This Nodal Protocol Revision Request (NPRR) clarifies what type of documentation Qualified Scheduling Entities (QSEs) must submit to ERCOT as proof of natural gas purchases when requesting additional compensation for fuel costs incurred when providing Reliability Unit Commitment (RUC) services. The NPRR further clarifies which documents are deemed acceptable as proof of fuel purchases and directs QSEs to request ERCOT Board approval for documentation not covered by the Nodal Protocols.
Reason:
This NPRR is being submitted by ERCOT to clarify the type of evidence a QSE must supply to ERCOT as proof of fuel purchases made intra-day as a result of providing a RUC service. The existing language in Section 9.14.7 was introduced with NPRR174, FIP Modifications in Verifiable Startup and Minimum Energy Costs and Recovery of Exceptional Fuel Costs During RUC Intervals. This language, however, is not clear on the type of documentation a QSE must file with ERCOT as proof of fuel purchases.
The intent of NPRR174 was to compensate QSEs for fuel purchases made intra-day to recover the costs of spot market fuel as a result of a RUC deployment and the QSE’s inability to make arrangements to purchase fuel in advance of the RUC deployment, since a QSE may not know if a particular Resource is going to be deployed by RUC before the gas market closes during the early hours of the Day-Ahead Market (DAM). Hence, it was the intent of the market to allow for additional compensation of intra-day fuel purchases whenever the QSE showed proof of such costs. However, ERCOT does not believe the intent of the market was to allow as documentation bilateral contracts between a QSE and a third party unless the third party’s primary business is providing (buying, selling or transporting) fuel services. ERCOT is of the opinion that if bilateral contracts between two parties are allowed as proof of fuel purchases, there is no incentive for QSEs to negotiate for "the best price" knowing full well that the incremental costs above the Fuel Index Price (FIP) used by ERCOT in establishing fuel costs can be recuperated via a Settlement dispute.