Stakeholder Comment Form ISO Rules Process – Special April 2009 Long Lead Time Energy Dispatches and Directives Rules Appendix 7 – Payment for Incremental Generation Costs for Long Lead Time Energy Directive and Generator Outage Cancellation and Reporting Date of Request for Comment: Period of Consultation: March 5, 2009 March 5 through April 3 2009 Comments From: _______________ Date: _______________ Contact: _______________ Phone: _______________ E-mail: _______________ G1 Definitions “long lead time energy” means energy produced by a long lead time generating asset. � Support "long lead time energy directive" means a directive issued by the system controller to a pool � Oppose participant to provide long lead time energy. � Indifferent “long lead time generating asset” means a generating asset that: a) requires more than one hour to synchronize or deliver its energy to the AIES under normal operating conditions; and b) is not delivering all of its energy for reasons other than an outage. Reason for Stakeholder Positions: Alternate Proposal: 6.3.5.1 Authority to Issue a Long Lead Time Energy Directive The system controller may, in accordance with this rule 6.3.5, issue a long lead time energy directive to a pool participant with a long lead time generating asset. Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 1 of 8 � Support � Oppose � Indifferent Reason for Stakeholder Positions: Alternate Proposal: 6.3.5.2 Requirements and Directives a) Long lead time energy with respect to a long lead time generating asset must be declared to the ISO by a pool participant, upon request by the system controller in accordance with ISO Operating Policies and Procedures. b) A pool participant whose long lead time generating asset is not synchronized to the AIES must submit to the ISO the time of day that such asset will be synchronized to the AIES, in order to have such asset dispatched according to the energy market merit order. c) A pool participant whose long lead time generating asset is synchronized to the AIES but has long lead time energy not reflected in its available capability due to asset constraints, must reflect the availability of such energy by appropriately adjusting the available capability of such asset in order to have such energy dispatched according to the energy market merit order. d) The time of day and the adjustment to available capability referenced in rules 6.3.5.2 (b) and 6.3.5.2 (c) must represent the physical condition of the long lead time generating asset as determined by either the time of the last notice of the long lead time generating asset’s intention to start or the time of such asset’s last dispatch off, as it relates to the operating constraints submitted to the ISO under rule 3.5.3.4. The time of day and the adjustment to the available capability must be submitted at least two hours prior to the beginning of the settlement interval. e) Subject to subsections 18(1) and 18(2) of the T-Reg, and in accordance with ISO Operating Policies and Procedures, the system controller may issue a long lead time energy directive to a pool participant for a specified settlement interval, if the adequacy assessment pursuant to ISO Operating Policies and Procedure forecasts insufficient supply to meet AIES demand during such settlement interval. The system controller must cancel the long lead time energy directive once the adequacy assessment indicates there is sufficient supply to meet AIES demand in subsequent settlement intervals. Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 2 of 8 � Support � Oppose � Indifferent f) Subject to rule 6.3.5.2 (g), a pool participant that has complied with a directive to provide long lead time energy and to stop providing long lead time energy may be eligible to receive payment for incremental generation costs from the ISO in accordance with section 1 of Appendix 7. g) A pool participant that elects to participate in the energy market prior to receiving a directive, or after receiving a directive to stop providing long lead time energy and such election results in the directive being cancelled, is not eligible for payment for incremental generation costs. A pool participant that has received a long lead time energy directive may change the availability of the long lead time energy in accordance with rules 6.3.5.2 b), 6.3.5.2 c), and 6.3.5.2 d). In such circumstances, the system controller must cancel the long lead time energy directive and dispatch the long lead time generating asset according to the energy market merit order and the pool participant is not eligible for payment for incremental generation costs in accordance with section 1 of Appendix 7. Reason for Stakeholder Positions: Alternate Proposal: 6.3.6.2 Conditions for Dispatch Down Service Dispatch The system controller must dispatch off operating blocks in the energy market merit order that have offered eligible DDS when the conditions described in rules 6.3.6.2 a) or 6.3.6.2 b) or in both exist. a) With respect to DDS for transmission must-run quantities the conditions are: i) The system marginal price is less than or equal to the reference price; and ii) A source asset has been issued a transmission must-run dispatch or directive; and iii) The sum of the transmission must-run quantity (MW) and the long lead time energy directive quantity (MW) is greater than constrained down directive quantity (MW) as calculated by the system controller, b) With respect to DDS for a long lead time energy directive the conditions are: i) The pool participant has received a long lead time energy directive; ii) The long lead time generating asset is delivering its energy in accordance with such directive; Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 3 of 8 � Support � Oppose � Indifferent and iii) The system marginal price is less than or equal to the highest priced operating block in the energy market merit order for the current settlement interval. Reason for Stakeholder Positions: Alternate Proposal: 6.3.6.3 Determining Dispatch Down Service Dispatch Quantity a) Subject to rules 6.3.6.2 a) and 6.3.6.2 b), the DDS dispatch quantity (MW) is the lesser of: i) the transmission must-run quantity (MW) and the long lead time energy directive quantity (MW) less the constrained down directive quantity (MW). The DDS dispatch quantity (MW) cannot be less than zero MW. � Support � Oppose � Indifferent ii) the eligible quantity of DDS offers. b) Operating blocks in the energy market merit order that have been dispatched off with respect to DDS for transmission must-run quantities will be dispatched on by the system controller prior to dispatching operating blocks that are greater than the reference price. c) Operating blocks in the energy market merit order that have been dispatched off with respect to DDS for a long lead time energy directive will be dispatched on by the system controller following the dispatch of the highest priced operating block in the energy market merit order for the current settlement interval. Reason for Stakeholder Positions: Alternate Proposal: 8.1.1 Settlement at Pool Price For each source asset and for each settlement interval the pool participant will receive the amount calculated by the following formula: Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 4 of 8 � Support � Oppose Energy payment in $ = ((energy production in MWh) minus (net settlement instruction MWh volumes in MWh)) multiplied by (pool price in $/MWh) � Indifferent where: “energy production in MWh” is the metered MWh value for generating assets or the interchange MWh schedule across the interconnection for importing assets. If the energy production in MWh is less than the net settlement instruction MWh volume then the pool participant is deemed to have purchased the MWh volume difference from the power pool. The pool participant must pay to the ISO in respect of electric energy received by it in a settlement interval an amount equal to the energy payment. Payment for emergency energy production installed and producing during an emergency transmission outage outside of an energy market suspension event will be paid based on the energy payment calculation noted above. The calculation of payment for emergency energy production installed and producing during an emergency transmission outage outside of an energy market suspension event will be based on metered energy submitted to the ISO as per rule 8.3.2 b). The calculation of payment for energy production as a result of a long lead time energy directive outside of an energy market suspension event will be based on metered energy submitted to the ISO as per rule 8.3.2 a). If the pool participant’s total variable costs for the energy production are not fully recovered by rules 8.1.1 and 8.1.2, an additional payment will be paid in accordance with the terms set forth in Appendix 7. Reason for Stakeholder Positions: Alternate Proposal: 8.4.2 g) Final Pool Statement Long Lead Time Energy Directive Costs The ISO may charge an ISO fee to recover the costs associated with a long lead time energy directive. The contribution paid by a pool participant shall be determined by prorating the amount paid to the pool Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 5 of 8 � Support � Oppose � Indifferent participant issued the long lead time energy directive over the total energy consumption of each pool participant during the settlement intervals where the long lead time energy was required. Where the long lead time energy was subsequently not required, the contribution paid by a pool participant shall be determined by prorating the amount paid to the pool participant issued the long lead time energy directive over the total energy consumption of each pool participant during the settlement intervals where the energy was forecast to be required. The long lead time energy costs will be invoiced with the pool statement. Reason for Stakeholder Positions: Alternate Proposal: APPENDIX 7 - PAYMENT FOR INCREMENTAL GENERATION COSTS FOR LONG LEAD TIME ENERGY DIRECTIVE AND GENERATOR OUTAGE CANCELLATION AND REPORTING 1.0 PAYMENT FOR INCREMENTAL GENERATION COSTS FOR LONG LEAD TIME ENERGY DIRECTIVES 1.1 Definitions “incremental generation costs”, for the purpose of rule 6.3.5 means, where the system controller has issued � Support a directive to a pool participant to start and run a long lead time generating asset, reasonable costs � Oppose incurred to start and run an asset in response to a long lead time energy directive, and which may � Indifferent reasonably be determined to have been avoided but for a long lead time energy directive, including, without limitation, the following: (i) variable STS charges which is the actual cost of all variable charges from Rate Schedule STS of the ISO Tariff, including the applicable loss factor charge or credit; (ii) variable O&M charges; (iii) fuel cost to start and run the asset; and (iv) other related reasonable costs. Reason for Stakeholder Positions: Alternate Proposal: Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 6 of 8 1.2 (a) Payment for Incremental Generation Costs Payment for incremental generation costs to a pool participant that has complied with a long lead time energy directive is intended to keep the pool participant whole, to the extent that energy receipts received as a result of the directive do not recover incremental generation costs. (b) In the event a pool participant is eligible for payment for incremental generation costs and does not recover its incremental generation costs from the hourly revenue received or associated with the hourly energy production, the ISO may pay an additional amount up to, but not more than, the incremental generation costs net of such revenue. � Support � Oppose � Indifferent Reason for Stakeholder Positions: Alternate Proposal: 1.3 Financial Settlement Where a long lead time generating asset has complied with a long lead time energy directive, then: a) � Support within 40 business days after the end of the settlement period in which such directive was issued, � Oppose the pool participant must issue to the ISO a statement showing: � Indifferent amount owing or owed as calculated in accordance with rules 1.2 and 1.3 of this Appendix 7 along with supporting documentation; and (i) (ii) such other information as the ISO considers appropriate and has requested; b) the pool participant must provide to the ISO the supporting data used to determine the amount specified in any such statement, including all data necessary to confirm the costs, charges and other items specified in rule 1.2 of this Appendix 7; c) settlement in respect of any such statement shall occur on or before 40 business days following receipt by ISO of the statement and supporting data specified in rules 1.3 a) and 1.3 b) of this Appendix 7; and d) any disputes in respect of any such statement shall be resolved in accordance with rules 8.5 b), 8.5 c), 8.5 d) and 8.5 e), applied mutatis mutandis on the basis that the ISO is the disputing party in respect of a statement provided by the pool participant pursuant to rule 1.3 a) of this Appendix 7. Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 7 of 8 Reason for Stakeholder Positions: Alternate Proposal: 3. REPORTING In the event the system controller issues a directive to cancel a generating asset’s scheduled outage or issues a long lead time energy directive the ISO must prepare a report and post such report on the AESO website. Such report must include: a) an explanation of the circumstances that caused and are related to the cancellation of a scheduled outage or the issuance of a long lead time energy directive, (e.g., date, duration, quantities (MW) affected); b) chronological events and material market impacts; c) d) reasons for a decision to depart from the prescribed steps set out in rule 5.1.2.2; and any other matters the ISO deems appropriate. Reason for Stakeholder Positions: Alternate Proposal: Please return this form with your comments by April 3, 2009, to: Staff Title E-mail: XXX Phone: (403) XXX Fax: (403) XXX Special April 2009 ISO Rules Process - Proposed ISO and OPP Rule Changes Page 8 of 8 � Support � Oppose � Indifferent