Compliance Quarterly Report Q2 2013

Compliance Quarterly Report
Q2 2013
ISO Rules…………………………………………………………………………………………1
ISO Rule 9.1 ……………………………………………………………………………………..2
Load Settlement………………………………………………………………………………….3
Alberta Reliability Standards……………………………………………………………………4
Terminology………………………………………………………………………………………5
Compliance Quarterly Report- ISO Rules- Q2 2013
Update August 08, 2013
The following charts summarize the activities of the ISO Rules Compliance group in Q2 of 2013 and the distribution of events over the past 4 quarters. Please refer to the attached
help documentation for details on interpreting the charts below. For any questions in regards this report, please send an email to [email protected].
Files Opened in Period- Count by Category
Files Opened in Period- Count by Origin
Files Closed in Period-Count by Status
R 502.4, 1
R 203.4, 2
R 303.1, 1
Dropped , 11
Monitoring, 6
R 6.5.3, 5
R 201.7, 6
Internal
Referral, 11
Referral to MSA,
24
R 301.2, 1
Other, 1
R 3.6.2, 1
R 201.3, 1
Referrals to MSA in Period- Count by Category
Commentary
There were 18 files opened this quarter and 35 files closed. The bulk of the opened files pertained to
dispatch variances or AS directives. Note that there is a change in rule numbering corresponding to the
coming into effect of the new core market rules in January. There were 24 referrals to the MSA of
suspected contraventions in Q2, 20 of which were for rule 201.3 - Offer Control Information and
pertained to events with file dates in Q4 2012 or Q1 2013. There were 48 referrals to the MSA over the
last 4 quarters with 28 being for rule 201.3. These referrals continue to be distributed across a large
number of market participants. ISO 201.3, the offer control rule came into effect in December 2012.
The large number of referrals this report and last reflect a misunderstanding of when and how the offer
control information should be provided. Based on our interactions with market participants, we believe
that it is unlikely we will continue to see a large number of contraventions of this rule in the future. Ten
Q2 files remain open at the time of this report. There have been small decreases in the average
processing time of files between this report and the last.
R 3.5.3 , 1
R 6.5.3, 1
R 6.6, 2
R 201.3, 20
Note: As the AESO may refer multiple events in a single referral to the MSA, the count of Referrals to MSA will not necessarily line up with the count
of penalties issued by the MSA in any given period.
Files Opened by Quarter of File Date - Count By Category
Q3-12
Q4-12
Q1-13
Files Opened by Quarter of File Date - Count By Status
Dropped
Q2-13
Referral to MSA
Open
60
45
54
40
50
35
30
40
25
34
20
30
15
24
10
20
5
10
11
10
OPP 404
R 304.3
R 203.3
R 203.4
R 502.4
R 303.1
R 201.7
R 201.3
R 6.4.3
R 3.6.2
R 301.2
OPP 303
OPP 003.2
OPP 102
R 6.6
R 6.5.3
R 6.3.3
R 3.5.3
0
6
7
Q3-12
Referrals to MSA by Quarter of File Date and
Category
Q4-12
1
Q4-12
2
2
1
1
1
Q1-13
1
1
1
1
Q2-13
2
1
1
Q3-12
3
3
Q4-12
1
1
4
Q1-13
3
Q2-13
Processing Time of Files Opened in Last Four Quarters
Average
Category
ISO rule 3.5.3
ISO rule 6.3.3
ISO rule 6.5.3
ISO rule 6.6
Opp 303
ISO rule 3.6.2
ISO Rule 201.3
ISO rule 201.7
ISO rule 303.1
Max
Median
Q2-13
203
200
1
1
150
3
25
1
1
1
2
1
103
100
99
84
77
64
1
1
1
1
1
1
1
1
1
50
18
6
3
10
7
0
0
Disc. Date to
Prelim. Assess.
1
1
1
1
1
1
1
Q1-13
Days
Q3-12
1
0
Referrals to MSA by Quarter of File Date and
Masked ID
Participant
P1
P2
P3
P4
P5
P6
P7
P8
P9
P10
P11
P12
P13
P14
P15
P16
P17
P18
P19
P20
P21
P22
P23
P24
P25
P26
P27
P28
P29
P30
P31
P32
P33
P34
P35
P36
P37
P38
4
1
1
1
1
2
1
2
1
1
1
1
1
1
1
1
Prelim. Assess.
Prelim. Assess. To
Drop/Refer
File Date to
Drop/Refer
ISO Rule 9.1 Compliance Quarterly Report - Q2 2013
Update July 31, 2013
The following charts summarize the status of the 2012 and 2013 activities of ISO Rules Compliance group in relation to ISO rule 9.1 as of Q2 2013. For any questions in regards
this report, please send an email to [email protected].
3. Other 9.1 Events in 2012/2013 Count by ISO Rule Subsection
2. Distribution of 2013 Audits Count by Masked TFO
1. Status of the 2012/2013 ISO Rule 9.1
Compliance Audits - Count by Projects
3
R9.1.3.1 =
1
R9.1.5.6b)
=1
Not yet initiated
4
Initiation phase
3
4
TFO 2
Testing phase
TFO 3
Draft report phase
TFO 4
Report finalized
12
TFO 1
R9.1.5 = 2
Audit complete
R9.1.3.4 =
3
2
1
4. 2012/2013 ISO Rule 9.1 Event Outcomes - Count
by Category
1
6. 2012 ISO Rule 9.1 Completed Compliance Audits – Duration in days of
each phase
140
5
No. of events where no
contraventions identified
120
100
No. of events where 1 or
more suspected
contraventions identified
80
Average
Maximum
60
Median
40
20
14
0
Initiation phase
5. Suspected Contraventionsions in 2012/2013 Count by ISO Rule Subsection
1
Testing phase
Draft report phase
Report finalized
Audit completed
7. 2013 ISO Rule 9.1 Completed Compliance Audits – Duration in days of
each phase
140
120
100
5
R9.1.5.2/9.1.5.3
R9.1.5.6a)
80
Average
Maximum
60
R9.1.5.10
Median
40
6
20
0
Initiation phase
Testing phase
Draft report phase
Report finalized
Audit completed
Commentary
This report for the second quarter of 2013, includes a summary of activities and monitoring for 2012/2013.
All of the ten transmission facility projects subjected to audits in 2012 have been completed, as well as two projects subjected to audit in 2013 as shown in graph no. 1. As of Q2
2013, three audits are at the testing phase and 2 audits are at the draft report phase.
Other 9.1 events captured in graph no. 3 are compliance monitoring activities (i.e. audits and/or assessments) that were identified through internal and external referrals.
There have been five referrals to the MSA regarding suspected contraventions of ISO rule 9.1, as shown in graph no. 4, some with multiple contraventions of the subsections of
the rule shown in graph no. 5. All of these referrals resulted from the 2012 monitoring.
Graphs 6 and 7 serve as an indication of the time it has taken to complete the various phases of each completed audit.
The Compliance section of the AESO website contains a subsection titled “ISO Rule 9.1 Compliance Monitoring”. This is intended to provide clarity and transparency regarding
the AESO’s monitoring of TFO compliance with ISO rule 9.1. Among the documents is a Compliance Monitoring Audit process document, as well as related templates. These
documents provide market participants with a comprehensive description of how the audits are carried out. This documentation is updated and enhanced as the processes are
refined and market participants are encouraged to review it at regular intervals. Updates made in 2013 can be found in the Compliance section of the AESO website under
Notices.
In addition, Information Document # 2012-003(R) Transmission Facility Projects, was posted to the Rules and Standards section of the AESO website in Q2 2012. This
Information Document is intended to provide additional clarity on the intent of ISO rule 9.1.
2
Compliance Quarterly Report - Load Settlement - Q2 2013
Update August 15, 2013
The following charts summarize the activities of the Load Settlement Compliance group over the four quarters ending June 2013. Please refer to the attached chart
explanation and help documentation for details on interpreting the charts below. For any questions in regards this report, please send an email to [email protected].
Files Opened in Period - Count by Category
Files Closed in Period - Count by Status
Files Opened in Period - Count by Origin
External
Referral, 0
Referral to
AUC, 2
Settlement, 4
Metering, 4
Metrics, 0
Dropped , 6
PFAM, 2
Monitoring, 4
Other, 0
Referrals to AUC in Period - Count by Category
Commentary
For the second quarter of 2013 we saw very low errors from market participants. This steady
improvement with market participants compliance to Rule 21 shows that the Rule is stabilizing
and market participants systems are working.
Metering, 2
PFAM, 2
The six files 'dropped' were still identified to the AUC and the market participant as potential
contraventions but were deemed not material enough for a full investigation. Corrections by the
market participant were made when deemed necessary
We will continue to work with industry and the AUC to simplify and streamline Rule 021 to make
it more effective for all involved.
Microgen, 0
Settlement, 0
Other , 0
Files Opened by Quarter - Count by Status
Files Opened by Quarter - Count By Category
Q3-12
Q4-12
Q1-13
Dropped
Q2-13
Referral to AUC
Open
10
6
9
5
8
7
4
6
5
3
4
2
3
2
1
1
0
0
Microgen
Other
Metrics
Referrals to AUC by Quarter of Referral Date and
Masked Participant ID
Participant
LS1
LS2
LS3
LS4
LS5
LS6
LS7
LS8
LS9
LS10
LS11
LS12
LS13
Q3-12
1
1
2
Q4-12
1
Q1-13
1
2
1
Q2-13
1
2
1
PFAM
Q3-12
Settlement
Category
Metering
Microgen
Other
Metrics
PFAM
Settlement
Q3-12
1
2
Q4-12
Q1-13
Q4-12
Q1-13
Q2-13
Processing Time of Files Opened in Last Four Quarters
Referrals to AUC by Quarter of Referral Date
and Category
Average
16
Q2-13
Maximum
15
Median
15
15
14
1
12
1
1
2
1
2
10
Days
Metering
8
8
8
7
6
4
4
2
1
1
0
1
0
Disc. Date to Prelim. Assess.
3
Prelim. Assess.
Prelim. Assess. To
Drop/Refer
Compliance Quarterly Report - Alberta Reliability Standards Monitoring - Q2 2013
Update July 11, 2013
The following charts summarize the activities of the Alberta Reliability Standards Compliance Monitoring group as of end of Q2 - 2013 and the distribution of events over the past
four quarters. Please refer to the attached help documentation for details on interpreting the charts below. For any questions in regards this report, please send an email to
[email protected].
Self-Certification
# Requested
# Received
Periodic Reporting
# Resubmission Requested
# Referred
# Requested
# Received
# Investigated
# Referred
9
30
8
25
7
20
6
5
15
4
10
3
2
5
1
0
0
Cycle 3-2012
Cycle 4-2012
Cycle 1-2013
Cycle 2-2013
Q3-12
Compliance Monitoring Audits
# of Scheduled Audits
# of Audits in Progress
# of Audits Completed
Q4-12
Q1-13
Q2-13
Alberta Reliability Standards Registry
# of MSA referrals
# of Spot Audits
Q3-12
Q4-12
Q1-13
Q2-13
7
90
6
80
70
5
60
4
50
3
40
30
2
20
1
10
0
Q3-12
Q4-12
Q1-13
0
Q2-13
# of Registered Market Participants
Registration by Functional Entity Type - Table 1
Q3-12
Q4-12
Q1-13
Registration by Functional Entity Type - Table 2
Q2-13
Q3-12
60
60
50
50
Q4-12
Q1-13
Q2-13
40
40
30
30
20
20
10
10
0
Legal Owner of Legal Owner of Legal Owner of Legal Owner of
a generating a transmission
an electric
an aggregated
facility
unit
distribution
generating
system
facility
0
Demand
Customer
Generation Facility Operator of a
Owner
generating unit
Pool Participant
Transmission
Facility Owner
Wire Owner
Wire Services
Provider
# Requirements by Functional Entity Type - Table 1*
Q3-12
Q4-12
Q1-13
Q2-13
Market
Participant
Operator of an Operator of an Operator of a Operator of a Pool Participant
generating unit transmission
electric
aggregated
facility
distribution
generating
system
facility
# Requirements by Functional Entity Type - Table 2*
Q3-12
* Count based on Start of Quarter
90
80
80
70
70
Q4-12
Q1-13
Q2-13
* Count based on Start of Quarter
60
60
50
50
40
40
30
30
20
20
10
10
0
0
Demand Customer Generation Facility
Owner
Operator of a
generating unit
Pool Participant
Transmission
Facility Owner
Wire Owner
Market
Legal Owner Legal Owner Legal Owner Legal Owner
Participant
of a
of a
of an electric
of an
aggregated distribution generating transmission
facility
unit
system
generating
facility
Wire Services
Provider
Operator of
an
aggregated
generating
facility
Pool
Operator of Operator of a Operator of a
an electric generating transmission Participant
facility
unit
distribution
system
Commentary
Self-Certification: There were 2 administrative deficiencies for Cycle 2-2013.
Periodic Reporting: All periodic reports were submitted on time.
Compliance Monitoring Audits: All compliance monitoring audits for Q3 2012 are completed. Four (4) audits scheduled for Q4 2012 have been completed and two (2) are in progress. Five (5)
audits scheduled for Q1 2013 are in progress. For Q2 2013, five (5) audits are in progress and one (1) is completed.
Alberta Reliability Standards Registry: The registry currently includes 78 market participants.
*Note: As the AESO may refer multiple items within a single referral to the MSA, the count of Referrals to MSA will not necessarily line up with the count of penalties issued by the MSA in any given period.
4
Common Terminology
Category
Table Specific Terminology
Each Compliance File has an associated Category which refers to the ISO rule,
AUC Rule 021 topic or Reliability Standard which may have been contravened. In
the case of multiple categories, a principle category is assigned to the File.
Origin
Clarification
Request
An email request sent in the ISO Rules Compliance process seeking additional
detail on the information submitted with an offer restatement. This is part of the
ISO Rules Monitoring process.
Compliance
File
A compliance file refers to one or more Flagged Events that have been logged for
Preliminary Assessment, or where a suspected contravention has been identified
through a Compliance Monitoring Audit in accordance with ISO Rule 103.12.
Every Compliance File has a status of Open, Dropped or Referred. Each
Compliance File is applicable to a single market participant and has an associated
File Date and Category.
Compliance
Monitoring
Audit
As described in ISO Rule 103.12. The process of monitoring or review of a TFO's
compliance with ISO Rule 9.1.5.
Compliance
Monitoring
Audit Report
A report described in ISO Rule 103.12.9 (4) which communicates the results of the
Compliance Monitoring Audit to the TFO and provides support for any referral to
the MSA.
Date of
Discovery
For an internal or external referral, the date that the referral was received. For
an event identified by Monitoring, the date on which the AESO discovers the
event and logs it for Preliminary Assessment.
Date of
Notification
File
File Date
Files Closed in
Period
CR
External
Referral
Other
A File Origin of type Other refers to events which Compliance examined but which
were brought to our attention through untypical means such as a question from a
market participant or an AESO IT problem report.
Synonym for Compliance File.
Compliance Files whose status changed to either Dropped File or Referred File
within the reporting period. Note that these may have file dates from earlier
quarters.
A File Origin of External Referral is a possible ISO rule, AUC 021 topic or
Reliability Standard contravention identified by individuals outside the AESO and
referred to compliance for a more detailed examination.
A File Origin of Internal Referral is a possible ISO rule, AUC 021 topic or
Reliability Standard contravention identified by other (non-compliance) personnel
in the AESO in the course of their own work and referred to compliance for a more
detailed examination.
Dropped File
A unique date associated with a Compliance File. In the case of ISO rules
compliance, this is the date of the event itself. In the case of AUC 021 monitoring,
this is the Date of Discovery.
A File Origin of CR indicates that the event resulted from a Clarification
Request.
Internal Referral
Status
The date that a TFO is notified of a Compliance Monitoring Audit of its
transmission facility project and a request for information that facilitate
commencement of the Compliance Monitoring Audit.
A Compliance File has an origin which is an indication of how the Flagged Event
was identified eg. Monitoring, SC Referral, OC Referral, etc.
Open File
The current state of a Compliance File. Either Open File, Dropped File or
Referred File.
The status of a Compliance File which is closed but is not a Referred File. A File
may be closed for a variety of different reasons including: unreliable data, AESO
IT system problems, Mitigating Factors as defined in ISO Rule 103.12 or an
assessment that no rule has been contravened. A dropped file may have resulted
in a Warning Letter being sent.
The status of a Compliance File which has been opened but which has not yet
been Dropped or Referred to the MSA/AUC.
Referred File
The status of a Compliance File for which a referral regarding the file has been
made to the AUC/MSA in accordance with ISO Rule 103.12.
A collection of one or more submissions or actions carried out by a market
participant that may form the basis of a compliance file. Flagged events can come
from Monitoring, an Internal Referral or an External Referral or from
Clarification Requests.
Processing
Time of Files
Opened in the
Last Four
Quarters
An indication of the number of days taken to move a Compliance File through
the various stages of the Compliance Process.
Information
Request
As described in ISO Rule 103.12, an Information Request is a letter submitted to
a market participant describing the particulars of a potential ISO rule, AUC 021
topic or Reliability Standard contravention and seeking the market participant’s
input on the event.
Disc. Date to
Prelim. Assess
The number of days between the Date of Discovery for a Compliance File and
the commencement of the Preliminary Assessment.
Masked
Participant ID
A unique identifier associated with each market participant for tracking Referred
Files for that participant but without revealing the particular participant. The
Masked Participant ID will NOT be consistent from report to report.
Prelim. Assess.
The number of days between the commencement of the Preliminary
Assessment and its completion.
Masked
Transmission
Facility Owner
(TFO)
A unique identifier associated with each TFO for tracking Compliance Monitoring
Audits for that participant but without revealing the TFO name. The Masked TFO
ID will NOT be consistent from report to report.
Prelim. Assess.
To Drop/Refer
The number of days between the completion of a Preliminary Assessment and
the decision to drop or refer the file to the MSA/AUC. This is only relevant for
events where an Information Request was sent.
Files Opened in
Period
Flagged Event
Monitoring
Compliance Files with a Date of Discovery falling within the reporting period.
Queries, reports and other tools run by Compliance on a regular basis to identify
Flagged Events.
Other
A Category of Other applies to events which Compliance examined but did not
prove to be associated with any potential rule contravention.
Other Events
Compliance monitoring activities, other than Compliance Monitoring Audit, in
relation to ISO Rule 9.1.1 Monthly Reporting , ISO Rule 9.1.3.4 Project Change
Proposal , and ISO Rule 9.1.3.6 Final Cost Report .
Preliminary
Assessment
Referrals in
Period
TFO Records
Warning Letter
File Date to
Drop/Refer
Duration of
ISO Rule 9.1
Compliance
Audits
As described in ISO Rule 103.12. The process of carrying out a detailed
examination of a potential ISO rule, AUC 021 topic or Reliability Standard
contravention (which is separate from a Compliance Monitoring Audit). This starts
with the opening of a Compliance File and culminates in a decision to: send an
Information Request regarding the event to the relevant market participant; to
conclude that the data does not support an assessment of non-compliance and to
drop the event; or, potentially, to make a referral to the AUC or MSA.
Initiated
Testing phase
Draft report
phase
Compliance Files which have been referred to the MSA/AUC (as appropriate) in
the period. Note that these may have file dates from previous quarters.
Documents, correspondences and other records of information that support
compliance with ISO Rule 9.1.5
Report finalized
In certain cases where a Preliminary Assessment has not been carried out or does
not support an assessment of non-compliance, a letter may be sent to one or more
participants which clarifies the obligations of a particular rule.
5
Audit
completed
The number of days between the File Date and the change in status for the
Compliance File to either Dropped File or Referred File.
An indication of the number of weeks taken to move a Compliance Monitoring
Audit through the various stages of the audit process.
The number of weeks between the Date of Notification and the date that the
AESO received the TFO Records.
The number of weeks between the receipt of the TFO Records and the date that
the AESO provided a Draft Compliance Monitoring Audit Report to the TFO for
review and comments.
The number of weeks between the end of the Testing Phase and the receipt of
TFO comments on the draft Compliance Monitoring Audit Report.
The number of weeks between the receipt of the Draft Compliance Monitoring
Audit Report with TFO comments and the Compliance Monitoring Audit
Report is finalized.
The number of weeks between the date of finalizing the Compliance Monitoring
Audit Report and the date of referral to the MSA or closing the audit, in case of
non-referral.