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Texas Generator to Pay $10,000 Fine for Not Offering Power at Offer Cap When Required To Do So
Calpine Corporation would pay $10,000 under a settlement with Staff of the Public Utility Commission of Texas to resolve alleged violations of ERCOT Protocols § 6.4.3.1, related to energy offer curves for RUC-committed resources.
Prior to the end of the Adjustment Period for an Operating Hour during which a Generation Resource has been committed by ERCOT as part of a Reliability Unit Commitment (RUC) process, a QSE shall ensure that an Energy Offer Curve (EOC) that prices all energy from LSL to HSL at the SWOC [system wide offer cap] for the Operating Hours in the RUC commitment period has been submitted and accepted by ERCOT.
On March 20, 2013, the Oversight & Enforcement Division of the Commission (O&E) issued a warning letter to Calpine for behavior occurring in 2012 in lieu of an administrative penalty at that time. "O&E determined that Calpine was in noncompliance with ERCOT Protocol 6.4.3.1, and therefore PURA § 39.151(d) and (j) and P.U.C. SUBST. R. 25.503(f)(2), as well," the settlement states.
"The non-compliance by Calpine in 2012, relating to Calpine's failure to have EOCs priced at the SWOC for the Operating Hours for which it received RUC commitments, was due to human error," the settlement states.
Subsequent to O&E's issuance of the warning letter, Calpine self-reported additional instances of noncompliance with ERCOT Protocol § 6.4.3.1 that occurred on November 15, 2013.
On this date, Calpine correctly updated the RUC status of the Current Operating Plan (COP), but failed to update its EOC to price all energy from LSL to HSL at the SWOC for Operating Hours 21-24 during the RUC commitment period. This error, again the result of human error, resulted in SCED dispatching the unit above LSL for a portion of the hours during the RUC commitment period, the settlement states
Between December 19, 2012 and November 15, 2013, Calpine was RUC committed for 36 total Operating Hours and failed to have EOCs priced at the SWOC in 16 of those hours, or 44% of the time, the settlement states.
Since the date of the activity subject to the settlement (November 15, 2013), Calpine has priced its EOCs at the SWOC for RUC-committed Operating Hours in over 99% of the over 500 RUC commitments Calpine has received.
While the failure to price energy at the SWOC was attributed to human error, and while we stress that we do not in any way aver, suggest or otherwise imply that such attribution is not true, we do note that to the extent Calpine's actions impeded the formation of scarcity prices, the actions did help feed a desired narrative that the current energy-only market was not functioning properly because it was not producing scarcity pricing when expected.
Docket 42588
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