Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
2011-04-14
Proposed New ISO Rules Section 103.4 “Power Pool Financial Settlement”
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]:
Listed below is the summary of changes for the proposed new, removed or amended sections of the ISO rules. Please refer back to the Letter of Notice under the “Attachments to Letter of Notice”
section to view the proposed content changes to the ISO rules. Please place your comments / reasons for position underneath (if any).
1. ISO Rules Definitions
(a) New
“Package 8” ISO Rule Definition Changes, containing new ISO rules definitions,
are being consulted on concurrently with proposed New Financial Rules. Click
here to view the Letter of Notice for the “Package 8” ISO Rules Definition
Changes.
Stakeholder Comments and/or Alternate Proposal
Comment # 1: Insert Comments / Reason for Position (if
any)
(b) Removals
“Package 8” ISO Rule Definition Changes, containing ISO rules definitions
proposed for removal, are being consulted on concurrently with proposed New
Financial Rules. Click here to view the Letter of Notice for the “Package 8” ISO
Rules Definition Changes.
Comment # 2: Insert Comments / Reason for Position (if
any)
(c) Amendments
“Package 8” ISO Rule Definition Changes, containing ISO rules definitions
proposed for amendment, are being consulted on concurrently with proposed
Comment # 3: Insert Comments / Reason for Position (if
any)
Issued for Stakeholder Consultation: 2011-04-14
AESO Replies
Page 1 of 13
New Financial Rules. Click here to view the Letter of Notice for the “Package 8”
ISO Rules Definition Changes.
2. ISO Rules
(a)
New
Proposed new ISO rules Section 103.4 set out the power pool financial
settlement requirements. These requirements have been redrafted and relocated
from existing ISO rules Section 8 “Power Pool Financial Settlement”.
Comments
Comment # 4: Insert Comments / Reason for Position (if
any)
AESO Replies
The authoritative provisions relating to the ISO fees and charges specified in
existing ISO rules Section 8 have been redrafted and relocated to proposed new
ISO rules Section 103.6 “ISO Fees and Charges”.
The authoritative provisions relating to defaults and remedies in existing ISO
rules Section 8 have been redrafted and relocated to proposed new ISO rules
Section 103.7 “Financial Default and Remedies”.
Information Document 2011-002R – Power Pool Financial Settlement has been
created to support proposed new ISO rules Section 103.4, and replaces the
AESO’s “Settlement Process Guide” currently posted on the AESO’s website.
Click here to view Information Document 2011-002R.
Existing ISO rules Section 8 will be removed in its entirety once proposed new
ISO rules Sections 103.4, 103.6 and 103.7 come into effect.
Subsection 1 - Applicability
Comment # 5: Insert Comments / Reason for Position (if
any)
This subsection specifies that proposed new ISO rules Section 103.4 apply to
pool participants and the AESO and, in the AESO’s opinion, is consistent with the
applicability of existing ISO rules Section 8.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 2 - Currency
Comment # 6: Insert Comments / Reason for Position (if
any)
This subsection requires that all payments, charges and calculations must be in
Canadian dollars. The requirement to use Canadian dollars has been redrafted
and relocated from existing ISO rules Section 8, subsection 8.4.4. To eliminate
the need to restate the requirement for Canadian dollars multiple times in
proposed new ISO rules Section 103.4, the AESO proposes that the currency be
stated once in this subsection near the beginning of these ISO rules.
Subsection 3 - Source Asset Payment and Settlement Calculation
Comment # 7: Insert Comments / Reason for Position (if
any)
This subsection requires the AESO to pay a pool participant for energy
production from each source asset during a settlement interval, and provides the
formula for that payment. As well, this subsection requires a market participant to
pay the AESO the net difference if the energy production is less than the volumes
of net settlement instruction. These requirements have been redrafted and
relocated from existing ISO rules Section 8, subsection 8.1.1.
Subsection 4 - Payment for Energy Production During a System Emergency
Comment # 8: Insert Comments / Reason for Position (if
any)
This subsection requires the AESO to calculate and pay for energy production
during a system emergency caused by a transmission outage. These
requirements have been redrafted and relocated from existing ISO rules Section
8, subsection 8.1.1.
Subsection 5 - Payment for Long Lead Time Energy
Comment # 9: Insert Comments / Reason for Position (if
any)
This subsection requires the AESO to calculate and pay for energy production
related to incremental generation costs a pool participant incurs as a result of a
directive that the AESO issues for long lead time energy, other than during an
energy market suspension. These requirements have been redrafted and
relocated from existing ISO rules Section 8, subsection 8.1.1.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 6 - Payment to a Supplier on the Margin
Comment # 10: Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to pay an energy production uplift payment to
a pool participant with a source asset that has delivered energy pursuant to a
dispatch during a settlement interval if certain conditions are met. As well, this
subsection requires the AESO to calculate the energy production uplift payment
in accordance with the formula specified in this subsection. These requirements
have been redrafted and relocated from existing ISO rules Section 8, subsection
8.1.2.
Subsection 7 - Payment for Dispatch Down Service
Comment # 11: Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to calculate and include on the pool
statement a dispatch down service payment for a pool participant with a source
asset that has provided dispatch down service in accordance with a dispatch for
dispatch down service during a settlement interval. As well, this subsection
specifies the formula for the dispatch down service payment. These requirements
have been redrafted and relocated from existing ISO rules Section 8, subsection
8.1.3.
Subsection 8 - Dispatch Down Service Charge
Comment # 12: Insert Comments / Reason for Position
(if any)
This subsection requires a pool participant to pay the AESO a dispatch down
service charge and specifies the formula for calculating that charge. These
requirements have been redrafted and relocated from existing ISO rules Section
8, subsection 8.1.4.
Subsection 9 - Sink Asset Calculation and Payment
Comment # 13 Insert Comments / Reason for Position
(if any)
This subsection requires the pool participant to pay the AESO for the energy
consumed or received in a settlement interval and specifies the formula for
calculating that payment. These requirements have been redrafted and relocated
from existing ISO rules Section 8, subsection 8.2.1.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 10 - Charge for Cost of Long Lead Time Energy
Comment # 14: Insert Comments / Reason for Position
(if any)
This subsection allows the AESO to charge a fee to recover any costs associated
with a long lead time energy directive and reflect this charge as a line item on
power pool statements. This requirement has been redrafted and relocated from
ISO rules Section 8, subsection 8.4.2.
Subsection 11 - Allocation of Charges for Payments to a Supplier on the
Margin
Comment # 15: Insert Comments / Reason for Position
(if any)
This subsection requires pool participants to pay the AESO a charge related to
an uplift payment if the pool participant consumed energy in the settlement
interval when the uplift payment was made. This requirement has been redrafted
and relocated from existing ISO rules Section 8, subsection 8.2.4.
Subsection 12 - Post Final Adjustments for Load Settlement
Comment # 16: Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to calculate post final adjustments for load
settlement and include those adjustments on the preliminary pool statement.
This requirement has been redrafted and relocated from existing ISO rules
Section 8, subsection 8.2.2.
In addition, this subsection requires the AESO to include post final adjustments in
the final power pool statement for the current settlement period or on the final
power pool statement for the next settlement period if all information was not
received within the time periods set out in the post final adjustment mechanism
schedule posted on the AESO website. This requirement is new and aligns with
the amendments to Alberta Utilities Commission (“AUC”) Rule 021 – Settlement
System Code, specifically subsection 5.3.7.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 13 - Other Post Final Adjustments
Comment # 17: Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to make other adjustments as required after
the month of final determination. This requirement has been redrafted and
relocated from existing ISO rules Section 8, subsection 8.2.3.
Subsection 14 - Energy Market Trading Charge
Comment # 18: Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to include the energy market trading charge
as a line item on the power pool statement. This requirement has been redrafted
and relocated from existing ISO rules Section 8, subsection 8.4.2.
The actual calculation of the energy market trading charge has been redrafted
and relocated to proposed new ISO rules Section 103.6. In the AESO’s opinion, it
is more logical to consolidate all ISO fees and charges into a single ISO rule
rather than have ISO fee content dispersed across multiple ISO rules.
Subsection 15 - ISO Reporting of Import and Export Transactions
Comment # 19: Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to facilitate financial settlement for import and
export transactions. This requirement has been redrafted and relocated from
existing ISO rules Section 8, subsection 8.3.1. This provision has been amended
to clarify that the AESO settles these transactions based on the interchange
schedules, after considering constraints on the transfer paths. This amended
language is now consistent with the language used in proposed new ISO rules
Section 203.6 “Available Transfer Capability and Transfer Path Management”.
Subsection 16 - Metering Data Submission Requirements
Comment # 20: Insert Comments / Reason for Position
(if any)
This subsection requires load settlement agents and meter data managers to
provide metering data to the AESO in the format specified the in AUC Rule 021.
These requirements have been redrafted and relocated from existing ISO rules
Section 8, subsection 8.3.2.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 17 - Preliminary Power Pool Statement
Comment # 21 Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to issue a preliminary power pool statement
to pool participants by the end of the fifth (5th) business day for amounts
determined on the initial, interim and final basis, and sets out the specific line
items for inclusion on the preliminary pool statement.
As well, this subsection requires the AESO to provide a pool participant with any
supporting records used in determining the power pool statement line items
subject to any confidentiality requirements set out in existing ISO rules Section
103.1 “Confidentiality”.
This subsection also requires a pool participant to notify the AESO if it is unable
to retrieve the preliminary power pool statement from the AESO’s website, and if
notified, the AESO must use alternate means to deliver the pool statement.
These requirements have been redrafted and relocated from existing ISO rules
Section 8, subsection 8.4.1. The provisions relating to the line items regarding
interest, late payment and other charges have been redrafted and relocated from
existing ISO rules Section 8, subsection 8.4.3 and included as part of the
preliminary power pool statement rather than solely the final power pool
statement; as these charges could potentially be reflected on a preliminary power
pool statement.
Proposed new paragraphs 17(2)(c) and (e) have been added to this subsection;
to align with the settlement period changes in the AUC Rule 021.
Subsection 18 - Final Pool Statement
Comment # 22 Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to issue a final power pool statement to pool
participants by the end of the fifteenth (15th) business day for amounts
determined on the initial, interim and final basis that contain the same line items,
as appropriate, as referenced in Subsection 17 for the preliminary power pool
statement.
Issued for Stakeholder Consultation: 2011-04-014
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As well, this subsection requires pool participants to notify the AESO if it is
unable to retrieve the preliminary pool statement from the AESO’s website, and if
notified, the AESO must use alternate delivery means.
These requirements have been redrafted and relocated from existing ISO rules 8,
subsection 8.4.2.
Subsection 19 - Pool Settlement Date and Payment Obligations
Comment # 23 Insert Comments / Reason for Position
(if any)
This subsection requires a pool participant to settle the payment obligations with
the AESO in accordance with the pool settlement dates published each January
by the AESO, irrespective of any dispute. This requirement has been redrafted
and relocated from existing ISO rules Section 8, subsection 8.4.3.
Subsection 20 - Acceleration in Pool Settlement Dates Due to Default
Comment # 24 Insert Comments / Reason for Position
(if any)
This subsection requires pool participants upon notice from the AESO to
accelerate their pool settlement payment dates when specific payment default
events occur. This requirement has been redrafted and relocated from existing
ISO rules Section 8, subsection 8.4.3 and 8.4.4.
Subsection 21 - Interest and Other Late Payment Costs and Charges
Comment # 25 Insert Comments / Reason for Position
(if any)
This subsection requires a pool participant to pay interest, late payment charges
and other costs if it fails to pay its power pool statement on or before the
settlement date. This requirement has been redrafted and relocated from ISO
rules Section8, subsection 8.4.4.
In addition, this subsection makes reference to proposed new ISO rules Section
103.7 “Financial Default and Remedies”. Proposed new ISO rules Section 103.7
consolidates all financial defaults and remedies provisions and includes interest
and late payment charges.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 22 - Method of Payment
Comment # 26 Insert Comments / Reason for Position
(if any)
This subsection requires pool participants to make all settlement payments in the
form of wire transfers. This requirement has been redrafted and relocated from
existing ISO rules Section 8, subsection 8.4.3.
With regard to the method of payment, the AESO is proposing not to relocate the
statement referring to the “electronic transfer method” to proposed new ISO rules
Section 103.4, as this method is obsolete and the AESO does not accept
electronic transfers.
Subsection 23 - Prepayment Procedures
Comment # 27 Insert Comments / Reason for Position
(if any)
This subsection specifies the requirements for prepayments for the pool
participant and the AESO. These requirements have been redrafted and
relocated from existing ISO rules Section 8, subsection 8.4.3.
The AESO has not relocated the requirement to notify the AESO regarding
prepayment with the prepayment details. The AESO is proposing to remove this
requirement, as the AESO does not require notification when a pool participant
chooses to prepay.
Subsection 24 - Informal Disputes
Comment # 28 Insert Comments / Reason for Position
(if any)
The dispute resolution procedures relating to settlement have been aligned with
existing ISO rules Section 103.2 “Dispute Resolution”, and this subsection allows
the pool participant and the AESO to resolve disputes informally. This provision
has been redrafted and relocated from existing ISO rules Section 8, subsection
8.4.2 and contemplates that the pool participant and the AESO may resolve
disputes by mutually agreement in accordance with existing ISO rules Section
103.2.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 25 - Formal Dispute Periods
Comment # 29 Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to publish on its website, each January, the
formal dispute submission periods for the settlement periods for the calendar
year. This requirement has been redrafted and relocated from existing ISO rules
Section 8, subsection 8.5.
Subsection 26 - Power Pool Statement Formal Disputes After Final Pool
Statement
Comment # 30 Insert Comments / Reason for Position
(if any)
This subsection specifies the requirements for resolving disputes, between the
pool participant and the AESO, after the final power pool statement has been
issued. These requirements have been redrafted and relocated from existing ISO
rules Section 8, subsection 8.5.
The AESO has not relocated existing ISO rules Section 8, subsection 8.5.5(d) to
proposed New ISO Rules Section 103.4. Subsection 8.5.5(d) allows the AESO to
review and settle a dispute arising after the dispute submission period but in any
event no more that twenty-six (26) months following the end of the settlement
period. The AESO is proposing to remove this provision to align with its current
practices, as the AESO does review and settle disputes outside of the twenty-six
(26) month window if the dispute is valid.
Subsection 27 - Power Pool Statement Adjustments For Resolved Disputes
Comment # 31 Insert Comments / Reason for Position
(if any)
This subsection requires the AESO to include any adjustment amounts resulting
from resolution of an informal dispute on the final power pool statement.
As well, this subsection requires the AESO to include any adjustment amounts
resulting from resolution of a formal dispute on the next final power pool
statement. These requirements have been redrafted and relocated from existing
ISO rules Section 8, subsection 8.4.2.
Issued for Stakeholder Consultation: 2011-04-014
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Subsection 28 - Settlement System Code Determination by the ISO
Comment # 32 Insert Comments / Reason for Position
(if any)
This subsection allows the pool participant to notify the AESO if it does not agree
with a “Determination” made under the Alberta Utilities Rule 021. This provision
has been redrafted, updated and relocated from existing ISO rules Section 8,
subsection 8.5 (b).
Other
1.
Comment # 33 Insert Comments / Reason for Position
(if any)
The AESO is proposing not to relocate the last provision in existing ISO
rules Section 8, subsection 8.4.2, to proposed new ISO rules Section 103.4.
This provision was a time limited provision dealing with long lead time
energy directives in existing ISO rules Section 6 “Dispatch and Directive”.
This provision is no longer required as these ISO rules amendments are
now in effect. This last provision in ISO rules 8.4.2 states:
“The specified ISO rule amendments cited in Application No. 1605244 will
be effective 30 calendar days after the date to be determined by the
Commission for, collectively, ISO rules consisting of G1 definitions, 6.3.5.1,
6.3.5.2, 6.3.6.2, 6.3.6.3 and Appendix 7 (collectively the “LLTD Rule”)”
2.
The AESO has not relocated the provisions from existing ISO rules Section
8, subsection 8.5 (e), (f) and (g). These provisions are described below:
a. Existing ISO rules Section 8, subsection 8.5 (e): Any disputes raised in
accordance with b) or d) and relating to metering data provided to the
AESO by a meter data manager or other source as approved by the
AESO shall be communicated to the respective information source. The
respective information source may participate in the resolution of such
disputes.
The AESO resolves and directly communicates dispute information with
the party raising the dispute, therefore, the AESO is proposing to
remove this requirement.
Issued for Stakeholder Consultation: 2011-04-014
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b. Existing ISO rules Section 8, subsection 8.5 (f): Any disputes raised in
accordance with b) or d) and relating to a net settlement instruction
MWh volume provided by a forward market operator shall be
communicated to the applicable forward market operator. The forward
market operator shall participate in the resolution of such disputes.
c.
This statement is inaccurate as the forward market operator is not the
party providing net settlement instructions to the AESO in proposed
new ISO rules 103.5 “Net Settlement Instructions”. Therefore, the
AESO is proposing to remove existing ISO rules Section 8, subsection
8.5 (f) above.
Existing ISO rules Section 8, subsection 8.5 (g): Disputes relating to
Commission orders or directions relating to regulations under the Act
shall be referred directly to the Commission for resolution.
AUC Rule 021, subsection 5.3.4 sets out requirements for disputes with
respect to Commission orders or directions relating to regulations under
the Act. Complimentary to AUC Rules 021 are the dispute resolutions
procedures set out in proposed new ISO rules Section 103.4 and in
existing ISO rules 103.2. In the AESO’s opinion, this collectively set of
dispute resolution requirements are comprehensive and, therefore, the
AESO is proposing to remove provision ISO rules Section 8, subsection
8.5 (g) above
3.
The AESO has not relocated ISO rules Section 8, subsection 8.7 “Goods
and Services Tax Registration”. The pool participant is required to indicate
its Goods and Services Tax registration number on the pool participant
application form when registering to become a pool participant. This being
the case, the AESO is proposing to remove this requirement from the ISO
rules.
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(b)
Removals
No ISO rules are being proposed for removal.
(c)
Amendments
No amendments to ISO rules are being proposed.
(d)
Other (Stakeholders wishing to comment on specific provisions are
requested to copy the provision into this area and provide comments)
Issued for Stakeholder Consultation: 2011-04-014
Comment # 34 Insert Comments / Reason for Position
(if any)
Comment # 35 Insert Comments / Reason for Position
(if any)
Comment # 36 Insert Comments / Reason for Position
(if any)
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