Request for Stakeholder Comments on AESO Recommendations for Revisions to
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Request for Stakeholder Comments on AESO Recommendations for Revisions to
Request for Stakeholder Comments on AESO Recommendations for Revisions to Generating Unit Owner’s Contribution Provisions Background On October 16, 2012, the AESO published its Recommendations for Revisions to Generating Unit Owner’s Contribution ISO Rule and ISO Tariff Provisions, which outlined proposed revisions related to contributions paid by and refunded to owners of generating units in accordance with section 29 of the Transmission Regulation. Those provisions currently exist in: ISO rule 9.5: Annual Performance Criteria for Refund of System Contribution; ISO tariff section 10: Generating Unit Owner’s Contribution; and Generator System Contribution Policy. The AESO proposes to implement the ISO rule and information document changes in January 2013 and to include the ISO tariff changes in the AESO’s next tariff application in March 2013. The AESO is seeking comments from stakeholders on the proposed changes as presented in the recommendation paper. Please use the comment form below when submitting comments to the AESO on the proposed revisions. Please ensure that your comments represent all interests within your stakeholder organization with respect to the proposed revisions. Please provide comments or questions no later than November 5, 2012, to Raj Sharma at [email protected] or 403-539-2632. Consultation and Stakeholder Identification Date of Request for Comments: October 16, 2012 Period of Consultation: October 16 – November 5, 2012 Comments From: Date: Contact: Phone: Email: Stakeholder Comments on AESO Proposals Stakeholder Comment 3.1.2 Stakeholder Position The AESO proposes that all provisions relating to generating unit owner’s contributions should apply at the generating unit level (or at the aggregated generating facility level, in the case of an aggregation of generating units designated as such by the AESO, as for a wind generating facility using multiple wind-powered generators). Support Reasons for Stakeholder Position: Oppose Indifferent Recommendations for GUOC Provisions Stakeholder Comment Form Page 1 of 3 Confidentiality: Public October 16, 2012 Stakeholder Comment 3.2.2 Stakeholder Position The AESO proposes that generating unit owner’s contribution provisions relating to Rate STS contract capacity be revised to accommodate: increases or decreases in capacity included in a “staged” Rate STS contract; and increases or decreases in capacity implemented through an amendment to a Rate STS contract after commercial operation. Support Reasons for Stakeholder Position: Oppose Indifferent 3.3.2 The AESO proposes to relocate content respecting commercial operation, reduction or forfeiture of refunds, and payment of annual refunds from the ISO rule to the ISO tariff. Support Reasons for Stakeholder Position: Oppose Indifferent 3.4.2 The AESO proposes to eliminate the self-reporting requirements from the ISO rule and ISO tariff. Support Reasons for Stakeholder Position: Oppose Indifferent 4.1.2 The AESO proposes to use an availability-based criterion where possible instead of the current production-based criterion to assess utilization of the interconnected electric system. As well, the AESO proposes that the annual refund amount would vary linearly from zero refund to full refund across a range of average availability, to avoid the “cliff” created by a single threshold level. Support Reasons for Stakeholder Position: Oppose Indifferent 4.2.2 The AESO proposes to use a volume-based criterion instead of the current event-based criterion to assess generation above contract capacity. Support Reasons for Stakeholder Position: Oppose Indifferent 5.1.2 The AESO proposes that subsection 2 of section 10 of the existing ISO tariff be relocated to section 2 of the tariff. Support Reasons for Stakeholder Position: Oppose Indifferent Recommendations for GUOC Provisions Stakeholder Comment Form Page 2 of 3 Confidentiality: Public October 16, 2012 Stakeholder Comment 6.1.2 Stakeholder Position The AESO proposes to use all generation projects that have passed Gate 2 of the connection process, including all projects that have entered commercial operation, in the calculation of the regional factor to determine the generating unit owner’s contribution rate. Support Reasons for Stakeholder Position: Oppose Indifferent 6.2.2 The AESO proposes to use inter-regional flows under normal winter peak conditions from the latest available AESO system study to determine dominant flows between regions. Support Reasons for Stakeholder Position: Oppose Indifferent Additional comments Please return this form with your comments by November 5, 2012, to: Raj Sharma Senior Regulatory Analyst Email: [email protected] Phone: (403) 539-2465 Fax: (403) 539-2632 Recommendations for GUOC Provisions Stakeholder Comment Form Page 3 of 3 Confidentiality: Public October 16, 2012