1. Name of Company or Organization. Solas Energy Consulting on behalf of the Renewable Energy Coalition

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1 [print] 1. Name of Company or Organization Solas Energy Consulting on behalf of the Renewable Energy Coalition 8/28/18 12:13:11 PM MDT 2. Alberta Energy intends to post all of the feedback received from stakeholders on its website. This provides transparency in the engagement process. Please check here if your organization does not wish to have your organization's feedback posted. 3. Do the proposed additional concepts numbered 1 to 4 adequately cover the types of conduct that would not support fair, efficient and open competition in the capacity market? If not, why not? 1. Yes 8/28/18 12:14:36 PM MDT 4. To what extent is proposal 5 already addressed by the existing provisions outlined in the Fair, Efficient and Open Competition Regulation in Sections 2(j) or 2(k)? 5. Is it desirable to seek to strengthen competition through the addition of stronger protections such as those proposed in the additional concept number 5? 2. No While a noble goal, proposal 5 is not enforceable. The point of a market is that participants are acting for their own benefit. Market participants need clear rules, and if there is a deficiency in the rules then the rules need to be corrected. Market participants should not operate under fear of interpretation of what behaviour may constitute a deficiency in the market or rules. 8/28/18 12:14:36 PM MDT 6. Could amendments to Sections 2(j) or 2(k) of the Fair, Efficient and Open Competition Regulation adequately achieve the regulatory intent articulated in proposal 5? If yes, please include suggested amendments.

2 7. Are there any other revisions to Section 2 of the Fair, Efficient and Open Competition Regulation that would strengthen competition in either the electricity or capacity markets? 8. Does the proposed concept adequately address competition concerns associated with the preferential sharing of records in the capacity market? Is any more specificity required? Please provide a rationale for your answer. 9. Does the proposed concept to prohibit information sharing adequately address concerns with joint ventures participating in either the energy market or capacity market? Please provide a rationale for your answer. 10. Any other comments? 11. Does the drafting of the existing regulation achieve the intent of providing timely and useful reporting of outages by the AESO to market participants? If not, why not? 12. What terminology could replace generating unit by fuel type in order to provide timely and useful information to market participants? 13. Should there be a specific reference to mothballed or delisted generating units in this section?

3 14. Any other comments? 15. Demand side response is not currently included in the market share offer control calculation outlined in Section 5(2). Should demand side response be included in the market share offer control calculation? 2. No Offer control is meant to limit the ability of generators to increase the electricity price. The interest of demand side participants is in lower electricity prices, therefore demand side response should not be included in the offer control calculation 8/28/18 12:16:00 PM MDT 16. It has been proposed that electric storage facilities be included in the market share offer control calculation outlined in Section 5(2). Are there any concerns with including electricity storage facilities in the calculation? 1. Yes In general, energy storage should be included in the calculation of offer control as storage offers could be used to manipulate power price just like any other source of generation. However, there are certain situations where energy storage should not be included. Namely, energy storage should not be included if the addition of storage to a facility does not increase the volume of the STS contract associated with the facility. Example 1: A 50 MW wind power generation facility adds a 10 MW energy storage facility to supply energy during low wind periods and therefore leaves the STS contract unchanged at 50MW. The offer control contribution for this facility would remain at 50 MW since it is not possible for the facility to supply more than 50MW to the grid. Example 2: A generator operates an energy storage facility at a load facility for internal purposes and does not create an STS contract. The storage volume would not be added the offer control calculation since no offers will be made to the energy merit order. 8/28/18 12:16:00 PM MDT 17. Any other comments? 18. While considering the need to balance transparency with the goals of maintaining fair and open competition in the market, when should auction information be publicly released? Please provide a rationale for your answer. 5. Other (please specify) (30 days after the close of the final rebalancing auction)

4 Auction information should be publicly released 30 days after the close of the final rebalancing auction. Once the final rebalancing auction has closed, the information cannot be used to market participants to influence the price during the delivery period but is still relevant to helping participants understand market dynamics and perform market forecasts. Generation and load participants will be better able to make educated assessments about future market prices and plan for implications to revenue and costs. Information released much after the end of the obligation period will be of little value. Older historical information is only useful to the extent that it informs a trend in market dynamics, therefore the lack of recent data will reduce the usefulness of all the data. 8/28/18 12:16:58 PM MDT 19. Are there any competitionrelated concerns with releasing asset identification along with price/quantity pairs? 20. Any other comments? 21. Please provide your views on any additional amendments that could be made to the Fair, Efficient and Open Competition Regulation that could strengthen competition in Alberta s electricity and capacity markets. 22. Are there any amendments that could provide greater clarity on agency roles with respect the fair, efficient and openly competitive operation of the market? 23. During the engagement process for regulations related to the capacity market, Alberta Energy has used several means to share information with stakeholders and gather feedback. Please rank how satisfied your company or organization was with the following aspects of the engagement process: Very satisfied Satisfied Neither Dissatisfied Webinars X Discussion document X Feedback forms X 8/28/18 12:17:28 PM MDT 24. Do you have any additional feedback on how the Government of Alberta can improve their engagement process for future policy initiatives?

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