FERC Filings

FERC RTO NOPR COMMENTS

Timing

Timing
With respect to certain of the seven minimum functions, the NOPR proposes additional time for RTOs to satisfy the Commission's requirements. For congestion management (Function 2), RTOs will have one year after start-up to implement the required function. For parallel path flows (Function 3), RTOs will have three years after start-up to implement the required function. For transmission planning and expansion (Function 7), RTOs will be required to develop a plan for meeting this function within three years of start-up. The Commission invites comments of these timetables.
EPSA has a fundamental concern with delaying the implementation of any of the required minimum functions. The NOPR does an excellent job detailing the residual discrimination and remaining market inefficiencies the NOPR is intended to remedy. To the extent these problems are having a direct and significant impact on market operations - and the experience to date is that the problems are hampering market developments - delay in implementing solutions is troubling. The problems the Commission intends these minimum functions to address are not new and the industry, in a variety of forums, has been confronting them for years. The Commission should require that the industry complete its efforts to resolve these issues as soon as possible. The operational deadline for RTOs set by the Commission is over two years away. Further delay would prolong these problems for additional years.
Extended time limits only encourage further debate and dialogue, without driving the industry towards acceptable resolutions. The Commission should require RTOs to implement all required functions by the December 15, 2001 operational deadline.