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FCM – Non-Price Retirements

FCM – Non-Price Retirements

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FCM – Non-Price Retirements

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  1. FCM – Non-Price Retirements

  2. From the ISO’s January 10th presentation at the MC – “There are approximately 428 MW of new resources that were to be commercial by June 1, 2010 but have not yet reached commercial operation” • Many of these MWs are DR MWs that could not terminate prior to the auction because a resource must request a Non-Price Retirement (NPR) for the entire capacity of a Generating Capacity Resource. (III.13.1.2.3.1.5.2 Timing Requirements).

  3. It is unclear whether the NPR rules pertain to DR and; • The Market Rule does not permit partial retirements of a resource. A DR resource is usually comprised of multiple assets, therefore a DR provider would need to terminate the entire resource which would likely include assets that are commercial • Permanent and Static delisting are insufficient tools, since they can be rejected for reliability. If a DR resource is unable to sign on enough customers to meet its capacity supply obligation, it makes no sense to “retain it for reliability.” There is nothing to retain, yet ISO-NE is boxed into a corner by the rules, forcing them to take a nonsensical action in the auction.

  4. III.13.1.2.3.1.5.2 Timing Requirements:  A Non-Price Retirement Request must be submitted for the entire capacity of a Generating Capacity Resource.  The request must be submitted to the ISO between the Existing Capacity Qualification Deadline and 120 days prior to the date of the relevant Forward Capacity Auction.  In the case of a resource that has a Permanent De-List Bid rejected by the Market Monitor, a Non-Price Retirement Request may be submitted within 14 days after the resource receives notice of the rejection or 120 days prior to the date of the relevant Forward Capacity Auction, whichever is later. III.13.1.2.3.1.5.2 Timing Requirements:

  5. Permit DR resources to request Non-Price Retirements and change the rule to allow for partial Non-Price retirements of such DR Resources. Solution

  6. III.13.1.2.3.1.5.1. Description of Non-Price Retirement Request. A Non-Price Retirement Request is a binding request to retire the entire capacity of a Generating Capacity Resourceor a portion of the capacity of a Demand Response Resource. Non-Price Retirement Requests will be approved subject to review for reliability impacts under Section III.13.2.5.2.5. Even if not approved, a Generating Capacity or Demand Response Resource that has submitted a Non-Price Retirement Request may retire pursuant to Section III.13.2.5.2.5.3(a)(iii). Once submitted, a Non-Price Retirement Request may not be withdrawn. A Non-Price Retirement Request supersedes any prior de-list bid for the same Capacity Commitment Period. Solution

  7. And: III.13.1.2.3.1.5.2 Timing Requirements:  A Non-Price Retirement Request must be submitted for the entire capacity of a Generating Capacity Resource or a portion of the capacity of a Demand Response Resource.  The request must be submitted to the ISO between the Existing Capacity Qualification Deadline and 120 days prior to the date of the relevant Forward Capacity Auction.  In the case of a resource that has a Permanent De-List Bid rejected by the Market Monitor, a Non-Price Retirement Request may be submitted within 14 days after the resource receives notice of the rejection or 120 days prior to the date of the relevant Forward Capacity Auction, whichever is later.