Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation

Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation
Date: 2012-03-06
Second Consultation on Proposed New ISO Rules 301.2 ISO Directives (“New ISO Rules Section 301.2 Version 2.0”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
Comments From:
ATCO Power
Date [yyyy/mm/dd]:
2012/03/30
2012/03/06
2012/03/06
through 2012/03/30
Contact:
Aliza Dewji
Phone:
403-245-7727
E-mail:
[email protected]
Listed below is the summary description of changes for the proposed new, removed or amended sections of the ISO Rules. Please refer back to the Letter of Notice under the “Attachments to
Letter of Notice” section to view the actual proposed content changes to the ISO Rules. Please place your comments / reasons for position underneath (if any).
1. ISO Rules Definitions
(a) New
There are no new ISO rules definitions with proposed New ISO Rules Section
301.2 Version 2.0.
Stakeholder Comments and/or Alternate Proposal
Comment # 1: Insert Comments / Reason for Position (if
any)
(b) Removals
There are no ISO rules definition removals associated with proposed New ISO
Rules Section 301.2 Version 2.0.
Comment # 2: Insert Comments / Reason for Position (if
any)
(c) Amendments
“Package 12” ISO Rule Definition Changes contains a proposed amended
definition for “directive” and is being consulted on separately but concurrently with
proposed New ISO Rules Section 301.2 Version 2.0. To view the Letter of Notice
for the “Package 12” ISO Rules Definition Changes please visit the AESO website
at www.aeso.ca and follow the path Rules & Standards > ISO Rules > Proposed
ISO Rules & OPP Changes.
Comment # 3: Insert Comments / Reason for Position (if
any)
Please see ATCO Powers comments regarding the
proposed definition.
2. ISO Rules
Issued for Stakeholder Consultation: 2012-03-06
Stakeholder Comments and/or Alternate Proposal
AESO Replies
AESO Replies
Page 1 of 4
(a) New
Proposed New ISO Rules Section 301.2 Version 2.0 set out certain authoritative
provisions relocated from existing ISO OPP 806 Reliability Directives (“ISO OPP
806”), as well as new provisions.
Comment # 4: Insert Comments / Reason for Position (if
any)
The following outlines the key differences and rationale for each of the amended
subsections between the previously consulted on February 4, 2011 New ISO
Rules Section 301.2 and proposed New ISO Rules Section 301.2 Version 2.0.
Title Change
Comment # 5: Insert Comments / Reason for Position (if
any)
The title of proposed New ISO Rules Section 301.2 Version 2.0 has been
changed from “Directives for the Reliable Operations of the Interconnected
Electric System” to “ISO Directives”. In the AESO’s opinion, Proposed New ISO
Rules Section 301.2 Version 2.0 is focused on directives received from the
AESO, and as such, the title ISO Directives is appropriate.
Subsection 2(2) Directives the ISO Issues
Comment # 6: Insert Comments / Reason for Position (if
any)
A provision has been added which states that the AESO may issue a directive
verbally, electronically or in writing. The AESO’s current practices are that it
issues a directive verbally, electronically or in writing; therefore, in the AESO’s
view, adding this provision provides certainty and clarity with regard to how the
AESO issues directives.
Subsection 3(1) Requirement to Comply
The specific conditions which may prevent the legal owner of a generating unit or
an aggregated generating facility from complying with an ISO directive have been
added. These specific conditions were previously contained in ISO OPP 806. In
the AESO’s opinion, these specific conditions have been included in proposed
New ISO Rules Section 301.2 Version 2.0 for clarity.
Issued for Stakeholder Consultation: 2012-03-06
Comment # 7: Insert Comments / Reason for Position (if
any)
ATCO Power recommends the AESO remove sections
3(1), 3(2) and 3(3).
Regarding section 3(1), the obligation for a market
participant to comply with an ISO directive is already
contained within ISO rule 6.7.3; the duplication is not
necessary.
Section 3(2) repeats the allowed exceptions under
section 39(4) of the EUA.
Section 3(3) is simply a reference to the Transmission
Regulation.
Duplication of legislation / regulation is not required
Page 2 of 4
within an ISO rule.
Subsection 3(4) Requirement to Comply
Comment # 8: Insert Comments / Reason for Position (if
any)
A provision has been added requiring a market participant that is a pool
participant to communicate any ISO directive it receives to the operator of the
facility. In some circumstances, a pool participant may be the recipient of an ISO
directive and therefore the pool participant should be obligated to communicate
the ISO directive to the operator of the facility. This new provision is necessary,
in the AESO’s opinion, as it provides clarity for pool participants and operators.
Subsection 4 Report Inability to Comply
Comment # 9: Insert Comments / Reason for Position (if
any)
A five (5) minute timeframe for reporting an inability to comply with an ISO
directive or from communicating the ISO directive to the operator if the ISO
directive was received by a pool participant has been added. In the AESO’s
opinion, this five (5) minute timeframe is important and necessary from a
compliance perspective and provides clarity and certainty for market participants.
Issued for Stakeholder Consultation: 2012-03-06
Page 3 of 4
(b) Amendment
Related proposed amendments to ISO OPP 806 Reliability Directives (“ISO OPP
806 Changes”) are being consulted on separately but concurrently with the
proposed New ISO Rules Section 301.2 Version 2.0. To view the Letter of Notice
for the proposed ISO OPP 806 Changes please visit the AESO website at
www.aeso.ca and follow the path Rules & Standards > ISO Rules > Proposed
ISO Rules & OPP Changes.
Comment # 10: Insert Comments / Reason for Position
(if any)
(c) Removals
The proposed amended definition for the term “directive” was initially consulted on
as part of proposed New ISO Rules Section 301.2 on February 4, 2011. In the
AESO’s opinion, the definition for directive should be consulted on as a separate
definition package such that it follows the AESO’s typical protocols for consulting
on definitions. Accordingly, the AESO has included the proposed amended
definition for directive in “Package 12” as indicated above
Comment # 11: Insert Comments / Reason for Position
(if any)
(d) Other
Comment # 12: Insert Comments / Reason for Position
(if any)
(Stakeholders wishing to comment on specific provisions are requested to copy
the provision into this area and provide comments)
Issued for Stakeholder Consultation: 2012-03-06
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