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Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Date: 2012-07-17 Proposed Removal of Existing ISO rules Section 6 Dispatch and Directives (“ISO Rule 6 Removal”) Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: Comments From: ATCO Power Date [yyyy/mm/dd]: August 31, 2012 2012/07/17 2012/07/17 through 2012/08/31 Contact: Mary Dylke Phone: 403-245-7521 E-mail: [email protected] Listed below is the summary description 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 actual proposed content changes to the ISO Rules. Please place your comments / reasons for position underneath (if any). 1. ISO Rules (a) New No new ISO rules provisions are being proposed for the proposed ISO Rule 6 Removal. (b) Amendment No amendments to ISO rules provisions are being proposed for the proposed ISO Rule 6 Removal. (c) Removals The AESO is proposing to remove portions of existing ISO rules Section 6 Dispatch and Directives. For a detailed breakdown showing where content has Issued for Stakeholder Consultation: 2012-07-17 Stakeholder Comments and/or Alternate Proposal AESO Replies Comment # 1: Insert Comments / Reason for Position (if any) Comment # 2: Insert Comments / Reason for Position (if any) Comment # 3: Insert Comments / Reason for Position (if any) Page 1 of 3 been relocated or deleted, please see the Table of Concordance. ISO rules Section 6 sets out requirements for the AESO in issuing dispatches and directives for energy, dispatch down service, and long lead time pool assets. These rules also set out the requirements for pool participants in receiving and complying with those dispatches. In general, provisions addressing unusual market conditions such as long lead time energy, dispatching equal prices and involuntary load curtailment, have been relocated to proposed New ISO Rules Division 202 Non-Routine Conditions in the Markets. Requirements addressing energy or dispatch down service under normal operating conditions have been relocated to proposed New ISO Rules Division 203 Energy Market or proposed New ISO Rules Division 204 Dispatch Down Service, respectively. In general, ATCO Power is supportive of the proposed deletions. However, in the cases where content is relocated to the System Controllers Procedures our comment is that this should be done with careful consideration. Even though certain actions are clearly the responsibility of the System Controller, in some cases it may be beneficial to allow market participants to retain visibility of the System Controller requirements. This would allow market participants to anticipate actions they may need to take to assist the System Controller in meeting its requirements. ISO rules Section 6 also sets out requirements on the AESO’s pricing methodology. This content has been moved to proposed New ISO rules Section 201.6 Pricing. Existing ISO Rules Subsections 6.4 and 6.5 address dispatches and directives for ancillary services. Requirements that address contracted ancillary services such as black start, voltage support, or power system stabilizers have been removed, as these products are administered through contracts. Requirements for transmission must run have been relocated to proposed New ISO rules Section 205.8 Transmission Must Run. Requirements addressing dispatches and directives for operating reserves will remain in existing ISO rules Section 6 and will be removed at a later date as these requirements are transitioned into the future proposed operating reserves rules. ISO rules Subsection 6.6.2(b) sets out requirements for regulating reserve. These requirements will remain in ISO rules Section 6 and will be transitioned into the future proposed operating reserves rules. ISO rules Subsection 6.7 addresses system security. This section will remain in the existing ISO rules framework and will be transitioned at a later date. Issued for Stakeholder Consultation: 2012-07-17 Page 2 of 3 (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: 2012-07-17 Comment # 4: Insert Comments / Reason for Position (if any) Page 3 of 3