Stakeholder Comment Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
November 9, 2015
Re-Consultation on Proposed New Section 504.5 of the ISO rules, Service Proposals and Cost Estimating (“New Section 504.5")
Date of Request for Comment:
Period of Consultation:
November 9, 2015
November 9, 2015
through
Contact:
Darcy Fedorchuk, P.
Eng.
November 24, 2015
Comments From:
AltaLink Management Ltd
Phone:
403 267 5985
Date [yyyy/mm/dd]:
2015/12/14
Email:
[email protected]
Listed below is the summary description of changes for the proposed New Section 504.5 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) New
New Section 504.5 is proposed for the purpose of adopting the Association for the
Advancement of Cost Engineering practices for estimating the costs of transmission
facility development in Alberta.
Stakeholder Comments and/or Alternate Proposal
Comment # 1: Insert Comments / Reason for Position
(if any)
AESO Replies
1. No Comments
The AESO is seeking comments from stakeholders with regard to the following
matters:
2. See below for comments specific to each section
1. Do you agree or disagree with the revisions to proposed New Section 504.5?
If you disagree, please provide comments.
4 (c) : In Response to our comments concerning using
AACE defined ranges for NIDs and service proposal
estimate, the AESO states the following:
2. Are there any subsections where the language does not clearly articulate the
requirement for either the AESO or a market participant? If yes, please indicate
the subsections and suggest language that would improve the clarity.
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1) The proposed definitions for “NID
estimate” (class 4) and “service proposal
estimate” (class 3) set out the high and
low bands of the accuracy range for the
specified class in accordance with the
Association for the Advancement of Cost
Engineering (“AACE”) practice. As part of
the AESO’s request for a cost estimate
under subsection 3 of proposed New
Section 504.5, the AESO would include
the accuracy range required for that
particular estimate within the accuracy
bands for the class.
Note that the wider accuracy bands in the
proposed definitions of “NID estimate”
and “service proposal estimate” allow for
cost estimates to be provided in an
accuracy range that is larger than the
accuracy range required under the
current Section 9.1.2. However, the
AESO retains the flexibility to request the
owner of a transmission facility (“TFO”) to
provide a cost estimate in a narrower
accuracy range, as long as it is still within
the high and low accuracy bands for the
class. This narrower accuracy range may
be necessary for certain types of projects,
such as those for which the project
definition is high and systematic or
unknown risk is low (i.e. small, less
complex projects), or in unique
circumstances where the AESO would
benefit from a narrower accuracy range
(i.e. in the case of a request for “NID
estimates” for the purpose of assessing
available alternatives).
AML requests that based on the AESO’s reply
that “if the AESO deviates from the ranges
defined within AACE when requesting an
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estimate from a TFO, the AESO must explain
why the AESO needs the increased level of
accuracy”. This will enable AESO to specify
that the request is for a brown field project or
some other project where the TFO is able to
provide a greater level of detail. The scope of
work is what allows the legal owner of a
transmission facility to provide an estimate
with a tighter banding level of accuracy.
The AESO has to understand that if they
request a level of accuracy that is not
available or without consideration of the
defined scope, the estimate must contain a
contingency to cover this risk ( to guard
against a penalty for non-compliance)
.
Alternatively the if the AESO requests a tigher
banding of the accuracy of the estimate would
AESO consider allowing more time for design
and scope definition along with the associated
costs to support the increased scope
definition?
5(1) “Upon receiving the information described
in subsection 4, the ISO may make a written
request that the legal owner of a
transmission facility provide a cost
estimate or revised cost estimate; within a
specified time period”
AML requests that “within a specified time
period” be revised to “within a reasonable
specified time period”.
7(3) same comment as in 4(c), the AESO
must specify why the range is more stringent
than defined in AACE.
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8 (1)The legal owner of a transmission
facility that provides a cost estimate to the
ISO in accordance with subsection 5 must
provide ISO with a final cost estimate no
later than ninety (90) days after final
energizatin of all facilities included in a
service proposal for a transmission facility
project, unless the ISO agrees otherwise in
writing.
The current requirement of a final cost
estimate 90 days after the final energizatoin;
at a AACE Class 1 level of accuracy does not
allow for follow on costs associated with AC
Mitigation or other project costs.
8(2) same comment as in 4(c), the AESO
must specify why the range is more stringent
than defined in AACE.
8(3) There is no ability for the TFO to provide
an accuracy range other than what the AESO
has specified.
9(1) “….in an appropriate level of detail”.
Need to define what this means respecting
that processes, standards and level of detail
are in place relative to the estimating process
and the detail may not be available.
9(2) “….in an appropriate level of detail”. See
9 (1)
“specified time period” be replaced with
“reasonable specified time period”
9(3) same as 9 (1) and 9(2) relative to
‘“appropriate level of detail” and “specified
time period”
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