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NY ISO: Operates only in New York, but is fully FERGjurisdictional. New York City is a very <br />u ansmission-constrai~~ed area within the N'Y ISO, which requires substantial mitigation of the <br />NY ISO power markets. <br />~t PJM: Operates in all or parts of Delaware, Illinois, Kentucky, Maryland, Michigan, New Jersey, <br />North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of <br />® Columbia. PJM has a very large footprint, but faces substantial transmission constraints <br />between its eastern and western regions. American Electric Power and Allegheny Power have <br />both proposed to build substantial high voltage transmission projects from Western to <br />Eastern PJM that they assert will help to ease transmission congestion in tY~e region. <br />SPP: Operates in all or parts of Arkansas, Kansas, Louisiana, Mississippi, I~~lissouri, New <br />Alexico, Oklahoma and Texas. SPP has approached RTO formation and market <br />development on a slower and more conservative track than many other RTOs. It does not <br />operate LMP-based day-ahead and real-tune markets, but implemented areal-time energy <br />r1 imbalance market in February 2007. <br />I~ ' ' ' ' 1 1 <br />APPA members in RTO regions report substantial problems that impair their ability to <br />provide reasonably priced and reliable long-term service to their own electric consumers. <br />Among the problems they have experienced: <br />1 Exposure to very high spot market energy prices that are in many hours based on bids <br />® submitted by natural-gas or oil fired generation, when many power sellers in fact use other, <br />lower cost fuels. These high spot market prices in turn make power sellers unwilling to <br />enter into longer-term bilateral contracts with buyers at prices that reflect their own <br />production costs. <br />1 In RTO-administered electricity markets, prices are often volatile and unpredictable, even <br />in regions with longstanding markets. Some market participants, especially LSEs that need <br />electricity to serve end-use customers, have complained that volatile prices complicate their <br />operational and financial planning. As rate caps end and retail prices are deregulated in <br />many states, price volatility also exposes retail consumers to large financial burdens when <br />prices increase or unexpectedly spike at high levels. <br />1 RTO market mitigation and monitoring regimes that may not prevent the exercise of <br />generation market power by sellers and thus may fail to assure reasonable power prices. <br />1 Financial transmission rights (FTRs) that were designed to provide LSEs a hedge nn their <br />exposure to congestion costs by giving them an offsetting stream of dollars during the <br />hours when they must pay transmission congestion costs, but which often fail to provide <br />the needed level of protection from congestion charges. Until recently, these rights have <br />been exclusively short-term (no more than one year at a time). LSEs therefore had very <br />little certainty about their ability to manage congestion costs from one year to the next. <br />That uncertainty has biased LSE power supply planning toward correspondingly short-term <br />power supply arrangements (which limit an LSE's exposure to congestion costs, but may <br />force it to forgo the efficiencies and savings of longer-term arrangements). FERC has <br />developed rules under which RTOs are required to provide long-term financial rights, and <br />the subject RTOS are now filing their own long-term rights proposal. It remains to be seen <br />whether these longer term rights will in fact give LSEs a stable and useful hedge over long <br />time periods. <br />1 RTOs themselves do not have the ability to construct transmission facilities. Rather, they <br />must rely on their member transmission owners. Many of these transmission owners have <br />wWw.APPAnet.Org continued <br />r <br />15 <br />