6.6. ERMUSR 01-11-2005 - Laserfiche WebLink

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to dedicate scarce personnel resources to unraveling incomprehensible (and often erroneous) billings and settlement statements received from their RTOs.~6 Corrected statements can come months, if not years, after the period in duestion, disturbing accounting periods that have already been closed and upsetting the economics of deals ah~eady done. Outside counsel and consultants must be retained at considerable expense, simply to keep track of RTO collaborative processes and tariff rnodifications.t~ Even APPA members not participating in KTOs are finding that 1~ZT0 cost adders are being lad-erect on top of their existing transmission see vice agreements with TOs that do participate in KTOs. These costs can be substantial.is Difficult "scams" issues can also arise, when RTO operating protocols do not conform to the uniform operating practices used by neighboring control areas within the region that have not. established RTOs. APPA members are also concerned that RTO market mitigation and monitoring regimes are insufficient to prevent the exercise of generation market powf:r and thus to asst re just and reasonable poi-rer prices. The theory underpinning LIy7P markets calls for sellers into the R~),O's (footnote rontznucd from ~~~~evious pcrgE;i additional X14.4 million (plus carrying charges) that Dominion spent on the defunct Alliance RTO proposal Dominion also expects to incur X241 million in PJI\i adrninistr;ttive charges on behalf of its retail customers during the first five years of membership. See, Pf~'I1lralerronnection, L.I.G. and Virg nia ~~lerhic a7ad Pozuer Co., 109 FERC ~[ 61,012 at P 47, n. 4G, issued October 5, 2001, available at: htt %w~~~~.ferc.g_ov; EvcntCalendar/Files/20041005132245- I-:R04-829-OOO.pol. ~~' For example, the CAISO has over 100 charge u~pes, ~~~~hich greatly add to the conrplexiry and costs of administering billings and settlements. See, CAISO Settlernent_Charge Matrix 17.x1s, Effecti~~e: Trade Date 10/1/2004. 17 See, Letter dated September 9, 2004, from Marc S. Gerken, President and CEO of A~1P-Ohio, Inc., to FI?RC Chairman Pat y~'ood, available at: htt /ferris.ferc.gov:0/idmws/file list.asp?docurrient id=4238777 (describing increased costs A1~iP-Ohio has incurred due to implementation of RTOs, including payTnent of $j5.9 million annually in RTO administrative costs); Letter Response of FERC Chairman Pat ~~1'ood to :Marc S. Gerken, dated October 14, 2004, and filed in FERC Docket No. R~IO~k-12-000 (Document Accession No. 20041022-0037) . 1H For example, the Los Angeles Department oC~~Vater and Power estimates that it is being charged approximately ~b12 million per year in GAISO-related pass- through charges for sen~ice under its existing transmission agreements within the CAISO control area. Restructuring at the Crossroads: FERC Electric Policy Reconsidered 15