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COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN RESPONSE TO NOTICE INVITING COMMENTS ON ALLOCATION OF REGIONAL TRANSMISSION ORGANIZATION (RTO) CHARACTERISTICS AND FUNCTIONS BETWEEN SEPARATE ORGANIZATIONS WITHIN AN RTO REGION

BACKGROUND

The Notice invited all interested persons to file comments on how the functions and characteristics specified in Order No. 2000 should be coordinated or shared within an RTO, if there is more than one transmission-owning entity in that RTO. The Commission also invited comments on the regional scope of functions and whether it would be more efficient from an engineering or economic perspective for certain functions to be administered over a broad region or a smaller region. Additionally, the Commission sought comment on whether it is appropriate to apportion functions based on whether they relate to operating and administering the transmission grid or operations and oversight of trading markets. Finally, input was sought on whether the business model or incentive structure was relevant to allocating functions.

The Commission provided a matrix that identifies elements of each of the eight functions, with options to check if the RTO should be solely responsible or if the element can be shared with an ITC, or if there another way the function can be allocated. EPSA appreciates the matrix, since it provided parameters around which EPSA could gain consensus from its members.

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