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Timing of FCA Bids and Offers. Pete Fuller NEPOOL Markets Committee September 12, 2012. Qualifier. NRG continues to believe FCM is deeply flawed as it is currently structured and administered:
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Timing of FCA Bids and Offers Pete Fuller NEPOOL Markets Committee September 12, 2012
Qualifier • NRG continues to believe FCM is deeply flawed as it is currently structured and administered: • Mitigation of existing resources should provide an opportunity for the marginal capacity resource to recover all of its annual fixed costs • A demand curve that recognizes the incremental value of additional capacity is essential, especially in the absence of a supply curve based on long-run costs • Reliability reviews of existing resource offers (delist bids) should be eliminated; all constraints that are to be enforced in the auction should be specified in the auction requirements
Proposal • In conjunction with ISO’s proposal to allow modification of delist bids for a short period after the Qualification Determination Notification, NRG proposes that all bids and offers, from new as well as existing resources, become binding at that time* * NRG continues to support a construct in which all bids and offers (including delist bids below the reviewed and approved ‘reference’ price) can be entered during the descending clock auction. However, ISO has taken the position that static delist bids must become binding months prior to the auction. If that is the structure, then NRG proposes that all bids and offers should become binding at that time.
Proposal • All new and existing resources submit their prices no later than 7 days after QDNs are issued • Under ISO’s proposal, any existing resource offers (delist bids) submitted in advance for Market Monitor review become binding at that date • In the interest of comparability, all resources participating in the auction to transact the same product should be subject to the same deadlines for pricing • The fully-specified supply curve in advance of the auction will also enable more efficient auction clearing and less uncertainty in reliability reviews
Next Steps • Consultation with ISO and stakeholders • Circulate market rule language • Further Markets Committee consultation and amendment to be offered to the ISO changes at October MC and November PC (if needed) • Rule changes must be effective prior to the start of Existing Resource Qualification for FCA8