AESO RESPONSE TO FEEDBACK REGARDING THE PROPOSED NEW NOTIFICATION OF FORCE MAJEURE EVENT FORM
October 24, 2007
Name of Interested Party and Comments Submitted by
the Interested Party
AESO Response
ATCO Power Comment
“So far I have liked what I have seen. I would also like to
emphasize that I have only had limited opportunity to use
the form.
Some things that I would like to see changed include
making the form specific to our company ie Customer and
unit should just be related to ATCO. I do recognize that
this form will double my work for Force Majeures and I am
ok with that as long as the AESO is willing to be flexible
with the two day limit for submitting FM’s. I will try to give
adequate notice if I am going to be late as I have done in
the past. This usually doesn’t occur to often, but I would
like to make you aware of this concern.”
The new FM form was designed to enhance the efficiency of
processing claims of force majeure, and was designed to
enable the AESO to process claims without re-typing the
information into our current system.
The new FM form is not intended to increase participants’ work
load. Given the concerns raised by market participants, the
AESO will assist market participants in customizing the new
form (including the development of templates) such that it is as
simple as possible to use.
The AESO will not make the new FM form mandatory, and will
allow those market participants that prefer the use of the
existing FM form to continue to use the existing form. The
AESO will continue to work with market participants to address
the concerns raised during consultations.
Participants are expected to adhere to the terms of the contract,
which requires FM notification within two business days of its
occurrence. If it can be shown that there are extenuating
circumstances to justify a time extension, the AESO will take
that into consideration.
ENMAX Comment
“I have briefly looked at the new sheet and find it to be even
more time consuming than the previous version. I find that
entering each hour individually is cumbersome and too time
consuming. I would recommend a sheet such as the
attached, in which one description of the Force Majeure
details can be used to FM several hours (such as shaped
volume that the AESO often procures for active products).
The new FM form was designed to enhance the efficiency of
processing claims of force majeure, and was designed to
enable the AESO to process claims without re-typing the
information into our current system.
The new FM form is not intended to be more time consuming or
cumbersome. Given the concerns raised by market
participants, the AESO will assist market participants in
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Name of Interested Party and Comments Submitted by
the Interested Party
Also, I think it would be useful if there was a way to force
majeure all volume for a unit in an hour....as this would save
a lot of time instead of FM'ing the next day after a unit trips.”
AESO Response
customizing the new form (templates for shaped volumes) such
that it is as simple as possible to use.
The AESO will not make the new FM form mandatory, and will
allow those market participants that prefer the use of the
existing FM form to continue to use the existing form. The
AESO will continue to work with market participants to address
the concerns raised during consultations.
Ancillary services are tracked and invoiced by product and time
and, therefore, when ancillary services are force majeured, the
product and time must be defined.
It is possible to submit both the existing and new FM forms in
real time once the FM volume and times are known. However,
circumstances may change, requiring revisions if notice was
submitted too soon. The AESO recommends submitting
notification after an event occurs to minimize the work required
for any particular FM notification. Participants have up to two
business days to submit notification of an FM event after it has
occurred.
EPCOR Comment
“- Can the file name be named anything we choose as
long as the extension is .xls?
- how many characters are available for the Reason?
- Should an error exist, how long until the automated
response generates an email?
- What is the timeline for introduction of this new form?
Yes.
There is no limit to the number of characters that are available
for the reason. Market participants are encouraged to use as
many characters as required to adequately explain the reason
for the FM.
Once the file is uploaded, the error message would be
generated immediately. The message will be forwarded to the
participant as soon as it is generated. Error messages using
the new FM form are expected to be more straightforward than
under the existing FM form. Another advantage of the new FM
form is that errors can be identified to a specific hour rather
than to a range of hours.
Participants may begin submitting FM notifications using the
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Name of Interested Party and Comments Submitted by
the Interested Party
AESO Response
new FM form as of the date of the accompanying letter.
This form seems to make its easier for the AESO but
appears to make it more difficult for the market
participants? Is the AESO willing to modify this form in
order to ease the burden now faced my market
participants? Example, drop down menu's prevent the
'dragging' down of a cell entry; now that the FM form will
not accept a range of hours, entry lines required are
magnified by a factor of 16 for a whole on-pk product and
8 for an off-pk product.”
The new FM form was designed to enhance the efficiency of
processing claims of force majeure, and was designed to
enable the AESO to process claims without re-typing the
information into our current system.
The AESO will consider the suggestions made by market
participants as part of future enhancements. Given the
concerns raised by market participants, the AESO will assist
market participants in utilizing drag and drop capabilities, and in
developing templates for shaped volumes, in order to make the
form as simple as possible to use.
The AESO will not make the new FM form mandatory, and will
allow those market participants that prefer the use of the
existing FM form to continue to use the existing form. The
AESO will continue to work with market participants to address
the concerns raised during consultations.
TransAlta Comment
“The only real comment that I have is the requirement to
enter each hour as a separate line item. If you have to FM
out of an entire HLH or even a full day, you will have to
enter 1 line for every hour in the day.
The AESO notes the suggestion that one entry for a range of
hours is preferred. This suggestion will be taken into
consideration as a future enhancement of the new FM form.
Currently, the ability to have a start and end HE selection is
much more efficient. Other than, not much to comment on.”
TransCanada Energy Comment
“TransCanada has reviewed the form and the only comment
we wish to make is that it would be our preference to enter a
start and end hour for an event as opposed to making
entries during each hour that a situation might persist.
The AESO notes the suggestion that one entry for a range of
hours is preferred. This suggestion will be taken into
consideration as a future enhancement of the new FM form.
We hope the AESO is able to accommodate this change,
we understand other participants share our view.”
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