AESO Market Compliance Year in Review – 2011 February 10, 2012

AESO Market Compliance
Year in Review – 2011
Presentation to Alberta Compliance Discussion Council
February 10, 2012
Topics
• Market Compliance Team changes
• 2011 stats review
• Trends over 2011
• Other 2011 work (screening added, Notifications, rule
9.1, website updates, DVN)
• 2012 areas of increased/new focus (tentative)
• Issues discussion/updates
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Topic: Market Compliance Team
VP Regulatory
Heidi Kirrmaier
Director-Compliance
Peter Wong
Manager – Compliance
Manager – Compliance
Manager – Compliance
Alberta Reliability Standards
Load Settlement
Market Monitoring
Daniela Cismaru
Mike Choboter
Kevin Wipond
ARS team
Load Settlement Team
Analyst
Merima Halkic
Analyst
Pedro Lagos
Analyst
Umesh Pillai
3
Topic: 2011 Statistics
• Statistics for 2011 – thus far (Nov/Dec outstanding)
– Tentative (subject to revision prior to external report)
• Comparison to 2010 numbers (at approx. same time)
4
Stats: Event Count (as of Feb 1, 2012) tentative
Counts 2010
Counts2011
180
180
160
140
120
100
80
60
40
20
0
163
153
160
145
126
140
120
100
80
53
60
40
19
40
20
Events
IR
Still Open
Completed
10
0
Count
IR
Still Open
Completed
5
Stats: by Rule (as of Feb/12) - tentative
2011 by rule
2010 by rule
OPP 505
1%
OPP 102
2%
OPP 003.2
4%
ISO rule 6.5.3
9%
ISO rule 6.3.3
20%
Other
4%
OPP 517
1%
DV
58%
ISO rule 3.5.3
1%
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Stats: by Source (Feb/12) - tentative
2010 Event Sources
Clarification, 4
OC Referral, 11
ASP, 1
Other, 4
SC referral, 17
Routine Monitoring, 126
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Stats: by Outcome (Feb/12) - tentative
2010 Outcomes
Referral, 23
Not-pursuing Letter, 9
Dropped, 121
8
Stats: Event Processing Time (as of Feb/12)
- tentative
ProcessingTimeof Eventsin2010
Average Min Max Median
160
145
140
120
Days
100
74
80
63
62
60
47
37
36
40
20
10
6
0
1
0
31
7
5
8
0
Disc. DatetoPrelim.
Assess.
Prelim. Assess.
Prelim. Assess. To
Drop/Refer
Event Dateto
Drop/Refer
Process substep
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Stats: Referrals (as of Feb/12) - tentative
Referrals in2010 - Count byMaskedParticipant IDand
Quarter of Occurrence
Referrals to MSAby Quarter of File Date and Masked ID
Participant
P1
Q1-11
Q2-11
1
1
Participant ID
Q1
1
P1
P2
P3
P4
P5
P6
P7
P8
P9
P10
P11
P12
P13
P14
P16
1
1
1
1
1
P2
P3
P4
1
1
1
1
P5
P6
P7
1
2
1
2
P10
P11
P12
P13
1
1
1
1
1
P14
P15
1
1
P8
P9
Q3-11
1
1
Q4-11
Q2
Q3
1
1
2
2
1
1
1
1
1
1
1
1
1
3
1
10
Referrals in 2011 (thus far)
• 6.3.3 – 4 all year – failure to coordinate offer with e-tags
• 6.6 – 5 all year – 4 cogens – 30-60 min duration
• 6.5.3 – 1 all year
• 3.5.3 – 4 all year, human error, testing
Referrals to MSA by Quarter of File Date and
Category
Category
ISO rule 3.5.3
ISO rule 3.6.2
ISO rule 6.3.3
ISO rule 6.5.3
ISO rule 6.6
OPP 102
OPP 806
ISO rule 3.5.5
Q1-11
Q2-11
Q3-11
2
2
3
1
1
Q4-11
1
3
1
1
1
1
1
1
3
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Trends in 2011
• Greater self-reporting to MSA
– 206 in 2011(tentative)
– 85 in 2010
• Less non-compliance
• Smaller magnitude/duration/impact
• More complex cases – rule interpretation and
markets/commercial involvement
12
Other 2011 work
• Added screening
• Notification letters
• ISO rule 9.1 efforts
• Website updates
• DVN changes
13
New/additional screening 2011
• Demonstrated ramp rate review
• Unanswered wind facility phone calls
• New screening of AS directives
• Greater attention to response to reliability directives
• Review of behavior during OPP 801 (supply shortfall)
events – phone calls, offer changes, dispatch response
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Notifications Letters in 2011
• Notification letters – not NC!
• Notification letters w/o examples sent to some/all
relevant participants – clarity on obligations, examples
– TSR and ATC info in m/x restates down
– Testing is not an AOR
– 9.1 FCR reporting
• Adding all relevant past Notifications to website for
reference
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ISO rule 9.1 Transmission Projects
• Major focus in 2011 and continuing into 2012
• Impact on TFOs
• Obligations in rule for project reporting and competitive
procurement
• Audits of procurement
• Formalizing AESO business practices and
communicating/clarifying obligations and implications of
non-compliance
• Possible rewrite of rule initiated in 2012
• 6-10 audits to be carried out
16
Website updates
• FAQ
• Minor updates to other areas
• Quarterly reporting
• Suggestions?
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DVN
• No changes in 2011 except for bug fixes
• Enhancements coming in early 2012
– Advance dispatch reminder at top of hour
– Fixes for handling of AS dispatches
• Other possibilities
– Usefulness?
– Ideas?
18
Increased focus in 2012 (tentative)
• Rule 5 – outage scheduling obligations – declaration,
timing
• AC submission timeliness
• MSG rule
• WPM
• Reliability directives – automation?
• More attention to M/X restatements down especially with
more data
• Testing – AC changes, new rule to replace 603
19
Issues discussion/update
• OPP 603 and testing
• AS market and ISO rule contraventions
• TCM and reliability directives
• Alignment with MSA 30 day self-reporting window
• Clarification requests
20
OPP 603 and Testing
• Obligations – don’t have to schedule right now
• Benefit of scheduling
• Testing without scheduling, risks
• What is coming?
– some testing will have to be scheduled
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AS market and ISO rule contraventions
• AESO can choose to pursue certain AS behavior as
both a contract and ISO rule contravention and its not
double jeopardy!
• AS directives – 6.5.3
• 6.4.3 – AS provider discretion/expectations – eg
accepting a dispatch for SR and not being synchronized
• 3.6.2 – AS availability – eg failure to restate out after a
trip
• How decide – frequency, referral, materiality
• 2012?
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TCM and reliability directives
• Use of DT to calculate constraints
• Use of DT to issue directives
• Instead of verbally
• Obligation to pass on vs act on
• TCM rule including allowed approaches
– 9.4.1f – curtail highest price effective asset for up to end of T+2
– 9.4.2 ‘additional optional procedures’ – eg respecting MSG
– Review the rule and seek clarification
• Refusal of reliability directive if ‘real and substantial risk to facility,
personnel, public or environment’ – work cooperatively with SC
23
Timing changes
• Introduction of 30 day lag
• Implications – self-report, our event processing delays
• Opinions?
24
Clarification Requests - reminder
• Part of the screening process - not an IR
• 46 sent in 2011 (so far) and 2 resulted in IR
• A ‘light weight’ mechanism for market participants to elaborate on their restatement
reason and the basis on which they determined that there was an acceptable
operational reason (AOR)
• A single email asking for more detail on potentially multiple unrelated instances
• Based on the review of the response to the CR, the AESO may decide to proceed with
an Preliminary Assessment (but usually not)
• Value of CR process?
– Typically handled much more quickly by the AESO
– Less onerous for some market participants than Information Request response
– Change in behavior (eg more detail in restatement reason)
• Some market participants treat a Clarification Request like an Information Request
• Because it is informal, response is not intended to be part of evidence passed to MSA,
need for separate IR response
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Questions/Issue discussion
• ETS problems?
• Other issues?
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