Generator Expectations During a Gas Curtailment or Operational Flow Order (OFO) User s Guide
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1 Generatr Expectatins During a Gas Curtailment r Operatinal Flw Order (OFO) User s Guide Intrductin: On days when gas system reliability culd be at risk, the Lcal Distributin Cmpany (LDC), interstate r intrastate gas pipeline may invke an Operatinal Flw Order (OFO) r issue ther instructins restricting use f gas imbalance service. Unlimited use f balancing gas by generatrs culd, in sme circumstances, endanger gas system reliability. This dcument is applicable t all generatrs that are available but fr ptential fuel limitatins. When the Generatr s LDC r pipeline has issued an OFO, r instructins restricting imbalance usage, the Generatr may be subject t charges fr incurring gas imbalances that exceed certain limited tlerances specified in the OFO r instructin. NYISO will nt rdinarily permit inclusin in generatr reference levels charges fr vilating Operatinal Flw Orders r fr vilating LDC/pipeline instructins restricting gas usage. Hwever, if and t the extent that a Market Party has btained specific authrizatin frm the relevant natural gas LDC r pipeline t use gas that wuld therwise be unauthrized, the ISO shall nt cnsider such usage t be unauthrized use. Market Parties shall make every effrt t clearly dcument authrizatin they btain frm an LDC r pipeline. Dcumentatin btained after the fact will be cnsidered. This dcument describes the NYISO s expectatins fr entities that Bid int the NYISO administered markets during times when an Operatinal Flw Order (OFO) r ther instructins restricting imbalance usage are in effect. Installed Capacity Prviders have an bligatin t Bid, schedule, r ntify fr all hurs in the Day- Ahead Market ( DAM ) in accrdance with Market Administratin and Cntrl Area Services Tariff ( Services Tariff ) Sectin In additin t the Services Tariff requirements fr Installed Capacity Prviders, it is expected that any available generatr that is acting in a cmpetitive manner wuld be bidding int bth the Day- Ahead Market and the Real-Time Market. This guide is written in general terms that may nt apply t a Generatr s unique circumstances. Nthing in this dcument circumvents NYISO s Ecnmic withhlding rules. General Statements: Fr the purpse f this dcument, the term prtfli refers t gas balancing prtflis. The failure f a gas-nly Generatr t ffer additinal incremental (in excess f its scheduled MWs) energy r ancillary services in real-time during an OFO due t the inability t btain gas, wuld be deemed cnduct cnsistent with cmpetitive behavir fr purpses f physical withhlding evaluatins cnducted pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23). If an interruptin f gas service ccurs befre Day-Ahead Market Bid windw clses, gas-nly generatrs are nt expected t Bid int the Day-Ahead Market t the extent they are unable t btain fuel. Such generatrs wuld be expected t ntify utage scheduling f a frced utage (See GADS Reprting Sectin). Draft fr Discussin Purpses Only Page 1
2 If an interruptin f gas service ccurs after a gas-nly generatr receives a Day-Ahead schedule, the generatr is expected t derate fr lack f fuel (See GADS Reprting Sectin), and is expected t ntify the NYISO f its unavailability due t lack f fuel thrugh its TO. 1. Daily Operatinal Flw Order (OFO) During a daily OFO, the fllwing rules apply: 1.1 Gas Only Generatrs Single Generatr Day-Ahead Market Expectatins Since ne electric day spans prtins f tw gas days, Generatrs Bids shuld cnsider the OFO fr the apprpriate 24-hur gas day. A Generatr is expected t reflect any csts (risks) assciated with perating during an OFO perid in its Bids Real-Time Market Expectatins A gas-nly Generatr is nt expected t ffer additinal, incremental Energy r Ancillary Services in real-time during an OFO if it cannt prcure additinal gas r wuld have t use unauthrized gas services t satisfy its Energy r Ancillary Services ffer. A Generatr is expected t ffer int the Real-Time Market during the available gas nminatin perids even if the Generatr was nt awarded a Day-Ahead Market schedule. A Generatr is expected t ffer int the Real-Time Market during the available gas nminatin perids if the Generatr was awarded a Day-Ahead Ancillary Services schedule fr hurs utside the available gas nminatin perid. If a Generatr chses nt t ffer in the Real-Time Market during the perid it was awarded a Day-Ahead Ancillary Services schedule, the Generatr must be derated t 0 MW fr that time perid. (See the GADS Reprting sectin in this Users Guide fr details n reprting derates in GADS). The failure f a gas-nly Generatr t ffer additinal incremental Energy r Ancillary Services (in excess f its Day-Ahead scheduled MWs) in real-time, during an OFO, due t the inability t btain gas wuld nt be cnsidered physical withhlding pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23). Draft fr Discussin Purpses Only Page 2
3 1.2 Dual Fuel Generatrs Single Generatr Day-Ahead Market Expectatins A dual-fuel Generatr that has been assigned a default reference fuel type f gas, but is unable t btain gas due t an OFO, might nnetheless be able t run n il fr the day. In such circumstances, the Generatr is expected t include a fuel type adjustment (frm gas t il) in its Market Infrmatin System (MIS) bid frm Real-Time Market Expectatins Generatrs that wuld therwise be available, but fr the inability t btain gas due t an OFO, are expected t Bid fr all hurs f the Real-Time Market. A dual-fuel Generatr that has been assigned a default reference fuel type f gas, but is unable t btain gas due t an OFO, might nnetheless be able t run n il fr the day. In such circumstances, it is expected the generatr will include a fuel type adjustment (frm gas t il) in its Market Infrmatin System (MIS) bid frm. If a generatr has sufficient il, but fails t ffer int the RT Market n il, the generatr will be reviewed fr pssible physical withhlding pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23) and the generatr is expected t reprt this apprpriately in GADS (See the GADS Reprting sectin fr details n hw t reprt this derate in GADS). 1.3 Prtfli (cmbinatin f gas nly & dual fuel generatrs) Day-Ahead Market Expectatins A Generatr is expected t reflect any csts (risks) assciated with perating during an OFO perid in its Day-Ahead Market Bids. Alternatively, t the extent a dual-fuel Generatr reasnably expects it will be unable t btain gas it culd Bid n its alternate fuel during an OFO perid Real-Time Market Expectatins Generatrs that wuld therwise be available, but fr the inability t btain gas due t an OFO, are expected t Bid MWs in the Real-Time Market that were nt scheduled in the Day- Ahead Market. Generatrs that have sufficient il are expected t Bid int the Real-Time Market. If, due t an OFO, a Generatr cannt secure sufficient gas t meet the Generatr s Day- Ahead schedule, and n alternative fuel is available, the NYISO expects the Generatr t take a frced utage (See GADS Reprting Sectin). If a Generatr with sufficient il chses nt t Bid int the Real-Time Market, the Generatr must derate t 0 mw (See the GADS Reprting sectin fr details n hw t Draft fr Discussin Purpses Only Page 3
4 Example #1: reprt this derate in GADS). Generatrs are expected t Bid additinal available capacity in the Real-Time Market utside the available gas nminatin perids when the prtfli can perate within the balancing service allwed during the OFO. 1.4 Prtfli (Gas-nly generatrs) Day-Ahead Market Expectatins A Generatr is expected t reflect any csts (risks) assciated with perating during an OFO perid in its Day-Ahead Market Bids. If, due t an OFO, a gas-nly Generatr des nt expect t be able t secure sufficient gas t supprt bidding int the Day-Ahead Market, the NYISO expects the Generatr t take a frced utage (See GADS Reprting Sectin) and is expected t ntify utage scheduling Real-Time Market Expectatins Generatrs that are able t nminate gas are expected t bid in the Real-Time Market during the available gas nminatin perids. Generatrs are expected t Bid additinal available capacity in the Real-Time Market utside the available gas nminatin perids when the prtfli can perate within the balancing service allwed during the OFO. If, due t an OFO, a gas-nly Generatr cannt secure sufficient gas t meet the Generatr s Day-Ahead schedule, the NYISO expects the Generatr t take a frced utage (See GADS Reprting Sectin) and is expected t ntify the NYISO f its unavailability due t lack f fuel thrugh its TO. The NYISO wuld expect a gas-nly prtfli t stack the generatrs by heat rate (cst). If a prtfli knws that they culd have five f their generatrs receive Real-Time Market schedules, and they culd stay within the 2% prtfli restrictin, then they shuld ffer thse five generatrs in the RT Market. It wuld be cnsidered cnsistent with cmpetitive behavir t nt Bid the remaining generatrs in the prtfli int the RT Market. Example #2: When bidding int the RT Market, a gas-nly prtfli must take int cnsideratin that the current bidding hur impacts the secnd bidding hur. If a gas-nly prtfli assumes full cmmitment fr the secnd bidding hur, and wuld still have bandwidth fr the 2% prtfli restrictin with full cmmitment, then the prtfli shuld cntinue t Bid fr the fllwing hur. If the prtfli assumes full cmmitment fr the secnd bidding hur and wuld have n bandwidth fr the 2% prtfli restrictin, then they wuld nt be cnsidered physical withhlding pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23) if they didn t Bid all f their generatrs fr the fllwing hur. Draft fr Discussin Purpses Only Page 4
5 Example #3: If the prtfli is n track t under burn fr the day in cmparisn t their gas nminatin ( lng n gas ), the expectatin wuld be that the generatr asset wner wuld ffer int the Real-Time Market MWs nt scheduled in the Day-Ahead Market. Hwever, if prducing an additinal MW puts the prtfli int a situatin which vilates the OFO, then the NYISO wuld nt find the generatrs t be physically withhlding if they didn t ffer int the Real-Time Market. If prducing an additinal MW des nt put the prtfli int a situatin which vilates the OFO, then the NYISO wuld expect the prtfli t ffer. If the prtfli is nt ffered in this situatin, then the generatrs nt ffered wuld be evaluated fr Physical Withhlding cnduct and impact. Example #4: Pst Cycle Transactins. If a generatr can typically btain pst-cycle gas, then the NYISO wuld expect that generatr t ffer int the RT Market based n the prbability f getting pst-cycle gas. 2 Hurly (Ratable) Operatinal Flw Order (OFO) 2.1 Gas Only Generatrs Single Generatr Day-Ahead Market Expectatins During an hurly r 1/24th OFO, a gas LDC r pipeline may require its Generatr custmers t maintain similar levels f gas usage acrss an entire gas day. Fr gas-fired GTs that might nly receive DAM schedules fr an hur r tw f the gas day, the DAM schedule might, in sme cases, frce a Generatr t buy mre gas than it actually needs, and then sell the extra gas it purchased at a lss. The NYISO will wrk with generatrs that face such a risk t include temprary adders in Day-Ahead Market start-up reference levels t allw Generatrs t reflect expected sell-back lsses. If, due t an OFO, a Generatr cannt secure sufficient gas t supprt its Bid int the Day- Ahead Market, and n alternative fuel is available, the NYISO expects the Generatr t take a frced utage (See GADS Reprting Sectin). Generatrs that are Installed Capacity Suppliers are expected t Bid in accrdance with Services Tariff Sectin fr all hurs f the Day-Ahead Market. If the OFO is called prir t the Day-Ahead Market Bid windw clsing, the NYISO expects that the Generatr wuld include the csts assciated with perating during a ratable OFO in its Day-Ahead Market Bid Real-Time Market Expectatins A gas-nly Generatr is nt expected t ffer additinal, incremental energy r ancillary services abve their DAM award in real-time during an OFO if it cannt prcure additinal Draft fr Discussin Purpses Only Page 5
6 gas r wuld have t use unauthrized gas services in rder t perate t effectuate its energy r ancillary service ffer. If a generatr Bids int the RT Market and that Bid results in vilating the OFO, the penalty charges will nt be included in reference levels r in the calculatin f the generatr s cmpensatin. Generatrs are expected t cmply with the prvisins f OATT Sectin 34 (als referred t as OATT Attachment BB). If the generatr is determined t be a Lcal Critical Generatr r a Bulk Critical Generatr and said Critical Generatr has crdinated Feasible Natural Gas delivery with the LDC as utlined in OATT Attachment BB, it is expected that the generatr will bid fr all applicable hurs in the RT Market. As utlined in Services Tariff Sectin , if and t the extent a Market Party has btained specific authrizatin frm the relevant natural gas LDC r pipeline t use gas that wuld therwise be unauthrized, such use shall nt be cnsidered unauthrized use by the ISO and the Market Party wuld be expected t bid fr all hurs in the RT Market. Market Parties shall make every effrt t clearly dcument authrizatin they btain frm the LDC r pipeline. Dcumentatin btained after the fact will be cnsidered. If a generatr has n accepted DAM schedule, and has nt prcured gas fr the RT Market, the generatr has tw ptins: The generatr can bid int the RT Market. The bid shuld include the csts t prcure sufficient gas t satisfy the restrictins f the OFO. If a generatr cannt prcure sufficient gas, then the generatr wuld nt be expected t bid int the RT Market. The NYISO wuld expect the Generatr t enter a Reserve Shutdwn cnditin (See GADS Reprting Sectin). There wuld be n evaluatin fr physical withhlding pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23) in this circumstance. If a generatr has a DAM Ancillary schedule, but has nt prcured gas fr any hurs ther than that ancillary schedule, the generatr has tw ptins: The generatr can bid int the RT Market fr all hurs, including thse utside the Ancillary schedule. The bid shuld include the csts t prcure additinal gas t satisfy the restrictins f the OFO. If a generatr cannt prcure additinal gas, then the generatr wuld nt be expected t bid int the RT Market utside the hurs f the Ancillary schedule. The NYISO wuld expect the generatr t enter a Reserve Shutdwn cnditin fr the hurs utside the Ancillary schedule (See GADS Reprting Sectin). Draft fr Discussin Purpses Only Page 6
7 If a generatr has a DAM Ancillary Schedule but cannt prcure gas t satisfy this schedule in the RT Market, then the NYISO wuld expect the generatr t take a frced utage (See GADS Reprting Sectin). The failure f a gas-nly Generatr t ffer additinal incremental (in excess f its scheduled MWs) energy r ancillary services in real-time during an OFO due t the inability t btain gas, wuld be deemed cnduct cnsistent with cmpetitive behavir fr purpses f physical withhlding evaluatins cnducted pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23). During an hurly r 1/24th OFO, a gas LDC r pipeline may require its Generatr custmers t maintain similar levels f gas usage acrss an entire gas day. Fr gas-fired GTs that might nly receive DAM schedules fr an hur r tw f the gas day, the DAM schedule might, in sme cases, frce a Generatr t buy mre gas than it actually needs, and then sell the extra gas it purchased at a lss. The NYISO will wrk with generatrs that face such a risk t include temprary adders in DAM start-up reference levels t allw Generatrs t reflect expected sell-back lsses. 2.2 Oil Generatrs Single Generatr Day-Ahead Market Expectatins During an hurly (ratable) OFO, an il-fired generatr that has nt already been scheduled t prvide nn-synchrnus reserves, r t start, and that must start n natural gas might need t find intraday startup gas. This may invlve the generatr btaining authrizatin frm the LDC allwing use f the startup gas. If the ability t btain authrizatin is unknwn at the time the generatr is bidding int the DA Market, then the NYISO wuld expect the generatr t include in their bid the risk (cst) f nt being granted the authrizatin Real-Time Market Expectatins If the LDC refuses t authrize the use f start-up gas, then an il-fired generatr that must start n natural gas is nt expected t bid in the Real-Time Market while the OFO is in effect. (See GADS Reprting Sectin). 2.3 Dual Fuel Generatrs Single Generatr Day-Ahead Market Expectatins Generatrs that are Installed Capacity Suppliers are expected t Bid in accrdance with Services Tariff Sectin fr all hurs f the Day-Ahead Market. A dual-fuel Generatr that has been assigned a default reference fuel type f gas, but is unable t btain gas due t an OFO, might nnetheless be able t run n il fr the day. In such circumstances, it is expected the generatr will include a fuel type adjustment (frm gas t il) in its Market Infrmatin System (MIS) bid frm. Draft fr Discussin Purpses Only Page 7
8 2.3.2 Real-Time Market Expectatins Generatrs that wuld therwise be available, but fr the inability t btain gas due t an OFO, are expected t Bid fr all hurs in the Real-Time Market. A dual-fuel Generatr that has been assigned a default reference fuel type f gas, but is unable t btain gas due t an OFO, might nnetheless be able t run n il fr the day. By including a fuel type adjustment (frm gas t il) in its Market Infrmatin System (MIS) bid frm, the Generatr may avid unnecessary mitigatin. 3 Interruptin f Gas Service 3.1 Gas Only Generatrs Day-Ahead Market Expectatins If interruptin f gas service ccurs r a ntice f interruptin has been issued by the pipeline r LDC befre Day-Ahead Market Bid windw clses, generatr are nt expected t Bid int the Day-Ahead Market. Such generatrs wuld be expected t ntify utage scheduling f a frced utage. (See GADS Reprting Sectin). If interruptin f gas service ccurs r a ntice f interruptin has been issued by the pipeline r LDC after a generatr receives a Day-Ahead schedule, the generatr is expected t derate fr lack f fuel (See GADS Reprting Sectin). The generatr is expected t ntify the NYISO f its unavailability due t lack f fuel thrugh it s TO. If a generatr did nt bid int the DA Market r RT Market, they wuld nt be evaluated fr physical withhlding pursuant t the NYISO s Market Pwer Mitigatin Measures (Services Tariff Sectin 23) during an interruptin f service. Generatr must reprt status apprpriately in GADS (See GADS Reprting Sectin). Installed Capacity Suppliers lcated East f Central-East shall Bid in the Day-Ahead all Capacity available fr supplying 10-Minute Nn-Synchrnized Reserve (unless the Generatr is unable t meet its cmmitment because f an utage as defined in the ISO Prcedures). (See Sectin 5 Exceptin) Real-Time Market Expectatins If a generatr bid int the Day-Ahead Market, and didn t get scheduled, generatr wuldn t be expected t bid int the Real-Time Market. If nt bid int the Real-Time Market, the generatr wuld reprt this as a Reserve Shutdwn in GADS (See GADS Reprting Sectin). Generatr wuld be expected t ntify their TO f their unavailability t run due t lack f available fuel. Draft fr Discussin Purpses Only Page 8
9 3.2 Dual Fuel Generatrs If an LDC system r pipeline is experiencing lw pressure, and requests that generatrs behind that LDC r n that pipeline stp burning gas, the generatr is expected t cntact its Transmissin Owner (TO) t determine if the TO needs the generatr t switch t its alternate fuel fr reliability. If the TO determines that the generatr is required fr reliability, the TO will place the generatr OOM (which will allw the generatr t autmatically recver any additinal csts incurred with switching t its alternate fuel) and the generatr wuld be expected t switch t its alternate fuel. If the TO des nt require the generatr t switch t its alternate fuel fr reliability, the generatr will then decide t either switch t its alternate fuel and run withut any mechanism t recver additinal csts assciated with switching t its alternate fuel; r it will chse t shut dwn, derate t 0 MW and reprt the utage apprpriately in GADS (See GADS Reprting Sectin). 4 Generating Availability Data System (GADS) Reprting Generatrs are expected t reprt frced utages r reserve shut dwn cnditins in the Generatr Availability Data System (GADS). This sectin utlines what shuld be reprted as a frced utage and what shuld be reprted as a reserve shutdwn. Examples f Frced Outages: Reprting Frced Outages When the Generatr s LDC r pipeline has issued an OFO, instructins restricting imbalance usage, r there is an interruptin f gas service, and gas is nt available t the generatr, the generatr is required t enter a Frced Outage/Derate (U1, U2, U3 / D1, D2, D3) with the Cause Cde 9130 r 9131 in their GADS data (except as nted belw). Generatr nt available t bid int the Day-Ahead Market due t lack f fuel. Generatrs scheduled fr Incremental Energy in the Day-Ahead Market, but cannt get fuel in the Real-Time Market t meet the Day-Ahead schedule. Generatrs nt scheduled in the Day-Ahead Market, but SRE d r placed OOM and cannt perate in the Real-Time Market because f the OFO. Generatrs nt scheduled in the Day-Ahead Market, but scheduled in the RT Market fr Incremental Energy and cannt run in the Real-Time market because f the OFO. Generatrs nt scheduled in the Day-Ahead Market but scheduled fr reserves in the Real-Time Market and asked t cnvert t Incremental Energy and cannt perate because f the OFO. Draft fr Discussin Purpses Only Page 9
10 4.1.2 Reprting Reserve Shutdwns A reserve shutdwn is a situatin where a gas-nly generatr is nt scheduled t run in the Day-Ahead Market and cannt run in the Real-Time Market due t an inability t btain gas. Examples f Reserve Shutdwns: Generatrs that bid int the DA Market, but was nt scheduled, and cannt perate in the RT Market due t the OFO. Additinal Incremental Energy r Ancillary Services MWs (in excess f its Day-Ahead scheduled MWs) nt ffered in real time due t lack f fuel. 5 Exceptin Real-Time Obligatins f Installed Capacity Suppliers lcated East f Central-East Installed Capacity Suppliers lcated East f Central-East are required (See Services Tariff Sectin ) t bid in the Day-Ahead and Real-Time Markets all Capacity available fr supplying 10-Minute Nn-Synchrnized Reserve (unless the Generatr is unable t meet its cmmitment because f an utage). Except fr generatrs that have demnstrated t the ISO that they are subject t envirnmental, cntractual r ther legal r physical requirements that wuld therwise preclude them frm prviding 10-Minute Nn-Synchrnized Reserve. 6 GADS Reprting fr Installed Capacity Suppliers lcated East f Central-East which prvide 10-Minute Nn-Synchrnized Reserves Reprting Frced Outages When the Generatr s LDC r pipeline has issued an OFO, instructins restricting imbalance usage, r there is an interruptin f gas service, and gas is nt available t the generatr, the peratr/wner is required t enter a Frced Outage/Derate (U1, U2, U3 / D1, D2, D3) with the Cause Cde 9130 r 9131 in their GADS data. Examples f Frced Outages fr these generatrs: Generatrs scheduled fr Incremental Energy in the DA Market, but cannt get fuel in the RT Market. Generatrs scheduled in the DA Market fr reserves and asked t cnvert t Incremental Energy in the RT Market but cannt get fuel. Generatrs nt scheduled in the DA Market, but SRE d r placed OOM and cannt perate in the RT Market because f the OFO. Draft fr Discussin Purpses Only Page 10
11 6.1.2 Reprting Reserve Shutdwns Examples f Reserve Shutdwns fr these generatrs: Generatrs scheduled in the DA Market fr reserves and NOT asked t cnvert t Incremental Energy but OFO called in the RT Market. Generatrs scheduled in the DA Market fr Incremental Energy r Reserves and then nt scheduled in the RT Market but OFO is called. Generatrs nt scheduled in the DA Market and didn t bid int the RT Market because the OFO was called. Generatrs nt scheduled in the DA Market but scheduled fr Reserves in the RT Market and NOT asked t cnvert t Incremental Energy but can t run because f an OFO. 7 Reference Level Sftware (RLS) Reprting The NYISO expects all generatrs t cmmunicate with the Mitigatin References (MR) team any expected additinal csts incurred as a result f perating during an OFO cnditin r instructins restricting imbalance usage. Generatrs are expected t cmply with the prvisins f the NYISO Reference Level Manual; specifically sectin Bidding, fuel prcurement and reference updates in the presence f gas balancing csts r Operatinal Flw Orders. 8 Outage Scheduling Generatrs are expected t cmply with the prvisins f the NYISO Outage Scheduling Manual. Please refer t the NYISO Outage Scheduling Manual when ntifying the NYISO f planned and unexpected changes t the peratinal availability f their transmissin and generating facilities. These ntificatins are given in the frm f requests t the NYISO fr cnsideratin and apprval as Outage Schedules. Draft fr Discussin Purpses Only Page 11
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