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.

Comment Period: August 25 to September 22, 2025

We value stakeholder input and invite stakeholders interested in participating in a Fast Frequency Response Plus (FFR+) procurement to provide their level of interest in each FFR product and procurement design discussed in 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(2)) 
• 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 FFR+ Rationale Document. An addendum to the Rationale Document includes alternative product and procurement designs that reflect the feedback received from industry to date.

Purpose

This round of written feedback will inform the level of interest and anticipated cost of each product and procurement design presented in the Rationale Document and addendum. An anonymized and aggregated summary of this 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 those industry stakeholders who are interested in participating in a procurement for FFR.

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 B: Expression of Interest in FFR Product and Procurement Designs; and
• Click on the "Submit Stakeholder Feedback" box below to upload your completed feedback form.
  
  

All responses to Part B will be summarized, aggregated and anonymized on AESO Engage and in the AESO’s application to the AUC. If you have any questions, please email ffrservices@aeso.ca.

All information provided through Part B will be treated as commercially sensitive and is non-binding.

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

Questions

Option A: Initial FFR+ Design

1. Are you interested in participating in a procurement for an FFR+ long-term (20-year) contract with a new asset where a final investment decision has not been made? If yes, please provide details on the asset(s) that may participate including the technology, configuration, connection type (transmission or distribution connected), maximum capability, location, estimated in-service date, project number, project name and connection stage (if applicable).

2. Which of the following best describes your pricing requirements for an availability payment to invest in a new FFR+ capable asset under a long-term (20-year) contract?

• Less than $10 per MWh (less than $83,220 per MW-year)
• $10 - $14.99 per MWh ($83,220 - $124,747 per MW-year)
• $15 - $19.99 per MWh ($124,830 - $166,357 per MW-year)
• $20 - $24.99 per MWh ($166,440 - $207,967 per MW-year)
• Greater than $25 per MWh (greater than $208,050 per MW-year)

Note: Revenues from annual availability payment assume an average 95% availability and 20-year contract. In addition, AESO has also proposed a monthly true-up payment to net energy revenues and charging costs to zero.

Please provide any key assumptions (e.g., government incentives, etc.) or comments regarding pricing requirements (if applicable).

3. Are you interested in participating in a procurement for an FFR+ medium-term (7-10-year) contract with either: 1) a new asset where a final investment decision has not been made, 2) an existing asset where a final investment decision has been made but has not achieved commercial operation, or 3) an asset currently in commercial operation? If yes, please provide details on the asset(s) that may participate including the technology, configuration, connection type (transmission or distribution connected), maximum capability, location, estimated in-service date, project number, project name and connection stage (if applicable).

4. Which of the following best describes your pricing requirements for an availability payment to invest in a new FFR+ capable asset or an existing FFR+ capable asset under a medium-term (7-10 year) contract?

• Less than $10 per MWh (less than $83,220 per MW-year)
• $10 - $19.99 per MWh ($83,220 - $166,357 per MW-year)
• $20 - $29.99 per MWh ($166,440 - $249,577 per MW-year)
• $30 - $39.99 per MWh ($249,660 - $332,797 per MW-year)
• Greater than $40 per MWh (greater than $332,880 per MW-year)

Note: revenues from annual availability payment assume an average 95% availability and 10-year contract. In addition, AESO has proposed a monthly true-up payment to net energy revenues and charging costs to zero.

Please provide any key assumptions (e.g., government incentives) or comments regarding pricing requirements (if applicable).

Option B: Initial FFR+ Design Eligible for Operating Reserves (OR)

This question is only applicable to those stakeholders who expressed an interest in Option A above.

5. To evaluate the merits of Option B where an FFR+ asset is eligible to participate in operating reserves, please describe how this may change your pricing requirements under a long-term (20-year) and medium-term (7-10 year) FFR+ contract and therefore does it change your response to questions 2 and 4. Note: FFR providers that are removed from the OR stack and armed for FFR would not be paid for providing OR but would be waived of any OR-related penalties.

Option C: Market-Based Contracts for Uncommitted Capacity

6. Are you interested in participating in a short-term market-based contract that is evergreen with an arming payment indexed to pool price for uncommitted capacity? If yes, please provide details on the existing asset(s) that may participate, including asset ID and anticipated bid volume into FFR. For new projects that have not started development or assets that are under development and have not achieved commercial operation, please include the technology, configuration, connection type (transmission or distribution connected), maximum capability, location, estimated in-service date, project number and project name (if applicable).

7. Which of the following best describes your anticipated FFR bid price for capacity that is uncommitted in operating reserves?

• Premium to pool price
• Pool price
• Pool price minus discount of $0.01 - $19.99 per MWh
• Pool price minus discount of $20 - $39.99 per MWh
• Pool price minus discount of $40 - $59.99 per MWh
• Pool price minus discount of $60 – 99.99 per MWh
• Pool price minus discount of $100 – 199.99 per MWh
• Pool price minus discount of $200 – 399.99 per MWh
• Pool price minus discount of $400 – 499.99 per MWh
• Pool price minus discount of $500 MWh or greater

Note: If a discount to pool price is bid, the arming payment is the greater of zero or pool price minus offered discount. There is no availability payment with this payment mechanism.  Stakeholders should assume a response payment of $3,000 per MW.

Please provide any key assumptions or comments regarding your anticipated bid price (if applicable).

Option D: Market-Based Contracts for All Capacity

8. Are you interested in participating in a short-term market-based contract that is evergreen with an arming payment indexed to pool price for all capacity? If yes, please provide details on the existing asset(s) that may participate, including asset ID and anticipated bid volume into FFR. For new projects that have not started development or assets that are under development and have not achieved commercial operation, please include the technology, configuration, connection type (transmission or distribution connected), maximum capability, location, estimated in-service date, project number and project name (if applicable).

9. Which of the following best describes your anticipated FFR bid price for all capacity? 

• Premium to pool price
• Pool price
• Pool price minus discount of $0.01 - $19.99 per MWh
• Pool price minus discount of $20 - $39.99 per MWh
• Pool price minus discount of $40 - $59.99 per MWh
• Pool price minus discount of $60 – 99.99 per MWh
• Pool price minus discount of $100 – 199.99 per MWh
• Pool price minus discount of $200 – 399.99 per MWh
• Pool price minus discount of $400 – 499.99 per MWh
• Pool price minus discount of $500 MWh or greater

Note 1: If a discount to pool price is bid, the arming payment is the greater of zero or pool price minus offered discount. There is no availability payment with this payment mechanism.  Stakeholders should assume a response payment of $3,000 per MW. Note 2: If capacity is removed from the OR stack and armed for FFR, the FFR service provider would be paid the greater of their FFR price or the price of the OR product that the provider has foregone.

Please provide any key assumptions or comments regarding your anticipated bid price (if applicable).

10. Is there a potential different utilization and sequencing for FFR arming than proposed in the addendum?  If so, describe this change.  How does your described change affect your interest in participating in a procurement for a short-term contract based on Option C or Option D (questions 6 and 8)? How would this impact your anticipated FFR bid price for Options C and D (questions 7 and 9)?

FFR Market

11. Are you interested in proceeding directly into a FFR market (without FFR+ Contracts or Market-Based Contracts)? If yes, please provide details on the existing asset(s) that may participate, including asset ID and anticipated offer volume into FFR. For new projects that have not started development or assets that are under development and have not achieved commercial operation, please include the technology, configuration, connection type (transmission or distribution connected), maximum capability, location, estimated in-service date, project number and project name (if applicable).