Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
Date: 2011-04-14
Proposed New, Amended and Removed ISO Rules Definitions
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
Comments From:
2011/04/14
2011/04/14
through 2011/05/06
Company Name
Contact:
Company Contact
Phone:
Contact Phone Number
E-mail:
Date [yyyy/mm/dd]:
ISO Rules Definitions – New
Existing
Proposed
Rationale
Stakeholder Comments and/or
Alternate Proposal
The current defined term ‘prudential
requirements’ is, in the opinion of the
AESO, overly broad and captures
components of financial obligations,
financial information and financial
security. As a result, it can create
interpretation imprecision in trying to
understand certain of the
requirements of existing ISO rules
Section 2, subsection 2.1 “Prudential
Comment # 1: Insert Comments /
Reason for Position (if any)
AESO Reply
No ISO rules definitions
currently exist in the ISO rules
for the terms addressed in this
section.
“financial information” means
any information and records
about the business, credit and
financial standing, condition
and viability of a market
participant or its credit support
provider.
Issued for Stakeholder Consultation: 2011-04-14
Page 1 of 16
Requirements”, and ISO rules
Appendix 3 “Pool Participant
Prudential Requirements”. The
defined term also appears in ISO
rules Section 8, subsection 8.6.1.
The AESO has instead used three
more precise and accurate financial
definition concepts: “financial
obligations”, “financial information”
and “financial security”.
The AESO has redrafted and
relocated the existing authoritative
provisions into proposed new ISO
rules section 103.3 “Financial
Security Requirements” and
proposed new ISO rules Section
103.7 “Financial Defaults and
Remedies”. In the AESO’s opinion,
these proposed new ISO rules
sections better articulate the
concepts of all basic payments,
financial information and security
requirements provided to the AESO
and use the new definitions
accordingly. It should be noted that
these proposed new defined terms
also take into account their eventual
usage under the ISO tariff, and is
consistent with AESO’s universal
drafting and definition reforms.
However, the defined term
‘prudential requirements’ will remain
in the AESO’s Consolidated
Authoritative Documents Glossary
until all references to ‘prudential
Issued for Stakeholder Consultation: 2011-04-14
Page 2 of 16
requirements’ in the AESO’s
authoritative documents have been
addressed and removed.
“financial security” means
sufficient enforceable credit
support to secure the financial
obligations of a market
participant to the ISO.
Please refer to the rationale above
supporting the proposed new ISO
rules definition for ‘financial
information’.
Comment # 2: Insert Comments /
Reason for Position (if any)
The AESO is introducing the more
precise defined term for ‘financial
security’, at this time, by referring to
the actual credit support to be
provided by a market participant.
"pool asset" means a
generating unit, an
aggregated generating
facility, a load, an export
service or an import service
identified by a pool ID and
registered to a pool
participant.
During its overall review of the ISO
rules, the AESO determined that the
current ISO rules definition of ‘asset’
does not properly reflect how the
defined term is actually being used.
The concept of “asset” is used
throughout the authoritative
documents and generally is a
reference to any physical asset.
However, in relation to the power
pool, the concept is not a general
one, but is more specifically related
to both the numerical identifier that is
used to identify a physical asset and
the physical asset itself. This has the
potential of creating significant ISO
rules interpretation confusion.
Comment # 3: Insert Comments /
Reason for Position (if any)
Therefore, on a go forward basis, the
AESO has discontinued the
universal use of ‘asset’ as an ISO
rules definition, and instead, have
developed more discrete defined
Issued for Stakeholder Consultation: 2011-04-14
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terms, including new ISO rules
definitions of ‘pool asset’ and ‘pool
ID’ to capture the specific power pool
practical usage and meanings. The
term ‘asset’ will continue to appear in
the ISO rules but will be used in its
plain language sense where
applicable.
The AESO will use the proposed
new defined terms for ‘pool asset’
and ‘pool ID’ in those sections of the
ISO rules that deals with the relevant
subject matter, including proposed
new ISO rules Sections 103.3, 103.4
“Power Pool Financial Settlement”,
and 103.7.
It should be noted the defined term
‘asset’ will remain in the AESO’s
Consolidated Authoritative
Documents Glossary until all
instances of the use of the defined
term ‘asset’ in the AESO’s
authoritative documents have been
addressed and revised to ensure
context continuity.
“pool ID” means a unique
identifier the ISO assigns to a
pool asset for the primary
purpose of enabling a pool
participant to enter into
transactions in the power
pool.
Please refer to the rationale above
for proposed new ISO rules
definition for ‘pool asset’.
Comment # 4: Insert Comments /
Reason for Position (if any)
ISO Rules Definitions - Amended
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Existing
Proposed
Rationale
Stakeholder Comments and/or
Alternate Proposal
“Act” means the Electric Utilities
Act.
“Act” means the Electric
Utilities Act and any
regulations made under it.
While the proposed amendment to
this ISO rules definition is not
financial in nature, it is aligned with
the AESO’s 2010 ISO tariff
Compliance Filing (1607003 - ID
1074). Although the AESO intends to
provide clear references in its
authoritative documents to either the
‘Act’ or to specific regulations, on
additional review, the AESO has
concluded that general references
will be required in certain instances
and accordingly, has proposed the
amended ISO rules definition for
‘Act’.
Comment # 5: Insert Comments /
Reason for Position (if any)
"financial obligations" means
the power pool financial
obligations of a pool
participant actually incurred or
likely to be incurred, including
the net dollar value of the
transactions plus any charges
expected or to be owed to the
ISO.
"financial obligation" means
any debt, payment or similar
obligation of a market
participant actually incurred or
likely to be incurred under the
ISO rules, the reliability
standards, the ISO tariff or as
a counterparty to any contract
with the ISO.
Comment # 6: Insert Comments /
Reason for Position (if any)
"net settlement instruction"
means a direct sales
agreement or forward contract
registered with the ISO by a
pool participant or forward
"net settlement instruction"
means an electronic
instruction:
(i) to the ISO from two (2)
counterparty pool
The proposed amendment provides
a more precise ISO rules definition
of what is meant by such obligations
and broadens it to make reference to
market participants instead of only
pool participants. As well, the
proposed amendment contemplates
the use of the amended defined term
in the Alberta Reliability Standards
and the ISO tariff, which is
consistent with the AESO’s intent to
develop universal definitions for
application in its authoritative
documents.
The proposed amendments remove
references to a ‘direct sales
agreement’ and ‘forward contract’.
The existing ISO rules definition
includes the misleading concept of
Issued for Stakeholder Consultation: 2011-04-14
AESO Reply
Comment # 7: Insert Comments /
Reason for Position (if any)
Page 5 of 16
market operator under the
requirements of rule 4.2, which
will be netted out of meter
volumes for purposes of
calculating power pool
settlements.
participants; and
(ii) containing transactional
information including
volumes, start and end
times and applicable pool
assets,
which enables the ISO to
perform netting of metered
energy for purposes of
calculating power pool
settlements.
the agreements being registered
with the AESO, as the actual
agreements are not, in fact,
submitted to the AESO. In the
AESO’s opinion, the amended
language more accurately reflects
the current ‘net settlement
instruction’ process of electronic
registration and is consistent with the
AESO’s standard structure for
drafting defined terms.
"settlement interval" means a
period beginning on the hour
and ending 60 minutes later and
is the time increment that MWh
amounts are settled financially
by the ISO. A settlement
interval is the time increment at
which distinct load estimates
are calculated by load
settlement systems.
"settlement interval" means a
period beginning on the hour
and ending sixty (60) minutes
later and is the time increment
for which:
(i) the ISO financially
settles energy
amounts; and
(ii) the load settlement
system calculates
distinct load estimates.
The proposed amendments to this
defined term have been made to
provide additional clarity and to be
consistent with the AESO’s standard
structure for drafting defined terms.
Comment # 8: Insert Comments /
Reason for Position (if any)
ISO Rules Definitions – Removed
Existing
Proposed
Rationale
Stakeholder Comments and/or
Alternate Proposal
“bank value” means that the
power pool has sufficient funds
in its bank account on the date
of settlement in order to meet
obligations relating to payment
of funds.
The defined term ‘budget’ appears in
existing ISO rules Section 8,
subsections 8.4.3 and 8.4.4, which
the AESO has redrafted and
relocated into proposed new ISO
rules Section 103.4.
Comment # 9: Insert Comments /
Reason for Position (if any)
AESO Reply
The proposed new ISO rules Section
103.4 does not use the defined term
‘bank value’. Therefore, the AESO
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has proposed to remove the defined
term for ‘bank value’ from its
Consolidated Authoritative
Documents Glossary
“budget” means the budget
prepared by the ISO under rule
2.2.
The defined term ‘budget’ appears in
existing ISO rules Section 2,
subsection 2.2, certain of the
authoritative provisions of which the
AESO has transitioned into
proposed new ISO rules Section
103.6 “ISO Fees and Charges”.
However, the defined term has not
been included into proposed new
ISO rules Section 103.6, for reasons
explained below.
Comment # 10: Insert Comments /
Reason for Position (if any)
The defined term ‘budget’ is also
currently used in existing ISO rules
Section 8 “Power Pool Financial
Settlement”, the authoritative
provisions of which the AESO has
transitioned into proposed new ISO
rules Section 103.4.
Neither of these new ISO rules
requires the use of the formal
definition. Where a reference to the
ISO “budget’ is necessary in any
authoritative document, the AESO
has proposed to use plain language
text. In the AESO’s opinion, use of
the term budget is well understood
and does not require a specific ISO
rules definition. As a result, the
AESO has proposed to remove this
defined term from its Consolidated
Authoritative Documents Glossary.
Issued for Stakeholder Consultation: 2011-04-14
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““direct sales agreement” has
the same meaning as that
provided in section 19 of the
Act.
The AESO has removed the
reference to the defined term ‘direct
sales agreement’ in the proposed
amendment to the ISO rules
definition ‘net settlement instruction’.
Therefore, since this is the only
reference to ‘direct sales
agreement’, the AESO has proposed
to remove this defined term from its
Consolidated Authoritative
Documents Glossary.
Comment # 11: Insert Comments /
Reason for Position (if any)
“dispute submission period”
means the 20 business days
after the final pool statement is
issued for a settlement period.
The only reference to the defined
term ‘dispute submission period’ is
currently found in existing ISO rules
Section 8.
Comment # 12: Insert Comments /
Reason for Position (if any)
The AESO is of the view that this is
another “one-time” definition usage
and can be removed. However, the
AESO will continue to use the
common phrase in proposed new
ISO rules Section 103.4 and to set
out the periods on the AESO
website. The AESO therefore has
proposed to remove this defined
term from its Consolidated
Authoritative Documents Glossary.
"energy production uplift"
means an amount that may be
paid to a pool participant with
a source asset that has
received an energy market
dispatch, subject to the
conditions and calculations
provided for in rule 8.1.2.
Issued for Stakeholder Consultation: 2011-04-14
The only references to ‘energy
production uplift’ are currently found
in existing ISO rules Section 8. This
therefore is another definition with
very limited universal applicability
and is a candidate for removal.
Comment # 13: Insert Comments /
Reason for Position (if any)
The AESO has transitioned the
Page 8 of 16
authoritative provisions of existing
ISO rules Section 8 into proposed
new ISO rules Section 103.4, and is
proposing to embed the meaning of
the term “uplift payment” by
sufficiently explaining the relevant
criteria and using plain language text
in proposed new ISO rules Section
103.4. The AESO therefore has
proposed to remove the defined term
for ‘energy production uplift’ from its
Consolidated Authoritative
Documents Glossary.
“final statement” means the
accounting statement issued
pursuant to a default action in
accordance with rule 8.5.1.
The only reference to the defined
term ‘final statement’ is currently
found in existing ISO rules Section 8.
Essentially, it is a reference to the
final statement the ISO prepares for
a final accounting post-termination.
The successor provision appears
under subsection 10 of proposed
new ISO rules Section 103.7
Comment # 14: Insert Comments /
Reason for Position (if any)
The AESO proposes to delete the
defined term because it is another
one-time ISO rules definition. It
further is confusing in the context of
the continued use of the phrase
“final statement” for ordinary course
settlement periods, which the AESO
will continue to specify in proposed
new ISO rules Section 103.4.
Therefore, the AESO has proposed
to remove the defined term for ‘final
statement’ from its Consolidated
Authoritative Documents Glossary.
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“financial year” means the 12
calendar month period
beginning on January 1 in each
year and ending on December
31 in the same year.
The references to the defined term
“financial year” are currently only
found in existing ISO rules Sections
2.2 and 8.
Comment # 15: Insert Comments /
Reason for Position (if any)
The AESO has transitioned key
authoritative provisions of existing
ISO rules Section 2, subsection 2.2
into proposed new ISO rules Section
103.6, and the authoritative
provisions of existing ISO rules
Section 8 into proposed new ISO
rules Section 103.4. In both cases,
the AESO simply uses the plain
language term ‘calendar year’” to
accurately reflect the intended
meaning. Therefore, the AESO has
proposed to remove the defined term
for ‘financial year’ from its
Consolidated Authoritative
Documents Glossary.
“forward market operator”
means a person that provides
net settlement instruction
MWh volumes on behalf of
pool participants, and has
entered into an operating
agreement with the ISO.
Issued for Stakeholder Consultation: 2011-04-14
The reference to the defined term
‘forward market operator’ is currently
another limited use definition, only
found in existing ISO rules Sections
4 and 8.
Comment # 16: Insert Comments /
Reason for Position (if any)
The AESO has transitioned the key
authoritative provisions of existing
ISO rules Section 4 into a proposed
new ISO rules Section 103.5, and
the authoritative provisions of
existing ISO rules Section 8 into
proposed new ISO rules Section
103.4. Neither of the proposed new
sections use the defined term
Page 10 of 16
‘forward market operator’, referring
instead to pool participants or market
participants, as appropriate. The
AESO has proposed to remove the
defined term for ‘forward market
operator’ from its Consolidated
Authoritative Documents Glossary.
“load settlement calculations”
are the calculations conducted
by a load settlement agent.
The reference to the defined term
‘load settlement calculations’ is
another limited use definition,
currently only found in existing ISO
rules Section 8.
Comment # 17: Insert Comments /
Reason for Position (if any)
The AESO has transitioned the key
authoritative provisions of existing
ISO rules Section 8 into proposed
new ISO rules Section 103.4 and
does not use the defined term ‘load
settlement calculations’ in these new
sections. Rather it has incorporated
language that makes it clear that the
calculation will be based on data
provided from load settlement
agents. The AESO has proposed to
remove the defined term for ‘load
settlement calculations’ from its
Consolidated Authoritative
Documents Glossary.
“MAP buyer” means the entity
purchasing a MAP product
from the Balancing Pool under a
Balancing Pool Power Sale
Agreement of December 2000
and any permitted assignee or
transferee of those rights.
Issued for Stakeholder Consultation: 2011-04-14
The reference to the defined term
‘MAP buyer’ is currently found only
in existing ISO rules Section 4.
Comment # 18: Insert Comments /
Reason for Position (if any)
As the AESO has transitioned key
authoritative provisions of existing
ISO rules Section 4 into proposed
new ISO rules Section 103.5, and
Page 11 of 16
does not use the defined term ‘MAP
buyer’” in these new sections, the
AESO has proposed to remove the
defined term for ‘MAP buyer’ from its
Consolidated Authoritative
Documents Glossary.
““MAP product” means the
energy rights purchased, under
a Balancing Pool Power Sale
Agreement of December 2000
for the Market Achievement
Plan, by a MAP buyer.
The reference to the defined term
‘MAP product’ is currently found only
in existing ISO rules Section 4.
“metering data” means the data
associated with a metering
point.
The reference to the defined term
‘metering data’ is another “one-time”
limited use definition, currently only
found in existing ISO rules section 8.
Comment # 19: Insert Comments /
Reason for Position (if any)
As the AESO has transitioned key
authoritative provisions of existing
ISO rules Section 4 into proposed
new ISO rules Section 103.5, and
does not use the defined term ‘MAP
product’” in these new sections, the
AESO has proposed to remove the
defined term for ‘MAP product’ from
its Consolidated Authoritative
Documents Glossary.
Comment # 20: Insert Comments /
Reason for Position (if any)
The AESO has transitioned the
authoritative key provisions of
existing ISO rules Section 8 into
proposed new ISO rules Section
103.4. While the AESO has retained
references to ‘metering data’ in
these new sections, in the AESO’s
opinion the plain language meaning
of the phrase “metering data” is
sufficiently clear. Therefore, the
AESO has proposed to remove the
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defined term for ‘metering data’ from
its Consolidated Authoritative
Documents Glossary.
“net settlement instruction
MWh volume” means net
settlement instruction quantities
of energy in MWh, registered
with the ISO that a seller has
agreed to sell or to provide a
purchaser for a specified
settlement interval.
The references to ‘net settlement
instruction MWh volume’ are
currently only found in existing ISO
rules Sections 4 and 8.
“pool settlement date” means
the business day on which
financial settlements relating to
the pool statement will occur in
accordance with rule 8.4.3.
The reference to the defined term
‘pool settlement date’ is currently
only found in existing ISO rules
Section 8.
Comment # 21: Insert Comments /
Reason for Position (if any)
Both of proposed new ISO rules
Sections 103.4 and 103.5 “Net
Settlement Instructions” do not use
the formal term ‘net settlement
instruction MWh volume’ but rather
refers to ‘volumes of net settlement
instruction’. Therefore, the AESO
has proposed to remove the defined
term for ‘net settlement instruction
MWh volume’ from its Consolidated
Authoritative Documents Glossary.
Comment # 22: Insert Comments /
Reason for Position (if any)
In proposed new ISO rules Section
103.4, the AESO has simply used
the plain language meaning of
‘settlement’ and has Information
Document 2011-002R - Power Pool
Financial Settlement, which explains
the settlement process and dates.
Therefore, the AESO has proposed
to remove the defined term ‘pool
settlement date’ from its
Consolidated Authoritative
Documents Glossary.
Issued for Stakeholder Consultation: 2011-04-14
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“pool statement” means the
accounting statement issued
pursuant to rule 8.4.
The reference to the defined term
‘pool statement’ is currently only
found in existing ISO rules Section 8.
Comment # 23: Insert Comments /
Reason for Position (if any)
As the AESO has transitioned the
authoritative provisions of existing
ISO rules Section 8 into proposed
new ISO rules Section 103.4 and
has combined the existing ISO rules
definition of ‘power pool’ and the
plain language meaning of the term
“statement” to replace any
references to the ‘pool statement’ in
these proposed new ISO rules
sections with ‘power pool statement’,
the AESO has proposed to remove
the defined term for ‘pool statement’
from its Consolidated Authoritative
Documents Glossary.
“post final adjustment
mechanism (PFAM)” is a
process that market
participants must follow when
final settlement data is being
disputed and the market
participants are requesting
financial adjustments be made
as a result of the dispute.
The reference to the defined term
‘post final adjustment mechanism
(PFAM)’ is currently only found in
existing ISO rules Section 8.
Comment # 24: Insert Comments /
Reason for Position (if any)
The AESO has transitioned the
authoritative provisions of existing
ISO rules Section 8 into proposed
new ISO rules Section 103.4, and
has not used the defined term ‘post
final adjustment mechanism (PFAM)’
but rather refers to post final
adjustments using plain language
text in these new ISO rules.
Proposed new ISO rules Section
103.4 has specified that the AESO
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Page 14 of 16
must calculate and process post final
adjustments in accordance with
Alberta Utilities Commission (“AUC”)
Rule 021 System Settlement Code
which provides any additional clarity
that might be required.
As such, the AESO has proposed to
remove the defined term for ‘post
final adjustment mechanism (PFAM)’
from its Consolidated Authoritative
Documents Glossary.
“signoff letter” an official ISO
correspondence detailing power
pool settlement dispute
information including, but not
limited to:
• ISO dispute number; •
settlement period in dispute;
• settlement summary of
adjustments and pool
participant signoff provision.
The reference to the defined term
‘signoff letter’ is currently only found
in existing ISO rules Section 8.
“total trading charge” means
the amount calculated pursuant
to rule 2.2.3.
The AESO has redrafted and
consolidated all authoritative
provisions related to ISO fees and
charges from existing ISO rules
Sections 2.2, and 8, relocated these
provisions into proposed new ISO
rules Section 103.6 “ISO Fees and
Charges” as, in the AESO’s opinion,
it is more convenient and logical for
stakeholders that ISO fees and
charges are centralized in one
section of the ISO rules.
The AESO has not used the defined
Issued for Stakeholder Consultation: 2011-04-14
Comment # 25: Insert Comments /
Reason for Position (if any)
In proposed new ISO rules Section
103.4, the text simply refers to
written notice rather than a “signoff
letter”. Therefore, the AESO has
proposed to remove the defined term
for ‘signoff’ from its Consolidated
Authoritative Documents Glossary.
Comment # 26: Insert Comments /
Reason for Position (if any)
Page 15 of 16
term ‘total trading charge’ in
proposed new ISO rules Sections
103.6 and 103.4, but rather refers to
the charge by the plain language
phrase “energy market trading
charge’ which is the term the AESO
uses when calculating these annual
charges and posting them on its
website.
Therefore, the AESO has proposed
to remove the defined term for ‘total
trading charge’ from its Consolidated
Authoritative Documents Glossary.
“trading limit” means the
maximum financial obligations
to which a pool participant is or
is expected to be owing the ISO
where such limit is determined
by the ISO or is the amount of
financial security provided in
accordance with Appendix 3.
Issued for Stakeholder Consultation: 2011-04-14
The reference to the defined term
‘trading limit’ is currently only found
in existing ISO rules Section 8.
Comment # 27: Insert Comments /
Reason for Position (if any)
In proposed new ISO rules Section
103.4, the AESO has not used the
defined term “trading limit” but rather
refers to a credit limit using plain
language text. Therefore, the AESO
has proposed to remove the defined
term for ‘trading limit’ from its
Consolidated Authoritative
Documents Glossary.
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