FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON ADMINISTRATIVE LAW JUDGE MEDIATOR’S REPORT TO THE COMMISSION
Comments on Specific Features of the Report
As Judge Young’s description indicates, most of the Business Plan is intended to provide something of a procedural roadmap for future action on specific issue areas and “options” identified in the Mediation Report. However, the Mediation Report does address two substantive matters of critical
importance: market design and governance. How the Commission deals with these could have a profound effect on the effort to establish one RTO in the Northeast.
1.
Market Design
The questions and choices associated with market design are, in many critical ways, central to this process. How the Commission deals with this issue could have a significant effect on the rapid and effective development and implementation of a single energy market in the Northeast. As stated in the Report, Option 3-M “is the most aggressive market proposal…[that] far outstrips the other options in diversity and extent of stakeholder support.” Judge Young noted that support for Option 3-M is “extensive, broad-based…Its distinguishing feature is speed. Estimated time to complete RTO transition: 24 months.” Accordingly, EPSA urges the Commission to endorse the approach to market design contained in Option 3-M of the Business Plan.
2.
Governance
Governance was among the key issues on which Judge Young specifically sought Commission guidance. A board with the knowledge, authority and funding necessary to pursue market design and software development is critical. Among the factors relating to the choice of governance models, perhaps none is more important than which board composition will be best equipped to efficiently begin implementing the Commission favored PJM platform.
PJM indicates that to meet its November, 2003 (or earlier) target, it needs a predominant role and opportunity to lead the transition. EPSA urges the Commission to consider this factor and authorize a transition board in accordance with the post-mediation governance proposal set forth in Option 1-G of the Business Plan.