FERC Filings

RE: Docket No. PL01-5—Technical Conference on RTO Interregional Coordination Under Order No. 2000 (Function 8)

Filing-Part A

June 8, 2001

David P. Boergers
Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Dear Mr. Boergers:

EPSA would like to thank the Commission for granting the request for a technical conference to address the serious issues associated with the requirement in Function 8 of Order No. 2000 that RTOs coordinate reliability and market interface practices. EPSA members view the technical conference as an important opportunity to present views on ways the Commission can enhance timely and effective compliance with Function 8. The coordination of presently incompatible critical features in the developing RTOs’ systems is a matter of immediate concern to competitive power suppliers. Therefore, the parties listed below would appreciate the opportunity to speak at the June 19th Conference on RTO interregional coordination:

Peter Brown, Aquila Energy Marketing Corporation
Jim Stanton, Calpine Corporation
Harvey Reed, Constellation Power Source, Inc.
J. Jolly Hayden, Dynegy Inc.
Reem Fahey, Edison Mission Energy
William Roberts, Edison Mission Energy
Charles Yeung, Enron Corp.
Regina Corrado, Exelon Generation Company, LLC
Jeff Perry, Mirant Corp.
Joe DeVito, NRG Power Marketing, Inc.
Paul Savage, NRG Power Marketing, Inc.
Frank Cassidy, PSEG Power LLC
John Meyer, Reliant Energy
Robert O’Connell, The Williams Companies

Speakers summaries are attached.

In structuring the technical conference, EPSA urges the consideration of the following key issues:

The conference should challenge the rationale raised by numerous RTOs that internal development must precede coordination. In fact, FERC should direct all parties to simultaneously address system and market design and coordination to minimize, if not eliminate, potential seams problems;

The Commission should establish a standard format for RTOs to use in addressing seams and coordination issues, and establish a calendar with milestones and reporting obligations. In addition, FERC should clarify and confirm the precise seams issues the milestones should focus on; and

The conference should include an overview of the existing efforts to address seams issues (several EPSA members intend to provide information on this) and identify the potential FERC role to centralize and intensify this important work.

We look forward to working with you on this important event. If we can be of any assistance, please contact Mark Bennett at (202) 628-8200. Thank you for the opportunity for EPSA members to participate in this very important conference.

Sincerely,

Mark E. Bennett
Senior Manager of Policy