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Frequently Asked Questions - #55

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FAQ-55

A marketer is a Qualified Bidder in the BGS-RSCP Auction.  Before submitting the Part 2 Application, can this marketer ask the trading desk of a wholesaler, who is also a Qualified Bidder in the BGS-RSCP Auction, for quotes on energy blocks to be delivered to a particular zone?  Could these two Qualified Bidders, in good faith, make or uphold all the certifications in the Part 2 Application for the BGS-RSCP Auction?


It is possible for the marketer to ask for quotes in a way that avoids revealing confidential information relative to its bidding strategy or regarding the Auction Process so that it can make or uphold certifications in the Part 2 Application.  The marketer can ask for quotes for energy blocks only and the marketer can ask for quotes for multiple EDC zones rather than for a particular EDC.  Further, the marketer can take all due care in its contact with the trading desk not to state that it is a Qualified Bidder for the auction (which would reveal confidential information regarding the Auction Process) and not to otherwise reveal confidential information, relative to its bidding strategy or regarding the Auction Process.

The marketer's preference to serve one EDC over another is considered confidential information relative to the marketer's bidding strategy under the Association and Confidential Information Rules. The fact that the marketer asks for quotes for energy blocks for multiple EDC zones, regardless of its true preferences, means that the marketer will not reveal its preference for one EDC over another.  Energy is only one component of BGS-RSCP supply, and energy blocks are traded independently of the auction, so that obtaining quotes for energy blocks alone is unlikely to provide confidential information regarding the marketer’s or the wholesaler’s valuation of the auction product (see for instance, FAQ-50 for a discussion of transactions involving products other than energy blocks).  It is possible that both Qualified Bidders and entities that are not Qualified Bidders in the BGS-RSCP Auction may ask for these quotes to obtain information concerning current market prices.

Please note that if the precautions above are not followed, for example because the marketer makes the request in a way that reveals a preference for one EDC over another, the wholesaler, who is also a Qualified Bidder for the BGS-RSCP Auction, would be required to disclose that it had such knowledge regarding the marketer's bidding strategy in its Part 2 Application.  The marketer would have to disclose in its Part 2 Application that it had revealed such confidential information to another Qualified Bidder in the BGS-RSCP Auction.  The Auction Manager would consider these disclosures in assessing whether these entities can become Registered Bidders in the auction.



11/15/2021, in Association and Confidential Information Rules.

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