Enron Mail

From:ray.alvarez@enron.com
To:tom.alonso@enron.com, robert.badeer@enron.com, tim.belden@enron.com,sean.crandall@enron.com, michael.driscoll@enron.com, mark.fisher@enron.com, mark.guzman@enron.com, tim.heizenrader@enron.com, chris.mallory@enron.com, susan.mara@enron.com, matt.mot
Subject:Order Clarifying April 26, 2001 Order on MMP
Cc:steve.walton@enron.com, susan.mara@enron.com, alan.comnes@enron.com,leslie.lawner@enron.com, rebecca.cantrell@enron.com, donna.fulton@enron.com, jeff.dasovich@enron.com, christi.nicolay@enron.com, james.steffes@enron.com, jalexander@gibbs-bruns.com,
Bcc:steve.walton@enron.com, susan.mara@enron.com, alan.comnes@enron.com,leslie.lawner@enron.com, rebecca.cantrell@enron.com, donna.fulton@enron.com, jeff.dasovich@enron.com, christi.nicolay@enron.com, james.steffes@enron.com, jalexander@gibbs-bruns.com,
Date:Tue, 29 May 2001 03:16:00 -0700 (PDT)

Late in the afternoon on Friday May 25, FERC issued an order providing=20
clarification and preliminary guidance on implementation of the mitigation=
=20
and monitoring plan for the California wholesale electric markets that it=
=20
adopted on April 26. The order is limited to clarifying four critical issue=
s=20
prior to the Mitigation Plan's May 29 (today) effective date: (1) treatment=
=20
of generators who did not supply heat and emission rates; (2) calculation o=
f=20
a natural gas proxy price; (3) price mitigation in the ISO's spot markets=
=20
other than Imbalance Energy; and (4) creditworthiness. The order does not=
=20
resolve the rehearing requests, nor does it accept or reject the ISO's=20
proposed tariff amendments for filing. These pleadings are still under=20
review and FERC will address them in a separate order. =20

Treatment of Generators Who Did Not Supply Heat and Emission Rates

FERC accepts the ISO=01,s proposal for generating units within California=
=20
(including non-public utility generating units) that have not supplied heat=
=20
and emission rates in compliance with the April 26 Order:

For the generating units that have not provided the requisite data or whose=
=20
data the ISO believes to be inadequate, the ISO will use data from a viable=
=20
alternative source (e.g., either current or pre-existing Reliability Must-R=
un=20
Contracts). If an alternative source of data does not exist and the=20
generating unit continues to refuse to supply the requisite information, th=
e=20
ISO will treat the non-compliant generators as price-takers, i.e., the ISO=
=20
will assume a $0/MWh bid for all available capacity from these units. Thes=
e=20
generators, if dispatched, will be paid the market clearing price. =20

The FERC finds that to the extent a non-compliant seller does not wish to b=
e=20
treated as a price-taker, the ISO's approach will provide such entities wit=
h=20
an incentive to provide the ISO and the Commission with the requisite data.

Calculation of a Natural Gas Proxy Price

FERC rejects the ISO proposal to calculate a proxy natural gas cost based=
=20
upon the simple average of Gas Daily index prices for Malin, PG&E CityGate,=
=20
and Southern California Border (Kern River Station). The ISO is directed t=
o=20
calculate the natural gas proxy price using the published daily prices for=
=20
Malin, PG&E CityGate, Southern California Border (Kern River Station),=20
SoCalGas large packages, and PG&E large packages. The Commission will=20
consider whether any changes should be made to the California delivery poin=
ts=20
during rehearing of the April 26 Order. =20

Price Mitigation in the ISO's Spot Markets other than Imbalance Energy

The FERC finds that the ISO erred in its interpretation- that it does not=
=20
intend to apply any price mitigation to its Ancillary Services spot markets=
=20
or Adjustment Bids. The April 26 Order did not explicitly address the issue=
=20
of price mitigation in any market other than that for Imbalance Energy, the=
=20
order nonetheless noted that "this proceeding was established . . . to=20
address whether a price mitigation plan was needed to replace the $150/MWh=
=20
breakpoint methodology." The $150/MWh breakpoint methodology applied to th=
e=20
ISO's Ancillary Services markets. Therefore, the ISO must replace the=20
$150/MWh breakpoint methodology in those markets with the superseding=20
methodology adopted in the April 26 Order. The Commission further clarifie=
s=20
that the April 26 Order did not replace the ISO's current methodology for=
=20
mitigating Adjustment Bid prices.

With respect to calculating the market clearing price for Ancillary Service=
s,=20
FERC directs the ISO to use each relevant average hourly mitigated Imbalanc=
e=20
Energy price. If the Ancillary Services markets clear below the average=20
hourly mitigated Imbalance Energy price for that hour, then the ISO will pa=
y=20
the Ancillary Services clearing price for that market. If the Ancillary=20
Services markets clear above the average hourly mitigated Imbalance Energy=
=20
price, then the ISO will use that price to clear the market and will pay=20
as-bid for all Ancillary Services that are needed above the mitigated price=
. =20
Bids accepted above the mitigated price will be subject to refund and=20
justification. =20

Creditworthiness

As of May 29, 2001, FERC expects the ISO to ensure the presence of a=20
creditworthy buyer for all transactions made with all generators who offer=
=20
power in compliance with the must-offer requirement in the Mitigation Plan.=
=20


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