053NPRR 03 Coral Power Comments 040207 by yuamI14H


									                                      NPRR Comments

NPRR                         NPRR
                 053               Creation of New Trading Hub at Venus
Number                       Title

Date                         April 2, 2007

                                     Submitter’s Information
Name                         Jeff Brown
E-mail Address               Jeff.A.Brown@Shell.com
Company                      Coral Power, LLC
Company Address              909 Fannin Street, Houston, TX 77010
Phone Number                 713-767-5317

                         ERCOT/Market Segment Impacts and Benefits

Assumptions      1

                                Impact Area                         Monetary Impact
 Market Cost     1

                                Impact Area                         Monetary Impact
Market Benefit   1

  Qualitative    1



    Coral objects to the creation of a new Hub that would include only the two Venus 345
    kV Electrical Buses for the following reasons:

    1. The North 345 kV Hub (North 345) already includes the two Venus Electrical Buses
    as two of 84 other Hub Buses; thus, we don’t need a new Hub at Venus:

       76 VENSW           345       1907 VENUS N         345        NORTH
       77 VENSW           345       1906 VENUS S         345        NORTH
    (from The ERCOT Nodal Protocols, Sec.

    053NPRR-03 Coral Power Comments 040207                                            Page 1 of 2
                                  NPRR Comments

2. The market has already addressed this issue concerning Venus and the North 345
kV Hub by including language in hundreds if not thousands of contracts and transaction
confirmations that specify that the “Delivery Point” shall be “the Hub that includes
Venus”, (which of course is the North 345 kV Hub). Thus we don’t need another Hub
that includes Venus.

3. Given that the market has already been transacting on the fact that Venus is part of
the North 345 kV Hub, creating yet another new Hub that also includes Venus, even as
Venus is still part of the North 345 kV Hub along with 82 other Hub Buses, is a bad idea
that will create confusion and numerous needless disputes in the market over the
identity of the actual delivery point.

4. The definition of a Hub Bus states that “A Hub Bus is an Electrical Bus or group of
Electrical Buses in one substation that is a single element of a Hub definition. This term
is used solely for calculating the prices of Hubs. The LMP of a Hub Bus is the simple
average of the LMPs assigned to each Electrical Bus in the Hub Bus” (ERCOT Nodal
Protocols, Sec. 3.5.2.). Because a Hub Bus is used for calculating the prices of Hubs, if
Venus is allowed to be in two different Hubs, each having a different price, the result will
cause a dispute with respect to nearly every contract and transaction entered into that
has referenced the Venus.
Coral Power recommends that this proposal not be approved by PRS or TPTF.

                      Revised Proposed Nodal Protocol Language

053NPRR-03 Coral Power Comments 040207                                             Page 2 of 2

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