Stakeholder Comment Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
2015-08-31
Proposed New ISO Rules Part 500 Facilities, Division 505 Legal Owners of Generating Facilities, Section 505.2, Performance Criteria for Refund of Generating Unit Owner’s
Contribution (“New Section 505.2”)
Date of Request for Comment:
Period of Consultation:
August 31, 2015
August 31, 2015
Comments From:
TransAlta Corporation
Date [yyyy/mm/dd]:
2015-09-09
through
September 16, 2015
Contact:
Chris Codd
Phone:
403-267-3664
Email:
[email protected]
Listed below is the summary description of changes for the proposed New Section 505.2. 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
The AESO is seeking comments from stakeholders with regard to the following
matters:
1. Do you agree or disagree with the proposed New Section 505.2? If you
disagree, please provide comments.
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.
Issued for Stakeholder Consultation: 2015-08-31
Stakeholder Comments and/or Alternate Proposal
Comment # 1: TransAlta is concerned that the proposed
hourly availability metric for generation in subsection 3(3)
of the proposed rule is not an accurate reflection of
satisfactory operation of a generating unit. This metric
defines availability of as availabile capability divided by
maximum capability. Maximum capability is defined in the
AESO’s Consolidated Authoritiative Document Glossary
as the maximum output ahieveable under ideal conditions.
This means that a large coal-fired generator that is always
available will not be able to achieve a 100% availability
under this metric because ambient temperatures prevent
the generator from achieving its full output at all times of
the year. Further, large coal-fired generators typically
undergo planned outages lasting about a month every 2
or 3 years. Finally, there can be significant variability in
forced outages from year to year. The overall impact of
these factors could lead to a coal-fired generator not
meeting the 80% avavailbility requirement despite having
satisfactory operations. TransAlta submits that the AESO
should find a way to exclude ambient temperature derates
and planned outages from the metric or that the AESO
AESO Replies
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should reduce the required availability for a full refund to
70% or 75% to reflect the operating characteristics of
large coal-fired generators.
Comment # 2: TransAlta is concerned with the grouping of
wind and hydroelectric generation does not reflect the
characteristics of each type of generation. Wind
generation has significant variance in fuel availability from
year to year that may prevent a wind aggregated
generating facility from meeting the 25% capacity factor
set in subsection 4(4) of the proposed rule even if the
wind aggregagted generating facility had 100%
availability. Under the current wind dispatch rules, it is
possible to utilize available capability to reflect the
availability of a wind aggregated generating facility.
TransAlta submits that the AESO could employ a 75%
availability for wind generation using the definition of
availability in subsection 3(3). In the alternative, TransAlta
requests that the AESO maintain the 20% capacity factor
rerquirement from the previous Section 9.5 of the ISO
rules to reflect the operating characteristics of wind
generation.
Comment # 3: TransAlta agrees with the AESO that it is
more efficient to have the AESO conduct the assessments
to determine generating unit owner’s contribution refunds
and TransAlta supports this change. However, TransAlta
is concerned that there is no requirement for the AESO to
provide the data it has used to conduct the assessments.
TransAlta submits that there should be a requirement in
the rule for the AESO to provide its assessment used to
determine a generating unit owner’s contribution refund if
it is requested by a market participant.
Comment # 4: It is unclear to TransAlta how the hourly
availability under subsection 3(3) is calculated in time
periods where the generator has a Rate STS contract
capacity of 0 MW. Subsections 4(3) and 5(3) of the
proposed rule include requirements for the AESO to
assess a 100% availability in hours during a month where
the Rate STS contract capacity is 0 MW. TransAlta
Issued for Stakeholder Consultation: 2015-08-31
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requests that the AESO include a clause to deem the
hourly availability for generation other than wind, hydro,
less than 5 MW and behind-the-fence as 100% for months
when the Rate STS contract capacity is 0 MW.
Comment # 5: The Letter of Notice states that the
proposed New Section 505.2 applies to market
participants and the AESO but the draft rule states that it
only applies to the AESO. Please confirm whether the
proposed rule is intended to apply to market participants.
Issued for Stakeholder Consultation: 2015-08-31
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