Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
2013-03-19
Proposed Amendments to Existing ISO OPP 402 Supplemental and Spinning Reserve Services (“ISO OPP 402”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2013/03/19
2013/03/19
Comments From:
TransCanada Energy Ltd. (TCE)
Date [yyyy/mm/dd]:
2013/04/05
through 2013/04/05
Contact:
Janene Taylor
Phone:
403-920-7682
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
a) Amendment
The Montana Alberta Tie Line (“MATL”) is expected to be energized on June 1,
2013, and a number of incidental amendments to existing ISO rules are required to
facilitate the event (“MATL Rules Changes”). The proposed MATL Rules Changes
are required to remove specific references to British Columbia and Saskatchewan
interties and entities and replacing these references with more generic references,
where possible, to allow imports and exports to flow on MATL to be in compliance
with these ISO rules.
The proposed MATL Rules Changes are largely procedural in nature and will
amend requirements for the AESO regarding calculations that reference
import/export available transfer capability (“ATC”) on specific tie-lines, and
communication with neighboring balancing authorities. These amendments do not
constitute substantive changes in the scope or intent of the relevant ISO rules and
will not materially affect the way in which ATC is allocated.
ISO OPP 402 sets out the contingency reserve criteria for the Alberta
interconnected electrical system and provides guidelines and procedures for the
AESO system controller in dispatching assets for supplemental and spinning
Issued for Stakeholder Consultation: 2013-03-19
Stakeholder Comments and/or Alternate Proposal
AESO Replies
As a general comment OPP 402 refers to the “backstop
portfolio” in numerous places. TCE understands that
the AESO no longer procures backstop and
recommends that the references to backstop be
removed from the OPP.
Section 3.2 Contingency reserve requirements, still
makes reference to ILRAS. Given the update to ISO
Rule 303.1 to remove all references to ILRAS it seems
appropriate to remove this reference from OPP 402 as
well.
In Section 5.1 8.e and 5.4 6 there is a reference to OPP
1301. TCE understands that OPP 1301 is being
removed. The references should be removed as well.
Finally as a general comment TCE recommends that
the AESO update the cases in Appendix A to better
reflect current system conditions so as to be more
helpful to stakeholders.
Page 1 of 4
1. ISO Rules
reserves and in issuing an ancillary service directive for the delivery of
supplemental and spinning reserve energy.
Stakeholder Comments and/or Alternate Proposal
The AESO has proposed amendments to ISO OPP 402 to replace references to
AB-BC and AB-Saskatchewan interconnections with more general references to
accommodate the MATL tie-line. Amendments were made to Table 1 to reflect
the addition of the MATL tie-line in the calculation of contingency reserve
requirements.
The AESO is seeking comments from stakeholders with regard to the following
matters:
1) Do stakeholders agree or disagree with the amendments being proposed to
existing ISO OPP 402? If you disagree, please provide comments.
2) Are there any subsections where stakeholders feel that the language does not
clearly articulate the requirement either for the AESO or a market participant? If
yes, please indicate the subsection and suggest language that would more
clearly articulate the requirement.
Issued for Stakeholder Consultation: 2013-03-19
Page 2 of 4
AESO Replies
1. ISO Rules
(a) Other
“Table 1: Alberta Contingency Reserve Requirements
System Conditions
Lines in service:
1201L (Langdon – Cranbrook)
5L92 (Cranbrook – Selkirk)
2L294 (Cranbrook – Nelway)
Lines in service:
1201L (Langdon – Cranbrook)
2L294 (Cranbrook – Nelway)
Lines out of service:
5L92 (Cranbrook – Selkirk)
Alberta Contingency Reserve
Requirements
Contingency Reserve required is the
greater of:
1. Net import schedule on the
combined BC/MT interconnections –
net export schedule on the combined
BC/MT interconnections – armed LSSi
load.(see note 4)
2. Alberta’s contingency reserve
obligation to NWPP. (see note 1)
Contingency Reserve required is the
greater of:
1. Alberta’s most severe single
contingency + net import schedule on
the combined BC/MT interconnections
– net export schedule on the
combined BC/MT interconnections –
armed LSSi load. (see note 2 and 4)
Stakeholder Comments and/or Alternate Proposal
Table 1: Please confirm in the OPP that the
Contingency Reserve Requirements are the same in the
case where Alberta is a net importer and a net exporter.
Also Table 1 refers to LSSi where as all of the other
references in OPP 402 and ISO Rule 303.1 refer to
load shed service or LSS.
Row 1, Column 1:
Please indicate in the Table which scenario represents
System Normal. Also, does MATL’s operational status
impact whether or not the AESO is operating under
System Normal Conditions. TCE notes that MATL’s
operational status is only indicated in two of the five
system condition scenarios and requests that MATL’s
operational status be indicated in all scenarios.
2. Alberta’s contingency reserve
obligation to NWPP. (see note 1)
Row 3, Column 2:
Lines in service:
1201L (Langdon – Cranbrook)
5L92 (Cranbrook – Selkirk)
Lines out of service:
2L294 (Cranbrook – Nelway)
Contingency Reserve required is the
greater of:
1. Cranbrook/Natal/Elkford area loads
+ net import schedule on the
combined BC/MT interconnections –
net export schedule on the combined
BC/MT interconnections – armed LSSi
load.
2. Alberta’s contingency reserve
obligation to NWPP. (see note 1)
Issued for Stakeholder Consultation: 2013-03-19
The calculation for the Contingency Reserves Required
accounts for Cranbrook/Natal/Elkfrod area loads. Could
the AESO please confirm if that value is net of any
generation in the area?
Page 3 of 4
AESO Replies
1. ISO Rules
Lines out of service:
1201L (Langdon – Cranbrook)
MATL (Picture Butte – Great Falls)
Lines out of service:
Any combination of BC Hydro lines
islanding BC load or generation to AB.
(MATL must be out of service for
this condition)
Stakeholder Comments and/or Alternate Proposal
Contingency Reserve required is the
greater of:
1. Alberta’s most severe single
contingency + net import schedule on
the BC Interconnection – net export
schedule on the BC interconnection.
(see note 3)
2. Alberta’s contingency reserve
obligation to NWPP. (see note 1)
Contingency Reserve required is the
greater of:
1. Alberta’s most severe single
contingency.
2. Alberta’s contingency reserve
obligation to NWPP. (see note 1)
Issued for Stakeholder Consultation: 2013-03-19
Row 4, Column 2
Please indicate in the Table whether or not lines 5L92
(Cranbrook – Selkirk) and 2L294 (Cranbrook – Nelway)
are in service when 1201L is out of service?
Finally, does the status of the 138 kV transmission lines
that make up part of Path 1 have any impact on the
scenarios identified in the table? If so, please include
the status of the 138 kV lines.
Page 4 of 4
AESO Replies