FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN RESPONSE TO NOTICE INVITING COMMENTS ON TIMELINE AND REPORT BY THE NORTHEAST INDEPENDENT SYSTEM OPERATORS ON SEAMS RESOLUTIONS
COMMENTS ON TIMELINE AND REPORT
EPSA welcomes the Northeast ISOs Timeline and Report, and appreciates the ISOs’ continuing effort to resolve these important issues. However, arriving nearly one year after the technical conference, the Report requires substantial clarification regarding, among other things, implementation deadlines, overlapping responsibilities among NERC, NAESB, the ISOs and the RTOs relating to standard market design (SMD), performance measurements and overall accountability. Especially important for the Commission to clarify is what market-related operational issues will fall outside the scope of the final version of SMD and how to ensure that the resolution of those outstanding issues will not compromise market operations.
EPSA urges the Commission to begin a more proactive approach to seams problems by taking this opportunity to transform the Timeline and Report into a more useful tool. In order to drive toward project completion and implementation, ISOs should be required to; (1) prioritize projects; (2) specify project start and completion dates and; (3) develop more definitive implementation timelines and reporting obligations back to the Commission. Additionally, stakeholders should have the opportunity to assess ISO/RTO staff performance, as well as the effectiveness of seams-related rules. To that end EPSA is providing a red-lined version of the Report with comments and questions on specific entries.
There are many categories of seams issues. Taking as an example the capacity requirement among the Northeast ISOs, the Report addresses the capacity requirement and claims that a May 2002 filing by the NYISO has resolved capacity-related seams issues. This is simply not the case, as shown by the working group document “Comparison of NYISO, ISO NE and PJM” recently presented to the Joint Capacity Adequacy Group which documents the variety of seams issues. In addition, this May 24, 2002 filing by the NYISO in Docket No. ER02-1900 may or may not resolve fundamental inter-ISO capacity transaction seams depending upon the answers to questions raised by interveners (such as whether the current PJM approach to firm transmission from the interface will continue to present a seams problem).
Also, EPSA notes that the nature, scope and details contained in the Timeline and Report raise questions regarding the respective roles to be played by the standard setting bodies, NERC and NAESB, and the ISOs themselves. In this connection, EPSA is concerned that there may be too many “cooks in the kitchen,” especially in light of the significant linkage and overlap between “core reliability” for which NERC is responsible, the “business practices” NAESB will develop and market operation measures ISOs/RTOs may adopt that affect seams issues. Accordingly, EPSA believes that by addressing the seams-related issues in its SMD, the Commission could substantially clarify the respective roles of these organizations. Ultimately, achieving the critical objectives of consistency, uniformity and liquidity for markets within and across geographic and RTO boundaries requires the Commission to take an active role and adopt a comprehensive approach to all market-related activities.