Stakeholder Comment Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
May 5, 2015
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 [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
May 5, 2015
May 5, 2015
through
Contact:
Betsy Li
Manager, Agency Engagement
May 20, 2015
Comments From:
ATCO Electric (Transmission)
Phone:
780-509-2142
Date [yyyy/mm/dd]:
2015/05/20
E-mail:
[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 (“AACE”) practices for estimating the costs of
transmission facility development in Alberta.
The AESO is seeking comments from stakeholders with regard to the following
matters:
1. Do you agree or disagree with the proposed New Section 504.5? 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: 2015-05-05
Stakeholder Comments and/or Alternate Proposal
ATCO agrees with the adoption of the AACE practices
for cost estimates with the flexibility to allow a TFO to
outline with reasons when an alternative accuracy
range is required for its estimate.
AESO Replies
However, the subsection (4) requirement of ten
business days for a TFO to respond to an AESO
request for a needs identification document (NID) or
service proposal estimate (with the associated
accuracy range or justification for why an alternative
accuracy range must be used) is too short for large or
complex projects which can need more time. Greater
flexibility on the time required is needed here.
Also, the subsection 8(1) requirement for a TFO to
provide a final cost estimate two months after final
energization can be problematic, especially if
reclamation or salvage is required. Again, additional
flexibility on the time required is needed here.
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In addition to changes suggested above, ATCO
strongly recommends that the following sections of the
current ISO Rules Section 9.1.2 be added and adopted
into the proposed Section 504.5:
Issued for Stakeholder Consultation: 2015-05-05

Sections 9.1.2.1 (b) and 9.1.2.3 (c) – These
sections, which currently obligate the AESO to
provide the TFO with the information required for
the TFO to prepare a timely NID or service
proposal estimate (including a complete functional
spec), are noticeably absent from the proposed
Section 504.5. ATCO recommends that these
AESO obligations should remain in the new rule.
The new rule should not be focused solely on the
TFO’s responsibilities and what the AESO can
direct the TFO to do, but rather on the obligations
of all parties involved.

Sections 9.1.2.3 (b) (ii) and (iii) – Under the current
Rule, Transmission customers can opt to forgo the
Service Proposal review by the AESO. This option
is now absent from the new rule. ATCO
recommends that his option be retained in the new
Rule, to speed up the connection process for
customers.
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