NOTICE DATE:  September 20, 2013
NOTICE TYPE:  M-B113012-05 NPRR
SHORT DESCRIPTION:  Delayed Implementation of NPRR 416, Creation of the RUC Resource Buyback Provision
INTENDED AUDIENCE:  ERCOT Market Participants
DAY AFFECTED:  September 20, 2013
LONG DESCRIPTION:  ERCOT has identified a potential problem with the implementation of NPRR 416, Creation of the RUC Resource Buyback Provision, which is scheduled for release next week.  The NPRR requires QSEs to submit a Resource Status of ONOPTOUT for any Resource that opts out of a RUC commitment.  However, Protocols Section 6.5.7.6.1(4) allows a QSE to allocate its Regulation obligation among the Resources in its portfolio.  This creates a potential ambiguity because moving Regulation to a Resource requires the QSE to telemeter a Resource status of ONREG, ONOSREG, or ONDSRREG.
This ambiguity could be problematic.  If the QSE telemeters an ONOPTOUT status for a buyback Resource on which it intends to carry Regulation Service, the Load Frequency Control (LFC) system will not recognize the Resource as being available for Regulation dispatch.  This creates a reliability risk and a possible compliance risk in that ERCOT will not be able to dispatch the full amount of the committed Regulation. It also has a market impact in that the QSE will be short on its Regulation obligation.
Alternatively, if the QSE telemeters a status of ONREG (or ONOSREG or ONDSRREG) for a buyback Resource, that status would conflict with the previously submitted Current Operating Plan (COP) status of ONOPTOUT.  The disparity between the COP and telemetered status would result in an alarm for the ERCOT Operations Desk and would require the Operator to inquire about the issue with the QSE, drawing the Operator's attention away from potentially more critical obligations.  This would also conflict with the apparent intention of NPRR 416 to require an ONOPTOUT status for any buyback Resource.
While some may have expected that this NPRR would foreclose QSEs from moving a Regulation obligation to a buyback Resource, ERCOT must also consider the Protocol language allowing QSEs to allocate the Regulation obligation among its Resources.  Because of the potential operational, compliance, and market risks associated with implementing this NPRR with this ambiguity in place, ERCOT believes the more prudent course of action is to delay implementation of this NPRR until a broader stakeholder discussion of the proper approach can be had.  ERCOT intends to retain the Protocol text added by NPRR 416 in a gray-box until this ambiguity has been addressed.  Appropriate solutions may involve further system changes and/or a clarifying NPRR.  ERCOT expects to discuss these solutions with stakeholders at the next meeting of the QSE Managers Working Group on October 4, 2013.
Instead of extracting all code associated with NPRR 416 from the upcoming Project Release, ERCOT will simply implement an additional minor modification that will prevent the use of the ONOPTOUT status code.  The Market Manager User Interface will allow the user to select the ONOPTOUT Resource Status Code for COP submissions, but any attempt to submit that selection will be automatically rejected by ERCOT's systems.  Any telemetry of the Resource Status Code intended for ONOPTOUT status (Status Code 18) will not be recognized by ERCOT systems.
CONTACT:  If you have any questions, please contact your ERCOT Account Manager. You may also call the general ERCOT Client Services phone number at (512) 248-3900 or contact ERCOT Client Services via email at [log in to unmask]<mailto:[log in to unmask]>.
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