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RSG Costs ($ Millions)

Capacity

Constraint

Total

Share

Need Unknown

$6.68

$18.29

$24.97

23%

Not Deviation Related

9.17

12.04

21.21

19%

Other Exemption

0.52

0.06

0.58

0.5%

Testing

0.00

0.02

0.02

0.0%

Start Stop

0.44

0.08

0.52

0.5%

Intermittent

0.85

0.20

1.05

1.0%

Wind

2.68

0.68

3.36

3.1%

Cont Res Deployment

0.03

0.00

0.03

0.0%

Dispatch Bands

1.35

0.11

1.46

1.3%

Virtual Load

0.00

0.74

0.74

1%

Wheels

0.00

0.10

0.10

0%

Must-Run

0.00

0.15

0.15

0%

Deratings

10.22

0.89

11.12

10%

Deficient Energy

0.21

0.02

0.23

0%

Excessive Energy

0.00

0.01

0.01

0%

Virtual Supply

11.77

1.66

13.44

12%

Exports

6.23

0.19

6.42

6%

Imports

3.71

0.31

4.02

4%

Load

18.13

1.48

19.61

18%

2009 State of the Market Report

Market Performance

Figure 43 provides a detailed breakdown of the RSG attribution results. This figure provides the total real-time capacity and constraint-related RSG costs that we attributable to each type of deviations.

Figure 43: Attribution of RSG Costs by Factor January 6, 2009 to December 31, 2009

The figure also shows that of the seven exempt factors, the largest quantities of real-time RSG costs were caused by intermittent resources, totaling more than four percent of the real-time RSG costs. Most of this quantity was caused by wind resources (approximately three percent). Since the publication of our study, the Midwest ISO has resolved to eliminate dispatch bands and proposed to remove the exemption from deviations for wind resources.

Deviations that currently bear all of the real-time RSG costs only cause approximately one-half of those costs. This results in inefficient incentives for the participants responsible for those deviations. The implementation of the improved RSG cost allocation should address this issue, but it has been pending FERC action since February 2009.

Note: Due to data limitations, the eight types of deviations at the bottom of the table includes deviations from participants that have “carve-out” rights associated with GFAs that are not allocated RSG.

Total

$72.01

$37.03

$109.04

100%

$80

$70

$60

$50

$40

$30

$20

$10

$0

Capacity

Constraint

Page 64

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