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
through
Comments From:
Utilites Consumer Advocate
Date [yyyy/mm/dd]:
2015/09/10
September 16, 2015
Contact:
Doug Simpson
Phone:
403 476-4999
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: Disagree with the new availability
assessment criterion. This criterion will limit the incentive
to offer energy into the Pool at prices that will be
dispatched. This will also make it easier for generators to
capture their refund, making the decision to locate far from
load less costly. A combination of refund based on actual
capacity factor, and linear refund (proposed by the AESO)
mechanism may be optimal. This will still incent
generation to be dispatched, but also not completely
penalize them for not having system access (congestion).
AESO Replies
Comment 2: Performance Criteria section 4.1 – Does the
70% availability factor take into account that gas turbines
are significantly derated due to ambient termperature by
20% or more for much of the year without counting any
planned or forced outages?
Comment 3: Performance Criteria section 4.1 – In the new
proposal, is the availability properly assessed where the
ISDs base their AC on net to grid flow and there is little
relationship to the generating units capabilities?
Issued for Stakeholder Consultation: 2015-08-31
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Issued for Stakeholder Consultation: 2015-08-31
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