ERCOT Identifies "Issues" Concerning Identification Of Transmission-Level Customer Securitization Opt-Outs, Calculation Of Adjusted Metered Load
September 29, 2021 Email This Story Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • email@example.com
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ERCOT filed with the Texas PUC a pleading to notify the Commission and the parties of potential issues that may impede ERCOT’s ability to calculate the amount of Uplift Balance bond proceeds due to Load-Serving Entities (LSE) under the methodology agreed to as part of the Docket No. 52322 partial settlement
The previously reported partial settlement would address certain issues resulting from HB 4492, which creates a program to finance, and provide funds to LSEs, Reliability Deployment Price Adder ("RDPA") charges and Ancillary Service costs above the Commission's system-wide offer cap for the period beginning 12:01 a.m., February 12, 2021, and ending 11:59 p.m., February 20, 2021 (known as "uplift")
As previously reported, the settlement, among other things, addresses the allocation of financing proceeds to LSEs
ERCOT said that the purpose of its latest pleading, "is to provide the Commission and the parties with adequate time to begin developing solutions before the ten-day period begins for ERCOT to calculate the amount of proceeds due to each eligible LSE, not to cast doubt on the feasibility of the Docket No. 52322 settlement methodology."
"To be clear, at this time ERCOT has not received an indication from any party in this matter that there will be disagreement among the parties as to the issues presented in this filing. Nevertheless, ERCOT makes this filing now so that any potential concerns regarding the issues raised herein can be resolved in a timely manner," ERCOT said
ERCOT noted that as part of the mechanism in the settlement, ERCOT would be required to, "calculate a load ratio share for each LSE using ERCOT interval-level Adjusted Metered Load (AML) data for the 180-day Real Time Market True Up settlements for the period of emergency (defined as February 12-20, 2021) adjusted for the LSE’s transmission level opt-out settlement meter data which will be adjusted to account for transmission losses and unaccounted for energy allocations."
ERCOT said that it has the ability to calculate the load ratio share, but there are several issues that need to be resolved before ERCOT can perform that calculation:
"First, ERCOT cannot begin calculating each LSE’s portion of proceeds until ERCOT has all necessary information to account for every opt out, including all information necessary to properly account for every transmission-voltage opt out. Therefore, it is imperative that ERCOT receive accurate information identifying all opt outs as quickly as possible.
"Second, there needs to be an agreement or Commission guidance regarding which transmission-voltage customers are eligible to opt out. ERCOT submits that the only transmission-voltage entities that should be eligible to opt out are: (1) those customers that have been identified by Transmission and Distribution Service Providers as transmission-voltage customers; and (2) those entities deemed transmission-voltage customers for purposes of the Renewable Energy Credit program. Using those criteria to identify the eligible transmission-level customers, ERCOT proposes to provide each LSE a list of the Electronic Service Identifiers ('ESI IDs') associated with that LSE’s transmission-voltage customers. If a transmission-level customer decides to opt out, the customer’s LSE must provide ERCOT notice of that opt-out, along with the ESI IDs associated with that customer and the LSE’s interval-level settlement meter data for the customer for the Period of Emergency (defined as February 12-20, 2021). ERCOT will then adjust the relevant LSE’s AML for purposes of calculating the LSE’s exposure by removing the opted-out transmission-level customer’s meter data from the LSE’s AML.
"Third, there needs to be agreement or Commission guidance regarding which information ERCOT will use if its interval-level settlement data does not match that of the LSEs. Although the Partial Stipulation requires LSEs to provide ERCOT with meter data for the LSE’s transmission-voltage opt outs, ERCOT already possesses interval-level meter data for the Period of Emergency for each of the transmission-voltage customer ESI IDs. Although ERCOT may use
the LSEs’ transmission-voltage customer meter data to help ERCOT clearly identify each transmission level opt-out, ERCOT does not intend to rely upon that LSE-provided meter data to calculate the LSE’s adjusted AML. Rather, ERCOT intends to use the meter data possessed by ERCOT for the identified transmission level opt-outs to make the needed adjustments to each LSE’s AML. Accordingly, if there is a discrepancy between the meter data provided by LSEs and the data possessed by ERCOT, ERCOT will use its own data. To the extent paragraph 10 of the Partial Stipulation requires ERCOT to 'aggregate [the transmission opt out] interval-level meter data for each REP, adjust for transmission losses and unaccounted-for-energy, and provide the market-wide aggregated data to the parties in Docket No. 52364,' ERCOT intends to base the aggregated data filed in Docket No. 52364 on the meter data possessed by ERCOT for the transmission level opt-outs."
"The purpose of this pleading is not to dictate terms to the Commission or the parties. Rather, it is to identify potential issues, provide ERCOT’s perspective on how they should be resolved in the absence of agreement or Commission direction to the contrary, and invite comments from the parties," ERCOT said