ISO-NE, NEPOOL stakeholders evaluate proposals for eliminating power price offer rule

ISO New England worked with stakeholders and the New England Power Pool July 7 to identify market designs that would support a competitive capacity market without a minimum offer price rule, while maintaining power system reliability and addressing potential power price impacts.

The ISO has said it will work with the New England states and NEPOOL stakeholders to make a Federal Energy Regulatory Commission filing to eliminate the MOPR for Forward Capacity Auction 17 with a filing to be made in the first quarter of 2022, according to an ISO-NE presentation given during a remotely held NEPOOL Markets Committee meeting.

The MOPR relies on administratively set price floors and provides the premise for ISO-NE's competitive auctions for sponsored policy resources rules approved by a split FERC in 2018.

Two key themes have developed during the discussion which has been ongoing for the past few months. Specifically, the rationale for eliminating MOPR and the region's risk-related concerns with MOPR elimination, according to the presentation.

Stakeholders also asked ISO-NE to quantitatively assess the potential impacts that eliminating MOPR could have on capacity auction prices and outcomes, the ISO said.

High-cost resources developed to meet states' policy objectives are not credited for regional resource adequacy contributions, as they may not clear the capacity auctions when the MOPR is applied, which is "inefficient" and "will result in excess regional investment" or "overbuild" over time if the rule is not reformed, the grid operator said.

To address capacity price formation uncertainty in the absence of MOPR, the ISO's current thinking is to use the existing capacity market clearing engine to simulate potential clearing price impacts.

For example, the ISO could use estimated FCA 16 demand data without applying the MOPR to impacted resources, according to the presentation. ISO-NE said it expects to have more details that can be shared with stakeholders in August and aims to provide preliminary results in September.

Benefits of that approach include using real production software and market parameters including real data that "will likely provide the most accurate basis for clearing price simulations" without a need to develop new FCA models, or outsource the analysis to consultants, the ISO said.

However, challenges exist around how to show meaningful data without divulging market sensitive information, the software is intensive to run which may limit the number of scenarios that can be considered and the results would be less informative over the longer term when the power generation resource mix may be very different, according to the presentation.

Stakeholder proposals, concerns

Several stakeholders offered suggestions for how MOPR could be eliminated.

Independent power producer Calpine proposed making specific modifications to the market rule pertaining to Capacity Supply Obligations to better reflect ISO-NE's current generation resource portfolio.

Calpine proposed changing the rule, added to the tariff in 2005, so that the sum of the generating capacity resource's notification time plus start-up time plus minimum run time plus minimum downtime is less than or equal to 24 hours, instead of 72 hours, as it currently stands.

"Regardless of what happens with MOPR, the rules for CSOs should be revised to better reflect the needs of the system," the Calpine presentation said.

"The need for flexible resources is even more pronounced now than in it was in 2005 and thus our view is that 24 hours is better for system reliability than 72 hours," Calpine said.

Other stakeholders including Vistra Energy and trade group New England Power Generators Association focused on the need to protect against buyer- and seller-side market power.

Removing the MOPR, "without any substitute to evaluate non-competitive offers, leaves the FCM at risk of producing unjust rates" because of buyer-side market power from new capacity resources, NEPGA said.

And Vistra said that eliminating MOPR without addressing market power could be subject to legal challenges that "could delay and further frustrate the ability of states to bring resources into the capacity market."

Vistra proposed, as an interim solution, reinstituting the Renewable Technology Resource Exemption in the capacity market that would ensure material accommodation of state-sponsored resources. That approach would give the region time to develop "a durable market design," including the effective load-carrying capability for intermittent resources, a carbon solution, and the required buyer-side mitigation.

Stakeholder meetings will continue through the end of the year with votes on rule change proposals scheduled for December at the Markets Committee and January 2022 at the Participants Committee, ISO-NE said.