FERC Filings
RESPONSE OF ELECTRIC POWER SUPPLY ASSOCIATION AND ELCON TO ELECTRONIC SCHEDULING COLLABORATIVE-Docket No. RM-00-10-000
IV. CONCLUSION
The electric industry is at a juncture similar to the challenges of the natural gas industry after the implementation of Orders 436 and 636. Natural gas pipelines operated disjointed electronic bulletin boards (EBBs) that varied in “look and feel” and lacked common business practices. This created a severe impediment to a seamless pipeline grid and a competitive natural gas market. FERC’s mandate in Order 587 established standard procedures and provided common business practices that promoted competition in the natural gas industry.
However, this entire process took over a decade to play out. Had effective pipeline collaboration (then through the Gas Industry Standards Board) occurred earlier in the process, the industry could have avoided the expense of shifting from proprietary EBBs to those with a more common look and feel. We hope that the OASIS Phase II process does not lead to similar inefficiencies in the wholesale electric industry.
The approach to E-Scheduling that the ESC proposes will be inadequate to address the needs of the marketplace, burdening transmission customers with the job of reconciling the differences in scheduling and other requirements that individual RTOs will put in place. To ensure that the goals of Order No. 2000, and Function 8 in particular, for seamless RTOs are achieved, FERC could direct that the business practices component of OASIS Phase II be unified with the coordination requirements set forth in Function 8.
We urge the Commission to reach beyond the ESC’s proposed approach by refocusing the process to create more opportunities for technology providers to develop truly inter-regional solutions now. Accordingly, we ask that FERC consider the following next steps:
a) direct the ESC to revise their current approach and focus on getting all RTOs to develop compatible scheduling practices rather than accommodate the piecemeal systems developed within individual RTOs;
b) ask the industry for other solutions that can be implemented in conjunction with the scheduled RTO start-up on December 15, 2001 to avoid the entrenchment of diverse RTO scheduling and reservation systems; and
c) include the ESC in a technical conference addressing interregional coordination issues under Function 8.
Respectfully submitted,
Dated: February 20, 2001
Mark E. Bennett, Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 H Street, Suite 760
Washington, D.C. 20005
(202) 789-7200
John A. Anderson, Executive Director
ELECTRICITY CONSUMERS RESOURCE COUNCIL
1333 H Street, N.W.
8th Floor, West Tower
Washington, D.C. 20005
(202) 682-1390