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Marjket Operations Standing Committee
IMO Day Ahead Market Design Update
Market Operations Standing CommitteeSeptember 22, 2003Market Evolution Program
Long-Term Resource Adequacy UpdateJason Chee-Aloy
Market Operations Standing Committee of the IMO September 22, 2003 Slide 2
Long-Term Resource Adequacy Update
Agenda
Long-Term Resource Adequacy Chronology
Identified Paths and Long-Term Resource Adequacy Working Group Update
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 3
Long-Term Resource Adequacy (LTRA) - Chronology Summer 2002 - Market Participants identified resource adequacy as a high priority issue
in response to the IMO Straw-Plan for Market Evolution Fall 2002 - IMO 2003-2005 Business Plan states resource adequacy as a principle
objective in the evolution of Ontario’s electricity market February 2003 - work commences on the LTRA project March 2003 - first meeting of the LTRA Working Group (LTRAWG)
• Over 25 members (w/ diverse membership)
• LTRAWG meets every 2 weeks June 2003 - Feasibility Assessment published
• Identifies Paths/Options to address LTRA
• Contains several recommendations but does not champion a single Path/Option June 2003 - Market Advisory Council supported Feasibility Assesssment
recommendations July 2003 to Present - LTRAWG continuing discussion on specific recommendations to
address LTRA
Market Operations Standing Committee of the IMO September 22, 2003 Slide 4
Long-Term Resource Adequacy Update
Agenda
Long-Term Resource Adequacy Chronology
Identified Paths and Long-Term Resource Adequacy Working Group Update
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 5
Potential Paths to Address Long-Term Resource Adequacy
Path A: Complete the initial market design and structures without an explicit Resource Adequacy Requirement (RAR) Rely on results of improved energy and ancillary service markets alone (e.g. Pricing Team
work, day-ahead market, multi-interval optimization, etc.)
Path B: Create Load Serving Entities (LSE) and assign a RAR to these entities LSEs required to contract forward capacity requirements through bilateral contracts (different to
bilateral contracts for energy) IMO could administer a resource adequacy auction market (similar to NYISO and PJM) as a
complementary element to LSE capacity contracts
Path C: Allow a central agency to procure adequate resources and allocate the resource acquisition costs to loads IMO administers a resource adequacy auction market and secures forward capacity on behalf
of loads (NYISO, PJM and ISO NE are developing)
Market Operations Standing Committee of the IMO September 22, 2003 Slide 6
Long-Term Resource Adequacy Working Group Update
Key points from the current discussion:
• LTRA encompasses all interrelated aspects of the Ontario electricity market• Recommendations will contain necessary elements that will help Ontario
move toward a complete, workable and sustainable approach to addressing LTRA, under a competitive market framework
• Elements of the identified Paths (from the Feasibility Assessment) are likely not mutually exclusive
LTRAWG is now focussing on:• The high level detail how an explicit resource adequacy requirement may be
workable• Interim/transitional mechanisms that may be required
Market Operations Standing Committee of the IMO September 22, 2003 Slide 7
Long-Term Resource Adequacy Update
Agenda
Long-Term Resource Adequacy Chronology
Long-Term Resource Adequacy Working Group Update
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 8
Next Steps
LTRAWG continues to meet every 2 weeks
Update to IMO Board on LTRAWG on October 3, 2003
Update to Market Advisory Council on October 8, 2003
Market Operations Standing Committee of the IMO September 22, 2003 Slide 9
IMO Day Ahead Market Design Update
Market Operations Standing CommitteeSeptember 22, 2003Market Evolution Program
Day Ahead Market UpdateLeonard Kula
Market Operations Standing Committee of the IMO September 22, 2003 Slide 10
Day Ahead Market Design Update
Agenda
DAM Chronology
DAM Design and Features
DAM Pricing Options
DAM Benefits
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 11
Day Ahead Market (DAM) - Chronology Fall 2002 - IMO 2003-2005 Business Plan identifies that a DAM is a critical element
in creating a more effective, reliable and mature market January 2003 - work commences on the DAM project February 2003 - call for DAM Working Group (DAMWG) members
• ~ 28 members from all industry sectors (generators, loads, transmitter, distributors, marketers, OEB and OEFC)
• meet every ~10 days - 23 meetings to-date April 2003 - DAMWG recommends further development of a comprehensive DAM
• closely aligned with day ahead markets in neighbouring jurisdictions May 2003 - DAM hi-level design summary prepared June 2003 - broad stakeholder consensus obtained regarding design direction and
plan to continue to develop DAM (Market Advisory Council) July - Aug 2003 - DAMWG discusses hi-level design concepts and reviews hi-level
design strawman
Market Operations Standing Committee of the IMO September 22, 2003 Slide 12
Day Ahead Market Design Update
Agenda
DAM Chronology
DAM Design and Features
DAM Pricing Options
DAM Benefits
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 13
Day Ahead Market - Initial Options
R e a l T im eM a rke t o n ly
C u rre n t
No DAM
C le a r o ffe rs /b ids(ig n ore con g e stio n)
F in a nc ia l co m m itm e nt
O p tio n 1
Sim ple DAM(e.g. Energy Forw ard
M arket)
financial com mitm ent+ unit com m itm ent
(considers congestion)
real-tim e marketbecomes a
balancing market
sa m e se tt le m e nttre a tm en t as
cu rre n tre a l-t im e m a rke t
g e n era to rs re ce ive ...u n ifo rm p rice +
s id e p a ym e n ts fo rco n g e s tion (C M S C)
lo a ds pa y...u n ifo rm p rice +
u p lift fo rco n g e s tion (C M S C)
O p tio n 2u n ifo rm p rice m o d e l
g e n era to rs rece ive(a n d so m e loa d s p a y)
...n od a l p rice
(m o st) lo ad s pa y...u n ifo rm p rice
(w e ig h te d a vera geo f n od a l p rice s)
O ptio n 3An o d a l p rice m o d e l
g e n era to rs re ce ive ...n o d a l p rice
lo a ds pa y...n o d a l p rice
O ptio n 3Bn o d a l p rice m o d e l
Com prehensive DAM
Day Ahead Market (DAM) Evolution
Market Operations Standing Committee of the IMO September 22, 2003 Slide 14
Day Ahead Market - Initial Options
R e a l T im eM a rke t o n ly
C u rre n t
No DAM
C le a r o ffe rs /b ids(ig n ore con g e stio n)
F in a nc ia l co m m itm e nt
O p tio n 1
Sim ple DAM(e.g. Energy Forw ard
M arket)
financial com mitm ent+ unit com m itm ent
(considers congestion)
real-tim e marketbecomes a
balancing market
sa m e se tt le m e nttre a tm en t as
cu rre n tre a l-t im e m a rke t
g e n era to rs re ce ive ...u n ifo rm p rice +
s id e p a ym e n ts fo rco n g e s tion (C M S C)
lo a ds pa y...u n ifo rm p rice +
u p lift fo rco n g e s tion (C M S C)
O p tio n 2u n ifo rm p rice m o d e l
g e n era to rs rece ive(a n d so m e loa d s p a y)
...n od a l p rice
(m o st) lo ad s pa y...u n ifo rm p rice
(w e ig h te d a vera geo f n od a l p rice s)
O ptio n 3An o d a l p rice m o d e l
g e n era to rs re ce ive ...n o d a l p rice
lo a ds pa y...n o d a l p rice
O ptio n 3Bn o d a l p rice m o d e l
Com prehensive DAM
Day Ahead Market (DAM) Evolution
Market Operations Standing Committee of the IMO September 22, 2003 Slide 15
Day Ahead Market - Initial Options
R e a l T im eM a rke t o n ly
C u rre n t
No DAM
C le a r o ffe rs /b ids(ig n ore con g e stio n)
F in a nc ia l co m m itm e nt
O p tio n 1
Sim ple DAM(e.g. Energy Forw ard
M arket)
financial com mitm ent+ unit com m itm ent
(considers congestion)
real-tim e marketbecomes a
balancing market
sam e settlem enttreatment as
currentreal-tim e market
generators receive...uniform price +
side payments forcongestion (CM SC)
loads pay...uniform price +
uplift forcongestion (CM SC)
Option 2uniform price m odel
g e n era to rs rece ive(a n d so m e loa d s p a y)
...n od a l p rice
(m o st) lo ad s pa y...u n ifo rm p rice
(w e ig h te d a vera geo f n od a l p rice s)
O ptio n 3An o d a l p rice m o d e l
g e n era to rs re ce ive ...n o d a l p rice
lo a ds pa y...n o d a l p rice
O ptio n 3Bn o d a l p rice m o d e l
Com prehensive DAM
Day Ahead Market (DAM) Evolution
Market Operations Standing Committee of the IMO September 22, 2003 Slide 16
What Is Meant By A Comprehensive Day-ahead Market?The DAM WG recommended further development of a Comprehensive DAM (April 2003).
Key features include: A financial market administered by the IMO, which accepts supply offers
and demand bids and clears the market at day-ahead prices.• Creates a 2-settlement system, with the RTM a “balancing” market.
Integrates a 3-part bid process to optimize unit commitment for:• Supplies available to the DAM to meet loads buying in the DAM• Supplies available to the RTM to meet RTM forecast load
A multi-pass process for committing units, arranging DAM schedules, and defining DAM prices, plus indicative schedules for the RTM.
The use of uplifts to cover commitment costs not recovered from market revenues.
The simultaneous optimization of energy and operating reserves, and the optimization of the market over the 24 hour period.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 17
DAM - Design And Features
The Proposed DAM would: Be based on...
• supply offers to sell and demand bids to purchase energy • supply offers to sell operating reserves
Be open to all MPs
Include imports and exports
Allow virtual offers and bids
Include an IMO-optimized unit commitment process
Use multiple commitment and/or dispatch passes to optimize results
Market Operations Standing Committee of the IMO September 22, 2003 Slide 18
A DAM Functions Before The RTM In A Two-Settlement System
Day Ahead MarketMPs offer to sell and bid to buy energy in real time.
Offers/bids used to define RT schedules and prices
IMO uses offers/bids to arrange constrained dispatch
2nd Settlement =
Quantity Deviations from DA purchases and sales times RT prices
PRT(QRT - QDA)
MPs offer to sell and bid to buy energy day ahead.
Offers/bids used to define DA schedules and prices
DA schedules are financial obligations to buy/sell energy at DA prices
1st Settlement =
DA purchases and sales times DA prices
(QDA x PDA)+
Real Time Market
Market Operations Standing Committee of the IMO September 22, 2003 Slide 19
Virtual Supply Offers And Load Bids Add Liquidity To DAM And Converge DAM And RTM Prices
Day Ahead Market
Participation unavoidable
Commitment to buy Q in RTM
Commitment to sell Q in RTM
Converge to expected RTM prices
Participation voluntary
• MPs submit virtual offers to sell Q in DAM =
• MPs submit virtual bids to buy Q in DAM =
• With virtual offers/bids, DAM prices tend to =>
Real Time Market
Market Operations Standing Committee of the IMO September 22, 2003 Slide 20
The Day Ahead Market Includes A Unit Commitment Process For DAM and RTM
Day Ahead Market
IMO-committed units from DA unit commitment are available for dispatch to meet RT loads
IMO arranges security-constrained economic dispatch from supply offers and demand bids
MPs submit 3-part price offers:
(1) Incremental energy
(2) Start-up costs
(3) Minimum generation costs
IMO optimizes commitment and commits units for:
(1) DAM bid-in load
(2) Forecast RT load
Bid Production Cost Guarantee (BPCG) - Generators made whole if DAM revenues don’t cover full bid-in costs
Real Time Market
Market Operations Standing Committee of the IMO September 22, 2003 Slide 21
DAM Uses Multiple Passes To Commit Units And Define Dispatch Schedules And Prices
Pass 2
Commit units to meet RT forecast
load
Pass 3
Optimize dispatch/define
schedules to meet DAM bid-in load
Pass 4
Dispatch to indicate schedules/prices for
RT forecast load
Pass 1
Commit units to meet DAM bid-in
load
(Optional)
Market Operations Standing Committee of the IMO September 22, 2003 Slide 22
Proposed DAM Uses Multiple Passes To Define Commitments For DAM And RTM
Pass 2
Pass 1 and Pass 2 optimize unit commitment using 3-part offers/bids
IMO optimizes and commits more units to meet forecast RT load
Constrained pass
Physical Suppliers Physical Loads Exports/Imports
No Virtuals
Pass 1
IMO optimizes commitment and commits units to meet bid-in DA load
Constrained pass
Physical Suppliers Physical Loads Exports/Imports
Virtual offers/bids
Results
Market Operations Standing Committee of the IMO September 22, 2003 Slide 23
Committed Units Are Used To Define Schedules And Prices For DAM (and RTM)
Given the units committed in Passes 1 & 2, Passes 3 & 4 define schedules and prices
Pass 4
IMO optimizes dispatch for forecast RT load
Defines indicative schedules & prices for RTM
Constrained pass
Pass 3
IMO optimizes dispatch over 24 hours for bid-in load
Defines DAM schedules and nodal prices
Constrained Pass
Market Operations Standing Committee of the IMO September 22, 2003 Slide 24
Committed Units May Not Recover Bid Costs From Market. Uplifts Are Needed
Pass 2
Principle: Those on whose behalf the commitment costs were incurred pay the associated uplift
Committed units entitled to bid-cost payment guarantee
Uplift for these units paid by net RT loads (those who chose not to participate in DAM)
Uplift based against DAM revenues
Pass 1
Committed units entitled to bid-cost payment guarantee
Uplift paid primarily by all physical RT loads
Uplift based against DAM revenues
Market Operations Standing Committee of the IMO September 22, 2003 Slide 25
Efficient Results Need Consistent Schedules and Price Formation Between DAM And RTM
Day Ahead MarketSchedules
From constrained dispatch.
Based on all units with closed breakers or able to close breakers within 5-minutes
Prices
From constrained dispatch.
Based on all units with closed breakers or able to close breakers within 5-minutes
Schedules
From Pass 3 = constrained, Includes all committed units
Prices
From Pass 3 = constrained
Limited to committed units and quick start units
Real Time Market
OK
OK
Market Operations Standing Committee of the IMO September 22, 2003 Slide 26
Moving Import & Export Trades To The DAM Should Reduce IOG Payments And Uplifts
Day Ahead Market
RTMs are 5-minutes
Imports offer to sell into RTM
Exports bid to buy from RTM
Imports/exports are cleared in the pre-dispatch, but settled at RTM prices
IMO must pay intertie trades at their offers if RTM prices are not enough to cover offer prices for pre-dispatch schedules
DAM is hourly
Imports offer to sell into DAM
Exports bid to buy from DAM
Imports/Exports are cleared in the DAM and settled at the DAM prices
No intertie offer guarantee payments are needed for DAM import/exports
Real Time Market
Market Operations Standing Committee of the IMO September 22, 2003 Slide 27
Imports And ExportsThe procedures proposed for the IMO to schedule imports and exports in the DAM are generally similar to the procedures that it uses to schedule internal generation and loads in the RTM.
Imports In The Reliability Commitment When it is necessary to commit additional generating capacity to ensure that the IMO will be able to meet its load forecast: Only the commitment costs of slow-starting generation will be
considered when determining whether it should be committed. In cases when the offer for an import is less than the commitment
costs of internal generation, selecting the imports can reduce the cost of committing additional units to cover forecast load.
The IMO will charge net real-time load for the cost of committing these imports.
Committing these imports can reduce the amount that real-time load needs to pay in these circumstances.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 28
Transmission Rights Settlements
Once the DAM is implemented, TRs will need to be settled in the DAM.
Transmission rights could be options or obligations (still to be discussed in detail).
DAM schedules are obligations.
Settling TRs in the DAM will maintain revenue adequacy for the IMO.
The FTRs and the DAM schedules otherwise would constitute competing sets of claims on RTM congestion rents.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 29
Day Ahead Market Design Update
Agenda
DAM Chronology
DAM Design and Features
DAM Pricing Options
DAM Benefits
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 30
A Day Ahead Market Based Upon Uniform Pricing?
The Comprehensive Day Ahead Market was expected to comprise a constrained schedule of resources and a uniform price methodology to determine prices for the DAM and RTM to converge, require consistent methods in
DAM and RTM to determine schedules and prices the current real-time market determines schedules on a
constrained basis the current real-time market determines price using a uniform
pricing methodology
The DAM WG examined the implications of employing a uniform pricing methodology in the DAM.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 31
“Uniform” Pricing Is Misnamed. It Has Locational Differences, But The Wrong OnesA so-called “uniform” pricing system must pay different prices to generators at different locations whenever there is congestion.
During congestion, the value of energy necessarily varies at different locations, because transmission constraints prevent some cheaper generation from getting to some loads. • Lower-cost generators at some locations must be “constrained off” to
relieve constraints, while at other locations . . .• Higher-cost generators must be “constrained on” to meet load.
The IMO cannot manage congestion in a market without paying different prices to generators at different locations relative to the congestion. • Otherwise, generators would not follow dispatch instructions.
During congestion, uniform prices must therefore be augmented by side payments that vary by location, depending on the extent and location of the congestion and the prices that generators offer.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 32
“Locational” Prices Under Uniform Pricing Are Not Efficient and Not “Market” PricesAlthough generators at different locations are paid different prices under uniform pricing whenever there is congestion, the resulting prices are not true market-clearing prices and are not efficient.
Generators paid “constrained-off” payments are usually paid more than their energy is worth (they are paid not to run or produce less).
• And they have an incentive to adjust their offers to maximize the side payments they receive for not running or producing less.
Generators paid “constrained-on” side payments are often not paid as much as their energy is worth. They’re paid “as bid.”
• So they have an incentive to adjust their offers to maximize the side payments to try to capture the market value, but they have to guess and will often be wrong, yielding inefficiency – there is no transparent market price.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 33
A Uniform Pricing System Is Problematic
The current uniform pricing system is the root source of several problems. It creates price incentives that may:
Encourage supply and demand-side investments at the wrong locations.
Discourage supply and demand-side investments at the right locations.
Every US ISO that has tried uniform pricing had to develop extensive non-market mechanisms to counteract the undesired incentives from uniform pricing. Eventually, each such US ISO concluded that it must replace uniform pricing with nodal locational marginal pricing for generators.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 34
Uniform Pricing “Simplicity” Is A MythA uniform pricing system is always more complex than the alternative of settling generators at their respective nodal prices. Requires a complex set of side payments that are non-transparent -- This
complexity will be magnified with a DAM, as shown in the July 28 presentation to the DAM WG. (Only 8 of 64+ cases were shown.)
Experience in other markets has shown that some generators can be encouraged to manipulate their offer prices to maximize the side payments. • This problem will substantially increase with a DAM if based on uniform
pricing. (See, California ISO web site re Enron practices)• Extensive administrative rules will be needed to monitor, limit and
counteract this behaviour
Conclusion of DAM working group (August 19, 2003): A Day Ahead Market under a uniform pricing regime would be costly to
implement and maintain, complex and confusing, and is not recommended
Market Operations Standing Committee of the IMO September 22, 2003 Slide 35
Day Ahead Market - Pricing Options
R e a l T im eM a rke t o n ly
C u rre n t
N o D A M
C le a r o ffe rs /b ids(ig n ore con g e stio n)
F in a nc ia l co m m itm e nt
O p tio n 1
S im p le D A M(e .g . E n e rg y F orw a rd
M a rke t)
financial com mitm ent+ unit com m itm ent
(considers congestion)
real-tim e marketbecomes a
balancing market
sa m e se tt le m e nttre a tm en t as
cu rre n tre a l-t im e m a rke t
g e n era to rs re ce ive ...u n ifo rm p rice +
s id e p a ym e n ts fo rco n g e s tion (C M S C)
lo a ds pa y...u n ifo rm p rice +
u p lift fo rco n g e s tion (C M S C)
O p tio n 2u n ifo rm p rice m o d e l
generators receive(and som e loads pay)
...nodal price
(m ost) loads pay...uniform price
(w eighted averageof nodal prices)
Option 3Anodal price m odel
generators receive...nodal price
loads pay...nodal price
Option 3Bnodal price m odel
Com prehensive DAM
Day Ahead Market (DAM) Evolution
Market Operations Standing Committee of the IMO September 22, 2003 Slide 36
Nodal Pricing Is Simpler, More Efficient
For Generators: Unlike uniform prices, the nodal prices make intuitive sense to generators – they are consistent with the generators’ offers.• If not dispatched, the nodal prices were below the offer• If partially dispatched, the nodal prices are consistent with the offer• If fully dispatched, the nodal prices will be at least as high as and possible
higher than the offer.
For Dispatchable Loads: Nodal pricing provides correct incentives for price-responsive demand • Sends correct price signals about the value of demand-side responses at
different locations
For the IMO: Unlike uniform prices (even with side payments), nodal prices are consistent with the actual dispatch.• So the price signals are consistent with what the IMO needs the
generators to do to maintain reliable operations.• So complex rules for side payments aren’t needed for reliability.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 37
Nodal Pricing For Generators Can Coexist With ‘Uniform Pricing’ Applied To Loads
The nodal pricing framework used in US ISOs continues to settle most loads at “zonal” prices, which are averages of nodal prices for each utility’s service area.
This construct could be used in Ontario if it wishes to continue charging all consumers the same price for energy, as today. In this scenario, ‘uniform prices’ could be the weighted average price of all load nodes.
It should be understood that any averaging scheme introduces some inefficiency and inherently involves cost shifts. For reliability purposes, this is not a serious problem, except for those customers/loads that could participate in price-responsive demand opportunities.
Market Operations Standing Committee of the IMO September 22, 2003 Slide 38
Day Ahead Market - Nodal Price Model
Need to assess the impact of a nodal pricing solution before making recommendations: Market Participants
• While the DAM WG agrees that Uniform Pricing in a DAM is not workable, more analysis of nodal pricing is needed:
– pricing impact - historical and going-forward
– broad Market Participant education and stakeholdering
Impact upon DAM design• DAM based upon nodal pricing is simpler• System of transmission rights for internal congestion required
Impact upon RTM design• RTM would need to be settled on nodal basis - settlement system
changes
Market Operations Standing Committee of the IMO September 22, 2003 Slide 39
Day Ahead Market Design Update
Agenda
DAM Chronology
DAM Design and Features
DAM Pricing Options
DAM Benefits
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 40
Day Ahead Market - Benefits
Improved point of convergence for forward products DAM provides a transparent and predictable price that converges on the
RTM price
• Lower volatility - DAM price volatility lower than RTM price
• Greater liquidity - DAM explicitly allows non-dispatchable load bids and ‘virtual’ participation
• Price convergence - ‘virtual’ participants in DAM encourage price arbitrage between DAM and real-time market
DAM price better than RTM price as an index - facilitates forward price curve development contracting
Experience in other markets...
• Contracting in PJM and NY > 50% of market
• PJM futures activity setting volume records on NYMEX
Market Operations Standing Committee of the IMO September 22, 2003 Slide 41
Day Ahead Market - Benefits
Improved reliability Allows for direct participation of all loads in market
• Additional opportunity for demand-side response
Improved commitment process• Allows IMO to commit sufficient resources to meet forecast demand• Drivers to ensure committed resources ‘show-up in real-time’• Utilizes 3-part offer construct and provides BPCG
Imports and exports priced and scheduled day-ahead• Moves transactions from RTM to DAM and reduces intertie trading
uncertainty – Should reduce number of failed intertie transactions– Should reduce Intertie Offer Guarantee (IOG) uplift
payments
Market Operations Standing Committee of the IMO September 22, 2003 Slide 42
Day Ahead Market Design Update
Agenda
DAM Chronology
DAM Design and Features
DAM Pricing Options
DAM Benefits
Next Steps
Market Operations Standing Committee of the IMO September 22, 2003 Slide 43
DAM - Next Steps
Assess Impact of Nodal Pricing
• The DAM WG will continue to address DAM-related issues,
including those related to nodal pricing
• Need to determine appropriate vehicle to stakeholder issues
related to impact of nodal pricing in RTM
Complete DAM High Level Design Strawman