Stakeholder Comment Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
2014-10-07
Consultation on Proposed New ‘Transmission Constraint Rebalancing’ ISO Rule Definition (“New Transmission Constraint Rebalancing Definition”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2014/10/21
2014/10/07
Comments From:
Utilities Consumer Advocate
Date [yyyy/mm/dd]:
Tuesday, October 21, 2014
through
2014/10/21
Contact:
Jeff Crozier
Phone:
Cell: 403-801-6468 or Office: 403-476-4998
E-mail:
[email protected]
Listed below is the summary description of the proposed new ISO rules definition. Please refer back to the Consultation Letter under the “Attachments to Consultation Letter” section to view the
actual content changes to the proposed new ISO rules. Please place your comments/reasons for position underneath (if any).
Definition – New
Existing
No definition currently exists in the
AESO’s CADG.
Proposed
Rationale
“transmission constraint rebalancing”
means the delivery of energy from a pool
asset on the downstream constraint side
of a transmission constraint in response
to that portion of an energy market
dispatch it receives to restore the energy
and supply balance on the interconnected
electric system due to measures taken to
mitigate a transmission constraint.
In the course of developing the
proposed Amended Transmission
Constraint Management Rules, the
AESO determined that a new
defined term, Transmission
Constraint Rebalancing, should be
adopted for inclusion in the AESO’s
Consolidated Authoritative
Document Glossary (“CADG”).
Please provide your comments
relating to any technical deficiency
that would arise as a result of the
use of the New Transmission
Constraint Rebalancing Definition.
Issued for Stakeholder Consultation: 2014-10-07
Stakeholder Comments
and/or Alternate Proposal
1. The October 2, 2014, letter
(page 3) notes that the
AESO has rejected the use
of a downstream clearing
price (DCM) and will
continue with a pay as bid
approach. The stated
rationales for this approach
are unclear and
unsubstantiated. It appears
to be a technical deficiency
to not explain in detail why
the DCM approach is not
more consistent with
economic efficiency and
competitive market
principles than the pay as
bid approach. As a
separate point, the AESO
AESO Reply
Page 1 of 2
has not explained why it
believes that the pay as bid
approach will be less costly
either in the short run or the
long run.
2. The AESO does not
substantively address the
issue of local market power
anywhere in the proposed
revisions. This appears to
be a significant technical
deficiency and the AESO
has not provided any
explanation for failing to
address the local market
power issue. Local market
power is frequently the
result when transmission
constraints create local
markets with a small
number of owners who can
respond to dispatch
requests to resolve the
constraint.
3. As a minor point, most of
the acronyms in the
October 2, 2014, letter are
not included in the AESO’s
Consolidated Authoritative
Glossary. The AESO
should publish a list of
acronyms and their
definitions if it has not.
Issued for Stakeholder Consultation: 2014-04-29
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