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    BTF Process Changes

    This page is intended to provide Market Participants familiar with the Behind the Fence (BTF) Process with a high-level overview of noteworthy changes resulting from the Amended 2018 ISO Tariff Compliance Filing, together with additional process efficiencies being implemented by the AESO. The following is not intended to be a comprehensive explanation of all changes; rather it is intended to facilitate awareness and understanding of key BTF Process changes that may be of importance to your project.

    Throughout this page, the tariff which became effective on January 1, 2021 will be referred to as the “Proposed Tariff”, and can be found here. The tariff that was previously in effect can be found here.

    An overview of the BTF Process can be found in the Quick Reference Guides section on the Connecting to the grid page.

    Questions or clarifications beyond what is captured on this page can be directed to your project manager or to customer.connections@aeso.ca.

    • Acronym Reference
         

      AUC

      Alberta Utilities Commission

      CCD

      Construction Contribution Decision

      DFO

      Distribution Facility Owner

      DTS

      Demand Transmission Service

      GFO

      Generation Facility Owner

      GUOC

      Generating Unit Owner’s Contribution

      ISD

      In-Service Date

      MC

      Maximum Capability

      MP

      Market Participant

      NID

      Needs Identification Document

      P&L

      Permit & License

      SAS

      System Access Service

      SASR

      System Access Service Request

      STS

      Supply Transmission Service

      TFO

      Transmission Facility Owner

    • SASR Critical Information
      • What’s changing?

        Specific information provided in the SASR, including location, capacity, and ISD, is now identified as “critical information” in the Proposed Tariff. The AESO relies on the accuracy of this information to plan the connection for a project. MPs are required to submit a project change proposal to amend the SASR for any changes to the critical information. The AESO will evaluate the impact of the changes to determine the response. In some cases, the AESO may cancel the project if the changes are significant.
      • What’s the impact?

        Although critical information is now clearly described in the Proposed Tariff, the process for providing and changing this information remains the same. While the impact on projects is therefore minimal, MPs will have better visibility and understanding of the critical information process.
      • Why the change?

        Clarifying which information is critical and the consequences of changing it will incent MPs to provide accurate information at the beginning of the process. This will minimize changes later in the project, and better support the AESO in its planning decisions.
      • When is it changing?

        Critical information will be provided in SASRs that are submitted on or after the effective date of the Proposed Tariff. For projects that are in-flight as of the effective date of the Proposed Tariff, the critical information will be taken from the SASR on file or, if applicable, from an approved change proposal for the project.
      • Where can I find more information?

        Critical information is described in subsection 3.2 and 3.9 of the Proposed Tariff. A new SASR template and guide, and corresponding change proposal form, will be posted on the AESO website by the effective date of the Proposed Tariff. These materials will provide a detailed explanation of the specific critical information being requested by the AESO.
    • SAS Agreement Timing
      • What’s changing?

        MPs will now be required to execute the SAS agreement in Stage 3/4 of the process as a requirement for completing the stage, and the agreement will become effective immediately upon signing. The MP may request to execute the SAS agreement any time after the functional specification has been issued, subject to Stage 3/4 maximum timelines (see the Stage Target and Maximum Timelines section).
      • What’s the impact?

        Once the SAS agreement becomes effective, both the AESO and MP are bound by the terms and conditions of the agreement. The MP risks forfeiting a portion of the GUOC refund or having to make a payment in lieu of notice (PILON) if any amendments to the SAS agreement are required after the effective date. As a result, it is important for MPs to gather and finalize their critical information in Stage 3/4 of the process, including the requested ISD and capacity, to avoid any adverse financial implications. This also results in the AESO ensuring that they are able to meet their obligations to provide the service described in the SAS agreement earlier in the process (see the Project Inclusion Criteria section).
      • Why the change?

        Earlier execution of the SAS agreement provides the AESO with increased certainty that the project will proceed to the requested ISD and contract capacity. This additional certainty supports better planning decisions and minimizes changes to the AESO’s system transmission plans and to the connection plans of other projects.
      • When is it changing?

        Projects that have not passed Gate 3/4 or received power plant approval as of the effective date of the Proposed Tariff will be required to execute their SAS agreement prior to completing Stage 3/4 (projects that have passed Gate 3/4 without receiving power plant approval should see the Power Plant Approval Timing section). Projects that have already passed Gate 3/4 and have power plant approval will be grandfathered and continue to execute the SAS agreement 30 days prior to the contract capacity start date.

        Note: Eligible projects may elect to comply with the provisions of the Proposed Tariff. Please refer to the Transitional Election Process for more details.
      • Where can I find more information?

        SAS agreement execution is discussed in subsection 3.6 of the Proposed Tariff, and SAS agreement effective dates are discussed in subsection 3.7. Details on the provision of system access service can be found in the Rate DTS and Rate STS proformas and Section 2 of the Proposed Tariff.

       

    • Generating Unit Owner’s Contribution
      • What’s changing?

        There are a number of changes related to GUOC in the Proposed Tariff. These changes include:
        • GUOC will now be calculated based on the MC of a generator, and will apply to all generators with an MC of greater than 1 MW
        • The regional rates used for the GUOC calculation have been updated
        • A GUOC Assessment will be provided for the GFO to acknowledge in Stage 1
        • GUOC will be invoiced directly to the GFO in Stage 3/4, must be paid within 30 days of any related SAS agreement becoming effective, and is a requirement to complete the stage

          Note: GUOC will also apply to generators with an MC of greater than 1 MW that join the energy market but are not required to submit a SASR. More information will be posted to Joining the energy market by the effective date of the Proposed Tariff.
      • What’s the impact?

        The GFO will now have a formal role in the process as they will be invoiced for and required to pay GUOC directly. GFOs will need to secure financing earlier in the process to ensure they can make the earlier GUOC payment in Stage 3/4. Projects should be aware that the GUOC amount assessed under the Proposed Tariff may differ from previous assessments as a result of the shift to MC based calculations and the updated regional rates.
      • Why the change?

        Basing the GUOC amount on the MC rather than the STS contract capacity more accurately reflects the actual impact of the generator on the system, and the updated regional rates provide a price signal that reflects the current generation capability in each region. Invoicing the GFO rather than the MP better aligns with the requirements in the Transmission Regulation.
      • When is it changing?

        Projects that have not passed Gate 3/4 or received power plant approval as of the effective date of the Proposed Tariff will be required to follow the GUOC provisions in the Proposed Tariff (projects that have passed Gate 3/4 without receiving power plant approval should see the Power Plant Approval Timing section). Projects that have already passed Gate 3/4 and have power plant approval will be grandfathered and continue to pay their GUOC 30 days prior to the contract capacity start date of the SAS agreement. Payment will continue to be based on the contract capacity and invoiced to the MP.

        Note: Eligible projects can elect to comply with the provisions of the Proposed Tariff. See the Transitional Election Process for more details.
      • Where can I find more information?

        GUOC is discussed in Section 7 of the Proposed Tariff, and timing of the GUOC payment is discussed in subsection 3.6(10).
    • Project Inclusion Criteria
      • What’s changing?

        A project will now be accounted for in the studies performed by other projects once the SAS agreement for the project is effective, which occurs upon execution in Stage 3/4. If the project is not executing a SAS agreement but is paying a GUOC, it will be included once the GUOC payment has been received. If the project is not executing a SAS agreement or paying a GUOC, it will be included once it has passed Gate 3/4.
      • What’s the impact?

        Study inclusion will occur earlier for projects than in the existing process. Provided there are no changes to a project’s critical information, MPs can have confidence in their connection once their SAS agreement is effective.
      • Why the change?

        When a SAS agreement becomes effective, the AESO must provide system access service up to the contract capacity for the capacity start date. The project must therefore be accounted for in other project studies to ensure the AESO will be able to meet its obligations under the terms of the SAS agreement.
      • When is it changing?

        Projects that have not passed Gate 3/4 or received power plant approval as of the effective date of the Proposed Tariff will be included in the studies performed by other projects using the new criteria (projects that have passed Gate 3/4 without receiving power plant approval should see the Power Plant Approval Timing section). Projects that have already passed Gate 3/4 and have power plant approval will be grandfathered and included per the existing practice of GUOC payment for generation, and passing Gate 3/4 for load.

        Note: Eligible projects can elect to comply with the provisions of the Proposed Tariff. See the Transitional Election Process for more details.
      • Where can I find more information?

        The project inclusion criteria will be detailed in an update to ID 2018-018T Provision of System Access Service and the AESO Connection Process, which will be posted prior to the effective date of the Proposed Tariff.

       

    • Proposal to Proceed
      • What’s changing?

        The AESO will now provide the MP with a Proposal to Proceed letter near the end of Stage 2, which will confirm that the project can proceed as requested in the SASR. The MP will be required to review and acknowledge this letter before moving into Stage 3/4.
      • What’s the impact?

        MPs will receive documentation from the AESO that an assessment has been completed and that the project may proceed as requested.
      • Why the change?

        There was no consistent process for notifying MPs of the results of the assessment for a BTF Project. Issuing a Proposal to Proceed letter provides consistency, and aligns the BTF Process with how the preferred alternative is presented to the MP in the Connection Process.
      • When is it changing?

        Projects that have not passed Gate 2 as of the effective date of the Proposed Tariff will be issued the Proposal to Proceed letter before completing Stage 2. Projects that have passed Gate 2 will not be affected.
      • Where can I find more information?

        Details on where the Proposal to Proceed letter fits into the process can be found in the BTF Process Quick Reference Guide.
    • Formalized Role of the GFO
      • What’s changing?

        The GFO will now have a formalized role in projects where the MP submitting the SASR is not the GFO, as is the case for distributed generation connections. The GFO will participate in meetings, review documents such as the Project Plan and Study Scope, and perform generator-related activities, such as acknowledging the GUOC Assessment and requesting the Commissioning Certificate.
      • What’s the impact?

        The GFO will be required to commit more time throughout the process on project activities, but this will result in closer alignment between all parties, and ensure that the GFO will have a better understanding of the scope, costs, and risks of their project.
      • Why the change?

        Coordination with the GFO has previously been the responsibility of the MP submitting the SASR, and this has resulted in a number of inefficiencies. Formalizing the role of the GFO throughout the process will improve clarity, communication and potentially result in improvements to project timelines.
      • When is it changing?

        Documents and activities that are underway as of the effective date of the Proposed Tariff will not require GFO involvement. New deliverables and activities will require GFO involvement as outlined in the process details posted on the website, which will be updated for the effective date of the Proposed Tariff.
      • Where can I find more information?

        Details on where the GFO is involved in the process can be found in the BTF Process Quick Reference Guide, and will be available in the process details found under Connecting to the grid.
    • CCD and GUOC Assessment Timing
      • What’s changing?

        A CCD will now be provided to the MP in Stage 1 of the process, and updated if required in Stage 2. A GUOC Assessment will also be provided to the GFO at the same time, if applicable.
      • What’s the impact?

        MPs and GFOs will have visibility of project costs before studies are completed in Stage 2, which will allow them to assess the financial viability of their project earlier in the process.
      • Why the change?

        Existing investment at a substation can often be a significant financial barrier for the viability of a project. Providing this information to the MP before performing studies allows that assessment to occur before performing potentially unnecessary work and incurring the related costs.
      • When is it changing?

        Projects that are in early Stage 1 as of the effective date of the Proposed Tariff will be provided the Stage 1 CCD and GUOC Assessment. Projects in late Stage 1 or in Stage 2 may request their CCD and GUOC Assessment from their AESO project manager, or wait until the Stage 2 documents are normally issued.
      • Where can I find more information?

        The Stage 1 CCD and GUOC Assessment are listed in the BTF Process Quick Reference Guide.
    • Power Plant Approval Timing
      • What’s changing?

        A power plant approval issued by the AUC will now be a requirement to pass Gate 3/4 of the process for projects with generation.
      • What’s the impact?

        Projects that have completed all other Gate 3/4 requirements will not move into Stage 5 of the process until they also have the power plant approval for any generation. Previously, completing the stage only required having filed the power plant application. Projects that are in stage 5 but do not have power plant approval will be reclassified to Stage 3/4, and the new Stage 3/4 timelines and required deliverables will apply. This change does not apply to projects that have received their power plant approval but have ongoing amendments.
      • Why the change?

        The requirements for earlier execution of the SAS agreement and payment of the GUOC in the Proposed Tariff have resulted in a situation where generation projects in Stage 5 without a power plant approval would be required to immediately perform these activities. Reclassifying these projects to Stage 3/4 allows MPs to execute the SAS agreement and pay the GUOC on a timeline that makes sense for their project, subject to maximum stage timelines. This change also aligns Stage 5 of the BTF Process with the Connection Process, where all deliverables required for construction have been completed prior to entering the stage.
      • When is it changing?

        Projects that are in Stage 5 but do not yet have a power plant approval as of the effective date of the Proposed Tariff will be reclassified into Stage 3/4 on the AESO Connection Project List. The new Gate 3/4 requirements will apply to these projects and all others not yet in Stage 5. Projects in Stage 5 that have their power plant approval will remain in Stage 5.
      • Where can I find more information?

        The requirement for power plant approval to complete Stage 3/4 is detailed in the BTF Process Quick Reference Guide.
    • Stage Target and Maximum Timelines
      • What’s changing?

        Stages 1, 2 and 3/4 of the BTF process will now have target and maximum timelines for the completion of each stage. Projects will be expected to complete the required deliverables for each stage within the maximum timelines that are established. Failure to do so may result in the project being cancelled.
      • What’s the impact?

        Projects must now progress through the process stages in a timely manner, and will not be able to pause indefinitely within a stage, unless they request the Stage 2 On Hold Option.
      • Why the change?

        Adopting stage target and maximum timelines ensures that projects move through the process in a timely manner and gives the AESO a mechanism to remove projects that are not progressing in a material way. Projects that do not progress in the process impact AESO planning decisions, other project studies, and take up significant resources. This aligns the BTF Process with the timeline requirements that already exist in the Connection Process, and will allow for the reporting and communication of process metrics.
      • When is it changing?

        Projects that are in Stage 1, 2 and 3/4 as of the effective date of the Proposed Tariff will be subject to the new timelines, which will be measured beginning on the Proposed Tariff effective date regardless of how long a project has been in the stage. Going forward, stage timelines will begin once the gate has been completed for the previous stage.
      • Where can I find more information?

        Stage target and maximum timelines will be detailed in an update to ID 2018-018T Provision of System Access Service and the AESO Connection Process, which will be posted prior to the effective date of the Proposed Tariff.