California Independent System Operator Memorandum To: ISO Operations (MRTU) Committee From: Eric Leuze, Director of Compliance cc: ISO Board of Governors, ISO Officers Date: April 29, 2005 Re: Deferral of Uninstructed Deviation Penalties: Monitoring Plan and Stakeholder Process This memorandum requires Board action. EXECUTIVE SUMMARY In the interest of addressing certain significant stakeholder concerns, Management requested approval from the Board of Governors to conditionally defer the Uninstructed Deviation Penalty (UDP) beyond May 1, 2005. At the April 25, 2005 meeting of the Board by teleconference, Management explained its proposal to define objective criteria to determine whether deferral of UDP can be continued, and to initiate a stakeholder process to identify whether any UDP rules must be revised. At Management s request, the Board passed a motion on April 25 authorizing Management to continue deferring the Uninstructed Deviation Penalty (UDP) until the May 6 meeting. This memorandum presents Management s proposal for: 1) conditional deferral of UDP and a framework for defining the circumstances under which the ISO may seek an immediate effective date for UDP to provide a safety net for Summer 2005 operations, and 2) a schedule and plan for a stakeholder process to define outstanding questions and resolve any UDP design issues. Four criteria have been identified to provide objective measures of whether or not system conditions have degraded to such a point that action, such as seeking immediate implementation of UDP, is required. A method for establishing benchmarks for each of these criteria and threshold changes in those criteria are proposed, so that if the threshold values for any two of the criteria are exceeded in any report on performance, then the presumption is that the ISO should file a tariff amendment to make UDP effective, subject to Management s consideration of other factors and conclusion that immediate action is required. Management would begin publishing these bi-weekly reports on May 12, 2005. Because the premise of deferring implementation of UDP is that some changes in UDP rules may be necessary, Management also proposes that the Board authorize Management to include narrowly defined changes in UDP rules in any such tariff amendment to establish an effective date for UDP. In summary, Management seeks authority to file a tariff amendment during Summer 2005 for an immediate effective date for UDP, and, as Management determines necessary and appropriate, to increase the Tolerance Band to no more than 5 percent and/or to provide an exemption for brief excursions outside the Tolerance Band. Authority to file such a tariff amendment is contingent on Management s determination that: 1) Uninstructed deviations have contributed to significant degradation in operating conditions as indicated by two metrics that exceed the threshold criteria as specified in this memorandum, and 2) Immediate action to address such uninstructed deviations is required. Created by: EML CAISO LST UPDT: 4/21/05 151 Blue Ravine Road Folsom, California 95630 Page 1 (916) 351-4400
Recognizing that circumstances change, and that unanticipated conditions may well arise, Management does not propose that the Board obligate Management to file for an immediate effective date for UDP if any two of the threshold criteria are triggered, but that the Board allow Management the discretion to consider other relevant factors in determining whether filing for an immediate effective date is necessary. Should Management conclude that no filing should be made even though two or more of the threshold criteria have been triggered, Management will promptly enumerate the reasons for that conclusion for the Board s consideration, and the Board may then concur or direct Management to immediately file a tariff amendment immediately or take some other action at the Board s discretion. Moved, that the Board of Governors hereby authorizes Management to: 1) Defer action to implement the Uninstructed Deviation Penalty (UDP) until the Board provides further direction at its September 2005 meeting; 2) Move forward with the stakeholder process and monitoring plan as described in the memorandum of April 28; and 3) Take action as described in the April 28 Memorandum in the event that the conditions described in that memorandum arise. INTRODUCTION On October 1, 2004, the ISO implemented the market redesign features of Phase 1B of the Market Redesign and Technology Upgrade (MRTU) Project, which included the Real Time Market Application (RTMA). RTMA estimates the ISO s Imbalance Energy requirement, and based on bids and operating constraints submitted by Imbalance Energy resources, RTMA issues Dispatch Instructions every five minutes. The Uninstructed Deviation Penalty (UDP) provides an incentive that is critical under this integrated design to follow Dispatch Instructions and deliver expected Energy in each 10-minute Settlement Interval. 1 The purpose of this memo is to provide the proposed metrics that the ISO will monitor during the conditional deferral of UDP implementation, the threshold changes in those metrics that may indicate that the ISO should file UDP, additional information responsive to stakeholder comments, and an outline the ISO s plan for a stakeholder process. The ISO is Prepared to Implement UDP As explained in the April 21 Board memo, Management believes that the ISO has fully met the conditions that FERC established on UDP implementation, which included an electronic reporting mechanism for reporting changes in the availability of Generating Units, and multiple ramp rates to better reflect differences in capability across the full operating range of a Generating Unit. The January 21, 2005 Board memorandum specified four additional milestones that must be completed before UDP should be implemented. In brief, the status of accomplishment of these milestones follows: 1) Automated Dispatch System (ADS) connectivity issues were resolved on March 11, 2005 2) A modification to verify delivery of instructions issued through ADS Application Programming Interface (API) will be implemented by May 13, 2005; 1 For additional background, refer to the April 21, 2005 memorandum regarding Briefing on Revised Management Proposal for Implementation of Uninstructed Deviation Penalties, available at http://www.caiso.com/docs/09003a6080/35/9a/09003a6080359a0d.pdf 2
3) The ISO published two months of advisory UDP results based on Settlement Quality data, by mid-march, and has now published more than three months of such results; 4) All required process improvements and software modifications to reduce UDP processing time were implemented in February and March 2005. The public comments offered at the April 25 Board meeting regarding ISO readiness to implement UDP are addressed in detail later in this memorandum. Phase 1B Business Objectives Are Aggressive Metrics previously identified for Phase 1B implementation provide a relevant starting point for the development of proposed metrics that the ISO will monitor during the conditional deferral of UDP. The Phase 1B business objectives are summarized below: 2 Improve Frequency Control An objective of a 10% improvement in performance on ACE was established. Changes in the ISO s success in meeting Control Performance Standards (CPS) since Phase 1B was implemented is one measure of whether the ISO has improved frequency control. Reduce Generation Deviations Although no specific reduction in uninstructed deviations was targeted, one objective standard might be the relationship between uninstructed deviations and a reliability target, such as CPS2 performance. Reduce Regulation Requirement A reduction in Regulation requirement of 10% to 20% was targeted when Phase 1B was implemented These business objectives provide a point of reference for the development of metrics related to the impact of uninstructed deviations. However, as discussed further below, the threshold criteria for implementation of UDP in Summer 2005 represent much less aggressive expectations for the success of Phase 1B the ISO may fall far short of the Phase 1B business objectives and still avoid tripping the threshold criteria and the associated presumption that UDP should be immediately implemented. Purpose of Proposed Threshold Criteria is Limited To be clear, Management does not propose that operation through September 2005 without tripping any threshold criteria would mean that UDP is unnecessary. The threshold criteria are being proposed to provide a test of whether or not conditions have deteriorated so significantly that the temporary suspension of UDP cannot be continued. In fact, it is possible that none of the threshold criteria for an immediate filing to make UDP effective are triggered, while at the same time the results may indicate that the ISO is falling far short of the business objectives established for the Phase 1B redesign of the ISO s real time market. For example, one business objective for the ISO s Imbalance Energy Market was to reduce Regulation requirement by 10 percent to 20 percent. In contrast, the threshold criterion for whether the ISO should consider seeking immediate implementation of UDP is an increase in Regulation requirement of 5 percent. 3 This difference illustrates the narrow purpose of the threshold criteria. 2 Phase 1B business objectives are described in Update on Phase 1B Roll-Out and Operation, presentation to ISO Board of Governors on November 10, 2004, page 9, available at http://www.caiso.com/docs/09003a6080/33/b5/09003a608033b566.pdf 3 The metric calculated for the current period is compared to a calculation for a similar time period before Phase 1B was implemented. 3
Limited Changes to UDP Design Will Be Considered As noted in the April 21 Board memo, some Market Participants have argued that there are certain circumstances in which UDP cannot be avoided due to unrecognized operating constraints, such as steam inertia. The ISO believes that additional analysis of advisory UDP results and information from stakeholders will be useful in determining whether there are circumstances where UDP is imposed because an operating constraint has not been recognized. If the ISO concludes that some portion of UDP assessments may arise due to the existence of unrecognized operating constraints, then some modification of UDP rules may be appropriate. The ISO does not propose to customize the UDP rules for every technology, but has identified two categories of changes that may mitigate the UDP risk associated with any unrecognized operating constraints. First, the ISO will consider expanding the Tolerance Band. Although the New York ISO uses a tolerance band similar to the ISO s existing design, which is based on 3 percent of the maximum capability of a generating facility, the ISO is willing to consider an expansion of the Tolerance Band up to 5 percent. This expansion would allow additional minor deviations if necessary due to unspecified operating or design characteristics of a Generating Unit. The ISO will be particularly interested in identifying, where possible, some of the root causes of deviations that would be subject to UDP if the Tolerance Band is only 3 percent, and why an expanded Tolerance Band is necessary. The second possible change the ISO has identified is to provide a limited exemption for brief excursions outside the Tolerance Band. The ISO understands that the New York ISO provides such an accommodation for up to three dispatch intervals or 15 minutes to mitigate the possible consequences of operating constraints such as steam inertia, and is interested in exploring whether such an accommodation would be effective in addressing any operating constraints that RTMA does not recognize. In the event that the threshold criteria are triggered and Management is required to consider a tariff amendment for an immediate effective date for UDP, Management is requesting authority to consider modification of UDP rules. With the Board s approval, the amendment to the ISO Tariff seeking an immediate effective date for UDP may incorporate the following specific changes: an increase in the Tolerance Band up to and including 5 percent of the maximum capability (PMax) and/or an exemption for brief excursions outside the Tolerance Band. The ISO Does Not Believe Changes to SLIC or RTMA are Required In the April 21 Board memorandum, the ISO described several stakeholder concerns that Management does not at this time believe should delay UDP implementation. However, the ISO will provide an opportunity for stakeholders to provide additional information and explain these concerns, which include contentions that SLIC is too cumbersome and that RTMA dispatch is too unpredictable. As noted in the April 21 memo, the ISO acknowledges that reporting outages can be cumbersome, and is reviewing possible design changes to improve the supplier s access to outage information and the efficiency with which changes in availability can be reported. The ISO again affirms its belief that SLIC functionality fully meets FERC's condition that the ISO provide a proven means of allowing electronic reporting of outages and derates. The ISO knows of no circumstance in which SLIC limitations would prevent a supplier from reporting a change in operating status necessary to avoid UDP within 30 minutes after such an event occurs. Nonetheless, the ISO intends to invite stakeholders to comment on SLIC, provide examples of problems, and explain the specific limitations that prevent a supplier from reporting timely changes in availability necessary to avoid UDP. The ISO also reaffirms its commitment to evaluate RTMA performance and the volatility of the Imbalance Energy Market to determine whether there are any changes in rules for how the Imbalance Energy Market is used to balance the system. As Management has noted, RTMA appears to be operating consistent with its design, and there are no guarantees that any reduction in volatility can be achieved. However, the ISO will provide additional 4
information on RTMA operation and will invite stakeholder comments, examples and analysis with regard to RTMA design deficiencies or performance shortfalls. At the June Board meeting, Management will present its conclusions regarding the scope of issues relevant to UDP implementation. MONITORING PLAN This section defines proposed metrics and criteria for the ISO s consideration in determining whether immediate implementation of UDP may be appropriate. Four metrics are identified, and would be periodically published to objectively characterize the performance of the Imbalance Energy Market and the impact of uninstructed deviations. The first report would be issued on May 19, 2005. 4 Appendix 1 provides an illustration of a summary of the calculations that will be developed. This summary, together with supporting documentation, will be published in each bi-weekly report. Approach For each metric, a margin of difference is defined to represent an unacceptably large degradation in performance. The metric for the benchmark period is adjusted by the margin to define the threshold criterion. This threshold criterion is compared to the metric calculated for the current period. If the metric calculated for the current period exceeds the threshold criterion, then that criterion is triggered. Measurement and Reporting The ISO proposes to use a rolling measurement interval of 8 weeks, and to calculate the metrics every two weeks. One significant question is what data should be used, involving a critical trade-off between the timeliness and the accuracy of the calculated metrics. If the metrics are calculated using data available shortly after the trade day, then accuracy will suffer, as significant changes to Expected Energy due to verbal instructions and other issues may occur several days after the Trade Day. Conversely, if the ISO uses data reflected in Preliminary Settlement Statements, then there is a delay of several weeks between operating period and the calculation of the metrics. Although the ISO will consider whether some other option is available, Management now proposes to rely on Preliminary Settlement Statement data. 5 However, if any conditions arise that suggest an unacceptable degradation of performance, then the ISO will not wait until the metrics are calculated, but will promptly alert the Board and FERC, and take other actions, as necessary. The ISO will use existing tariff authority, such as the Enforcement Protocol, to address event-specific problems where, for example, a supplier fails to comply with an operating order. Measurement Interval Using an interval as short as one week or even one month may be unreasonable due to the increased volatility one would expect with respect to any metric over a shorter measurement interval. A longer duration of 8 weeks is proposed. Margin of Difference A separate margin is proposed for each metric. The margins are estimates of what would represent unacceptably large degradations in performance. 4 The May 19 report will present metrics for the benchmark period of January 21, 2004 to March 17, 2004 and for the current period of January 21, 2005 to March 17, 2005. The benchmark period and current period will roll two weeks with each biweekly report. 5 From October through mid-january, the ISO relied on data that was available before settlement statements were published in the interest of providing more timely advisory UDP results. Based on that experience, the ISO concluded that accuracy must take precedence over timeliness, and in mid-january time began publishing advisory results based on data used for Preliminary Settlement Statements. 5
Reporting A rolling 8-week calculation is proposed to be published bi-weekly. The calculated metrics will be reported on the ISO Home Page. Proposed Metrics The ISO proposes to monitor the following metrics. An update on the performance of these metrics will be provided at the June Board meeting, at which time revisions may be proposed. Uninstructed Deviations Significant increases in the mean and/or variance in aggregate uninstructed deviations by Generating Units may suggest that a strong incentive to follow Schedules and instructions as would be provided by UDP should not be further delayed. This metric is calculated by comparing the Expected Energy based on Final Hour Ahead Schedules, as adjusted by ISO Dispatch Instructions, to the metered Energy for each Settlement Interval. One issue is that all corrections to Expected Energy are not completed until several weeks after the Trade Day, although 95% of corrections are completed within 96 hours. Since these corrections generally reduce the volume of estimated uninstructed deviations, there is an increased risk that an erroneous conclusion that the magnitude or variance of uninstructed deviations has increased exists for calculations that are made shortly after the relevant Trade Days. The longer the calculation is delayed, the better the data quality, but the longer before any ISO action that depends on such a metric is taken. 6 As noted above, the ISO has determined that accuracy takes precedence over timeliness with respect to the calculation of metrics, and Preliminary Settlement Statement data will be used. The proposed margin for uninstructed deviations is the greater of an increase of 50% or 200 MW in average uninstructed deviations (e.g., an increase from 100 to 200 MW would not be a trigger, but 50 MW to 250 MW would be a trigger.) Reliability Any significant decline in average CPS 2 performance demands attention. While uninstructed deviations may play a role, other factors can have a significant effect, including limited ramping capability in the Imbalance Energy Market, deficiencies in the supply or performance of Regulation, or other factors such as the magnitude and volatility of interchange ramps and deviations between forward scheduled load and actual load. Recognizing that the Imbalance Energy Market is a key tool in balancing the system, however, a metric based on significant change in CPS2 performance is proposed. The propose margin is the smaller of a drop to below 90% in CPS2 performance, or a decrease of 4 percentage points in CPS performance (e.g., a decrease from 94% to 90% or 92% to 89% would be a trigger, but not a decrease of 93% to 90%.) Impact of Deviations on Reliability One way to better recognize the relationship between uninstructed deviations is to explicitly consider the contribution that uninstructed deviations make to CPS2 violations. A CPS2 violation occurs whenever the ISO s average ACE across a ten-minute interval exceeds a specified threshold ( L10 referred to as Lsub10 ), which is 116.3 MW in 2005. 7 6 A second issue is that the magnitude and/or variance of uninstructed deviations may increase as the load level, and the associated number of Generating Units and the total expected Generation, increases. It may be useful to consider uninstructed deviations normalized by load level to eliminate the effect of increasing loads on the level on uninstructed deviations. However, such a metric may erroneously imply that so long as uninstructed deviations do not increase relative to load level that no action is required, when in fact any significant increase in the absolute magnitude or variance of uninstructed deviations is the more relevant consideration. A metric based on normalized deviations would require additional time to make sure that the variables are properly specified and that the hypotheses are well constructed. No such metric is proposed at this time. 7 CPS2 is measured monthly by considering the number of 10-minute intervals in which the average Area Control Error (ACE) is within a bandwidth defined by L10. The ISO s L10 is determined annually based on the targeted frequency bound for each Control Area in the WECC, and the Frequency Bias Setting for the ISO, which is a measure of the MW associated with a given 6
If uninstructed deviations are in the same direction as the ISO s ACE in a 10-minute interval, then the uninstructed deviations contribute to or exacerbate the CPS2 violation, while if the uninstructed deviations are of the opposite sign, then the uninstructed deviations mitigate ACE. 8 If the aggregate uninstructed deviations contribute to ACE by an amount in excess of L10, then such a condition, while not definitive, suggests that uninstructed deviations may have had a significant impact on the ISO s ability to maintain system balance. The ISO proposes to initially establish a benchmark for the number or percentage of intervals with CPS2 violations in which the average volume of contributing uninstructed deviations exceeds the ISO s L10. The proposed margin is a 50 percent increase in the proportion of CPS2 intervals in which contributing uninstructed deviations exceed the ISO s L10. For example, if uninstructed deviations exceed the ISO s L10 in 10 percent of CPS2 intervals in the benchmark period and 16 percent in the current period, then the threshold criterion is triggered (16 percent represents a 60 percent increase over 10 percent). Regulation Requirement Another proposed metric is changes in the volume of Regulation requirement. As Imbalance Energy Performance declines, the ISO will be required to increase reliance on Regulation. As a point of reference, Regulation procurement has decreased for January through March 2005, as compared to the same period a year earlier, but has not declined to the extent of the Phase 1B business objective. 9 The proposed margin is an increase in Regulation requirement of 5 percent. For example, if the average hourly Regulation requirement increases from 750 MW in the benchmark period to 780 MW in the current period, representing a 4 percent increase, then the threshold criterion is not triggered. Management Must Reserve Discretion If the threshold criteria for two or more of the selected metrics are triggered in one of the bi-weekly reports, then the presumption is that the ISO should file for an immediate effective date for UDP. However, Management will have the discretion to consider additional factors in determining whether the ISO should instead take some other action. Conversely, the presumption is that if two or more of the threshold criteria are not triggered, then the ISO will not file to make UDP effective until all issues are resolved. Here again, Management will consider other factors in determining whether Board authority should be requested to file a tariff amendment to make UDP immediately effective, either as designed, or reflecting modification of the Tolerance Band or an exemption for brief excursions outside the Tolerance Band. 10 PUBLIC COMMENTS AT APRIL 25 BOARD MEETING The public comments provided during the Board s meeting on April 25 are worth considering. One commenter suggested that the ISO might not need UDP because the ISO has the necessary tools to address uninstructed deviations, which include FERC s Market Behavior Rules, the ISO s new authority to impose penalties under Amendment 55, and the ISO s No Pay provisions. While each of these tools is important, none provides a reasonable substitute for UDP. Action under the first tool, FERC Market Behavior Rules, would only be taken if the change in frequency. The NERC standard and the ISO s corporate goal require that the ISO s ACE be within the L10 during 90% of the 10-minute intervals over a calendar month. 8 For example, if the ACE averages positive 200 MW across a ten-minute interval, and uninstructed deviations average a positive 100 MW across the ten-minute interval, then those deviations contribute to ACE, while if the uninstructed deviations average 50 MW, then they mitigate ACE. 9 Regulation requirement decreased between 3 and 9 percent between December 2004 and March 2005 as compared to the prior year. 10 To be clear, no authority is proposed to be delegated to Management to file a tariff amendment without further Board approval unless two or more of the criteria are triggered. 7
ISO, or FERC on its own initiative, identified an egregious event or a pattern of behavior that consistently violates one or more of the Market Behavior Rules. This is no substitute for UDP, which monitors performance of every resource subject to UDP in every Settlement Interval. The second tool, the ISO s authority under the Enforcement Protocol accepted by FERC in Amendment 55, does not provide the ISO any penalty authority FERC has reserved all authority to impose penalties under the EP. More importantly, the only instructions subject to review as violations of an ISO operating order under the EP are those that are communicated by means other than the ISO s Automated Dispatch System (ADS). 11 In sharp contrast, the only instructions that are subject to UDP are those that are communicated by ADS. The ISO s EP and UDP are not substitutes, but complements with no overlap. Finally, the ISO s No Pay provisions described in Section 2.5.26 of the ISO Tariff simply eliminate capacity payments for Ancillary Services that are unavailable, such as when a supplier scheduled to provide Operating Reserve fails to perform or is incapable of performing in accordance with its bid. In contrast, UDP applies much more broadly to resources dispatched by the ISO in the Imbalance Energy Market to assure that the ISO receives the aggregate Imbalance Energy response required to reliably and economically operate the ISO Control Area. Other comments provided during the public comment section of the April 25 Board meeting are addressed in the table below: Stakeholder Comment ISO Response The milestones identified as prerequisites for UDP implementation have not been achieved. ISO verbal Dispatch Instructions are not accurately recorded on a consistent basis resulting in erroneous UDP UDP fails to properly include accurate ramp rates. The specific milestones that were established in the January Board memo have been met Stakeholders believe other issues, which require additional system changes, must be resolved before UDP is implemented. These issues are addressed below. ISO endeavors to record all verbal instructions no UDP is applied for verbal instructions, unless those instructions specifically confirm an ADS instruction. Suppliers have the opportunity to specify up to nine ramp rate segments, and to update ramp rates or specify other changes in availability in real time ISO will seek to understand this concern, but is not aware of any conflict with the accuracy of the ramp rates it applies in UDP. 12 11 In its February 20, 2004 order accepting the ISO s proposed Rule of Conduct regarding operating orders on Amendment 55, FERC specifically acknowledged the limitation proposed by the ISO in response to stakeholder comments, stating that this market rule applies to operating orders that are directly communicated to Scheduling Coordinators by means other than the ISO's automated dispatch system." 106 FERC paragraph 61,179, at P 56 12 The ISO will provide an exemption from UDP in the case of outages, as explained in Section 7 of the UDP technical documentation available at http://www.caiso.com/docs/2005/04/22/200504221509011710.pdf 8
Stakeholder Comment Real time Dispatches of RMR units are not accurately reflected in RTMA dispatch Differences in understanding between Scheduling Coordinators and the ISO real-time operations staff regarding the interpretation of SLIC outage information results in faulty UDP calculations RTMA Dispatch Instructions cause significant wear and tear on Generating Units. ISO Response Under some circumstances the ISO issues verbal Dispatch Notices to RMR units that are not reflected in RTMA instructions. Expected Energy is corrected from such verbal instructions, and when such corrections are made, an exemption from UDP is provided. 13 ISO Management established no prerequisite to UDP implementation related to SLIC functionality. 14 The ISO is aware of questions raised when Scheduling Coordinators have made errors in entering information into SLIC about a change in availability. All known bugs or SLIC design issues that would limit the ability of a Scheduling Coordinator to properly report a change in availability have been resolved. However, the ISO will seek to verify that there are no additional outstanding issues, and that sufficient training is provided to Scheduling Coordinators to use SLIC. As noted elsewhere, the ISO will also continue to consider changes in the web client interface to make SLIC more user-friendly. Although no condition on UDP implementation was established in the January Board memo, the ISO continues to examine results of RTMA dispatch and to consider examples and questions provided by suppliers. 15 However, the ISO believes that RTMA is operating consistent with its design, and changes to RTMA are not proposed as a condition on UDP implementation. STAKEHOLDER PROCESS The purpose of the stakeholder process is to first verify that the ISO s proposed scope of review of UDP rules is reasonable, and to then develop an objective foundation on which to base a decision regarding what if any changes to UDP rules are necessary and appropriate. Toward this end, the ISO intends to better coordinate inquiries directed to different ISO system owners and understand implications across all systems as they relate to the ability to perform within the Tolerance Band. The ISO will also seek to confirm that stakeholder concerns are well understood, and will hold a meeting with stakeholders during the week of May 9 to identify issues and examples of problems with UDP, RTMA and SLIC. As noted, the ISO does not presently believe that any change in the design of either RTMA or SLIC is necessary for UDP to be just and reasonable. However, the ISO looks forward to engaging stakeholders on this subject to make sure that ISO decisions are based on a full and complete 13 Id, Section 10.2. 14 See the January 27, 2005 Board memo available at http://www.caiso.com/docs/09003a6080/34/73/09003a608034734c.pdf 15 The January 27, 2005 Board memo on UPD specifically recognized that the four milestones established by the ISO as prerequisites to UDP implementation did not address all stakeholder concerns, including those related to the frequency of changes in direction that ISO Dispatch Instructions required of Generating Units. 9
understanding of stakeholder concerns and any problems that might have their root cause in the design of either of these systems. The following milestones are proposed. Additional meetings and conference calls may be scheduled and other deliverables may be produced as required. Activity Date Stakeholder meeting to provide detailed specification of issues Week of May 9 Briefing to ISO Board on scope of issues and performance of metrics June 15 Provide draft report for stakeholder comment By June 29 One or more stakeholder meetings or conference calls July Board update July 28 One or more stakeholder meetings or conference calls August Final recommendation to Board September 13, 2005 10
Current Period: December 1, 2004 through January 25, 2005 Benchmark Period: December 1, 2003 through January 25, 2004 Metric (1) (2) (3) (4) Uninstructed Deviations CPS2 Violations Regulation Requirement Contribution of Uninstructed Deviations to CPS2 Violations Is Threshold Exceeded? No No No No Benchmark Values Mean 70.37 96% 756.06 8.6% Variance 9085.16 0% NA NA Margin Absolute 100 4% NA NA Relative 50% 90% 5% 50% Threshold Values Mean Threshold 170.37 92% 794 12.9% Variance 13627.75 0% NA NA Current Values Mean 118.96 95% 731.60 8.3% Variance 5401.39 0% NA 0% Increase (Decrease) over Threshold Mean NA NA NA NA Variance NA NA NA NA Does current value significantly exceed threshold? Mean No NA NA NA Variance NA NA NA NA Summary Statistics APPENDIX 1 SUMMARY UDP IMPLEMENTATION METRICS REPORTED APRIL 28, 2005 t-value/f-value for current> threshold Mean (t-value) NA NA NA NA Variance (F-value) NA NA NA NA (5) p-value Mean NA NA NA NA Variance NA NA NA NA Notes: (1) Uninstructed Deviations in aggregate MW per 10-minute interval averaged over the period. (2) CPS2 performance measures as % of Intervals each day in the period - threshold is the higher CPS2 percentagegreater of 4% below the benchmark value or 90%. (3) Regulation requirement in MW per hour (4) % of Intervals with CPS violation where contributing uninstructed deviations exceeded the ISO's L 10. (5) P-Value is the probability that the threshold criteria have not been exeeded. 11