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Why My Tariff is Different Than Yours: Comparing Nonprice Terms in Utility Filings Against FERC's Pro Forma Tariffs

Fortnightly Magazine - May 1 1996

period can exceed 30 days. Nonfirm service is subject to interruption or curtailment at the transmitting utility's discretion.

Network Service. Network service permits transmission customers to designate a group of generation resources to service their load in a transmitting utility's control area (em much as a transmitting utility uses its system to serve native-load customers. Network service has the same priority as the transmitting utility's native load as well as priority over all nonfirm uses by the transmitting utility or third parties. Subject to availability, network transmission customers may also receive service from non-networked resources. Such service will be considered nonfirm, but will enjoy a higher curtailment priority than other nonfirm, point-to-point service.

Network transmission customers must operate as a control area or contract with a transmitting utility or other entity to act as a control area, subject to good utility practice and the requirements of the North American Electric Reliability Council. Network transmission customers must also agree to "reciprocity" (em that is, they must provide comparable transmission service to their transmission provider, including redispatch of resources, if necessary.

Ancillary Services. Point-to-point and network service include six ancillary services: loss compensation, load following, system protection, energy imbalance, reactive power and voltage control, and scheduling and dispatch. The FERC requires transmitting utilities, if they are able, to make these services available to transmission customers, subject to "good utility practice."

Key Differences

in Utility Tariffs

The tariffs discussed below have been approved and are available to transmission customers, though the FERC may set the rates for hearing (and transmission customers may get refunds if the FERC eventually adjusts the rates). However, the FERC has deferred consideration of all nonrate terms and conditions identified in the Table for generic resolution in the final open-access rule.

Not Subject to Tariff Terms and Conditions. A key element of the NOPR, and of comparability itself, is that transmitting utilities must take transmission service under their own tariff to ensure that all parties are receiving the same service and the same terms and conditions. The tariffs submitted by Northeast Utilities and Florida Power do not follow this policy, and Nevada Power exempts the utility's own transactions from the terms and conditions of its tariff. The tariff of Jersey Central Power & Light, Metropolitan Edison, and Pennsylvania Electric (em all subsidiaries of General Public Utilities (GPU) (em only covers offsystem sales under new contracts.

Missing Tariffs. The FERC's final goal envisions two transmission tariffs on file for each utility: 1) firm and nonfirm point-to-point transmission, and 2) network transmission. GPU did not file a network tariff; Southwestern Public Service did not submit a flexible point-to-point tariff; Commonwealth Electric did not include a nonfirm point-to-point tariff.

Limited or Restricted Ancillary Services. Transmitting utilities must offer the six types of ancillary services (see above), but the NOPR also permits wholesale customers to provide their own services or purchase them from third parties. Citizens Utilities says it cannot offer ancillary services because it is a small utility that purchases ancillary services from the New England Power Pool (NEPOOL). Commonwealth Edison claims that spinning