text_combined: ferc 4 26 01 order california price mitigation per voicemail forwarded richard shapiro na enron 04 27 2001 07 04 subject ferc 4 26 01 order california price mitigation read ray alvarez summary yesterday evening open attached word document read changes made summary since receiving final order issued afternoon alan comnes full order available http www ferc fed us electric bulkpower htm summary ferc order establishing prospective mitigation monitoring plan california wholesale electric markets establishing investigation public utility rates wholesale western energy markets issued april 26 2001 effective date price mitigation effective may 29 2001 iso needs day ahead proxy price ready 5 28 physical withholding prevent physical withholding plan require sellers pga offer available power real time extent scheduled bilateral trade california generators even subject ferc price regulation required sell iso real time market condition use iso interstate transmission lines hydroelectric facilities exempted requirement provide power hours 24 7 lyr price mitigation plan establish single market clearing price auction real time market stage 1 2 3 emergencies iso real time market generator hydro participating generator agreement required offer available power bid marginal cost based generator heat curve emission rates gas costs emission costs plus 2 mwh emissions based cantor fitzgerald environmental brokerage services iso publish 8 00 gas emission figures used next day hour emergency declared figures next day based prior day gas daily cantor fitzgerald data single market clearing price determined real time generators highest bid sets clearing price gas fired generator must file ferc iso within 5 days confidential basis heat emission rates generating unit iso use rates calculate marginal cost generator including maintenance operating costs generators submit bids market clearing price subject refund liability although following qualification made however public utility rates subject refund violations conditions imposed market based rates discussed infra presumably anomalous bidding behavior event generator submits bid higher proxy price generator must within 7 days end month file report ferc iso justifying price ferc explicitly acknowledges units may gas costs exceed delivery point index adopted ferc 60 days review act opportunity costs real time marketers held generator cost standard must prepared justify bid purchased cost based specific purchases portfolio opportunity cost underscheduling penalites ferc acknowledges pending request revoke current underscheduling penalty indicates still place thus although may advantageous wait buy power r capped prices may make scheduling coordinator subject currently effective 100 mwh penalty see p 20 ferc order new generation new generation exempted commission price mitigation measures demand response beginning june 1 public utility load serving entities must submit demand side bids curtail load identify load curtailed bids ferc attempting make demand curve price responsive requirement effect hours 24 7 outages pga generators coordinate planned outages report forced outages iso required make tariff filing within 15 days order proposing mechanism coordination control outages including periodic reports commission term order expires one year date issuance rto filing california iso two utilities must make rto filing june 1 order lapses effect rto filing consistent characteristics functions order 2000 iso reporting september 14 2001 iso must file status report things working much generation built comments due 15 days quarterly reports thereafter revocation market based rate authority refunds market based rate authority public utilities conditioned 1 physical withhold capacity 2 inappropriate bidding behavior inappropriate bidding behavior includes bidding unrelated known characteristics generation unit without input cost basis bidding based unit behavior increased bid based increased demand could apparently inappropriate addition hockey stick bids expressly prohibited e bidding 95 marginal cost 5 much higher level prohibited bidding practices identified include pricing single unit much higher units supplier portfolio changes bids due increased scarcity rather changes generator costs west wide section 206 investigation opens section 206 investigation concerning j r wholesale power wscc sales caiso market ferc requests comments scope nature price mitigation however proposal refund conditions apply real time markets power less 24 hours advance r spot markets contingency within control area falls 7 within control area ferc attempting mirror rules applied california comments due 10 days 206 investigations although still formulating price mitigation plan non california pnw ferc sets refund effective date 60 days publication order nox limits california must sell requirements apply unit prohibited running law however appears incurring fines overcome must sell requirement include fines part price bid also nox limited may seek show generation would sold elsewhere different times determining price surcharge pay past amount due comments due 30 days 1 whether ferc require iso surcharge parties payment escrow account pay past costs 2 effect surcharge would pg e bankruptcy filing treatment caiso market stabilization plan msp ferc rejects caiso msp saying ferc plan market mitigation sufficient expressly rejects caiso plan create day ahead hour ahead energy markets expressly reject tells caiso stop actions implement software changes effectuate markets unfortunately expressly reject caiso plan cut exports general mention made issue exports power california although statement caiso must become real rto would support notion caiso must honor firm schedules system recap dates identified order issue date 4 26 01 heat rate emission filing generators due 5 days 5 1 01 comments due wscc wide price mitigation 10 days 5 6 01 iso tariff filing due 15 days 5 11 01 comments iso tariff due 5 days thereafter 5 16 01 comments whether commission allow premium recover unpaid generator bills 5 30 01 effective date proxy prices 5 29 01 demand responsive bids load serving entities 6 1 01 refund effective date begins 60 days publishing federal register late june first iso quarterly report 9 14 01 comments first iso quarterly report 15 days thereafter 9 29 01 plan terminates 4 26 02 ra gac