Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft 2010-07-20 New ISO

Rule Section 302.2 Connection Remedial Action Schemes

NOTE: The AESO is asking market participants to give an initial indication of their support for, or opposition to, the specific ISO rule changes referenced below. Such an initial indication assists in the AESOs practical understanding of the receptivity of the industry to the proposed changes, and in that regard the AESO thanks in advance all market participants who choose to respond. With regard to the specific ISO rule changes and their implications, such responses are without prejudice to the rights of market participants under the Act, any regulations, or related decisions of the Commission. Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: Comments From: Date [yyyy/mm/dd]: 2010/07/20 through 2010/08/31 Contact: Phone: E-mail: Gordon Nadeau 403-539-2568 gordon.nadeau@aeso.ca

2010/07/20

Shad Bendiak - ATCO Power Canada Ltd. 2010/09/03

Listed below is the summary 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 proposed content changes to the ISO Rules. Please double-click on the check box for either Support or Oppose and/or place your comments / reasons for position underneath (if any). 1. Definitions (a) New No defined terms are being added as part of the proposed New ISO Rule 302.2 Comments Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any) (b) Removals Issued for Stakeholder Consultation: 2010-07-20 Support Support with language suggestions Page 1 of 5 Rationale and/or Alternate Proposal

No defined terms are being proposed for removal as part of the New ISO Rule 302.2

Oppose Insert Comments / Reason for Position (if any)

(c) Amendments No defined terms are being amended as part of the New ISO Rule 302.2

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

2. Rule (a) New This section provides a description of the proposed new ISO rules sections and the rationale for the additions. Applicability 1 This new section identifies who would be impacted by the new connection remedial action scheme (RAS) rule 302.2.

Comments Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

Rationale and/or Alternate Proposal

Requirements 2 Initial Connection Remedial Action Scheme Assessment This new section stipulates that if the AESO in assessing a connection application determines that a connection RAS is required to manage a transmission constraint then the specifics of the connection RAS will be provided through the connection process.

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

Can the AESO please elaborate on the possible case where 2(1)(a)(i) is met but 2(1)(a)(ii) is not? What would be the course of action in such a case? Would the connection be approved even if it would lead to a transmission constraint? ATCO Power does not support connecting new load or generation if it is known well in advance that a real time transmission constraint will be created. The AESO has the authority to delay the connection until

Issued for Stakeholder Consultation: 2010-07-20

Page 2 of 5

such a time that real time TCM would not be needed to support it. This would be the preferred course of action.

Connection Remedial Action Scheme Considerations

This new section outlines the considerations that the AESO will include when assessing the potential use of a connection RAS.

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

3(c) the transmission system constraint cannot be properly and adequately dealt with by ISO system control procedures in real time ATCO suggests this be removed from the rule. Real time TCM should not be a solution for transmission constraints that can be avoided by proper system planning.

Notification of Connection RAS

This new section stipulates that if the AESO proposes a connection RAS then the AESO will document through the connection process certain specified information regarding the connection RAS and create a connection proposal document. Further, if the market participant executes the connection proposal document which includes specifics of the connection RAS, the AESO will proceed with the connection. If not, the AESO will not proceed with the connection.

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

Further Connection Remedial Action Scheme Determination by ISO

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

This new section indicates that a connection RAS may be identified or altered between the time that a connection proposal document is executed and the connection occurs. If that occurs, the market participant will be notified and the provisions of this rule 302.2 will apply including the requirement that the market participant must accept the specifics of the connection RAS or not be connected. Issued for Stakeholder Consultation: 2010-07-20

Page 3 of 5

Connection Remedial Action Scheme Provisions in System Access Service Agreement

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any) Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any) ATCO Power requests that the AESO more clearly define extraordinary and compelling circumstances. In a hypothetical case where a new entrant causes a transmission constraint but an incumbent unit is more effective in mitigating it, would the connection RAS ever be placed on the incumbent rather than the new entrant? ATCO Power would view this as a unacceptable scenario.

This new section requires the AESO to have the market participant system access service agreement incorporate the terms and conditions of the connection RAS. 7 Multiple Market Participant Connections in Constrained Area This new section outlines the existing AESO policies regarding: 1) connection RAS assignment based connection queue position 2) connection RAS order of use if more than one connection RAS can manage a transmission constraint 3) the AESO use of multiple connection RAS only in extraordinary and compelling circumstances

(b) Removals There are no ISO rule sections to be removed.

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

(c) Amendments There are no ISO rules sections to be amended.

Support Support with language suggestions Oppose Insert Comments / Reason for Position (if any)

Issued for Stakeholder Consultation: 2010-07-20

Page 4 of 5

(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: 2010-07-20

Page 5 of 5