Adrian Pieniazek, NRG Texas and Randy Jones, Calpine
Urgent:
No
Sections:
1.3.1.1, 6.5.7.1.13
Description:
This Nodal Protocol Revision Request (NPRR) removes a requirement to post certain State Estimator information that can be used to determine Resource status, which is confidential information as per Public Utility Commission of Texas (PUCT) rules.
Reason:
State Estimator data includes transmission and transformer flow information as identified in paragraphs (4)(b) and (4)(d) of Section 6.5.7.1.13, Data Inputs and Outputs for the Real-Time Sequence and SCED. Because transmission and transformer flow data at generation-only busses reflects generation output, disclosure of this information would make it possible to determine Resource status information in Real-Time. Resource status information has consistently been considered competitively sensitive information in the competitive market and cannot be posted until 60 days after the operating day. See subsection (f)(3)(B)(iii) of P.U.C. Subst. R. 25.505, Resource Adequacy in the Electric Reliability Council fo Texas Power Region.
During the initial phases of Nodal Market testing, NRG Texas noticed that the posting of certain transmission information every hour, as required by Protocol Sections 6.5.7.1.13(4)(b) and (d), allows Market Participants to determine the actual output of Resources on the system. NRG Texas and Calpine filed comments and a proposed amendment to address this issue via NPRR 202, Clarification of Network Operations Model and State Estimator Postings, which restricted other information in the network model from being publicly posted. The proposed amendment was rejected, due in part to concerns that attempting to modify NPRR202 could hold up that NPRR’s implementation. Because NRG Texas and Calpine agree that the majority of NPRR202 is acceptable and neither entity wishes to hold up progress on NPRR202, they chose not to appeal the rejection of the proposed amendment. Instead, this new NPRR addresses the specific issues that are of concern to NRG Texas and Calpine.
PUCT Subst. R. 25.505(f)(3)(B) states: "Two months after the start of operation of the market under a nodal market design:
Offer curves (prices and quantities) for each type of ancillary service and for energy at each settlement point in the real-time market, shall be posted 60 days after the day for which the information is accumulated except that, for the highest-priced offer selected or dispatched for each interval on an ERCOT-wide basis, ERCOT shall post the offer price and the name of the entity submitting the offer 48 hours after the day for which the information is accumulated.
If the MCPE or the MCPC exceeds the event trigger during any interval, the portion of every market participant’s price-quantity offer pairs for balancing energy service and each other ancillary service that is at or above the event trigger for that service and that interval shall be posted seven (7) days after the day for which the offer is submitted.
Other resource-specific information, as well as self-arranged energy and ancillary capacity services, and actual resource output, for each type of service and for each resource at each settlement point shall be posted 60 days after the day for which the information is accumulated." (emphasis added)If Resource status information is available in Real-Time, in addition to being contrary to the PUCT rule, availability of this data may provide gaming opportunities. For example, the availability of such data may allow other generation owners to know when generation is not available in a certain area and raise their offer prices accordingly.