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much more needs to be done. The Commission needs to vie~ti~ RTOs for <br />what they are-regional monopolies that it must vigorously regulate, not <br />regional extensions of the Commission itself. The FYA does not exempt <br />from regulation public utilities simply because they are I~fOs. <br />RTO Governance Must Be Made Accountable <br />To Electric Consumers' Interests <br />Four of the fi.-e current RTOs have independent and, in some cases, sell= <br />perpetuating boards. FERC's reason for requiring independent boards was <br />a good one: to avoid RTO governance structures that could be "captured" <br />by one or a few industry sectors, leading to bias in RTO operations and <br />transmission service provision. But AY PA members' experience with <br />independent RTO boards shows that there is a significant dog-onside as Drell. <br />First, independent RTO boards can lack direct accountabilit}' to the <br />industry participants in the KTO's region and to the electric consumers <br />the RTO ultimately serves. APPA members have seen RTO boards vote <br />to take actions that a eery substantial majority of industry stakeholders <br />in their own regions vehemently opposed. When such events occur <br />repeatedly, there is a loss of confidence in-and "buy in" to- <br />APPA nlenlbe~S have RTO actions b}' industry participants. This can be very damaging <br />..Sean RTC bOardS Vot@ t0 for the RTO itself in the long run. RTOs will only be able to <br />tak88ct100S that a Very operate effectively iF they are accountable and have the respect <br />SUbStantlal majority.Of `' of all industry participants that must deal with the RTC). "hhat <br />IndUStry~StakeholderS respect has to be gained and maintained through RTO board <br />10 their OWn re910nS and management accountability. <br />Vehemently Opposed. Second, some independent boards seem to rely to a very significant <br />degree upon RTO management and staff (who can also be <br />inexperienced). 'This can lead to insufficient oversight (in the cost area <br />discussed above, for example). Recent corporate governance scandals in <br />this and other industries point out the need to avoid boards that are too <br />dependent on management and staff, without independent knowledge <br />of what is happening "on the ground," both within their own RTO <br />organization and in the RTO's region. <br />This lack of RTO accountability to customers and stakeholders creates the <br />~~~idely held view that RTOs have only one dominant stakeholder-.FERC. <br />This perception is damaging to the credibility of both FERC and the <br />respective RTOs. To allay this problem, FERC and the RTOs must take <br />steps to promote an atmosphere of mutual respect and constructive <br />relations between RTOs and the industry participants that must deal <br />Restructuring at the Crossroads: FERC Electric Policy Reconsidered 17 <br />