2014 Compliance Year in Review November 18, 2014

2014 Compliance Year in Review
November 18, 2014
Introductory Remarks
• Objectives of this presentation and discussion:
– To provide an opportunity to meet face to face
– To review the year’s stats and some recent or upcoming changes
– To look ahead to monitoring in 2015
• Today’s meeting is NOT a consultation session on our processes, on the
handling of particular events or on the ‘reasonableness’ of particular rules
• Expectation that audience has an understanding of rules and processes
• We are interested in identifying concerns/issues particularly if widely
shared but not intending solution exploration today
• Questions…
• Administrative… conference call and questions, washrooms, slides
Agenda
• Team Intros
• Process Overview – UP
• 2014 Stats – JN
• Rule 9.1 monitoring
• Rule and System Changes in 2014
• Looking to 2015
• Issues/Questions raised in invite response
• Other Questions
Topic: Market Compliance Team
VP Regulatory
Heidi Kirrmaier
Director-Compliance
Peter Wong
Manager – Compliance
Alberta Reliability
Standards
Daniela Cismaru
ARS team
Manager – Compliance
Load Settlement
Mike Choboter
Load Settlement Team
Manager – Compliance
Market Monitoring
/ISO Rules
Kevin Wipond
Analyst
Jordan Neff
Analyst
Brian Heaton
Analyst
Umesh Pillai
Senior Analyst/Auditor
Carlo Gaerlan
Topic: Process Review
• Compliance Process
• Ancillary Services Compliance Process
• Contacting the AESO
Energy Market Compliance Process
• STEP 1 - Identification of the events of interest
– At the beginning of each month: We compile a list of candidate
‘events’ from 2 months previous (30 day self-report period)
– Screening – various tools
– Internal referrals
– Prioritize, organize and select a subset
• STEP 2 – Preliminary Assessment (40-60 days after event)
– Analysis of the event of interest
– Outcome is decision to drop the event or proceed to CR/IR
Energy Market Compliance Process continued
• STEP 3 – Request for Information
– Clarification Request (CR)
(1 week response period typically)
– A CR is used for regulatory efficiency to gather additional
information on the event of interest
– Information Request (IR) and participant response (2 week
response period typically)
– An IR is a written letter submitted to market participants
outlining the specifics of the event, relevant rules and soliciting
additional information
Energy Market Compliance Process continued
• STEP 4 – Final Assessment
– The AESO reviews the IR response and determines an
outcome: drop the event or referral to MSA (often 3-4 months
after event occurred)
– Referral letter or ‘Not pursuing’ letter
– In circumstances where the AESO determines a suspected
contravention, the ISO must refer the matter to the MSA
– The market participant is notified of a referral submission
– The MSA can either assess penalties or forebear
Compliance Process – Energy Market Monitoring
Possible Contraventions Identified By:
AESO Compliance
Monitoring/Reports
AESO Internal
Referrals
Information from
the MSA or AUC
Preliminary
Assessment
Send
Information
Request to
Participant
External Referrals
AESO declines to
proceed further
AESO
communicates
decision to
relevant parties
Participant
Final
Assessment
Proceed to
Referral to
MSA
Ancillary Services Contract Compliance
Process
• Section 103.12 of the ISO Rules is not generally applied to
compliance in the AS market
– Because obligations are, for the most part, detailed in contracts
(not ISO rules)
– Inadequate response to AS directives is the main exception
(ISO rule 6.5.3), others…
Ancillary Services Contract Compliance
Process (cont.)
• Over the month market participants
– Contract to provide ancillary services through NGX
– Make offer restatements and/or asset substitutions
– Submit force majeure (FM) within 2 business days after event
• In the following month we run the technical review
– Automated review of contracts, restatements and substitutions - “contract
non-compliance”
– Automated review of performance of assets versus dispatch and directive
• “dispatch non-compliance” and “directive non-compliance”
• Followed by a manual validation of dispatch and directive non-compliance
cases to take into account information not available to ASP
Ancillary Services Contract Compliance
Process (cont.)
Financial adjustments
– Automated process performed after technical review
– Claw back of payment – minimum consistent provision over an hour
– Liquidated damages (LD) – portion of costs of activated standby reserves
Submission of the financial statements to the participants
– Beginning of 2nd month following (eg in early November. for September.)
Over the next month or so…
– Market participants can ask for justification and/or re-examination of specific
instances
– Market participants are encouraged to substantiate inquiry with own
data/records
– AESO may reverse its initial decision based on market participant’s data or
internal additional data
Contacting the AESO with concerns or
problems impacting compliance
• AESO First Call (Operations Support):1-888-588-2376,
[email protected]
• [email protected] – Questions, enhancement suggestions
• Communication with Compliance: [email protected]
• Pool Participant Manuals on AESO website
• Compliance section of ISO website (FAQ, overviews, quarterly
reports, Notifications)
• AESO System Controller
– To make them aware of a limitation on your: scada, ADaMS, ETS
– To make them aware of a problem with one of our systems
– To make them aware of potential impacts on grid reliability
ISO Rules
ISO Rules – Information Documents
Topic: 2014 Statistics
Annual Stats: Event Count by Status
2014 YTD
300
2013
2012
2011
2010
257
250
200
173
155
150
125
100
97
91
71
50
63
68
66
49
38
27
34
0
Events
IR
Referred
45
Stats: By Rule
Q4 2012 – Q3 2013
0
10
20
30
Q4 2013 – Q3 2014
40
ISO Rule 201.3
37
ISO Rule 6.5.3
31
ISO Rule 203.4
19
ISO Rule 3.6.2
14
ISO Rule 203.3
10
ISO Rule 201.7
9
ISO Rule 3.5.3
6
ISO Rule 301.2
5
ISO Rule 6.6
4
0
50
10
20
30
ISO Rule 203.3
25
ISO Rule 6.5.3
16
ISO Rule 201.3
14
ISO Rule 301.2
5
ISO Rule 505.4
5
ISO Rule 203.6
4
ISO Rule 3.6.2
4
ISO Rule 502.1
3
3
3
ISO Rule 203.1
ISO Rule 6.3.3
3
ISO Rule 201.7
50
43
ISO Rule 203.4
ISO Rule 502.4
40
2
ISO Rule 203.6
2
ISO Rule 303.1
1
ISO Rule 304.3
2
ISO Rule 201.4
1
OPP 404
1
OPP 003.2
1
OPP 102
1
ISO Rule 306.6
1
ISO Rule 6.4.3
1
ISO Rule 6.4.3
1
ISO Rule 203.1
1
ISO Rule 505.4
1
ISO Rule 303.1
1
Stats: By Source
Q4 2012 – Q3 2013
160
Q4 2013 – Q3 2014
151
140
129
122
120
110
100
80
60
40
20
29
19
0
Internal Referral
Routine Monitoring
Total
Stats: By Outcome
Q4 2012 – Q3 2013
160
Q4 2013 – Q3 2014
151
140
129
120
100
80
75
72
62
60
38
40
17
20
11
5
0
Dropped
Not-Pursuing Letter
Referral
Open
Total
Stats: Referrals to MSA
Q4 2012 – Q3 2013
Q4 2013 – Q3 2014
Total: 72
P40
P39
P38
P37
P36
P35
P34
P33
P32
P31
P30
P29
P28
P27
P26
P25
P24
P23
P22
P21
P20
P19
P18
P17
P16
P15
P14
P13
P12
P11
P10
P9
P8
P7
P6
P5
P4
P3
P2
P1
Q4 2013 – Q3 2014
Total: 38
P26
P25
P24
P23
P22
P21
P20
P19
P18
P17
P16
P15
P14
P13
P12
P11
P10
P9
P8
P7
P6
P5
P4
P3
P2
P1
0
1
2
3
4
5
Q4 2012 – Q3 2013
ISO Rule 6.6
ISO Rule 6.5.3
ISO Rule 6.3.3
ISO Rule 505.4
ISO Rule 502.1
ISO Rule 306.6
ISO Rule 303.1
ISO Rule 3.6.2
ISO Rule 203.4
ISO Rule 203.3
ISO Rule 203.1
ISO Rule 201.7
ISO Rule 201.3
0
1
2
3
4
5
0
10
20
30
40
Stats: Event Processing Time
Q4 2013 – Q3 2014
Average
Max
Median
250
231
200
150
105
95
100
98
89
67
50
37
12
11
15
35
7
0
Discovery Date to Prelim.
Assess.
Preliminary Assessment
Preliminary Assessment to
Drop/Refer
File Date to Drop/Refer
MSA Q3 2014 Stats
Topic: ISO Rule 9.1 monitoring
What is ISO Rule 9.1?
There are 3 main obligations:
• Transmission Facility Owner (TFO) Obligation to Provide Estimates and Proposals (ISO
Rule 9.1.2)
• Project Reporting by Designated TFOs (ISO Rule 9.1.3)
• Project Procurement (ISO Rule 9.1.5)
How are the rules currently being monitored?
Prior to 2011 – adhoc program
2012 to present – monitoring activities:
• Quarterly monitoring of project reports
• Compliance Monitoring Audits (Full/Focused) – ISO Rule 9.1.5 only
• Internal and/or External referrals
• MSA request
For more information, please see (AESO.ca/Compliance/ISO Rule 9.1 Compliance Monitoring).
ISO Rule 9.1 (continued)
Results of current monitoring
• In 2012 and 2013 –total of 20 full audits, 5 internal referrals, 1 MSA request and 1 from
quarterly monitoring
• 2014 – 12 full audits initiated. To date, 7 audits have been completed, 4 audits are
underway, and 1 audit in the evidence gathering phase.
• There have been 9 MSA referrals of a total 22 suspected contraventions between 2012 and
now.
For more information, please see the Compliance Quarterly Reports in the AESO website
(AESO.ca/Compliance/Quarterly Reports).
What’s ahead…
• The ISO Rule 9.1 rewrite initiative for ISO Rules 9.1.2, 9.1.3 and 9.1.5, is currently
underway.
• Working groups formed to discuss the needed changes to improve the rules.
• Rule development and filing with the AUC are planned for early to mid-2015.
Topic: 2014 changes
• Rule changes
• DT and ETS changes
2014 Rule Changes
• 306.5 – Generation Outage Reporting and Coordination
• Effective July 2
• Planned outage/derate requirements – 2 yrs, 3 mnths
• Delayed forced outage – ETS, call SC if <24 hrs
• Automatic forced outage – ETS, call SC
• 306.6 – Transmission Planned Outages
•
Effective July 2
•
2 yrs, min 30 days for significant outages – requests
•
Noon tues week before for non-significant
•
Outage request submission detail
•
Real-time – call to SC
•
Requirement to coordinate outages with gen legal owners 5(1)
•
Requirement for gen to also work with TFO
2014 Rule Changes
• Changes for Dispatchable wind
• Change to ADV for wind
• 306.5 – outage notification requirements apply to wind
• 304.3 – wprm taking into account any dispatches to wind
• 502.1 – tower availability must be reflected in AC
• Effective Apr 1, 2015
• OPP 401/402
• OR restatement to higher level MUST be prior to T-30
• Effective June 1
2014 - ETS and DT Changes
• Removal of interchange dispatches – Dec 2013
• Addition of MSG to ETS historical offers report - Feb
• IE9 support – Mar
• Tightening of timing of Merit Order Snapshot report - Oct
• Warning on missing offer control at submission - Oct
Topic: Upcoming for 2015
• Rule changes
• DT and ETS changes
• Increasing Compliance focus
Upcoming Rule Changes
• New OR rules including directive response
• Effective Dec 2014 (current target)
• AS Technical Requirements to rules
• Preserving handling dispatch and contract non-compliance via
contract provisions
• Clarity on requirements
• Load provision of SR
• Revised SR/SUP directive compliance
– Must ramp up by 100% of directive by T+10
– Must maintain avg generation until T+15
– ADV applies after T+15
– Clarification on expectations when energy dispatch while
directive response
Upcoming Rule Changes (tentative)
• New TCM rule – no changes from compliance monitoring
perspective (directives – 301.2)
• 502.7 Load Technical requirements
• Min tech requirements for load connected or connecting
• Initiated early in 2014, will be resumed in 2015
• Battery Technical and Operational Requirements
• 502.13/14
• Posting draft rules in early 2015
• LSSI contract changes (tentative)
•
Mid year 2015
•
Changes discussed in LSSI review report published earlier this year
•
Non-compliance ‘waiver’ process, availability lockdown by T-23,
manual trip provision (10 minute response)
Upcoming Rule Changes (tentative)
• AOR initiative
• Discussion paper in early 2013
• Currently on hold
• Update in 2015 to indicate where it is going
• Rule effective date issue
• Eg 502.8, 502.4,…
• Link to AD meetings/schedule
• Home->Rules & Standards->Authoritative Document Process >Authoritative Documents Stakeholder Information Sessions
Upcoming ETS and DT changes (tentative)
• ADaMS/DVN enhancements
• Project initiated in October – to be rolled out in Q2
• First changes in several years
• Monitor RR dispatches and warn if unit not set up
• Monitor AC changes to 0 MW and warn if OR obligation
• Option to use ramping aligned with 203.4 requirements
• Making configuration parameters modifiable by participants
Upcoming ETS and DT changes (tentative)
• Other modifications to ADaMS
• Part of same October project with projected Q2 rollout
• Addition of messages related to TCM initiated or completed
• Message when limiter in place after dispatch reject
• Message when start time must be submitted
• Ability to test alarm sounds at user end
• Ability to modify passwords by user
Upcoming ETS and DT changes (tentative)
• ETS enhancements
• Missing offer control report
• Simpler default offer control – separation from standing offers
• Design currently, tentative rollout in Q2
2015 – Increasing Compliance Focus
• Wind participation including directive response, frequency
response and dispatch response
• Timeliness of AC declarations
• OR directive response
• AGC demonstrated ramp rate
• Generator Outage rule
• Transmission Outage rule
Topic: Questions
• Issues/Questions submitted in response to the session invite
– Most common infractions (see stats!)
– Areas not looking at so much any more, areas with more focus (see stats!)
– Tolerances when evaluating non-compliance
– Perception of targeting market participants
– Compelled to investigate if asked about interpretation/application of rule?
– Update on request to auto restate on e-tag curtailments
– ETS browser support – update to newer versions and other browsers
• Other Questions?
Thanks for coming!