Market Rule and Change Management Consultation Process

1. Market Rule and Change Management Consultation Process John MacKenzie / Darren Finkbeiner / Ella Kokotsis, IMO Market Operations Standing Committee

2. Authorities Under Electricity Act • IMO Board has authority to make (approve) market rules • Minister of Energy has authority to revoke any amendment approved by IMO Board • OEB can review rules and any amendment approved by IMO Board • Any person can ask for OEB review of an approved market rule amendment • Any person adversely affected by provision of a market rule can ask for OEB review of that provision Market Operations Standing Committee

3. Amendment Submission • Any person may submit one • Form on IMO web site: • Rules and Manuals\Rule Amendment Process • Identify issue (and suggest rule change) • Reviewed by IMO staff against published criteria • criteria in Appendix B of Market Manual 2.3 • IMO recommendation to Technical Panel • Technical Panel decisions: warrants consideration; priority; stakeholder consultation Market Operations Standing Committee

4. Amendment Proposal - 1 • Detailed proposed amendment and rationale • Developed by IMO staff and Technical Panel • may be several iterations • Technical Panel votes on “final” amendment proposal • Technical Panel report to IMO Board • recommended amendment proposal • vote recorded • issue(s) of dissenter(s) • IMO impact assessment Market Operations Standing Committee

5. Amendment Proposal - 2 • IMO Board decisions regarding recommended amendment proposal • approve as is or with changes, or • reject, or • refer back to TP or to some other person • Approved amendment published • within 15 days of publication, Minister may revoke and refer back to IMO • within 21 days of publication, any person can ask for OEB review • 22 days from publication, rule can become effective Market Operations Standing Committee

6. Stakeholder Consultations - 1 • IMO Publication and Stakeholder Notification: • Amendment submission with TP decisions* • If requested by TP, draft amendment proposals • TP recommended amendment proposals* • IMO Board approved amendments* • Update reports at MOSC * market rule obligations • With every publication, e-mail notification: • MP main contacts; Market Rules and Market Design subscription list; key stakeholder groups; TP members • include short summary of amendment document and links to actual documents Market Operations Standing Committee

7. Stakeholder Consultations - 2 • Technical Panel: • may request stakeholder review & comment of amendment submission and/or amendment proposal (draft and recommended) • may direct/hold special stakeholder meetings • will consider unsolicited comments Market Operations Standing Committee

8. Where to Get Further Information • IMO web site: • market rule amendment documents: www.theimo.com/imoweb/amendments/mr_Amendments.asp • Technical Panel meeting agendas and minutes: www.theimo.com/imoweb/amendments/Amendprocess.asp Market Operations Standing Committee

9. Market Operations Standing Committee

10. Objectives for IMO Change Management • Minimize disruption to market participant process and systems • Ensure functionality of market systems and procedures remains consistent with each other, with market rules and with legislation Method: • Participant consultation • Ensure impact upon both the IMO and market participants is clearly understood Market Operations Standing Committee

11. Overview • Process divides into two general steps • Concept development phase • Implementation phase • Complex changes require both phases • IMO weighs benefits and costs on market and participants (w/ participant input) Market Operations Standing Committee

12. Concept Development phase • Several sources for proposed changes:- 1) Standing Committees, 2) Rule amendment submissions; 3) Market Participants; ... • Steps:- • identify issue • prepare proposed solutions • assess and choose preferred solution • decision whether to proceed with implementation stage • Stakeholdering:- Conferences, workshops, conference calls, web posting, email notification, project web pages Market Operations Standing Committee

13. Implementation Phase • preparation of tool changes: • requirements lead to detailed specification to coding, delivery, testing • preparation of documentation changes: • development of technical interface documents to support software change • development of external market-facing documentation (e.g. market manuals, MRs) Market Operations Standing Committee

14. Implementation of tool changes • March, June, September and December (4 times) • Two categories of tools changes: • Category 2 - change has functional impact on MPs • Category 3 - change requires a technical interface change • Category 3 - only March and September and will include changes with functional impacts on MPs • Release dates for tool changes same as Baseline dates for documentation Market Operations Standing Committee

15. Implementation of Baseline Document changes • Baseline - any documents that are published on the IMO web site which describe market facing procedures or explain how to use market processes and systems are part of the external design baseline. • Market-facing external documentation changes rolled-out in accordance with baseline calendar. • Calendar for next 3 baselines currently on IMO web site Market Operations Standing Committee

16. Stakeholdering Baseline Document Changes • Two week stakeholdering period to comment on changes to market manuals • Posted to Pending Changes 7 weeks before baseline/release date • E-mail notification to Market Rules and Market Design subscription list • MOSC meetings scheduled during stakeholdering period to review changes Market Operations Standing Committee

17. Integration of Tool and Document Changes • Same dates for baselines and releases • Same ID numbers, eg., 11.0 starting March 3, 2004 • Pending Changes page provides links to:- • Release calendar and implementation plans • Baseline calendar (for next 9 months), and • Listing of documents being updated - both Technical Interface and Market Manuals Market Operations Standing Committee

18. Changes between Baseline dates • May need to update market documents outside this stakeholdering period; eg. Urgent rule amendments • Use Interim Market Document Change • E-mail notification to Market Rules and Market Design subscription list • 1- 2 week stakeholder period for comments • IMDCs rolled into applicable manual on next baseline date Market Operations Standing Committee

19. IMO Communications Process (Email Notification) If obligation, must meet given publication date as per MarketRules

20. IMO Communications Process (Web Notification) Market Operations Standing Committee