20190524EIM Report.pdf

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May 24,2019
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Wash i ngton Street
Boise, ldaho 83702
Re Case No. IPC-E-16-19
Deferral and Recovery of Costs Associated with Participation in Energy
lmbalance Market - ldaho Power Company's Benefits and Costs of
Participation in the Energy lmbalance Market ("ElM') Report
Dear Ms. Hanian
ln compliance with Order No. 33706 issued in Case No. IPC-E-16-19, ldaho Power
Company ("ldaho Power" or "Company") hereby submits four (4) copies of its report of
the benefits and costs of participation in the EIM ("Report"). As discussed in the Report,
ldaho Power believes that the EIM has provided financial benefits to the Company and,
ultimately, its customers. However, ldaho Power believes that the California lndependent
System Operator's ("CA!SO') calculation of benefits for the Company is overstated. ln
the Report, ldaho Power presents its quantification of actua! EIM benefits and costs,
explains its methodology for determining EIM benefits, and discusses the adjustments
made to CAISO's calculations. The Report also describes the Company's ongoing efforts
to address issues and improve the methodology utilized in CAISO's quarterly benefit
reports.
lf you have any questions regarding this Report, please contact Senior Regulatory
Analyst Mark Annis at [phone] or [e-mail].
Sin
RECEIVED
l8lg t{AY ztt Pl{ trs lrlr
IilA:-IC PUBLIC
TILI.iIHS COMITISSION
An IDACORP Company
'1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON
Senior Counsel
[e-mail]
JAH:csb
Enclosures
cc: Service List - w/enc!
r
u lia A ilton
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of May 2019 I served a true and correct
copy of IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET REPORT OF
BENEFITS AND COSTS OF PARTICIPATION upon the following named parties by the
method indicated below, and addressed to the following:
Gommission Staff
KarlT. Klein
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W esl Washington Street (837 02)
P.O. Box 83720
Boise, ldaho 83720-007 4
Industrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
q req @ rich ardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Snake River Alliance
Holly Harris, Executive Director
Snake River Alliance
223 North 6th Street, Suite 317
P.O. Box 1731
Boise, ldaho 83701
ldaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North 6th Street
Boise, ldaho 83702
CERTIFICATE OF SERVICE
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email dahoconservati
Bearry al
IDAHO POWER COMPANY'S
ENERGY IMBALANCE MARKET REPORT
OF BENEFITS AND COSTS OF PARTICIPATION
May 24,2019
I. INTRODUCTION
On August 19, 2016, ldaho Power Company ("ldaho Power" or "Company") filed
an application, Case No. IPC-E-16-19, requesting that the ldaho Public Utilities
Commission ("Commission"): (1) acknowledge that Company participation in the Western
Energy !mbalance Market ('ElM') could net customers long-term benefits; (2) authorize a
deferral account to track incremental costs associated with participating in the EIM; and
(3) authorize the Company to recover those costs from customers in a future rate
proceeding.
The Western EIM is a five-minute market administered by a single market operator,
the California lndependent System Operator ("CAISO'), which uses an automatic
economic dispatch model to find and determine the least-cost energy resources to serve
real-time customer demand across a wide geographic area. The Western EIM focuses
solely on real-time imbalances and allows EIM entities to retain all balancing
responsibilities and transmission provider duties. !n addition, it uses generating
resources from market participants to meet real-time load efficiently and cost-effectively
across the entire Western EIM footprint.
ln Order No. 33706, the Commission concluded that the Company's participation
in the Western EIM would provide an opportunity for benefits greater than costs, thus a
possibility of a net benefit to the Company's customers. Additionally, the Commission
found that the Company joining the Western EIM was reasonable and in the public
interest.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 1
Order No. 33706 also required that after ldaho Power participated in the EIM for
one year, the Company file a report with the Commission describing the costs and
benefits of participation thus far and other relevant information. ldaho Power was directed
to include any available benefit and cost information in this report, including, but not
limited to, CAISO's quarterly quantifying EIM benefits reports. The Company was further
directed to work with Commission Staff to determine what information may be relevant
going forward.
Pursuant to Order No. 33706, ldaho Power previously provided the Commission
with the quarterly CAISO Western EIM Benefits Reports ("CAISO Report") forthe second,
third, and fourth quarters of 2018. The Company is filing the CAISO Report for the first
quarter of 2019 concurrently with this report, the "ldaho Power EIM Report."
ln compliance with Order No. 33706, ldaho Power submits this ldaho Power EIM
Report after its first year of participation in the market, detailing the costs incurred and
estimated benefits achieved in the first year of EIM participation. Within this ldaho Power
EIM Report, the Company presents its quantification of the benefits and costs of
participation and provides a discussion of its methodology for determining EIM benefits.
ldaho Power also discusses a recent issue related to a component of the CAISO EIM
benefit calculation that parties, including ldaho Power, are currently investigating, which
could have an impact on the benefit calculation.
!I. EIM BENEFITS
Every quarter CAISO prepares the CAISO Report, detailing the benefits received
by participants from their participation in the ElM. The underlying data used to develop
CAISO Reports provides a starting point for the Company's evaluation of the benefits of
participation in the ElM. As discussed in detail in this ldaho Power EIM Report, the
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 2
Company believes the CAISO Reports overstate EIM benefits for ldaho Power,
necessitating certain adjustments to develop an appropriate estimate of Company-
specific benefits.
Upon joining the ElM, ldaho Power began performing a detailed review of the
CAISO benefit calculation. The Company worked to develop a more precise benefit
quantification that uses inputs specific to ldaho Power. Idaho Power contracted with
Power Settlements, a software company that specializes in providing software solutions
to energy companies that participate in independent system operator and regional
transmission organization physical power markets. One of the benefits of Power
Settlements' software is the ability to shadow CAISO's benefit calculations, allowing ldaho
Power to better understand CAISO's methodology and identify any potential issues. The
shadow calculation validates the accuracy of CAISO's benefit calculation and identifies
any inconsistencies or data errors. Additionally, the shadow calculation allows ldaho
Power to run its own EIM benefit calculations using inputs and assumptions that are
specific to the Company, which more accurately quantifies benefits specific to ldaho
Power due to its participation in the Western ElM.
The quarterly CAISO Reports have reported annual EIM gross benefits of $35.3
million for the Company over its first year of participation, supporting ldaho Power's belief
that the Company and, ultimately, its customers have received benefits from the
Company's participation. However, while ldaho Power believes that its participation in
the EIM has provided financial benefits, the Company believes that CAISO's calculation
of benefits is overstated. This ldaho Power EIM Report describes several revisions to
CAISO's benefit methodology to provide a more accurate estimated gross benefit of $17.1
million during the first year of participation. Table 1 below summarizes the dollar values
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 3
of CAISO's benefits calculation and ldaho Power's revisions, which wi!! be discussed in
further detail in subsequent sections.
Table 1: Summary of Annual EIM Benefits and ustments
S 35,315,532
(5,183,399)
29,133,L33
(LL,074,t}4l
(970,359)
$ 17,08&570
Per the original CAISO Reports for 2nd quarter 2018, 3rd quarter 2018, 1st quarter 2019, and revised report for
4th quarter 2018.
A. Correction to GAISO Methodoloqv: Quarter 2 and Quarter 3 2018.
During the Company's review of CAISO's benefit calculation, Idaho Power
identified an issue with CAISO's counterfactual ('CF") methodology, which has resulted
in CAISO changing one of its assumptions in the benefit calculation for all participating
entities. The calculation of the CAISO EIM benefits used a CF methodology in which
dispatch for an EIM Balancing AuthorityArea ("BAA") mimics operations without importing
or exporting through EIM transfers. The CF dispatch moves units inside the BAA to meet
rea!-time imbalances based on economic merit order. CAISO's quantification of total
estimated EIM benefits is the cost savings of the EIM dispatch compared to the CF without
EIM dispatch. To determine CF costs, CAISO relies upon the bid stack submitted by each
EIM entity.
Upon receiving the CAISO Report for the fourth quarter of 2018, which included
an initial EIM benefit of $10.4 million for ldaho Power, the Company evaluated the CAISO
benefit calculation and determined that the CF methodology was excluding some
dispatchable lower-priced resources. The reason for this was that CAISO was using the
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 4
Benefits as reported on CAISO Reports *
Correction to CAISO methodology Q2 and Q3 2018
CAISO revised amount
Zero-priced hyd roelectric adj ustment
Third-party load adjustment
.
Net benefits - ldaho Power - April 2018-March 2019
transfer pricel as a floor. Only resources with dispatchable capacity at bids equal to or
higher than the transfer price were included in the CF calculation. Any resources with
dispatchable capacity at bids lower than the transfer price were excluded from the CF
calculation. In other words, the CF methodology was not using the least-cost available
resources and therefore was overstating CF cost savings and ultimately the EIM benefits.
CAISO agreed to correct this modeling assumption for all EIM entities going forward.
Additionally, CAISO agreed to re-run the fourth quarter benefits calculation for ldaho
Power, which resulted in a more accurate benefit amount of $5.8 million, a 44 percent
decrease from the initial estimate.
Because of the administrative work required, CAISO declined to re-run or re-
publish prior quarters' CAISO Reports for ldaho Power utilizing the corrected modeling
methodology. However, CAISO agreed to re-run one month from both the second and
third quarters of 2018 with the corrected modeling methodology:
. For the second quarter of 2018, CAISO re-ran its June benefits
calculation, which resulted in a reduction from the initial benefits estimate of $2.6 million
to $1.9 million, a 28 percent reduction.
o For the third quarter of 2018, CAISO re-ran its August benefits
calculation, which resulted in a reduction from the initial estimate of $6.4 million to $4.4
million, a 30 percent reduction.
To estimate corrected benefits for the remaining months of the second and third
quarters, the Company then applied the June and August percentage reductions to the
full second and third quarter CAISO-reported amounts, respectively. These revised
CAISO EIM benefit amounts were not published publicly but were provided to ldaho
1 The transfer price is the average price of transfers between the Company and adjacent EIM BAAs.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 5
Power for informational purposes. Table 2 below summarizes the adjustments made by
ldaho Power to the CA|SO-reported amounts.
Table 2: Summary of Quarterly CAISO Reports
CAISO Quarterly Reports
ldaho Power adjustment, based on
CAISO data
Adjusted CAISO Report methodology
s 7,750,000 s 13,305,275 s 5,815,3tr s 8,445,893 s 35,316,532
(2,I7O,8OO) (4,012,5991 (6,183,399)
s 5,579,200 5 9,292,676 s 5,815,364 s 8,445,893 s 29,133,133
B. ldaho Power Modelinq Adiustments.
!n addition to the methodology correction implemented by CAISO, two additional
adjustments are necessary in order to arrive at an accurate estimate of ldaho Power-
specific EIM benefits. These adjustments are related to (1) the appropriate application of
hydroelectric dispatch costs and (2) the existence of third-party loads within ldaho
Power's BAA. The following sections discusses each of these adjustments in detail.
1. Zero-PricedHvdroelectricAdiustment.
CAISO's CF dispatch cost is based on bid prices submitted for each participating
resource, which CAISO assumes is equal to the true dispatch cost, or the economic value,
of the resources. For most resource types, this assumption may be reasonable; however,
this assumption is not accurate for hydroelectric resources. Because hydro is essentially
a zero-variable dispatch cost resource, ldaho Power bids hydro resources based on an
operational value rather than dispatch cost. When ldaho Power operators move water
into the higher tiers, which have a higher bid price, it is a response to operational needs
and does not reflect market benefits. Without adjusting for these operating scenarios,
CAISO's CF dispatch results in a baseline that is inaccurate for reflecting cost savings of
participation in the market.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 6
Due to Federal Energy Regulatory Commission ("FERC") limitations on job duties
and information sharing between transmission and merchant groups within the Company,
ldaho Power implemented a system of hydro "tiers," both operational and pricing, for EIM
offers. Operational tiers are used by the Company's Load Serving Operations group
('LSO'), while the pricing components associated with each tier are established by the
Company's Power Supply Merchant group ("PSM"). The LSO determines available hydro
energy for various operating conditions and reservoir management requirements, which
is used by operators to allocate energy among the tiers. Based on this operational
information, the PSM develops and submits bids to the EIM market operator. ln other
words, the LSO communicates operational goals to the PSM and the PSM establishes
pricing based on these operational goals.
The LSO determines how much water should go into each tier considering multiple
system condition factors, including, but not limited to, how much the EIM has already
dispatched Company resources up or down in previous hours, whether ldaho Power's
system is surplus or deficit compared to what was planned on preschedule, and how
much flexibility the Company has to deviate from the daily targeted flows through the
Company's Hells Canyon Complex. Thus, the operational tiers reflect operational goals
and the amount of water that is available for each tier. Lower tiers generally reflect a
greater ability to move water and generate energy with less of an impact on future planned
operations.
The PSM establishes pricing tiers with the lowest tier having lower prices and
higher tiers having higher prices. Consistent with FERC's Standards of Conduct, the LSO
has no visibility or influence on the establishment of price, and the PSM has no visibility
or influence on the amount of water placed into each tier. The PSM establishes the prices
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 7
using seasonal values that include expected future energy for dispatch based on
minimum flow requirements.
To manage the varying system conditions and ensure that ldaho Power
appropriately manages its water, it is often necessary to allocate energy to higher tiers to
reduce volatility and maintain hydro flows within required ranges.2 As an example, if the
EIM has already increased generation significantly in previous hours, the Company may
have already increased its daily average flows by the amount permitted, resulting in the
need to allocate energy to higher tiers in future hours to prevent the flow of more water
than allowed during a particular time frame. There are also timing restrictions that impact
the allocation of hydro energy among operational tiers. For example, the Company
typically plans to operate its hydro generation resources in a manner that reserves water
for periods of the day when demand is at its highest. lf ldaho Power allocates too much
energy to a lower operationaltier and the EIM dispatches this energy over several hours,
then the Company may not have enough water to increase generation during a higher
load period and may have to purchase energy rather than relying on its own resources to
serve load.
For reasons such as these, ldaho Power LSO operators must carefully select the
operational tiers into which water is placed. When ldaho Power operators move water
into the higher tiers, it is a response to operational needs, which is not captured in the CF
calculation. But when operators place the water into higher tiers, a higher price is
assigned to the water when the bids are submitted to CAISO. As a result, the baseline
used to calculate savings does not reflect the Company's true dispatch costs and the
CAlSO-calculated benefits are overstated.
2 Requirements may include flood control obligations, fish flow obligations, etc.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 8
The Company has developed an alternate hydro pricing structure to CAISO's EIM
benefits calculation. Specifically, ldaho Power revised the inputs to the hydro bid tier
prices for the fourth quarter of 2018 in order to show a zero-dispatch cost for these
resources. The revised inputs were then used to recalculate the CF component of the
EIM benefit calculation. The Company believes this modified approach more
appropriately reflects actual savings achieved through participation of those units in the
EIM.
ln ldaho Power's shadow calculation, it replaced the tier prices reflected in
CAISO's benefit calculation for al! months of the fourth quarter with a zero cost. By doing
so, the revised EIM benefits were $2.5 million, which is a $3.3 million or 56 percent
reduction to CAISO's revised fourth quarter EIM benefit of $5.8 million.
For the first quarter of 2019, the Company continued to apply the alternate hydro
pricing structure methodology used in the fourth quarter of 2018. The revised EIM
benefits were $7.2 million, a $1.2 million or 15 percent reduction to CAISO's first quarter
EIM benefit of $8.4 million.
Because ldaho Power's trial period with Power Settlements began in mid-
September 2018, there is no bid data available to shadow CAISO's benefit calculation
prior to October 2018. As a result, ldaho Power could not input revised costs into the
shadow calculation to determine a revised benefit for the second or third quarter of 2018.
Because system conditions in the third quarter of 2018 were similar to conditions
in the fourth quarter, the Company applied the 56 percent reduction identified for the
fourth quarter to CAISO's benefit calculation for the third quarter. This resulted in a
revised third quarter EIM benefit estimate of $4.1 million, which is $5.2 million less than
CAISO's third quarter EIM benefit of $9.3 million.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION .9
For the second quarter of 2018, the Company applied a24 percent reduction factor
for replacing hydro bids in all tiers with zero prices. This resulted in a revised second
quarter EIM benefit estimate of $4.2 million, which is $1.4 million less than CAISO's
second quarter EIM benefit of $5.6 million. The 24 percent factor used to reduce the
second quarter of 2018 was based on first quarter 2019 data,3 which the Company
believes was similar in nature to the second quarter of 2018.
ln total, as shown in Table 1, the zero-priced hydroelectric adjustment was a
reduction of $11.1 million to the Company's estimate of EIM benefits.
2. Third-ParW Loads Adiustment.
The benefits reported by CAISO reflect a value for the entire BAA each month.
The Company has third-party load in its BAA, benefits for which are being included in
CAISO's reported benefits for ldaho Power. To better determine the benefits attributable
to ldaho Power, the Company designed a method to reflect the monthly EIM BAA benefits
based on a load ratio allocation between ldaho Power load and third-party customer loads
in the ldaho Power BAA.
The Company applied the monthly percentage of transmission load ratio share
attributable to its third-party load customers for April 2018 through February 2019. This
calculation determined that, on average, approximately 7.25 percent of the BAA load
relates to third parties. !n order to only include EIM benefits related to ldaho Power, the
Company's estimate of its EIM benefits was reduced by $t.0 million, which reflects 7.25
percent of the total BAA EIM benefits.
3 During February and March 2019, the electricity market experienced unusual price activity. For
that reason, the Company chose to exclude February and March 2019 actualdata from the factor used to
estimate the second quarter 2018 zero-price hydro adjustment. ldaho Power's adjustment to the hydro
pricing structure for January 2019 resulted in the 24 percent reduction factor.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 1O
3. Onsoinq CAISO Benefit lnitiative.
ldaho Power is concerned that the current EIM benefit calculation is further
overstated due to a recent initiative identified as part of the Real-Time Market Neutrality
Settlemenf /ssue Paper and Straw Proposal("lssue Paper") published by CAISO on April
25,2019. Real-Time Market Neutrality is settled in the Real-Time lmbalance Energy
Offset ("RTIEO') charge code for EIM entities. ln the lssue Paper, CAISO acknowledged
that the transfer in/out mechanism used to transfer market neutrality in and out of an EIM
BAA should be removed from the calculation of RTIEO. ln addition, CAISO
acknowledged that the value of transfers used to calculate market neutrality as part of
RTIEO was not valued correctly if the market transfer was between non-California BAAs
and they were not deemed delivered by CAISO (therefore receiving a greenhouse gas
("GHG") award).
Based on its analysis of the RTIEO account from April 2018 through March 2019,
ldaho Power believes that GHG revenue has been improperly charged back to the EIM
entity through the RTIEO account when it is transferring between an EIM entity that is not
a California BAA and has not been deemed delivered (received a GHG award) to
California. ldaho Power also agrees with CAISO that the transfer in/out adjustment
mechanism has incorrectly shifted RTIEO dollars between EIM entities, resulting in some
entities being overcharged and some undercharged.
Idaho Power submitted comments to CAISO on May 14,2019, and May 24,2019,
requesting that CAISO consider the current design of the RTIEO charge code and review
the current EIM benefit methodology to ensure that benefits have been properly adjusted
in the RTIEO account for the above concerns. Specifically, ldaho Power is concerned
that some GHG revenue and EIM transfer revenue has been nullified and paid out through
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 11
the RTIEO account. These transfers and adjustments are not taken into account in the
CAISO EIM benefit methodology, which would result in an overstatement of EIM benefits.
ldaho Power requested that CAISO review the financial impacts and the EIM benefits
over the past year to determine if an adjustment to the benefits calculation is warranted.
III. EIM COSTS
Order No. 33706 provided for recovery of EIM-related costs through the true-up
portion of the Company's Power Cost Adjustment ('PCA") mechanism. For the PCA,
Idaho Power calculated a monthly ldaho-jurisdiction EIM revenue requirement that
included recovery of ElM-related operating expenses as well as a return on and return of
EIM-related capital costs, as summarized in Table 3 below.
Table 3: ldaho Jurisdiction EIM Revenue ment
5 7s8,246
1,005,545
L,342,73L
S3,LO6,522
s 2,951,195
*
ldaholurisdiction amounts. ldaho represents over 95 percent of ldaho Power's total system.
EIM capital costs consist primarily of expenditures for software integration and
metering upgrades. The Company incurred total ldaho-jurisdiction capital costs of $7.8
million as of March 31,2019. The Company calculated a monthly return on net rate base
for these capital costs, using the overall rate of return authorized in its most recent ldaho
general rate case of 7.86 percent, to arrive at a required return of $0.8 million, grossed
up for income taxes, for the ldaho jurisdiction.
Annual depreciation and amortization expenses related to the EIM-related
capitalized costs totaled approximately $1.0 million for the ldaho jurisdiction.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION . 12
Return on EIM-related capital investments
Depreciation and amortization expense
Operating and maintenance expenses and other
Total
Total after 95 percent sharing
EIM-related operations and maintenance and other costs of approximately $1.3
million for the ldaho jurisdiction consist primarily of incremental service fees paid to
CAISO and to Open Access Technology lnternational, lnc., and for incremental internal
labor expenses.
Commission Staff reviewed these EIM-related costs as part of its audit of the
Company's 2019 PCA deferral entries in Case No. !PC-E-19-16.
IV. CONCLUSION
ldaho Power believes that participation in the Western EIM has provided financial
benefits to the Company and, ultimately, its customers. The analysis and investigation
described above-showing benefits of $17.1 million and ldaho-jurisdiction costs of $3.1
million during the first year of participation-validates that belief. While market conditions
and operating conditions will vary from year to year, the significant difference between
benefits and costs of participation provides the Company reasonable comfort that, absent
significant fluctuations in market conditions and operating costs, !daho Power's
participation in the Western EIM will continue to provide benefits into the future.
IDAHO POWER COMPANY'S ENERGY IMBALANCE MARKET
REPORT OF BENEFITS AND COSTS OF PARTICIPATION - 13