|
|
Enron Mail |
Linda --
Can you please pull a copy of the ComEd OATT that would include the calculation of "OPC" mentioned below? Janine -- Doesn't it make sense that we are disadvantaged vis-a-vis their own transmission service and should talk to Donna Fulton about a complaint at FERC? Jim -----Original Message----- From: Migden, Janine Sent: Sunday, August 12, 2001 10:12 PM To: Steffes, James D. Cc: Migden, Janine Subject: FW: Imbalance Issues Jim, Per your request, below is an email from Chris Townsend explaining the imbalance program. I plan to call him to get a better handle on the discount issue, but I think that it is useful that marketers can trade imbalances, but the benefit is premised on there being many suppliers. More to follow when I return. Janine -----Original Message----- From: "Townsend, Christopher J. - CHI" <christopher.townsend@piperrudnick.com<@ENRON [mailto:IMCEANOTES-+22Townsend+2C+20Christopher+20J+2E+20-+20CHI+22+20+3Cchristopher+2Etownsend+40piperrudnick+2Ecom+3E+40ENRON@ENRON.com] Sent: Wednesday, August 08, 2001 8:01 PM To: Migden, Janine Cc: Fein, David I. - CHI Subject: Imbalance Issues Janine -- As you might recall from the memo summarizing the 1999 Edison DST proceeding, the Illinois Commerce Commission essentially "punted" on the imbalance issue, instead deferring to FERC. Attached is the section from our memo that discussed the imbalance issue. It is my recollection that the issue of establishing subaccounts was not addressed. We will try to confirm this tomorrow. As lawyers, please do not hesitate to call or email if we can be of any further assistance. < Christopher J. Townsend < Piper Marbury Rudnick & Wolfe < 203 N. LaSalle Street < Chicago, IL 60601 < (312) 368-4039 (direct line) < (312) 630-6300 (direct fax) < christopher.townsend@piperrudnick.com < Energy Imbalances 1. Jurisdictional Issues The ARES Coalition, Alliant, and IIEC argued that the Commission should address energy imbalances in the proceeding. Enron and NewEnergy abandoned this argument after reaching a settlement agreement with Edison. Staff and Edison argued that charges for energy imbalances are properly addressed within Edison's OATT and subject to the jurisdiction of the FERC. The Commission concluded that in the interest of avoiding protracted litigation and the harm of delay to retail competition, the Commission would not address the propriety of FERC's asserted authority over energy imbalance issues. The Commission indicated that its deferral to the FERC in no way "waives its right to assert jurisdiction over energy imbalance service at some future time." 2. Factual & Policy Issues Edison proposed an energy imbalance service to retail customers containing the following provisions: * Energy imbalance will be calculated separately for each hour and settlements will occur on a cash basis for each hour's imbalances; * For those RESs whose energy imbalance in an hour is 2% or less, or 2 MW or less, settlement is made at 100% of out-of-pocket costs ("OPC"), regardless of the net imbalance or the direction of the error; * * Those RESs whose energy imbalances exceed 25% of their own individual schedules will pay an adder or be charged a discount of 25% of OPC. Adjustments are made to avoid double-counting of adders and discounts applicable to those RESs that are also subject to an adder or discount below. These imbalance charges will be phased-in as follows: * * From October 1, 1999 through December 31, 1999 -- No adder will apply under this provision. * * From January 1, 2000 through March 31, 2000 -- 25% adder/discount will apply to those RESs whose imbalances exceed 25% of their schedules 20% or more of the hours of the month. If the 20% of the hours are exceeded, the adder/discount shall apply to all hours. * * Starting April 1, 2000 -- 25% adder/discount will apply to those RESs whose imbalances exceed 25% of their schedules 10% or more of the hours of the month. If the 10% of the hours are exceeded, the adder/discount shall apply to all hours. * Edison also applies a bandwidth to the total net energy imbalance attributable to unbundled retail load served by RESs. If the hourly imbalance caused by all unbundled retail load, excluding PPO load, is within the 100 MW bandwidth, no RES (except those whose imbalance exceeds ?25%, as noted below) will be subject to an adder or discount. PPO load will, in aggregate, be subject to the same terms and conditions as above, but imbalance attributable to the PPO will be compared against a 100 MW deadband separately from all RES load. * Edison will permit RESs to trade energy imbalances among themselves, to offset their imbalances at whatever prices and terms they wish, before applying a charge for energy imbalance. According to Edison, this feature will allow RESs to minimize energy imbalance charges by exchanging overscheduled megawatt-hours for underscheduled megawatt-hours in the same hour. All remaining imbalances will be settled in cash at 100% of Edison's OPC. Edison shall make available information on OPC ten days prior to the opening of the trading window. * * The net retail energy imbalance in excess of 100 MW will be charged an adder or discount of 10%. This charge will be allocated among RESs who are out of balance in the direction of the net and whose imbalance exceeds their individual deadband. The allocation will be based on the ratio-share of the amount by which these individual RESs' imbalances exceed their individual deadbands. Any such adder/discount will be billed separately from charges for any imbalances remaining after trading. Likewise, any adder/discount attributable to the provisions of Paragraph 3 will be billed separately from charges for any imbalances remaining after trading. * * Load profiles will be developed using Dynamic Load Modeling with seasonal adjustments. Edison will not require the installation of interval demand recorders for customers of less than 400 kW at this time. * * Energy imbalances will be assumed to be within the bandwidth (i.e., no adders/discounts) when the imbalances are due to (1) Edison interruptions and restorations, or (2) customer force majeure events, that are in each case material to the RESs' schedule and of which the RES could not reasonably be aware in sufficient time to adjust the schedule. * * Edison will include a description of the methodology for determining OPC in its energy imbalance schedules filed with the FERC. The IIEC opposed Edison's proposal and requested that the Commission require Edison to offer an optional imbalance service at the distribution level. Blackhawk also opposed Edison's proposal and supported the IIEC proposal Alliant also supported Edison being required to offer an energy imbalance service at the distribution level. Mid-American opposed any effort by the Commission to exert jurisdiction on energy imbalances. The Commission failed to weigh-in on the energy imbalance issue consistent with its determination that the FERC is the appropriate forum for such issues. The Commission reserved the right to address the issue in some future FERC proceeding. ____________________________________________________________________________ The information contained in this communication may be confidential, is intended only for the use of the recipient named above, and may be legally privileged. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please re-send this communication to the sender and delete the original message and any copy of it from your computer system. Thank you. For more information about Piper Marbury Rudnick & Wolfe, please visit us at http://www.piperrudnick.com ____________________________________________________________________________ - C.DTF << File: C.DTF <<
|