Day-Ahead Market and Forward Reliability Commitment Timing to Meet FERC Order on Compliance for Gas Electric Scheduling Requirements

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1 Day-Ahead Market and Forward Reliability Commitment Timing to Meet FERC Order on Compliance for Gas Electric Scheduling Requirements Market Subcommittee January 5, 2016

2 Purpose Review Background of FERC Order 809 (RM ) Communicate regulatory requirements and MISO response to FERC s December 17, 2015 Order on MISO s Order 809/Section 206 compliance filing (ER , EL ) Key - Takeaways MISO recommended response to FERC Comply with the Commission s requirement to post our Day-Ahead Market (DAM) Results at least 30 minutes prior to the 2:00 p.m. Eastern Prevailing Time (EPT) Timely Nomination deadline Maintain the 6:00 p.m. EPT Forward Reliability Assessment Commitment (FRAC) notification time as previously proposed Explain why our Day-Ahead Schedule start time should depend upon Daylight Saving Time due to the fact that operations and market administration observe Eastern Standard Time throughout the year 2

3 Background - FERC Order 809 On April 16, 2015 FERC Issued Order 809 on Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities. Highlights: No change to the nationwide Gas Day Start, 09:00 at Central Clock Time (CCT) Natural Gas Timely Day-Ahead Nomination Deadline moved from 11:30 to 13:00 CCT Additional Intra-day cycle to improve scheduling flexibility FERC reinforced its directive for ISOs/RTOs to align Electric Market with Gas Market or Show Cause Gas Nomination Cycle changes Effective April 1, 2016 Compliance filings were due on July 23, 2015 MISO was required to comply or show cause why such changes were not necessary 3

4 Background - FERC Order 809 MISO made its Compliance Filing on July 23, 2015 proposing modifications as follows: Day-Ahead Market (DAM) Shifted DAM (and FRAC) to Eastern Prevailing Time (EPT) year round Changed DAM close from 11:00 EST to 11:00 EPT, and moved results publication up one hour to 14:00 EPT - clearing window cut from 4 to 3 hours Maintained Market day (settlement and instructions) at 24 hours in EST (00:00-24:00 EST) Next-Day Forward Reliability Assessment Commitment (FRAC) Maintained One (1) hour Rebid following DAM results at 14:00-15:00 Begins at 15:00 EPT, posts at 18:00 EPT - window also 3 hours, now Filed Show Cause as to why publication of Day-Ahead Market results ahead of the Timely Nomination Cycle was not necessary or beneficial 4

5 DA Market Clearing ( ) MISO Day-Ahead and FRAC Timelines As Filed R e b i d Next- Day FRAC ( ) Electric Day ( ){Nov-Mar*} Electric Day ( ){Apr-Oct} Timely Nomination Deadline (1400) Evening Nomination Deadline (1900) Next Gas Day Intraday 1 (1100) Intraday 2 (1530) Intraday 3 (2000) Current Gas Day ( ) Nomination and Market times are Eastern Prevailing Time *Summer Daylight Savings Time (DST) runs from the second Sunday in March through the first Sunday in November 5

6 FERC December 17, 2015 Order on 206 Requirements In the Order on MISO s filing in Docket ER the Commission found that MISO failed to show cause and required MISO to: Move Day-Ahead Market (DAM) results posting deadline such that it is at least 30 minutes in advance of the revised Timely Nomination Cycle deadline of 2:00 p.m. EPT. (Order at p. 64) Consider proposing a different notification time for Forward Reliability Assessment Commitment (FRAC), as long as any such notification is sufficiently in advance of the Evening Nomination Cycle (Order at p. 2) Make DAM schedule effective at 12:00 a.m. EPT (11:00 p.m. CCT) or explain why differing start times should depend on the use of Daylight Savings Time (Order at p. 66) 6

7 MISO s Recommended Compliance Actions Day Ahead and FRAC Timelines Comply with the Commission s requirement to post our Day-Ahead Market (DAM) Results at least 30 minutes prior Timely Nomination deadline As a result, the DAM clearing window will move up an additional 30 minutes to close 10:30 a.m. to publish results by 1:30 p.m. Eastern Prevailing Time (EPT) Maintain the 6:00 p.m. EPT Forward Reliability Assessment Commitment (FRAC) notification time, as previously proposed FERC found the proposed time satisfied the requirement of Order 809 and the 206 Order FRAC rebid period remains 1 hour and aligns with the new DAM window MISO publishes FRAC results as available, so deadline typically has minimal impact on when Market Participants actually receive notification 7

8 DA Market Clearing ( ) MISO Day-Ahead and FRAC Timelines Recommended Compliance R e b i d Next-Day FRAC ( ) Electric Day ( ){Nov-Mar*} Electric Day ( ){Apr-Oct} Timely Nomination Deadline (1400) Evening Nomination Deadline (1900) Next Gas Day Intraday 1 (1100) Intraday 2 (1530) Intraday 3 (2000) Current Gas Day ( ) Nomination and Market times are Eastern Prevailing Time *Summer Daylight Savings Time (DST) runs from the second Sunday in March through the first Sunday in November

9 MISO s Recommended Compliance Actions Schedule Effective Time Explain why our Day-Ahead Schedule start time should not adjust for Daylight Savings Time (DST) MISO s historical practice of maintaining EST throughout the year dates back prior to 2006 when Indiana did not observe DST Implementing semi-annual transitions to and from DST will result in significant impact and cost to MISO and our Market Participants MISO can t quantify any benefits of transitioning to DST Transitioning to DST has not been identified as a future market or operational enhancement and such an effort would delay higher priority, higher value enhancements identified by MISO and our stakeholders Order 809 did not specifically require modifications to the Gas Day, Electric Day, or alignment thereof 9

10 Next Steps January 19, 2016 MISO will submit compliance filing to FERC January 19, 2016 MISO intends to seek rehearing on the limited issue of modifying the Day Ahead Schedule start time 10

11 Appendices 11

12 Day Ahead Nomination Changes Time Shifts -- All times CCT Timely Evening Current NAESB Standards Revised NAESB Standards* Nomination Deadline 11:30 a.m. 1:00 p.m. Schedule Issued 4:30 p.m. 5:00 p.m. Start of Gas Flow 9:00 a.m. Nomination Deadline 6:00 p.m. 6:00 p.m. Schedule Issued 10:00 p.m. 9:00 p.m. Start of Gas Flow 9:00 a.m. *Effective April 1,

13 Intraday Nomination Changes Time Shifts -- All times CCT Intraday 1 Intraday 2 Intraday 3 Current NAESB Standards Revised NAESB Standards* Nomination Deadline 10:00 a.m. 10:00 a.m. Schedule Issued 2:00 p.m. 1:00 p.m. Start of Gas Flow 5:00 p.m. 2:00 p.m. IT Bump Rights bumpable bumpable Nomination Deadline 5:00 p.m. 2:30 p.m. Schedule Issued 9:00 p.m. 5:30 p.m. Start of Gas Flow 9:00 p.m. 6:00 p.m. IT Bump Rights no bump bumpable Nomination Deadline 7:00 p.m. Confirmations 9:30 p.m. Schedule Issued 10:00 p.m. Start of Gas Flow 10:00 p.m. IT Bump Rights no bump *Effective April 1,

14 Timeline Summary Timeline Description MISO s As-Filed Order 809 Compliance Proposal FERC Compliance Requirement Modifications Day-Ahead Market Clearing (EPT 1 ) Next-Day FRAC Clearing (EPT 1 ) Next Gas Day 2 Nomination Cycle Alignment 11:00 14:00 15:00 18:00 DAM Evening FRAC Evening 10:30 13:30 14:30 18:00 DAM Timely FRAC Evening Current Gas Day 3 Nomination Cycle Alignment DAM ID2 FRAC ID3 DAM ID2 FRAC ID3 Notes 1 All Times Eastern Prevailing Time (EPT) 2 The Next Gas Day - the 24 Hour Period starting at 10:00 EPT the following day 3 The Current Gas Day runs until 10:00 EPT the following day 4 Summer Daylight Savings Time (DST) runs from the second Sunday in March through the first Sunday in November 5 Changes in Red as a result of December 17, 2015 FERC Order Abbreviations FRAC Forward Reliability Assessment Commitment DAM Day-Ahead Market Timely Timely Nomination Deadline 14:00 EPT Evening Evening Nomination Deadline 19:00 EPT ID1 Intraday 1 Nomination Cycle Deadline 11:00 EPT ID2 Intraday 2 Nomination Cycle Deadline 15:30 EPT ID3 Intraday 3 Nomination Cycle Deadline 20:00 EPT 14

15 Revised Market Timing Accepted ISO/RTO Time for Submission of Bids (CCT) Time for Publication of Day-Ahead Commitment Bids (CCT) Time for Publication of FRAC Results(CCT) New York Independent System 4:00 a.m. 10:00 a.m. 10:00 a.m. Operator, Inc. (NYISO) ISO New England Inc. (ISO-NE) 9:00 a.m. 12:30 p.m. 4:00 p.m. PJM Interconnection, LLC (PJM) 9:30 a.m. 12:30 p.m. 6:30 p.m. Midcontinent Independent 9:30 a.m. 12:30 p.m. 6:00 p.m. System Operator, Inc. (MISO)* Electric Reliability Council of 10:30 a.m. 1:30 p.m. 5:00 p.m. Texas (ERCOT) Southwest Power Pool, Inc. (SPP 9:30 a.m. 2:00 p.m. 6:15 p.m. California Independent System Operator Corporation (CAISO) 12:00 p.m. 3:00 p.m. 3:00 p.m. *Per compliance requirements 15

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