FERC Filings
RESPONSE OF ELECTRIC POWER SUPPLY ASSOCIATION AND ELCON TO ELECTRONIC SCHEDULING COLLABORATIVE-Docket No. RM-00-10-000
I. INTRODUCTION
The relationship between national, uniform standards for the reservation and scheduling of transmission capacity and effective competitive markets has been a consistent theme in Orders Nos. 888, 889 and 2000. Transactions in today’s markets often cross RTO boundaries; clearly, the protocols and practices governing activity involving multiple RTOs should promote, not hinder, such power flows. In the ANOPR, the Commission referred to Order No.2000 to emphasize the importance of standardizing transmission transactions as a means of minimizing costs and “permit[ting] customers to acquire expeditiously common services among RTOs.”
For that purpose, and to supplement the requirements set forth in Order No. 2000, the Commission intends to adopt by regulation communications protocols and standards for business practices to implement OASIS Phase II. Under the ESC’s informational filing, the industry “consensus” sought by the Commission amounts to a mutual recognition of disparate business practices employed by individual transmission systems and the expectation of accommodating a diversity of operational systems.
Additionally, the ANOPR expressly contemplates “standards to be fully implemented by December 15, 2001.” Under the ESC’s timetable, however, electronic scheduling would not be implemented until the fall, 2002. The ESC could produce E-scheduling Standards and Communication Protocols (S&CP) for
OASIS Phase II that all RTOs and transmission providers will be able to employ for interchange scheduling. This is problematic as we will explain later, however we wish to first stress our concern on the lack of consistent business practices across multiple RTOs. Without guidance and encouragement from the Commission on the development of compatible transmission and scheduling practices, the final OASIS II implementation may fail to promote “seamless” competitive market activity. The ESC appears confident that the technical specifications it is developing for an integrated communications infrastructure will successfully link RTOs.
<sup>“The implementation of OASIS Phase II will be based on open standards (meaning that interfaces will be clearly defined and non-proprietary). The ESC expects that those standards should enable RTOs to easily integrate with and expand upon existing systems, to the extent possible, and should be considered in the RTO systems under development. Existing RTO systems will bridge the gap between now and when OASIS Phase II is implemented. The open standards architecture of OASIS Phase II will mean that RTOs should be able to make significant use of their investment in existing systems.”</sup>
Unfortunately, however fine-tuned and integrated the computerized communication links become, the existence of incompatible business practices will present formidable obstacles to Function 8 compliance. It is apparent that transmission owners are looking “inward” in developing individual RTOs; therefore, their transmission and scheduling practices are primarily intended to facilitate intra-RTO markets.
Rather than provide details for interregional coordination in the initial RTO filings as Function 8 required, transmission owners have only recently begun to address the inter-RTO coordination of schedule timing requirements and congestion management systems. The OASIS Phase II development by the ESC is proceeding with the assumption that differences in these business practices will have to be recognized and that compromise and changes to individual RTO practices for the good of inter-RTO coordination is not a priority. In fact, the possible lack of consensus on scheduling practices is recognized in the ESC filing:
<sup>“Participants in the ESC come from different market segments, have different business objectives, and are at different stages of development of their systems. That diversity results in a slow and laborious process to build consensus. If 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. The time needed to resolve those issues may require adjustments to this schedule to incorporate any decisions into the final documents.”</sup>
FERC must reemphasize the need to address Order No. 2000’s Function 8 requirements and ensure RTOs will seek to resolve those differences now. A lack of compatible business practices threatens the viability of market transactions into, out of and through RTOs. Postponing Commission action until the ESC’s August filing creates a risk that activities relating to OASIS Phase II will actually disrupt RTO compliance with Function 8. Unless RTOs implementing diverse scheduling practices and systems for OASIS Phase II give immediate consideration to the requirements of Function 8, sunk costs and seams problems will continue.