FTR Credit Requirements Prevailing Flow Paths Affected by Transmission System Upgrades

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FTR Credit Requirements Prevailing Flow Paths Affected by Transmission System Upgrades Hal Loomis Manager, Credit Markets & Reliability Committee December 7, 2017

Credit Risk Exposure Issue Description FTR credit requirements for prevailing paths are currently based on the weighted historical congestion on those paths for the past three years. Transmission system upgrades may decrease future congestion thus decreasing the value of primarily prevailing flow FTRs in the vicinity of the transmission system upgrade. PJM s FTR bid and cleared credit requirements should incorporate consideration of the projected congestion impact to FTRs of major transmission system upgrades, in order to mitigate the associated default exposure to PJM s members. 2

PJM Proposal PJM is proposing to use results from PJM s PROMOD model simulations of major transmission system upgrades, applied to historical path congestion amounts, to establish FTR bid and cleared credit requirements for paths whose congestion levels are projected to be negatively impacted by modeled transmission system changes effective for any portion of the FTR s term. The Credit Subcommittee has endorsed the proposal with 72% in support and 68% indicating preference for the proposal over the status quo. 117 Members representing all sectors participated in the poll. 3

PJM Proposal - Continued The fundamental credit calculation framework would not change. FTR credit requirements would continue to be based on FTR price, historical path congestion amounts, and any applicable undiversified adder(s) for all FTRs on both prevailing flow and counterflow paths FTRs that are not negatively affected by a modeled transmission system change would continue to utilize actual historical values FTRs that are negatively affected by a modeled transmission system change would utilize an adjusted historical value in the calculation The historical congestion value used for each path would be the actual historic value adjusted for any PROMOD-calculated reduction in congestion value 4

Transmission System Upgrades Criterion for upgrades for which PROMOD congestion simulations would be run: Transmission upgrades, individually or as a cluster, having 10% or more impact on the congestion on any individual constraint or cluster of constraints with congestion of $5MM or more ( low frequency-high impact ) For 2017/2018, only 3 of the 22 transmission system upgrades met this criterion Rebuild existing Graceton-Bagley 230kV single line to double circuit 230kV line Rebuild existing Bagley-Raphael Road 230kV single line to double circuit 230kV line Construct a new Byron-Wayne 345kV circuit 5

Example Paths Affected by Sample Upgrade Affected Paths Actual Historical Congestion (A) PROMOD Congestion Change (B) Adjusted Congestion From Simulation C = (A - B) Adjusted Congestion Used in New Credit Requirement D = lower of A or C Path A $16,548 ($9,930) $6,618 $6,618 Path B ($17,430) $2,209 ($15,521) (1) ($17,430) (1) Path C $89,157 ($16,362) $72,795 $72,795 Path D ($882) ($7,722) ($8,604) ($8,604) (1) Adjusted congestion is only used if it is less than actual historical congestion; otherwise, actual historical congestion is used 6

Examples Modified Credit Requirements FTR Adjusted Congestion Used in New Credit Requirement (D) 17/20 LTFTR Auction Clearing Price (E) Profit (Loss) With Projected Congestion F = (D E) Original Credit Requirement G = E (0.9 x A) New Credit Requirement H = E (0.9 x D) Path A $6,618 $10,751 ($4,133) - (1) $4,795 (2) Path B ($17,430) ($12,347) ($2,875) $6,826 (3) $6,826 (3) Path C $72,795 $61,628 $11,167 - (1) - (1) Path D ($8,604) ($1,596) ($7,008) - (1) $7,868 (2) (1) Individual FTR credit requirements can be negative, but whole month credit requirement cannot be less than zero (2) Adjusted congestion is used because it is less than actual historical congestion; therefore, the credit requirement increases (3) Adjusted congestion is not used because it is not less than actual historical congestion; therefore, the credit requirement does not change 7

Analysis of Sample Transmission Upgrades Maximum Change in Credit Requirement 15/18, 16/19, and 17/20 Long Term FTRs Upgrade A and B 45 40 35 49% 50% * Actual credit requirement increase may be less, depending on monthly distribution of credit requirements 39% 30 Count of Members 25 20 15 19% 19% Upgrade A Upgrade B 10 10% 11% 5 0 1% 2% 0% No Net Increase Less than $100k $100k-$1 Million $1 Million - $5 Million Greater than $5 Million 8

Implementation Description and Timing Proposed implementation time: Spring 2018 Coincident with the annual historical value update Historical values to be updated annually thereafter, and may also be adjusted for newlyidentified significant transmission changes Effective for 2018-2019 annual FTR auction and all subsequent auctions Long-term, annual, balance-of-planning-period (monthly) Applied to existing positions at the time of the annual update of historical prices Special transition plan would mitigate impact to members 9

Transition Plan Members with credit shortfall upon implementation will be restricted in their FTR transaction ability during a transitional cure period Shortfall in FTR credit allocation will not be an event of default during transitional cure period Transitional cure period will be 12 months in duration Members will only be permitted to enter into FTR transactions that reduce credit requirements e.g. sale of an FTR, if sale would reduce credit requirements All other credit-screened transactions prohibited INC, DEC, Up-to congestion, Export, and RPM transactions Collateral returns not allowed until credit shortfall is cured Members may cure their shortfall at any time through provision of sufficient collateral Full transaction rights would be restored upon cure 10

Next Steps Target stakeholder timeline: Credit Subcommittee: Endorsement October 2017 Market Implementation Committee: First read October 11, 2017; Endorsement November 8, 2017 Markets and Reliability Committee: First read October 26, 2017; Endorsement December 7, 2017 Members Committee: Endorsement December 7, 2017 FERC Filing December 2017 11

Appendix Credit Subcommittee Poll Results PROMOD Background and Simulation Reasonableness

Credit Subcommittee Poll Results 117 members from all sectors participated in the Credit Subcommittee poll 72% support the proposal 68% prefer the proposal over the status quo 73% support posting the credit calculator before the auctions The calculator would include the PROMOD-adjusted historical values used in credit calculations 89% support applying the proposed new rules to existing FTRs and utilizing the transition plan for portfolios with a credit shortfall 84% support freezing all credit-screened transactions for members with credit shortfall during the transition period Including all INC, DEC, up-to-congestion, and export transactions 13

PROMOD Inputs/Outputs 14

Overview of Market Efficiency Base Case Inputs PROMOD SCED Simulation Interregional Inputs Reporting Inputs Generation Expansion Plan (ISA/FSA) Intermittent resource hourly shapes Demand Response Forecast Transmission Topology (As-Is, RTEP) MISO and NY Updates: GenExp, load forecast, wind profiles, major upgrades, flowgates, transactions with SPP/MRO, imports Canada RTO Weighted Average Cost of Capital RTO Fixed Carrying Charge Rate Fuel Price Forecast: Natural Gas,Coal, Oil-H, Oil-L Topology Mapping: Bus-Area, BusLoad-Demand, Gen-Bus (As-Is, RTEP) ARR Source Sink Paths and Cleared MW Emissions Price Forecast: CO2 (National, RGGI), SO2, Nox (seasonal,annual) Demand Forecast: Annual Peak Load and Energy, Hourly shapes Reactive Interface PV Analysis Monitored lines and contingencies, interfaces and nomograms, PARs Pool Interaction Modeling: M2M flowgates, pseudo-ties, DC schedules, hurdle rates, import/export limits, inactive pools Project Cost and ISD 15

Market Efficiency Inputs Update Process PROMOD NERC Data Annual Release Assumptions Analysis PJM Load Forecast Update PJM Generation Queue Update RTEP Power Flow Update Bus to Load Zone mapping Flowgate model Reactive limits (PV Analysis) External Model Updates (MISO and others): load, gen, flowgates Market Efficiency Base Case 16

PROMOD Benchmarking 1,800 1,600 1,400 Actual Costs Simulated Results System-wide Congestion Convergence Metrics ($Millions) 1,200 1,000 800 600 400 200 Historical - 90% convergence (on average) Recent 87% convergence 0 2009 Analysis 2010 Analysis 2011 Analysis 2012 Analysis 2017 PROMOD (Jan - Aug) 2017 Actual Total Congestion (Jan - Aug) $ 311 MM $ 356.5 MM 17

2017/2018 RTEP Impacts to FTR Paths Source FTR Path Sink Impacted by RTEP? Historical Value (50/30/20) PROMOD Value FTR Market Price WHUB BGE Y $ 71,394 $ 24,090 $ 24,440 COMED BGE Y $ 116,508 $ 39,157 $ 47,304 DOM BGE Y $ 42,048 $ 17,782 $ 18,133 PPL RECO N $ 14,716 $ 14,016 $ 12,789 PECO PPL N $ 3,066 $ 3,153 $ 2,978 Paths Historical Value to FTR Market Price Ratio PROMOD to FTR Market Price Ratio Impacted by RTEP 257% 93% Not impacted by RTEP 113% 109% 18