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I-SEM – Market Rules Working Group Meeting XII

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1 I-SEM – Market Rules Working Group Meeting XII
10th November 2016

2 Agenda Capacity Market Code; AOB & Next Steps.

3 General Changes Since Draft One
Expanded the set of included definitions. Tightened up the wording of many clauses. More content in appendices. Addressed numerous minor comments submitted to us Updated notes / comments to be more stand-alone (e.g. no reference to Plain English Guide). As discussed at last WG, simplified terminology around capacity (discussed next) A tracked changed version of the CMC was provided so you have visibility on any changes we do not discuss here. Many of these are just minor rewordings or enhancements to the detail.

4 De-Rated Capacity (Total)
Changes to Terminology - All Sections Physical Unit (values determined for physical units summed to give values for associated Capacity Market Unit) Capacity Market Units Gross De-Rating Factor (Total) = Gross De-Rated Capacity (Total) / Initial Capacity (Total) Gross De-Rated Capacity (Total) Gross De-Rated Capacity (New) Gross De-Rated Capacity (Existing) Awarded Capacity Initial Capacity (Existing) Initial Capacity (Total) Net De-Rated Capacity (New) Net De-Rated Capacity (Existing) New Capacity “Awarded New Capacity” Existing Capacity Gross De-Rating Factor (Existing) = Gross De-Rated Capacity (Existing) / Initial Capacity (Existing)

5 Participant Registered (Physical) Unit Registered
Accession and Registration (B.5) Arrangements described at a last working group have been refined and incorporated into B.5. TSC Party Accedes Participant Registered (Physical) Unit Registered Used in Settlements New Capacity (yet to be registered under TSC) Build Unit Candidate Unit CMC Party Accedes Capacity Market Unit Registered Capacity Market Unit ID () (E.3.1.5) Qualification Provisional Registration (intending participant) Candidate Unit (provisional until built or becomes part of a registered CMU in qualification) Capacity Market Auctions & Secondary Trade

6 Intermediaries (B.5.5) The requirements around Intermediaries are still under consideration by the RAs. The CMC has been drafted in a manner that would accommodate any outcome. The RAs are considering if a new Form of Authority is required under the CMC, or whether it can be “common” between the CMC and the TSC. A process has been added to the end of the section to address changes of Intermediaries, including allowing a 60 day period for the transfer of Generating Units to another Intermediary as an alternative to de-registration of Generator Units.

7 System Operator Fees (B.7)
This section proposes a set of fees to fund the cost of operation of the CMC. Actual values would need to be set by the RAs through a parameter like process. Drafting has these charges being collected under the CMC . System Operator fees comprise: a Qualification Fee applicable to Participants for each Application for Qualification in respect of a Candidate Unit a Fixed System Operator Charge applicable to Participants in respect of their Capacity Market Units a Variable System Operator Charge applicable to all Participants in respect of their Supplier Units While there is no collateral requirement in respect of fees, there are provisions around payments, interest applying for late payments and overdue amounts may be offset against other amounts payable to the participant by the System Operators.

8 Obligations on Parties (B.8) & Market Manipulation (B.9)
B.8.2 enables System Operators to collect information required for regulatory / legal reasons. This clause is not prescriptive, rather it allows System Operators to fulfill such a role if it were to exist under legislation (e.g. resulting from a decision outside of the scope of the CMC). We have received comments that legal definitions of Market Manipulation in B.9 (e.g. REMIT) would supersede the CMC. While we do not disagree, the section was proposed by the RAs and does serve to spell out requirements in the context of this market. The section has been updated to include Opt Out Notifications (as these could conceivably could be used to influence auction outcomes).

9 Role of Capacity Market Auditor (B.11.2)
B has been updated to specify that the RAs will consult on the Capacity Market Auditor’s terms of reference (for the following year) after the publication of each audit report. While appointed for a period of 3 years, this process ensures that the audit terms of reference can evolve with the needs of the market. This parallels provisions from the TSC. There is no similar requirement for the Capacity Auction Monitor as its role is about compliance monitoring, not audit.

10 Modification Process (B.12)
Some comments sought more Participant involvement in the modification process – presumably to make it more like that in the TSC. However the CMC reflects CRM Decisions which propose a quite different process from the TSC. B.12.3 clarified. It describes the Modification Proposal Date that the RAs may publish, being the cut off date for an accepted modification to take effect for a Capacity Auction. B has System Operators reporting to RAs on the status of modifications one month before the Modification Proposal Date (if set). Comments were received about the Workshop and Consultation processes for which (in each case) it is stated that “substantial compliance” is acceptable. A note has been added to explain that these clauses are to protect the integrity of the modification process if immaterial deviations from the process occurs – e.g. if an unaffected party failed to receive an because of an out of date mailing list. It is commonly used in similar situations. B (on publication of RA decisions) has been removed, covered by B.12.13

11 Suspension (B.13.3 ) One of the suspension conditions have been changed: B (g) previously referred to 3 defaults in a 20 day period. E.g. the Party to the Code breaches the Code 3 times in 20 days (where each event has a material adverse effect on another party). This is less likely to occur under the CMC than under the TSC markets. Instead, now suspension can be triggered if the System Operators have issued a Default Notice to the Party and the Party has failed to remedy the Default within the period of 20 Working Days following the Default Notice being issued. Note: a Default is a breach that has a material adverse affect on another Party or the SEM

12 Disputes ( B.14) and Force Majeure (B.16)
B (e) describes a new “Conflict Dispute” being a Dispute in relation to a claimed conflict between the Code and other relevant Legal Requirements – brings into line with TSC. B had text on “reasonable endeavours obligations” in resolving disputes which has been removed as it was duplicating the meaning of B Force Majeure B If an FM event is due to a conflict between the Code and relevant Legal Requirements it can be requested by the System Operators or the RAs that the Affected Party propose an Urgent Modification to address the issue, or serve a Notice of Dispute in respect of the issue, within 5 working days. This provides a path to resolve the issue. This drafting brings the CMC in line with TSC

13 De-Rating and Capacity Concepts (Chapter C)
Sections removed from CMC to reflect that it is now proposed that RAs determine the Technology Classes, Capacity Requirements & De-Rating Factors via an RA decision. C.1 describes key concepts – primarily to give context to terminology. C.2. describes Initial Capacity A new definition of Initial Capacity has been added for Autoproducers. Instead of being limited by Maximum Export Capacity it is now limited by the lesser of: the Maximum Export Capacity; the (total) registered capacity less the Maximum Import Capacity This means that an Autoproducer will not be required to sell more than its net generation capacity (after supplying its load) into the Capacity Market. C.3. specifies the Initial Capacity to use in the Alternative Qualification Process. Key difference with C.2 is that C.2 allows some choice where multiple values are possible (e.g. 2 generators at a site with total capacity exceeding MEC), but C.3 uses a pro-rata approach linked to Registered Capacity to give a unique value.

14 Pre Capacity Auction Processes (Chapter D)
D.2, the Capacity Auction Timetable (detailed in Appendix C) has been modified so that instead of referring to “deadlines” it now refers to “dates”. D.3.1.2, the Capacity Auction Information Pack, now includes the Reserve Scarcity Pricing Curve (i.e. the ASP curve). D.3.1.3, the information required to be provided by the RAs for the Capacity Auction Information Pack, now includes the Auction Price Cap. D.3.1.4, specifies that the Annual Capacity Payment Exchange Rate applicable to Awarded Capacity in an Auction is the Annual Capacity Payment Exchange Rate last calculated under paragraph K.1.2 (Chapter K) prior to the release of the Capacity Auction Information Pack for that Capacity Auction.

15 (Physical) Unit Registered Provisional Registration
The Big Picture – Qualification TSC (Physical) Unit Registered Opt Out Notification If declined Qualification Application CMC Provisional Registration (candidate unit) Capacity Market Unit ID De-rating data for physical facilities and CMU Capacity Market Unit Assessment of Data Alternative Qualification Process Eligible, wrong or inadequate data (Based on SO data) Qualification Rejected Not eligible Qualification Approved Qualification Process (Based on applicant data)

16 Requirements to Qualify (E.2 ) & Dual Rated Units
E introduces the option for a participant’s Candidate Unit to be excused from needing to Qualify if permission for this is given by the RA’s under E.4.1.1(b). E (b) allows permission to be granted if the Candidate Unit is taking an extended planned outage during the Capacity Year. E introduces a process to assign a Capacity Market Unit Identifier (Ω) to a Capacity Market Unit for which Qualification is sought if no identifier already exists. This allows the CMU to be identified in the Qualification process. Dual Rated Units The issue of treatment of dual-rated units is still under consideration by the RAs. The issue is that the Technical Offer Data of such units can be changed through switching fuels, and in particular, if the maximum available capacity applies only for a rarely used fuel then de-rated values based on that value may create additional risks when operating on other fuels with lower available capacity.

17 Opt Out Notifications (E.4)
Unit can now be opted out due to an extended planned outage if the RAs approve this. CMC refers to Grid Code requirement to notify System Operators of unit closure (2 to 3 years ahead). This is in RoI Grid Code and is coming into NI Grid Code. Issue: if closing a unit because it does not win in a T-1 auction then participant may not want to wait 2 or 3 years. This can only be addressed in the Grid Code. E requires (as applicable) confirmation that the Candidate Unit will be Closed by the end (was start) of the Capacity Year, and, where required by the System Operators, evidence of any Regulatory Authority or Grid Code notification of the Closure; if applicable, a copy of the determination of the Regulatory Authorities allowing the unit to opt-out for a planned outage. a certificate signed on behalf of the Participant by a director or officer of the Participant that information submitted is true and correct and that the Opt-out Notification is not for the purposes of, or connected with, Market Manipulation by the Participant or any of its Associates.

18 Requirements for Qualification (E.7)
E introduced to say System Operators should use judgement reasonably expected of a Prudent System Operator in conducting Qualification. E introduces Qualification fee payment as a pre-condition for Qualification. E states some basic requirements for New Capacity to be qualified. E has been added so if New Capacity has already been Awarded Capacity then Qualification should not be rejected for the reasons outlined in E (as Chapter J governs its termination). Capacity beyond this can still be refused Qualification (the current wording is a bit unclear and will be clarified). E.7.7 (Requirements for Aggregating Units in a Capacity Market Unit) now precludes the inclusion of a unit for which a Unit Specific Price Cap applies. This is because the CMU would comprise units with different price caps. This is also noted after E (which relates to RA approval of such cap). E has a missing cross-reference. The references should be to E.8.2 & E.8.3

19 Except for a Variable Unit in which case:
Qualification Calculations (E.8 ) Process for determining Gross De-Rated Quantities has been converted to equations. E (Existing Capacity) GDRCE = MIN[ DRFE × ICE× (1 + IncTol), MAX[DRFE × ICE × (1- DecTol), NDRVE]] Except for a Variable Unit in which case: GDRCE = MIN[ DRFE × ICE × (1 + IncTol), NDRVE] = MIN[ , MAX [ , ]] = MIN[ , MAX [ , ]] = MIN[ , MAX [ , ]] De-rated factor (DRFE) scaled initial capacity for existing capacity (ICE), increased based on a % increase tolerance (IncTol) De-rated factor (DRFE) scaled initial capacity for existing capacity (ICE), reduced based on a % decrease tolerance (DecTol) Nominated Gross De-Rated Capacity (Existing) = MIN[ , ] = MIN[ , ] = MIN[ , ] Can Qualify To Zero

20 Except for a Variable Unit in which case:
Qualification Calculations (E.8 ) Process for determining Gross De-Rated Quantities has been converted to equations. E (New Capacity) GDRCN = MAX[0, MIN[ DRFT × ICT × (1 + IncTol), MAX[DRFT ICT× (1 - DecTol), NDRVE + NDRVN]] - GDRCE] Except for a Variable Unit in which case: GDRCN = MAX[0, MIN[ DRFT × ICT × (1 + IncTol), NDRVE + NDRVN] - GDRCE] Gross De-Rated Capacity (Existing) = MAX[0, MIN[ , MAX [ , =220 ]] ] = MAX[0, MIN[ , MAX [ , = 182 ]] ] = MAX[0, MIN[ , MAX [ , = ]] ] De-rated factor (DRFE) scaled initial capacity for total capacity (ICT), increased based on a % increase tolerance (IncTol) De-rated factor (DRFE) scaled initial capacity for total capacity (ICT), reduced based on a % decrease tolerance (DecTol) Nominated Gross De-Rated Capacity (Existing) + Nominated Gross De-Rated Capacity (New) = MAX[0, MIN[ , = ] ] = MAX[0, MIN[ , = ] ] = MAX[0, MIN[ , = ]] ] Can Qualify To Zero

21 Qualification Calculations (E.8 )
Similar equations apply for AGU’s (E and E.8.2.4), the difference being that the calculations are applied to Generators and summed to give the AGU result. The prior version summed all capacity of a given technology and applied the de-rating value for that quantity. As de-rating factors fall with increasing capacity this would have produced a lower de-rated value than the new method, which uses the de-rating factor applicable to each Generator. E.8.3 takes the Gross De-Rated Capacity determined for Generator Units and Interconnectors and sums these to the Capacity Market Unit level for each of Existing and New Capacity. Awarded Capacity is subtracted to give associated Net De-Rated Capacity quantities. (Clause (f) refers to Net De-Rated Capacity (Total) – this concept is not needed or defined so will be removed). E deals with the calculation of Firm Offer Requirement, which reflects a de-rated view of firm access to networks, now refers to Firm Network Access Capacity, defined to be Transmission or Distribution firm access. E.8.7 defines Initial Capacity and the Gross De-Rating Factor (used in TSC settlement) for Capacity Market Units (based on candidate unit data).

22 Qualification Decisions (E.9 ) & Extended Qualification (E.11)
E.9.1, Qualification Information Results, lists the information given to Applicants. It has been modified to include the Firm Offer Requirement (previously missing) and the Initial Capacity values for a CMU. E.9.4, Publication of Qualification Results, now lists public information released. This is based on system specifications and reflects data aggregated at Technology Class and Unit Type level. A note states that this will reveal more information about units of which there are only one or a few of a given Technology Class or Unit Type level. E.11 includes provisions that allow a CMU qualified for a Capacity Year (Year X) to: Have its qualification brought forward to start in Capacity Year X-1 if the unit is commissioned in that year (and not otherwise qualified) Have its qualification extended to end in Capacity Year X+1 if the unit closes in that year. This provides a very simple mechanism to allow these units to participate in Secondary Trade for partial Capacity Years.

23 (Physical) Unit Registered
The Big Picture – Primary Auction TSC (Physical) Unit Registered CMC Provisional Registration (candidate unit) Capacity Market Unit Terminated Capacity & Trade Registry Entry Pending Active New Existing Capacity Market Auction Accept Auction Results, Accept Implementation Plan, Post initial Performance Bond Accept Auction Results “Win” in auction

24 an allowance for changes in forecast capacity requirements;
Capacity Auctions (Chapter F ) & Registries (Chapter G) F.2 now contemplates that qualified New Capacity is not required to participate in the auction. While that position seems reasonable, it is a change to the current design. A change request is being raised to implement this. Based on comments, F has been reworded to say that the RAs are expected to set the demand curve to be the Capacity Requirement adjusted for existing Awarded Capacity in respect of the relevant Capacity Year and (as considered appropriate by the RAs); an allowance for changes in forecast capacity requirements; an allowance for capacity to be procured in later auctions; and an allowance for (the de-rated value) of capacity that is expected to be operational during the Capacity Year but which is not required to participate. F.6, Locational Constraints, has been moved from Chapter C to Chapter F though is currently just the heading. Section G.4 has been deleted as functionality has been moved to the TSC.

25 This has no impact on settlement.
Capacity Auctions (Chapter F ) & Registries (Chapter G) The CMC states (in F.8.1) that for a capacity auction a volume of awarded capacity is recorded for each of Existing Capacity and New Capacity, with price of each equal to the average value of the awarded offer steps. Thus, if a participant used 2 offers steps for Existing Capacity and was cleared for 100 MW at the auction price of €50,000/MW, and for 50 MW at a pay-as-offer price of €80,000/MW, then the trade recorded for Existing Capacity should be a single trade of 150 MW with a price of (100×50, ×90,000) /150 = €60,000/MW. A similar calculation would apply for New Capacity. An alternative, and potentially cleaner way to implement in the systems, is to record each step cleared as its own trade. This has no impact on settlement. Proportion of capacity commissioned or terminated would just be applied to each trade. May minimise the need for other system changes in the future.

26 Existing Capacity Price Cap
Capacity Auction Offers Price (€/MW per year) Inflexible Duration:1 Yr New Capacity (Not Satisfying New Capacity Investment Rate Threshold) Lowest price for new capacity must exceed highest price for existing capacity New Capacity (Satisfying New Capacity Investment Rate Threshold) Flexible Duration 10 Yrs Inflexible Must be same duration Existing Capacity Existing Capacity Price Cap Inflexible Duration:1 Yr Auction Price Cap Process to Apply for a Unit Specific Price Cap

27 (Physical) Unit Registered
The Big Picture – Secondary Trade TSC (Physical) Unit Registered CMC Provisional Registration (candidate unit) Commissioned Capacity Capacity Market Unit “Win” in auction Terminated Secondary Trade Auction Capacity & Trade Registry Entry Pending Active New New Existing Capacity Market Auction Accept Auction Results, Accept Implementation Plan, Post initial Performance Bond Accept Auction Results “Win” in auction

28 Also, to clarify a point about load following:
Secondary Trade (Chapter H ) H introduces a requirement for the System Operators to consult with the RAs on the design of secondary trade products. H adds text to make clear that the exchange rate used in the Secondary Trade Auction Information Pack is the most recently calculated exchange rate under Chapter K applicable for the period to which a product relates. Also, to clarify a point about load following: A real-time load following factor is determined under the TSC. The RA’s are to determine a forecast of those load following factors. The Secondary Trading arrangements use FPFCQSF. A note following H now clarifies that this is intended to be a “conservative estimate over the duration of the product” of the load following factor. While it could be based on the RA forecast it is not actually the same thing. It is unique to a product and can have different values for different product definitions.

29 A note at the front of the section identifies an issue.
Secondary Trade Bids and Offers (Chapter H.7 ) A note at the front of the section identifies an issue. If a unit has been awarded capacity in prior capacity auction but now has a lower de-rated capacity than implied by the awarded capacity then while it will have no restrictions on its ability to buy capacity through secondary trade, it will be restricted by the 70 day limit in selling capacity. If it were on outage and bought out of its awarded capacity (Trade A) but were to end its outage early, it could only trade back into its original position if it had not exceed the 70 day limit … otherwise it would have to wait until the expiration of Trade A. More fundamentally, the TSC will limit a participant’s exposure to difference charges to not exceed its de-rated capacity if it is not trading above its de-rated capacity. Thus if such a variable unit had a de-rated capacity of zero and had awarded capacity it would have no exposure to difference charges. A potential solution to this issue would be to require that Gross De-Rated Capacity (Existing) and Gross De-Rated Capacity (New ) for a CMU cannot be less than the awarded capacity already held (for new and existing capacity, as applicable). This has no impact on the Capacity Market Auction as the Awarded Capacity is netted from these values to give the New De-Rated Capacity values

30 Secondary Trade Bids and Offers (Chapter H.7 )
H introduces a factor called the Secondary Trade De-Rated Capacity Tolerance (STDCT) to the Seller Limit. This can be used to further limit trade above de-rated capacity by unit type. If set to a low value it could be used to limit how much heavily de-rated units can trade upwards, e.g. because of limitations on the reliability with which they could deliver that capacity. This feature will be inactive as things stand but would be available were there a need to further limit trade above de-rated capacity.

31 For a particular product.
Secondary Trade Bids and Offers Scaled Up Scaling undoes load following before it is applied. For a particular product. Scaled Up Price (€/MW per year) Cumulative Prior Trades Seller Limit (Trade above De-Rated Capacity) STDCT Buyer Limit Seller Limit (Normal) Price Cap For  70 days per Capacity Year the 5 steps can extend further 0 MW Initial Position Gross De-Rated Capacity Initial Capacity Commissioned Capacity

32 Calling this “Legitimate Reasons” may therefore be more appropriate.
Secondary Trade Bids and Offers (Chapter H.7 ) H and H introduce a definition of Legitimate Technical Reasons (the previous draft used the term “Outages”) and which is a requirement for all bids to buy capacity. This version allows for Outages as well as the ability for a participant to be allowed to secondary trade if the RAs agree the plant has become too unreliable or uneconomic (discussed in CRM consultations). It is highlighted that the current definition is restrictive as secondary trades that do not reduce the primary auction position logically should not be caught up in this (except maybe close to real time). [See Next Slide] Calling this “Legitimate Reasons” may therefore be more appropriate.

33 Secondary Trade Bids and Offers (Chapter H.7 )
Secondary Trade in this range should not be restricted except possibly close to real-time (where it might be due to an outage rather than economic trading). Secondary Trade Primary Trade Secondary Trade Secondary Trade in this range should be due to an outage or as allowed by RAs Time

34 (Physical) Unit Registered
The Big Picture – New Capacity TSC (Physical) Unit Registered CMC Provisional Registration (candidate unit) Commissioned Capacity Capacity Market Unit Commissioning Grid Codes “Win” in auction Substantial Completion or Minimum Completion Terminated Secondary Trade Auction Capacity & Trade Registry Entry Implementation Progress All / part terminated if do not achieve Substantial Completion Pending Active New New Existing Capacity Market Auction New Accept Auction Results, Accept Implementation Plan, Post initial Performance Bond Accept Auction Results Progress Build, Keep Performance Bond up to Date, Report on Progress “Win” in auction

35 Content of Implementation Plans (J.2 )
J.2 modified to make clearer that implementation plans relate to physical units, but that they are tracking progress of New Capacity associated with Capacity Market Units. Also, J has been added (for discussion) to give a different definition of the milestones for AGUs and DSUs such that the only applicable milestones are: Substantial Financial Completion, which occurs when a contract is in place between the Participant and the provider of the physical capacity and evidence of this is provided to the System Operators; Completion of “network connection”, which in this context mean the physical systems (e.g. SCADA/metering) required for operation as an Aggregated Generator Unit or Demand Side Unit under the applicable Grid Code are in place; the Substantial Completion Milestone, which is the standard definition. J now limits extent to which Participants must advise the System Operators about changes to major contracts to events which would change the data they qualified with, or would delay achieving any milestone. J excuses participants from providing evidence (e.g. of commissioning) where that evidence is in fact issued by one of the System Operators.

36 Performance Bonds (J.3 ) and Progressing Reporting (J.4)
J now includes detailed provisions concerning cash deposits (from TSC). Progress Reporting J now defines what is required for verification of Substantial Financial Completion: a certificate from an independent Certified Engineer (after making due and careful enquiry and to the best of their knowledge, information and belief of achievement) a certificate signed on behalf of the Participant by a director or officer of the Participant certifying that, having made due and careful enquiry and to the best of their knowledge, information and belief, Substantial Financial Completion has been achieved, and in particular that: all the Major Contracts (now defined as EPC contract or a contract worth at least 20% of Total Project Spend) and financing arrangements are in place; each Major Contract and other document is legal, valid, binding, in full force and effect, and has been entered into with parties that can perform the obligation; Participant has/will have sufficient financial resources for Total Project Spend. Clause also allows for alternative processes to be approved by System Operators.

37 Only the RA’s can extend Substantial Financial Completion.
Remedial Action (J.5 ) J previously just allowed Participants or their financiers to seek approval to change an EPC Contractor or to change the supplier of a major piece of equipment if that does not decrease the likelihood of delivery prior to the Long Stop Date. It has now been extended to allow Participants to seek to change a milestone date (other than Substantial Financial Completion) if they can provide sufficient evidence to satisfy the System Operators that this will not decrease the likelihood of delivery prior to the Long Stop Date ( e.g., by facilitating a new EPC Contractor). This gives effect to the fact that reporting against milestones must allow for some modification in schedule. Only the RA’s can extend Substantial Financial Completion.

38 Almost full set of Appendices now provided. Following material is new:
Appendix B: Template for Dispute Resolution Agreement – follows equivalent in TSC Appendix H: Data Publication Appendix I: Template for Standard Letter of Credit – follows equivalent in TSC Appendix J: Template for Deed of Charge and Account Security (for Performance Bonds provided by way of a cash deposit in a Reserve Account) – follows format from recent Modification to TSC. We have removed appendices related to the De-Rating Methodology and Technology Classes as these are now under an RA consultation process.

39 (Physical) Unit Registered
The Big Picture – All In One Place TSC (Physical) Unit Registered CMC Provisional Registration (candidate unit) Commissioned Capacity Capacity Market Unit Commissioning Grid Codes “Win” in auction Substantial Completion or Minimum Completion Terminated Secondary Trade Auction Capacity & Trade Registry Entry Implementation Progress All / part terminated if do not achieve Substantial Completion Pending Active New New Existing Capacity Market Auction New Accept Auction Results, Accept Implementation Plan, Post initial Performance Bond Accept Auction Results Progress Build, Keep Performance Bond up to Date, Report on Progress “Win” in auction

40 Next Steps Provide us your comments and questions within 5 working days of this meeting.


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