Stakeholder Comment and AESO Replies Matrix Meeting September 14, 2012

Stakeholder Comment and AESO Replies Matrix
AESO Consultation – 2013 Budget Review Process:
Meeting September 14, 2012 - AESO’s Draft Business Initiatives for 2013
The AESO is asking market participants and interested parties to comment on the 2013 draft Business Initiatives (revised) presentation given at the
Budget Review Process (BRP) stakeholder review meeting September 14, 2012.
2013 Draft Business Initiatives – Timeline/Calendar - Proposal to add a second Technical Meeting
Do stakeholders have any comments regarding the proposal to add a third Technical Meeting to review the AESO’s 2013 Own Costs budget
th
proposal on Wednesday, October 17 ?
Note - The Technical Meeting scheduled for October 3 is to continue as planned and review the AESO’s Ancillary Services and Transmission Line
Losses Costs Forecasts for 2013.
Stakeholder
Stakeholder Comment
AESO Replies
ADC
1. No objection - although Edmonton meetings
are always appreciated.
Comment 1. Noted.
CPC
1. CPC is supportive of adding a third technical
meeting and will appreciate the opportunity to
review a detailed breakdown of the AESO’s
proposed budget.
Comment 1. Noted.
IPCAA
1. October the 17 will not work for IPCAA. The
AUC (through Bulletin 2012-09) has initiated a
review of AUC Rule 002: Service Quality and
Reliability Performance Monitoring and
Reporting which is scheduled to occur from
th
October 16 to October 18 in Edmonton.
th
Comment 1. We will review the proposed
October 22 revision. We will also consider
other alternative dates. As a result of our
review, we will follow up with stakeholders on
any proposed revision of calendar dates.
The week of October 8th or October 22nd
would be preferred.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
1
2013 Draft Business Initiatives - Strategic Objectives and 2013 Draft Business Initiative Proposal
Do stakeholders have any comments on the AESO’s Strategic Objectives and supporting Business Initiatives proposed for 2013?
Stakeholder
Stakeholder Comment
ADC
In general the ADC is supportive of the AESO
business priorities. Specifically:
AESO Replies
1. The ADC is supportive of the AESO’s
continued development of demand
participation in the market. The ADC is
concerned over the comments from the MSA
and other market participants on the LSSi
program. This program needs time to work
and it is premature to make any assessments
on its success.
Comment 1. Demand side market
participation is an identified 2013 business
initiative.
2. The ADC is supportive of moving to a 15
minute settlement alignment of dispatch and
settlement periods.
Comment 2. Management believes this will be
a multi-year initiative tied to the replacement of
aging market systems. Initial design work will
begin in 2013.
3. The ADC is supportive of moving forward with
the Transmission cost accountability
recommendations. The ADC encourages the
AESO to allocate sufficient resources to
oversee and audit the execution of the direct
assigned projects as well as provide visibility
to the AUC of project costs, schedule and in
service dates. We also would like to
compliment the AESO on their continued
participation with the TFCMC.
Comment 3. Noted. AESO will continue to
review the need to allocate resources to
monitor transmission costs and support the
TFCMC.
4. The ADC reemphasizes the need to have the
transmission cost model kept up to date. We
suggest that a detailed model of the
distribution elements is out of scope for the
AESO.
Comment 4. AESO is actively working on an
updated transmission rate impact analysis.
The AESO expects to have this completed and
published by year-end. We would agree that
the distribution elements are out of scope for
the AESO.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
An informed assessment of the impact of the
LSSi program on the market requires sufficient
data be available for analysis. An assessment
review is planned in 2013.
2
ADC, Cont’d.
5. With respect to the AESO’s public outreach
plan, the ADC feels that the cost to support is
more appropriately sourced from the taxpayer
through a budget within the DoE.
Comment 5. The AESO has been engaged in
public education for over five years as part of
our corporate mandate to inform all Albertans
about its role in ensuring the province’s
electricity system and competitive wholesale
market continue to meet the needs of
Albertans today and in the future. As a not-forprofit organization that does not own or
operate any power facilities and has no
financial investment in the industry, a strong
and trusted reputation with all stakeholders
allows the AESO to successfully fulfill its
mandate.
CPC
1. CPC is supportive of the majority of the
AESO’s initiatives for 2013 and trusts the
AESO will continue to engage stakeholders in
a manner that will permit meaningful and
fulsome consultation on each initiative.
Comment 1. Noted. Stakeholder consultation
is a fundamental principle used by AESO to
develop business initiative details such as
requirements and timing. The results and
recommendations from these consultations are
posted on aeso.ca for transparency.
2. CPC requests that the AESO add the
timelines and associated deliverables for all
their proposed business initiatives for next
year. Adding these items would greatly benefit
stakeholders in their own planning
requirements. Also, presenting the initiatives
in order of importance from the AESO’s
perspective would be helpful in focusing the
efforts of the AESO and stakeholders on those
projects with the highest priority.
Comment 2. The response to comment 1
above highlights that individual business
initiative details are essentially developed in
consultation with stakeholders and the
resulting details published on aeso.ca. In
addition, the AESO provides a high-level
overview of its business initiatives in the
Business Plan and Budget and provides
progress updates in the Budget Review
Process quarterly report.
3. The AESO has indicated that despite the
numerous initiatives being proposed that they
have adequate resources to handle the
workload and will not result in corresponding
budget increases. However, CPC requests
that the AESO also be mindful that
Comment 3. Noted. Stakeholder engagement
and feedback in planning, prioritization and
development activities (Comment 2 above) will
help the AESO improve the overall
coordination of consultation activities.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
3
CPC, Cont’d.
stakeholders have limited resources available
to them to engage in AESO and other agency
consultation initiatives, and requests that the
AESO coordinate their consultation processes
accordingly, both internally and with other
agencies as required, in order for stakeholders
to be able to provide appropriate and
meaningful input into each initiative.
With respect to proposed initiatives for 2013, CPC
has the following comments:
4.
As indicated by the AESO, CPC is anticipating
that the Wind Integration recommendation
paper will be released by September 30, 2012
and contemplates this issue will be examined,
and the consultation processes coordinated,
in conjunction with other inter-related issues.
Comment 4. Noted .The AESO examines all
issues in a coordinated manner. Also, See
AESO Reply to ADC Comment 2 above.
Since it was identified as an enhancement
within the 2005 Policy Framework paper, CPC
is of the opinion that the alignment of dispatch
should be viewed as a priority by the AESO.
CPC is supportive of this review and looks
forward to participating in the consultation
process for this enhancement.
5. The AESO stated the Brattle Report on seams
issues will be released by Q4 2012 and CPC
looks forward to reviewing the report as part
of the AESO’s consultation process.
Comment 5. The Report will be published on
completion.
6. CPC is interested in receiving more about the
AESO’s energy storage initiative; more detail
as to why certain parties have identified it as a
high priority, if storage will be considered a
regulated facility part of the transmission
system or if they will be treated as merchant
facilities, and the timeline for completing the
AESO’s research.
Comment 6. Noted. This business initiative is
early in its life cycle. Program scope not been
fully defined. Ongoing consultation will provide
additional details to stakeholders. Process
updates will be posted on aeso.ca
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
4
CPC, Cont’d.
MSA
7. The AESO has indicated their discussion
paper on dynamic scheduling is not yet
complete and requires further work. CPC
requests that the AESO provide a timeframe
for when they anticipate the paper to be
released for consultation.
Comment 7. The AESO anticipates additional
consultation on the implementation of dynamic
scheduling to begin in the fourth quarter of
2012.
8. Since it will continue to be a significant
undertaking for all stakeholders in 2013, CPC
believes that TOAD should be included as
part of the AESO’s business initiatives and
that the AESO factor in the many subcomponents of this project in order to consider
time and resource constraints faced by
stakeholders as a result of the numerous
AESO initiatives.
Comment 8. AESO management believes the
TOAD process will have reached a steady
state (operational -standard practice) in the
second quarter of 2013. However, AESO
Management concurs that the ongoing AD
(authoritative document) operational practice
will need to be cognizant of internal/external
resource requirements/constraints.
1. From the AESO 2013 Draft Business
Initiatives demand response (load as
spinning reserve, energy storage)
Comment 1. Demand side participation in the
market development is an identified 2013
business initiative. It is the AESO’s goal to
remove barriers to participation in our markets
to the degree that this is possible.
When reading the new Bal-002 somehow I had
assumed that load would have the ability to
provide Regulating Reserve to the AESO. Does
the term Load as Spinning reserve remove the
potential for load to provide regulating Reserve?
IPCAA
IPCAA has the following comments on the
Business Initiatives:
1. LSSi Review may need to be conducted in
advance of the 18-month-after-the-fact time
period. There is some concern that we are
not able to import additional power when it is
needed most.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
Comment 1. See AESO Reply to ADC
Comment 1 above.
5
IPCAA, Cont’d.
2. IPCAA is willing to work with the AESO to
promote operating reserve provision –
particularly spinning reserve provision, when it
becomes allowable – by loads.
Comment 2. Noted.
3. Customers are interested in an update of the
AESO transmission rates and impact
information. This update needs to be prompt
and publicly available. The 2011 calculator is
out-of-date and budgets for power are
currently being compiled.
Comment 3. See AESO reply to ADC
comment 4 above. The AESO has deferred a
2012 rates update application since AUC
Bulletin 2012-03 limits increases in rates for
transmission services.
4. There is some concern that the Transmission
Facilities Cost Monitoring Committee
(TFCMC) work will require more of the
AESO’s time and resources. This is a priority
for customers, and it is critical that sufficient
AESO resources are available for
transmission cost accountability and
oversight.
Comment 4. Noted. See AESO Reply to ADC
Comment 3 above.
5. Both load and generation customers are
concerned with the schedules and costs of
connecting to the grid. Customers are
interested in an industry-wide review to
highlight areas of improvement – including
policy-level recommendations.
Comment 5. AESO is committed to
continuous improvement in this area. Many
improvements have been implemented since
2010. An industry wide connection process
innovation workshop has been scheduled for
October 22. This workshop provides another
opportunity for additional stakeholder
recommendations for improvement.
6. IPCAA has some concerns with “Assess
AESO advocacy opportunities” under
Strategic Objective 7. What does this entail?
Comment 6. This business initiative has been
removed from the 2013 proposal as the scope
has not been fully developed.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
6
IPPSA
1.
IPPSA’s comments are contained to the 2013
Draft Business Initiatives of the ‘Market
Development’ Strategic Objective
High-level recommendation
•
Please look for linkages in issues and
proceed in a holistic manner
External issues
•
The AESO is facing three AUC decisions on
rules (losses, ATC and CM). How will these
decisions impact 2013 priorities?
•
The market may also need a high-level
agency alignment dialogue to
interpret/internalize the AUC’s new approach
to efficiency. (This may or may not resolve
itself in the AESO/AUC court of appeal
matter.) Such a discussion may also impact
2013 priorities.
2.
IPPSA suggested priorities for 2013
Comment 1. Noted. AESO Management
concur that external factors and decisions
could have a significant impact on the
business initiatives proposed, particularly with
respect to the scope of work and timing.
Recognizing that a number of scenarios could
occur throughout the life cycle of any business
initiative the AESO has established an internal
portfolio management process intended to help
respond to such changes. Together with input
obtained from ongoing stakeholder
consultation (e.g., BRP, MAC, other).
Management uses this process to facilitate
overall prioritization and alignment of
supporting programs, and rebalances the
portfolio (e.g., scope, schedule, budget,
deferral, cancellation, etc.) should a change in
external factors warrant it.
Comment 2. Noted.
Of the ‘policy’ issues, we see the following as our
priorities in order of highest to lowest. Frankly,
we see the bottom three as ‘nice to haves’,
meaning they can be delayed for some time:
1.
Interties (restoration, merchant transmission
integration, dynamic scheduling, jurisdictional
seams issues)
2.
Alignment of dispatch and settlement
3.
Demand response topics (load as spinning
reserve, storage)
4.
Price cap and floor
5.
T-2 change
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
7
IPPSA, Cont’d.
Of the following AESO 2013 priorities, we see the
following as maintenance or ‘final strokes’
implementation issues:
1.
Wind integration
2.
Operating reserve rules
3.
Market performance metrics
4.
Market rule AD conversion
5.
Market system replacement (IT)
2013 Draft Business Initiatives – Meeting facilities and teleconferencing services
Do stakeholders have any comments on the facilities and teleconferencing services provided in support of the meeting?
Stakeholder
Stakeholder Comment
AESO Replies
ADC
1. The ADC is appreciative of accommodating
meeting attendance through conference
call and web meeting.
Comment 1. Noted.
2. Many of the AESO participants are not
located in Calgary, the ADC urges the
AESO to look at meeting facilities that can
accommodate a broad base of
stakeholders through web based facilities
for ongoing AESO stakeholder
consultations.
Comment 2. Web based conferencing
alternative is being considered a standard
alternative for all stakeholder consultations, not
just the Budget Review Process.
CPC
1. Facilities were satisfactory for the meeting.
Comment 1. Noted.
IPCAA
No comments.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
8
Other Comments
Do stakeholders have any other comments to offer at this time?
Stakeholder
Stakeholder Comment
ADC
None.
CPC
1. CPC appreciates the effort of the AESO in
capturing stakeholder comments at the
th
September 14 meeting and found the
summary notes helpful.
IPCAA
No additional comments.
AESO Stakeholder Comment and AESO Replies Matrix: 2011-01-26
AESO Replies
Comment 1. Noted.
9