Purpose

On December 10, 2024, the AESO held its first Reliability Standards Workshop, focused on addressing initial stakeholder written feedback to the draft TPL and SOL Standards. During this session, the AESO provided responses to some of the comments received during the first round of written stakeholder feedback.

Some stakeholder comments required additional input from stakeholders and further internal AESO analysis. The AESO had follow-up questions at the December 10 Workshop to better understand stakeholders' concerns.

To continue obtaining feedback and provide stakeholders with additional time to consider the issues, the AESO is providing the questions posed during the December 10 Workshop, as well as additional follow-up questions, in a stakeholder survey.

AESO responses to stakeholder comments

The AESO will post all comments it receives, provide written responses, and post those responses on AESO Engage. For those comments that the AESO had initially identified as requiring additional consideration, the AESO will use the additional feedback and information gathered through this stakeholder survey to develop more comprehensive responses, and post them on AESO Engage.

The AESO values stakeholder feedback and invites all interested stakeholders to provide their comments via the Stakeholder Feedback Survey on or before February 4, 2025.

Instructions

1.  To submit your feedback, you will need to be registered and signed in on the AESO Engage platform.
2. Please click on the "Complete Stakeholder Feedback" box below to provide your specific comments.
3. Please submit one completed Stakeholder Feedback survey per organization.
4. Stakeholder Feedback results will be posted on AESO Engage, in their original state.
5. Responses due on or before February 4, 2025.

Stakeholder Questions:

1. Do you agree with the AESO’s proposed implementation timeline for newly designated lines in FAC-003-AB-5? If not, why not?
2. The AESO would like to better understand if Stakeholders are aware of any Alberta-specific factors that would result in the costs outweighing the reliability benefits of draft FAC-003-AB-5. If so, please specify and provide associated details.
3. Do you agree that “rate escalation” should be added to Requirement R7 of proposed new FAC-003-AB-5 as item 7.10?. If so, why? Please outline the benefit of adding this item.
4. Do you agree with the proposed updates to R8.A1 and R8.A2 of proposed new FAC-003-AB-5. If not, why not?
5. Which approach would you like the AESO to take with respect to the format of Table 1 of proposed new FAC-003-AB-5?
   1. Approach 1: Separate Tables – 1 for imperial and 1 for metric (for each AC and DC tables)
   2. Approach 2: Combined Tables – have imperial and metric in the same table (one for AC and one for DC)
   3. Approach 3: Continue to align with NERC (separate tables for AC, and combined for DC).
6. Do you agree with newly added Requirement R7 of proposed new FAC-014-AB-3. If not, why not?
7. Would you like the AESO to keep in alignment with NERC and leave Section 6.0 as it currently exists in proposed new IRO-008-AB-3. If not, why not?
8. Do you agree with newly added Requirements R5 and R6 of proposed new IRO-008-AB-3. If not, why not?
9. Do you believe the existing timeline set out in Requirement R13.1 of proposed new PRC-002-AB-4 of 3 calendar years is sufficient to implement sequence of event recording (“SER”) and Fault Recording (“FR”) data? If not, why not? Please provide your rationale and proposed alternate timeline.
10. Questions on re-evaluation list related to Requirement R1:
    1. Have you encountered an issue so far where there may not be enough time to install a new device (e.g., Transient Fault Recorder (“TFR”)). Please be specific on your response including location, root cause of the issue, and whether the need was identified due to your own re-evaluation or a notification received by another legal owner.
    2. Do you think your organization can align the timing of re-evaluation per Requirement R1.3 of proposed new PRC-002-AB-4, with your budget or General Tariff Application planning cycle, to account for the installation of a new device to meet PRC-002-AB-4 requirements in time? 
11. For Requirement R13.2 of proposed PRC-002-AB-4, do you believe that 3 calendar years is sufficient to implement Dynamic Disturbance Recording (“DDR”)? If not, please provide your rationale and proposed timeline.
12. Have you encountered an issue so far where there may not be enough time to install a new device, such as a TFR or digital relay capable of meeting PRC-002-AB-2 requirements, after you received the notification from the AESO Please be specific on your response including location and root cause of the issue.
13.  If the AESO requests you to stream the DDR data to the AESO per requirement R5.3A in proposed PRC-002-AB-4, do you believe that additional time may be required to account for data streaming? If yes, please provide your rationale and proposed timeline. As a guiding example, consider the elements that have been identified by the AESO under existing PRC-002-AB-2 and discuss how implementing streaming data for such elements would look like from the timeline perspective.
14. Do you have any additional feedback you would like to provide the AESO with respect to the impact of the emergency rating discrepancy and how these discrepancies are being addressed?
15. Questions on Load Forecasting:
    1. What are the challenges that you are facing regarding load forecasting?
    2. What are the potential solutions to those challenges?
    3. Where does the current load forecasting methodology need to be improved?
    4. What new methodology or tools are required?
16. Questions on Probabilistic Factors of Spare Strategy and Threshold for Outage Exclusion:
    1. What probabilistic factors do you consider when developing your spare strategy?
    2. What are the potential solutions to mitigate the risk associated with long lead time of transmission equipment?
    3. What are the factors that will impact the threshold for outage exclusion?
    4. How is the threshold for outage exclusion established?
17. Questions on Short Circuit Analysis and Corrective Action Plan (“CAP”) Development:
    1. How do you currently develop and maintain the short circuit model?
    2. What short circuit analysis method or software do you use?
    3. What short circuit analysis standard do you use?
    4. What design margin or assumptions do you use? 
18. Questions on Provision of protection system information:
    1. What relay loadabililty information is available?
    2. Do you have generic relay settings related to power swing that can be used to screen for power swings that will result in transmission element tripping?
19. Questions on Capital and O&M cost associated with implementation of TPL-001-AB-5.1:
    1. What is your current practice for managing ARS compliance related costs?
    2. Do you manage capital and O&M cost differently?
    3. Do costs associated with initial compliance expenditure versus costs associated with on-going compliance effort make a difference to you?
20. Do you see a discrepancy with the definition of the proposed new authoritative term “system voltage limit” and the use of this term in other AESO documents? If so, please specify.