price caps - - - - - - - - - - - - - - - - - - - - - - forwarded by vladimir gorny / hou / ect on 11 / 01 / 2000 03 : 39 pm - - - - - - - - - - - - - - - - - - - - - - - - - - - from : tim belden 10 / 27 / 2000 05 : 40 pm to : john j lavorato / corp / enron , dave delainey , mike swerzbin / hou / ect @ ect , robert badeer / hou / ect @ ect , sean crandall / pdx / ect @ ect , tim belden / hou / ect @ ect , jeff richter / hou / ect @ ect , diana scholtes / hou / ect @ ect , tom alonso / pdx / ect @ ect , mark fischer / pdx / ect @ ect , john m forney / hou / ect @ ect , paul choi / sf / ect @ ect , john malowney / hou / ect @ ect , holli krebs / hou / ect @ ect , greg wolfe / hou / ect @ ect , chris h foster / hou / ect @ ect , stewart rosman / hou / ect @ ect , kim ward / hou / ect @ ect , debra davidson / pdx / ect @ ect , tim belden / hou / ect @ ect , lester rawson / pdx / ect @ ect , john zufferli / cal / ect @ ect , james d steffes / na / enron @ enron , mary hain / hou / ect @ ect , christopher f calger / pdx / ect @ ect , dave parquet , phillip k allen / hou / ect @ ect , vladimir gorny / hou / ect @ ect , monica lande / pdx / ect @ ect , elliot mainzer / pdx / ect @ ect , tim heizenrader / pdx / ect @ ect , cooper richey , stephen swain / pdx / ect @ ect , susan j mara / sfo / ees @ ees , steven j kean / na / enron @ enron , mark palmer / corp / enron @ enron cc : debra davidson / pdx / ect @ ect subject : price caps the following summarizes recent price cap events in california . i think that i have most of it right . if there is anything wrong or missing please let me know . please don ' t share the attached spreadsheet with anyone outside of enron . regards , tim new cap specifics on 10 / 26 / 2000 the iso board passed a motion by a vote of 13 - 10 to implement a new price cap methodology . the new methodology will become effective 11 / 3 / 2000 or as soon thereafter as can be implemented . caiso staff has indicated that it will be difficult to achieve that start date . they have not yet indicated what an achievable date might be . the new price cap methodology will remain in place until : comprehensive market changes have been implemented and the market has proven to be workably competitive under a variety of load conditions . either ferc or the iso board orders its removal . cap prices will be based on the average nymex l 3 d settlement average and the following heat rate table : load level heat rate 4 . 00 gas example cap 40 gw $ 250 / mwh $ 250 / mwh caps will be rounded up to the nearest $ 5 / mwh increment . demand bids and demand responsiveness programs are exempt from these caps . the iso will post the price caps for each load level at least 48 hours prior to the beginning of each calendar month . based on the iso ' s two day - ahead system load forecast , the iso will post hourly caps at least 24 hours prior to the hour of delivery . ferc context ferc has delegated cap authority to the caiso until 11 / 15 / 2000 . the iso has asserted that they don ' t need ferc authority since it is a bid cap rather than a sales cap . ferc regulates sales , not purchases , of electricity and therefore can regulate sales prices but not purchase prices . the iso has filed with ferc for an extension of the price cap authority . ferc has to rule on the filing by 11 / 18 / 2000 . ( note that this is 3 days after their authority expires ) ferc will release its proposed order on 11 / 1 / 2000 based on the results of its 206 investigation of the california wholesale power markets . we don ' t know what they will find or what they will propose . the proposed order will have a 30 day comment period , after which ferc will likely issue a final order . ferc will be accepting oral comments on 11 / 9 / 2000 in washington . enron still has to determine who will provide oral comments . many companies have filed at ferc advocating or opposing a litany of price caps , cost based rates , and market redesign recommendations . it is likely that the price caps approved by the iso board will go into effect . how long they will remain in effect will depend on whether ferc extends the iso price cap authority and whether the final order stemming from the current 206 investigation stipulates a specific price cap policy . impact of price caps the attached spreadsheet contains a table of likely maximum monthly prices at different gas price levels . we think that this is the highest that markets would clear since it assumes that each hour clears at the cap . it is hard to say whether actual prices would clear significantly lower than the cap because we don ' t know whether sellers will offer below the cap or at the cap . the assumptions behind our analysis are detailed in the bullets below . take actual historical loads from 1999 and 2000 . calculate implied price cap for each hour using actual historical load , new price cap methodology , and a range of gas prices . divide historical hours into peak and off - peak buckets . calculate average price for each month for peak hours and off - peak hours . for example , we have two years worth of data for the months of january through september . each month has approximately 400 hours . for january through september , we took approximately 800 observations for each month ( 400 from each year ) and calculated a simple average of all of the individual observations . we created a peak table and an off - peak table . the table shows the calculated implied cap based off of the acutal loads at varying gas prices for each month . this value represents what the month would clear at if each hour cleared at the cap ( based on historic loads ) . while any given hour could be above this value , our calculation estimates the likely monthly average cap value ! the blue shading indicates what the caps would be given current ( 10 / 27 / 2000 nymex ) forward prices . the yellow shading indicates those forward power prices which are in excess of the proposed cap .