Two obstacles must be overcome to achieve true competitive markets: reversal of the long-term underinvestment in transmission, and greater clarity in the legal and regulatory environments. How can...
the ISO with generators selling into the pool; and 2) a second, more accessible EIN linking the ISO with those buying from the pool. As Gaebe advised the FERC, "California will evidently have a different market structure from the rest of the country, starting in 1997."
That comment didn't sit well with Terry Callender, vice president for regulatory affairs at NGC Corp. (Natural Gas Clearinghouse/Electric Clearinghouse). During the Q&A session, he warned,
"Several weeks ago, we completed a trade where we moved offpeak power from the Los Angeles Department of Water & Power to Jacksonville, FL. That could not happen with different market structures."
Protocol is All
The National Rural Electric Cooperative Association (NRECA) put its finger on the larger problem in its comments in Docket No. RM95-9-000: "It is difficult to separate completely the issues raised in this docket and those raised in the open-access NOPR."
The NRECA comments also raised other nagging questions: "It is unclear to NRECA exactly which industry participants will be required to maintain RINs ¬ [Rural co-ops] can be the target of a [Federal Power Act] section 211 complaint, but many (in fact, most) of them do not operate their own control areas, do not do their own dispatching, and are surely not equipped to set up and operate a full-scale RIN."
Dave Nevius, from the North American Electric Reliability Council, added a slightly different spin: "Is RINs a scheduling system or just an information notice system?"
Surprisingly, some witnesses implied that industry structure might not matter at all. Most witnesses stressed that, to work properly, data networks must be adaptable to any industry structure. They suggested that the FERC mandate only two legal requirements: 1) transmission owners must establish elec-tronic bulletin boards (EBBs), and 2) those EBBs must employ a standard communications protocol. With those mandates, a multitude of private RINs vendors could step in and create a variety of applications and interfaces to interpret and translate utility-specific EBB data to user-friendly formats. Industry structure would be left to follow or get out of the way.
John Stojka, vice president and general manager of CPEXO, saw no confusion: "The Commission should not mandate RIN applications, their functions, or their characteristics, nor should [it] mandate who should develop RINs. RINs should be developed in response to the needs of a free market."
All of this leads to irony. Real-time access to electric transmission implies a specific, mandatory transport protocol for data exchange (em but that would oblige the FERC to regulate telecommunications and computer interfaces (em a task that lies well outside its expertise, but now forms a critical link in electric utility restructuring.
*Acronym Translation: Old terms(emConstruction Work in Progress; Allowance for Funds Used During Construction, New terms(emInter Control Center Communications Protocol; Transmission Control Protocol/Internet Protocol; Applications Program Interface; Available Transmission Capacity; First Contingency Total Transfer Capacity.
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