To table NPRR519 and to refer the issue to WMS and the Credit Work Group (Credit WG)
Passed
Background
Status:
Approved
Date Posted:
Feb 6, 2013
Sponsor:
ERCOT
Urgent:
No
Sections:
16.2.1, 16.17
Description:
This Nodal Protocol Revision Request (NPRR) exempts those Qualified Scheduling Entities (QSEs) that represent only Emergency Response Service (ERS) Resources and that do not participate in the Day-Ahead Market (DAM), Real-Time Market (RTM) and Congestion Revenue Right (CRR) markets ("ERS-only QSEs") from the collateral and financial statement reporting requirements in Section 16.11, Financial Security for Counter-Parties, and from each of the various requirements in Section 16.16, Additional Counter-Party Qualification Requirements, including those relating to capitalization, certification, and the verification of a risk management framework. Upon notifying ERCOT of its election to move to ERS-only status, ERCOT would verify that the QSE meets the relevant requirements, including having a Total Potential Exposure (TPE) of zero, before authorizing this designation. If a QSE wishes to terminate its ERS-only status in order to participate in other ERCOT markets, it must provide advance written notification to ERCOT and must demonstrate compliance with the relevant collateral and capitalization requirements before receiving approval to terminate.
Reason:
The collateral, capitalization, and various other related requirements in Sections 16.11 and 16.16 should not apply to ERS-only QSEs because their participation in ERS does not expose ERCOT to any significant risk of default. Unlike participation in the RTM, DAM or CRR market, participation by a QSE in ERS typically results only in a one-way transaction—a payment from ERCOT to the QSE based on (1) the offer accepted by ERCOT prior to the ERS Standard Contract Term and (2) the QSE’s performance and availability during the ERS Standard Contract Term. Because ERS QSEs do not typically owe sums to ERCOT, those measures designed to reduce financial risk exposure of ordinary Counter-Parties are unnecessary in the context of ERS. ERS QSEs would be obligated to pay ERCOT only in the limited circumstance of an overpayment identified in a resettlement of ERS. In that case, ERCOT would require limited collateralization of any exposure until the overpayment is repaid but would not require compliance with capitalization and reporting requirements.