FERC Filings
RESPONSE OF ELECTRIC POWER SUPPLY ASSOCIATION AND ELCON TO ELECTRONIC SCHEDULING COLLABORATIVE-Docket No. RM-00-10-000
1. Implementation of OASIS Phase II Should Be Accelerated
The failure to implement OASIS Phase II, with coordinated and compatible business practices, by the RTO start-up dates, raises serious concerns. RTOs are considering, or have already undertaken, substantial investments in the construction of scheduling systems. Further, the ongoing development of business practices gives priority to accommodating the parochial needs and various models that exist across the country. These investments in, and development of, differing models for system operation threaten to undermine the Commission’s goal “to identify standardization issues before entities invest extensive capital in a system.”
These practices and computer systems to implement them will create sunk costs and further entrench entities from changing these practices in the future. Moreover, even well-functioning, integrated communication systems will be of little value if RTOs develop incompatible business practices. RTO implementation of scheduling and reservation systems will be much more expensive and difficult to unwind than the current OASIS Phase I and IA systems. The Phase I and IA systems are tariff-facilitating mechanisms that do not hinge on the functionality of generation and transmission scheduling and operating systems. The scope and pervasiveness of OASIS Phase II may require certain operators to either replace or implement new scheduling systems. If such changes are required, systems implemented to accommodate RTO implementation will at least require modification and at worst become expensive anachronisms with little or no use.