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Communication of ROFR

Communication of ROFR. Timing and Flowchart Assignment. Purpose. Recommend a mechanism for the submission and processing of MATCHING TSRs TP submission to the pre-submittal workspace Exercising ROFR Opting out of ROFR Define requirements for TP communication of the minimum Matching profile

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Communication of ROFR

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  1. Communication of ROFR Timing and Flowchart Assignment

  2. Purpose • Recommend a mechanism for the submission and processing of MATCHING TSRs • TP submission to the pre-submittal workspace • Exercising ROFR • Opting out of ROFR • Define requirements for TP communication of the minimum Matching profile • Define requirements for communication of TC Match submission • Define requirements for communication of TC opt-out

  3. Parking lot items • Requirement 68 (unresolved) • Expand the requirements needed on how to create a matching request • Requirement 24 • Consider Pre-submittal Workspace to queue a valid matching request • Requirement 54 • Should the minimum matching request created automatically by the TP and made available to the defender?

  4. The Pre-submittal Workspace • When competition is initiated for a valid Challenger, each valid Defender that has ROFR shall be notified of the competition through a MATCHING request created on OASIS in a PRESUBMITTEDstatus in the pre-submittal workspace • This is an expansion of the pre-submittal workspace concept developed for NITS • Will require changes to the PTP State Transition Diagram • Template changes will be needed to support this functionality • The PRESUBMITTED state indicates the MATCHING TSR is present in the pre-submittal workspace but has not yet been submitted

  5. TP communication of terms • The MATCHING request placed in the pre-submittal workspace by the TP shall communicate the following information: • The Aref of the Challenger • TheMatching profile, consisting of the transmission service and minimum profile of capacity and price over time and required to be submitted by the Defender in order to exercise their ROFR. This is the profile that was tested for feasibility of the Defender to exercise their ROFR • The remaining profile of capacity over time that the Defender would retain if they do not exercise their ROFR

  6. Exercising rofr • To exercise their ROFR, the Defender must move the MATCHING request to QUEUED status and provide the following information: • The Matching profile, consisting of the transmission service, profile of capacity, and price over time. This profile can meet or exceed the minimum requirements to exercise ROFR • The remaining profile of capacity over time that the Defender is requesting to retain in the event that the MATCHING request is denied. This can be the same remaining profile provided by the TP, or a lower profile as allowed by the TP.

  7. Exercising rofr (cont.) • The remaining profile allowance fulfills the mandatory portion of Motion 51, and can allow for the optional portion of Motion 51 as allowed by the TP. • “A Defender with ROFR that elects to exercise ROFR during the Preemption and Competition process shall also be given the opportunity to simultaneously submit a revised transmission service capacity profile for the time periods subject to recall which may be at or below the service capacity remaining after preemption, indicating the final amount of service to be held by the Defender in the event the MATCHING request is denied due to other simultaneous matching opportunities being exercised by other Defenders.” The TP shall be obligated to either grant the MATCHING request in full or, if infeasible, to reduce the remaining transmission service obligation held by the Defender to the amount so indicated by the Defender.”

  8. Exercising rofr: items not addressed • The recommendation proposes a mechanism for exercising ROFR. It is not intended to address how specific scenarios should be implemented. • How will the Match and remaining profile be processed when: • The Match is infeasible due to exceeding the minimum term • The Match fails to meet the minimum term • The Match becomes infeasible due to system changes while in the pre-submittal workspace • How does the TP indicate that the remaining profile has been applied? • Can a Matching request be REBID and/or WITHDRAWN?

  9. Opting out of rofr • The defender may explicitly indicate their intent to NOT exercise ROFR by submitting the MATCHING request with status of QUEUED and the following information: • The MATCHING profile of the PRESUBMITTED MATCHING request set to 0 MW over time • Restatement of the remaining profile of capacity over time as stated in the PRESUBMITTED MATCHING request. This can be the same remaining profile provided by the TP, or a lower profile as allowed by the TP.

  10. Opting out of rofr (cont.) • This is part of the same response mechanism used to exercise ROFR. Only the information submitted to the TP has changed. • The discretionary portion of Motion 51 applies to the profile submitted when opting out of ROFR • “At the election of the TP such TP may, through its business practice standards, offer to the Defender with a confirmed reservation subjected to Recall or Displacement as a result of the Preemption and Competition process, the option to reduce some or all of the remaining capacity on the preempted reservation to an amount below the capacity remaining after preemption.”

  11. Questions?

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