January 12-13, 2016 | NEPOOL Markets Committee| Milford MA - PowerPoint Presentation

January 12-13, 2016 | NEPOOL Markets Committee| Milford MA Chris Geissler EconomistMarket Developmentcgeissler@iso-ne.com | 413.535.4367 FCM Zonal Demand Curves

2 FCM Zonal Demand Curves WMPP ID: 63 Proposed Effective Date: FCA 11 ISO is proposing new zonal demand curves for the FCA Improve locational price signals in the FCM Better reflect incremental reliability impact of capacity than existing (fixed) zonal requirements Derived using a methodology that satisfies three core design principles Robust to zonal configuration changes Comply with FERC Order requiring zonal curves for FCA 11 This meeting: Discuss stakeholder and filing schedule in light of Dec. 28 FERC Order Robustness of proposed curves to upward-sloping supply curves and year-over-year variation New results on price volatility Proposed elimination of administrative pricing rules for zones

Agenda For Today December 28 FERC Order Requires ISO to file sloped zonal demand curves by March 31, 2016Updated Local Sourcing approachModifications to the transfer capability assumptions for import-constrained zonal demand curvesNew sensitivity analysesResults using new simulation models with stepped upward-sloping supply curves that model entry and exit Price volatility analysisComparison of volatility between ISO’s proposal and current system demand curve and zonal requirementsAdministrative pricing rules ISO proposes to discontinue several administrative pricing rules in import-constrained zones 3

Additional Materials Available ISO memo titled ‘Administrative pricing rules under the proposed demand curve design for FCA 11’Discusses ISO’s decision to discontinue administrative pricing provisions as part of proposal FCM Simulator Excel fileAllows market participants to see market clearing prices and under a range of demand curves, supply conditions, and zonal configurationsISO technical memo on FCM Demand Curve Methodology (Dec 7, 2015) 4

Updates to This Presentation Updated the historical supply model (Model 3) results for FCA 10 zonal configurationIncludes performance results with and without NNE export zoneClarified explanations in two sections:Edits to ‘Updated Local Sourcing Approach’ section New figures to explain ‘New Sensitivity Analysis’ resultsAppendices now include additional results requested by stakeholders: Indicative demand curves and model results for FCA 9 zones including Maine export zone that was tested but not includedUpdated results for hybrid (‘bolt-on’) approach Requested cost-to-load impact analysis by load zone5 Updated 1/22/16

December 28 FERC Order Requires ISO to file sloped zonal demand curves by March 31, 2016 6

7 December 28 FERC Order FERC Order requires “ISO-NE to submit Tariff revisions by March 31, 2016 providing for zonal sloped demand curves to be implemented beginning in FCA 11” (p. 16) Previous project schedule had the ISO filing shortly after the April PCTo adhere to the Order, the schedule needs to be modified to meet the March 31st deadline set by FERC (next)

Potential Project Schedule 2016 (1 of 3) Jan. 2016 Administrative pricing rules; further quantitative and qualitative results for ISO’s and stakeholders’ proposalsFeb. 2016 Continued discussion and results; Tariff language; potential amendments raised March 2016 Continued discussion and results; final Tariff language (ISO proposal and amendments); Markets Committee vote Tentative 2016 MC Schedule 8 Potential for additional MC meetings within each month as needed

Updated Committee Schedule (2 of 3) Jan. 2016 Discussion of reliability outcomes and zonal capacity transfer capability assumptions under ISO proposal Feb. 2016 Continued discussion; Tariff language March 2016 Reliability Committee vote Tentative 2016 RC Schedule 9

Potential Project Schedule (3 of 3) Late March 2016 PC vote ( additional meeting) March 31 FERC filing. Tent. effective date June 2016. Implementation February 2017 Tentative Filing Schedule 10

Committee Discussions To-Date Oct. MC Overview of ISO’s revised approach Nov. MC Details of ISO’s method; assumptions and computed demand curves for FCA 10 zones; process and timing for annual updates Dec. MC ISO’s results for other zonal possibilities (e.g., FCA10 zones with an added export zone); initial results for alternate, stakeholder approaches 2015 Schedule 11

Updated Local Sourcing Approach Modifications to the capacity transfer capability assumption used to derive import-constrained zonal demand curves 12 Updated Section

13 ISO is Modifying its Local Sourcing Approach Ahead Next:Initial transfer capability assumptions and stakeholder concernsUpdated methodology uses a revised transfer capability assumptionNew transfer capability assumption produces a sensible demand curve for SENEResults with FCA 10 inputs and new SENE demand curveAdditional discussion on reliability benefits and outcomes begin at January Reliability Committee meeting

14 Previous Import Limit Assumptions ISO’s initial design presented in Nov./Dec. calculated zonal MRI curves assuming the N-1-1 import limit into import-constrained zonesN-1-1 is an input to the TSA calculationExisting LRA calculation uses N-1 import limitExisting import zone requirement is higher of TSA, LRA Stakeholders voiced concerns that using the N-1-1 import limit assumption would be inappropriate in the context of zonal demand curvesISO testing of other scenarios identified that using N-1-1 could produce zonal curves well to the ‘right’ of TSA at all possible prices Not this project’s intent to raise overall zonal reliability requirements

15 Updated Local Sourcing Approach ISO’s updated capacity transfer capability assumption builds on the current methodology used to generate the Local Sourcing Requirement based on both the TSA and LRA values“For each import-constrained Capacity Zone, the Local Sourcing Requirement shall be the amount needed to satisfy the higher of: (i) the Local Resource Adequacy Requirement as determined pursuant to Section III.12.2.1.1; or (ii) the Transmission Security Analysis Requirement as determined pursuant to Section III.12.2.1.2 .”MRI calculations now assume capacity transfer capability is: (N-1 limit) – max(TSA-LRA,0)Starts with N-1 limit, but includes adjustment based on difference between TSA and LRA to account for second contingency Yields zonal curves that are ‘between’ what would be obtained using true (N-1) and (N-1-1) import limit valuesShifts import-constrained zonal demand curves to the left relative to previous assumption

16 Example: SENE Capacity Transfer Capability FCA 10 Input Parameters:N-1-1 Import Limit = 4,600 MWN-1 Import Limit = 5,700 MWLocal Resource Adequacy (LRA) = 9,584 MWTransmission Security Adequacy (TSA) = 10,028 MW Revised capacity transfer capability assumption for SENE zonal MRI calculations is: 5,700 MW – max(10,028 TSA - 9,584 LRA, 0) = 5,256 MWThis implies a lower (‘left-shifted’) zonal demand curve than using the N-1-1 import limit value ( see next).

17 Indicative SENE (Congestion Pricing) Demand Curve Notes: LRA = 9,584 MW, TSA = 10,028 MW for SENE in FCA 10.

18 Curve Observations for SENE N-1-1 import limit leads to a congestion price of $8.50 at LSR The illustration shows N-1 import limit paying a congestion price of $0.06 at LSRISO proposal falls in between extremes – pays a congestion price of approximately $0.80 at LSR under the conditions illustrated

19 ISO Proposal (1 of 4) – System-Level Results

20 ISO Proposal (2 of 4) – SENE Import Zone Results

21 ISO Proposal (3 of 4) – NNE Export Zone Results

22 ISO Proposal (4 of 4) – Rest-of-System Results

23 Summary of Results Forward-looking supply models produce similar results with updated SENE zonal demand curvesBase case model meets 1-day-in-10 criteria (as design intends)When clearing prices are lower than estimated Net CONE, estimated reliability (LOLE) is above criteriaWhen clearing prices are higher than estimated Net CONE, estimated reliability (LOLE) is below criteriaWhen there is price separation between ROP and the import-constrained zone, less capacity is cleared in the import zone, and more cleared in rest-of-system

24 Updated Methodology Produces Sensible Curves Capacity transfer capability assumptions for import-constrained zones incorporate the “higher of” logic of existing TSA and LRA rules, accounting for 2nd contingency calculationsLess conservative than previous N-1-1 import limit assumption, leading the zonal curves to be shifted to the left In SENE, produces a modest but positive congestion price at the LSR MW value

New Sensitivity Analysis Results using new simulation models with stepped upward sloping supply curves that model entry and exit 25

26 Stepped Supply Curve Model Ahead Next:Outline stepped supply curve model and its assumptionsModel uses numerous simulated supply curves that are:Stepped and upward slopingAllow independent entry and exit in each simulationAnalyze performance of demand curves under this supply model relative to ‘base case’ supply model Do average prices and reliability vary significantly?Compare price volatility of proposed curves to existing system curve and zonal requirements

27 Stakeholder Requests for Additional Supply Models In earlier presentations, the ISO evaluated the performance of the proposed curves using two types of supply models‘Forward looking supply’ models that assume flat supply at a range of prices‘Historic supply’ models that generate simulated supply curves from recent FCAs, where supply curves were steep Stakeholders requested that the ISO also evaluate supply curves that:Are upward sloping, but not as steep as the historical dataVary year-over-year as suppliers enter and exit the market

28 Stepped Supply Model - Overview Supply curve uses step function rather than having a constant slope‘Supply block’ quantities and locations are randomly sampled from qualified capacity for FCA 10Available at http://www.iso-ne.com/markets-operations/markets/forward-capacity-marketOffer prices are modeled to yield an (assumed) overall average supply curve slope A simulated system supply curve

29 Stepped Supply Model - Simulations Model includes year-over-year variation by allowing new resources to enter the market, and existing resources to exitEntry and exit are randomly determined independently in each simulationCreate variation in supply curve that allows for price and quantity volatilitySimulated supply curves are calibrated so that on average, they pass through NICR at Net CONE Brattle’s simulation models (in prior demand curve work) were calibrated so that on average, they yield 1-in-10 reliability at Net CONE

30 Stepped Supply Model – Entry and Exit When a new resource (A) enters, supply curve shifts right by additional capacity at offered priceCleared capacity increases from Q1 to Q2Clearing price decreases from P1 to P2When an existing resource (B) exits, supply curve shifts left by removed capacity at its offer price Cleared capacity decreases from Q 1 to Q 3 C learing price increases from P 1 to P 3

31 Stepped Supply Model – Model Parameters 1000 simulations for each scenarioTwo scenarios for average slope of supply curves:‘Modest Slope’ – with each additional 100 MWs of capacity supply offered, price increases by $0.30 in ROP, $0.45 in SENE (on average)‘Steep Slope ’ with each additional 100 MWs of capacity supply offered, price increases by $0.50 in ROP, $0.75 in SENE (on average) Entry and exit in each simulationAssume between 0 and 10 entrants with equal probability Assume between 0 and 10 resources exit with equal probabilityEntry and exits randomly drawn If resource A is 1 MW and resource B is 600 MWs, each is equally likely to enter or exit

32 Stepped Supply Model Simulated Supply Curves New Slide Example: 10 (out of 1,000) simulated s upply curves, Moderate Slope s cenario

33 Stepped Supply Model Does Not Simulate Multiple Years as Sequential ‘Paths’ Each simulation is independentStart with same stepped supply curve, then randomly determine entry/exitModeling over multiple years is complexRequires conditional probabilities of entry and exit that are dependent on current ‘state of the world’ (supply curve in previous simulation)Due to its complexity, time constraints, and limited additional information it provides, ISO is not planning to develop a multi-year supply model

34 Stepped Supply Model Results Assume FCA 10 zonal configuration and demand parametersEvaluate the performance of the demand curves against the new supply curves in two ways:How do average prices and reliability change relative to the base case supply model where the market always clears at a price of Net CONE?How does price volatility compare between current rules and the ISO’s proposed curves under this supply model?

35 System Results (1 of 3)

36 SENE Results (2 of 3)

37 Rest-of-System Results (3 of 3)

38 Key Observations from Results With the stepped supply curve analyses, averages prices remain in the range of Net CONEAverage reliability is slightly lower in stepped supply-curve simulation analyses, but remains quite close to the 1-in-10 criteriaLow reliability outcomes and high clearing prices occur infrequently

Price volatility analysis Comparison of volatility between ISO’s proposal and current system demand curve and zonal requirements 39

40 Price Volatility of Proposed Demand Curves Ahead Next:ISO’s forward looking supply models yield no price volatilityIn previous Markets Committee meetings, stakeholders requested additional ISO analysis on price volatilityUse stepped supply model to compare price volatility under ISO’s proposed demand curves to that with current rules Price volatility is modest and similar under each set of demand curves

41 Volatility Analysis Variables Consider the volatility of three variables under ISO’s proposal and current system curve with vertical zonal requirementsClearing priceCleared quantityTotal market payments

42 Volatility is Comparable Between ISO Proposal and Current Rules Price volatility is conventionally measured by the standard deviation of pricesStandard deviation of prices is comparable between current rules and ISO proposal$0.65 vs $0.59 with modest-slope stepped supply $1.10 vs $0.98 with steep-slope stepped supplyQuantity volatility is much smaller under the ISO proposal Flatter demand curves tend to produce greater quantity volatilityHigher quantity volatility under status quo demand curve may yield more uncertainty for a new entrant about whether it would clear

43 Clearing Rules Help Decrease Price Volatility ISO’s proposal substitutes capacity between zones in the clearing processWhen FCA clears more in the ROP zone, it will tend to clear less in an import constrained zoneIn the simulations, we do observe a negative correlation between quantity cleared in ROP and SENEConsider a simulation where a large, low-price resource enters in ROP zone: Shifts ROP supply curve to the right, increasing cleared quantity in the ROP and decreasing system price This shifts the zonal demand curve ‘down’, since the zonal demand curve specifies a congestion price ‘adder’ to the system priceThis decreases the cleared quantity in the import zone as wellThe reduction in cleared quantity in the import zone partially offsets the change in the system priceImplies that the system price still falls, but by less because zonal and system clearing is interdependent – reducing system price volatility

44 Summary: Price Volatility is Comparable with the ISO’s Proposed Curves and Existing Rules Produces modest price volatility that is comparable to current system curve and fixed zonal requirementsPrice volatility concerns are partially mitigated by interaction between zones in how market is clearedVolatility is tempered as the stepped supply curve becomes flatter

Administrative Pricing Rules ISO proposes to discontinue several existing administrative pricing rules in import-constrained zones 45

46 Elimination of Administrative Pricing Provisions Ahead Next:Overview of current provisionsFERC Order and recent historyExisting administrative pricing provisions are inconsistent with the ISO’s proposal and sound market fundamentalsSloped demand curves and mitigation better address the concerns that originally led to administrative pricing rules

47 Administrative Pricing Rules ISO has three administrative pricing rules in the FCA:Inadequate Supply (IS): pays existing capacity an administratively determined price when there is not sufficient supply to meet the capacity requirement (III.13.2.8.1)Insufficient Competition (IC): pays existing capacity an administratively determined price when there is not sufficient existing supply to meet the capacity requirement and there is limited new capacity (III.13.2.8.2) Capacity Carry Forward Rule: pays all capacity an administratively determined price when a non-rationable entrant cleared in a recent auction which causes total existing capacity to exceed the Local Sourcing Requirement (III.13.2.7.9)

48 January 24, 2014 FERC Order FERC Order stated “we find that the Tariff’s current administrative pricing for existing resources in situations of Inadequate Supply and Insufficient Competition are unjust and unreasonable” (p. 28) The administrative pricing rules were eliminated at the system level coincident with introduction a system sloped demand curve for FCA 9Existing administrative pricing rules were retained in import-constrained zones, where the auction continued to procure fixed requirementsCoincident with sloped demand curves in constrained zones, the ISO proposes to eliminate the remaining administrative pricing rules

49 Existing Administrative Pricing Provisions are Inconsistent with ISO Proposal ISO’s proposed design pays capacity in each zone based on its marginal reliability impactWhen paying existing less than entrants (as under IS and IC), this property cannot hold for both new and existing resourcesInstead, existing resources get paid less than if they were paid based on their marginal reliability impactSends wrong price signal:E.g. Higher prices paid to existing capacity in Import Zone A when the marginal reliability impact of capacity is higher in Import Zone B Can discourage entry and encourage exit in areas where capacity is most needed

50 Other Concerns with Existing Administrative Pricing Provisions Introduce distortions that encourage participants to bid inconsistently with their true valuation to:Ensure that trigger conditions are met/not metExploit expected price difference for existing capacity between primary auction and reconfiguration auctions Require subjective design elements that are difficult to defend based on economic fundamentals including: Trigger conditions (when to pay different prices)Pricing schedule (what to pay different ‘types’ of resources)Entrants will submit higher priced supply offers because they expect to receive lower capacity payments in future years (when IS or IC condition is triggered)

51 Sloped Demand Curves and Mitigation Provide Protection Against Non-Competitive Outcomes Sloped zonal curves decrease the potential price impacts associated with withholding capacity or lumpy new entryReduces potential payoff associated with such behaviorMitigation process more directly addresses concerns with non-competitive outcomesPrevent existing supply from withholding capacity or submitting inflated delist bids into the auction Process now includes imports, and pending FERC approval, may include Non-Price Retirement Requests (NPRR) beginning in FCA 11Minimum Offer Price Rule (MOPR) addresses buyer-side market power concerns

52 ISO Proposal Discontinues Existing Administrative Pricing Rules Current rules are not compatible with ISO’s proposed designProvisions use subjective criteria that are not consistent with sound market fundamentalsCreate perverse incentives and may increase long-run costs to consumersSloped demand curves and market mitigation better address concerns with non-competitive auctions

53 Chris Geissler (413) 535-4367 | cgeissler@iso-ne.com

Appendix 1 Results table footnotes

55 Results table footnotes with FCA 10 zones plus indicative NNE export-constrained zone These results model one import zone in southeast New England ("SENE") and one export zone in northern New England (“NNE”). NICR is 34,151 MW, SENE LSR is 10,028 MW, and NNE MCL is 8,830 (see August PSPC materials at http://www.iso-ne.com/static-assets/documents/2015/08/pspc_082715_a3.2_2019_20_fca_icr_resuts.pdf). Models 1 and 2 assume market participants submit bids consistent with the full Pay for Performance design, so supply offers are at Net CONE. No random bids are simulated for Models 1 or 2. Demand curves derived for the Model 1 Base Case assume the FCA 10 estimated ("administrative") Net CONE value of $10.81 per kw-month Model 2 Sensitivity Cases use the same demand curves as in the Model 1 Base Case, and report performance results for the FCA if bid/offer prices are above/below est. Net CONE.Model 3 uses the same demand curves as in the Model 1 Base Case, but evaluates performance and payments by simulating 1000 hypothetical supply curves using supply bid/offers from the three most recent Forward Capacity Auctions (FCA7 - FCA9)Results in (B) use the same assumptions as in the Model 1 Base Case, except the demand curves are derived using the estimated ("administrative") Net CONE values shown. Model 6a assumes a slope of 0.003 in Rest-of-Pool and a slope of 0.0045 in SENE. It randomly allows up to 10 resources to enter and exit and runs 1000 simulations. Model 6b assumes a slope of 0.005 in Rest-of-Pool and a slope of 0.0075 in SENE. It randomly allows up to 10 resources to enter and exit and runs 1000 simulations.

Appendix 2: FCA 9 Zonal Demand Curves and Results Assessing the ISO’s proposal with smaller constrained zones 56 New Slide

57 Demand Curves in Smaller Constrained Zones Stakeholders requested additional information on shape of curves in smaller zonesIndicative demand curves for Connecticut, NEMA and SEMA import constrained zonesResults tables for a system with these zonesPosted an Excel file with the curve data for each zone New Slide

58 Demand Curve Assumptions Estimated Net CONE is $10.81FCA 9 input assumptionsNet ICR = 34,189CT LSR = 7,331 (TSA)NEMA LSR = 3,572 (TSA)SEMA LSR = 7,479 (LRA)For more information see http://www.iso-ne.com/static-assets/documents/2014/08/2018-19_fca_icr_values_pspc_08282014.pdf New Slide

59 Indicative System Demand CurveUsing FCA 9 Inputs Notes: NICR = 34,189 MW for FCA 9 . New Slide

60 Indicative Connecticut (Congestion Pricing) Demand CurveUsing FCA 9 Inputs Capacity Quantities and Slopes at Selected Prices Congestion Price $1.00 $2.00 $5.00 $10.00 MW Quantity 7,157 6,969 6,721 6,514 Slope (per 100 MW) -$0.35 -$0.77 -$1.75 -$3.16 Notes: LSR = 7,331 MW for CT in FCA 9 . New Slide

61 Indicative NEMA (Congestion Pricing) Demand CurveUsing FCA 9 Inputs Capacity Quantities and Slopes at Selected Prices Congestion Price $1.00 $2.00 $5.00 $10.00 MW Quantity 3,411 3,296 3,130 2,984 Slope (per 100 MW) -$0.59 -$1.19 -$2.60 -$4.39 Notes: LSR = 3,572 MW for NEMA in FCA 9 . New Slide

62 Indicative SEMA/RI (Congestion Pricing) Demand CurveUsing FCA 9 Inputs Capacity Quantities and Slopes at Selected Prices Congestion Price $1.00 $2.00 $5.00 $10.00 MW Quantity 7,398 7,376 7,029 6,859 Slope (per 100 MW) -$0.41 -$0.90 -$2.18 -$3.92 Notes: LSR = 7,479 MW for SEMA/RI in FCA 9 . New Slide

63 Observations for Indicative Curves in Smaller Import Zones Shape is similar to SENE import zone curve presented earlierPrice at LSR varies slightly between zones, ranges from $0.42 to $0.73Design produces reasonable curves across a range of import-constrained zones of different ‘sizes’ New Slide

64 ISO Proposal (1 of 5) – System-Level Results New Slide

65 ISO Proposal (2 of 5) – CT Import Zone Results New Slide

66 ISO Proposal (3 of 5) – NEMA Import Zone Results New Slide

67 ISO Proposal (4 of 5) – SEMA/RI Import Zone Results New Slide

68 ISO Proposal (5 of 5) – Rest-of-System Results New Slide

69 Observations from Results Tables New Slide Satisfy reliability criteria in base case Performance in forward-looking models is comparable to that with FCA 10 zones When capacity is more expensive in import-constrained zones, substitute from zones to rest-of-system

70 Indicative Demand Curve for Maine Export Zone Stakeholders have requested additional information on what a demand curve may look like if Maine were to return as an export-constrained zone Provide curve using indicative FCA 9 MCL value of 3,913 MWs New Slide – 1/22/16

71 Indicative Demand Curve for Maine Export ZoneUsing FCA 9 Inputs New Slide – 1/22/16 Capacity Quantities and Slopes at Selected Prices Congestion Price -$ 1.00 -$ 2.00 -$5.00 -$ 10.00 MW Quantity 4,007 4,150 4,460 4,844 Slope (per 100 MW) -$0.60 -$0.79 -$1.13 -$1.50 Notes: Indicative MCL = 3,913 MW for Maine in FCA 9 .

Appendix 3: Updated ‘Hybrid method’ results Assessing the performance of the ISO’s proposed zonal demand curves with the existing system curve 72 New Slide

73 Hybrid Method (1 of 3) – System-Level Results New Slide Preliminary Results

74 Hybrid Method (2 of 3) – SENE Import Zone Results New Slide Preliminary Results

75 Hybrid Method (3 of 3) – Rest-of-System Results New Slide Preliminary Results

Appendix 4: Cost Impact by Load Zone Estimating the cost impact of the ISO’s proposal across zones 76 New Slide

77 Cost Impact by Load Zone: Model and Results In this Appendix:Stakeholders requested additional analysis showing how costs-to-load (i.e., payments) are impacted by the ISO’s proposal, across a range of clearing pricesModeling assumptionsResults across a range of prices for ISO’s proposed curves and status quo (existing system curve and fixed zonal requirements) New Slide

78 Modeling Approach -- Overview Employed (an approximate version of) the existing FCA Cost Allocation rules to assess cost-to-load by load zoneMain simplifications include:Omitted cost adjustments for multi-year lock-ins at prior FCA pricesOmitted certain specifically-allocated CTRs (difficult to model in time)Assume uniform price paid in each capacity zone Peak load in each load zone based on five year averageEstimated total FCA payments by load zone under a range of clearing conditions under both ISO’s proposal, and status quo New Slide

79 Modeling Scenarios and Assumptions Case 1, Low Price Separation: System clears at $10.81, SENE clears at $11.81, NNE clears at $9.81Case 2, Medium Price Separation: System clears at $10.81, SENE clears at $12.81, NNE clears at $8.81Case 3, High Price Separation: System clears at $10.81, SENE clears at $15.81 , NNE clears at $5.81For each case, show payments by load zone under (a) ISO proposal and (b) status quo New Slide

80 Case 1: Low Price SeparationSystem at Net CONE, SENE + $1, NNE - $1 New Slide

81 Case 2: Medium Price SeparationSystem at Net CONE, SENE + $2, NNE - $2 New Slide

82 Case 3: High Price SeparationSystem at Net CONE, SENE + $5, NNE - $5 New Slide

83 Observations from Analysis Costs to consumers in all load zones decrease with ISO proposal across all three casesOccurs because status quo tends to procure more system and SENE capacityIn Case 3, the higher payments under status quo include:$34 million in NEMA$23 million in CT $106 million for the system New Slide