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Public Power Views on <br />Federal Restructuring Policies <br />Federal Transmission Policy Must <br />Accommodate Regional Diversity <br />As previously noted, the country has live up-and-running FERC jurisdictional <br />RTOs. It does nor appear likely that RTOs ~~~ill form in the rest of the country <br />(with the possible exception of the SPP region). Lven if it were politicall>~ <br />possible to export nc~ current IZIO model to those regions that do nor have <br />P."hOs now (~~~hic}1 iris not), the experience ro date of those <br /> ~~PP~~ mcmhers located in RTO regions does nor support such a <br />Even if it were politically . <br />course. In fact, given the considerable differences that exist in <br />possible t0 export the the various regions of the country, it should nor be assumed that <br />current RTO model t0 those RTOs arc tl~le only, or even the preferred, mechanism available <br />regions that d0 not have to ensure competitive wholesale po~,~er markets. <br />RTOs now (which it is not), <br />the experience t0 date ~~PPA rnembcrs located ill RTO regions report substantial, <br />Of those APPA members across-the-board problems ~,~it1i spiraling KZ'O costs, <br />located In RTO regions does rznaccountablc governance, lack of understanding of <br />not Support SUCK a COUI'Se. transmission customer and end-user needs and less-than- <br /> satisfactory service options. They see more and more RTC) <br /> services being provided through duestionable market <br />mechan isms, and RTO resistance to any tluestioning of the economic <br />theories underpinning these actions. <br />The rcrnaining non-RTO regions are vet}~ different both from each other <br />and from the regions ~~~hcre RTOs have already been created. Some <br />regions have a history of using contractual an-angements and regional <br />institutions or practices to capture mama of the benef7ts claimed for RTOs <br />at less risk and cost, and have sho~~~n a wil-ingness to pursue alternatives <br />to enhance transmission access and the efficiency of existing markets. <br />Othier differences include the prevalence oljointl}' o~~'ned generation and <br />transmission, the radial nature of transmission s}stems connecting remote <br />generation to loads, the predominance of hydropower in the generation <br />rnix, differences in population density, the extent to which open region-wide <br />planning processes arc used, the existence of a frame~~~ork for enforcement <br />of reliability standards by contract, the extent to ~,hich a standard Dorm <br />of contracting is used for bilateral transactions, the existence of active <br />~n,holesale market hubs accessible to many market participants, the presence <br />or absence of a few large dominant IOU transmission providers, existence of <br />6 Restructuring at the Crossroads' FERC Electric Policy Reconsidered <br />