Three units describe three different things in FERC's February 7 uplift proposal. Dollars measure payments. Megawatts measure operator-initiated commitments. Megawatt-hours measure schedule deviations relevant to the proposed allocation of certain real-time uplift costs. Substituting one for another would obscure what the proposal asks regional electricity-market operators to explain. [2017-02332][2016-30971]

The allocation rule would apply where an operator already charges real-time uplift to deviations. It would limit those charges to transactions reasonably expected to cause the costs, rather than require all operators to adopt that method. The deviation definition excludes changes related to economic or reliability dispatch instructions. Within the proposed framework, helpful deviations offset harmful ones hourly. [2017-02332][2016-30971]

Transparency has its own structure. Proposed uplift reporting organizes dollar payments by transmission zone, day and category, with aggregation or omission provisions for small zones, and separately totals each recipient resource's monthly uplift. Operator-initiated commitments would be reported in megawatts by zone and reason. These are proposed disclosures, not evidence that payments have fallen. [2017-02332][2016-30971]

The separate fast-start proposal published in December concerns how eligible resource offers enter prices. Its definition combines startup within ten minutes, minimum run time no longer than one hour and an economic energy offer, excluding self-scheduled energy. It does not promise price-setting in every circumstance. Reading the two proposals together separates the allocation of costs from calculation of prices; their common agency origin does not provide independent proof of economic benefits. [2017-02332][2016-30971]

Source documents

  1. Uplift Cost Allocation and Transparency in Markets Operated by Regional Transmission Organizations and Independent System Operatorshttps://www.govinfo.gov/content/pkg/FR-2017-02-07/html/2017-02332.htm
  2. Fast-Start Pricing in Markets Operated by Regional Transmission Organizations and Independent System Operatorshttps://www.govinfo.gov/content/pkg/FR-2016-12-30/html/2016-30971.htm