Annex 1 PIPPA Comments on the Proposed Amendments to the Administered Price Determination Manual Title Section Provision Proposed Amendment Rationale PIPPA Comments General Comment: The proposed amendment to Section 4.2.1 should be consolidated with the proposed amendments in the APDM submitted by 1590 Energy Corporation as both proposals would address the indeterminate values of Administered Price. PIPPA would further like to propose that aside from the Generator Administered Prices, the formula on Customer Settlement Amounts should also be updated so that no unnecessary charges will be attributed to the settlement amounts. The proposed formulation will be equitable and fair to all customers. The concept is causers pay regardless of the location of the load because the generated price is system-based Title Generator Administere d Prices – Average ExPost Nodal Energy Price Section 4.2.1 Provision 4.2.1.1 For each generator node, the administered price will be computed as the load weighted average of the expost nodal energy prices and meter quantity of the four most recent same-day xxx 4.2.1.2 In case of any of the prices covered by the four preceding same days have been administered xxx 4.2.1.3 In cases where any of the prices in the four preceding same days reflect Proposed Amendment Additional: 4.2.1.4. If no administered price can be determined for a generator trading node because the generating plant associated with that trading node had no actual generation, i.e., no metered quantity or MQ, the administered price shall be determined as follows: 4.2.1.4.1. The Ex-Post Price of the immediately preceding same day, same hour, non-administered price, with actual generation, but not earlier than one (1) year prior to the trading day and hour being considered shall be used in Rationale When the concerned generating plant has not produced electricity for the last previous four weeks, the computation for the administered price values results to indeterminate values. This issue has been raised by the PA in their findings, PA.MS.3 and occurred in the case of San Roque Hydro Electric Power Plant during the Market Suspension due to Typhoon Glenda. PIPPA Comments Where: EPP = Ex-Post Price AP = Administered Price (based on PIPPA Proposal) i = Generator resources (Suppliers) MQ = Meter Quantity 1 Annex 1 Title Section Provision xxx Proposed Amendment Rationale PIPPA Comments calculating the administered price. 4.2.1.4.2 In case Section 4.2.1.4.1 failed to determine a valid value for administered price, it shall then be computed by obtaining the simple average of the ex-post nodal prices of four preceding, same-day, samehour trading intervals that have not been administered. This is set out in the following formula: SA = Settlement Amount n = number of generator resources with positive meter quantity m = number of load resources with negative meter quantity j = Load resources (Customers) Rationale: Where: EPP = Ex-Post Price AP = Administered Price D = number of historical trading days to be considered i = Generator resources MQ = Meter Quantity To ensure that no line rentals are imputed to the customer BCQ when prices are administered. The proposed formula will correct double charging of line rental in the present computation and remove cross subsidy simply by netting out BCQ quantities from WESM Purchases. In effect, only WESM purchases will be charged line rentals and payments for BCQ quantities will be based on the respective contract prices of the load and Gencos. 2