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1 Stakeholder Comment and AESO Replies Matrix AESO Consultation 2013 Budget Review Process: Meeting September 14, AESO s Draft Business Initiatives for 2013 The AESO is asking market participants and interested parties to comment on the 2013 draft Business Initiatives (revised) presentation given at the Budget Review Process (BRP) stakeholder review meeting September 14, Draft Business Initiatives Timeline/Calendar - Proposal to add a second Technical Meeting Do stakeholders have any comments regarding the proposal to add a third Technical Meeting to review the AESO s 2013 Own Costs budget proposal on Wednesday, October 17 th? Note - The Technical Meeting scheduled for October 3 is to continue as planned and review the AESO s Ancillary Services and Transmission Line Losses Costs Forecasts for Stakeholder Stakeholder Comment AESO Replies ADC 1. No objection - although Edmonton meetings are always appreciated. CPC 1. CPC is supportive of adding a third technical meeting and will appreciate the opportunity to review a detailed breakdown of the AESO s proposed budget. IPCAA 1. October the 17 th will not work for IPCAA. The AUC (through Bulletin ) has initiated a review of AUC Rule 002: Service Quality and Reliability Performance Monitoring and Reporting which is scheduled to occur from October 16 to October 18 th in Edmonton. Comment 1. We will review the proposed October 22 revision. We will also consider other alternative dates. As a result of our review, we will follow up with stakeholders on any proposed revision of calendar dates. The week of October 8th or October 22nd would be preferred. AESO Stakeholder Comment and AESO Replies Matrix:

2 2013 Draft Business Initiatives - Strategic Objectives and 2013 Draft Business Initiative Proposal Do stakeholders have any comments on the AESO s Strategic Objectives and supporting Business Initiatives proposed for 2013? Stakeholder Stakeholder Comment AESO Replies ADC In general the ADC is supportive of the AESO business priorities. Specifically: 1. The ADC is supportive of the AESO s continued development of demand participation in the market. The ADC is concerned over the comments from the MSA and other market participants on the LSSi program. This program needs time to work and it is premature to make any assessments on its success. 2. The ADC is supportive of moving to a 15 minute settlement alignment of dispatch and settlement periods. 3. The ADC is supportive of moving forward with the Transmission cost accountability recommendations. The ADC encourages the AESO to allocate sufficient resources to oversee and audit the execution of the direct assigned projects as well as provide visibility to the AUC of project costs, schedule and in service dates. We also would like to compliment the AESO on their continued participation with the TFCMC. 4. The ADC reemphasizes the need to have the transmission cost model kept up to date. We suggest that a detailed model of the distribution elements is out of scope for the AESO. Comment 1. Demand side market participation is an identified 2013 business initiative. An informed assessment of the impact of the LSSi program on the market requires sufficient data be available for analysis. An assessment review is planned in Comment 2. Management believes this will be a multi-year initiative tied to the replacement of aging market systems. Initial design work will begin in Comment 3. Noted. AESO will continue to review the need to allocate resources to monitor transmission costs and support the TFCMC. Comment 4. AESO is actively working on an updated transmission rate impact analysis. The AESO expects to have this completed and published by year-end. We would agree that the distribution elements are out of scope for the AESO. AESO Stakeholder Comment and AESO Replies Matrix:

3 ADC, Cont d. 5. With respect to the AESO s public outreach plan, the ADC feels that the cost to support is more appropriately sourced from the taxpayer through a budget within the DoE. Comment 5. The AESO has been engaged in public education for over five years as part of our corporate mandate to inform all Albertans about its role in ensuring the province s electricity system and competitive wholesale market continue to meet the needs of Albertans today and in the future. As a not-forprofit organization that does not own or operate any power facilities and has no financial investment in the industry, a strong and trusted reputation with all stakeholders allows the AESO to successfully fulfill its mandate. CPC 1. CPC is supportive of the majority of the AESO s initiatives for 2013 and trusts the AESO will continue to engage stakeholders in a manner that will permit meaningful and fulsome consultation on each initiative. 2. CPC requests that the AESO add the timelines and associated deliverables for all their proposed business initiatives for next year. Adding these items would greatly benefit stakeholders in their own planning requirements. Also, presenting the initiatives in order of importance from the AESO s perspective would be helpful in focusing the efforts of the AESO and stakeholders on those projects with the highest priority. 3. The AESO has indicated that despite the numerous initiatives being proposed that they have adequate resources to handle the workload and will not result in corresponding budget increases. However, CPC requests that the AESO also be mindful that Stakeholder consultation is a fundamental principle used by AESO to develop business initiative details such as requirements and timing. The results and recommendations from these consultations are posted on aeso.ca for transparency. Comment 2. The response to comment 1 above highlights that individual business initiative details are essentially developed in consultation with stakeholders and the resulting details published on aeso.ca. In addition, the AESO provides a high-level overview of its business initiatives in the Business Plan and Budget and provides progress updates in the Budget Review Process quarterly report. Comment 3. Noted. Stakeholder engagement and feedback in planning, prioritization and development activities (Comment 2 above) will help the AESO improve the overall coordination of consultation activities. AESO Stakeholder Comment and AESO Replies Matrix:

4 CPC, Cont d. stakeholders have limited resources available to them to engage in AESO and other agency consultation initiatives, and requests that the AESO coordinate their consultation processes accordingly, both internally and with other agencies as required, in order for stakeholders to be able to provide appropriate and meaningful input into each initiative. With respect to proposed initiatives for 2013, CPC has the following comments: 4. As indicated by the AESO, CPC is anticipating that the Wind Integration recommendation paper will be released by September 30, 2012 and contemplates this issue will be examined, and the consultation processes coordinated, in conjunction with other inter-related issues. Comment 4. Noted.The AESO examines all issues in a coordinated manner. Also, See AESO Reply to ADC Comment 2 above. Since it was identified as an enhancement within the 2005 Policy Framework paper, CPC is of the opinion that the alignment of dispatch should be viewed as a priority by the AESO. CPC is supportive of this review and looks forward to participating in the consultation process for this enhancement. 5. The AESO stated the Brattle Report on seams issues will be released by Q and CPC looks forward to reviewing the report as part of the AESO s consultation process. 6. CPC is interested in receiving more about the AESO s energy storage initiative; more detail as to why certain parties have identified it as a high priority, if storage will be considered a regulated facility part of the transmission system or if they will be treated as merchant facilities, and the timeline for completing the AESO s research. Comment 5. The Report will be published on completion. Comment 6. Noted. This business initiative is early in its life cycle. Program scope not been fully defined. Ongoing consultation will provide additional details to stakeholders. Process updates will be posted on aeso.ca AESO Stakeholder Comment and AESO Replies Matrix:

5 CPC, Cont d. 7. The AESO has indicated their discussion paper on dynamic scheduling is not yet complete and requires further work. CPC requests that the AESO provide a timeframe for when they anticipate the paper to be released for consultation. 8. Since it will continue to be a significant undertaking for all stakeholders in 2013, CPC believes that TOAD should be included as part of the AESO s business initiatives and that the AESO factor in the many subcomponents of this project in order to consider time and resource constraints faced by stakeholders as a result of the numerous AESO initiatives. Comment 7. The AESO anticipates additional consultation on the implementation of dynamic scheduling to begin in the fourth quarter of Comment 8. AESO management believes the TOAD process will have reached a steady state (operational -standard practice) in the second quarter of However, AESO Management concurs that the ongoing AD (authoritative document) operational practice will need to be cognizant of internal/external resource requirements/constraints. MSA 1. From the AESO 2013 Draft Business Initiatives demand response (load as spinning reserve, energy storage) When reading the new Bal-002 somehow I had assumed that load would have the ability to provide Regulating Reserve to the AESO. Does the term Load as Spinning reserve remove the potential for load to provide regulating Reserve? Comment 1. Demand side participation in the market development is an identified 2013 business initiative. It is the AESO s goal to remove barriers to participation in our markets to the degree that this is possible. IPCAA IPCAA has the following comments on the Business Initiatives: 1. LSSi Review may need to be conducted in advance of the 18-month-after-the-fact time period. There is some concern that we are not able to import additional power when it is needed most. Comment 1. See AESO Reply to ADC Comment 1 above. AESO Stakeholder Comment and AESO Replies Matrix:

6 IPCAA, Cont d. 2. IPCAA is willing to work with the AESO to promote operating reserve provision particularly spinning reserve provision, when it becomes allowable by loads. 3. Customers are interested in an update of the AESO transmission rates and impact information. This update needs to be prompt and publicly available. The 2011 calculator is out-of-date and budgets for power are currently being compiled. 4. There is some concern that the Transmission Facilities Cost Monitoring Committee (TFCMC) work will require more of the AESO s time and resources. This is a priority for customers, and it is critical that sufficient AESO resources are available for transmission cost accountability and oversight. 5. Both load and generation customers are concerned with the schedules and costs of connecting to the grid. Customers are interested in an industry-wide review to highlight areas of improvement including policy-level recommendations. 6. IPCAA has some concerns with Assess AESO advocacy opportunities under Strategic Objective 7. What does this entail? Comment 2. Noted. Comment 3. See AESO reply to ADC comment 4 above. The AESO has deferred a 2012 rates update application since AUC Bulletin limits increases in rates for transmission services. Comment 4. Noted. See AESO Reply to ADC Comment 3 above. Comment 5. AESO is committed to continuous improvement in this area. Many improvements have been implemented since An industry wide connection process innovation workshop has been scheduled for October 22. This workshop provides another opportunity for additional stakeholder recommendations for improvement. Comment 6. This business initiative has been removed from the 2013 proposal as the scope has not been fully developed. AESO Stakeholder Comment and AESO Replies Matrix:

7 IPPSA 1. IPPSA s comments are contained to the 2013 Draft Business Initiatives of the Market Development Strategic Objective High-level recommendation Please look for linkages in issues and proceed in a holistic manner External issues The AESO is facing three AUC decisions on rules (losses, ATC and CM). How will these decisions impact 2013 priorities? The market may also need a high-level agency alignment dialogue to interpret/internalize the AUC s new approach to efficiency. (This may or may not resolve itself in the AESO/AUC court of appeal matter.) Such a discussion may also impact 2013 priorities. 2. IPPSA suggested priorities for 2013 Of the policy issues, we see the following as our priorities in order of highest to lowest. Frankly, we see the bottom three as nice to haves, meaning they can be delayed for some time: 1. Interties (restoration, merchant transmission integration, dynamic scheduling, jurisdictional seams issues) 2. Alignment of dispatch and settlement 3. Demand response topics (load as spinning reserve, storage) 4. Price cap and floor 5. T-2 change AESO Management concur that external factors and decisions could have a significant impact on the business initiatives proposed, particularly with respect to the scope of work and timing. Recognizing that a number of scenarios could occur throughout the life cycle of any business initiative the AESO has established an internal portfolio management process intended to help respond to such changes. Together with input obtained from ongoing stakeholder consultation (e.g., BRP, MAC, other). Management uses this process to facilitate overall prioritization and alignment of supporting programs, and rebalances the portfolio (e.g., scope, schedule, budget, deferral, cancellation, etc.) should a change in external factors warrant it. Comment 2. Noted. AESO Stakeholder Comment and AESO Replies Matrix:

8 IPPSA, Cont d. Of the following AESO 2013 priorities, we see the following as maintenance or final strokes implementation issues: 1. Wind integration 2. Operating reserve rules 3. Market performance metrics 4. Market rule AD conversion 5. Market system replacement (IT) 2013 Draft Business Initiatives Meeting facilities and teleconferencing services Do stakeholders have any comments on the facilities and teleconferencing services provided in support of the meeting? Stakeholder Stakeholder Comment AESO Replies ADC 1. The ADC is appreciative of accommodating meeting attendance through conference call and web meeting. 2. Many of the AESO participants are not located in Calgary, the ADC urges the AESO to look at meeting facilities that can accommodate a broad base of stakeholders through web based facilities for ongoing AESO stakeholder consultations. Comment 2. Web based conferencing alternative is being considered a standard alternative for all stakeholder consultations, not just the Budget Review Process. CPC 1. Facilities were satisfactory for the meeting. IPCAA No comments. AESO Stakeholder Comment and AESO Replies Matrix:

9 Other Comments Do stakeholders have any other comments to offer at this time? Stakeholder Stakeholder Comment AESO Replies ADC None. CPC 1. CPC appreciates the effort of the AESO in capturing stakeholder comments at the September 14 th meeting and found the summary notes helpful. IPCAA No additional comments. AESO Stakeholder Comment and AESO Replies Matrix:

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