FERC Filings

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

CONCLUSION

EPSA submits that the success of different transmission organizations in the competitive wholesale market depends on whether they have independent governance structures and adequately defined operational authority. Commission-approved governance structures that ensure the independence of RTOs and ITCs will facilitate market design decisions. Of course, final consideration of allocation of functions will depend greatly on the specific market design for a region.

EPSA believes that meeting the Commission’s goal of seamless, competitive electricity markets can best be achieved by RTOs that are market administrators and have responsibility for key market functions. ITCs should not have responsibility for functions that can, in essence, make them “markets within markets.” Those key functions that should rest with the RTO, not the ITC, are:

- Congestion management
- Ancillary services
- Security coordination
- Administration of balancing markets
- Tariff administration and design
- OASIS administration and calculation of Available Transmission Capacity (ATC) and Total Transmission Capacity (TTC)
- Regional transmission facility planning
- Independent market monitoring

While in some in some cases the RTO may coordinate with ITCs in the provision of these functions, EPSA submits that the details of any “sharing” must be well-defined and subject to careful scrutiny by the Commission.

March 12, 2002

Respectfully submitted,

/S/___________________________
Julie Simon, Vice President of Policy
Jack Cashin, Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
202-628-8200