Comment Period: August 25 to September 22, 2025

We value stakeholder input and invite stakeholders to provide their feedback on the Rationale for Ancillary Service Procurement for Intertie Restoration: Fast Frequency Response Plus (FFR+) (the Rationale Document) and addendum via the following stakeholder feedback form by September 22, 2025, at 4:00 p.m. MT. Please be as specific as possible with your responses. Thank you for your input.

Background

We have been engaging with industry stakeholders to develop a product and procurement design for an ancillary service that: 

• has regard to the four principles (i.e., technical feasibility, reliability, cost and fairness, efficiency and open competition) for the procurement of ancillary services in the Electric Utilities Act (EUA) (s.17.1(2I)) 
• satisfies sections 16 and 16.2 of the Transmission Regulation to make arrangements to procure ancillary services in amounts sufficient to support import flows at specified levels 

We published our initial proposed design in the Rationale Document.  An addendum to the Rationale Document includes alternative product and procurement designs and approaches that reflect the feedback received from industry to date.   

Purpose

This round of written feedback will further inform the final product and procurement design, which may include one or more of the options presented in the Rationale Document and addendum. The feedback will form part of our reference question application to the Alberta Utilities Commission (AUC) requesting guidance on whether the final design reasonably considers the four principles in the EUA and is in the public interest.

Instructions

1. This feedback form is open to all industry stakeholders.

2. Please fill out the sections below as indicated.

3. Only one completed feedback form will be accepted per organization.

• To upload your completed feedback form:
• You will need to be registered and signed in on the AESO Engage platform; and
• You will need to be on the FFR+ page (https://aesoengage.aeso.ca/fast-frequency-response-plus), which can be found on the AESO website at www.aeso.ca and follow the path: AESO Engage (found on very top navigation bar) > Fast Frequency Response Plus (FFR+) > Stakeholder Feedback > Part A: Written Feedback on FFR+ Product and Procurement Designs; and
• Click on the "Submit Stakeholder Feedback" box below to upload your completed feedback form.
  
  

All responses to Part A will be shared on AESO Engage in their original format. If you have any questions, please email ffrservices@aeso.ca.

Responses are due by September 22, 2025, at 4:00 p.m. MT.

Questions

Product and Procurement Design Options A, B, C and D as Described in Rationale Document and Addendum

1. Does the design of “Option A: Initial FFR+ Design” reasonably consider the four principles (i.e., technical feasibility, reliability, cost and fairness, efficiency and open competition) in the EUA (s. 17.1(2)) for procuring ancillary services and is it in the public interest? Please explain why the design does or does not appropriately balance the four principles. Is there a recommended change to this design that better balances the four principles and is in the public interest?   

2. Does the design of “Option B: Initial FFR+ Design Eligible for OR” reasonably consider the four principles in the EUA (s. 17.1(2)) for procuring ancillary services and is it in the public interest? Please explain why the design does or does not appropriately balance the four principles. Is there a recommended change to this design that better balances the four principles and is in the public interest?   

3. Does the design of “Option C: Market-Based Contracts for Uncommitted Capacity” reasonably consider the four principles in the EUA (s. 17.1(2)) for procuring ancillary services and is it in the public interest? Please explain why the design does or does not appropriately balance the four principles. Is there a recommended change to this design that better balances the four principles and is in the public interest?

4. Does the design of “Option D: Market-Based Contracts for All Capacity” reasonably consider the four principles in the EUA (s. 17.1(2)) for procuring ancillary services and is it in the public interest? Please explain why the design does or does not appropriately balance the four principles. Is there a recommended change to this design that better balances the four principles and is in the public interest?

Combination of FFR+ Contracts and Market-Based Contracts

5. Does a FFR program combining FFR+ Contracts (Option A or B) and Market-Based Contracts (Option C or D) reasonably consider the four principles in the EUA (s.17.1(2)) for procuring ancillary services and is it in the public interest? Please explain why combining FFR+ Contracts and Market-Based Contracts does or does not appropriately balance the four principles. Is there a recommended change to this design that better balances the four principles and is in the public interest?

FFR Market

6. Does proceeding directly to a FFR market reasonably consider the four principles in the EUA (s.17.1(2)) for procuring ancillary services and is it in the public interest?

7. Please explain why proceeding directly to a FFR market does or does not appropriately balance the four principles. What are some key features that should be considered in the design of a FFR market that balance the four principles and is in the public interest? 

8. Is there an alternative product design that you believe better balances the four principles in the EUA (s.17.1(2)) for procuring ancillary services and is in the public interest? Please describe your proposed alternative product design.

Preferred Product and Procurement Design

9. Which product and procurement design best balances the four principles in the EUA (s.17.2(s)) for procuring ancillary services and is in the public interest? Please select one or more boxes below with the option, or combination of options, that best achieve the objective.

• Option A: Initial FFR+ Design
• Option B: Initial FFR+ Design Eligible for Operating Reserves (OR)
• Option C: Market-Based Contracts for Uncommitted Capacity
• Option D: Market-Based Contracts for All Capacity
• FFR market
• Alternative product and procurement design

10. Please provide any additional comments to support your preferred product and procurement design, as applicable.