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Kyele's Passion. Ameren prefers that any remaining uplift associated with transmission rights should be assigned pro rata over all financial transmission rights holders. Financial Transmission Rights: Analysis, Experiences and Prospects present a systematic and comprehensive overview of financial.
Lecture Notes in Energy. Financial transmission rights: Analysis, experiences and prospects holder has either the right to collect a payment when congestion occurs in the energy market or. NYISO states that it is already in compliance with guideline 2 because its financial transmission rights Transmission Congestion Contracts are already fully funded, with transmission owners paying any revenue shortfalls.
However, New York Transmission Owners argue that the transmission rights allocated in New York to support native load are not currently consistent with guideline 2 because they are allocated annually and the quantities may not be the same each year. To fix the quantities from year to year, they argue that NYISO would presumably have either to reduce the quantity allocated, create counterflow rights, or eliminate the simultaneous feasibility test, all of which could create congestion rent shortfalls in the day-ahead market.
Hence, they argue that it is critical that the Commission ensure that NYISO and stakeholders have flexibility in the development of the rules for long-term rights. TAPS argues that the full funding guarantee would place the burden on the transmission organizations to be accountable for the performance of the transmission rights that they allocate. New England Public Systems argue that full funding is consistent with the underlying principles of Order No.
Under Order No. Transmission providers also bear redispatch costs, which provided a further incentive to expand transmission capacity to accommodate known or predictable uses. APPA similarly argues that full funding is consistent with section b 4. A few commenters, such as TAPS, also include rights to renewable generation resources. Hence, full funding would only extend to that quantity of rights. PJM agrees that a limited application of full funding is feasible. A number of parties note that full funding will require a consistent approach to transmission planning and expansion to minimize the potential for cost shifting.
We address the relationship of long-term firm transmission rights and transmission planning and expansion in Section II. BPA suggests that while locational marginal pricing may not be the congestion pricing model adopted in the Pacific Northwest, the principles underlying guideline 2 should be upheld.
BPA argues that cost stability for long-term transmission should prevail over concerns about equity and fairness of the allocation of long-term rights and associated costs among market participants. On the proper allocation of responsibility for revenue shortfalls, several commenters supporting full funding argue that some or all of the revenue shortfalls encountered by long-term rights should be funded by transmission owners. Industrial Consumers argues that transmission organizations cannot manage risks associated with financial transmission rights, and that such risks can only be managed by transmission owners.
A few commenters that support the assignment of full funding uplift to transmission owners argue for limits on the obligations of transmission owners. PJM Public Power Coalition states that transmission owners should be held accountable for inadequate maintenance Start Printed Page practices or poor system planning and any resulting long-term rights funding shortfall should be assigned to them. Similarly, BP Energy argues that revenue shortfalls should be assigned to transmission owners only if they are due to negligence.
NRECA and TAPS argue that the assignment of revenue shortfalls to transmission owners is appropriate only if the transmission owner fails to fulfill in good faith the transmission organization's instruction to plan and construct transmission facilities. Absent that situation, TAPS argues that funding responsibility should be broadly shared by all users of the transmission grid on a pro rata basis, since the failure is the transmission organization's failure to plan and expand the system.
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Most transmission owning utilities and some other commenters argue that transmission owners should not be required to fully fund long-term rights under most circumstances. Second, in the planning process, it is the transmission organization that must undertake the planning for upgrades and approve new transmission facilities to reduce congestion.
Third, decisions of siting authorities and input of stakeholders significantly affect location of new facilities and when they are brought on-line. Fourth, due to the nature of power flows in a large regional transmission organization, it may be difficult to determine exactly which transmission owners are responsible for changes in transmission capability. Fifth, just as important to revenue adequacy as building new facilities is the design of the transmission rights and the modeling used in their allocation.
Under most transmission organization rules, transmission owners cannot directly reduce the quantity of rights that are allocated or auctioned to manage their exposure to full funding uplift charges although some commenters note that guideline 2 may create an incentive for the transmission owner to do so indirectly by providing the transmission organization with conservative ratings for transmission facilities.
Moreover, transmission organizations control the development and implementation of the models that underlie FTR allocation. Sixth, transmission transfer capability is often affected by factors outside the transmission owners' and transmission organization's control, such as loop flow.
IPL notes that since a proposed transmission facility required for purposes of transmission rights held by others may have limited local benefits, state approvals may be difficult to obtain.
IPL and Reliant argue that the Commission should not attempt to use the revenue sufficiency rules for long-term rights as an incentive for transmission investment, which is better addressed through separate incentives. MSATs note that transmission owners that are transcos firms that own regulated transmission assets only would be particularly problematic because such firms do not hold FTRs.
MSATs ask that the Commission recognize that such a requirement would directly conflict with the transco business model for two primary reasons. First, transcos are neither transmission customers nor market participants. Hence, requiring transcos to take a position in the transmission rights markets would be inconsistent with their business model.
It would also be inequitable to transcos. Second, transcos rely on a revenue stream that is far more concentrated than that of a vertically integrated utility.
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MSATs claim that the liability associated with underfunded transmission rights could exceed a transco's total transmission service-dependent revenue in some cases. Allegheny argues that while it can support full funding, the transmission organization should be responsible for providing full funding through its transmission customers. Allegheny recommends that this charge be assessed on all long-term firm and network transmission customers. Several commenters propose that only the holders of long-term transmission rights be collectively allocated the costs of any revenue inadequacy associated with the rights.