FERC Filings
RE: Docket No. PL01-5—Technical Conference on RTO Interregional Coordination Under Order No. 2000 (Function 8)
CHARLES YEUNG-ENRON CORP.
RTO development has focused on developing market models and transmission access tariffs within RTOs. Although the RTO Order No. 2000 Function 8 requirements for inter-regional coordination are essential in ensuring the viability of inter-regional markets, addressing and resolving seams issues has not been a high priority in RTO discussions to date.
RTO market models are varied and, as such, the business practices and data requirements by which market participants need to abide will also be varied from RTO to RTO. There are several RTO seams efforts underway, but from preliminary findings at the Electronic Scheduling Collaborative, these efforts have not been fruitful. Consequently, because resolution of the seams issues is not a high priority for the RTOs, the RTO internal structures that are being created do not address the seams issues efficiently. This has the potential effect of impeding the import and export of power into and out of an RTO. There is also concern that the RTO structures being created are limiting the ability for RTOs to change practices in the future that could better facilitate “seamless” scheduling of inter-regional market transactions.
FERC must ensure that RTOs place a high priority on facilitating “into” “out of” and “through” transactions, in addition to enabling internal market systems. The Commission must provide the incentives to RTO participants to address these seams issues now before new market structures are implemented that will potentially create balkanized markets. EPMI has specific proposals on ways for the RTOs to resolve certain seams issues and is prepared to discuss these proposals at the Technical Conference.