FERC Filings
Motion of the Electric Power Supply Association for Leave to Intervene and Comment on the Midwest Independent System Operator's Open Access Transmission and Energy Markets Tariff Filing
Introduction
EPSA has vigorously supported the Commission’s effort to develop a seamless wholesale power marketplace through the establishment of Regional Transmission Organizations (RTO’s) whose boundaries mirror prevailing operational and trading patterns. In its February 24, 2003 (February 24 Order), the Commission endorsed the general direction of the MISO’s proposed market rules. The Commission stated that it “believes this filing represents an important first step in moving to functional competitive bulk power markets in the Midwest.” The Commission also concluded that there is “no substantial benefit to delaying the progress and momentum already in motion for establishing market rules that we believe will enhance competition and reliability in the very near term for the Midwest.” EPSA agrees, and urges the Commission to provide the approvals necessary for the Energy Markets Tariff to become effective on March 31, 2004, as the MISO has requested.
However, certain critical aspects of the Energy Market Tariff raise concerns and warrant close Commission scrutiny, direction and, in several instances, revision. The Commission could help ensure the MISO’s ultimate success by providing strong guidance and direction on certain open issues, including:
• MISO’s authority over multiple control areas vis-à-vis short term reliability and security coordination and the need for a definitive plan for control area consolidation by a date certain;
• Delaying centralized procurement of ancillary services until 2005;
• The use of System Support Resources (SSR) in MISO’s Energy Market construct;
• Implementing resource adequacy provisions;
• Avoiding overdependence on the Reliability Assessment Commitment (RAC) process;
• The time for bid submissions; and
• The need for detailed confidentiality procedures to ensure that market participants are protected by allowing only those with a legitimate need to have access to commercially sensitive information.