1 TAC ADR Task Force Presentation to TAC 6 May 2005.

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TAC ADR Task Force

Presentation to TAC

6 May 2005

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Why is this important to you?

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• Changes to a QSE’s load will change its load imbalance (LI) dollar amounts, ERCOT Administration charge, and Load Ratio Share (LRS).

• Net changes to the total ERCOT load imbalance (LI) dollar amounts will be uplifted through Balancing Energy Neutrality Adjustment (BENA) based on LRS.

• Changes to a QSE’s LRS will change the amount uplifted to them for OOMC, OOME, Black Start, etc.

• Most likely there would not be changes to the total load for ERCOT.

Why is this important to you?

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Co-Chair Shawnee Claiborn-Pinto PUC Staff

Co-Chair Shannon K. McClendon Residential Consumer Representative

ERCOT Betty Day

Andrew Gallo

Diana Zake

Ann Boren

Cheryl Moseley

Energy Analysis & Aggregation

Legal

Market Rules

Stakeholder Services

Market Rules

Introductions

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TXU Energy: Brad Jones, BJ Flowers AEP: Susan Potters

BP Energy: Judy Briscoe Austin Energy: Leonard Stanfield

Reliant: Kevin Gresham, Ruth Johnson Direct Energy: Ryan Thomason

First Choice: Michelle Treneary Cirro: Shannon Bowling

StarTex: Marcie Zlotnik TEAM: Neil Edelman

Calpine: Randy Jones Texas Genco: Derenda Plunkett

Shumate & Associates: Walt Shumate Bryan Texas Utilities: Lee R. Starr

CenterPoint Energy: DeAnn Walker, Zachary Collard

Participating Market Participants

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Introductions

SCOPE and Relevant Protocols, PURA, and PUC Rules

Retail Data Variance & Wholesale Settlement Brief

Interpretations of Protocols

ERCOT’s

TXU’s and Other’s

Overview

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Discussion of Legal Perspectives

ERCOT

TXU

TEAM

Direct Energy

OPC

Issues, Advantages, and Disadvantages of the Interpretations

TAC discussion, questions and answers, and VOTE

Overview (continued)

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The Task Force reached unanimous consensus regarding the Scope of the ADR Taskforce:

The ADR Task Force will provide education to TAC relative to the issue of the denial of

outstanding post-true up load imbalance ADRs

Scope Of Task Force

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The Task Force agreed that:• The Task Force was not resolving the outstanding

ADRs

and

• The Task Force was not attempting to resolve how to deal with post-True Up Load Imbalances occurring in the future – that is currently a COPS assignment

Scope Of Task Force (cont.)

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• ERCOT Protocols Sections 2, 9, 10, 11, 15 & 20– Section 9: Settlement & Billing (9.2.5 - .7, 9.4.4)– Section 10: Metering (10.1, 10.2.2, 10.2.3.1, 10.3.3.1, 10.11.3)– Section 11: Non-EPS Metered Points (11.2.2)– Section 15: Customer Registration (15.1.1.9, 15.1.2.8, 15.3,

15.4, 15.4.1, 15.4.1.4, 15.5)– Section 20: Alternative Dispute Resolution Procedures (20.1,

20.2.3

• PURA (§§ 38.005 & 39.151(1))

• PUC Rules (§§ 22.251, 25.28, & 25.480)– Including only 6 mos. for back billing

Relevant Cites Provided

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Retail Data Variancesand

Wholesale Settlement

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• Data Aggregation & Settlements Process• ERCOT Data Loading• System Change Request 727 (SCR 727)• Data Extract Variances (DEV) and Settlements• DEVs and Settlement Disputes • Resettlements and the 2% Threshold• Charge Types Impacted by Resettlement after

True-Up

Review Items

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UFE-AdjustedREP Load

(AML)

Generation Data

RetrieveData

Apply T&D Losses

Apply T&D Losses

Generation & Zonal

Meter Data Aggregation

Generation & Zonal

Meter Data Aggregation

Calculate and Allocate

UFE

Calculate and Allocate

UFE

Loss-adjusted

REPLoad

Data Aggregation ProcessTDSP

ProfilingProfiling

SettlementsSettlements

Generation, DC Tie, & NOIE

Meters

Retail Load Data

Aggregation

Retail Load Data

Aggregation

Gen/ZonalData

AggregatedREP Load

Limited Gen & NOIE Data

RegistrationData

RegistrationData

Protocols Section 15

Retail UsageData

ProtocolsSection 10 & 15

Data Aggregation & Settlements Process

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ERCOT Data Loading - Usage

10.11.3 TDSP Polled Settlement Meters

TDSPs are responsible for providing ERCOT with [data that has been edited, validated, and is appropriate for ERCOT Settlement Agent to use for settlement and billing purposes] for the TDSP polled meters on their system and for ensuring that at a minimum the VEE requirements as specified in the Uniform Business Practices (UBP) standard for Validation, Estimating and Editing have been properly performed on such data. ERCOT will not perform any VEE on the Settlement Quality Meter Data it receives from TDSPs.

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ERCOT Data Loading - Usage15.3 Monthly Meter Reads

Each TDSP shall send monthly consumption information for all ERCOT Non-EPS ESI IDs within its service area to ERCOT not later than three (3) Retail Business Days after the scheduled meter read cycle or scheduled meter cycle by day of the month for a Point of Delivery, using the SET 867_03. TDSPs shall send monthly consumption information for all ESI IDs associated with EPS metered Facilities to ERCOT no later than three (3) Retail Business Days after TDSP receipt of daily EPS meter data from ERCOT according to the TDSP scheduled meter read cycle or scheduled meter cycle by day of the month for a Point of Delivery, using the867_03. ERCOT will forward ERCOT accepted consumption information to the CR within one (1) Retail Business Day. If the meter read for an ESI ID fails the TDSP’s internal validation procedures, the TDSP may, at its discretion, delay sending consumption information for the ESI ID to ERCOT for an additional seven (7) days in order to obtain a valid meter reading.

If a TDSP is unable to obtain a meter reading for an ESI ID because the TDSP is denied access to the meter, the TDSP may, at its discretion, delay sending consumption information for the ESI ID to ERCOT for an additional seven (7) days in order to obtain a valid meter reading.

A TDSP, with notification to the market, may suspend the transmission of monthly consumption information during periods of storm restoration or other emergency operations undertaken pursuant to its Emergency Operations Plan.

For non-ERCOT ESI IDs, TDSPs shall have the option of sending monthly consumption information and effectuating meter reads to ERCOT using the 867_03. ERCOT will then forward the monthly consumption and meter read information to the CR within one (1) Retail Business Day.

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ERCOT Data Loading – ESI ID Information

15.4 Electric Service Identifier (ESI ID)Each TDSP Service Delivery Point (SDP) shall have a unique number within Texas. Once this unique number has been created and assigned to a SDP, it shall not be re-issued, even in the event of termination of the associated point-of-service. This unique number shall be referred to as the Electric Service Identifier (ESI ID).

15.4.1.4 New ESI ID CreationSince it is anticipated that the ESI ID will be based on the existing TDSP account or Premise numbers (with a prefix identifying the TDSP), the TDSP will assign and submit to the registration database ESI IDs for new Premises as service is extended to them. TDSPs that opt-in after the market startup will be responsible for the creation of ESI IDs for all existing SDPs in their service territory.The TDSP will send ESI ID information using the 814_20. ERCOT will verify that this transaction meets SET specifications. ERCOT will respond to the TDSP within one (1) Retail Business Day, with acceptance or rejection of these transactions using the 814_21. At least the following data elements are required to be sent in the 814_20:(1) ESI ID;(2) Service Address; City, State, Zip;(3) Load Profile Type;(4) Meter Reading Cycle or Meter Cycle by day of month;(5) Station ID;(6) Distribution Loss Factor code; and(7) Premise Type.

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ERCOT Data Loading – ESI ID Information

15.5 Database Changes

The TDSP will notify ERCOT of any changes in information related to an ESI ID for which it is responsible. The TDSP will send changes to ERCOT using the 814_20. ERCOT will respond to the TDSP within one (1) Retail Business Day, using the 814_21. In addition, ERCOT will send all affected CRs notice of the changes using the 814_20. Each CR will reply to ERCOT using the 814_21. The TDSP is responsible for the following data elements:

(1) Service Address; City, State, Zip;(2) Load Profile Type;(3) Meter Reading Cycle or Meter Cycle by day of month;(4) Station ID;(5) Distribution Loss Factor code;(6) Eligibility Date;(7) Meter Type;(8) Rate class and sub-class, if applicable;(9) Special Needs Indicator;(10) Meter type, identification number, number of dials and role for each meter at the ESI

ID, if ESI ID is metered;(11) For unmetered ESI IDs, number and description of each unmetered device; and(12) Premise Type.

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ERCOT Data Loading

• ERCOT performs validations (TX Set, ANSI, and business validations) on transactions prior to loading data into ERCOT systems

• ERCOT’s settlement system (Lodestar) contains only a current view of ESI ID data – historical records are maintained in the archive

• Settlement occurs with the data that is current in Lodestar at the time of the run (best available at the time of each settlement run)

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SCR 727 Extracts and Data Extract Variances

What are SCR 727 extracts?– Extract of ESIID level data loaded into ERCOT systems and used for

Settlement (usage, ESI ID characteristics, REP relationship, etc)

– Provided to TDSPs and LSEs for data transparency

– Delivered daily

How are they used by Market Participants?– Compare SCR 727 extract data to internal source system data

– Identify data discrepancies

– Report discrepancies as Data Extract Variances (DEVs) and work to reconcile them

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Jan 23, 2003 – BOD suspends true-up for 2002 (had completed 1/1/02 – 4/20/02)

Mar 3, 2003 – SCR 727 first released to Market

Mar 14, 2003 – First DEVs submitted for 2001 & 2002

May 13, 2003 – Began resettlingTrue-Ups (1/1/02 – 4/20/02)

July 8, 2003 – Began True-Ups for 4/21/02 forward

July 2003 – MPs identified a data discrepancy in SCR 727

Sep 16, 2003 – BOD voted to suspend 2003 True-Ups

Sep 30, 2003 – Completed 2002 True-Ups

Dec 2003 – New SCR 727 released

June 1, 2004 – Began True-Ups for 2003

Oct 15, 2004 – Completed True-Ups for 20030

Feb 2004 – BOD voted to start 2003 True-Ups on 6/1/04

Dec 5, 2004 – Caught up on True-Ups (current within 6 months)

2003 2004 2005

History of SCR 727 & True-Up Settlements

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Operating Day

Final Settlemen

t

True-Up Settlemen

t

Day 17

Initial Settlemen

t

Day 0 Day 59 Day 180

Deadline for Disputes on Initial, Final, or anyResettlements

10 Business Days(Timely Dispute Deadline)

Day 170

10 Business Days (Dispute Deadline)

- Time period for timely disputes

- Time period for dispute submission

- Time available for DEV resolution

Day 105

Deadline for DEV to be filed timely for correction prior to True-Up

History of SCR 727 & True-Up Settlements

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DEVs and Settlement Disputes

ESI ID data

Adjusted Meter Load (AML)

Load Imbalance = Schedule – AMLDisputes

QSEs

DEV

LSEs

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DEVs and Settlement Disputes

• DEVs:– Generally filed between Final Statement &

True-up Statement (must be filed 75 days prior to issuance of True-up)

– Generally filed by REPS using the FasTrak tool

• Disputes:– Filed on settlement charges in question

• Example: Load Imbalance

– Filed by the QSE using settlement dispute tool

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Load Imbalance Disputes

• Load Imbalance Disputes– ERCOT Process

• Work with QSE to verify shadow settlement system calculations

• Work with QSE to verify dispute is related to data variances• If cause is other than data variance

– Work with ERCOT staff to correct data issues– Corrected data used in next settlement run

• If cause is data variance– Communicate that ERCOT settled based on data provided by

TDSPs as prescribed in ERCOT protocols– After SCR 727

» Communicate with QSE that data variances need to be worked through the DEV process

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Resettlements – Protocols Reference Language

9.2.5 Resettlement Statements

A Resettlement Statement will be produced using corrected settlement data due to resolution of disputes, correction of data errors or a short pay situation, as described in Section 9.4.4, Partial Payments. Any Resettlement occurring after a True-Up Statement has been issued must meet the same IDR Data Threshold requirements defined in Protocol Section 9.2.6. The Board may, in its discretion, direct ERCOT to run Resettlement of any trade day to address unusual circumstances.

Resettlement due to data error will occur when the total of all significant errors in data results in an impact greater than two-percent (2%) of the ERCOT Operating Day market transaction dollars, excluding bilateral transactions. A Resettlement Statement of this sort will be produced as soon as possible to correct the errors. ERCOT will review this percentage on an annual basis. Upon this review, ERCOT may make a recommendation to revise this percentage in accordance with Section 21: Process for Protocols Revision.

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Resettlements

• ERCOT produces Resettlement Statement for:– Resolution of disputes– Correction of data errors

• When the total of all significant errors in data results in an impact greater than two-percent (2%) of the ERCOT Operating Day market transaction dollars

– Short pay situation– As directed by the ERCOT Board

• ERCOT’s Practice of 2% threshold:– ERCOT calculates 2% of the absolute value for each service (line item on

the Revenue Equalization Report)– ERCOT sums those amounts for the Operating Day – This is the 2% threshold amount

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Charge Types Impacted by Resettlement After True-Up

• Question: What charge types are impacted by resettling 2001 & 2002?

• Answer: It Depends!

• Charge types affected due to data changes since the last resettlement– Data changes may occur for several reasons

• Each type may affect different charge types

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Load (ESI ID) Data Changes

• Continuously changing through retail data transactions• Will account for almost all of the changes if 2001 and 2002

are resettled• No data changes for wholesale delivery points would be

expected• Affected Charge Types:

• Load Imbalance • BENA • Any Load Ratio Share allocated charges

– Black Start and RMR Capacity Charges – Local Balancing Energy Service Charge– OOM Energy Charge – Administrative Fee Charge– System Congestion Fund (was in effect in 2001) – etc...

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Generation Resource-ID Data Changes

• Minimal changes expected for Generation Resource data if 2001 and 2002 are resettled

• Affected Charge Types: • Generation Output (GSITETOT) based payments such as the following

– RI – Local Balancing Energy Payment – OOM Energy Payment – RMR and Black Start Energy Payments

• Generation Output (GSITETOT) based charges such as the following – URC – BENA – Load Ratio Share Allocation of the above charge types

» Black Start and RMR Capacity Charges » Local Balancing Energy Service Charge » OOM Energy Charge » etc...

• Any change in generation will change Load and Load Ratio Share values• All the charge types listed for Load changes on prior slide will be affected

– Magnitude of change is significantly smaller

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Other Data Changes

• There may be some miscellaneous manual data changes entered after the last settlement statement run that did not trigger a Resettlement Statement but would be included if ERCOT resettles these Operating Days

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Questions?

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• ADRs are confidential

• Initially difficult to discuss Task Force’s issues because of abstract nature

• TXU provided an ADR example, generally, to assist in understanding the nature of the beasts

– The tale of two cities (their Loads and ESI IDs)

Confidentiality Issues

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ERCOT’s Perspective – Andrew Gallo

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ERCOT’s Perspective

• Protocols §2– Data Aggregation System

The database and communication system that will collect meter data from TDSPs….

– Meter Data Acquisition System

The system to obtain…Settlement Quality Meter Data from the TDSP for settlement and to populate the Meter Data Aggregation System and ERCOT Data Archive.

– Settlement Quality Meter Data

Data [from the TDSPs] that has been edited, validated, and is appropriate for ERCOT Settlement Agent to use for settlement and billing purposes.

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• TDSPs:– “are the only entities authorized to provide Settlement

Meter data.” (§10.1) – “are responsible for supplying ERCOT with meter data

associated with…all Loads in the ERCOT system.” (§10.2.2)

– “are responsible for…providing consumption data for each ESI ID….” (§10.3.3.1(1))

– “are responsible for…Validating, Estimating and Editing (VEE) meter data…before submitting data to the settlement process.” (§10.3.3.1(4))

– “are responsible for…metering all Loads by May 1, 2001….” (§10.3.3.1(6))

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• TDSPs:– “are responsible for providing ERCOT with [data that has

been edited, validated and is appropriate…to use for settlement and billing purposes] for the TDSP polled meters on their system….” (§10.11.3)

– “provide data for TDSP Metered Entities.” (§11.2.2)

– “shall send monthly consumption information for all ERCOT Non-EPS ESI IDs….” (§15.3)

– must “create, assign, maintain and retire, as necessary, an ESI ID to each SDP in its service area.” (§15.4.1)

– “will assign and submit to the registration database ESI IDs for new Premises as service is extended to them.” (§15.4.1.4)

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• TDSPs:– assign a Station ID to an ESI ID to inform ERCOT the sub-station

for the ESI ID (§15.4.1.4)• At least the following data elements are required to be sent…:

(1) ESI ID;

(2) Service Address; City, State, Zip;

(3) Load Profile Type;

(4) Meter Reading Cycle or Meter Cycle by day of month;

(5) Station ID;

(6) Distribution Loss Factor code; and

(7) Premise Type.

– ERCOT maps the sub-stations to the CMZs.

– Depending on which sub-station assignment the TDSP provides, ERCOT puts the ESI ID in the corresponding CMZ.

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• TDSPs:– “will notify ERCOT of any changes in information related to an

ESI ID for which it is responsible.” (§15.5)– are “responsible for the following data elements:” (§15.5)

(1) Service Address; City, State, Zip;(2) Load Profile Type;(3) Meter Reading Cycle or Meter Cycle by day of month;(4) Station ID;(5) Distribution Loss Factor code;(6) Eligibility Date;(7) Meter Type;(8) Rate class and sub-class, if applicable;(9) Special Needs Indicator;(10) Meter type, identification number, number of dials and role for

each meter at the ESI ID, if ESI ID is metered;(11) For unmetered ESI IDs, number and description of each unmetered

device; and(12) Premise Type.

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PURA §38.005 requires that “transmission and distribution utilities” must “comply with any operational criteria duly established [ERCOT] or adopted by the commission.”

In essence, ERCOT has followed the requirements of the Protocols in settling the Operating Days at

issue.

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Legal Perspectives

• TXU – Brad Jones

• TEAM

• Direct Energy – Ryan Thomason

• OPC – Laurie Pappas

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PURA

Protocols

TXU’s Perspective

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Analysis of PURA and ERCOT market protocols provide the following viewpoints relating to ADR application and management. Though preliminary, the insight provided by the analysis points below raises further questions regarding the validity of the ADRs that are before the market.

TEAM’s Perspective

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The Protocols are adopted by ERCOT through authority delegated by the PUC under PURA § 39.151(i).

These Protocols were reviewed and approved by the PUC (See, P.U.C. Docket No. 23220).

The Protocols are an extension of the PUC’s rules and are not contractual provisions.


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The establishment of the 2% threshold in Protocol 9.2.5 does not authorize ERCOT to resettle for data errors below the 2%.

The language in the protocol that requires this threshold to be revisited annually implies that there is no discretion for ERCOT to resettle based on data errors below this threshold.


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The ADR provisions in Chapter 20 of the Protocols do not allow an ADR to be held for an extended period of time. Protocol 20.1 states that Parties shall exercise good faith efforts to timely resolve ADRs.

Also, there are specific timelines for processing any pending ADR request. If the ADR is not resolved, there are also specific trigger points that initiate the 35 day window for appealing the action/inaction to the PUC under P.U.C. Proc. R. 22.251.


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It is Direct Energy’s position that the Market Protocols dictate the proper avenues of resolving a dispute or an ADR whether or not the Market Participant is satisfied with the outcome of the resolution.

Direct Energy would like to affirm ERCOT’s current interpretation and practice regarding the “2% Rule”, as set forth in Section 9.2.5 of the Protocols.

Direct Energy’s Perspective

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Section 9.2.5 Resettlement Statement states :• “Resettlement due to data error will occur when

the total of all significant errors in data results in an impact greater than two-percent (2%) of the ERCOT Operating Day market transaction dollars…”– According to ERCOT, the claimants’ stated dollar value does not

meet the 2% Market threshold.

– Direct Energy cannot recall any incident where ERCOT circumvented Section 9.2.5 so as to accommodate a Market Participant. Is this true?

Direct Energy’s Perspective

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• PURA

• PUC Rules

• Protocols

Office of Public Utility Counsel’s Perspective

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Interpretation of Protocols

TAC ADR Task Force

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Interpretation 1 - ERCOT’s interpretation of the Protocols: deny post-true up load imbalance ADRs related to data that is provided to ERCOT by Market Participants, including TDSPS, unless the data error is greater than 2%.

ADVANTAGES DISADVANTAGES ISSUES/IMPACTS

Finality Increases individual market participant risk

Places financial risks on TDSPs

Clarity Accepts less accurate data set if other data becomes available post true-up

More disputes against 3rd Parties

Certainty Denying a market participant what they are due

Different set of market participants

Reduce Market Risk by abiding by Protocols

More disputes against 3rd parties

If party being denied takes the issue to the PUCT and then ERCOT is ordered to do something that we have no say in – outcome that we may not like – Encourages further actions at PUCT/District Court level.

Discourages non-specific disputes Lose ability to recover charges from customers

Encourages getting data right within 180 days

Continuous settlements raises costs for everyone – this lowers market participants costs

Reaffirms governance process(file PRR if grey area)

Preventing administrative costs

Costs to absorb uplift avoided

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Interpretation 2 – ERCOT may resettle if the data error is less than 2%


Chances of getting it right Perpetual resettlements Synchronization of ERCOT settlement timeline, TDSP tariffs, Customer Protection rules

Reduces individual market participants risk

Disincentive to get it right the first time

Grants Market participants what they are owed

Creates incentive for MPs to get things in on time

Accuracy of Settlement improved Presents opportunity for undue discrimination - “May”

Accountability is reduced

Lose ability to recover chargers from customers

Financial exposure for MPs* (especially public companies)

May increase escalation of ADRs

Data storage, system capability, resources to analyze volume of ADRs, resettlement – ERCOT costs increased

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*Financial Exposure includes the following :•Financial books of MP’s have been closed for resettlement periods in question•Financial impact to market can be substantial potentially forcing certain market players out of the market due to possible uplift recovery as a result of other MPs having exited he market•Precedent for secondary ADR/resettlement of any operating day•Cost to resettle market based on TDSP and ERCOT resources required to re-work DEV issues for operating days in question could be significant•True monetary value of ADRs filed is unknown•Potential delay in current settlement process as a result of revisiting previously closed operating days•Subsequent adjustments to balancing energy for operating days in question•Subsequent credit requirement adjustments for market participants

Interpretation 2 – ERCOT may resettle if the data error is less than 2%

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Interpretation 3 – ERCOT may resettle even if data error was external to ERCOT


May relieve TDSPs of financial risks

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Deny post-true up load imbalance ADRs related to data errors

unless the data error is greater than 2% of the ERCOT Operating Day market transaction

dollars.

ERCOT’s Interpretation of Protocols(Interpretation # 1)

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Interpretation #1: Advantages

• Certainty– At some point certain, market participants

(MPs) know if they made or lost money (and the amount).

– MPs can close their books– Creates less risk for investors

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Interpretation #1: Advantages (continued)

• Clarity• Reduces market risk by abiding by the

Protocols– Participants know what ERCOT will do– Don’t have to worry about ERCOT favoring

certain market participants

• Discourages non-specific disputes– Placeholder disputes in case some new data

comes along

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Interpretation #1: Advantages (continued)

• Encourages getting data right in 180 days– If ERCOT accepts data whenever it becomes available, it does not

encourage Market Participants to be diligent in getting correct data to ERCOT in a “reasonable” timeframe.

• Reaffirms governance process– If the area is grey a Protocol can be filed

• Continuous settlements raises costs for everyone– this scenario lowers market participants’ costs

– Prevents administrative costs (many parties house data on microfiche and/or would have to outsource re-settlement activities to technical third parties or hire additional resources)

– Costs to absorb uplift avoided

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Interpretation #1: Disadvantages

• Increases individual market participant risks– A market participant may not be settled accurately

• Accepts less accurate data set if other data becomes available post true-up

• Denies a market participant what they are due

• Could create more disputes against 3rd parties

• Lose ability to recover charges from customers

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Interpretation #1: Issues/Impacts

• May place financial risks on TDSPs

• More disputes against 3rd parties

• Potentially different set of market participants impacted– Parties who weren’t in the market at the time will incur

share of the uplift

– Parties who were in the market at the time do not incur their share of the uplift

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Interpretation #1: Issues/Impacts (continued)

• Encourages further actions at the PUCT and/or District Court– Market will not have a say in the outcome– Outcome may be something market doesn’t like– Creates risk

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ERCOT may resettle if the data error is less than than 2% of the ERCOT Operating Day market transaction dollars.

Another Interpretation of Protocols(Interpretation # 2)

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Interpretation #2: Advantages

• Chance of getting it right

• Reduced individual market participant risk

• Grants market participants what they are owed

• Accuracy of Settlement improved

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Interpretation #2: Disadvantages

• Perpetual resettlements• Disincentive to get it right the first time• Creates disincentive for market

participants to get things in on time• Presents opportunity for undue

discrimination• Accountability is reduced• Companies lose ability to recover charges

from customers

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Interpretation #2: Disadvantages (continued)

• Financial Exposure for Market Participants especially public companies– Financial books have been closed for resettlement

periods in question– Financial impact to market can be substantial-

potentially forcing certain MPs out of the market– Precedent for ADR/resettlement of any operating day– Cost to resettle market based on TDSP and ERCOT

resources required to re-work DEV issues for operating days in question could be significant

– True monetary value of ADRs filed is unknown– Potential delay in current settlement process as a result

of revisiting previously closed operating days

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Interpretation #2: Disadvantages (continued)

• May increase the number of ADRs

• ERCOT costs increased– Data storage– System capability– Resources to analyze volume of ADR’s

resettlement

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• Synchronization of ERCOT settlement timeline, TDSP tariffs and customer protection rules

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ERCOT may resettle even if the data error was external to ERCOT.

Another Interpretation of Protocols(Interpretation # 3)

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• May relieve TDSPs of financial risks– Risks associated with meter reading errors– Risks associated with instrument failure– Other risks– Uplift to customer may be viewed by different

entities as either positive or negative

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Has the TAC ADR Task Force

educated you?

TAC ADR Task Force Presentation

70

The monkey is off our back.

TAC ADR Task Force Presentation

The buck has now been passed.

It’s time for TAC to act.

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TAC ADR Task Force

Presentation to TAC

6 May 2005

1 TAC ADR Task Force Presentation to TAC 6 May 2005.

Documents

Transcript of 1 TAC ADR Task Force Presentation to TAC 6 May 2005.