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TAC ADR Task Force Presentation to TAC 6 May 2005

TAC ADR Task Force Presentation to TAC 6 May 2005. Why is this important to you?. Why is this important to you?. Changes to a QSE’s load will change its load imbalance (LI) dollar amounts, ERCOT Administration charge, and Load Ratio Share (LRS).

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TAC ADR Task Force Presentation to TAC 6 May 2005

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  1. TAC ADR Task Force Presentation to TAC6 May 2005

  2. Why is this important to you?

  3. Why is this important to you? • Changes to a QSE’s load will change its load imbalance (LI) dollar amounts, ERCOT Administration charge, and Load Ratio Share (LRS). • Net changes to the total ERCOT load imbalance (LI) dollar amounts will be uplifted through Balancing Energy Neutrality Adjustment (BENA) based on LRS. • Changes to a QSE’s LRS will change the amount uplifted to them for OOMC, OOME, Black Start, etc. • Most likely there would not be changes to the total load for ERCOT.

  4. Introductions

  5. Participating Market Participants

  6. Overview • Introductions • SCOPE and Relevant Protocols, PURA, and PUC Rules • Retail Data Variance & Wholesale Settlement Brief • Interpretations of Protocols • ERCOT’s • TXU’s and Other’s

  7. Overview (continued) • Discussion of Legal Perspectives • ERCOT • TXU • TEAM • Direct Energy • OPC • Issues, Advantages, and Disadvantages of the Interpretations • TAC discussion, questions and answers, and VOTE

  8. Scope Of Task Force The Task Force reached unanimous consensus regarding the Scope of the ADR Taskforce: The ADR Task Force will provide education to TAC relative to the issue of the denial of outstanding post-true up load imbalance ADRs

  9. Scope Of Task Force (cont.) The Task Force agreed that: • The Task Force was not resolving the outstanding ADRs and • The Task Force was not attempting to resolve how to deal with post-True Up Load Imbalances occurring in the future – that is currently a COPS assignment

  10. Relevant Cites Provided • ERCOT Protocols Sections 2, 9, 10, 11, 15 & 20 • Section 9: Settlement & Billing (9.2.5 - .7, 9.4.4) • Section 10: Metering (10.1, 10.2.2, 10.2.3.1, 10.3.3.1, 10.11.3) • Section 11: Non-EPS Metered Points (11.2.2) • Section 15: Customer Registration (15.1.1.9, 15.1.2.8, 15.3, 15.4, 15.4.1, 15.4.1.4, 15.5) • Section 20: Alternative Dispute Resolution Procedures (20.1, 20.2.3 • PURA (§§ 38.005 & 39.151(1)) • PUC Rules (§§ 22.251, 25.28, & 25.480) • Including only 6 mos. for back billing

  11. Retail Data VariancesandWholesale Settlement

  12. Review Items • Data Aggregation & Settlements Process • ERCOT Data Loading • System Change Request 727 (SCR 727) • Data Extract Variances (DEV) and Settlements • DEVs and Settlement Disputes • Resettlements and the 2% Threshold • Charge Types Impacted by Resettlement after True-Up

  13. Protocols Section 10 & 15 Protocols Section 15 Data Aggregation & Settlements Process Data Aggregation Process Retail Usage Data TDSP Retail Load Data Aggregation Aggregated REP Load Profiling Loss-adjusted REP Load UFE-Adjusted REP Load (AML) Apply T&D Losses Calculate and Allocate UFE Registration Data Settlements Generation Data Limited Gen & NOIE Data Generation & Zonal Meter Data Aggregation Generation, DC Tie, & NOIE Meters Gen/Zonal Data Retrieve Data

  14. ERCOT Data Loading - Usage 10.11.3 TDSP Polled Settlement Meters TDSPs are responsible for providing ERCOT with [data that has been edited, validated, and is appropriate for ERCOT Settlement Agent to use for settlement and billing purposes] for the TDSP polled meters on their system and for ensuring that at a minimum the VEE requirements as specified in the Uniform Business Practices (UBP) standard for Validation, Estimating and Editing have been properly performed on such data. ERCOT will not perform any VEE on the Settlement Quality Meter Data it receives from TDSPs.

  15. ERCOT Data Loading - Usage 15.3 Monthly Meter Reads Each TDSP shall send monthly consumption information for all ERCOT Non-EPS ESI IDs within its service area to ERCOT not later than three (3) Retail Business Days after the scheduled meter read cycle or scheduled meter cycle by day of the month for a Point of Delivery, using the SET 867_03. TDSPs shall send monthly consumption information for all ESI IDs associated with EPS metered Facilities to ERCOT no later than three (3) Retail Business Days after TDSP receipt of daily EPS meter data from ERCOT according to the TDSP scheduled meter read cycle or scheduled meter cycle by day of the month for a Point of Delivery, using the867_03. ERCOT will forward ERCOT accepted consumption information to the CR within one (1) Retail Business Day. If the meter read for an ESI ID fails the TDSP’s internal validation procedures, the TDSP may, at its discretion, delay sending consumption information for the ESI ID to ERCOT for an additional seven (7) days in order to obtain a valid meter reading. If a TDSP is unable to obtain a meter reading for an ESI ID because the TDSP is denied access to the meter, the TDSP may, at its discretion, delay sending consumption information for the ESI ID to ERCOT for an additional seven (7) days in order to obtain a valid meter reading. A TDSP, with notification to the market, may suspend the transmission of monthly consumption information during periods of storm restoration or other emergency operations undertaken pursuant to its Emergency Operations Plan. For non-ERCOT ESI IDs, TDSPs shall have the option of sending monthly consumption information and effectuating meter reads to ERCOT using the 867_03. ERCOT will then forward the monthly consumption and meter read information to the CR within one (1) Retail Business Day.

  16. ERCOT Data Loading – ESI ID Information 15.4 Electric Service Identifier (ESI ID) Each TDSP Service Delivery Point (SDP) shall have a unique number within Texas. Once this unique number has been created and assigned to a SDP, it shall not be re-issued, even in the event of termination of the associated point-of-service. This unique number shall be referred to as the Electric Service Identifier (ESI ID). 15.4.1.4 New ESI ID Creation Since it is anticipated that the ESI ID will be based on the existing TDSP account or Premise numbers (with a prefix identifying the TDSP), the TDSP will assign and submit to the registration database ESI IDs for new Premises as service is extended to them. TDSPs that opt-in after the market startup will be responsible for the creation of ESI IDs for all existing SDPs in their service territory. The TDSP will send ESI ID information using the 814_20. ERCOT will verify that this transaction meets SET specifications. ERCOT will respond to the TDSP within one (1) Retail Business Day, with acceptance or rejection of these transactions using the 814_21. At least the following data elements are required to be sent in the 814_20: (1) ESI ID; (2) Service Address; City, State, Zip; (3) Load Profile Type; (4) Meter Reading Cycle or Meter Cycle by day of month; (5) Station ID; (6) Distribution Loss Factor code; and (7) Premise Type.

  17. ERCOT Data Loading – ESI ID Information 15.5 Database Changes The TDSP will notify ERCOT of any changes in information related to an ESI ID for which it is responsible. The TDSP will send changes to ERCOT using the 814_20. ERCOT will respond to the TDSP within one (1) Retail Business Day, using the 814_21. In addition, ERCOT will send all affected CRs notice of the changes using the 814_20. Each CR will reply to ERCOT using the 814_21. The TDSP is responsible for the following data elements: (1) Service Address; City, State, Zip; (2) Load Profile Type; (3) Meter Reading Cycle or Meter Cycle by day of month; (4) Station ID; (5) Distribution Loss Factor code; (6) Eligibility Date; (7) Meter Type; (8) Rate class and sub-class, if applicable; (9) Special Needs Indicator; (10) Meter type, identification number, number of dials and role for each meter at the ESI ID, if ESI ID is metered; (11) For unmetered ESI IDs, number and description of each unmetered device; and (12) Premise Type.

  18. ERCOT Data Loading • ERCOT performs validations (TX Set, ANSI, and business validations) on transactions prior to loading data into ERCOT systems • ERCOT’s settlement system (Lodestar) contains only a current view of ESI ID data – historical records are maintained in the archive • Settlement occurs with the data that is current in Lodestar at the time of the run (best available at the time of each settlement run)

  19. SCR 727 Extracts and Data Extract Variances What are SCR 727 extracts? • Extract of ESIID level data loaded into ERCOT systems and used for Settlement (usage, ESI ID characteristics, REP relationship, etc) • Provided to TDSPs and LSEs for data transparency • Delivered daily How are they used by Market Participants? • Compare SCR 727 extract data to internal source system data • Identify data discrepancies • Report discrepancies as Data Extract Variances (DEVs) and work to reconcile them

  20. History of SCR 727 & True-Up Settlements Mar 14, 2003 – First DEVs submitted for 2001 & 2002 July 8, 2003 – Began True-Ups for 4/21/02 forward 2003 2004 2005 June 1, 2004 – Began True-Ups for 2003 Dec 2003 – New SCR 727 released Mar 3, 2003 – SCR 727 first released to Market July 2003 – MPs identified a data discrepancy in SCR 727 Oct 15, 2004 – Completed True-Ups for 20030 Sep 30, 2003 – Completed 2002 True-Ups Feb 2004 – BOD voted to start 2003 True-Ups on 6/1/04 Dec 5, 2004 – Caught up on True-Ups (current within 6 months) May 13, 2003 – Began resettlingTrue-Ups (1/1/02 – 4/20/02) Sep 16, 2003 – BOD voted to suspend 2003 True-Ups Jan 23, 2003 – BOD suspends true-up for 2002 (had completed 1/1/02 – 4/20/02)

  21. History of SCR 727 & True-Up Settlements Operating Day Initial Settlement Final Settlement True-Up Settlement Day 105 Day 0 Day 17 Day 59 Day 180 Day 170 Deadline for DEV to be filed timely for correction prior to True-Up Deadline for Disputes on Initial, Final, or any Resettlements 10 Business Days (Timely Dispute Deadline) 10 Business Days (Dispute Deadline) - Time period for timely disputes - Time available for DEV resolution - Time period for dispute submission

  22. DEV LSEs Adjusted Meter Load (AML) Disputes QSEs Load Imbalance = Schedule – AML DEVs and Settlement Disputes ESI ID data

  23. DEVs and Settlement Disputes • DEVs: • Generally filed between Final Statement & True-up Statement (must be filed 75 days prior to issuance of True-up) • Generally filed by REPS using the FasTrak tool • Disputes: • Filed on settlement charges in question • Example: Load Imbalance • Filed by the QSE using settlement dispute tool

  24. Load Imbalance Disputes • Load Imbalance Disputes • ERCOT Process • Work with QSE to verify shadow settlement system calculations • Work with QSE to verify dispute is related to data variances • If cause is other than data variance • Work with ERCOT staff to correct data issues • Corrected data used in next settlement run • If cause is data variance • Communicate that ERCOT settled based on data provided by TDSPs as prescribed in ERCOT protocols • After SCR 727 • Communicate with QSE that data variances need to be worked through the DEV process

  25. Resettlements – Protocols Reference Language 9.2.5 Resettlement Statements A Resettlement Statement will be produced using corrected settlement data due to resolution of disputes, correction of data errors or a short pay situation, as described in Section 9.4.4, Partial Payments. Any Resettlement occurring after a True-Up Statement has been issued must meet the same IDR Data Threshold requirements defined in Protocol Section 9.2.6. The Board may, in its discretion, direct ERCOT to run Resettlement of any trade day to address unusual circumstances. Resettlement due to data error will occur when the total of all significant errors in data results in an impact greater than two-percent (2%) of the ERCOT Operating Day market transaction dollars, excluding bilateral transactions. A Resettlement Statement of this sort will be produced as soon as possible to correct the errors. ERCOT will review this percentage on an annual basis. Upon this review, ERCOT may make a recommendation to revise this percentage in accordance with Section 21: Process for Protocols Revision.

  26. Resettlements • ERCOT produces Resettlement Statement for: • Resolution of disputes • Correction of data errors • When the total of all significant errors in data results in an impact greater than two-percent (2%) of the ERCOT Operating Day market transaction dollars • Short pay situation • As directed by the ERCOT Board • ERCOT’s Practice of 2% threshold: • ERCOT calculates 2% of the absolute value for each service (line item on the Revenue Equalization Report) • ERCOT sums those amounts for the Operating Day • This is the 2% threshold amount

  27. Charge Types Impacted by Resettlement After True-Up • Question: What charge types are impacted by resettling 2001 & 2002? • Answer: It Depends! • Charge types affected due to data changes since the last resettlement • Data changes may occur for several reasons • Each type may affect different charge types

  28. Load (ESI ID) Data Changes • Continuously changing through retail data transactions • Will account for almost all of the changes if 2001 and 2002 are resettled • No data changes for wholesale delivery points would be expected • Affected Charge Types: • Load Imbalance • BENA • Any Load Ratio Share allocated charges  • Black Start and RMR Capacity Charges • Local Balancing Energy Service Charge • OOM Energy Charge • Administrative Fee Charge • System Congestion Fund (was in effect in 2001) • etc...

  29. Generation Resource-ID Data Changes • Minimal changes expected for Generation Resource data if 2001 and 2002 are resettled • Affected Charge Types: • Generation Output (GSITETOT) based payments such as the following • RI • Local Balancing Energy Payment • OOM Energy Payment • RMR and Black Start Energy Payments • Generation Output (GSITETOT) based charges such as the following • URC • BENA • Load Ratio Share Allocation of the above charge types • Black Start and RMR Capacity Charges • Local Balancing Energy Service Charge • OOM Energy Charge • etc... • Any change in generation will change Load and Load Ratio Share values • All the charge types listed for Load changes on prior slide will be affected • Magnitude of change is significantly smaller

  30. Other Data Changes • There may be some miscellaneous manual data changes entered after the last settlement statement run that did not trigger a Resettlement Statement but would be included if ERCOT resettles these Operating Days

  31. Questions?

  32. Confidentiality Issues • ADRs are confidential • Initially difficult to discuss Task Force’s issues because of abstract nature • TXU provided an ADR example, generally, to assist in understanding the nature of the beasts • The tale of two cities (their Loads and ESI IDs)

  33. ERCOT’s Perspective – Andrew Gallo

  34. ERCOT’s Perspective • Protocols §2 • Data Aggregation System The database and communication system that will collect meter data from TDSPs…. • Meter Data Acquisition System The system to obtain…Settlement Quality Meter Data from the TDSP for settlement and to populate the Meter Data Aggregation System and ERCOT Data Archive. • Settlement Quality Meter Data Data [from the TDSPs] that has been edited, validated, and is appropriate for ERCOT Settlement Agent to use for settlement and billing purposes.

  35. ERCOT’s Perspective • TDSPs: • “are the only entities authorized to provide Settlement Meter data.” (§10.1) • “are responsible for supplying ERCOT with meter data associated with…all Loads in the ERCOT system.” (§10.2.2) • “are responsible for…providing consumption data for each ESI ID….” (§10.3.3.1(1)) • “are responsible for…Validating, Estimating and Editing (VEE) meter data…before submitting data to the settlement process.” (§10.3.3.1(4)) • “are responsible for…metering all Loads by May 1, 2001….” (§10.3.3.1(6))

  36. ERCOT’s Perspective • TDSPs: • “are responsible for providing ERCOT with [data that has been edited, validated and is appropriate…to use for settlement and billing purposes] for the TDSP polled meters on their system….” (§10.11.3) • “provide data for TDSP Metered Entities.” (§11.2.2) • “shall send monthly consumption information for all ERCOT Non-EPS ESI IDs….” (§15.3) • must “create, assign, maintain and retire, as necessary, an ESI ID to each SDP in its service area.” (§15.4.1) • “will assign and submit to the registration database ESI IDs for new Premises as service is extended to them.” (§15.4.1.4)

  37. ERCOT’s Perspective • TDSPs: • assign a Station ID to an ESI ID to inform ERCOT the sub-station for the ESI ID (§15.4.1.4) • At least the following data elements are required to be sent…: (1) ESI ID; (2) Service Address; City, State, Zip; (3) Load Profile Type; (4) Meter Reading Cycle or Meter Cycle by day of month; (5) Station ID; (6) Distribution Loss Factor code; and (7) Premise Type. • ERCOT maps the sub-stations to the CMZs. • Depending on which sub-station assignment the TDSP provides, ERCOT puts the ESI ID in the corresponding CMZ.

  38. ERCOT’s Perspective • TDSPs: • “will notify ERCOT of any changes in information related to an ESI ID for which it is responsible.” (§15.5) • are “responsible for the following data elements:” (§15.5) (1) Service Address; City, State, Zip; (2) Load Profile Type; (3) Meter Reading Cycle or Meter Cycle by day of month; (4) Station ID; (5) Distribution Loss Factor code; (6) Eligibility Date; (7) Meter Type; (8) Rate class and sub-class, if applicable; (9) Special Needs Indicator; (10) Meter type, identification number, number of dials and role for each meter at the ESI ID, if ESI ID is metered; (11) For unmetered ESI IDs, number and description of each unmetered device; and (12) Premise Type.

  39. ERCOT’s Perspective PURA §38.005 requires that “transmission and distribution utilities” must “comply with any operational criteria duly established [ERCOT] or adopted by the commission.” In essence, ERCOT has followed the requirements of the Protocols in settling the Operating Days at issue.

  40. Legal Perspectives • TXU – Brad Jones • TEAM • Direct Energy – Ryan Thomason • OPC – Laurie Pappas

  41. TXU’s Perspective PURA Protocols

  42. TEAM’s Perspective Analysis of PURA and ERCOT market protocols provide the following viewpoints relating to ADR application and management. Though preliminary, the insight provided by the analysis points below raises further questions regarding the validity of the ADRs that are before the market.

  43. TEAM’s Perspective ØThe Protocols are adopted by ERCOT through authority delegated by the PUC under PURA § 39.151(i). These Protocols were reviewed and approved by the PUC (See, P.U.C. Docket No. 23220). The Protocols are an extension of the PUC’s rules and are not contractual provisions.

  44. TEAM’s Perspective ØThe establishment of the 2% threshold in Protocol 9.2.5 does not authorize ERCOT to resettle for data errors below the 2%. The language in the protocol that requires this threshold to be revisited annually implies that there is no discretion for ERCOT to resettle based on data errors below this threshold.

  45. TEAM’s Perspective • The ADR provisions in Chapter 20 of the Protocols do not allow an ADR to be held for an extended period of time. Protocol 20.1 states that Parties shall exercise good faith efforts to timely resolve ADRs. • Also, there are specific timelines for processing any pending ADR request. If the ADR is not resolved, there are also specific trigger points that initiate the 35 day window for appealing the action/inaction to the PUC under P.U.C. Proc. R. 22.251.

  46. Direct Energy’s Perspective It is Direct Energy’s position that the Market Protocols dictate the proper avenues of resolving a dispute or an ADR whether or not the Market Participant is satisfied with the outcome of the resolution. Direct Energy would like to affirm ERCOT’s current interpretation and practice regarding the “2% Rule”, as set forth in Section 9.2.5 of the Protocols.

  47. Direct Energy’s Perspective Section 9.2.5 Resettlement Statement states : • “Resettlement due to data error will occur when the total of all significant errors in data results in an impact greater than two-percent (2%) of the ERCOT Operating Day market transaction dollars…” • According to ERCOT, the claimants’ stated dollar value does not meet the 2% Market threshold. • Direct Energy cannot recall any incident where ERCOT circumvented Section 9.2.5 so as to accommodate a Market Participant. Is this true?

  48. Office of Public Utility Counsel’s Perspective • PURA • PUC Rules • Protocols

  49. TAC ADR Task Force Interpretation of Protocols

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