NPRRs

1. NPRRs • 606NPRR Removal of Risk Management Verification Fee.  The Protocols currently allow ERCOT to assess a fee to eligible Counter-Parties for all or part of the costs of verifying the risk management framework as set forth in Section 16.16.3.  The ability to charge and collect a separate fee to account for ERCOT’s risk management verification costs was added to the Protocols with Nodal Protocol Revision Request (NPRR) 438, Additional Minimum Counter-Party Qualification Requirements, Including Risk Management Capability Requirements, which was approved by the ERCOT Board in July 2012.  The Protocol language added by NPRR438, however, is not accompanied by a specific fee amount or approved methodology for calculating the fee.  As noted in the Impact Analysis for NPRR438, system implementation costs for NPRR438 were immaterial, and the ongoing staffing costs related to oversight of risk management verification should not exceed one Full-Time Equivalent (FTE).  Following discussion at the November 18, 2013 Finance and Audit Committee meeting, there was consensus that because the overall expenses related to risk management verification are minor, it would be more practical to eliminate the fee and include this expense within ERCOT’s Operations and Maintenance (O&M) budget.  This NPRR removes the language establishing the risk assessment fee from Section 16.16.3.

2. NPRRs • 607NPRR Short-Term System Adequacy Report Posting Modification.  This NPRR aligns the Protocols with current ERCOT business practice for posting the Short-Term System Adequacy Report by removing language requiring ERCOT to post the report upon detection of a change to Resource Status that changes the availability of a Resource.  • 609NPRR ERCOT System Administration Fee and User Fees.  This Nodal Protocol Revision Request (NPRR) clarifies the distinction between the ERCOT System Administration fee approved by the Public Utility Commission of Texas (PUCT) and user fees approved by the ERCOT Board • 610NPRR Eliminate Late Fees and Late Fee Invoices.  This Nodal Protocol Revision Request (NPRR) eliminates late fees and related Late Fee Invoices. The imposition of late fees has not been effective in deterring late payments by Settlement Invoice Recipients. The late fees charged have not exceeded $100.  Section 16.11.6.2, ERCOT’s Remedies for Late Payments by a Market Participant, sufficiently addresses late payments.

3. NPRRs • 612PRR Reduction of Cure Period Subsequent to Event of Default.  This Nodal Protocol Revision Request (NPRR) reduces the cure period for failure to make payment or transfer funds, provide collateral or designate/maintain an association with a Qualified Scheduling Entity (QSE), to one Business Day subsequent to written notification of the breach.  In addition, the NPRR clarifies that an Invoice payment from available security will be considered a Late Payment per Protocol Section 16.11.6; it eliminates discrepancies between Protocol and Standard Form Agreement language; and aligns terminology in Protocol Section 16. • 613NPRR Clarification of Fuel Adder into the Mitigated Offer Cap.   This Nodal Protocol Revision Request (NPRR) clarifies the implementation of the fuel adder into the Mitigated Offer Cap as provided in NPRR485, Clarification for Fuel Adder Provisions, approved by ERCOT Board of Directors 11/13/2012, and as planned to take effect upon ERCOT’s implementation of the automated solution of NPRR485.