An August 31
cut off date should
April 7, 2005
FIRM
Oppose – Agree with the
AESO that such an
amount allocated over all
AESO customers would
be immaterial.
Support – Agree that
stating the threshold on a
TransCanada
AESO
Recommendation
AESO that the
material test should
be applied to each of
the 4 cost
components.
Therefore,
TransCanada
recommends the
materiality test should
read: “For
cumulative
adjustments for a
single cost
component, ±1% of
AESO annual
revenue
requirement for the
corresponding cost
component.”
Oppose - See
comments in 4-A
below.
and time effective.
Also, costs are not
split evenly between
the 4 components;
therefore, the 25%
breakdown is not
applicable.
Oppose –
TransCanada
Further discussion is
required before
arriving at a final
decision.
Oppose – The AESO
agrees with FIRM’s
comment that such
an amount allocated
over all AESO
customers would be
immaterial.
Further discussion is
required before
arriving at a final
decision.
Support
Page 3 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
revenue component, ±1%
of AESO annual revenue
requirement
EnCana
FIRM
TransCanada
AESO
Recommendation
result in smaller
probability of
corrections and
refilings.
Therefore ±$250,000 is
a reasonable materiality
test. An individual
customer perspective is
important. A review of
the 2003 DAR data
suggests that even an
adjustment of
±$250,000 represents
significant “rate shock”
for most customers
(except DISCOs and a
few STS customers)
with the misfortune to
have a received a
billing error from the
AESO.
cost component basis
eliminates compensating
positive and negative
effects.
believes the AESO
should be concerned
about material
impacts on individual
customers as a result
of deferral account
adjustments, not just
all other customers.
The use of $250,000
as the threshold may
be a concern given
the varying sizes of
customers.
TransCanada would
support 4-A as
recommended if the
following wording
was added: “For
revenue, ±10% of a
customer’s annual
charges for a single
cost component.”
This wording will
ensure that major
impacts on a
customer’s annual
charges are not
ignored through a
materiality standard.
Re: TransCanada
comment – See 3-A
above.
Oppose - If a material
period A adjustment can
be allocated on the basis
Oppose –
TransCanada agrees
with the AESO that
Further discussion is
required before
arriving at a final
Post Cut-Off Adjustments — Material Period A Adjustments
5
Material adjustments
require refiling any time
before EUB decision is
Comment Matrix
See comments
below.
Support - First Choice
EnCana’s first choice is
to address material
April 7, 2005
Page 4 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
issued
5-A
Alternative A: Material
adjustments require
refiling any time before
close of record
See comments
below.
5-B
Alternative B: Material
adjustments before filing
delay filing to allow
inclusion
See comments
below.
EnCana
FIRM
TransCanada
AESO
Recommendation
adjustments any time
before an EUB decision
and Order to implement
the allocation of the
deferral accounts.
EnCana views the
materiality test as the
threshold for
determining when
adjustments should be
made. Breaching the
threshold indicates that
it would be fair to all
parties to recognize the
inaccuracy and to make
an amendment.
Could support as a
second choice, but this
assumes that any
subsequent process
uses the same criteria
and method to test and
implement adjustments.
of the respective year’s
deferral account
methodology it is
inefficient to have to refile
the whole deferral
account reconciliation
with the adjustment
amounts added. It would
be more efficient to treat
the incremental
adjustment with a
separate filing.
the original proposal
may be inefficient.
decision.
Support – This process is
supportable since the
Board would not have
commenced its review.
Support - Of the
proposal 5-A or 5-B,
TransCanada prefers
5-A since
TransCanada
expects the Board
will issue decisions
fairly quickly after the
close of record in this
type of proceeding.
Oppose - Proposal 5B provides too much
possibility of further
delays.
All parties were in
agreement.
Therefore, the AESO
will accept this
proposal.
Support
Oppose
Oppose
Oppose – This Alternative
is captured in Alternative
A above.
Further discussion is
required before
arriving at a final
decision.
Post Cut-Off Adjustments — Material Period B Adjustments
6
Material adjustments in
Period B (after decision,
Comment Matrix
See comments
below.
Support – If a 13th
month is to be used to
April 7, 2005
Oppose - For accuracy
purposes material
Page 5 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
refiling, or filing) are
included in next year’s
13th month
Comment Matrix
Comments
ATCO Power
EnCana
FIRM
allocate unprocessed
adjustments, the 13th
Month adjustment
should be allocated on
the production year’s
monthly revenue. (i.e.
2003 adjustment
allocated over 2003
revenue) This 13th
Month adjustment
would be part of the
next year’s DAR.
When this option is
combined with Option
5, it is expected that the
likelihood of a material
13th Month adjustment
to be small.
adjustments should be
subject to a production
month allocation process
and not simply an add-on
to next year’s
reconciliation where the
adjustment would be
spread evenly across the
calendar months.
April 7, 2005
TransCanada
AESO
Recommendation
Material adjustments
in Period B (after
decision, refiling, or
refiling) will be
included in next
year’s 13th month.
The AESO feels that
FIRM has
misunderstood its
position; adjustments
will be included by
the AESO in a 13th
month and not
spread evenly across
the calendar months.
As noted by EnCana,
when option 6 and 5
are combined, the
likelihood of a
material 13th month
adjustment will be
small. (see Encana
comment below)
Page 6 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
EnCana
FIRM
TransCanada
AESO
Recommendation
6-A
Alternative A: A Period B
adjustment for a single
cost component
exceeding ±2.5% of
AESO annual revenue
requirement would trigger
a separate application
See comments
below.
Oppose – Changing the
threshold of materiality
for adjustments to costs
does not comport with
the principle of
consistency and
suggests that the
importance of
adjustments depends
on when they
discovered.
Support - The separate
application would ensure
that the material
adjustment would be
allocated on a production
month basis in a similar
manner as if the
adjustment had been part
of the respective year
deferral account process.
Support
Further discussion is
required before
arriving at a final
decision.
6-B
Alternative B: A Period B
adjustment for a single
revenue component
exceeding ±2.5% of
AESO annual revenue
requirement would trigger
a separate application
See comments
below.
Oppose
Support - The separate
application would ensure
that the material
adjustment would be
allocated on a production
month basis in a similar
manner as if the
adjustment had been part
of the respective year
deferral account process.
Support
Further discussion is
required before
arriving at a final
decision.
Support - A refilling
should capture both
material and non-material
adjustments.
Support
Support – If an
adjustment is nonmaterial then the
simplified 13th month
approach is acceptable.
Support
All parties were in
agreement.
Therefore, the AESO
will accept this
proposal.
All parties were in
agreement.
Therefore, the AESO
will accept this
proposal.
Post Cut-Off Adjustments — Non-Material Adjustments
7
Any Period A refiling
would include nonmaterial Period A
adjustments
See comments
below.
8
If no Period A refiling
occurs, non-material
Period A adjustments
would be included in next
year’s 13th month
See comments
below.
Comment Matrix
Support – Any refiling
should include all
known adjustments
(material and nonmaterial).
Support
April 7, 2005
Page 7 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
EnCana
FIRM
TransCanada
AESO
Recommendation
Support – If an
adjustment is nonmaterial then the
simplified 13th month
approach is acceptable.
Support – Since the 13th
month accumulated
amounts are based on
non-material amounts
allocation on the basis of
annual revenue is
acceptable.
Support
All parties were in
agreement.
Therefore, the AESO
will accept this
proposal.
All parties were in
agreement.
Therefore, the AESO
will accept this
proposal.
9
Non-material Period B
adjustments would be
included in next year’s
13th month
See comments
below.
Support
10
13th month accumulated
amounts would be
allocated to customers
based on the next year’s
annual revenue (except
for losses which would be
allocated on volumes
times pool price)
See comments
below.
11
Portions of any
adjustments related to a
year prior to the deferral
account would also be
allocated as a 13th month
amount
See comments
below.
Support – EnCana
understands this option
to mean the prior-year
carryover (13th Month
non material
adjustment amounts)
would be allocated
using the subsequent
year’s revenue
amounts. E.g. 2003
carryover amounts
allocated over 2004
revenue amounts. This
is supportable if the 13th
Month amounts are
non-material only.
Support – EnCana
understands this option
to mean the prior-year
carryover (13th Month
amounts) would be
allocated using the
original year’s revenue
amounts. E.g. 2002
carryover amounts
allocated over 2002
annual revenue
amounts. This method
is preferable since it is
Comment Matrix
April 7, 2005
Oppose – If an
adjustment relating to a
year prior to a deferral
account is material then
such adjustment should
be subject to a separate
filing.
Support
Support
Further discussion is
required before
arriving at a final
decision.
Page 8 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
EnCana
FIRM
TransCanada
AESO
Recommendation
TransCanada
recommends that if a
material change has
occurred with respect
to the 2003 Deferral
Accounts, that the
adjustment should be
changed on the more
detailed process that
matches the reasons
for the material
adjustment.
TransCanada is
largely indifferent as
to whether this
occurs as a one-time
filing or a refiling of
the 2003 deferral
account
reconciliation,
assuming the
recommendation is
adopted.
Re: Encana comment
– The AESO would
like to restate its
comments made
during the March 16th
stakeholder
consultation meeting:
any refiling will not,
and can not simply
restate the numbers
with the adjustments
with a brief
explanation to
accompany. The
process of
adjustments involves
extremely large and
complex Excel
spreadsheets and
requires a lengthy
process of checking
and re- checking
calculations.
closer to the EUB’s
production month
whereby the billing
determinants of the
(original) production
month is to be used to
assign deferral account
amounts.
Comments With Respect to Filing to Address Material Adjustment Relating to 2003
See comments
below.
Comment Matrix
As part of the materials
filed in the 2006 GTA
and the materials
circulated in
preparation of the
March 16th meeting, the
AESO has indicated
that 2003 costs have
been adjusted down by
$36 million. These
adjustments exceed
even the broadest
materiality threshold put
forward in the
discussion paper.
These amounts are
material and breach the
material threshold.
Therefore, consistent
with EnCana’s position
put forward in this
discussion paper
(Option 5) the 2003
DAR should be
April 7, 2005
Rather than refiling the
entire 2003 deferral
account application, for
efficiency purposes, any
material adjustment for
2003 should be subject to
a separate filing.
Page 9 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
EnCana
FIRM
TransCanada
AESO
Recommendation
amended. This would
provide the most
accurate information for
the Board to render its
decision. EnCana
expects this refiling
would simply restate
the numbers with the
adjustments and a
brief explanation of the
adjustments for
inclusion into the
Boards final decision.
EnCana believes this is
consistent with s.14(2)
of the Board’s Rules of
Practice.
Additional Comments
ATCO Power does
not agree with the
proposed
methodology for
dealing with 2004
deferral account
balances. ATCO
Power supports the
implementation of a
prospective deferral
account rider
methodology as
quickly as possible.
Comment Matrix
EnCana provides these
comments on a “without
prejudice” basis in an
effort to advance the
development of the
DAR method. EnCana
understands that the
AESO will review the
comments of all parties
and develop its own
position respecting the
2004 DAR method.
This position is to be
circulated April 6, 2005
and will be further
April 7, 2005
The foregoing comments
pertain to 2003, 2004 and
2005 deferral account
reconciliation processes.
For the transmission
changes in 2006 and
when transmission losses
will be subject to a
separate deferral
account, the deferral
account cut-off dates and
post cut-off adjustment
process should be
revisited.
Re: ATCO comment
– The AESO will be
addressing a
prospective deferral
account rider in mid
2005.
Re: EnCana
comment – The
AESO is not opposed
to EnCana altering its
position after
reviewing comments
made by other
parties, including the
Page 10 of 11
AESO 2004 Deferral Account Cut-Off Date and Post Cut-Off Adjustment Process
Item
Detail
Comments
ATCO Power
EnCana
included in an
application to be filed
later. In view of the
process, EnCana may
alter the positions
presented in this
document after
consideration of
comments by parties,
the AESO’s application
or evidence filed within
the 2004 DAR
application.
Comment Matrix
April 7, 2005
FIRM
TransCanada
AESO
Recommendation
AESO.
Re: FIRM comment –
The AESO agrees.
Page 11 of 11
November 25, 2004
Sent Via E-mail
To:
Interested Parties
Re:
AESO Deferral Account Rider Methodology Workshop
In accordance with the AESO’s letter to the EUB dated November 4 and invitation to
interested parties dated November 9, 2004, the AESO held a Deferral Account Rider
Methodology Workshop on November 18 in Calgary. About 25 stakeholders attended
the workshop, which included a review of the AESO’s Decision 2003-099 compliance
filing and discussion of deferral account rider methodologies for 2004, 2005, and 2006.
A copy of the AESO’s presentation is available on the Current Regulatory Activities page
of the AESO’s web site at http://www.aeso.ca/transmission/319.html.
As part of the presentation, the AESO proposed:
1. An immediate modification to the calculation of Rider C such that amounts are based
on five months of estimates (rather than four) to allow notice of the rider amounts to
be posted three weeks (rather than one day) before the start of the quarter;
2. Reconciliation of the AESO’s 2004 deferral account as in 2003 (based on the final
EUB decision on the 2003 reconciliation), but containing initial settlement data only
for October (incorrectly stated as September in both the Compliance Filing and
presentation) to December 2004 to allow filing in mid-April 2005; and
3. Implementation of a prospective rider methodology for 2005, with the rider adjusted
quarterly on a final basis.
The AESO’s Decision 2003-099 Compliance Filing dated October 21, 2004 provides
more detail on these proposals and is also available on the AESO’s web site.
No participant at the workshop objected to the first and second components of the
AESO’s proposal listed above. However, discussion during the workshop resulted in
reconsideration of the third component of the AESO’s proposal. Most participants
supported a continuation of the current rider and retrospective reconciliation
methodology in 2005 in addition to 2004, and delay of implementation of a prospective
methodology until 2006. In that case, the prospective methodology would likely be
applied for by the AESO in mid-2005 for an effective date of January 1, 2006.
The AESO understands some of the considerations leading to support for continuing the
current rider and retrospective reconciliation methodology in 2005 were:
• Concerns about the materiality of some of the individual customer impacts when
comparing the current rider and retrospective reconciliation methodology with the
2500, 330 - 5th Ave SW Calgary, Alberta T2P 0L4
t (403) 539-2450 | f (403) 539-2949 | www.aeso.ca
-2–
•
•
•
proposed prospective methodology, as outlined in Section 4.2 of the AESO’s
Compliance Filing;
Possible alternatives to the “cap and trigger” approach proposed in Section 3 of the
AESO’s Filing which would achieve the same objective of spreading large deferral
account amounts over periods longer than a quarter;
Recognition that under the Transmission Regulation costs of the transmission
system will be wholly charged to demand customers effective January 2006, and a
significant deferral account rider methodology change for supply customers in 2005
may not be warranted; and
The transition from the current methodology to a prospective methodology may need
to be more fully examined and addressed with particular attention to the forecast
updating used by the AESO.
Participants at the workshop also raised whether the “cap” could be applied in 2005
even if the current rider and retrospective reconciliation methodology was continued.
The discussion concluded that such a change would be material and require a formal
application to the EUB. Given the timing, regulatory schedule, and possible alternatives
to the “cap and trigger” approach mentioned above, participants agreed the 2004 rider
methodology should be continued without modification — that is, without a “cap”.
Participants at the workshop suggested time be permitted for additional comments to the
AESO, either verbally or in writing, prior to the AESO finalizing its proposal. The AESO
therefore extends this opportunity to all stakeholders. Any party is invited to submit
additional comments on the AESO’s Decision 2003-099 Compliance Filing, subsequent
correspondence with the EUB, information presented in the November 18 workshop, and
the considerations summarized in this letter. Comments should be provided to John
Martin either by telephone at (403) 539-2465 in Calgary or by e-mail to
[email protected], no later than Friday, December 3, 2004.
Following that date, the AESO will advise the EUB of the outcome of the consultation
with stakeholders on the deferral account rider methodology. Based on the discussion at
the workshop, the AESO expects to confirm that the methodology approved for 2003 will
be followed for both 2004 and 2005, and that no formal application will be required to
continue this process. The AESO would then conduct further stakeholder consultation to
respond to questions raised at the workshop, in anticipation of making a mid-2005
application for the rider methodology to be used for 2006.
Parties are invited to provide comments to the AESO on this proposed process as well.
If you have any questions or need additional information on this matter, please call John
Martin at (403) 539-2465 or Rob Senko at (403) 539-2786.
Yours truly,
Signed by John Martin
John Martin
Manager, Regulatory
Copy: Robert Litt, Energy and Utilities Board
Interested Parties
Calgary Place
th
1700 355 4 Ave SW
main 403.691.7575
Calgary AB T2P 0J1
fax 403.691.7576
November 26, 2004
Delivered via E-Mail
Alberta Electric System Operator
2500, 330-5th Avenue SW
Calgary AB T2P-0L4
Canada
Attention:
John Martin,
Manager Regulatory
Dear Mr. Martin:
Re:
Deferral Account Rider Methodology
AltaGas Ltd. (“AltaGas”) has had an opportunity to consider the compliance filing made
by the AESO on October 21, 2004 with respect to Deferral Account Rider Methodology
and the associated presentation on November 18. In the compliance filing, the AESO
proposed to implement a new methodology for calculating deferral accounts on a
prospective basis commencing January 1, 2005. During the course of your November 18
presentation, a number of parties questioned implementation of a new methodology
when the existing tariff structure will only be in place for one more year. Variability of
Rate Rider C has been a serious concern for AltaGas. AltaGas has been a proponent of
moving to a purely prospective methodology for deferral accounts; however, we can see
the inefficiency of adopting a new methodology for only one year, particularly in light of
the heavy regulatory workload faced by the AESO in the next few months. In addition,
given the move to a new methodology, it is probably appropriate for a final reconciliation,
based on the existing methodology, to ensure that all parties are kept whole with the
adoption of the new tariff structure on January 1, 2006.
Subject to the caveats below, AltaGas is prepared to support continuing with the existing
deferral account methodology during 2005.
1.
The AESO allocates December 2005 balances to STS customers in Q1 2006
to reduce 2005 balances to zero and wind up the STS deferral accounts. The
methodology should be sufficiently robust to address imbalances that are
discovered more that one quarter after the Rider is set – for example,
imbalances resulting from settlement delays.
2.
AltaGas notes that, under the Transmission Regulation (s. 21), the AESO is
required to continue to collect for losses through its tariff after January 1,
2006. The Transmission Regulation also contemplates, in s. 21(2), that
deferral amounts related to losses will be collected on a prospective basis
only over a period of one or more years. AltaGas requests that the AESO
2
indicate, at the earliest opportunity, the methodology through which it
proposes to collect deferral accounts after January 1, 2006.
Please feel free to contact me at 269-5720 if you have any questions or concerns about
this letter.
Yours truly,
AltaGas Ltd.
K. Lynn Meyer
Manager, Regulatory
Initials of Author/typist
Enclosure
From:
Sent:
To:
Subject:
Hackett, Jim [[email protected]]
December 10, 2004 9:42 AM
John Martin
RE: AESO Deferral Account Rider Methodology
Hi John,
ATCO Power strongly opposes the retrospective reconciliation of deferral accounts. Only the
prospective methodology can offer the necessary consistency in rate structure. Charging
transmission rates on a variable ($/MWh) basis and retrospectively adjusting deferral accounts
on a fixed lump sum basis distorts the market signals that a generator offering at variable cost
will rely upon. How does a generator recover variable costs that were not included in the
energy pricing when they are retrospectively billed on a fixed basis? How do load customers
expect to recover the loss created by paying a generator with a retrospective bonus when the
actual variable costs are less than variable costs included in the generators offer price? The
prospective method avoids the distortions created by retrospective settlement or retroactive
rates and sends the appropriate signals. ATCO Power supports the implementation of a
prospective deferral account rider methodology as early as possible in 2005.
Thanks for the opportunity to provide our comments.
Jim
From:
Sent:
To:
Cc:
Subject:
[email protected]
December 5, 2004 1:02 PM
John Martin
[email protected]
RE: deferral account reconciliation - new methodolgy?
John,
Calpine would strongly support the deferral account reconciliation methodology that is
prospective in nature, rather than retrospective, as described in the Decision 2003-099
Compliance Filing. A key element of the prospective methodology that we feel is critical is the
final settlement methodology that employs a $/MWh rider adjusted quarterly, rather than a yearend lump sum reconciliation. The variable nature of a $/MWh charge employed on a
prospective basis appropriately allows system users to manage the changing nature STS
charges by way of adapting the price they offer on future sales of their product (MWs) on a goforward basis. Receiving a lump-sum invoice unfairly removes any ability of the system user to
manage or re-coup that cost. The reconciliation cost applies to volumes of product (MWs) sold
in the past that we have no-way to go back to in order to increase the charge to the correct
amount to cover the revised system charge for that time. A prospective variable charge allows
for the management of the true-up on a go-forward basis.
It has always been our understanding that true-ups were to be done on a variable basis,
calculated as a percentage increase or decrease of STS tariff (per MWh). As you may be
aware, Calpine has been granted leave to appeal Decision 2003-099 which is currently ongoing, with this issue being central to our appeal.
Regards,
Susan Dowse
EnCana Corporation
th
EnCana on 8
nd
1800 855 2 Street SW
PO Box 2850
Calgary AB T2P 2S5
Tel
Fax
(403) 645-2000
(403) 645-7660
December 3, 2004
VIA EMAIL
Alberta Electric System Operator (“AESO”)
Calgary Place, Suite 2500,
330 – 5th Avenue S.W.
Calgary, Alberta
T2P 0L4
Attention: Mr. John Martin
Manager, Regulatory
Dear Sirs:
Re: AESO’s Deferral Account Rider Method
EnCana is in receipt of your letter, dated November 25, 2004, requesting comments on the
materials and communications regarding the Deferral Account Rider (“DAR”) method for 2004,
2005 and 2006 and provides the following comments.
The Presumption of Agreement
EnCana appreciates the AESO’s efforts to hold a workshop for stakeholders and to review the
AESO’s analysis and recommendations for the DAR method. As beneficial as it was, we note
that the format of the workshop was partial to the presentation of information and was less
conducive to a full and extensive dialogue. Additionally, the AESO’s invitation and comments at
the workshop made reference to a forthcoming application to the Board, likely tempering the
inclination of parties to engage in detailed discussions. Though generally inappropriate for the
AESO to presume that the absence of comments on an issue necessarily represents agreement
from parties, it is even more the case in these circumstances. Any subsequent application, or
correspondence, by the AESO should be mindful of this limitation.
Transitioning to a Prospective Method
EnCana agrees with the AESO’s conclusion that the transition from a retrospective method to a
prospective method needs to be more fully examined. While much of the attention has focused
on the application and technical workings of such a method, EnCana is of the view that any
transition must also ensure that the reconciliation and prudence review inherent in the existing
retrospective method is maintained or replaced in a satisfactory manner. The inability of
stakeholders and the Board to examine the AESO’s accounts and to assess whether costs
where incurred prudently would be a fundamental, and unsupportable, flaw of any transition
proposal. In light of this position, EnCana strongly urges the AESO to ensure that any further
December 3, 2004
Page 2
consultation, and ultimately the application, on a prospective method provide due consideration
to a process for the reconciliation of accounts and the review of prudent costs.
The 2004 and 2005 Method
In EnCana’s view, the absence of a defined reconciliation and prudence review process under a
prospective method and the limited application of Rider C to STS customers in 2005 favours the
retention of the retrospective method for 2004 and 2005.
Such general agreement, however, should not be mistaken for concurrence on the details of the
application; these will be addressed on their own merits as part of the application. For instance,
the merits of approving the deferral account adjustments based on initial and interim settlement
data remains open in EnCana’s view and ought to be properly supported by the AESO at the
time of the application. Clearly, the information requests in the 2003 deferral account
reconciliation process suggested a certain apprehension with this approach that requires
attention in any application.
EnCana thanks you for the opportunity to provide comments. If you have any questions please
call me at 645-6688 or Rod Crockford 645-7871.
Yours truly,
ENCANA CORPORATION
distributed electronically
Rinde K. Powell P.Eng.
Director,
Regulatory Services
cc:
Robert Litt, Application Officer, AEUB
Interested Parties
From:
Sent:
To:
Cc:
Subject:
Hildebrandt, Kurtis [[email protected]]
November 29, 2004 8:50 AM
John Martin
Weismiller, Grant; Falconer, Robert; Vita, Rocco
Deferral Account Methodology
John,
In a November 25, 2004 letter to interested parties, the AESO asks parties to provide additional
comment prior to finalizing its proposal regarding deferral account rider methodology.
The AESO notes that "based on the discussion at the workshop, the AESO expects to confirm
that the methodology approved for 2003 will be followed for both 2004 and 2005, and that no
formal application will be required to continue this process."
One of ENMAX Energy Corporation's primary concerns with the prospective methodology taking
effect in 2005 would have been the impact on some key commercial contracts such as
ENMAX's Balancing Pool contracts. This issue is resolved for ENMAX with the delay in
implementation of the prospective methodology to 2006 and the change in cost allocation under
the Transmission Regulation effective January 1, 2006. As such, ENMAX supports the AESO
proposal outlined in the November 25, 2004 letter to delay implementation of the prospective
methodology to be effective for 2006.
The AESO proposes that no formal application is required for the continuation of the
retrospective deferral account reconciliation methodology for 2003, 2004 and 2005. ENMAX
agrees with and supports the proposed process that the AESO has outlined in the November
25, 2004 letter.
Please let me know if you have any questions about ENMAX's comments.
Sincerely,
Kurtis Hildebrandt
Kurtis Hildebrandt
Regulatory Specialist
ENMAX Corporation
Phone: (403) 514-2850
Fax: (403) 514-3360
[email protected]
From:
Sent:
To:
Subject:
Jurijew, Daniel [[email protected]]
December 6, 2004 5:51 PM
John Martin
RE: AESO Deferral Account Rider Methodology
John,
EPCOR Utilities Inc. indicated its support for continuing to utilize a retrospective reconciliation
methodology for 2004 and 2005, and believes that a prospective deferral account rider
methodology should only be implemented by 2006 at the earliest.
Regards,
Daniel Jurijew
Manager Regulatory Affairs
EPCOR Utilities Inc.
10065 Jasper Avenue
Edmonton, AB
T5J 3B1
Ph: (780) 412-3411
Cell: (780) 975-5206
Fax: (780) 412-3096
e
* Medicine Hat
V
T eGasCity
November 22, 2004
Utilities Services Division
Electric Utility
2172 Brier Park Place NW.
Medicine Hat, AB Tic 1S6
Telephone: (403) 502 8081
Fax: (403) 502-8061
Website: wwwmedicinehat.ca
Sent via E-Mail
John Martin
Manager Regulatory
Alberta Electric System Operator
2500_330_5thAveSW
Calgary, Alberta
T2P 0L4
Re: Deferral Account Rider Methodology
At the subject AESO Stakeholder Workshop held November 18, 2004 you invited comments from
stakeholders on the AESO proposals. The City of Medicine Hat (CMH) considered the workshop to be
very useful in understanding and evaluating the alternative methodologies.
From our assessment of the workshop information and the AESO Decision 2003-099 Compliance
Filing of October 21 2004, CMH firmly supports moving forward and implementing a prospective rider
methodology. While it is appreciated that feedback at the workshop was that this might not be
achievable until 2006, our view remains as ‘the sooner the better’. Any steps that can be taken to
facilitate the change to implementing a prospective rider should be.
,
This is submitted a voice of customer support for a prospective rider. If you have any questions
regarding this submission, please call or e-mail the undersigned at (403) 529-8365 or
[email protected].
Sincerely,
cc: AESO Regulatory Rob Senko
AESO Finance Carol Moline