Stakeholder Comment Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
2015-08-19
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 19, 2015
August 19, 2015
Comments From:
TransCanada Energy Ltd.
Date [yyyy/mm/dd]:
2015/09/16
through
Contact:
September 16, 2015
Janene Taylor
403-920-7682
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.
Stakeholder Comments and/or Alternate Proposal
Comment # 1:
AESO Replies
Section 2(b) of Section 10 of the ISO Tariff states “for an
existing system access service agreement which is
amended to add incremental Rate STS contract capacity
for a single new generation facility, the incremental Rate
STS contract capacity added to the agreement must be
allocated among each new generation facility in proportion
to its maximum capability.”
Neither Rule 502.5 nor Section 10 of the ISO Tariff
specifies under what conditions a Generating Unit Owners
Contribution would be assessed for increases to Rate
STS contract capacity.
Specifically, since the term generation facility is not
defined it is not clear if the following
modifications/additions would be considered a “new single
generation facility:
i.
An uprate to an existing generating unit (i.e.
turbine)
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ii.
iii.
Replacement of an existing generating unit
(i.e. turbine) with a larger generating unit (i.e.
Turbine)
An additional generating unit (i.e. turbine) at
an existing Point of Connection (POC).
TCE is of the view that either the Rule or the Tariff should
clearly state under what conditions a Generation Unit
Owner Contribution (GUOC) applies and it appears there
is an opportunity to provide this additional clarity in Rule
502.5.
In addition, Rule 502.5 does not specify how the AESO
will track in a transparent manner the fact that incremental
Rate STS contract capacity is allocated to a new
generation facility. In order for the contribution refund
calculations to be transparent TCE is of the view that the
SAS agreement itself should specify at the time of
amendment what portion of the final STS contract
capacity is allocated to which generation facilities.
Comment # 2: Section 505.2 Subsection 3
TCE notes that subsections 4(3) and 5(3) contemplate
circumstances for which the Rate STS contract capacity is
zero by requiring the AESO to assess a 100% availability
in those hours. TCE understands that this circumstance
could also arise for Generation Other than Wind, Hydro,
and Less than 5 MW and therefore requests that the same
clause should be include in Subsection 3.
Comment #3: Section 505.2. Subsection 4
TCE understands that at the time of the Recommendation
Paper wind generation facilitates did not offer into the
st
market. However as of April 1 of 2015, wind facilities are
required to offer in and have the option to offer at a price
greater than 0 MW. This creates an opportunity to also
utilize available capability similar to conventional
generation facilities for the purposes of determining the
GUOC.
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Comment #4: TCE supports the AESO conducting the
assessments to determine the generating unit owners
contriution refund. Rule 505.2 should therefore include a
requirement for the AESO to provide to the genreating unit
owner its assesement of the contribution refund if
requested by the generating unit owner.
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