Letters to the Editor

Fortnightly Magazine - May 2008

PURPA Redirected

In light of your prescient Frontlines column, “PURPA Redirected(February 2008), I am curious of your insight. Is there a nexus between §571 of EISA and the demand response (DR) text in the pending FERC NOPR, RM07-19-000, “Wholesale Competition in Regions with Organized Electric Markets,” issued Feb. 22, 2008?

In your opinion, can these two efforts be tied together in a neat bow? If not, is there any straight line at all to be drawn between the Energy Independence and Security Act (EISA) language and this pending FERC docket?

My attention is drawn mostly to ¶¶94 to 96 of the FERC NOPR.

Ya’akov ben Moshe Aaron, Policy Analyst
(Employer’s name withheld at letter writer’s request.)

The author responds: After a brief look at the paragraphs identified, I’d say the answer is clearly yes, although FERC invokes EISA §529 rather than 571. That’s probably because this NOPR seems to more directly address the data gathering requirement of EISA §529 than it does the action plan mandate in 571. (Of course, the former probably serves the latter.)

Having said that, I suspect FERC would have issued this NOPR, or something like it, irrespective of EISA. Some of the commissioners, including the chairman, have expressed determination to exercise FERC’s interstate authority on DR-related issues. So FERC was heading this way in parallel with Congress, and in fact its policy support might have helped get the DR language into EISA in the first place. –MTB


MISO Modification

Mark Volpe’s recent column (“Potential AmerenUE Pull Out Problematic,” Fortnightly’s Spark, March 2008) needs some additional clarification and perspective.

The article uses the names AmerenUE and Ameren interchangeably, which serves to confuse an already complex issue. In point of fact AmerenUE, which operates in Missouri, is the only Ameren company that has provided the Midwest ISO with a notice of intent to leave. That’s important because, while a departure by AmerenUE would be significant, it wouldn’t be comparable to the departure of all Ameren companies, as the article implies.

The article doesn’t include the important fact that FERC ruled on the matter of revenue allocation on February 1 (which we understand may have taken place after the article was written). FERC ruled that the requested tariff revisions were necessary to ensure that Midwest ISO transmission owners receive revenues consistent with the post-transition revenue distribution methodology in Appendix C of the Transmission Owners Agreement (i.e., based on revenue requirement).

Finally, the Midwest ISO has and will continue to collaborate with Ameren, as we do with all of our stakeholders, to improve the reliability, efficiency and development of the Midwest wholesale electricity market.

Carl Dombek,
Manager, External Communications,
Midwest ISO

Editor’s Note: In response to Mr. Dombek’s letter, we’ve revised the March 2008 edition of Spark so Volpe’s article more accurately distinguishes AmerenUE from its parent company. Further, in this issue of Fortnightly, Guillermo Israilevich examines the subject of RTO members jumping ship. –MTB