Stakeholder Comment Matrix September 7, Proposed New ISO Rule Section 207.1, Gross Minimum Procurement Volume

Transcription

1 Sakeholder Commen Marix Sepember 7, 2018 Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume Period of Commen: Sepember 7, 2018 hrough Sepember 28, 2018 Conac: Ricardo Rangel Ruiz Commens From: Capial Power Phone: Dae [yyyy/mm/dd]: 2018/09/28 Please provide commens relaing o he subsecion of he proposed rule in he corresponding box. Please include any views on wheher he language clearly ariculaes he requiremen for eiher he AESO or a marke paricipan, and provide any proposed alernaive wording by blacklining he proposed language below. Applicabiliy 1 Secion applies o: (a) he ISO. Requiremens Gross Minimum Procuremen Volume 2 The ISO mus, for each base aucion and rebalancing aucion, esablish he gross minimum procuremen volume ha mees he resource adequacy sandard in accordance wih subsecions 3 and 4 below. Capial Power believes ha increased ransparency regarding load forecas and probabilisic modeling assumpions is required. Capial Power requess ha he daa used in he AESO s models be shared o sakeholders in advance of he forhcoming AUC proceedings o help accelerae he review and approval process. Firsly, he rule should require ha he ISO mus make is assumpions publicly available. Secondly, given he imporance of cerain assumpions, Capial Power requess ha some assumpions be mandaed direcly in he rule while an associaed informaion documen (ID) could lis more specifics abou addiional daa. Capial Power provides specific suggesions below in his documen. Given he imporance of cerain demand inpus, Capial Power s commens wih respec Issued for Sakeholder Commen: Sepember 7, 2018 Page 1 of 30 Public

2 Base Aucion Gross Minimum Procuremen Volumes for 2021/2022 and 2022/2023 Obligaion Periods o subsecion 5 provide specific suggesions regarding criical daa o be included in an appendix of he rule. 3 The ISO mus esablish he gross minimum procuremen volumes as follows: (a) 18,516 MW of maximum capabiliy for he base aucion for he 2021/2022 obligaion period based on he asses lised in Appendix A; and (b) 18,597 MW of maximum capabiliy for he base aucion for he 2022/2023 obligaion period based on he asses lised in Appendix B. Capial Power requess greaer clariy wih respec o he reamen of demand response on he demand and supply side o suppor he filed numbers. See below subsecions 4 and 5 below. Capial Power undersands ha he AESO is filing he 2022/23 gross minimum procuremen volume o comply wih AUC Rule 017 secion 13.2(k). However, i is no clear o sakeholders wheher he AESO will adjus he minimum procuremen volume prior o he publicaion of he Capaciy Marke Aucion Guidelines of he 2022/23 base aucion based on benefis of beer more up-o-dae informaion. While his number is wha is being proposed o be filed for AUC approval, i is no clear wheher i will remain unchanged for he 2022/23 base aucion wih poenial derimenal effecs. Capial Power s view is ha he 2022/23 should be updaed closer o he base aucion. The rule mus specify how and when he minimum procuremen volume and demand curve will be published for he rebalancing aucions. Probabilisic Model 4 (1) The ISO mus perform a probabilisic model of resource adequacy ha considers he following characerisics: (a) he load forecas referred o in subsecion 5; (b) (c) he available capabiliy or available generaion from all individual generaing unis and aggregaed generaing faciliies in Albera ha he ISO anicipaes will have, for he obligaion period, a: (i) maximum capabiliy greaer han or equal o 5 MW; or (ii) uniform capaciy value ha is greaer han or equal o 1 MW. hisorical ouages of hermal asses, including auomaic forced ouages, delayed forced ouages, planned ouages and ambien emperaure The rule mus include a backcas requiremen of a leas hree years for he purpose of calibraion and ensuring sakeholder confidence. Capial Power is concerned wih recen commens from sakeholders (Demand Curve Se 3 Session on Sep 13, 2018) regarding poor confidence in he AESO s model calibraion. As previously saed in Capial Power s commens during he CMD consulaion process, a way o address calibraion and confidence issues is by performing robus backcasing of he probabilisic model for a minimum of 3 hisorical years and ideally incorporae years where he sysem exhibied significan evens. The AESO s probabilisic model mus include demand response (DR) and his mus be refleced in subsecion 4. The AESO mus make reasonable assumpions regarding Issued for Sakeholder Commen: Sepember 7, 2018 Page 2 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

3 (d) (e) (f) (g) (h) (i) (j) deraes, and any projeced changes as applicable; hisorical performance of exising inermien resources, including wind and solar, and any projeced changes; anicipaed performance of new inermien resources, including wind and solar; hisorical performance of hydroelecric generaion and any projeced changes; hisorical performance of cogeneraion sies in Albera and any projeced changes; he correlaion of load and generaion a cogeneraion sies in Albera, as applicable; he available ransfer capabiliy and gross impor offers on he ineries; and capaciy o mainain regulaing reserve. DR for modeling compleeness, avoid double couning and miigae any risk of under or over procuremen. The AESO has indicaed during CMD consulaions and rule se 3 capaciy marke rule sakeholder session, ha he load forecas incorporaes price responsive load impacs. To he exen hese resources paricipae in he capaciy marke on he supply side, here is a risk of under-procuremen. In addiion, given heir cos srucure, crypocurrency mining load is anicipaed o paricipae as DR and like priceresponsive load, i mus be included as a resource on he supply side. 4 (2) The ISO mus, as applicable, make assumpions abou he model characerisics idenified in subsecion 4(1) in order o minimize model error and he risk of over procuring or under procuring capaciy o he exen pracicable. 4 (3) The ISO mus add or subrac capaciy from he probabilisic model referred o in subsecion 4(1) o deermine he gross minimum procuremen volume ha mees he resource adequacy sandard. The rule should also require he ISO o share he specific assumpions abou he model characerisics wih sakeholders. This will allow marke paricipans he abiliy o be able o properly assess he probabilisic model and procuremen amoun. To his effec, informaion documen (ID) should lis he assumpions ha he AESO will make available before he base and rebalancing aucions. Specific suggesions regarding minimum amoun of informaion o be provided is lised in he ID commen box a he end of his marix. This subsecion or an associaed ID mus clearly ouline how he ISO will add and subrac capaciy from he probabilisic model referred o in subsecion 4(1) o deermine he gross minimum procuremen volume. Aligning wih he characerisics of he reference echnology may be adequae when adding new capaciy bu i is oo vague when i comes o subracing from he exising flee. Load Forecas 5 The ISO mus, for he purpose of performing he probabilisic model in subsecion 4, complee a forecas of Albera gross load for a 5-year forward looking period, considering he following variables: The rule should clearly indicae a requiremen on he ISO o make a cerain level of informaion publicly available regarding he load forecas inpus and assumpions. The rule reference a minimum lis of criical variables ha will be made public, including: Issued for Sakeholder Commen: Sepember 7, 2018 Page 3 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

4 (a) (b) (c) (d) (e) (f) (g) economic growh indicaors in Albera including real gross domesic produc, populaion, employmen, and naural resource producion; weaher and emperaure daa seleced from muliple locaions across Albera; load variaions in Albera based on calendar variables, including monh of he year, day of he week, hour of he day, dayligh savings, and holidays; hisorical load behaviour in Albera and any projeced changes; performance daa from load asses ha are qualified o paricipae in he capaciy marke o provide demand response; load forecas uncerainy reflecing variabiliy in he load forecas due o weaher and economic forecass; and any oher variables ha, in he ISO s deerminaion, may maximize he performance of he load forecas model. GDP, populaion, employmen, naural resource producion and any oher key macroeconomic variable hisorical and forecas used for he developmen of he model and is resuls. Economic forecas uncerainy ranges Hisorical demand DR assumpions for asses ha qualify and asses ha do no qualify (e.g. curren price responsive load) and an explanaion of how hey are incorporaed in he load forecas Crypocurrency assumpions given heir likelihood o paricipae in DR Annual energy and monhly peak demand forecass The emperaure locaions and weighs applied o each locaion Currenly, marke paricipans do no have he majoriy of he above informaion regarding he load forecas used o derive he gross minimum procuremen volume saed in he rule. The rule indicaes ha he AESO will consider performance daa from load asses ha are qualified o paricipae in he capaciy marke o provide demand response. Given ha no DR asse has qualified, he AESO canno consider any DR in he load forecas according o he rule. However, during he CMD consulaions and Se 3 capaciy marke rule sakeholder session, he AESO indicaed ha price responsive load has been considered in he preparaion of he load forecas. The language in he rule omis his price responsive load, leading o confusion for sakeholders. In his subsecion 5, he rule mus include price responsive load as a consideraion o perform he load forecas. In an ID, he AESO mus explain he reamen of price responsive load, wheher i is adding or subracing o he forecas based on is hisorical behavior, o undersand is impac on he capaciy procuremen level and avoid any risk of over or under procuremen. The ID should also explain how he AESO will provide DR and price responsive load informaion before each main and rebalancing aucion. The rule mus specify ha he 5-year load forecas should be he same as he AESO s LTO and, in general, he same load forecass used for ransmission planning purposes. In he even here are variances wih oher forecass produced by he AESO, hese variances should be explained ogeher wih he issuance of he 5-year capaciy marke projecions. Issued for Sakeholder Commen: Sepember 7, 2018 Page 4 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

5 Filing of Base Aucion Gross Minimum Procuremen Volume 6 The ISO mus file he gross minimum procuremen volume for a base aucion deermined in accordance wih his secion wih he Commission for approval a minimum of 6 monhs prior o he publicaion of he Capaciy Marke Aucion Guidelines for he applicable base aucion. See Secion 3 above regarding commens for he 2022/23 gross minimum procuremen volume. The rule mus specify when procuremen volumes for he rebalancing aucions will be esablished. Togeher wih he rebalancing volumes, he assumpions and resuls of he load forecas, as well as, any updaes o he probabilisic model assumpion should be released. Applicable Aucions 7 This Secion is in effec for he following aucions: (a) (b) (c) (d) he base aucion and rebalancing aucion for he 2021/2022 obligaion period; he base aucion and rebalancing aucion for he 2022/2023 obligaion period; he base aucion and rebalancing aucion for he 2023/2024 obligaion period; and he base aucion and rebalancing aucions for he 2024/2025 obligaion period. Subjec o he AUC s furher consulaion and amendmens o AUC Rule 017 on applicaion of ISO rules ha perain o he demand curve and relaed elemens of he capaciy marke, he ISO rule should provide he governance framework and sakeholder consulaion process including imelines ha he AESO will follow o develop he subsequen se of rules. Also, subjec o he AUC Rule 017 amendmens, he ISO rules should specify he requiremens and process ha he AESO will follow o updae he load forecas, reliabiliy requiremen, ne-cone and demand curve beween each of he obligaion periods described in his Secion 7. The imelines, informaion o be disclosed by he AESO and engagemen process should be specified for main and rebalancing aucions. Issued for Sakeholder Commen: Sepember 7, 2018 Page 5 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

6 Please provide your commens on his rule s appendices: Appendices A and B should include reasonable assumpions of DR as saed in 4(1) above. Issued for Sakeholder Commen: Sepember 7, 2018 Page 6 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

7 Please provide your commens on he following (as se ou in AUC Rule 017 s. 13(b-j)): Iem # 1 wheher you agree ha he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume relaes o he capaciy marke and why or why no 2 wheher you agree ha he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume should [or should no] be in effec for a fixed erm and why or why no 3 wheher you undersand and agree wih he objecive or purpose of he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume and wheher, in your view, he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume mees he objecive or purpose 4 how, in your view, he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume affecs he performance of he capaciy marke and he elecriciy marke 5 your views on any analysis conduced or commissioned by he AESO supporing he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume 6 wheher you agree wih he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume aken ogeher wih all ISO rules and in ligh of he principle of a fair, efficien and openly compeiive marke Sakeholder commens Capial Power agrees ha he proposed rule relaes o he capaciy marke and is, generally, necessary o esablish he requiremens o mee he reliabiliy sandard as legislaed by he Governmen of Albera. Capial Power undersands ha he AESO s reliabiliy modeling is in early sages and ha, as a maer of common pracice, demand curves should generally be re-se every 3 or 4 years and herefore agrees wih he raionale for prescribing a fixed erm for he proposed rule as proposed in subsecion 7. Capial Power agrees wih he objecive or purpose of he proposed rule which i undersands as defining he gross minimum procuremen volume for he base aucions of he capaciy marke. Capial Power has no commens a his ime. Greaer ransparency and analysis around price responsive load and poenial fuure DR is missing. Capial has no commens a his ime. Issued for Sakeholder Commen: Sepember 7, 2018 Page 7 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

8 Iem # 7 wheher you would sugges any alernaives o he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume 8 wheher you agree ha he proposed provisional rule suppors ensuring a reliable supply of elecriciy a a reasonable cos o cusomers and why or why no 9 wheher you agree ha he proposed provisional rule suppors he public ineres and why or why no Sakeholder commens Greaer requiremens for ransparency and disclosure of assumpions and daa is needed in he rules and IDs for sakeholder o accep he filed gross minimum procuremen volumes. To ensure reliable supply of elecriciy as well as reasonable coss o cusomers, he rule mus reflec he proper reamen of and accouning for DR. However, hese aspecs are missing from he currenly proposed rule. Capial Power srongly recommends ha he rule be revised as proposed above. Lasly, o promoe ransparency, Capial Power encourages he AESO o develop deails in his regard in an associaed informaion documen as noed below. Capial Power has no commens a his ime. Issued for Sakeholder Commen: Sepember 7, 2018 Page 8 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

9 Please provide your views on he ype of conen ha should be included in an informaion documen associaed wih he proposed new ISO Rule Secion 207.1, Gross Minimum Procuremen Volume. ID s should be par of he soluion o make he reliabiliy modeling more ransparen for sakeholders o gain confidence in he AESO s resuls. The IDs should explain he mehodology bu should also lis he assumpions and daa ha perain o he load forecas and probabilisic model ha he AESO should make available before each main and rebalancing aucion. In addiion o he informaion provided in proposed ID Load Forecas and proposed ID Minimum Procuremen Volume, he AESO mus provide a lis of daa o be made available wih he release of he gross minimum procuremen volume. In addiion o he se of variables provided in commens o secion 5 above, such lis mus include: The weighs used by he AESO in calculaing he economic variable index applied o RQTOA, RHA and RLEMA and any oher variable o calculae such index Any oher consideraion and variable used by he AESO o minimize forecas error A reasonable represenaion of he final demand forecas model specificaion in formulaic form. This should clarify how he weighed index is ineraced wih calendar and emperaure variables Hisorical and forecas planned ouage raes by asse or a leas by echnology class Hisorical and forecas forced ouage raes by asse or a leas by echnology class Toal cogeneraion capaciy and specific asses included in he aggregae cogeneraion caegory How cogeneraion ouages (planned and forced) are considered or no in he aggregae cogeneraion caegory Manual scheduled planned ouages due o cogeneraion aggregaion Exreme, abnormal evens excluded from he analysis Temperaure derae curves applied o gas asses Hisorical and forecas available ransfer availabiliy for he ineries and addiional gross offers applied o he Saskachewan inerie Deails regarding DR. Sakeholders need ransparen undersanding of how price responsive load and any expeced DR are reaed in he demand forecas and he probabilisic model. The AESO should explain how he mehodology once all DR assumpions are aken ino accoun does no double coun any resources. An explanaion of he mehodology o add and subrac capaciy in he reliabiliy model o arrive a he resource adequacy sandard. Deails on how he AESO plans o align he concep of characerisics of reference echnology when subracing from he exising flee. An ID should delineae how he AESO will presen he resuls of he mos recen probabilisic model (RAM) backcass wih commenary ha explains how he analysis provides enough confidence on he model forward looking resuls. An ID should delineae he process, informaion o be disclosed by he AESO, consulaion and imelines o updae he rebalancing aucions parameers. Issued for Sakeholder Commen: Sepember 7, 2018 Page 9 of 30 Public Proposed New ISO Rule Secion 207.1, Gross Minimum Procuremen Volume

10 Sakeholder Commen Marix Sepember 7, 2018 Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE Period of Commen: Sepember 7, 2018 hrough Sepember 28, 2018 Conac: Ricardo Rangel Ruiz Commens From: Capial Power Phone: Dae [yyyy/mm/dd]: 2018/09/28 Please provide commens relaing o he subsecion of he proposed rule in he corresponding box. Please include any views on wheher he language clearly ariculaes he requiremen for eiher he AESO or a marke paricipan, and provide any proposed alernaive wording by blacklining he proposed language below. Applicabiliy Secion applies o: (a) Requiremens he ISO. Esablish Gross-CONE, Energy and Ancillary Services Offse and Ne-CONE 2 The ISO mus esablish for each obligaion period: (a) (b) a gross-cone value in $/kw-year in accordance wih subsecions 3 and 4, as applicable; an energy and ancillary services offse value in $/kw-year in accordance wih subsecion 5; and The rule mus specify ha he AESO mus define wha gross-cone and Ne-CONE values are inended o represen. For example, a levelized value in fuure dollars ha represens annual ne revenues ha a new generaion resource needs o earn o recover is capial invesmen and fixed coss, given reasonable expecaions abou fuure cos recovery over is economic life. Currenly, he Brale repor does provide enough characerizaion of is gross-cone. However, given he seleced mehodology, i is unclear o sakeholders wha he ne-cone value represens, if i is consisen wih Brale s nominal levelized approach, and why i does no seem o represen an expecaion abou fuure cos recovery over he economic life of he asse (given consideraion o only one year). The rule mus specify ha he AESO will esablish a gross-cone value based on a sudy performed by independen and credible consulan. Even hough his is already he case, i should be included o se a preceden for he developmen of fuure CONE values. Issued for Sakeholder Commen: Sepember 7, 2018 Page 10 of 30 Public

11 (c) a ne-cone value in $/kw-year in accordance wih subsecion 6. Iniial Gross-CONE Value for 2021/2022 Obligaion Period The ISO mus esablish an iniial gross-cone value for he 2021/2022 obligaion period of $244.2/kW-year. Capial Power suppors he AESO s selecion of reference echnology ha bes fis he unique aspec of he Albera marke, being one of he mos economic, frequenly developed, and a echnology ha does no impede oher echnologies from compeing in he marke. Calculaion of Gross-CONE 4 (1) The ISO mus calculae he gross-cone value for every obligaion period following he 2021/2022 obligaion period in accordance wih he following formula: where: gross-cone = gross-cone =2021/2022 Composie Index (i) equals he obligaion period for which he gross-cone is being deermined; (ii) gross-cone is he gross-cone value for obligaion period ; (iii) gross-cone =2021/2022 is he iniial gross-cone value in subsecion 3 above; and (iv) Composie Index is he composie index value for obligaion period calculaed in accordance wih subsecion 4(2) below. 4 (2) The ISO mus, in calculaing he gross-cone value under subsecion 4(1) above, calculae he Composie Index using he following formula: Composie Index = 0.25 Labour Index Maerials Index Turbine US Cos Index Foreign Exchange Rae where: In he calculaion of gross-cone, Brale correcly recognizes ha developers will hedge he exchange rae for purposes of purchasing urbines and furher assumes ha developers will make paymens over a period of one year. Recognizing ha developers will purchase he urbines in he fuure and ha hey will hedge hese coss o he exen possible, i does no make sense for he composie index o updae he exchange rae assumpion wih hisorical exchange raes bu insead and o mainain consisency wih he iniial CONE esimae, he composie index should use he Forward exchange rae. Issued for Sakeholder Commen: Sepember 7, 2018 Page 11 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

12 (i) equals he obligaion period for which he gross-cone value is being deermined; (ii) Composie Index is he composie index value for obligaion period ; (iii) Labour Index is he mos recen 12 monh average of published Saisics Canada Consrucion Union Wage Raes (Elecrician), Monhly for Edmonon Albera, Table ; (iv) Maerials Index is he mos recenly published Saisics Canada Gross Naional and Gross Domesic Income, Indexes and Relaed Saisics, Annual, Table ; (v) Turbine US Cos Index is he mos recen 12 monh average of published Federal Reserve Economic Daa (S. Louis) Producer Price Index by Indusry: Turbine and Turbine Generaor Se Unis Manufacuring (PCU ); and (vi) USD/CAD Foreign Exchange Rae is he mos recen 12 monh average of published Saisics Canada Monhly Average Exchange Raes in Canadian Dollars, U.S. Dollar monhly average, Table Calculaion of Energy and Ancillary Services Offse 5 (1) The ISO mus, for every obligaion period, calculae he energy and ancillary services offse value in accordance wih he following formula: EAS Offse = (Forward Power Price Energy Marke Expense ) Forward Produc Energy Nameplae Capaciy 1000 where; (i) equals he obligaion period for which he energy and ancillary services offse is being deermined; (ii) EAS Offse is he energy and ancillary services offse for obligaion period ; (iii) Forward Power Price is he weighed average of he selemens Greaer clariy and consisency is necessary o undersand ne-cone. Conrary o CONE, ne-cone is no a levelized figure. I does no recognize increases or decreases in energy marke revenue poenial as he Albera flee changes over ime. I does no recognize ha new generaion may need higher capaciy revenues oday due o lower energy prices in he fuure or lower on-peak/off-peak spreads. An accoun of how he ne- CONE mehodology aligns wih he gross-cone mehodology in he conex of levelizing coss should be provided. The rule should specify ha he AESO mus provide in an ID greaer clariy regarding he crieria o be used in he selecion of Forward selemens. If a specific period canno be provided, he AESO mus provide he guidelines and crieria ha i will use in selecing a represenaive selemen period. In addiion, o avoid poenially unrepresenaive price samples, Capial Power suggess ha incorporaing a raded- Issued for Sakeholder Commen: Sepember 7, 2018 Page 12 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

13 maching he obligaion period, where he selemens are he average over a period deermined by he ISO, for he published NGX forward power produc in Appendix 1 ha yields he highes EAS Offse for obligaion period ; (iv) Energy Marke Expense is he energy marke expense value for obligaion period calculaed in accordance wih subsecion 5(3) below; (v) Forward Produc Energy is he forward produc energy value for obligaion period calculaed in accordance wih subsecion 5(2) below; and (vi) Nameplae Capaciy is equal o 93 MW. volume crieria a minimum bid ask spread for a minimum duraion posed on a recognized exchange or via broker could also suffice and, in some cases, may be more appropriae. Capial Power believes ha subsecion 5(1)(iii) may be prone o confusion as i may give he false impression ha he AESO will selec he Forward selemen average ha maximizes EAS offses. I is Capial Power s undersanding ha his is no he inenion. The AESO should consider separaing he selecion of produc argumen from he selecion of selemens argumen. The AESO mus ensure ha he reamen of axes in he E&AS offse is consisen wih he reamen used by Brale in he gross-cone calculaion. The Brale repor (p. 45) recognizes ha corporae income ax raes affec boh he cos of capial and cash flows in he financial model used o calculae CONE. I appears ha income axes are missing in he E&AS model. 5 (2) The ISO mus, in calculaing he EAS Offse under subsecion 5(1) above, calculae he Forward Produc Energy using he following formula: Forward Produc Energy = Average Capaciy (1 Forced Ouage Rae) Forward Produc Hours where: (i) equals he obligaion period for which he generaion is being deermined; (ii) Average Capaciy is equal o 87 MW; (iii) Forced Ouage Rae is equal o 3.0%; and (iv) Forward Produc Hours is he number of hours defined in he ICE NGX Conracing Pary Agreemen for he forward power produc associaed wih he Forward Power Price in subsecion 5(1)(iii) above, for obligaion period. Furher o he above commens, if he Ne-CONE measure is ruly mean o represen only he firs year of operaion, he forced ouage rae should be adjused up for ypically higher expeced ouages in ha firs year. However, Capial Power suggess ha ne- CONE should represen an average operaing year, as developers make invesmens for he economic life of asses. As such, he AESO should include an allowance for planned ouages in he forward produc energy calculaion. Issued for Sakeholder Commen: Sepember 7, 2018 Page 13 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

14 5 (3) The ISO mus, in calculaing he EAS Offse under subsecion 5(1) above, calculae he Energy Marke Expense using he following formula: Capial Power submis ha he energy marke rading charge should be escalaed by inflaion given he high likelihood ha he figure will be periodically updaed before he delivery year. Energy Marke Expense = [Forward Gas Price + (1 + Commodiy Fuel Charge )] Hea Rae + Variable Operaions and Mainenance + (Emission Inensiy Esablished Benchmark ) Carbon Price + Transmission Losses + Trading Charge where; (i) equals he obligaion period for which he energy and ancillary services offse is being deermined; (ii) Energy Marke Expense is he energy marke expense value for obligaion period ; (iii) Forward Gas Price is he weighed average of he selemens maching he obligaion period, where he selemens are he average over he period deermined by he ISO in subsecion 5(1)(iii), of NGX Phys, FP (CA/GJ), AB-NIT; (iv) Commodiy Fuel Charge is he mos recen 12 monh average of published NOVA Gas Transmission Ld NGTL Fuel Usage and Measuremen Variance; (v) Hea Rae is equal o GJ/MWh; (vi) Variable Operaions and Mainenance is he variable operaions and mainenance value for obligaion period calculaed in accordance wih subsecion 5(4) below; (vii) Emission Inensiy is equal o 0.50 onnes of CO2/MWh; (viii)esablished Benchmark is he weighed average of he calendar year values maching obligaion period for an esablished benchmark for elecriciy published by a public auhoriy; (ix) Carbon Price is he weighed average of he calendar year values Issued for Sakeholder Commen: Sepember 7, 2018 Page 14 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

15 maching obligaion period for he carbon price published by a public auhoriy; (x) Transmission Losses is he ransmission loss value for obligaion period calculaed in accordance wih subsecion 5(5) below; and (xi) Energy Marke Trading Charge is he mos recen energy marke rading charge published on he AESO websie. 5 (4) The ISO mus, in calculaing he Energy Marke Expense under subsecion 5(3) above, calculae he Variable Operaions and Mainenance value using he following formula: Variable Operaions and Mainenance = Variable Operaions and Mainenance =2021/2022 Maerials Index where: (i) equals he obligaion period for which he variable operaions and mainenance is being deermined; (ii) Variable Operaions and Mainenance =2021/2022 is equal o $4.60/ MWh; and (iii) Maerials Index for obligaion period is he value in subsecion 4(2)(a)(iv) above. 5 (5) The ISO mus, in calculaing he Energy Marke Expense under subsecion 5(2) above, calculae he Transmission Losses value using he following formula: Transmission Losses = where: n i=1 Loss Facor i Forward Power Price n (i) equals he obligaion period for which he ransmission losses is being deermined; (ii) i n are faciliies locaed in he For Saskachewan area idenified in he mos recen Loss Facors published on he AESO websie; The variable operaions and mainenance expense mus be adjused o he selecion of Forward ype. The AESO mus consider in is variable operaing and mainenance charge ha $4.60/MWh is based on baseload operaions and ha in he even ha he AESO swiches o on-peak or supper-peak forwards and forward energy, he mainenance charge may very likely become a funcion of sars and operaing coss should be adjused accordingly. Issued for Sakeholder Commen: Sepember 7, 2018 Page 15 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

16 (iii) Loss Facor i is he mos recen published loss facor values published on he AESO websie; and (iv) Forward Power Price for obligaion period is he value in subsecion 5(1)(a)(iii) above. Calculaion of Ne-CONE 6 (1) The ISO mus, subjec o subsecion 6(2), calculae he ne-cone value for every obligaion period in accordance wih he following formula: where: ne-cone = gross-cone EAS Offse (i) equals he obligaion period for which he ne-cone value is being deermined; (ii) gross-cone is he gross-cone value in subsecion 3 above or he gross- CONE value calculaed in accordance wih subsecion 4 above for he obligaion period, as applicable; and (iii) EAS Offse is energy and ancillary services offse value calculaed in accordance wih subsecion 5 above for obligaion period. 6 (2) The ISO mus, if he ne-cone value calculaed in subsecion 6(1) is: (a) (b) below zero, se he ne-cone value a zero. above he gross-cone value in subsecion 3 or 4, se he ne-cone value a he gross-cone value Publicaion of Ne-CONE, Daa and Indices 7 The ISO mus, publish he ne-cone value deermined in accordance wih his secion and he following daa and indices in he Capaciy Marke Aucion Guidelines for each base aucion and rebalancing aucion: (a) Composie Index =2021/2022 ; The combined federal and provincial corporae income ax rae may be missing if included in he calculaion of E&AS. (b) Composie Index ; Issued for Sakeholder Commen: Sepember 7, 2018 Page 16 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

17 (c) Labour Index ; (d) Maerial Index ; (e) Turbine US Cos Index ; (f) USD/CAD Foreign Exchange Rae ; (g) Energy Marke Expense ; (h) Forward Power Price ; (i) Forward Produc Hours ; (j) Forward Produc Energy ; (k) The period deermined by ISO refer o in subsecions 5(1)(iii), 5(2)(iv) and 5(3)(iii) ; (l) Forward Gas Price ; (m) Commodiy Fuel Charge ; (n) (o) Variable Operaions and Mainenance ; (o) (p) Emission Inensiy; (p) Esablished Benchmark ; (q) Carbon Price ; (r) Transmission Losses ; (s) () Loss Facor i ; and Trading Charge Subsiue Index or Benchmark 9 The ISO mus, if any of he indices or benchmarks referred o in his secion are unavailable or no applicable for use in he calculaion of he ne-cone value, use anoher comparable indusry index or benchmark and publish he index or benchmark in he Capaciy Marke Aucion Guidelines for each base aucion and rebalancing aucion. Issued for Sakeholder Commen: Sepember 7, 2018 Page 17 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

18 Applicable Aucions 10 This Secion is in effec for he following aucions: (a) (a) (a) (a) he base aucion and rebalancing aucion for he 2021/2022 obligaion period; he base aucion and rebalancing aucion for he 2022/2023 obligaion period; he base aucion and rebalancing aucion for he 2023/2024 obligaion period; and he base aucion and rebalancing aucions for he 2024/2025 obligaion period. Subjec o he AUC s furher consulaion and amendmens o AUC Rule 017 on applicaion of ISO rules ha perain o he demand curve and relaed elemens of he capaciy marke, he rule should provide he governance framework and sakeholder consulaion process including imelines ha he AESO will follow o develop he subsequen se of rules. Also, subjec o he AUC Rule 017 amendmens, he AESO rules should specify he requiremens and process ha he AESO will follow o updae he load forecas, reliabiliy requiremen, ne-cone and demand curve beween each of he obligaion periods described in his Secion 7. The imelines, informaion o be disclosed by he AESO and engagemen process should be specified for main and rebalancing aucions. Issued for Sakeholder Commen: Sepember 7, 2018 Page 18 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

19 Please provide your commens on his rule s appendices: Issued for Sakeholder Commen: Sepember 7, 2018 Page 19 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

20 Please provide your commens on he following (as se ou in AUC Rule 017 s. 13(b-j)): Iem # 1 wheher you agree ha he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE relaes o he capaciy marke and why or why no 2 wheher you agree ha he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE should [or should no] be in effec for a fixed erm and why or why no 3 wheher you undersand and agree wih he objecive or purpose of he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE and wheher, in your view, he proposed new ISO Rule Secion 207.2, Calculaion of Ne- CONE mees he objecive or purpose 4 how, in your view, he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE affecs he performance of he capaciy marke and he elecriciy marke 5 your views on any analysis conduced or commissioned by he AESO supporing he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE 6 wheher you agree wih he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE aken ogeher wih all ISO rules and in ligh of he principle of a fair, efficien and openly compeiive marke 7 wheher you would sugges any alernaives o he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE Sakeholder commens Capial Power agrees ha he proposed rule relaes o he capaciy marke and, in general, is necessary o deermine he ne-cone. Capial Power undersands ha CONE, ne-cone and he demand curve are proposed o be re-se every 3 or 4 years and herefore agrees wih he raionale for prescribing a fixed erm for he proposed rule as proposed in subsecion 7. Capial Power has no commen a his ime. The proposed E&AS mehodology may be prone o volailiy and adversely affec invesor confidence and he performance of he capaciy marke. Limied Forward marke liquidiy hree or more years ou suggess ha forward prices can change drasically from he ne-cone calculaion o delivery period and from aucion o aucion, no o menion ha Forwards are more volaile relaive o fundamenal forecass. The fac ha he ype of Forward curve (fla, on-peak, supper-peak) ha maximizes E&AS value can change from one aucion o he nex, furher increases he uncerainy around Ne-CONE, inflicing furher damage on markes performance. There is lack of analysis ha suppors he E&AS offse mehodology. The approach resuls in unrealisic operaions and capaciy facors. Furhermore, he resuling ne-cone does no represen he levelized missing money over he life of he asse. The mehodology fails o accoun for changes in energy revenue poenial as he Albera flee changes and movemens in energy prices over ime. Capial Power has no commen a his ime. The E&AS mehodology would be concepually sronger if i was complemened wih simulaions since i could (depending on how i is implemened) acually represen he levelized coss of enry. The simulaion approach would limi poenial E&AS volailiy and anchor he resuls closer o realisic operaions. Issued for Sakeholder Commen: Sepember 7, 2018 Page 20 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

21 Iem # 8 wheher you agree ha he proposed provisional rule suppors ensuring a reliable supply of elecriciy a a reasonable cos o cusomers and why or why no 9 wheher you agree ha he proposed provisional rule suppors he public ineres and why or why no Sakeholder commens Capial Power has reservaions regarding he E&AS calculaion and he financial assumpion used by Brale ha may affec ensuring a reliable supply of elecriciy a a reasonable cos o cusomers. On he oher hand, he proposed aeroderivaive echnology suppors he enry of resources ha beer fi he unique naure of he Albera marke and beer address he uncerainy around he acual unis ha will ge buil in he fuure. Imporanly, he selecion of aeroderivaive allows a greaer se of resources o compee, reduces he risk of marke failure and poor reliabiliy risk. In addiion, i allows reasonable prices o be achieved hrough compeiion. Capial Power has no commens a his ime. Issued for Sakeholder Commen: Sepember 7, 2018 Page 21 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

22 Please provide your views on he ype of conen ha should be included in an informaion documen associaed wih he proposed new ISO Rule Secion 207.2, Calculaion of Ne-CONE. If no included in he rule, he AESO s crieria o deermine he se of Forward selemens, including hings like exclusion of ouliers and mehodology o assign weighs. The AESO s definiion of ne-cone and an explanaion of how he ne-cone mehodology conforms o he CONE mehodology laid ou by Brale. The spreadshees or models used o calculae he EA&S. Issued for Sakeholder Commen: Sepember 7, 2018 Page 22 of 30 Public Proposed New ISO Rule Secion 207.2, Calculaion of Ne-CONE

23 Sakeholder Commen Marix Sepember 7, 2018 Proposed New ISO Rule Secion 207.3, Shape of Demand Curve Period of Commen: Sepember 7, 2018 hrough Sepember 28, 2018 Conac: Ricardo Rangel Ruiz Commens From: Capial Power Phone: Dae [yyyy/mm/dd]: 2018/09/28 Please provide commens relaing o he subsecion of he proposed rule in he corresponding box. Please include any views on wheher he language clearly ariculaes he requiremen for eiher he AESO or a marke paricipan, and provide any proposed alernaive wording by blacklining he proposed language below. Applicabiliy Secion applies o: (a) he ISO. Requiremens Esablish Preliminary Demand Curve 2 (1) The ISO mus, for he purpose of esablishing a preliminary demand curve in accordance wih subsecion 2(2), esimae he ne minimum procuremen volume in subsecion 3 below based on he mos recen uniform capaciy values calculad by he ISO in accordance wih Secion of he ISO rules, Uniform Capaciy Value Deerminaion 2 (2) The ISO mus, for each base aucion and rebalancing aucion, esablish a preliminary downward-sloping convex demand curve wih he following: (a) (b) a horizonal secion from 0 MW o he esimae of he ne minimum procuremen volume in subsecion 2(1), a a price cap ha is he greaer of: (i) 1.75 imes he adjused ne-cone in subsecion 4; or (ii) 0.5 imes gross-cone esablished in accordance wih Secion of he ISO rules, Calculaion of Ne-CONE divided by 0.8; a downward-sloping secion from he esimae of he ne minimum As commened above regarding procuremen volumes, he rules mus specify when he demand curve adjused for updaed volumes will be published for purposes of he rebalancing aucions. As can be inferred from CMD Final and he las se of maerials presened by Brale on June 14, 2018, Brale performed all he demand curve performance analysis based on gross capaciy and more specifically before neing ou self-supply and REP volumes. I is unclear if i was done before or afer convering oher asses MCs o uniform capaciy. Based on he demand rule as wrien, he demand curve can change drasically depending on he amoun of self-supply and final uniform capaciy seleced by marke paricipans (he laer wihin minimum and maximum ranges provided by he AESO). Brale s analysis shows a demand curve wih a widh (max min volumes) of around 2000 UCAP MW, while a demand curve ha nes ou he expeced self-supply and REP as repored by he AESO, resuls in a demand curve widh of abou 1600 UCAP MW. Issued for Sakeholder Commen: Sepember 7, 2018 Page 23 of 30 Public

24 (c) procuremen volume in subsecion 2(1) a he price cap in subsecion 2(2)(a) o an inflecion poin se a a mulipler of imes he adjused ne-cone in subsecion 4 below a a quaniy 7% above he esimae of he ne minimum procuremen volume; and a downward sloping secion from he inflecion poin in 2(1)(b) o a price floor of zero dollars a a quaniy 18% above he esimae of he ne minimum procuremen volume. Once convered o MC, his UCAP difference amouns o a significan 500 MW in widh difference. The widh and consequenly he shape are also a he mercy of wheher marke paricipans choose uniform capaciies generally a he upper or lower ranges o be provided by he AESO. Consequences: Alhough Capial Power does no agree wih Brale s uning mehodology of he demand curve and hinks ha he risk of under-procuremen is oversaed in heir analysis. Brale and he AESO have no proven ha he gross analysis yields he same resuls afer neing self-supply and REP, ha he differen widh demand curves will yield he same reliabiliy resuls of breaching he minimum reliabiliy requiremen of % EUE 5% of he ime. The RAM, as well as Brale analyses have been performed for he enire Albera sysem and i is difficul o undersand how he sysem s reliabiliy is no affeced by compleely differen procuremen levels -as porrayed by differen demand curve shapes- when simply changing how on-sie supply decides o paricipae in he marke and he final uniform capaciies chosen by marke paricipans. Furher explanaion from he AESO is required. Since nobody knows how much onsie generaion will selec self-supply and wha final uniform capaciies will be seleced, sakeholders canno asses he likely demand curve. A he exremes, one demand curve may sugges overprocuremen while anoher one under-procuremen. One way o overcome he poenial errors in ranslaing he Brale analysis and he uncerainy around he demand curve is o no ne ou self-supply and REP from he demand curve bu o add heir volumes a a zero price on he supply side. Depending on how Brale performed is iniial analysis, an adjusmen for discrepancies in selecion of uniform capaciies may be done on he supply side if a all required. 2 (3) The ISO mus publish he preliminary demand curve in he Capaciy Marke Aucion Guidelines for he relevan base aucion or rebalancing aucion. See commens in secion 2(2) above. Ne Minimum Procuremen Volume 3 The ISO mus, afer uniform capaciy values are assigned in accordance wih Secion The rule should specify ha he AESO should perform analysis ha demonsraes of he ISO rules, Uniform Capaciy Value Deerminaion, adjus he gross minimum fungibiliy among UCAPs of differen asses as i relaes o heir conribuion o reliabiliy in Issued for Sakeholder Commen: Sepember 7, 2018 Page 24 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve

25 procuremen volume esablished for each base aucion or rebalancing aucion in accordance wih Secion of he ISO rules, Gross Minimum Procuremen Volume o a ne minimum procuremen volume using he following formula: where: Ne minimum procuremen volume = UCAP Acual(i) (i) is he obligaion period for he base aucion or rebalancing aucion ha he gross minimum procuremen volume was esablished for; (ii) i n are all he asses modelled in he probabilisic model ha esablished he gross minimum procuremen volume for he obligaion period; (iii) UCAP Acual(i) is he final uniform capaciy value deermined in accordance wih Secion of he ISO rules, Uniform Capaciy Value Deerminaion for such asse or he mos recen esimae of he uniform capaciy value for such asse; n i he RAM model o ensure fairness and for he addiive funcion in his secion 3 o be valid. Adjused Ne-CONE The ISO mus, using he following formula, adjus he ne-cone esablished for each obligaion period in accordance wih Secion of he ISO rules, Calculaion of Ne- CONE: Since he performance facor of he reference echnology is expeced o change over ime, he rule should reference he performance facor insead of referencing 0.8 o avoid under or over-procuremen in any deliverabiliy period. where; Adjused ne-cone = ne-cone 0.8 (i) equals he obligaion period for which he adjused ne-cone value is being deermined; and (ii) ne-cone is ne-cone value esablished in accordance wih Secion of he ISO rules, Calculaion of Ne-CONE in $/kw-year. Esablish Final Demand Curve for Base Aucion and Rebalancing Aucion 5 (1) The ISO mus, for each base aucion and rebalancing aucion, esablish a final See commens in secion 2(2) above. Issued for Sakeholder Commen: Sepember 7, 2018 Page 25 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve

26 downward-sloping convex demand curve wih he following: (a) a horizonal secion from 0 MW o he ne minimum procuremen volume in subsecion 3, a a price cap ha is he greaer of: (i) 1.75 imes he adjused ne-cone in subsecion 4; or (j) 0.5 imes gross-cone esablished in accordance wih Secion of he ISO rules, Calculaion of Ne-CONE divided by 0.8; (b) (c) a downward-sloping secion from he ne minimum procuremen volume in subsecion 3 a he price cap in subsecion 5(1)(a) o an inflecion poin se a a mulipler of imes he adjused ne-cone in subsecion 4 below a a quaniy 7% above he ne minimum procuremen volume;and a downward sloping secion from he inflecion poin in 5(1)(b) o a price floor of zero dollars a a quaniy 18% above he ne minimum procuremen volume in subsecion 3 below. 5 (2) The ISO mus publish he final demand curve prior o he opening of he offering window for each base aucion or rebalancing aucion. More deailed should be indicaed of wha prior means. A reasonable amoun of ime should be provided for marke paricipans o prepare heir analyses before he sar of he aucion. Capial power suggess ha he demand curve should be published wo monhs before he offering window. Applicable Aucions 6 This Secion is in effec for he following aucions: (a) (b) he base aucion and rebalancing aucion for he 2021/2022 obligaion period; he base aucion and rebalancing aucion for he 2022/2023 obligaion period; Subjec o he AUC s furher consulaion and amendmens o AUC Rule 017 on applicaion of ISO rules ha perain o he demand curve and relaed elemens of he capaciy marke, he rule should provide he governance framework and sakeholder consulaion process including imelines ha he AESO will follow o develop he subsequen se of rules. (c) (d) he base aucion and rebalancing aucion for he 2023/2024 obligaion period; and he base aucion and rebalancing aucions for he 2024/2025 obligaion period. Also, subjec o he AUC Rule 017 amendmens, he ISO rules should specify he requiremens and process ha he AESO will follow o updae he load forecas, reliabiliy requiremen, ne-cone and demand curve beween each of he obligaion periods described in his subsecion 7. The imelines, informaion o be disclosed by he AESO and engagemen process should be specified for he main and rebalancing aucions. Issued for Sakeholder Commen: Sepember 7, 2018 Page 26 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve

27 Issued for Sakeholder Commen: Sepember 7, 2018 Page 27 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve

28 Please provide your commens on he following (as se ou in AUC Rule 017 s. 13(b-j)): Iem # 1 wheher you agree ha he proposed new ISO Rule Secion 207.3, Shape of Demand Curve relaes o he capaciy marke and why or why no 2 wheher you agree ha he proposed new ISO Rule Secion 207.3, Shape of Demand Curve should [or should no] be in effec for a fixed erm and why or why no 3 wheher you undersand and agree wih he objecive or purpose of he proposed new ISO Rule Secion 207.3, Shape of Demand Curve and wheher, in your view, he proposed new ISO Rule Secion 207.3, Shape of Demand Curve mees he objecive or purpose 4 how, in your view, he proposed new ISO Rule Secion 207.3, Shape of Demand Curve affecs he performance of he capaciy marke and he elecriciy marke 5 your views on any analysis conduced or commissioned by he AESO supporing he proposed new ISO Rule Secion 207.3, Shape of Demand Curve 6 wheher you agree wih he proposed new ISO Rule Secion 207.3, Shape of Demand Curve aken ogeher wih all ISO rules and in ligh of he principle of a fair, efficien and openly compeiive marke Sakeholder commens Capial Power agrees ha he proposed rule relaes o he capaciy marke and, in general, is necessary o deermine he appropriae shape of he demand curve. Capial Power undersands ha CONE, ne-cone and he demand curve are proposed o be re-se every 3 or 4 years and herefore agrees wih he raionale for prescribing a fixed erm for he proposed rule as proposed in subsecion 7. Capial Power agrees wih he overall objecive or purpose of he proposed rule which i undersands as defining he shape of he demand curve. However, he specific objecive of convering he gross minimum procuremen volume o ne minimum procuremen volume is no proven o be achieved according o unis of capaciy ha are equivalen or fungible. The performance of he demand curve in erms of reliabiliy is subjec o he amoun of load ha chooses self-supply and final chosen levels of uniform capaciy, as differen choices of self-supply and uniform capaciy will resul in differen amouns of oal capaciy demanded for he sysem as a whole. If differen levels of self-supply require differen levels of procuremen, i follows ha differen levels of self-supply should have been modeled in he reliabiliy (RAM) and Brale s demand simulaions, somehing ha was no underaken. In addiion, here would be no reason for increasing or decreasing oal demand due o marke paricipans selecing generally higher or lower uniform capaciies. One way of avoiding affecing he performance of he demand curve as modeled by Brale is o adjus self-supply and REP volumes on he supply side. Analysis is lacking ha proves fungibiliy of UCAP among differen resources. I is unclear wheher a MW of UCAP is equivalen across asses or even across echnology ypes, somehing ha, in principle and for fairness, he AESO should be sriving for. The AESO should validae he consisency of he conribuion of asses o reliabiliy beween he RAM model and he assigned UCAP in Secion of he ISO rules. To he exen ha UCAP is no ruly a fungible produc, somehing ha has no ye been proven, he capaciy marke will lack fairness. Issued for Sakeholder Commen: Sepember 7, 2018 Page 28 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve

29 Iem # 7 wheher you would sugges any alernaives o he proposed new ISO Rule Secion 207.3, Shape of Demand Curve Sakeholder commens See Capial Power s commens above. 8 wheher you agree ha he proposed provisional rule suppors ensuring a reliable supply of elecriciy a a reasonable cos o cusomers and why or why no 9 wheher you agree ha he proposed provisional rule suppors he public ineres and why or why no The uncerainy posed by differen self-supply and uniform capaciy oped levels on he shape of he demand curve makes i difficul for sakeholders o assess wheher he rule suppors reliable supply of elecriciy a a reasonable cos. Capial Power has no commens a his ime. Issued for Sakeholder Commen: Sepember 7, 2018 Page 29 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve

30 Please provide your views on he ype of conen ha should be included in an informaion documen associaed wih he proposed new ISO Rule Secion 207.3, Shape of Demand Curve. The range of possible demand curves ha can be derived according o differen chosen levels of self-supply and uniform capaciies, including Brale s curve. An analysis ha explains how he differen curves achieve he same reliabiliy performance. An ID ha specifies how he AESO will perform analyses ha proves fungibiliy among UCAPs of differen asses as i relaes o heir conribuion o reliabiliy in he RAM model for he formula presened in Secion 3 o be valid. Issued for Sakeholder Commen: Sepember 7, 2018 Page 30 of 30 Public Proposed New ISO Rule Secion 207.3, Shape of Demand Curve