FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN RESPONSE TO NOTICE INVITING COMMENTS ON SEAMS RESOLUTION UPDATE BY PJM INTERCONNECTION, L.L.C., NEW YORK INDEPENDENT SYSTEM OPERATOR, INC. AND ISO NEW ENGLAND, INC.
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However, much work remains to be done. Seams resolution is particularly important now given the stalled progress toward one RTO in the Northeast due to the withdrawal of the NERTO filing. Further, it is unclear whether the ISOs have sufficiently prioritized their work projects and established hard deadlines for their completion. Moreover, it remains imperative for the ISOs to increase stakeholder involvement and responsiveness to their concerns. Also, it remains unclear what market-related operational issues will be included in the final version of the SMD. The Commission will need to pay particular attention to those issues that fall outside the scope of the SMD to ensure that there are no outstanding issues, which are not standardized that could compromise inter-RTO market operations and inadvertently create or perpetuate seams.
The ultimate resolution of seams issues must involve coordinated reform of both tariffs and the market rules themselves to finally address scheduling and protocol differences. Accordingly, EPSA urges the Commission to require the ISOs to demonstrate that they are developing and implementing consistent and uniform products for the marketplace. Finally, the linkage of energy standards (with combined reliability and commercial dimensions) and regulatory policies relating to market operation and development is showcased in the ongoing effort being made to clarify the respective responsibilities of the two standard setting organizations — NERC and NAESB — and the ISOs themselves. This activity confirms that, ultimately, the Commission must take an active role in the standards development process to achieve the critical objectives of consistency, uniformity and liquidity for markets within and across RTO boundaries.