Stakeholder Comments Template

Load Granularity Refinements

Issue Paper and Pricing Study, August 08, 2013

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Please fill in the name, e-mail address and contact number of the specific person who can respond to any questions about these comments. / Please fill in here / Please fill in here

This template is for submission of stakeholder comments on the topics listed below, covered in the Load Granularity Refinements issue paper and pricing studyonAugust 08, 2013,and issues discussed during the stakeholder meetingonAugust 21, 2013.

Please submit your comments below where indicated. Your comments on any aspect of this initiative are welcome. If you provide a preferred approach for a particular topic, your comments will be most useful if you provide the reasons and business case.

Please submit comments (in MS Word) o later than the close of business on September 04, 2013.

  1. Pricing Study
  2. Does your organization believe the initial pricing study methodology is sufficient to aid in a determination as to whether to proceed with more granular load zones? If not, what additional analysis would your organization recommend?
  3. Please comment on if the results from the pricing study indicate a large enough divergence to pursue a further, more detailed analysis of price dispersion. If so, provide a description of the type of analysis your organization would find useful.
  1. Retail regulatory structure
  2. Please comment on the potential and timing for retail regulatory structure change and how that might affect the benefits of disaggregated load zones.
  1. Granular pricing benefits
  2. Absent changes in the retail rate structure, what efficiency gains could be captured from reducing the cross-subsidization between different areas?
  3. What are the expected benefits from more accurate locational price signals to your organization?
  4. Are some of those expected benefits currently available through the use of existing ISO programs, such as PDR?
  1. Congestion Revenue Rights
  2. Please comment on any estimated benefit from (1)improved hedging from more focused CRRs and (2) an increase in CRR allocation.
  1. Day Ahead Optimization
  2. Please provide comments on the benefits of increasing the efficiency of the day-ahead optimization.
  1. Costs
  2. What costs would be required in order for your organization to accommodate increase load pricing granularity in ISO settlements?
  3. What costs would be required for your organizationto make use of the increased load pricing granularity in its billing to end-use retail customers?
  4. What costs would be incurredyour organization to forecast load on a more disaggregated basis, and bid that disaggregated load into the ISO markets?
  5. What costs would be incurred your organizationdue to a modified CRR structure using more granular load pricing?
  6. Are there any other costs that your organization would incur from more granular load zones?
  1. Net Benefits
  2. Please provide estimates (either quantitative or qualitative) of the level of net benefits from disaggregating load pricing areas.
  3. Please comment on how net benefits from disaggregating load pricing areas compare to the net benefits from other ISO initiatives. Alternatively, how does disaggregating load pricing areas rank in comparison to the other initiatives the ISO is or is considering working on.
  1. Next Steps
  2. Should the initiative to develop more granular LAPs begin now or is there a time in future when the process should be started?
  3. What are potential indicators that the ISO should begin an initiative to disaggregate LAPs?
  4. Are there non-ISO indicators, such as changes in retail rate policies that shouldtrigger a restart of this process?
  5. Should the ISO continue to monitor the price deviations between the sub-LAPs and the LAPs and restart the initiative when those deviations exceed some threshold? What is an appropriate threshold?
  1. Additional Comments
  2. Please provide any additional comments.

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