Stakeholder Comment and Replies Matrix AESO AUTHORITATIVE DOCUMENT PROCESS (“ISO OPP 517”)

Stakeholder Comment and Replies Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Proposed Removal of Existing ISO Rules: ISO OPP 517 Keephills/Ellerslie/Genesee (KEG) Area Operation (“ISO OPP 517”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2013/11/06
2013/10/22
through
2013/11/06
1. ISO Rules
(a) Removals
The AESO is proposing to remove ISO OPP 517 Keephills/Ellerslie/Genesee
(“OPP 517”) in its entirety.
ISO OPP 517 sets out policies and procedures for the operation of the
transmission and generation facilities in the Keephills/Ellerslie/Genesee Area
(“KEG Area”) of the Alberta Interconnected Electric System (“AIES”) including, the
KEG Area cutplane limits and the allowable most severe single contingency at
Genesee.
Informational content from ISO OPP 517 outlining the transmission system
constraint conditions will be relocated to an Information Document. Tables setting
out the cutplane limits resulting from these conditions and schematic maps of the
KEG Area will also be relocated to an Information Document to assist market
participants in understanding the AESO’s transmission constraint management
procedures in the KEG Area.
The AESO is seeking comments from stakeholders with regard to the following
matter:
1. Do stakeholders agree or disagree with the proposed removal of ISO OPP
517? If you disagree, please explain why you believe ISO OPP 517 should not
be removed.
Comments
TransCanada Energy Ltd. (TCE)
AESO Replies
1. While TCE takes no position to the removal of OPP
517 at this time, TCE questions the timing of the
removal given the current state of the issue of
transmission constraint management. At present,
the Alberta Utilities Commission has upheld
objections to ISO rules Section 302.1 Real Time
Transmission Constraint Management (the “TCM
Rule”) and the TCM Rule is only permitted to
operate in the interim, while it is revised. Several
market participants, including TCE, have questioned
whether the AESO has properly complied with the
AUC’s decision, including questioning whether the
proposed 5-year timeline for revising the TCM Rule
is reasonable. These issues are the subject of AUC
Proceeding ID 2674.
1. The Alberta Utilities Commission (“AUC”)
issued Decision 2013-135 regarding Section
302.1: Real Time Transmission Constraint
Management of the ISO rules (the “interim
TCM Rule”), directed the AESO to make
changes to the interim TCM Rule, and
permitted the interim TCM Rule to be used in
the period until such changes are made.
Furthermore, market participants are questioning
whether the issue of transmission constraints in the
planning phase has been properly dealt with and
have objected to the AESO’s Business Practice for
System Access Service.
Given this context, it is not clear to TCE the
justification for removing OPP 515 before the
For the reasons set out in the AESO’s Letter
of Notice, the removal of ISO OPP 517 is
necessary for the consistent and proper
application of the interim TCM Rule during
the period before the changes to the rule are
in effect.
Concurrent with the removal of ISO OPP
517, the AESO is issuing Information
Document #2013-004R
Keephills/Ellerslie/Genesee Area
Transmission Constraint Management. As
with the other Information Documents related
to the interim TCM Rule, this Information
Document provides additional information
AESO Replies to Stakeholder Comments: 2013-12-19
Page 1 of 5
foregoing proceedings, revisions and complaints
have been fully dealt with.
Although the removal of OPP 515 will result in
informational content being transferred to
information documents, TCE believes market
participants need some assurance that the AESO
will develop and amend the information documents
in a transparent fashion.
It appears that the AESO will exercise considerable
discretion in applying the TCM Rule in each specific
region and TCE believes that there is insufficient
transparency and process with respect to
determining the following system modeling
assumptions; severity of N-0, N-1, etc. constraints;
and generator effectiveness at alleviating
constraints. TCE suggests that the AESO should
implement a process for participants to test these
AESO's assumptions and determinations including
some form of dispute resolution.
AESO Replies to Stakeholder Comments: 2013-12-19
regarding the unique operating
characteristics and resulting constraint
conditions and limits in the
Keephills/Ellerslie/Genesee Area of the
interconnected electric system.
The AESO creates and amends Information
Documents when it has determined such
information may be useful to market
participants. For further information on the
AESO’s Information Documents, please refer
to the AESO Information Document
Characteristics located on the AESO’s
website.
The AESO takes TransCanada's concerns
under advisement, but notes that they are
out of scope for the subject matter of this
consultation.
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ENMAX Corporation
2. On October 22, 2013 the AESO issued a Letter of
Notice on the Proposed Removal of Existing ISO
Rules. In its notice the AESO indicated:
…In order to: a) complete the transition
of the remaining OPP 500 Series, b)
ensure consistent application of the
TCM Rule to all areas of the Alberta
Interconnected Electric System
(“AIES”), c) allow for the updating of
operational studies and system
operating limits in the relevant areas of
the AIES through use of Information
Documents, and d) ensure the proper
utilization of the AESO’s IT systems
specific to transmission constraints
management, the AESO is now
proposing to remove ISO OPPs 515,
517, 521 in their entirety and transfer
the appropriate informational content
from these OPP 500 Series into
Information Documents…
The transfer of OPP information into information
documents raises a question regarding what the
differences are between information documents and
authoritative documents. The AESO has previously
defined information documents and authoritative
documents:
An information document is for
information purposes only and is
intended to provide guidance. In the
event of any discrepancy between the
information document and the related
authoritative document(s) in effect, the
1
authoritative document(s) governs .
1
2. On October 22, 2013, the AESO provided
market participants with a Letter of Notice –
Consultation on the Proposed Removal of
Existing ISO Rules a) ISO OPP 515 South
Area Operation; b) ISO OPP 517
Keephills/Ellerslie/Genesee (KEG) Area
Operation; and c) ISO OPP 521 SOK-240
Operation; (collectively the “proposed ISO
OPP Removals”) along with Information
Document #2013-009R South Area
Transmission Constraint Management,
Information Document #2013-004R
Keephills/Ellerslie/Genesee Area
Transmission Constraint Management, and
Information Document #2013-002R North
South Area Transmission Constraint
Management (collectively the “ISO OPP
Removal IDs”).
Within each of the ISO OPP Removal IDs it
states “Information Documents are not
authoritative.” For further information on the
AESO’s Information Documents, please refer
to the AESO Information Document
Characteristics located on the AESO’s
website.
Furthermore, within each of the ISO OPP
Removal IDs it states “Authoritative
Documents is the general name given by the
AESO to categories of documents made by
the AESO under the authority of the Electric
Utilities Act and regulations, and that contain
binding legal requirements for both market
participants and the AESO. AESO
Authoritative Documents include: the ISO
rules, the Alberta reliability standards, the
http://www.aeso.ca/downloads/ID_(504_3_and_504_4)_V_Final_Aug_7_2012.pdf
AESO Replies to Stakeholder Comments: 2013-12-19
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An authoritative document is the
general name given by the AESO to
categories of documents made by the
AESO under the authority of the Electric
Utilities Act and regulations, and that
contain binding legal requirements for
both market participants and the AESO.
AESO Authoritative Documents include:
the ISO rules, the Alberta reliability
standards, the ISO tariff, technical
standards, and Operating Policies and
2
Procedures.
Although the definition of an authoritative document
is clear; the definition of an information document is
not. The term “binding legal requirements” is part of
the definition of an authoritative document, but is
absent from the definition of an information
document. ENMAX is unsure if this denotes that the
“guidance” offered in information documents is not a
“binding legal requirement” and that market
participants and the AESO are free to disregard it?
Further, ENMAX would also like to understand the
differences between a “business practice” and an
information document? How are all these terms
defined?
ISO tariff, technical standards, and Operating
Policies and Procedures.”
As a result, ENMAX should have sufficient
information upon which to base its comments
on the questions raised in this consultation.
ENMAX’s question on the AESO’s business
practices is out of scope for this consultation
on the proposed ISO OPP Removals.
Generally, the AESO’s business practices
are non-authoritative documents created to
assist market participants in understanding
the AESO’s processes.
In light of the above, the AESO is not
extending the consultation period on the
proposed ISO OPP Removals.
In Decision 2013-381 and Decision 2013-382 the
Alberta Utilities Commission (“AUC”) recognized
market participants concerns and stated it was
willing to consider whether an industry wide
consultation might be an appropriate vehicle to
address such issues. ENMAX is a concerned
market participant and supports a form of
consultation. However, in the interests of efficiency,
ENMAX requests a response to its aforementioned
concerns so it can best respond to the AESO’s
request for comments on the proposed removal of
ISO Rules 515, 517, and 521.
2
http://www.aeso.ca/rulesprocedures/25258.html
AESO Replies to Stakeholder Comments: 2013-12-19
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How the AESO defines each term will directly
impact all market participants’. As such, ENMAX
respectfully requests that the AESO provide detailed
explanations of authoritative documents, information
documents and business practices, as well as
provide additional time to all market participants’ to
provide informed and comprehensive comments
based on the information provided.
(b) Other
Stakeholders wishing to comment on specific provisions are requested to copy the
provision into this area and provide comments.
AESO Replies to Stakeholder Comments: 2013-12-19
Comment # 2: Insert Comments / Reason for Position (if
any)
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