Capacity Market Regulation Feedback Form

Transcription

1 Capacity Market Regulation Feedback Form [print] 1. Name of Company or Organization Consumers Coalition of Alberta- 8/7/18 2:33:02 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 Should there be other AESO decisions that are subject to the abbreviated complaint process other than those listed above? If yes, please indicate what other capacity market complaints should be included. Please provide a rationale for your answer. Alberta Power (2000) Ltd's application for exemption from the HEE and EU Acts with respect to the Battle River Station supplying electricity to ATCO owned facilities leased to third party crypto currency operators may be another category for abbreviated complaint process. 4. Do you agree with the level of MSA involvement proposed for this process? If no, please provide additional input in the next question. 5. If you answered no to Question 4, please indicate which statement most reflects your rationale. 1. I would prefer the MSA provided a greater level of oversight to ensure decisions are fair.

2 The MSA should have the ability to take complaints/issues straight to the AUC without having to go through the AESO first. 6. Do you think that the documentation that would be submitted to the AUC for consideration of a complaint is appropriate, given the minimal time available to resolve these disputes? If no, please indicate what evidence you believe would be most valuable to assist in the resolution of these disputes. A brief discovery process through information requests and responses should be included 7. To facilitate the implementation of the capacity market, certain aspects of the energy and ancillary services (EAS) markets will be evolved. Given this, do you believe a similar, abbreviated dispute resolution process is needed for electricity market disputes? If yes, please indicate what disputes would require an abbreviated process. Please provide a rationale for your answer. CCA believes the only effective way to evolve the energy market is to move to a time ahead market. Notwithstanding the foregoing, energy market disputes under a certain monetary value could be subject to the abbreviated process. Others should be subject to full review. 8. Do you have any further comments on the regulatory concepts for dispute resolution? (3,000 character limit) 9. Overall, do the proposed regulatory concepts adequately establish the resource adequacy standard? If you do not believe them to be adequate, please explain what additional aspects are needed. The AESO should be required to achieve the resource adequacy standard through a least cost mix of flexible resources and other generation. For example if the AESO purchases a large amount of inflexible generation (mainly from converting old coal units to gas units) to meet resource adequacy targets, there would be additional requirement to procure ramping products and additional spinning reserves through

3 ancillary services in order to provide the required flexibility, thereby increasing overall costs to consumers 10. Should loss of load be defined in the regulation? Please provide your rationale. 11. Is the requirement for annual reporting from the AESO appropriate? 12. If you answered no to question 11 please indicate what, if any, would be a more appropriate reporting method? Please provide a rationale for your answer. 13. Do you have any further comments on the proposed regulatory concepts for the resource adequacy standard? (3,000 character limit) 14. Overall, do the proposed regulatory concepts provide adequate guidance to the AESO with regards to the development and implementation of the Weighted Energy Method? If no, what additional guidance or alternative concepts are required? Please provide rationale for your responses. 1. Weighting: In CCA's view, the weighting of time blocks should reflect the relative contributions of different blocks to Expected Unserved Energy (EUE) in the forecast period. Since all hours have some potential to contribute to EUE, it is the relative weighting that is important. Therefore no time blocks should have zero weighting. 2. Storage: Storage can provide ancillary services including frequency control and ramping. Storage can also provide time shifting services thereby helping to reduce overall EUE. Given that storage injection is not a conventional load but provides capacity benefits to the system, consideration should be given to exempting storage injections from capacity charges. If storage were to be charged every time there is cycling of storage, the storage resource could be rendered uneconomic. 15. Do the proposed regulatory concepts provide adequate guidance to distribution system owners with regards to cost recovery?

4 If no, what additional guidance is required? Please provide the rationale for your response. See 14 above 16. Are there any barriers for distribution system owners to treat the costs of the capacity market as flow through costs to end-use consumers? Please provide the rationale for your response. 17. What terminology do distribution system owners use to define and distinguish end-use consumers with interval meters, who are billed on their individual consumption, from end-use consumers who are billed on a deemed load profile and may have cumulative meters? Is this information currently used to allocate portions of the ISO tariff to these two different types of consumers? Load profiles specific to each customer class served at distribution level may be used to allocate costs to those without time of use meters 18. What are possible barriers for distribution system owners to apply the costs of the capacity market, in a manner that reflects the dollar per megawatt hour rates resulting from the weighted energy method approved in the ISO tariff and charges all consumers reasonably for the portion of this cost they have incurred? 19. Do you have any further comments on the regulatory concepts for cost allocation in the Capacity Market Regulation? (3000 character limit) The netting of load against self generation is increasing. This is called load defections. The large co generators in the Province, for example, can unpredictably increase their reliance on the system in any time block if their generation trips out. This is not a one time cost for capacity but requires capacity to be acquired and in place to serve them in the event their generation trips out. Ideally co gen gross loads should be subject to capacity costs. This would may be offset by the generation side of co gen customers contracting for capacity payments for their generation capability. The same principles may apply to distributed generation.

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