FERC Filings
RESPONSE OF ELECTRIC POWER SUPPLY ASSOCIATION AND ELCON TO ELECTRONIC SCHEDULING COLLABORATIVE-Docket No. RM-00-10-000
3. Proposed Action
In its filing, the ESC alerts the Commission that “[I]f consensus should not be possible on certain issues, then the ESC will describe those issues in the August filing and request that the Commission resolve them.” However, the industry, and competitive markets, can ill afford this wait-and-see approach. We urge the Commission to take immediate action to refocus this effort on the objectives it announced in the ANOPR and Order No. 2000. Rather than waiting for unlikely compromises on standardization to come out of the ESC, FERC could look to E-Scheduling solutions that already exist to establish uniform transmission and scheduling practices. We are aware of E-Scheduling tools available now or that will be available shortly that can provide
for the electronic infrastructure to provide for a seamless inter-RTO market. Certainly the vendors that are presently developing software for some individual RTOs could, if provided a forum, expand the scope of their effort and thereby help solve seams problems rather than exacerbate them.
At a minimum, immediate attention must be directed to the following requirements for seamless markets:
The ESC and its technical working group, the OASIS Standards Collaborative (OSC), are capable of meeting the challenge of meeting the technical requirements necessary to implement OASIS Phase II and E-Scheduling. The difficulty results from the decision to address the divergent needs of each RTO or transmission entity—with their own particular scheduling practices and needs—and allow that to dictate the process. These differences are driven by regional and market practices that have developed or are being developed to address distinct business initiatives.
The significance of this problem, and potential harm to competitive markets, cannot be overstated. On December 15, 2000, EPSA, ELCON, Enron Power Marketing, Inc., Reliant Energy Power Generation, Inc. and Dynegy Inc. formally petitioned the Commission to convene a technical conference to provide a more effective forum for addressing seams issues and interregional coordination under Function 8 of Order No. 2000. Electronic scheduling, communications protocols and business practices being developed under OASIS Phase II clearly intersect with, and presumably would be components of, RTO Function 8 compliance. Indeed, they represent potential solutions to the challenges of inter-regional coordination. Accordingly, we recommend that, in resolving the problems discussed herein, the Commission consider the benefits of addressing Function 8 and OASIS Phase II co-extensively in the context of a technical conference.