FERC Filings

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

ROBERT O’CONNELL-THE WILLIAMS COMPANIES

“Open Architecture” Feature of the Commission’s RTO Initiative – Unintended Consequences

While a Necessity from a Limited Statutory Perspective – It:

Overestimated Willingness of Industry to Embrace the Commission’s Initiative.

Has Resulted in a Mosaic of Operationally Incompatible, Non-Regional Transmission Organizations Especially with Respect to Reliability & Market Interface Practices (“Seams”). Examples:

Inability to Transact Capacity Across ISO/RTO Boundaries in the Northeast;

Diverse Settlement Process Software (PJM Software Available/Benefits);

Incompatible ATC Calculations & Congestion Management Approaches (Alliance RTO and PJM & PJM West; Entergy and SPP);

Unnecessary Disparate Transmission Rate Treatment (Flows Originating in SPP with MISO or Alliance Sinks);

Inconsistency in Interconnect Studies Related to New Generation

Seams Issues, if Unresolved, Will Lead to Further Supply/Demand Imbalances That Will Invoke Calls for Price Controls/Caps and Jeopardize the December 15, 2001 Operational Deadline for RTOs.

Optimal Remedy:

Commission Should Reconsider its Position of Not Electing to Exercise its FPA §202(a) Authority to Designate National Regional Districts.

Strongly Encourage, Not Mandate, the Industry to Adopt Standardized Reliability & Market Interface Protocols to Resolve/Mitigate Seams Issues.

Industry-Driven Standardized Protocols to Resolve/Mitigate Seams Issues Should Address:

Integration of Public Power Entities

Scheduling

Transmission Pricing & Rate Reciprocity

Compatible Ancillary Services Standards

Standardized Market Interface Protocols with

Respect to Congestion Management, ATC

Calculations, FTR Allocations and Auctions,

Generation Interconnections and Emergency
Procedures

Capacity Transactions Across ISO/RTO Boundaries

Uniform Standards and Practices for Monitoring Market Participant Activity