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Econometric Analysis of RSG at
      the Midwest ISO

      Presentation to MISO RSG TF
               Carmel, IN
              July 8, 2009
Brief Description of Problem
   FERC has determined that RSG should be
    distributed on a cost causality basis. However, this
    has not proven to be an easy task over the last four
    years.
   Various analyses have indicated potential causes of
    RSG, but not provided a marginal contribution for
    each. Further, previous analyses have failed to
    include multiple sources in a single, statistically
    valid model.
   This analysis presents the results of a statistical
    analysis including all of hypothesized causes of RSG
    where data was available in a single framework.
    From this work we are able to quantify the marginal
    contribution of these factors to hourly RSG MWP.

July 8, 2009
                        Greening
Summary of Results
   A statistically significant model can be
    developed between RSG MWP and many
    of the factors believed to be contributing
    to this charge.
   This framework can be used to:
       Focus efforts on tariff re-design
       Construct a tariff that is cost-causality based,
        provides ex ante pricing, and is equitable,
        flexible, and transparent.
       Serve as the basis of a RSG metric
        development process.

July 8, 2009
                          Greening
Summary of Results
                               (Continued)
   These results indicate that levels of RSG
    contributed by various factors vary substantially.
       Load contributes approximately 23% of RSG MWP over the whole
        period.
       Generators contribute approximately 39% to RSG MWP over the whole
        period.
       Changes in NSI contribute approximately 30% to RSG MWP over the
        entire period.
       Virtual supply contributes approximately 1.3%.
       Factors outside MPs control contribute the remainder.
   Further, these results raise any number of
    questions concerning the cost causality basis,
    equity, and effectiveness of the RSG Re-design
    and similar allocation schemes or proposed
    solutions.

July 8, 2009
                                Greening
Data Sources
   All data were extracted from publicly available
    reports on the MISO website.
   Several variables that might explain RSG MWP
    were not available. Inclusion of these variables
    would refine the results.
       Only the number of binding constraints were
        available, and not the MWs dispatched to address
        a constraint.
       Intra-hour changes in RT load, Econmax, and
        NSI.
       Headroom, and therefore a proxy was defined.
July 8, 2009
                         Greening
Variable Definitions
   RSG MWP: RT RSG Make Whole Payments per MW
    of Econmax eligible for payment.
   Obligated load covered during FRAC: Difference
    between load committed for in FRAC and DA-
    cleared load in GW. (An increase is positive.)
   Change in Econmax during RT: Difference between
    RT Econmax and FRAC committed Econmax in GW.
    (Negative means more capacity available; positive
    indicates more capacity required).
   Change in Load during RT: Difference between RT
    Load and FRAC Load in GW. (Negative indicates less
    capacity required in RT; increase indicates more
    capacity required).
July 8, 2009
                        Greening
Variable Definitions
                        (Continued)

   Change in Offer during RT: Difference in RT
    Econmax due to changes in offer parameters and
    FRAC in GW. (Negative means less capacity required
    in RT; positive means more capacity required).
   Binding constraints: Number of binding constraints in
    RT.
   Headroom proxy: Load covered in FRAC less FRAC
    committed Econmax less NSI in FRAC in GW
    (Negative indicates less potential requirement for
    headroom during RT; positive indicates potential
    requirement for headroom during RT).

July 8, 2009
                         Greening
Variable Definitions
                             (Continued)
   Virtual supply offers: Financial offers for supply
    cleared in DA- market in GW.
   Load forecast error: Difference between MTLF and
    SE (RT load) in GW. (Overforecast is negative, i.e.,
    less capacity needed; positive indicates
    underforecast).
   Change in NSI: Three measures used in GW
       Change in PJM interchange (market to market) between FRAC
        and 12:00 a.m. (beginning of RT).
       Change in other Tier 1 interchanges between FRAC and 12:00
        a.m. (beginning of RT market).
       Change in NSI after 12:00 a.m. in RT.


July 8, 2009
                              Greening
Methods of Analysis
   Period of analysis: 6/1/2006 through 5/31/2009.
   Hourly data used to estimate a quadratic cost function.
       Choice of specification is based on the potentially high number of
        negative values for independent variables.
       Cross-product terms account correctly for occurrence of multiple RSG-
        associated events during an hour.
   Binary variables were included to control for peak versus
    off-peak hours, summer versus winter, years, the FERC
    order of November 10, 2008, and ASM.
   Since fuel costs are exogenous to the MISO, and the fuel
    mix for units receiving RSG MWP was not available, RSG
    MWP was deflated with the BLS PPI for electricity
    generators. This deflator coupled with binary variables
    for year and season should account for this factor.

July 8, 2009
                                  Greening
Methods of Analysis
                         (Continued)

   Model estimated using a Tobit (dependent
    variable left censored at zero and
    assuming a gaussian distribution)
    implemented with maximum likelihood.
       Test statistics indicate that the overall model is
        extremely significant.
       Over 80 percent of the coefficients have
        significance levels of 90% or greater.
   Robust standard errors were obtained with
    a White’s estimator.
July 8, 2009
                          Greening
Marginal Contribution to RSG
   Impacts on RSG MWP were estimated by evaluating the
    first partial derivative with respect to each continuous
    variable. This provides the change in RSG MWP with
    respect to a change in the specified continuous variable,
    i.e., the marginal contribution to RSG MWP.
   Three cases were evaluated at variable means.
       The whole period
       The period before ASM started
       The period after ASM
   In addition to the expected value, upper and lower
    bounds were defined using the 90% jointly determined
    confidence intervals of the model coefficients and the
    90% confidence interval of the explanatory variables.
    These ranges are not symmetric due to the non-linearity
    of the underlying processes.


July 8, 2009
                                        Greening
Contribution to RSG MWP (2006$/MW):
                                                       Whole period
             Change in NSI after 12:00 a.m. in
                           RT
                                                                                                 $0.66
                   Change in other interchange                        -$0.06
                                                                                                           Hourly average
                  between FRAC and 12:00 a.m.
                                                                                                           RSG MWP:
                   Change in PJM interchange                                                               $1.9366
                                                                                     -$0.04
                  between FRAC and 12:00 a.m.

                     Load forecast error (MISO)        -$0.01


                           Virtual supply offers
                                                   $0.02

                                Headroom proxy
                                                              $0.13

                            Binding constraints
                                                           $0.11

                      Change in Offer during RT
                                                                                 $0.41

                     Change in Load during RT
                                                                       $0.28

                  Change in Econmax during RT
                                                                                     $0.46
                  Obligated load covered during
                              FRAC                                   $0.25

-$0.80   -$0.60        -$0.40     -$0.20      $0.00          $0.20           $0.40       $0.60           $0.80     $1.00    $1.20   $1.40
                                                           Real dollars (US 2006)



  July 8, 2009
                                                           Greening
Comments on Whole Period Case
    Not all factors contribute equally to hourly
     RSG MWP.
    Virtual supply offers appear to contribute on
     average only 1.3% which is much lower than
     previous estimates from incomplete models.
    Positive and negative deviations in RT NSI
     accounts for 30%.
    Generators account for 39% while load
     accounts for 23%.
    Factors outside MPs’ control account for the
     remainder.
    July 8, 2009
                       Greening
Comparison of Variable Means
   In comparing the results of the cases of before
    ASM and after ASM with the whole period case,
    a comparison of the means of variables is
    helpful.
   Notable points include:
       RSG MWP increased by 5% after ASM.
       Virtual supplies decreased by approximately 50%.
       The load forecast reversed from an overforecast to a
        substantial underforecast.
   Many of these changes could be attributable to
    weather.
July 8, 2009
                           Greening
5

                                                                                                                                       4

                                                                                                                           3

                                                                                                                   2

                                                                                                               1

                                                                                                           0

                                                                                                      -1

                                                                                                 -2

                                                                                     -3

                                                               -4

                                                    -5
                                        RSG MWP




   July 8, 2009
                      Obligated load covered during
                                 FRAC


                         Change in Load during RT


                         Change in Offer during RT


                    Change in Econmax during RT


                                Headroom proxy



                             Binding constraints



                            Virtual supply offers




Greening
                      Load forecast error (MISO)


                    Change in PJM interchange
                   between FRAC and 12:00 a.m.

                   Change in other interchange
                  between FRAC and 12:00 a.m.

                  Change in NSI after 12:00 a.m.
                            in RT
                                                                                                                                                     Means Comparison for Cases

                                                                                                                       After ASM: 3504
                                                                                                                       Before ASM: 22793
                                                                                                                       Whole period: 26297




                                                                                     After ASM
                                                                                                                       Numbers of observations




                                                                        Before ASM
                                                         Whole period
Contribution to RSG MWP (2006$/MW):
                                          Before and after ASM
        Binding constraints (after)                                                               Hourly average RSG
                               -$0.06                                                             MWP (before): $1.9222
                                                                                                  Hourly average RSG
      Binding constraints (before)                                                                MWP (after): $2.0301
                                           $0.14


 Change in Offer during RT (after)
                                                                $0.39


Change in Offer during RT (before)
                                                                      $0.42


 Change in Load during RT (after)
                                                                                  $0.57

Change in Load during RT (before)
                                                   $0.23

    Change in Econmax during RT
               (after)
                                                                    $0.40

    Change in Econmax during RT
              (before)
                                                                         $0.47

    Obligated load covered during
            FRAC (after)                                    $0.31

    Obligated load covered during
            FRAC (before)                           $0.24

               -$0.20             $0.00    $0.20              $0.40              $0.60    $0.80         $1.00             $1.20
                                                               Real dollars (US 2006)



 July 8, 2009
                                                      Greening
Contribution to RSG MWP (2006$/MW):
                                                Before and after ASM
                                                    (Continued)
                       Change in NSI after 12:00 a.m. in RT (after)
                                                                                                            $0.53

                     Change in NSI after 12:00 a.m. in RT (before)

                                                                                                                $0.68
 Change in other interchange between FRAC and 12:00 a.m. (after)
                                                                                       $0.15
Change in other interchange between FRAC and 12:00 a.m. (before)
                                                                           -$0.09

  Change in PJM interchange between FRAC and 12:00 a.m. (after)
                                                                       -$0.15

Change in PJM interchange between FRAC and 12:00 a.m. (before)
                                                                             -$0.02

                                        Load forecast error (after)
                                                                          -$0.10

                                      Load forecast error (before)
                                                                                   $0.01

                                       Virtual supply offers (after)
                                                                           -$0.09
                                     Virtual supply offers (before)
                                                                                    $0.05

                                           Headroom proxy (after)
                                                                                            $0.22

                                         Headroom proxy (before)
                                                                                           $0.12

          -$1.00                    -$0.50                        $0.00                             $0.50               $1.00   $1.50
                                                                       Real dollars (US 2006)



 July 8, 2009
                                                                Greening
Comments on ASM Cases
   After ASM (and the November FERC order), our
    analysis indicates a number of changes.
       Virtual supply offers declined roughly by half and the marginal
        contribution to RSG MWP dropped to -$0.10.
       The contribution by changes in Load during RT doubled.
       Comparison of other variables indicates a shift of RSG
        contribution from generators to load.
   Caveat: After ASM, this analysis only includes 3504
    hours in comparison to 22793 hours before. As a
    result, care should be taken in interpreting the
    results. A longer time span after ASM is really
    needed prior to making definitive statements
    concerning the impacts of the new tariff.


July 8, 2009
                                Greening
Conclusions
   This work demonstrates that the marginal contribution
    of various assumed causal factors to the incurrence of
    RSG in the MISO can be estimated.
   Direct contributions between assumed causes of RSG
    can be quantified. This is superior evidence to the use
    of correlation coefficients.
   Not all factors contribute equally to RSG MWP.
        Load contributes approximately 23% of RSG MWP over the
         whole period.
        Generators contribute approximately 39% to RSG MWP over
         the whole period.
        Changes in NSI contribute approximately 30% to RSG MWP
         over the entire period.
        Virtual supply contributes approximately 1.3%.
        Factors outside MPs control contribute the remainder.


July 8, 2009
                             Greening
Conclusions
                      (Continued)
   This approach provides for the identification of
    distortionary tariffs and regulatory responses.
   Use of this type of method in tariff design
    incorporates cost causality, ex ante pricing,
    flexibility, equity, and transparency.
   The approach could also provide a means of
    developing metrics that gauge the effects of
    changes in market behaviors.
   Caveat: Inclusion of more factors, and better
    definition of others at the nodal level would
    provide more conclusive results.

July 8, 2009
                       Greening
“And just because the rooster crows. . .”

       Questions on this analysis should be
                   directed to:

               Lorna Greening
     (505-695-9224 or LGDoone@aol.com)


July 8, 2009
                     Greening

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Rsg Results 070809

  • 1. Econometric Analysis of RSG at the Midwest ISO Presentation to MISO RSG TF Carmel, IN July 8, 2009
  • 2. Brief Description of Problem  FERC has determined that RSG should be distributed on a cost causality basis. However, this has not proven to be an easy task over the last four years.  Various analyses have indicated potential causes of RSG, but not provided a marginal contribution for each. Further, previous analyses have failed to include multiple sources in a single, statistically valid model.  This analysis presents the results of a statistical analysis including all of hypothesized causes of RSG where data was available in a single framework. From this work we are able to quantify the marginal contribution of these factors to hourly RSG MWP. July 8, 2009 Greening
  • 3. Summary of Results  A statistically significant model can be developed between RSG MWP and many of the factors believed to be contributing to this charge.  This framework can be used to:  Focus efforts on tariff re-design  Construct a tariff that is cost-causality based, provides ex ante pricing, and is equitable, flexible, and transparent.  Serve as the basis of a RSG metric development process. July 8, 2009 Greening
  • 4. Summary of Results (Continued)  These results indicate that levels of RSG contributed by various factors vary substantially.  Load contributes approximately 23% of RSG MWP over the whole period.  Generators contribute approximately 39% to RSG MWP over the whole period.  Changes in NSI contribute approximately 30% to RSG MWP over the entire period.  Virtual supply contributes approximately 1.3%.  Factors outside MPs control contribute the remainder.  Further, these results raise any number of questions concerning the cost causality basis, equity, and effectiveness of the RSG Re-design and similar allocation schemes or proposed solutions. July 8, 2009 Greening
  • 5. Data Sources  All data were extracted from publicly available reports on the MISO website.  Several variables that might explain RSG MWP were not available. Inclusion of these variables would refine the results.  Only the number of binding constraints were available, and not the MWs dispatched to address a constraint.  Intra-hour changes in RT load, Econmax, and NSI.  Headroom, and therefore a proxy was defined. July 8, 2009 Greening
  • 6. Variable Definitions  RSG MWP: RT RSG Make Whole Payments per MW of Econmax eligible for payment.  Obligated load covered during FRAC: Difference between load committed for in FRAC and DA- cleared load in GW. (An increase is positive.)  Change in Econmax during RT: Difference between RT Econmax and FRAC committed Econmax in GW. (Negative means more capacity available; positive indicates more capacity required).  Change in Load during RT: Difference between RT Load and FRAC Load in GW. (Negative indicates less capacity required in RT; increase indicates more capacity required). July 8, 2009 Greening
  • 7. Variable Definitions (Continued)  Change in Offer during RT: Difference in RT Econmax due to changes in offer parameters and FRAC in GW. (Negative means less capacity required in RT; positive means more capacity required).  Binding constraints: Number of binding constraints in RT.  Headroom proxy: Load covered in FRAC less FRAC committed Econmax less NSI in FRAC in GW (Negative indicates less potential requirement for headroom during RT; positive indicates potential requirement for headroom during RT). July 8, 2009 Greening
  • 8. Variable Definitions (Continued)  Virtual supply offers: Financial offers for supply cleared in DA- market in GW.  Load forecast error: Difference between MTLF and SE (RT load) in GW. (Overforecast is negative, i.e., less capacity needed; positive indicates underforecast).  Change in NSI: Three measures used in GW  Change in PJM interchange (market to market) between FRAC and 12:00 a.m. (beginning of RT).  Change in other Tier 1 interchanges between FRAC and 12:00 a.m. (beginning of RT market).  Change in NSI after 12:00 a.m. in RT. July 8, 2009 Greening
  • 9. Methods of Analysis  Period of analysis: 6/1/2006 through 5/31/2009.  Hourly data used to estimate a quadratic cost function.  Choice of specification is based on the potentially high number of negative values for independent variables.  Cross-product terms account correctly for occurrence of multiple RSG- associated events during an hour.  Binary variables were included to control for peak versus off-peak hours, summer versus winter, years, the FERC order of November 10, 2008, and ASM.  Since fuel costs are exogenous to the MISO, and the fuel mix for units receiving RSG MWP was not available, RSG MWP was deflated with the BLS PPI for electricity generators. This deflator coupled with binary variables for year and season should account for this factor. July 8, 2009 Greening
  • 10. Methods of Analysis (Continued)  Model estimated using a Tobit (dependent variable left censored at zero and assuming a gaussian distribution) implemented with maximum likelihood.  Test statistics indicate that the overall model is extremely significant.  Over 80 percent of the coefficients have significance levels of 90% or greater.  Robust standard errors were obtained with a White’s estimator. July 8, 2009 Greening
  • 11. Marginal Contribution to RSG  Impacts on RSG MWP were estimated by evaluating the first partial derivative with respect to each continuous variable. This provides the change in RSG MWP with respect to a change in the specified continuous variable, i.e., the marginal contribution to RSG MWP.  Three cases were evaluated at variable means.  The whole period  The period before ASM started  The period after ASM  In addition to the expected value, upper and lower bounds were defined using the 90% jointly determined confidence intervals of the model coefficients and the 90% confidence interval of the explanatory variables. These ranges are not symmetric due to the non-linearity of the underlying processes. July 8, 2009 Greening
  • 12. Contribution to RSG MWP (2006$/MW): Whole period Change in NSI after 12:00 a.m. in RT $0.66 Change in other interchange -$0.06 Hourly average between FRAC and 12:00 a.m. RSG MWP: Change in PJM interchange $1.9366 -$0.04 between FRAC and 12:00 a.m. Load forecast error (MISO) -$0.01 Virtual supply offers $0.02 Headroom proxy $0.13 Binding constraints $0.11 Change in Offer during RT $0.41 Change in Load during RT $0.28 Change in Econmax during RT $0.46 Obligated load covered during FRAC $0.25 -$0.80 -$0.60 -$0.40 -$0.20 $0.00 $0.20 $0.40 $0.60 $0.80 $1.00 $1.20 $1.40 Real dollars (US 2006) July 8, 2009 Greening
  • 13. Comments on Whole Period Case  Not all factors contribute equally to hourly RSG MWP.  Virtual supply offers appear to contribute on average only 1.3% which is much lower than previous estimates from incomplete models.  Positive and negative deviations in RT NSI accounts for 30%.  Generators account for 39% while load accounts for 23%.  Factors outside MPs’ control account for the remainder. July 8, 2009 Greening
  • 14. Comparison of Variable Means  In comparing the results of the cases of before ASM and after ASM with the whole period case, a comparison of the means of variables is helpful.  Notable points include:  RSG MWP increased by 5% after ASM.  Virtual supplies decreased by approximately 50%.  The load forecast reversed from an overforecast to a substantial underforecast.  Many of these changes could be attributable to weather. July 8, 2009 Greening
  • 15. 5 4 3 2 1 0 -1 -2 -3 -4 -5 RSG MWP July 8, 2009 Obligated load covered during FRAC Change in Load during RT Change in Offer during RT Change in Econmax during RT Headroom proxy Binding constraints Virtual supply offers Greening Load forecast error (MISO) Change in PJM interchange between FRAC and 12:00 a.m. Change in other interchange between FRAC and 12:00 a.m. Change in NSI after 12:00 a.m. in RT Means Comparison for Cases After ASM: 3504 Before ASM: 22793 Whole period: 26297 After ASM Numbers of observations Before ASM Whole period
  • 16. Contribution to RSG MWP (2006$/MW): Before and after ASM Binding constraints (after) Hourly average RSG -$0.06 MWP (before): $1.9222 Hourly average RSG Binding constraints (before) MWP (after): $2.0301 $0.14 Change in Offer during RT (after) $0.39 Change in Offer during RT (before) $0.42 Change in Load during RT (after) $0.57 Change in Load during RT (before) $0.23 Change in Econmax during RT (after) $0.40 Change in Econmax during RT (before) $0.47 Obligated load covered during FRAC (after) $0.31 Obligated load covered during FRAC (before) $0.24 -$0.20 $0.00 $0.20 $0.40 $0.60 $0.80 $1.00 $1.20 Real dollars (US 2006) July 8, 2009 Greening
  • 17. Contribution to RSG MWP (2006$/MW): Before and after ASM (Continued) Change in NSI after 12:00 a.m. in RT (after) $0.53 Change in NSI after 12:00 a.m. in RT (before) $0.68 Change in other interchange between FRAC and 12:00 a.m. (after) $0.15 Change in other interchange between FRAC and 12:00 a.m. (before) -$0.09 Change in PJM interchange between FRAC and 12:00 a.m. (after) -$0.15 Change in PJM interchange between FRAC and 12:00 a.m. (before) -$0.02 Load forecast error (after) -$0.10 Load forecast error (before) $0.01 Virtual supply offers (after) -$0.09 Virtual supply offers (before) $0.05 Headroom proxy (after) $0.22 Headroom proxy (before) $0.12 -$1.00 -$0.50 $0.00 $0.50 $1.00 $1.50 Real dollars (US 2006) July 8, 2009 Greening
  • 18. Comments on ASM Cases  After ASM (and the November FERC order), our analysis indicates a number of changes.  Virtual supply offers declined roughly by half and the marginal contribution to RSG MWP dropped to -$0.10.  The contribution by changes in Load during RT doubled.  Comparison of other variables indicates a shift of RSG contribution from generators to load.  Caveat: After ASM, this analysis only includes 3504 hours in comparison to 22793 hours before. As a result, care should be taken in interpreting the results. A longer time span after ASM is really needed prior to making definitive statements concerning the impacts of the new tariff. July 8, 2009 Greening
  • 19. Conclusions  This work demonstrates that the marginal contribution of various assumed causal factors to the incurrence of RSG in the MISO can be estimated.  Direct contributions between assumed causes of RSG can be quantified. This is superior evidence to the use of correlation coefficients.  Not all factors contribute equally to RSG MWP.  Load contributes approximately 23% of RSG MWP over the whole period.  Generators contribute approximately 39% to RSG MWP over the whole period.  Changes in NSI contribute approximately 30% to RSG MWP over the entire period.  Virtual supply contributes approximately 1.3%.  Factors outside MPs control contribute the remainder. July 8, 2009 Greening
  • 20. Conclusions (Continued)  This approach provides for the identification of distortionary tariffs and regulatory responses.  Use of this type of method in tariff design incorporates cost causality, ex ante pricing, flexibility, equity, and transparency.  The approach could also provide a means of developing metrics that gauge the effects of changes in market behaviors.  Caveat: Inclusion of more factors, and better definition of others at the nodal level would provide more conclusive results. July 8, 2009 Greening
  • 21. “And just because the rooster crows. . .” Questions on this analysis should be directed to: Lorna Greening (505-695-9224 or LGDoone@aol.com) July 8, 2009 Greening