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From:dljones@cps-satx.com
To:isonp@ercot.com, piwg@ercot.com, operations@ercot.com,manuel-munoz@reliantenergy.com, cgreer@tnpe.com
Subject:RE: Suggested Solution to the PUC's Concerns Regarding Local Cong
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Date:Wed, 29 Nov 2000 14:41:00 -0800 (PST)

Cc: kevin-gresham@reliantenergy.com, brenda_b_harris@reliantenergy.com
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Is Clayton reading it correctly? I must admit that I am having trouble
interpreting the proposed solution as well. Also, I would respectfully
disagree that the problem (i.e., potential for gaming) exists only when the
zonal MCPE is negative.

< ----------
< From: Greer, Clayton[SMTP:cgreer@tnpe.com]
< Sent: Wednesday, November 29, 2000 9:42 AM
< To: isonp@ercot.com; piwg@ercot.com; operations@ercot.com;
< manuel-munoz@reliantenergy.com
< Cc: kevin-gresham@reliantenergy.com; Brenda_B_Harris@reliantenergy.com
< Subject: RE: Suggested Solution to the PUC's Concerns Regarding Local
< Cong estion
<
< If I am reading this correctly, it appears that rather than provide an
< adjustment for decremental units relieving local congestion, they will be
< required to either pay the market clearing price of energy for the zone or
< redispatch another unit in the same zone to counter act the decremental
< instruction.
<
< I believe we can support this change as long as few questions are properly
< handled:
<
< If there are multiple units that can clear the local congestion problem,
< who
< gets selected? (best shift factor, submitted dec bids, ERCOT flips a
< coin?)
<
< If a generator fails to follow this instruction will it properly show up
< as
< an uninstructed deviation, or will ERCOT follow performance to these
< direct
< instructions some other way?
<
< Can this similar methodology be used on the incremental side to curb abuse
< by those who manipulate their resource plans to create congestion they
< will
< be the only resource to correct?
<
< Have a great day!
<
< < ----------
< < From:
< < manuel-munoz@reliantenergy.com[SMTP:manuel-munoz@reliantenergy.com]
< < Sent: Sunday, November 26, 2000 7:45 PM
< < To: isonp@ercot.com; piwg@ercot.com; operations@ercot.com
< < Cc: kevin-gresham@reliantenergy.com;
< Brenda_B_Harris@reliantenergy.com
< < Subject: Suggested Solution to the PUC's Concerns Regarding Local
< < Congestion
< <
< < <<File: Adib103100<<<<File: stoft-game.pdf<<<<File:
< < stoft-intra-zonal.pdf<<
< < In a memo from Parvis Adib dated Oct. 31 (copy attached), the PUC
< < describes
< < a serious concern on the part of the Commission regarding market abuse
< < through relieving Local Congestion under the current Protocols. John
< Meyer
< < has asked me to draft a suggested solution to this concern. I am
< < recommending the following solution and believe it should be very easy
< to
< < implement.
< <
< < THE PROBLEM: Gaming whereby an entity deliberately and chronically
< places
< < itself in a situation to create local congestion in order to profit from
< < instructions to decrement its energy deliveries.
< <
< < The current language states that when a resource is instructed to
< < decrement its energy deliveries and a Market Solution does not exist the
< < resource's QSE will pay the minimum of the MCPE for that zone or 0. The
< < trouble with this approach is that if the MCPE is negative the QSE is
< < rewarded for having a resource causing local congestion. If the
< situation
< < persisted over time this could encourage inefficient generation to be
< < built
< < on the same area so that it can profit by having its output reduced or
< < even
< < turned off.
< <
< < Note that this would only happen in a situation where the local
< congestion
< < is located within a zone that is also susceptible to CSC congestion as
< < well
< < and the QSEs in such a zone are decremented most of the time which leads
< < to
< < high incidence of negative MCPE for the zone. This does not appear
< likely
< < but could occur if a zone is relatively small; i.e., dominated by QSEs
< < that
< < are few in number and that consistently overschedule across a CSC zone
< < with
< < the anticipation that they will always be instructed to decrement energy
< < in
< < real time.
< <
< < RECOMMENDED SOLUTION :
< <
< < Do not compensate or charge a resource that is instructed to decrement
< its
< < energy deliveries by ERCOT when a Market Solution does not exist in
< < relieving local congestion. However, the resource must obey the
< < instruction in order to maintain system reliability.
< <
< < Please give me your comments on this solution concept before Dec. 1. I
< < am
< < recommending that we add this as an item to vote on at the RUG meeting
< < scheduled for Dec. 6. I will also draft the recommended language changes
< < (very minor) to sections 6 and 7 and distribute it prior to the meeting.
< <
< < Manny
< <
< <
< < (See attached file: Adib103100)
< <
< < (See attached file: stoft-game.pdf)
< <
< < (See attached file: stoft-intra-zonal.pdf)
< <
< <
<