FERC Filings
EPSA Comments on GRSI NOI
Summary
The Electric Power Supply Association (EPSA) supports the Commission’s goal of preventing market abuses and discriminatory behavior. The Commission must balance, however, the achievement of this goal with the burden placed on market participants in order to provide voluminous amounts of information to the Commission and the concomitant burden on the Commission of processing such a significant amount of data.
Likewise, the potential for disclosure of sensitive business information must be considered. The competitive harm from disclosure of sensitive business information is real and significant. Data on the physical operations of a generating unit can be used by competitors to gain an unfair advantage. Knowing the timing and operating characteristics for one generating unit can determine how a competing generator will choose to operate its unit. Therefore, GRSI has the potential to be used by competitors to gain an unfair advantage.
EPSA is concerned that the NOI is not specific about how the defined GRSI will help the Commission to identify and end discriminatory market behaviors. Further, EPSA does not see the benefits of the Commission collecting GRSI from generators on a regular basis.
However, if the Commission believes it is necessary to go forward with the GRSI effort, EPSA submits that the Commission should try and achieve a balance between policy goals and data collection efforts. The Commission can adequately monitor generator run status and ensure against discrimination and market abuse by taking the following steps:
• Convene a technical conference to determine what GRSI information is currently available and how is it formatted.
• Form a template for GRSI data elements based on Regional Transmission Organizations (RTOs), Independent System Operators (ISOs) and market monitors’ current collection efforts in organized markets.
• A GRSI data template would be maintained by the market monitors for use in the organized markets.
• In non-organized markets, generators can use this template to maintain GRSI data.
• Develop information retention protocols so that market monitors and generators can maintain GRSI in a format that the Commission can rapidly retrieve, and utilize should it need to.
• The Commission should specify how the GRSI will be used to identify discriminatory market abuses.