EXHIBIT 99.378
Alternatives for Mitigating Potentially
High Zonal Market Clearing Prices
Confidential Draft
California Power Exchange
06/28/02 – p.1
Summary of Alternatives:
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Pricing Proposals to Mitigate High Zonal Prices | | Mitigating | | Efficient | | Implement’n | | Gaming | | Long-term | | Work |
| | High Prices | | Prices | | Requirement | | Potential | | Application | | for MPs |
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Alternative 1 | | | | | | | | | | | | |
• Apply UMCP to all zones • Pay bid prices to suppliers above IPS • Create uplift charge to account for congestion charges from the ISO and added payments in 2 • Charge uplift to all demand based on MWh | | Very effective | | Inefficient | | Moderate | | Very limited | | No | | Minor |
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Alternative 2 | | | | | | | | | | | | |
• Same as Alternative 1 except charge uplift to all demand based on zone and MWh | | Very effective | | Moderately inefficient | | Moderate | | Very limited | | No | | Minor |
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Alternative 3 | | | | | | | | | | | | |
• Use Regional Incremental Costs (RICs) for zonal MCPs • Create uplift as the additional congestion payment/credit for the remaining ISO congestion charges • Charge uplift to all demand based on MWh | | Moderately effective | | Moderately efficient | | Moderate | | Limited | | No | | Minor |
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Alternative 4
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• Same as Alternative 3 except charge uplift to all demand based on zone and MWh | | Moderately effective | | Moderately efficient | | Moderate | | Limited | | No | | Minor |
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Alternative 5 | | | | | | | | | | | | |
• Stay with current marginal pricing procedures • Require incremental adjustment bids for all generators and imports capped at $250/MWh | | Moderately effective | | Efficient | | Moderate | | Limited | | Probably | | Moderate – may challenge Price caps |
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Alternative 6 | | | | | | | | | | | | |
• Stay with current marginal pricing procedures • Require that the SABs submitted with IPS to mimic overall portfolio bids – capped at $250/MW • Limit total import MW bid to less than the capacity of the path | | Effective | | Efficient | | Major | | Limited | | Probably | | Major |
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Alternative 7 | | | | | | | | | | | | |
• Stay with current marginal pricing procedures • Require the PX market participants to submit “unit bids” instead of portfolio bids – capped at $250/MW | | Very effective | | Efficient | | Major | | Limited | | Yes | | Major |
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06/28/02 – p.2
Details of Alternatives:
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Pricing Proposals to Mitigate High Zonal Prices | | Mitigating | | Efficiency | | | | | | | | Added |
| | High Zonal | | of Price | | Implementation | | Gaming | | Long-term | | Work |
| | Prices | | Signals | | Requirements | | Potential | | Application | | for MPs |
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Alternative 1 | | | | | | | | | | | | |
1. UMCP will apply to all zones 2. All suppliers with Final Schedule (FS) above Initial Preferred Schedule (IPS) will receive their bid price for supply above IPS as a lump sum 3. The ISO congestion charge and the added payment to suppliers are summed to create a congestion uplift payment (CUP) 4. CUP will be allocated to all loads based on their MWh use | | Very effective | | Inefficient | | • Settlements should be modified to allow extra payments as lump sum payment to supplies (generation or import) – not trivial • Settlements should be modified to assign CUP as a lump sum charge for demands (load or export) – not trivial. • Uplift charges and added payments can be calculated in ZPC and passed onto the Settlements – moderate effort • Will have time to the first Settlements cycle to implement | | Very limited gaming for the transmission auction | | Stop gap measure as we will deviate from marginal pricing principles | | None – except for potentially adjusting their software to deal with new charge items |
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Alternative 2 | | | | | | | | | | | | |
1. UMCP will apply to all zones 2. All suppliers with Final Schedule (FS) above Initial Preferred Schedule (IPS) will receive their bid price for supply above IPS as a lump sum 3. The ISO congestion charge and the added payment to suppliers are summed to create a congestion uplift payment (CUP) 4. CUP will be first allocated to each zone (ZCUP) based on the ISO relative congestion prices for the zones 5. ZCUP in each zone will be allocated to loads in that zone based on their MWh use | | Very effective | | Moderately inefficient | | • Settlements should be modified to allow extra payments as lump sum payment to supplies (generation or import) – not trivial • Settlements should be modified to assign CUP as a lump sum charge for demands (load or export) – not trivial. • Lump sum outside can be calculated in ZPC and passed onto the Settlements – moderate effort • Will have time to the first Settlements cycle to implement | | Very limited gaming for the transmission auction | | Stop gap measure as we will deviate from marginal pricing principles | | None – except for potentially adjusting their own software to deal with new charge items |
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1 Of course the PX market participants will not observe the prices until software changes are complete.
06/28/02 – p.3
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Pricing Proposals to Mitigate High Zonal Prices | | Mitigating High Zonal Prices | | Efficiency of Price Signals | | Implementation Requirements | | Gaming Potential | | Long-term Application | | Added Work for MPs |
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Alternative 3 |
1. Regional Incremental Costs (RICs)2 used for zonal MCPs 2. Additional congestion payment/credit for the remaining ISO congestion charges are translated into a CUP 3. CUP will be allocated to all loads based on their MWh use | | Moderately effective | | Moderately efficient | | • Settlements should be modified to assign CUP as a lump sum charge for demands (load or export) – not trivial. • Uplift charges can be calculated in ZPC and passed onto the Settlements – moderate effort • Will have time to the first Settlements cycle to implement | | Gaming opportunities with default congestion pricing will be mitigated | | Stop gap measure as we will deviate from marginal pricing principles | | None – except for potentially adjusting their own software to deal with new charge items |
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Alternative 4 |
1. Regional Incremental Cost (RIC) of each zone used for zonal MCP 2. Additional congestion payment/credit for the remaining ISO congestion charges are translated into a CUP 3. CUP will be first allocated to each zone (ZCUP) based on the ISO relative congestion prices for the congestion zones 4. ZCUP in each zone will be allocated to loads in that zone based on their MWh use | | Moderately effective | | Moderately efficient | | • Settlements should be modified to assign CUP as a lump sum charge for demands (load or export) – not trivial. • Uplift charges can be calculated in ZPC and passed onto the Settlements – moderate effort • Will have time to the first Settlements cycle to implement | | Gaming opportunities with default congestion pricing will be mitigated | | Stop gap measure as we will deviate from marginal pricing principles | | None – except for potentially adjusting their own software to deal with new charge items |
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2 RIC is the price bid value for the last unit incremented/decremented in a region (each region consists of one or more zones with no congestion).
06/28/02 – p.4
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Pricing Proposals to Mitigate High Zonal Prices | | Mitigating | | Efficiency | | Implementation | | Gaming | | Long-term | | Added Work |
| | High Zonal | | of Price | | Requirements | | Potential | | Application | | for MPs |
| | Prices | | Signals | | | | | | | | |
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Alternative 5 | |
1. Stay with current marginal pricing procedures 2. Require incremental adjustment bids for all generators and imports 3. Require the ISO not to change our prices for congestion management process 4. Limit incremental adjustment bid to a max of $250/MWh | | Moderately effective | | Efficient | | • Need to add validation for incremental bids – not trivial • ISO needs to modify software to leave our price bids alone | | Mitigated congestion pricing gaming. Less effective w/ energy price gaming | | Applicable | | • MPs need to create bids • Bids may be rejected delaying market close • Price caps may be challenged |
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Alternative 6 | |
1. Stay with current marginal pricing procedures 2. Require that the SABs submitted as part of IPS, when aggregated, to closely mimic the overall portfolio bids 3. Limit total import MW bid to less than the capacity of the path 4. Limit incremental adjustment bid to a max of $250/MWh | | Moderately effective | | Efficient | | • Need to add validation for incremental bids – not trivial | | Mitigated congestion pricing gaming. Less effective w/ energy price gaming | | Applicable | | • Bids may be rejected delaying market close • Will be difficult to mimic the portfolio bid • Price caps may be challenged |
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Alternative 7 | |
1. Stay with current marginal pricing procedures 2. Require the PX market participants to submit “unit bids” instead of portfolio bids 3. Convert the unit bids into SABs for congestion management 4. Limit incremental adjustment bid to a max of $250/MWh | | Very effective | | Efficient | | • Need to test OMH software for substantially lager number of bids • Need to develop a simple software to convert the unit bid into adjustment bid | | Limited overall gaming | | Applicable | | • Requires MPs to create bid curves per resource • Complicates the energy auction process • Price caps may be challenged |
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06/28/02 – p.5