FERC Filings
RESPONSE OF ELECTRIC POWER SUPPLY ASSOCIATION AND ELCON TO ELECTRONIC SCHEDULING COLLABORATIVE-Docket No. RM-00-10-000
II. BACKGROUND
In August, 2000, NERC invited EPSA, ELCON and several other trade associations to participate in the effort to develop an industry consensus filing in response to the ANOPR. In a letter dated September 7, 2000 (Attachment A), ELCON, EPSA, the American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA) responded by agreeing to support the NERC sponsored effort with several conditions outlined in that letter. At that time, we stressed the need to incorporate commercial views and the importance of meeting the February 15, 2001 deadline set forth in the ANOPR, and stated a fundamental concern: “we view timely implementation of OASIS Phase II as extremely important.”
In his reply, NERC president Michehl Gent expressed his view that the recently established Electronic Scheduling Task Force was the “proper group to respond to this ANOPR.” However, he indicated that the ESC would be open to all industry stakeholders; but as a practical matter, transmission operators and owners would have a voting advantage. Interestingly, in response to our point that, in addition to technical and regulatory issues, many commercial issues were central to the ANOPR’s objectives, Gent stated that all “[t]hose issues are key to
a reliable electric system and are not beyond NERC’s mission, and will be
addressed in NERC’s OASIS Phase II filing.”
While there is general agreement on many of the premises underlying the ESC’s Vision Statement and Functional Requirements Specifications, we are concerned that:
(1) the ESC’s proposed timeline will not meet the RTO start-up dates; and
(2) the ESC’s present course will result in a OASIS Phase II business practices and communications protocols that will not provide a seamless interface for the reservation and scheduling of transmission service into, out of and through RTOs.