3 Options remain Scope of the issue 2 scenarios Resale is done in the unconditional window Resale does not get competed or bumped Resale is done in the conditional window Resale could be identified as a Defender in Short Term Competition and Preemption ID: 557418
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Slide1
Resale Business Practice Standards
3 Options remainSlide2
Scope of the
issue – 2 scenarios
Resale is done in the unconditional window
Resale
does
not
get competed or bumped
Resale is done in the conditional window
Resale could be identified as a Defender in Short Term Competition and Preemption.
Questions are:
What do you do with the Resale?
How do you do it?Slide3
Real Issue – When the parent is Conditional
Current State:
ISSUE: WEQ 001 and WEQ 013 are not consistent in the treatment of capacity on a Resale
BPS WEQ 001 refers to the movement of scheduling rights not capacity.
BPS WEQ 013 refers to the movement of capacity
ISSUE: FERC language and guidance
FERC has already approved the current language and definition of
Resales
ISSUE: Transparency and traceability
Current BPS WEQ 001 and WEQ 013 do not explicitly call out how to ensure that the resale has capacity to redirect, they just state that a resale shall have the ability to redirect. Slide4
Option 1 – Status Quo
Current WEQ Version 3 Standards and Implementation guide remain unchanged in regards to
Resales
Assignees do not have ROFR
Resales
are not subject to P&C
Only the Parent is subject to Competition
This option allows TP to annul all
Resales
due to P&C on the parent
ISSUES
We will still have the same contradiction between WEQ 001 and WEQ 013
We will still have issues in traceability and transparency
Billing
Resale to self would shield TC from P&C
Aggregation of
ResalesSlide5
Option 2 – Move Capacity
Move Capacity from the parent to the Resale
Assignee has ROFR
Does not limit Secondary Transmission Market
Customer Satisfaction
ISSUES:
Business Practice Standards Change
Changes to WEQ Resale definitions and WEQ 001
TP
Defender identification meta data
tracking
WEQ
EC and FERC Support
Billing (Although this is an issue, NAESB Should not be addressing Billing issues as a standards making organization)
System/Process
updates
Aggregation of
ResalesSlide6
Option 3 - Restrict Resales
to the Unconditional window
Do not allow
Resales
until the Unconditional window
Conditionality transfers from the parent to the child
If parent tries to Resell in the conditional window, they will not be able to do so.
I
SSUES:
Business Practice Change
Implementation Guide Change
Minimizes Secondary Transmission Market
Low customer satisfaction
Slide7
Agreement on Options
Do you understand all Three options?
Are there other options?Slide8
Issues with Each Option
Option 1:
We
will still have the same contradiction between WEQ 001 and WEQ 013
We will still have issues in traceability and transparency
Billing (Although
this is an issue, NAESB Should not be addressing Billing issues as a standards making organization
)
Resale to self would shield TC from P&C
Still have issue with Daisy
Chain
Aggregation of
Resales
Option 2:
Business Practice Standards Change
Changes to WEQ Resale definitions and WEQ 001
TP Defender identification meta data tracking
WEQ
EC and FERC
resistance to Support
Billing (Although this is an issue, NAESB Should not be addressing Billing issues as a standards making organization)
System/Process
updates
Aggregation of
Resales
Option
3 (No resale of the Conditional Reservation):
Business Practice Change
Implementation Guide Change
Minimizes Secondary Transmission Market
Low customer
satisfaction
Possible FERC
resistance to
Support
Option
4 (fix Option 1 Issues):
We will
have to fix the
same contradiction between WEQ 001 and WEQ 013
We will still have issues in traceability and transparency
Billing (Although this is an issue, NAESB Should not be addressing Billing issues as a standards making organization)
Resale to self would shield TC from P&C
Still have issue with Daisy Chain
Aggregation of
Resales
Option
5 (Transfer):
Utilize the Transfer Mechanism for
Resales
Fix some attributes of stop and start time
This will have the three party approvalSlide9
Benefits of Each Option
Option 1:
No changes to current Business Practice Standards
Already approved by WEQ EC and FERC
Option 2:
Update to Standards will make WEQ 001 and WEQ 013 consistent
Traceability
Encourages Secondary Transmission Market Flexibility
Ability to redirect a Resale is already described in Standards
Option 3:
Ease of implementation
Minimal WEQ Business Practice Standard changes required
Easiest for TP to implementSlide10
Options Side by Side
Option 1
Option 2
Option 3
Change to Standard
No
Yes
Yes
Is there a contradiction between WEQ BPS
Yes
No
No
EC
approval
Yes
Not yet
Not Yet
FERC Approval
Yes
Not
Yet
Not Yet
Change to Implementation
guide
No
No
YesSlide11
Options Side by Side – continued
Option 1
Option 2
Option 3
Traceability
Little
Yes
Little
Secondary market impact
Little to None
Little
Yes
Conditionality
Stays with the parent and the child is part of the parent (WEQ 001-scheduling rights )
Conditionality transfers from the Parent
to the Child
Un-conditionality transfers from the Parent
to the Child
Duration
Not an issue
Must be determined
Not an issue
Queue Time
Not an issue
Must be determined
Not an issueSlide12
Option 1
Option 2
Option 3
Price
Not an issue
Must be considered
Not an issue
Billing
Same Billing Issues
as now
Billing issues
in regards to a Resale exercising ROFR, loss of capacity on Resale
Billing does
not have to account for loss of capacity on a Resale due to P&C
Aggregation
Issue
Issue
Not
an IssueSlide13
Recommendation
Option 2
Keeps Secondary Market Flexibility
Treatment of
Resales
is both transparent and traceable
Facilitate consistency in BPS and Implementation
Consistent with current BPS regarding redirecting a Resale
Allows for Aggregation of
Resales
to be processed as their own capacitySlide14
Option 2 – Draft language
Conditional Parent
Resale in the Conditional Window
Child will inherit the Conditionality of the Parent
Child will inherit the Service Increment of Parent
Child has it’s own Duration
Duration will be consistent with current motion 3
Based on Start Date and Time and End Date and Time
Child has it’s own Queue Time
Queue time is set when the Resale is entered into OASIS
Child has it’s own Price
Price is that amount entered into OASIS when the Resale is entered.Slide15
Option 2 – Draft Language
A Resale will be evaluated to determine if it is a valid Defender on but not limited to the SERVICE_INCREMENT , Capacity and POR/POD inherited from the Parent, and the duration, queue time and price determined when the Resale is entered into OASIS
A Resale will be identified as a Defender consistent with all other Business practice standards for P&CSlide16
Option 2 – Draft Language
Resale Matching request will be based off of the Resale reservation in OASIS and must match duration of the ChallengerSlide17
Resale Defender Example
When Resale is identified as a valid Defender based on it’s TSR in OASIS, the resale will have ROFR.
To exercise ROFR the Resale must match the duration of the Valid Challenger
Example
Parent is monthly, 3 month duration
Child has Service Increment of 1 month, but is 1 week in duration
Both the parent and the child are identified as valid defenders to a 4 month request
Parent must match the remaining month to exercise ROFR
Child must match all four months to exercise ROFR