Credit Reforms Comments Template
Stakeholder Comments Template
Credit Reforms in Organized Wholesale Electric Markets
Submitted by
Company
Please fill in name and contact number of Please fill in here
specific person who can respond to any
questions on these comments.
Date Submitted
Please fill in here
This template has been created for submission of stakeholder comments on the credit reform
topics covered by FERC’s Order 741. Upon completion of this template, please email your
comments (as an attachment in MS Word format) to CreditPolicyComments@caiso.com by
close of business February 25th. All comments will be posted to CAISO’s Credit Policy
Stakeholder Process webpage at
http://www.caiso.com/docs/2003/04/21/2003042117001924814.html.
Please submit your comments to the following questions for each topic in the spaces indicated.
Ability to net market transactions
1. Assuming the NYISO motion is granted, how would the MISO approach affect
stakeholders?
(Submit Comments Here)
2. What if the Day Ahead and Real Time markets were considered separate (i.e. no netting
between them)?
(Submit Comments Here)
3. What if the NYISO motion were denied?
(Submit Comments Here)
4. Is there interest in pursuing a central counterparty approach, like PJM?
(Submit Comments Here)
5. Are there implementation challenges with either approach that would prevent
implementation by 10/1/2011?
(Submit Comments Here)
6. Are there alternatives to consider?
(Submit Comments Here)
Shortening the billing and payment cycle
7. What implications are there to the ISO adopting a payment cycle that
– Changes the current timeline of the Initial Statement from T+7B to T+3B?
– Bases the Initial Settlement Statement on estimated meter data thus resulting in
true-ups in the Recalculation Statement T+38B?
– Shortens the time in which an invoice payment is due from T+5B to T+2B?
(Submit Comments Here)
8. Are there alternative invoicing cycles the ISO can adopt that meets this requirement and
minimizes the impact to market participants?
(Submit Comments Here)
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9. What constraints exist, if any, for meeting a 10/1/2011 effective date for this directive?
(Submit Comments Here)
Minimum participation requirements
10. In general, do you believe the minimum standards, as presented, are reasonable and that
they address FERC’s concern that under-capitalized market participants or market
participants lacking adequate risk management procedures pose a significant risk to the
market?
(Submit Comments Here)
11. Are there specific criteria in any of the focus areas that the ISO should restate or
eliminate altogether?
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–
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Effective risk management procedures
Effective communications with the ISO (i.e., respond to ISO direction)
Adequate capitalization level
Customer in good standing with the ISO
(Submit Comments Here)
12. Are there additional criteria in any of the focus areas that the ISO should consider?
–
–
–
–
Effective risk management procedures
Effective communications with the ISO (i.e., respond to ISO direction)
Adequate capitalization level
Customer in good standing with the ISO
(Submit Comments Here)
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Material adverse change
13. Are the proposed enhancements to the ISO’s existing material adverse change provisions
reasonable?
(Submit Comments Here)
14. To address FERC’s desire for the ISOs to use forward-looking indicators as a means to
make an unsecured credit limit reduction or a collateral call in advance of an adverse
event, what specific forward-looking indicators would you request the ISO consider?
(Submit Comments Here)
Uniform applicability
15. Are there certain individual entities whose default would not disrupt the market?
(Submit Comments Here)
16. Are there certain entity types that should not be subject to the minimum participation
requirements?
(Submit Comments Here)
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