ISO rules compliance
Complying with the ISO rules
As Alberta’s ISO, we have the authority to make ISO rules in accordance with Section 20 of the Electric Utilities Act. The Electric Utilities Act requires electricity market participants to comply with the ISO rules and the AESO is responsible for monitoring market participant compliance with ISO rules.. Compliance with the ISO rules is a key element of both system reliability and the operation of a fair, efficient and openly competitive market. As well as monitoring market participant compliance with the ISO rules, the AESO can, through training, publications, meetings, phone calls and other communications, work with market participants to help them to come to a better understanding of their obligations, the AESO’s expectations, the compliance monitoring process and the possible repercussions of non-compliance.
As part of our monitoring obligation, we must refer suspected contraventions of the ISO rules to the Market Surveillance Administrator. The Market Surveillance Administrator is responsible for the enforcement of compliance with the ISO rules.
The Alberta Utilities Commission defines the penalties for contraventions of ISO rules. Read the Alberta Utilities Commission Rule 019—Specified Penalties for Contravention of ISO Rules that sets out the approved penalties for ISO rule contraventions.
Read background on the ISO rules compliance monitoring process here:
ISO Rule 103.12 - Compliance Monitoring
ISO Rule 103.12 sets out the requirements for the ISO and market participants with respect to monitoring compliance with the ISO rules, the Alberta Reliability Standards and AUC 021 –Settlement System Code. Among other requirements, ISO rule 103.12 describes how the ISO may learn of cases of potential non-compliance and how it reviews the facts available with respect to the issue. It describes the confidential handling by the ISO of compliance matters. It describes the information request process by which the ISO obtains additional information related to potential non-compliances. The AESO provides an opportunity for a market participant who is suspected of potential non-compliance, to review the relevant facts and provide any additional facts and perspective for consideration. ISO rule 103.12 describes the referral process by which the ISO, after coming to a determination that it suspects an ISO rule was contravened, refers the matter to the Market Surveillance Administrator.
MSA Compliance Process
Once a suspected ISO rule contravention has been referred to the MSA by the AESO, the MSA assumes sole carriage of the matter and becomes the primary contact for the market participant. As part of the referral, the AESO will make available to the MSA, information obtained in the course of its compliance monitoring activities. The MSA makes a determination as to what enforcement action is appropriate.
The process by which the MSA handles referrals of suspected rule contraventions from the ISO is described in detail in the MSA Compliance Process.
We use a variety of approaches to monitor compliance with the ISO rules. These are explained in the following:
Monitoring compliance in the energy market
The energy market allows electricity from competitive generation in Alberta to be offered for sale, and enables that generation to be subsequently dispatched to meet demand on a minute-to-minute basis.
The energy market is explained in further detail here:
The requirements for market participants in the energy market are detailed in the ISO rules.
Guidance on how market participants submit information and receive instructions from the AESO with regard to participation in the energy market is found in the pool participant manuals.
A standard multi-step process is carried out each month to review the behaviour of the market participants in the energy market relative to the requirements in the ISO rules. Read about this process here:
Monitoring compliance in the Operating Reserves market
We procure Operating Reserve from Alberta generation and load through the Operating Reserve market.
Operating Reserves are part of the Ancillary Services provided by the AESO. Read a comprehensive overview of ancillary services, including Operating Reserves, here:
Information on how market participants submit information and receive instructions from the AESO in regard to the Operating Reserves market is found in the pool participant manual.
The process used to assess the compliance of Operating Reserve providers with the obligations in the contracts and the ISO rules is found here:
Monitoring compliance in transmission facility project procurement
Project procurement obligations for the legal owners of transmission facilities are detailed in subsection 9.1.5 of ISO rule 9.1.
The compliance monitoring of the project procurement requirements described in subsection 9.1.5 is carried out primarily through compliance monitoring audits. Read further details on this process here:
- Appendix A - Information request letter 1 (IR1) template - Initial notification of compliance monitoring audit and request for summary of project materials
- Appendix B - Summary of project materials template
- Appendix C - Information request letter 2 (IR2) template – request for TFO records
- Appendix D - Pre-audit conference meeting agenda
- Appendix E - Compliance monitoring audit query form template
Monitoring compliance with Section 501.2 of the ISO rules
Section 501.2 of the ISO rules describes obligations for the legal owners of critical facilities within Alberta's electricity industry. These obligations include the requirement for all critical facilities to have security measures in accordance with the Alberta Counter-Terrorism Crisis Management Plan (ACTCMP) as well as an emergency response plan in accordance with Directive 071 – Emergency Preparedness and Response Requirements for the Petroleum Industry (Directive 071), as published by the Alberta Energy Regulator.
Critical facilities within Alberta's electricity industry are named in the critical infrastructure list established under the ACTCMP and maintained confidentially by the Justice and Solicitor General branch of the Government of Alberta.
Read ISO Rule 501.2 here:
The process used to assess compliance of legal owners of critical infrastructure with the obligations set out in Section 501.2 is described here:
Section 501.2 of the ISO Rules Compliance Monitoring Program Guide [Posted: July 30, 2015]
Further guides and templates for critical facilities security compliance can be found here:
Section 501.2 of the ISO Rules Self-Assessment Process Guide [Posted: September 28, 2015]
ISO Rule 501.2 Self-Assessment Templates [Posted: March 4, 2016]
View presentations on the critical facilities compliance monitoring program here:
Presentation re: AESO stakeholder session on ISO Rule 501.2 Compliance Monitoring Program [Posted: June 5, 2015]
Presentation re: AESO stakeholder session for ISO Rule 501.2 Compliance Monitoring Program [Posted: March 31, 2015]
Read supplemental information on critical facilities compliance monitoring here:
Letter to participants re: ISO Rule 501.2 Compliance Monitoring for 2016 [Posted: February 19, 2016]
Letter to Legal Owners re: 2016 Compliance Monitoring Program and Critical Infrastructure List [Posted: November 12, 2015]
Compliance Monitoring Program - ISO Rule 501.2 Security of Critical Facilities [Posted: March 10, 2015]
Email us for more information at:
Other compliance related information is found in the following:
DVN tool for assisting participants with compliance obligations
To help maintain their own compliance with the ISO rules, market participants can use our optional dispatch variance notification (DVN) utility. This utility is embedded in our automated dispatch and messaging system (ADaMS). It can send out warnings to participants that may be of use in meeting certain obligations in the ISO rules. It’s important to note that use of the DVN utility does not ensure that a market participant is compliant with ISO rules.
Read further details in the Dispatch Variance Notification Functionality and Registration Guideline.
Email for further information on DVN here:
Download a registration form for DVN here:
Email your completed form here:
Review DVN related changes here:
AESO Compliance Notice on DVN [Posted: June 8, 2015]
Automated Dispatch and Messaging System (ADaMS) Enhancements – Audible Alarms, Warning Messages, and Other Enhancements ( Update) [Posted: May 28, 2015]
Automated Dispatch and Messaging System ("ADaMS") Enhancements [Posted: February 9, 2015]
Dispatch Variance Notification - Changes to DVN Functionality as of June 1, 2010 [Posted: May 31, 2010]
Download forms for complaints, dispatch variance notification requests, force majeure, and more here:
AESO Complaint Form [Posted: September 9, 2013]
ADaMS Dispatch Variance Notification - Asset Request and Acknowledgement Form [Posted: April 18, 2012]
AESO Force Majeure Submission Form [Posted: March 29, 2019]
AESO LSSI Force Majeure and Forced Outage Submission Form [Posted: December 18, 2018]
Notices to market participants
We regularly post notices to market participants containing information on compliance monitoring.
Read the latest notices for market participants below:
- Letter to participants re: ISO Rule 501.2 Updated Self-Assessment Templates [Posted: March 8, 2016]
- Letter to all participants (follow-up) re: Applicable Party Registration Process for ISO Rules [Posted: July 21, 2015]
- AESO compliance notice on DVN [Posted: June 8, 2015]
- Presentation re: AESO stakeholder session on ISO Rule 501.2 Compliance Monitoring Program held on June 5, 2015 [Posted: June 5, 2015]
- ISO Rule 501 2 letter to participants re self-assessment template parts 1 and 2 [Posted: May 26, 2015]
- Letter to participants re: Compliance Monitoring Program – Section 501.2 of the ISO Rules, Security of Critical Facilities [Posted: May 27, 2015]
- Letter to Participants re: Applicable Party Registration Process for ISO Rules [Posted: April 14, 2015]
- ISO Rule 501.2 Letter to Participants re Self-Assessment Template [Posted: April 2, 2015]
- ISO Rule 501.2 Self-Assessment Template Part 1 DRAFT [Posted: April 2, 2015]
- Presentation re: AESO stakeholder session for ISO Rule 501.2 Compliance Monitoring Program held on March 27, 2015 [Posted: March 31, 2015]
- Compliance Monitoring Program - ISO Rules Section 501.2 – Security of Critical Facilities [Posted: March 10, 2015]
Contact the AESO regarding ISO Rules compliance
Send AESO Complaint Forms and ask questions regarding the ISO rules compliance process here:
Alberta Electric System Operator (AESO)
Attention: Compliance - Market Monitoring
2500, 330 – 5th Avenue S.W.
Calgary, AB T2P 0L4