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Preemption and Competition Redirect Issues

Preemption and Competition Redirect Issues. NAESB OS Meeting June 6, 2012 BPA Presenting. Redirects. S&CP

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Preemption and Competition Redirect Issues

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  1. Preemption and CompetitionRedirect Issues NAESB OS Meeting June 6, 2012 BPA Presenting

  2. Redirects S&CP 001-9.1.3 A request to Redirect on a Firm basis shall be queued and evaluated in the same manner (i.e., same service priority) as any other Firm Point to Point request, subject to the other requirements of this standard. 001-9.2 The TC shall be allowed to request a Redirect on a Firm basis for a portion or all of the Capacity Available to Redirect, even if the transmission scheduling rights on the Parent Reservation have been limited due to outages or other reliability related events. 001-9.3 The TC shall be allowed to request a Redirect on a Firm basis for a portion or all of the time period of the Parent Reservation (i.e., bound by the start/stop times of the Parent Reservation). 001-9.4 The TC’s rights on the Parent Reservation shall remain unaffected during the Transmission Provider evaluation of the request to Redirect on a Firm basis. 001-9.4.1 If the request to Redirect on a Firm basis is denied for any reason, all rights and obligations shall remain per the Parent Reservation. 001-9.4.2 The TC shall be allowed to submit and have pending multiple requests for Redirects on a Firm basis against the same Capacity Available to Redirect. The TP shall evaluate each such request with the knowledge that only those requests up to the Capacity Available to Redirect may ultimately be confirmed. 001-9.4.3 If the TP determines that only a portion of the requested capacity can be accommodated, the TP shall extend to the TC that portion of the capacity (i.e., partial service) that can be accommodated through a COUNTEROFFER. 001-9.8 Any differences in charges associated with the Redirect on a Firm basis will be settled in accordance with the Transmission Provider’s tariff. 001-9.8.1 If not addressed in the Transmission Provider’s tariff or in a Service Agreement, any difference in charges associated with the Redirect on a Firm basis will be the responsibility of the TC submitting the Redirect.

  3. Preemption and Competition Concerns around Redirects 75 MW Challenger Monthly TSR for 100 MW 50 MW 25 MW Challenger 50 MW Redirect Matching TSR • Original TSR Challenged for 75 MW • Only challenged for what is left. • Chooses to defend • Original TSR displaced • New matching TSR Issued • Link to Redirect broken??? • Does not defend • Becomes 25 – 0 – 25 • Does not impact Redirect. • Billing Issues • Redirect TSR Challenged for 25 MW • Stands on its own. • Chooses to defend • Original Redirect displaced, capacity goes to AFC, not the Parent. • New matching TSR Issued, capacity from AFC, not Parent • Link to tags broken? Parent? • Does not defend • Displaced • No capacity goes back to parent. • Billing Issues

  4. Another Redirect Issue – Secondary Non-Firm • The S&CP • 001-10.5.3 The TC shall have the right to request the TP to release unscheduled capacity associated with a confirmed request to Redirect on a Non-Firm basis and • reinstate that capacity to the Firm Parent Reservation. The TP shall honor all • such valid requests, and reinstate the capacity on the Firm Parent Reservation. • 001-10.5.3.1 The TC shall submit to the Transmission Provider (TP) a request to release with a request type of RELINQUISH. • 13-2.6.6 states that a Firm Redirect to a Secondary Non-Firm (1-NS) can request the right to relinquish that capacity back to the parent. • Questions: • If the parent, the original TSR is displaced and a new Matching TSR created. Does the right to relinquish carry over to the matching TSR? Is the chain back broken?

  5. Redirect of Resales Order 890-A Paragraph 819. – With regard to reassignments of capacity in the secondary market, we clarify that the associated right of first refusal under sections 13.2 and 14.2 of the pro forma OATT to match a competing transmission service request applies to the primary transmission service, not the reassignment of scheduling rights. 001-11.7 DISPLACEMENT OF A RESALE In the event a Transmission Provider’s Tariff requires that a higher priority, competing transmission service request must displace all or a portion of a confirmed lower priority reservation, the TP shall have the right to nullify any Resales that reference the displaced reservation as their Parent. 001-11.7.1 Once the conditional window on the Parent Reservation has closed, Resales for firm service are not subject to displacement in accordance with Standard WEQ-001-11.

  6. Redirect of Resales Redirect 25mw Resale 75mw to Cust B Resale 50mw to Cust C (later Aggregated) 75mw Original 100mw Cust A 25mw • Must allow Resale while Parent is still conditional. • Resale TSR itself is safe from competition. • Parent is competed based on the full (i.e., pre-Resale) capacity. • The resale capacity need to come back to the parent prior to the competition so the full capacity can be competed. This requires the annulment of all child resales to bring the capacity back to the parent. • Unwinding must happen when or lose. Capacity has moved, no longer on this path. • Redirect is a standalone TSR able to challenge and defend on its own • For scheduling, capacity goes with the Resale • Neither of the Resales is competed • For competition, capacity remains with the parent

  7. Complicated Resales/Redirects/Tagging Tag Resale Grandchild TSR 25 MW For scheduling, capacity goes with the Resale. Tag 15 MW Resale Child TSR 1 25 MW For competition, capacity stays with the parent. Tag Tag 25 MW 10 MW Parent TSR1 Was 60 MW Now 10 MW Tag The Redirect is a standalone TSR able to challenge and to defend. Tag For Competition, Resales are safe from competition 25 MW Tag Resale Child TSR 2 Was 65 MW Now 5 MW Redirect Grandchild TSR Now 50 Parent TSR2 Was 40 MW Now 0 MW 50 MW 40 MW Tag Tag Challenges Tag If the capacity has to come back to the parent of a Resale for competition, and that parent is competed, PCM will need to annul all resales associated with it even if the parent chooses to exercise its ROFR. What happens to any Redirects from the Resale? What if part of that redirect has been resold, and redirected, and aggregated, and…? What about any tags along the way? What about downstream competitions? Anyone want to try unwinding this? Defender TSR who Could have Resales

  8. Discussion????

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