FERC Filings
RESPONSE OF ELECTRIC POWER SUPPLY ASSOCIATION AND ELCON TO ELECTRONIC SCHEDULING COLLABORATIVE-Docket No. RM-00-10-000
2. RTO “Self-Determination” Undermines the Development of Cohesive, Compatible Standards and Practices
Of greater concern is the present “self-deterministic” approach to developing interconnection-wide E-Scheduling business practices. Although an industry consensus-building approach has been successful in the OASIS Phase I and Phase IA processes, these were recognized as “short-term” solutions with limited scope and capability. We believe that OASIS Phase II must evolve beyond OASIS Phase I and IA, and be much more comprehensive in scope. Cohesive reservation and scheduling practices are critical to wholesale energy markets, as are common user interfaces for transmission customers. It is simply untenable and unrealistic to allow each RTO and transmission owner to negotiate a common form of scheduling practices, while contemporaneously adopting their own practices. Such an approach would, in all likelihood, create more coordination problems than it would solve, and highlights the disconnect between OASIS Phase II and Function 8.
In a concurring opinion to the ANOPR, then Commissioner Hebert expressed strong reservations about the need for OASIS Phase II, based upon the expectation that electronic communications standards would develop within the RTO formation process under Order No. 2000. He concluded his concurring opinion by requesting that parties commenting on the ANOPR discuss the concerns raised in his concurrence. We agree with Chairman Hebert’s view that electronic scheduling and communications are largely subsumed in Order No. 2000, and that RTOs must standardize and integrate market interface practices under Function 8.
Also, while we share the Chairman’s view that there are potential disadvantages and dangers associated with OASIS Phase II, we do so for different reasons. Function 8 unequivocally requires RTOs to “coordinate their practices with neighboring regions to ensure that market activity is not limited because of different regional practices.” We believe that along with the possible “distraction” from the goal of stand-alone transmission businesses, OASIS Phase II has diminished the attention paid to the need to standardize and coordinate business practices relating to transmission reservations, scheduling and other market interface requirements.
Most RTOs have already established business practices for reservation and scheduling, leaving inter-RTO seams coordination unresolved. There is little incentive through the process outlined in Order No. 2000 to address these seams issues. Nor has there been much, if any, consideration given to the overlap of
OASIS Phase II and Function 8. Instead, through the ESC process, RTOs have
managed to retain their scheduling systems and business practices. Indeed, this
has become an “objective” for the ESC.
In explaining the need to “accommodate regional diversity” in its Vision Statement, the ESC states that, while it may be “appropriate” to implement common business models, “[v]arious time frames, congestion management
schemes, ramping rules, ancillary services, and uses of resources must be allowed.” When describing Function 8, however, the Commission stated that: “[t]he integration of market interface practices involves developing some level of standardization of inter-regional market standards and practices, including the coordination and sharing of data necessary for calculation of TTC and ATC, transmission reservation practices, scheduling practices and congestion management procedures, as well as other market coordination requirements covered elsewhere in the Final Rule.” The ESC’s present course gives little assurance to transmission customers of resolving inter-RTO differences and largely ignores Function 8.