Market Renewal Program: Day Ahead Market (DAM) - Stakeholder Engagement Session 5 March 27, 2018 - Ieso
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DISCLAIMER This presentation and the information contained herein is provided for information and discussion purposes only. This presentation does not constitute, nor should it be construed to constitute, legal advice or a guarantee, representation or warranty on behalf of the IESO. In the event of any conflict or inconsistency between the information contained in this presentation and the Market Rules, the Market Manuals, any IESO contract or any applicable legislation or regulation, the provisions of the Market Rules, Market Manuals, contract, legislation or regulation, as applicable, govern. 2
Preliminary Decisions • Stakeholders have asked the IESO to bring forward preliminary decisions where possible. • These materials identify preliminary decisions and offer supporting rationale. • The IESO has made preliminary decisions where there is a single option or lack of viable alternative options, where there is substantial consensus by the IESO and stakeholders as to a preferred option, or where internal analysis has led the IESO to propose a specific solution. • Stakeholders are requested to use meeting time to discuss any comments, questions or concerns related to these preliminary decisions, and are also invited to provide written feedback. • Preliminary decisions are non-binding, are intended to facilitate progress on design elements, and are subject to final decision-making at the High Level Design Phase. 3
Acronyms DACP Day Ahead Commitment Process DAM Day-Ahead Market ELR Energy Limited Resources ERUC Enhanced Real-time Unit Commitment FTR Financial Transmission Rights HDR Hourly Demand Response LMP Locational Marginal Price MGBRT Minimum Generation Block Run-Time MLP Minimum Loading Point NDL Non Dispatchable Load NQS Non-Quick Start PRL Price Responsive Load RUC Reliability Unit Commitment SSM Single Schedule Market VG Variable Generation 4
Today’s Agenda 1. DAM project plan update for high level design – Where we are, what has been done and what is next 2. Design elements for today’s discussion – Recap preliminary decisions from Jan 31 meeting – Review Stakeholder Feedback – Present preliminary decisions for new primary and secondary level decisions 3. Next Steps – Stakeholder feedback – Topics for the May 23 meeting 5
Phases of High Level Design - Reminder • SE Meetings will be the primary vehicle for design discussions • In Phase 1 we will identify design elements, provide education, and define scope • In Phase 2 we will explore options for the design elements, provide analysis, as appropriate and develop preliminary decisions • In Phase 3 we will finalize decisions for all design elements and complete the HLD document • Throughout this process we are looking for stakeholders to actively and collaboratively work with us on the design 6
DAM Project Timeline for High Level Design Q4 2017 Q1 2018 Q2 2018 Q3 2018 Q4 2018 Q1 2019 Stakeholder Engagement Phase 1 Phase 2 Phase 3 1 2 3 4 5 6 7 8 9 10 11 Introduction & Fundamentals Options, Analysis & Preliminary Decisions HLD Market Renewal Working Group Strategic Issues and Design Decisions 7
Design Elements for Discussion Design Modules Design Elements Preliminary Decisions Primary Secondary A Participation and 1 Reference Quantity (formerly must-offer Revised from Jan 31 Today Input Data Requirements) 2 Load Participation Completed Jan 31 Today 3 Supply Participation: Variable Generation Completed Jan 31 May 23 Meeting 4 Reliability Input Parameters Completed Jan 31 N/A 5 Virtual Transactions (update only) Completed Jan 31 July 19 Meeting B Execution, Timing 6 Functional Passes Completed Jan 31 Today and Real-Time 7 Optimization of ELRs (update only) Completed Jan 31 May 23 Meeting Integration 8 Submission and Posting Deadlines Completed Jan 31 N/A 9 Initiation of Operational Commitments Completed Jan 31 N/A 10 Market Power Mitigation Completed Jan 31 Today 11 Price Setting Eligibility Completed Jan 31 N/A 12 Reporting Obligations July 19 Meeting N/A C Settlements 13 Two Settlement for Load Completed Jan 31 Today 14 Two Settlement for Supply Completed Jan 31 N/A 15 Make Whole Payments Today N/A 16 Uplift Recovery Today N/A 17 Financial Transmission Rights Completed Jan 31 N/A 18 Market System Failure July 19 Meeting July 19 Meeting 8
Meeting Objectives and Outcomes • Provide rationale for each of the preliminary decisions presented today: – Reference quantity (formerly must-offer) obligations – Price responsive load eligibility – Objectives and inputs of the functional passes for the DAM engine – Modified two settlement for non-dispatchable load participants – Eligibility for make whole payments – Uplift components and allocation • Articulate key concepts for virtual transactions • Present workplan with stakeholders on the optimization of energy limited resources in the DAM • Communicate expectations for stakeholder feedback and propose design element discussions for the May meeting 9
DESIGN ELEMENT DISCUSSIONS 10
REFERENCE QUANTITY (formerly must-offer) ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load Reference Functional Initiation of Two Settlement Quantity Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 11
Recap from Jan 31 Meeting • IESO brought forward a preliminary decision to revise the existing DACP must-offer requirement under a DAM – The existing DACP requirement does not address the potential for participants to physically withhold energy and operating reserve in order to raise DAM prices and profits – This decision would require coordination with the ICA project and its must-offer obligation • Today’s meeting will address how much capacity must be offered into the DAM for different resource technologies. 12
Stakeholder Feedback • It is not clear whether the must‐offer obligations apply to all future DAM participants, or only those that are brought to market via the ICA. • There are existing financial incentives that deal with the risk of physical withholding in some contracts. Adding additional must‐offer obligations may be punitive if those obligations are somehow conflicting with contractual terms. 13
Stakeholder Feedback • Capacity values from hydro facilities vary with hourly water conditions • Must-offer rules should only apply to water with a high degree of certainty leaving flexible and low certainty water to be offered into the real-time market • Methodologies and quantities need to be discussed and agreed to by stakeholders 14
Update • Ongoing discussion with the ICA project team revealed that our respective must-offer requirements should be designed independently – ICA wants to ensure resources satisfy their capacity obligation by offering their actual real-time capability – DAM wants to ensure resources are not exercising market power through physical withholding 15
Must-offer Requirement Name Change • This design element will be renamed to “Reference Quantity” moving forward – Differentiates it from the ICA must-offer obligation and aligns it with the design objective of preventing resources from physical withholding – “Reference Quantity” applies to all future DAM, ERUC and real-time market participant resources 16
Revised Preliminary Decision Previous Preliminary Decision: • Supply and load resources that are used to satisfy IESO resource adequacy requirements must offer energy and, if capable, offer operating reserve into the DAM. Revised Preliminary Decision: • All registered supply resources shall offer or forecast a reference quantity reflective of their expected energy availability, and if capable, all registered supply and load resources shall offer a reference quantity reflective of their operating reserve ramp capability into the DAM. – Revised decision clearly separates the reference quantity requirement from a capacity obligation and recognizes that loads are not incentivized to withhold energy 17
Reference Quantity for Energy • The amount of energy to be offered should vary for different resource technologies and account for: Mechanical Other Operating Restrictions Limitations (Fuel, Safety, Legal etc.) • We do not want participants to offer in capacity they are physically unable to deliver • Allows participants to reflect operational restrictions and manage financial risk under a two-settlement system 18
Defining the Reference Quantity for Energy Installed Capacity (Maximum Registered Capability) less the most restrictive of… Outages or • Restrictions that Deratings qualify as outage or reporting • Restrictions that do not requirements Pre- qualify as outage Approved reporting requirements • Grid incapability Operating • Could be discrete (easy (transmission outage) Restrictions to quantify on a continuous/periodic basis); or a • Range (difficult to quantify on a continuous/periodic basis) Reference Quantity 19
Pre-Approved Operating Restrictions in Other Jurisdictions • NYISO requires resources to register operating data and provide supporting documentation in order to recognize their operating restrictions and classify resources as: – Capacity Limited Resources (e.g. gas unit with inlet cooling capability) – Energy Limited Resources (e.g. hydro unit with a reservoir) – Ambient Condition Dependent Resources (e.g. gas unit with temperature based ratings) • Sets clear expectations for the must-offer requirement and rules out false positives when testing for physical withholding 20
Pre-Approved Operating Restrictions • Most operating restrictions should qualify as outage reporting requirements under the market rules • Pre-approved operating restrictions would not exempt resources from outage reportable restrictions • Would be captured through the facility registration process and could be updated as restriction conditions change 21
Pre-Approved Operating Restrictions • Potential operating restrictions that may differ from outage- reportable restrictions could include: Wind: Variable and intermittent fuel supply Solar: Variable and intermittent fuel supply Hydro: Head, streamflow, reservoir storage and recreational requirements Nuclear: None that the IESO is aware of Gas: None that the IESO is aware of Bio Fuel: Flow rate limitations that impact rate of biogas production Storage: Limited volume of fuel available in storage • Public safety, environmental, regulatory and legal requirements may also be valid restrictions for all resource types 22
Energy Reference Quantity Example 1 • Gas generator submits a forced derating to the IESO reflecting a capacity reduction due to high temperature and humidity Installed Capacity Variable Quantity Installed Capacity 100 MW Outages or Deratings Unavailable Outages / 20 MW Capacity Derates Pre- Approved Operating Pre-Approved N/A Restrictions Operating Restrictions Reference Quantity 80 MW Reference Quantity 23
Energy Reference Quantity Example 2 • An energy limited hydro resource registers a pre-approved operating restriction that reflects a regulatory range restriction in the summer Installed Capacity Variable Quantity Outages or Deratings Installed Capacity 80 MW Pre- Approved Operating Unavailable Outages / N/A Restrictions Capacity Derates Pre-Approved 20 – 40 MW Operating Restrictions Reference Quantity 40 – 60 MW Reference Quantity 24
Reserve Reference Quantity: Ramp Capability Most Restrictive Ramp Capability Time Period of the Operating for the Energy Reference Reserve Product Quantity (MW/min) (10 min or 30 min) 150 Energy Reference Quantity (MW) Ramp 10 20 30 (MW/min) Product Ramp Product Time Ramp x ≤ Energy Reserve (MW/min) Period (min) Time Period Reference Reference Quantity? Quantity 10 min OR 10 10 100 MW Yes 100 MW 30 min OR 10 30 300 MW No 150 MW 25
Test for Physical Withholding • A resource’s expected reference quantity for energy and/or operating reserve will be used to test for physical withholding as described in this morning’s presentation on market power mitigation for physical withholding
Questions for Stakeholders and Next Steps Wind Solar Hydro Nuclear Gas Bio Fuel Storage • Input that the IESO is looking for from Market Participants: – What operating characteristics should be captured in defining the proposed definition for pre-approved operating restrictions (with rationale)? • Do these operating restrictions translate into MWs (a discrete quantity or a range)? • When are these operating restriction effective (time of year, permanent, periodic or occasional)? – What issues might exist with implementing a range based reference quantity? 27
LOAD PARTICIPATION ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 28
Recap from Jan 31 Meeting Preliminary Decisions Rationale 1 Provide NDL the option of being a • Increase the efficiency of Price Responsive Load (PRL). PRLs scheduling and unit commitments submit their own bids into the DAM • Facilitates expanded participation and will receive a financially binding as dispatchable load in the future schedule, but would continue to be non-dispatchable in real-time. 2 The IESO will continue to bid on • Most efficient until a greater level behalf of all remaining NDL that are of load participation can be not registered as PRL. realized (e.g. load aggregators or load serving entities) • Today’s meeting will address which existing NDLs can elect to participate as PRL 29
Stakeholder Feedback • Providing opportunities for load to fully participate in the capacity and energy markets will allow for a competitive and efficient Ontario electricity market 30
PRL Eligibility • In the short term, the IESO expects the initial uptake of PRL status will come from industrial transmission connected or embedded loads that satisfy IESO registration requirements • As the market and sector continues to evolve, other loads, such as LDCs or aggregators may become PRL – Current regulatory requirements would limit the participation of LDCs as PRLs – Some participants, such as load aggregators, would have to meet metering and modelling requirements that may limit the amount of load they could bid for in the DAM. • Longer term, the PRL design is expected to be able to accommodate future regulatory, metering and modelling changes that might facilitate expanded load participation in the DAM. 31
Next Steps • No other decisions are required for high level design. • Any stakeholder feedback is requested and will be addressed on May 23. 32
TWO SETTLEMENT FOR LOAD ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 33
Recap from Jan 31 Meeting Preliminary Decisions Rationale 1 PRLs would be exposed to two Party responsible for bidding settlement upon receiving a financially should bear the financial binding DAM schedule responsibility of those bids 2 NDLs will also be exposed to two- Since the IESO will be responsible settlement, however the total sum cost for bidding on behalf of NDL, any (or benefit) of their real-time balancing balancing payments should be payments will be distributed amongst distributed in a non-discriminatory all NDL. manner • Today’s meeting will clarify NDL participant settlement and discuss how to distribute the cost or benefit of NDL real-time deviations from the IESO day ahead load forecast for NDL. 34
Recap: Two Settlement Day Ahead Real-Time (Balancing) QDA x $DA (QRT – QDA) x $RT • PRLs and DLs will submit their own bids into the DAM and be exposed to two settlement upon receiving a DAM schedule • NDL bids however, will be submitted by the IESO into the DAM on behalf of NDL market participants – A modified settlement approach is necessary for NDL participants considering the IESO uses a top-down approach in forecasting Ontario load and has little to no visibility for how much energy NDL participants may actually expect to consume at their location 35
Preliminary Decision and Rationale: NDL Settlement Modified Settlement for NDL $ForecastDeviation = cost or benefit of (QRT x $DA) + (QRT x $ForecastDeviation) forecast deviations on a per MW-consumed basis • NDL participants will only be exposed to day-ahead prices and a settlement if they actually consume in real-time – It is reasonable to assume that a NDL would not have bid into the DAM if they did not consume – QRT will therefore be used as the basis for NDL settlement • NDL participants that do consume in real-time will be exposed to a modified settlement and the total balancing cost or benefit of IESO forecast deviations will be prorated for each NDL based on their real-time consumption 36
Rationale: Balancing Settlement Distribution The IESO currently uses a top- Real-Time Day Ahead down, lower granularity approach (Balancing) in forecasting Ontario load QDA x $DA (QRT – QDA) x $RT Global Demand Forecast Distributing the Balancing overall cost or costs or benefit of load benefits could forecast Distribution be large for deviations factors are used some NDL among all NDL in projecting participants will more evenly load at a specific while small spread the cost location for others or benefit of these deviations 37
Balancing Settlement Distribution • The level for distributing the cost or benefit of NDL forecast deviations should be dictated by the granularity of the load forecast. – For example, a load forecast produced globally would dictate that the level of distribution should be global. – A load forecast produced globally and balancing costs distributed zonally could disproportionately benefit some zones and harm • Zonal distribution is generally favoured over global: – Produces prices that better reflect the marginal cost of consumption within the zone. – Provides a greater incentive for NDLs to respond to a zonal price recognizing this benefit would be reduced if they were also exposed to the cost of forecast deviations in other zones 38
Next Steps • The IESO is conducting an internal assessment on the feasibility to forecast load and manage forecast uncertainty at a zonal level. Global Demand Zone 1 Zone 2 Zone 3 Forecast Forecast Forecast Forecast • We will provide stakeholders with an update on our findings on May 23 and bring forward a preliminary decision of the level of socialization that can be achieved. 39
VIRTUAL TRANSACTIONS ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 40
Recap from Jan 31 Meeting • The need for virtual transactions in the initial implementation of a DAM depends on the level of risk market participants will be exposed to: Reduced need if IESO is bidding for most NDL; VG is forecasting into DAM under contract Increased need with greater PRL participation; VG is forecasting into DAM when contracts expire 41
Recap from Jan 31 Meeting Preliminary Decisions Rationale 1 The capability for virtual Virtual transactions are proven market based transactions will be included mechanisms that provide both efficiency and in the DAM high level design. disciplinary benefits for both participants and the IESO. 2 The decision as to whether Virtual transactions would be new to Ontario and they will be deployed for the additional education should be provided for initial implementation of stakeholders to understand how they could make DAM requires further use of virtual transactions in addition to the risks discussion with stakeholder. they may introduce if not carefully implemented. • Educational materials on virtual transactions will be posted shortly. • Today’s session will provide a summary of key concepts and illustrative examples on the use of virtual transactions. 42
Stakeholder Feedback • Virtual transactions should be included in the DAM at a nodal level 43
Virtual Transactions: Introduction • Virtual transactions are financial instruments used to buy and sell Real-Time Day Ahead (Balancing) energy in the DAM just like physical energy bids and offers. (QRT – QDA) x QDA x $DA + $RT • They are evaluated just like physical bids and offers, can receive a DAM schedule and are subject to two settlement QDA x $DA + – QDA x $RT • Since they do not represent physical load or supply, real-time quantities are always zero and their balancing settlement is always for their full DAM QDA x ($DA - $RT) schedule. 44
Virtual Transactions: Settlement Virtual Supply Virtual Load Sells MWs into the DA Buys MW from the DA market at the DA price market at the DA price Buys those MWs from the Sells those MW into the RT RT market at the RT price market at the RT price QDA is positive QDA is negative Virtual supply profits when Virtual load profits when $DA > $RT $RT > $DA QDA x ($DA - $RT) -QDA x ($DA - $RT) = QDA x ($RT - $DA) 45
Key Benefits of Virtual Transactions 1. Improve day-ahead and real-time price convergence by enlarging the pool of participants in the DAM – If $DA > $RT, virtual supply offers correct the imbalance by increasing QDA and drive $DA downward towards $RT – Conversely, if $DA < $RT, virtual demand will drive $DA upward towards $RT 2. Provide ways for loads and suppliers to manage their exposure to real-time price excursions – Generally not needed for load to hedge this risk at its own physical location, but could benefit a supplier – More prevalent in hedging bilateral contract price risk at another location 46
Virtual Transactions and Price Convergence 47
Physical Supplier Using Virtual Load • A generator must-offer 100 MW into the DAM to meet its reference quantity requirement but is concerned about RT price exposure because of a 10% derate risk (10 MW risk) • The generator could protect DAM revenues by scheduling a 10 MW virtual load bid, the 10 MW derate occurs and QRT > QDA QDA $DA DAM Rev QRT $RT RT Rev NET QDA x $DA (QRT – QDA) x $RT Rev Generator protects $100 Gen 100 $30 $3000 90 $40 (90-100) x 40 = -$400 $2600 of DAM revenue (Keeps $2700 vs. $2600) Virtual Load -10 $30 -$300 0 $40 (0- (-10))x 40 = $400 $100 • However if the 10 MW derate does not materialize and QRT < QDA, the generator will lose DAM revenue due the virtual load loss QDA $DA DAM Rev QRT $RT RT Rev NET QDA x $DA (QRT – QDA) x $RT Rev Generator loses $100 of Gen 100 $30 $3000 100 $20 (100-100) x 20 = $0 $3000 DAM revenue (Keeps $2900 vs. $3000) Virtual Load -10 $30 -$300 0 $20 (0- (-10))x 20 = $200 -$100 48
Physical Load Using Virtual Supply • A physical load seeking to hedge the risk of increased load consumption at a higher RT price at its own location could perform the reverse action of the generator in the previous example by submitting a virtual supply offer QDA $DA DAM Rev QRT $RT RT Rev NET QDA x $DA (QRT – QDA) x $RT Rev Load avoids $100 Load -90 $30 -$2700 -100 $40 (-100-(-90)) x 40 = -$400 -$3100 (Pays $3000 vs. $3100) Virtual Supply 10 $30 $300 0 $40 (0- (10))x 40 = -$400 $100 • However the load does not need a virtual supply offer to achieve this. It could simply schedule more of its physical load in the DAM QDA $DA DAM Rev QRT $RT RT Rev NET Load still avoids $100 QDA x $DA (QRT – QDA) x $RT Rev (pays no more than Load -100 $30 -$3000 -100 $40 (-100-(-100)) x 40 = $0 $3000 $3000) • This approach to hedging works because the DAM schedule and RTM physical injection or withdrawal occur at the same location. 49
Lessons Learned in Other Jurisdictions • Other jurisdictions with DAMs have reported that virtual transactions have helped to converge DAM and RTM prices – Physical load and supply take production or forecast uncertainty into account when offering into the DAM – Virtual transactions can proxy for physical load or supply that have been underbid into the DAM and have caused DAM and real-time prices to diverge – Virtual transactions can lengthen the time required to execute the DAM and have an impact on DAM engine performance – ISOs have taken steps to address performance issues by limiting the locations at which virtual transactions may be bid or offered and limiting the numbers of bids or offers per market participant 50
Next Steps • Additional educational materials will be posted shortly – Stakeholders are asked to review and submit follow up questions or comments ahead of the May meeting Secondary Decisions Next Steps 1 Timing of implementation • Discuss benefits and risks • Deploying on day one of DAM vs. on May 23 break-in period • Present preliminary decisions in July 2 Trading volume and impact on DAM • Discuss benefits and risks solution time on May 23 • Determining modelling • Present preliminary granularity (zonal vs. nodal) decisions in July and/or limits on virtual bid/offer quantities 51
FUNCTIONAL PASSES ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 52
Recap from Jan 31 Meeting Preliminary Decision Rationale 1 Apply Market Power Incremental energy and operating reserve costs Mitigation and NQS resource parameters must be mitigated on an ex-ante basis in single schedule markets. 2 Run RUC within DAM Allows reliability based commitments to be reflected in DAM schedules and prices, increasing operational certainty and supporting day ahead to real-time price convergence 3 Calculate Settlement Required in order to provide participants with Ready Prices accurate financially binding schedules. • Today’s meeting will address objective functions and input criteria for each functional pass 53
Preliminary Decision: Pass Objectives • The objectives for each of the functional passes will be similar to those already used in DACP today: 1 2 3 Bid Commitment Reliability Unit Final Scheduling & Commitment Pricing •NO CHANGE: •NO CHANGE: •NO CHANGE: Determine NQS Determine Determine final unit whether resource commitments additional NQS schedules needed to meet unit •NEW: bid load. commitments are Determine DAM •NEW: Market needed to meet clearing prices Power Mitigation IESO forecasts 54
Preliminary Decision: Pass 1 Input Changes 1 • Determine NQS unit commitments needed to meet Bid Commitment bid load. Bid Commitment • Apply market power mitigation. DACP Inputs DAM Inputs Rationale MP Supply Offers and No Change Forecasts (Dispatchable Gen, Self-Schedulers and Imports) IESO elected VG forecast MP elected VG forecast VG resources will be responsible for submitting their own forecast MP Load Bids (Dispatchable No Change Load, HDR and Exports) IESO average load forecast PRL bids and IESO avg. load NDL will have the option of for NDL forecast for remaining NDL becoming a PRL No Virtual Bids/Offers Virtual Bids/Offers Virtual transactions can participate in the DAM 55
Preliminary Decision: Pass 2 Input Changes 2 Reliability Unit • Determine whether additional NQS unit Commitment commitments are needed to meet IESO forecasts. DACP Inputs DAM Inputs Rationale NQS unit commitments from Pass 1 No Change MP Supply Offers and Forecasts (Dispatchable No Change Gen, Self-Schedulers and Imports) IESO elected VG forecast No Change IESO is responsible for reliability; therefore IESO forecast will continue to be used for assessment. MP Load Bids (Dispatchable Load, HDR and No Change Exports) IESO peak load forecast for NDL No Change IESO is responsible for reliability; therefore IESO forecast will continue to be used for assessment No Virtual Bids/Offers No Change Virtual transactions do not physically contribute to meet system reliability 56
Preliminary Decision: Pass 3 Input Changes 3 Final Scheduling & • Determine final resource schedules and DAM Pricing clearing prices. DACP Inputs DAM Inputs Rationale NQS unit commitments No Change from Pass 2 MP Supply Offers and No Change Forecasts (Dispatchable Gen, Self-Schedulers and Imports) IESO elected VG forecast MP elected VG forecast VG resource schedules and clearing prices will be based on MP elected VG forecasts MP Load Bids (Dispatchable No Change Load, HDR and Exports) IESO average load forecast PRL bids and IESO avg. load PRL schedules and clearing prices for NDL forecast for remaining NDL will be based on PRL bids No Virtual Bids/Offers Virtual Bids/Offers Virtual schedules and clearing prices will be based on virtual bids 57
Next Steps • No other decisions are required for high level design. • Stakeholder feedback is requested and will be addressed on May 23. 58
OPTIMIZATION OF ELRs ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 59
Recap from Jan 31 Meeting Preliminary Decision Rationale 1 Do not retain the DACP • Fairness and Competition - retaining the resubmission window resubmission window under a DAM would for cascade hydro provide one group of participants the potential to resources under a DAM. improve their financial positions but harm others’ 2 Determine alternative • Implementability - a reduced overall DAM ways for ELRs to duration will make it easier to introduce engine manage operational and enhancements as the market evolves (e.g. financial risks under a modelling and evaluating new technologies, DAM. virtual transactions etc.) • Today’s session will be used to • Review market participant feedback • Provide stakeholders with additional information on how cascade hydro resources are managed in other DAMs • Outline a process for addressing decision 2 above 60
Stakeholder Feedback • The following feedback for ELR optimization in the DAM was received: – Cascade hydro modelling within the DAM engine – Offer linking capabilities in both DAM and real-time market – Increasing self scheduling capabilities – Deferring the start time of DAM so that offers could better reflect anticipated conditions in real-time – Compliance/settlement aggregation and the use of one virtual delivery point for all stations on a cascade river system – Recognizing energy limitations in the must-offer requirement 61
Key Observations in Other Markets • As a general observation the responsibility for managing operational and financial risk usually lies with the market participant – Participants are in the best position to most efficiently manage these risks – Typically these risks are managed through offer curve submissions • Where risks leading to inefficient market outcomes are identified to be due to market design and tool limitations, such as for cascade hydro, system operators do provide some degree of mitigation such as: – Modifying offer requirements (market rules) – Modelling generic offer parameters that participants can couple with their offer curves • Market designs strive to achieve a fair balance of risk that leads to efficient market outcomes 62
Typical Offer Strategies • Cascade resources typically manage their operating characteristics through their offer curves – Offer desired quantities at lower prices and undesired quantities at higher prices, for example: Dispatchable G1 for 2 hrs at high $ G1 for 4 hrs at low $ (Flexible) Strategy G2 for 2 hrs at low $ G2 + G3 for 4 hrs at high $ Illustration G3 for 2 hrs at high $ 2 hrs G1 G2 G3 4 hrs • These base strategies are used in other DAMs with cascade hydro penetration similar to Ontario (i.e. New York and California) 63
Dispatchable Strategy: Potential Barriers • Offers strategies can also be used to exercise market power and the DAM will include features designed to mitigate these behaviours: Behaviour Mitigation Physically withholding supply in must-offer Requirements – the order to increase margins for other minimum quantity a resource must- remaining supply. offer into the DAM Economically withholding supply Reference Levels – price caps that by offering at very high prices replaces the offer price of a resource during tight supply conditions . when it is deemed to be economically withholding • While these measures are necessary, they may further limit a cascade resource’s ability to generate feasible DAM schedules through their offer curves 64
Dispatchable (Flexible) Strategy • Cascade resources can also couple additional parameters with their offer curves to minimize the risk of an infeasible DAM schedule: – Daily Energy Limits (do not schedule > X MWh per day) – Forbidden Regions (do not schedule between X MW and Y MW) • The NordPool (Norway) DAM has a much larger penetration of hydro (~95%) and provides participants with the ability to link offer curves between resources G1 offer must first be economic for G2 and G3 offers to be considered 2 hrs G1 G2 G3 4 hrs 65
The NordPool Market • Linked offer capabilities are available to all participants (i.e. technology neutral) • Linked offers can be more easily accommodated because their day ahead market engine is less complex – Less processing time needed because they do not account for the same level of transmission constraints that North American markets are required to account for in determining day ahead market schedules 66
Alternative Offer Strategies • Cascade resources could alternatively choose to self-schedule their resources in the DAM in order (non-dispatchable strategy) – Submit fixed quantities irrespective of price, for example: Self Scheduled G1 for 2 hrs at 0 MW G1 for 4 hrs at X MW (Inflexible) Strategy G2 for 2 hrs at X MW G2 + G3 for 4 hrs at 0 MW Illustration G2 for 2 hrs at 0 MW 2 hrs G1 G2 G3 4 hrs • This strategy is used by cascade hydro in the PJM market, however their hydro penetration is < 5% 67
Self Schedule (Inflexible) Strategy • Self scheduling strategies also create risk for both the market participant and the IESO – Market participant becomes a price taker, which still leaves them financially exposed because they have no ability to respond to lower prices that may not cover marginal costs – IESO loses the flexibility that dispatchable resource can provide in managing forecast uncertainty and providing standby energy (operating reserve) – Market outcomes are more costly because they are less efficient • The market design should not incentivize cascade resources to participate as self-schedulers 68
Aiming for a Flexible Offer Strategy • IESO will be working with stakeholders to implement a solution that allows cascade resources to participate in the day-ahead market within an acceptable level of risk. • Potential solutions include but are not limited to: – Striking a balance between must-offer Requirements and Reference Levels for Mitigation – Retaining the ability for Daily Energy Limits and Forbidden Regions to be submitted and optimized by the DAM engine – Introducing additional features such as linked offers 69
Next Steps • Continue investigating potential solutions that would allow cascade hydro resources to participate in the DAM within an acceptable level of risk. • Present findings and secondary decisions to stakeholders on May 23. 70
MAKE WHOLE PAYMENTS ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 71
Recap from Jan 31 Meeting • No preliminary decisions were brought forward, however two broad make whole scenarios were identified for consideration based on best practices and lessons learned in other jurisdictions: DAM energy and operating reserve Day-ahead Margin Assurance revenues are less than DAM offer Payments (DAMAPs). costs • Today’s session will address which of these make whole scenarios will apply and what the eligibility criteria are for each. 72
Triggers: DAM Revenues < DAM Offer Costs • There are constrained up and down events in the DAM where energy and operating reserve prices and revenues may not cover a resource’s as offered/bid costs into the DAM. How can Automatically during DAM Manually through out-of-market these occur? scheduling DAM operator actions Respecting resource operating To address reliability issues the Why do they parameters, price formation rules DAM may not recognize (e.g. occur? and IESO Reliability Unit local adequacy; extreme events) Commitment requirements • DAM make whole payments provide assurance offers and bids into the DAM will be recovered for the amount of the resource’s DAM schedule, which encourages efficient bids and offers. 73
Preliminary Decisions and Rationale: Make Whole when DAM Revenues < DAM Costs Preliminary Decision Rationale 1 The following resources • Self schedulers are non-dispatchable are ineligible: price takers who submit forecast • Self Schedulers schedules that do not reflect a • Non-Dispatchable Load resource’s costs • Virtual Transactions • Non-Dispatchable Loads are also price takers that the IESO submits forecast schedules for • Virtual transactions are purely financial instruments that do not have production costs 74
Preliminary Decisions and Rationale: Make Whole when DAM Revenues < DAM Costs Preliminary Decisions Rationale 2A All NQS resources will be eligible for NQS resources are scheduled a make whole payment if their based on minimum load energy, operating reserve and requirements and start-up commitment costs are not covered by and speed no load costs in the energy and operating reserve addition to their incremental revenues earned over their entire energy and operating reserve DAM schedule. costs. 75
Preliminary Decisions and Rationale: Make Whole when DAM Revenues < DAM Costs Preliminary Decisions Rationale 2B NQS resources must actually come online in • Current practice for order to qualify for a make whole payment DACP and common covering start up costs: practice in all other • Fully covered if the resource comes online jurisdictions. before the 30th min of their 1st scheduled hour • Reduces uplift as at MLP costs are only covered • Partially covered if the resource comes online if they are actually between 30 and 90 min of their 1st scheduled being incurred. hour at MLP (1/12th deducted for every 5 min • Incentivizes timely the resource is late to start) start-up for ISO • Not covered if the resource comes online reliability after 90 min of their 1st scheduled hour at requirements MLP 76
Preliminary Decisions and Rationale: Make Whole when DAM Revenues < DAM Costs Preliminary Decisions Rationale 2C NQS resources must actually come • Current practice for online in order to qualify for a make DACP and common whole payment covering speed no practice in all other load costs jurisdictions. • Fully covered if the resource • Reduces uplift as costs delivers energy for the full hour are only covered if • Partially covered at 1/12th of the they are actually being cost for every 5 min of delivery incurred. within an hour 77
Preliminary Decisions and Rationale: Make Whole when DAM Revenues < DAM Costs Preliminary Decision Rationale 3 All remaining supply and load Unlike NQS resources, all resources, including imports and remaining supply and load exports, will be eligible for a resources are only scheduled based make whole payment in every on their incremental energy and hour that their energy and operating reserve costs. operating reserve costs are not covered by their revenues. 78
Day Ahead Margin Assurance Payments • Lessons learned in other jurisdictions show certain real-time dispatch scenarios may unintentionally encourage resources to reduce their real-time dispatch flexibility to avoid balancing costs and protect DAM profits – Ramp-limited coal-fired generators that are unable to reverse their ramp direction quickly enough – An illustration for the described scenario is provided on the next two slides 79
Rationale for DAMAP in other Jurisdictions Issue Real-Time Output DAM Schedule Unit must buy out of DAM Unit is schedule at high price, dispatched reducing DAM margins below DAM schedule due to Price spike falling prices occurs, unit gets dispatched back up but is slow to turn- around. 80
Rationale for DAMAP in other Jurisdictions Undesired Response Real-Time Output DAM Schedule Day ahead buy out risk reduced Unit reduces its ramp rate offer to reduce risk of quick dispatch turnaround 81
Update and Next Steps • While the IESO doesn’t foresee a need for a DAMAP since coal has been decommissioned, analysis is being performed to determine if a DAMAP would be appropriate for slower ramping gas resources. – IESO is currently analyzing historical data to identify instances where a DAMAP may be appropriate – Results of the analysis and preliminary decision will be presented on May 23 82
UPLIFT RECOVERY ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 83
Recap from Jan 31 Meeting • No preliminary decisions were brought forward since the make whole payment design was still being developed. • With a make whole proposal now in place, today’s session will revisit uplift discussions from the fundamentals phase and provide preliminary decisions for recovery and disbursement. 84
Recap from Fundamentals Phase • The only uplift charges currently allocated to participants under DACP are make whole payments for NQS unit commitments (i.e. day ahead production cost guarantees) • Transitioning to a DAM will introduce additional uplift components for which allocation decisions are required: – DAM make whole payments for energy – DAM operating reserve costs 85
Status in Other Jurisdictions • All other DAMs do not levy uplift charges based on the two- settlement principle; no uplift recovery is settled in the DAM – Levying a charge on DAM load would discourage loads from scheduling in the DAM to avoid the charge. – Therefore uplift charges are only levied to all real-time loads and exports on a per MWh basis • Some DAMs allocate a portion of uplift costs to specific resources based on cost causation – Appropriate only if these costs can be allocated accurately and consistently, and incentivize efficient behaviour – For example, allocating a portion of commitment cost make whole payments to underbid load and virtual supply 86
Preliminary Decisions and Rationale Uplift component Allocation Rationale 1 DAM make whole All real-time Will not discourage loads and payments for loads and exports from participating in the incremental energy and exports DAM. commitment costs 2 DAM operating reserve costs 3 DAM energy residuals TBD Pending decisions on the disbursement methodology for these residuals being discussed in SSM. 87
Secondary Decisions and Next Steps • Will a portion of commitments costs coming out of the DAM reliability unit commitment pass be allocated to specific DAM resources? – Considerations include only allocating these uplift costs to underbid load and virtual supply, following best practice and lessons learned in other jurisdictions • A decision will be proposed on May 23 88
FINANCIAL TRANSMISSION RIGHTS ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 89
Recap from Jan 31 Meeting Preliminary Decision Rationale 1 External FTRs will External FTRs should be settled at DAM be settled at DAM prices in order to provide a hedge for prices congestion charges on day-ahead schedules (real-time congestion charges are already hedged by a participant’s DAM schedule). • Today’s session was intended to address how internal FTRs (i.e. disbursement of residuals) would be settled – This decision is on hold until the SSM project brings forward a final decision on the disbursement methodology currently being discussed with stakeholders. 90
SUBMISSION AND POSTING DEADLINES ISO and MP Inputs DAM Engine DAM Outputs & RT Settlements Market Processes Two Settlement Submission & Posting Deadlines for Load must-offer Functional Initiation of Two Settlement Requirements Passes Operational Make Whole for Supply Commitments Payments Load Optimization of Make Whole Participation Energy Limited Reporting Payments Resources (ELRs) Obligations VG Supply Uplift Participation Price Setting Eligibility Recovery Virtual FTRs Market System Failure Transactions Reliability Input Market Power Mitigation Parameters Process, Timing and Reference Levels 91
Recap from Jan 31 Meeting Preliminary Rationale Decision Execute DAM A posting deadline of no later than 12:30 EST between ~ 09:00 ensures DAM schedules are available to market and 12:30 EST participants before the gas nomination window closes at 14:00 EPT (during daylight savings time). • While there were no further decisions planned for high level design, stakeholders provided feedback on the preliminary decision • Today’s session will be used to highlight the feedback received 92
Stakeholder Feedback • A submission deadline equal to or after 10:00 EST would: – Have greater alignment with neighbouring jurisdictions – Increase offer certainty since forecast conditions improve as the day progresses and – Provide participants more time to inform their offers during normal business hours • Market renewal could be an ideal opportunity for the IESO to consider moving from EST to EPT across all timeframes in order to have greater alignment with other jurisdictions 93
RECAP AND NEXT STEPS 94
Summary of Preliminary Decisions • Reference quantity obligations will apply to all registered resources capable of providing energy and/or operating reserve and will account for outage and non-outage related restrictions – IESO is looking for participants to provide input on non-outage related operation restrictions that may apply to their resources • The PRL design is expected to be able to facilitate expanded load participation in the DAM from existing NDL participants. • Objectives for the DAM functional passes remain very similar to the current DACP. New inputs into the DAM will include: – Variable generator elected forecasts – Price responsive loads bids – Virtual transactions 95
Summary of Preliminary Decisions • A modified settlement equation will apply for NDL participants since the IESO will be bidding in the load forecast on their behalf. – The level of distribution of NDL balancing costs will depend on the level of forecast granularity that can be achieved (i.e. zonal or global). • Eligible resources will qualify for a make whole payment when their DAM revenues do not cover their as-offered DAM costs. – Eligibility criteria differs between NQS resources and all other resources. • DAM uplift will be allocated to all real-time loads and exports – A portion of DAM uplift may apply to certain DAM participants if cost causation can be determined with certainty. This preliminary decision will be presented at the next meeting. 96
Next Steps • Feedback on pre-approved operating restrictions (see slide 27 for details) requested by April 13 • Feedback on remaining preliminary decisions requested by April 27 • Design element decisions for the May meeting include: Design Elements Preliminary Decisions Being Brought Forward 3 VG Supply Participation VG submission and interaction procedures with existing IESO centralized forecasting procedures 7 Optimization of ELRs Alternative ways for cascade hydro resources to manage operational and financial risks under a DAM 18 Two Settlement for Load Forecast granularity and distribution level of balancing payments for NDL 16 Make Whole Payments Whether a Day Ahead Margin Assurance Payment will be included in the DAM design 17 Uplift Recovery Whether to allocate a portion of DAM make whole payments to DAM participants that specifically contributed to those costs. 97
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