Stakeholder Comment Form Quick Hits Rule Review Date of Request for Comment: Period of Consultation: June 12, 2008 June 12, 2008- June 26, 2008 Stakeholder: ___________________ Category/Topic Description ISO Rule(s) 1 Stakeholder Comments Alternate rule proposal DOE recommends refinements that will improve supply visibility and stability and enhance system reliability and price fidelity (DOE Framework1 p 3) 1.0 Merit Order Stabilizers 1.1 Maximum Capability (MC) DOE Policy Reference Maximum G1 MW under Definitionoptimal MC conditions for all assets Supply must submit before the delivery day and all available volume must be offered (DOE Framework p 25) Alberta’s Electricity Policy Framework: Competitive – Reliable – Sustainable June 6, 2005 Alberta Department of Energy (DOE Framework) Quick Hits Rule Review 1 Category/Topic Description 1.2 Available Capability (AC) Maximum MW for each hour of the trading day for all assets 1.3 Acceptable Operational Reason (AOR) Operational & other constraints which reduce MC and/or accurately represent the operating state of the asset Must submit offer restatement for an AOR if AC changes and/or quantity of MW are redistributed within operating blocks 1.4 Mandatory Energy Restatements ISO Rule(s) G1 DefinitionAC DOE Policy Reference Stakeholder Comments Alternate rule proposal Supply must submit before the delivery day and all available volume must be offered (DOE Framework p 25) G1 Total volume may not Definition- be restated except for AOR physical operational reasons (DOE Framework p 25) 3.5.3.2 a &b Any change or limitations to availability must be immediately communicated to the ISO (DOE Framework p 26) Quick Hits Rule Review 2 Category/Topic Description 1.5 Voluntary Price Restatements (VPR) May submit offer restatement to change prices/ AC allocation during the trading day 1.6 T-2 Restriction on VPR submission timing to two hours before the start of a settlement interval Deduction of AS and DDS dispatch MW from an assets AC or in merit offer in the energy market merit order 1.7 Implementation of Offers 2 ISO Rule(s) 3.5.3.3 3.5.3.3 DOE Policy Reference Stakeholder Comments Alternate rule proposal ISO duty to give participants a reasonable opportunity to participate in market (EUA2 17 b) Volume and price for the delivery hour will be fixed two hours ahead of the delivery hour (DOE Framework p 24) 3.5.3.5 a 2003 Electric Utilities Act (EUA) Quick Hits Rule Review 3 Category/Topic Description ISO Rule(s) 2.1 Dispatch down service a voluntary service offered by a source asset to be dispatched off G1 DefinitionDDS 2.2 DDS Offers and Restatements Characteristics - size, flexibility, block allocation, minimum stable generation DDS dispatch terms & conditions 3.5.1, 3.5.5 DDS may only be dispatched when SMP is below reference price 3.10a 2.4 Reference price use Stakeholder Comments Alternate rule proposal TMR rules and practices should preserve price fidelity and minimize undue interference in the energy market (DOE Framework p 38) 2.0 Transmission Must Run (TMR) and Dispatch Down Service (DDS) 2.3 DDS Eligibility DOE Policy Reference 6.3.6.1 Protection for consumers for overpayment for TMR services (DOE Framework p38) Quick Hits Rule Review 4 Category/Topic Description 2.5 Reference price formula Reference price equals 12.5 times natural gas price 2.6 DDS Payment & Charge DDS calculation and allocation method TMR & DDS Quantities, Reference Price 2.7 DDS Reporting ISO Rule(s) 3.10b DOE Policy Reference 8.1.3, 8.1.4 Constrained down payments will not be paid to generators (DOE Transmission Policy3 p8) 3.2 PSM settlement 3 Alternate rule proposal 10.6 g Encourage offer stability and more efficient energy dispatch (DOE Framework p22) 3.0 Payments to Suppliers on the Margin (PSM) 3.1 PSM eligibility & calculation Stakeholder Comments Eligibility conditions and payment calculation Allocation of PSM costs 8.1.2 8.2.4 “Transmission Development The Right Path for Alberta A Policy Paper” Alberta Energy Electricity Business Unit November 2003 (DOE Transmission Policy) Quick Hits Rule Review 5 Category/Topic Description ISO Rule(s) DOE Policy Reference Stakeholder Comments Alternate rule proposal Imports are to be treated the same as intra Alberta generators (DOE Framework p39) 4.0 Treatment of Imports and Exports 4.1 Impact of T-2 Restriction on VPR submission timing to two hours before the start of a settlement interval 3.5.3.3; AC; AOR; 6.3.3 e 4.2 Interconnection Dispatching Procedural 6.3.3 conditions for an energy market dispatch (etags, transmission procurement) 5.0 Adequacy Forecasting Comparison of 7 day forecast of load requirement and available supply 5.1, 10.2 , 10.3, Appendix 5 Ensures a mechanism for the ISO to commit units for reliability (DOE Framework p23) Quick Hits Rule Review 6 Category/Topic 6.0 Price Forecasting 7.0 Long Lead Time Energy Dispatch 7.1 Initial Startup Time 7.2 Adequacy Assessment and ISO Startup Request Description ISO Rule(s) Forecast 10.4, 5.2, dispatch price Appendix for the next 5 two settlement intervals Asset must provide time of day for synchronizati on which reflects the assets physical condition If assessment using start up information confirms need, ISO may request asset to start up and asset must confirm intentions 3.5.3.4; 6.3.5 a & b DOE Policy Reference Stakeholder Comments Alternate rule proposal Provision of timely and useful price forecasts (DOE Framework p25) DOE recommends communication of unit physical conditions and intentions to start to ISO (DOE Framework p3) 6.3.5 c & d Quick Hits Rule Review 7 Category/Topic Description 7.3 Withdrawal of Intention to Startup Intention to startup may be withdrawn before T-2 7.4 Additional comments and suggestions for improvement Topics could include outage consideration s, impact on multiple units for an asset, SC role and compliance with AC submission procedures ISO Rule(s) 6.3.5 e DOE Policy Reference Stakeholder Comments Alternate rule proposal General comments and suggestions for improvement Quick Hits Rule Review 8