By Robert Mullin

CAISO last year paid out $47 million more to congestion revenue rights holders than it took in from its auctions, the ISO’s internal Market Monitor has found.

That deficit — a persistent problem since the ISO instituted CRR auctions five years ago — could buttress the Monitor’s call for ending the auctions, which it says allows financial speculators to reap hundreds of millions of dollars at the expense of California electricity ratepayers. (See CAISO Monitor Proposes to End Revenue Rights Auction.)

“The [Department of Market Monitoring] believes that the trend of revenues being transferred from electric ratepayers to other entities warrants reassessing the standard electricity market design assumption that ISOs should auction off these financial instruments on behalf of ratepayers after the congestion revenue right allocations,” the Monitor said in its quarterly market issues and performance report covering the fourth quarter of last year.

The Monitor’s suggestion: Replace the auction with a bilateral or exchange market for contracts-for-differences for pairs of ISO nodes — also known as locational basis price swaps.

Under that arrangement, swaps would be traded among willing counterparties, rather than leaving ratepayers as unwitting parties in a market in which they are outmatched by more sophisticated traders, the Monitor says.

CAISO management has responded to the Monitor’s concerns by agreeing to consider a stakeholder initiative on potential changes to the auction, a move that has been met with mixed reactions from market participants. (See CRR Initiative Elicits Mixed Reviews from CAISO Participants.)

Proposal Unwarranted?

“While I don’t believe DMM’s latest findings warrant their specific proposal to replace the CRR auction with a bilateral market or locational price swaps … I think the CAISO’s study is absolutely an opportunity to make improvements to the current CRR auction and identify practices and transparency issues that may be causing some inefficiency in the CRR auction pricing,” Carrie Bentley, a principal with Resero Consulting, told RTO Insider.

Bentley’s firm frequently works on behalf of the Western Power Trading Forum (WPTF), an energy trader interest group that opposes the suggestion to scrap the auction. It has called the proposed stakeholder initiative a “pet project” of the Monitor.

The Monitor’s most recent findings show that last year’s CRR deficit increased by $1 million over 2015, with auction revenues representing just 68% of CRR payments made to auction participants, compared with 73% during the previous year.

While total payments to auction rights holders declined 15% to $147 million, auction revenues also fell 21% to $99 million year over year.

Financial traders last year took in $33 million from the auctions, paying 63 cents for every dollar made from their CRRs. Their overall take was down 30% from the previous year, but it still represented the largest share of all participants. The Monitor has contended that “purely financial entities” are the main beneficiaries of the auction program.

Power marketers saw their auction profits increase by 43% to $10 million, while generator profits fell by 29% to $5 million.

Load-serving entities, which CAISO provides an annual allocation of CRRs, made about $3 million from rights they sold into the auction, down sharply from $14 million earned the previous year.

Transmission congestion dropped last year as drought conditions resulted in decreased electricity use for moving water supplies across California. Transmission usage also was undercut by growth in behind-the-meter rooftop solar.

The fourth quarter saw the resumption of the prevailing pattern of CRR payments outpacing auction revenues, following a short-lived surplus during the third quarter (see chart).

WPTF Comments

In comments filed with CAISO earlier this year, WPTF contended that auction revenues increased as a percentage of payments in the third quarter after the ISO implemented practices that improved transparency into how it represents transmission outages in its market models.

“I think the fourth-quarter results were due to unexpected transmission outages and nomograms [prediction tools] that were not included in the CRR model or known by participants in advance of the auction,” Bentley said.

She cited as evidence the ISO’s own monthly market performance reports for October, November and December, which attributed at least a portion of auction revenue shortfalls each month to unexpected binding constraints on the transmission system.

Unlike other RTOs that have imposed penalties for “late, unnecessary or nonemergency outages that impact the day-ahead market, but were not modeled in the monthly auction,” CAISO has no such policies, Bentley said.

“Therefore, events like this last quarter are frequent, where outages impact CRR shortfalls with no repercussions on those causing the shortfall,” she said.

Bentley added that the ISO may compound the issue by not providing sufficient notice in advance of auctions about nomograms created to account for outages.

“While the majority of nomograms understandably may not be done in advance sufficient to notify market participants, a tightening up of transparency policies would enable better CRR auction outcomes in those cases that the CAISO could have given advance warning,” Bentley said.

Analysis Challenged

Ryan Kurlinski, manager of the Monitor’s analysis and mitigation group, rejected Bentley’s analysis. “There is no evidence to support WPTF’s suggestion that improvements in the ISO’s transmission outage reporting accounted for the reasons that CRR auction revenues exceeded payouts during the third quarter of 2016,” he said.

Kurlinski said the third quarter was “very anomalous” and that lower payments to auction participants stemmed from “unusually low” congestion appearing in the ISO’s day-ahead market during the period.

“During periods of this quarter, virtually no congestion appeared in the day-ahead market,” Kurlinski said. “DMM is working with the ISO to understand factors which might have caused this.” That lack of congestion likely accounts for last year’s overall drop in payouts to CRR holders.

Kurlinski doubted that adjustments to the auction model could ultimately improve outcomes for ratepayers.

“Even if the CRR auction model includes all outages known by CAISO [transmission owners] at the time the model is completed, there will be outages that cannot be adequately modeled,” Kurlinski said. “For instance, if an outage is scheduled for only a few days, this outage cannot be accurately represented in the monthly CRR model.”