NPRR 209 Presentation Adrian Pieniazek – NRG Texas Technical Advisory Committee May 6, 2010

What NPRR209 “Is NOT” An attempt to “overreach” or otherwise unduly limit market transparency. An attempt to make a statement on whether or not current market transparency provisions are “bad policy”. What NPRR209 “Is” An attempt to bring the nodal protocols into compliance with PUCT Substantive Rule

Rule Language PUCT Subst. R. §25.505(f)(3)(B) – (3)The following information in entity-specific form, for each settlement interval, shall be posted as specified below. (B) Two months after the start of operation of the market under a nodal market design: (i) Offer curves (prices and quantities) for each type of ancillary service and for energy at each settlement point in the real time market, shall be posted 60 days after the day for which the information is accumulated except that, for the highest-priced offer selected or dispatched for each interval on an ERCOT-wide basis, ERCOT shall post the offer price and the name of the entity submitting the offer 48 hours after the day for which the information is accumulated. (ii) If the MCPE or the MCPC exceeds the event trigger during any interval, the portion of every market participant’s price-quantity offer pairs for balancing energy service and each other ancillary service that is at or above the event trigger for that service and that interval shall be posted seven (7) days after the day for which the offer is submitted. (iii) Other resource-specific information, as well as self-arranged energy and ancillary capacity services, and actual resource output, for each type of service and for each resource at each settlement point shall be posted 60 days after the day for which the information is accumulated.” (emphasis added)

Intent of NPRR209 Language Changes Changes Section , Items Considered Protected Information, to change protected information status of Base Points from 7 days to 60 days, synching up the language with Section 3.2.5, Publication of Resource and Load Information. Requires that transmission and transformer voltages not be posted for 60 days, subject to a clarification from ERCOT on the actual data being posted. Reinstates the posting of transformer tap positions.

State Estimator Snapshot of November 11, 2008, 00:53 a.m.

Data from the ERCOT “60 Days Later Report” Same Operating Day Report title: 60_QSE_Actual_Res_Output-10-Jan-09 WAP5 = * 4 = MW Sum of WAP6, WAP7, WAP8 = ( ) * 4 =

Closing and Summary Comments Existing protocol language violates PUCT Subst. Rule § NPRR209 brings the protocol language into compliance with the rule. There is an important distinction between “market transparency” and “market participant transparency”. The intent of NPRR209 is to address the latter and comply with the rules. Even opponents of NPRR209 have stated a “subset” of transmission flows may conflict with Subst. Rule § PUCT Staff has stated that “Protocol , as currently drafted, requires the release of information that could be used to determine the actual output of Resources on the system in violation of PUC Subst. R (f)(3)(B).” There are LMP markets all over the country and none of them post state estimator information every hour of every day. These markets seem to be doing just fine. The PUCT and the IMM are responsible for efficient market outcomes and monitoring market participant behavior.