Mothball Outages in Capacity Markets

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1 Mothball Outages in Capacity Markets (preliminary review and summary for working group discussion purposes consult relevant ISO directly for latest and detailed legal requirements) September 13, 2017

2 NYISO Mothball Outage Applicable to a Generator in an outage state on or after May 1, 2015 The outage state in which a Market Participant s Generator is voluntarily removed from service, with applicable prior notice, for reasons not related to equipment failure. A Generator in a Mothball outage is subject to the provisions of the Services Tariff (5.18) and is ineligible to participate in the Installed Capacity Market. ICAP eligibility ends as of the start of a Mothball Outage ICAP eligibility resumes the first day the Generator returns to operation in the market and offers in without declaring an outage. No later than 60 days before starting the Mothball Outage, a Market Participant shall notify the ISO whether its Generator will be physically able to return within 180 days to resolve a reliability issue or it has good cause for an alternate period of time, stated in days, to return its Generator to service to resolve a reliability issue. This time period is shared with TFO. Maximum Term: Mothball Outage expires at the earlier of the loss of the unit s Capacity Resource Interconnection Service (CRIS) Rights, or where it has no CRIS rights after 36 consecutive months in the Mothball state the Generator is deemed Retired. If returning prior to when the Mothball Outage would expire and market participant has provided a reasonable return date, the Mothball Outage and CRIS rights will be tolled until the earlier of (i)120 days from when the outage would have expired or (ii) an ISO determination that the Market Participant has unreasonably delayed the repair / not followed a Credible Repair Plan. To toll its outage and CRIS, the market participant must submit a Repair Plan no later than 60 days prior to when the Mothball Outage would expire Market Administration and Control Area Services Tariff (MST) - 5 MST Control Area Services: Rights and Obligations

3 NYISO Mothballed Generator Return to Service Timely return required if return of Mothball Outage Generator resolves a reliability issue and includes an order establishing compensation from FERC. If compensation issue is at an impasse, Market Participant may submit a filing to FERC for compensation. A timely return will be considered to be within 180 days from the date of the Compensation Order, the alternate period of time demonstrated to be reasonable ( ), or such other date as agreed to by the parties No requirement to return unless otherwise agreed Timely return not impacted by TFO failure to connect Use of Interconnection Point of Mothballed Generator Market Participant shall provide a TFO with temporary use of the interconnection point of its Generator when a transmission solution using the Generator s interconnection point has been selected as either the Gap Solution or to resolve a reliability issue. Market Participant reconnects at no cost by submitting a Notice of Intent to Return notice to be provided 6 months prior to the expiration of its Mothball Outage. Transmission owner reports on cost of reconnecting.

4 PJM Notification of a mothball outage is given only 90 days prior to intended deactivation PJM can only request a unit to remain in service past its deactivation date for a specific reliability or market power issue and only until the reliability issue is addressed. A unit that is requested to remain in service after its deactivation is due compensation There is no maximum term length of a mothball outage A unit cannot be kept from mothballing due to economic or congestion issues Deactivation request includes a good faith estimate of investment and length of repairs, if any, required to return or keep the unit in operation PJM reviews reliability, market power, economic or congestion impacts Reliability issues result in further process with PJM ISO and Generator PJM estimate of impact and timeline to complete upgrade, Generator estimate of project costs. Costs go to PJM tariff or FERC Application

5 Section 9 of PJM Manual M-14d:

6 ISO NE Participants Experience with Mothballing Generators must buy back any existing capacity supply obligation. This typically occurs through a reconfiguration/rebalancing auction or through a bilateral transaction. This buy back releases the generator from its must-offer obligation in the energy market. For Generators to retain ability to offer capacity in the future a generator must continue to do testing on a seasonal basis (summer and winter testing on a particular schedule) If you do not continue testing ISO-NE administratively sets a generators qualified capacity to 0 MW and capacity cannot be sold until the generator submits a plan back to the ISO outlining how it plans to increase its qualified capacity and prove its capability for a new non-zero qualified capacity that can be sold into an auction

7 Mothball Outage Questions & Interdependencies Should a new rule grandfather mothball outages declared earlier? Should must offer apply? ISO desires visibility to all capacity? Sorted by price/return time? Resource Adequacy Requirements? Could capacity auction and demand curve assist in determining who is mothballed? Allow uneconomic units to price themselves out and not clear What is resulting pool price if mothballed unit directed on? Eligibility and Compensation Could compensation be based on COS. If a mothballed unit is requested for reliability is any capacity payment, or weighted capacity payment received? On what basis is UCAP calculated following return to service Market size and Concentration are mothballed units factored in? Definitions of other types of outages may need to be created (Inactive Reserves, Forced Outages, ICAP Ineligible Forced Outage, Retirement) Temporary use of Interconnection points Retirement and Interconnection rights

8 Discussion

9 Back-up slides follow