re : rto week - - summary of day two morning panel rto week
day 3 - - october 17 , 2001
standardizing rto tariffs
the morning panel focused on which transmission services should be standardized in rto tariffs across an interconnection or the entire country . there were many diverse views on the panel , and the staff and commissioners were somewhat more engaged in this session .
the panelists were : ricky bittle , arkansas electric coop ; jim caldwell , american wind ; peter esposito , dynegy ; rory mcminn , new mexico psc ; glenn ross , dominion resources ; audrey zibelman , xcel energy .
general observations
this panel had a lot less agreement than the previous panels . dynegy opposes standardization of a transmission tariff and urges ferc to give strong guidance to stakeholders and then let the stakeholders work out the details of a new tariff . dominion advocates a more prescriptive approach by ferc , noting that stakeholders have been unable to reach agreement over the last five years . excel has it ' s own focus - they want to be an itc and want to provide many of the rto services without being an rto . the wind group is mostly concerned about the ability to provide generation on an " as available " basis . the commissioner from new mexico does not want standardization , does not want ferc stepping on the state ' s jurisdictional toes , and does not want new mexico ratepayers ' rates to go up . arkansas electric coop insists that spp transmission capacity is full , so if competitors want to move power through spp , new transmission must first be built .
i am somewhat concerned that some of the commissioners may believe that tariff standardization is not necessary . while the dynegy concept had merit at one time , it may be too late to rely on the stakeholder process to resolve issues , and it could take many months to go through the process , only to have ferc , in the end , decide the details anyway . we may want to submit comments on this issue to ferc at the conclusion of rto week .
what services should be standardized ?
overall , dynegy opposes standardizing tariffs but believes certain aspects of reservations should be standardized - - timing , confirmation processing , maintenance issues , bus names , ramping protocols , assumptions for atc calculations , posting times , bumping rules , and settlement time . with regard to congestion management , it should not be standardized between rtos .
xcel does not support a standardized tariff but urges ferc to standardize some issues such as cbm calculations , reserve obligations and load balancing and penalties . american wind says ferc must focus on having liquid spot markets in rtos and not worry about tariff standardization . dominion cautions ferc about dynegy ' s proposal to let the industry work out the details . he says this is what happened with order no . 2000 and the industry was unable to work it out .
should ferc retain cbm ?
ricky ( arkansas coop ) believes that the bigger the rto , the less important cbm is because the rto will have enough resources internally to effectuate reserve sharing . dynegy thinks cbm should be eliminated . dominion thinks cbm should be retained but the rules need to be changed . cbm should not be set for a year - it changes on a daily basis and this should be reflected . nor should cbm be standardized because needs vary region to region . however , because cbm is used for load , the cost of cbm should be allocated to load . all panelists agreed with the concept that if cbm is retained , load should be required to purchase it as a service provided under the tariff .
network versus point to point service
peter ( dynegy ) discussed the need to develop a new type of transmission service that combines the best features from network and point to point , similar to transportation service offered in gas - - firm and interruptible . peter suggests starting with the crt tariff proposed several years ago . glenn ( dominion ) thinks the crt is outdated and thinks we need a new type of service but agrees that it should combine the best elements of network and point to point .
should all transmission service be under the rto ' s tariff ?
most of the panelists said yes , all service should be under the tariff , but ricky bittle said there needs to be a transition period - minimum of 5 years , no more than 10 years . commissioner mcminn said no - he sees this as an infringement on the states ' jurisdiction .
what services need to be changed under a new rto tariff ?
jim ( wind ) believes that the imbalance provisions must be revised so as not to penalize " as available " resources . ricky thinks transmission expansion is the most important issue to address in a new tariff . xcel urges ferc to recognize the distinction between rtos and itcs and allow itcs to design and offer their own transmission tariffs .
ray alvarez will circulate a summary of the afternoon panel on cost allocation .
please let me know if you have any questions .
sarah
re : rto week - - summary of day two morning panel
rto week
day 3 - - october 17 , 2001
standardizing rto tariffs
the morning panel focused on which transmission services should be standardized in rto tariffs across an interconnection or the entire country . there were many diverse views on the panel , and the staff and commissioners were somewhat more engaged in this session .
the panelists were : ricky bittle , arkansas electric coop ; jim caldwell , american wind ; peter esposito , dynegy ; rory mcminn , new mexico psc ; glenn ross , dominion resources ; audrey zibelman , xcel energy .
general observations
this panel had a lot less agreement than the previous panels . dynegy opposes standardization of a transmission tariff and urges ferc to give strong guidance to stakeholders and then let the stakeholders work out the details of a new tariff . dominion advocates a more prescriptive approach by ferc , noting that stakeholders have been unable to reach agreement over the last five years . excel has it ' s own focus - they want to be an itc and want to provide many of the rto services without being an rto . the wind group is mostly concerned about the ability to provide generation on an " as available " basis . the commissioner from new mexico does not want standardization , does not want ferc stepping on the state ' s jurisdictional toes , and does not want new mexico ratepayers ' rates to go up . arkansas electric coop insists that spp transmission capacity is full , so if competitors want to move power through spp , new transmission must first be built .
i am somewhat concerned that some of the commissioners may believe that tariff standardization is not necessary . while the dynegy concept had merit at one time , it may be too late to rely on the stakeholder process to resolve issues , and it could take many months to go through the process , only to have ferc , in the end , decide the details anyway . we may want to submit comments on this issue to ferc at the conclusion of rto week .
what services should be standardized ?
overall , dynegy opposes standardizing tariffs but believes certain aspects of reservations should be standardized - - timing , confirmation processing , maintenance issues , bus names , ramping protocols , assumptions for atc calculations , posting times , bumping rules , and settlement time . with regard to congestion management , it should not be standardized between rtos .
xcel does not support a standardized tariff but urges ferc to standardize some issues such as cbm calculations , reserve obligations and load balancing and penalties . american wind says ferc must focus on having liquid spot markets in rtos and not worry about tariff standardization . dominion cautions ferc about dynegy ' s proposal to let the industry work out the details . he says this is what happened with order no . 2000 and the industry was unable to work it out .
should ferc retain cbm ?
ricky ( arkansas coop ) believes that the bigger the rto , the less important cbm is because the rto will have enough resources internally to effectuate reserve sharing . dynegy thinks cbm should be eliminated . dominion thinks cbm should be retained but the rules need to be changed . cbm should not be set for a year - it changes on a daily basis and this should be reflected . nor should cbm be standardized because needs vary region to region . however , because cbm is used for load , the cost of cbm should be allocated to load . all panelists agreed with the concept that if cbm is retained , load should be required to purchase it as a service provided under the tariff .
network versus point to point service
peter ( dynegy ) discussed the need to develop a new type of transmission service that combines the best features from network and point to point , similar to transportation service offered in gas - - firm and interruptible . peter suggests starting with the crt tariff proposed several years ago . glenn ( dominion ) thinks the crt is outdated and thinks we need a new type of service but agrees that it should combine the best elements of network and point to point .
should all transmission service be under the rto ' s tariff ?
most of the panelists said yes , all service should be under the tariff , but ricky bittle said there needs to be a transition period - minimum of 5 years , no more than 10 years . commissioner mcminn said no - he sees this as an infringement on the states ' jurisdiction .
what services need to be changed under a new rto tariff ?
jim ( wind ) believes that the imbalance provisions must be revised so as not to penalize " as available " resources . ricky thinks transmission expansion is the most important issue to address in a new tariff . xcel urges ferc to recognize the distinction between rtos and itcs and allow itcs to design and offer their own transmission tariffs .
ray alvarez will circulate a summary of the afternoon panel on cost allocation .
please let me know if you have any questions .
sarah