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with [here. RTO management and boards cannot be subsen~ient to <br />industry particip~mts, but the}' should not be. able to simply- ignore <br />them. FEKC must also take steps to vigorously regulate RTOs as the <br />regional monopolies they have become, to ensure that they meet their <br />responsibilities to industry' participants and electric consumers. <br />RTO Regions Should Make Sense from a <br />Commercial and Reliability Perspective <br />PERC should reject choices by TOs to join RTOs when such choices arc <br />likely to increase costs to public po~~~er systems and other market participants <br />or decrease reliability in the region. Iy~Iany r~PPA members have been <br />dismayed by the "crazy quilt" geographic configurations PP.RC has <br />approved for their RTOs. Rather than joining t}ie RTO that makes <br />Rather than joining the <br />RTO that makes the <br />mosf sense from a <br />market and reliability <br />perspective, some FERC- <br />jurisdictional TOs have <br />t d th <br />tl~~e most sense from a market. and reliability perspective, some <br />PERCjurisdicrional TOs hay°e insisted on joining those RTOs that <br />fit best ~~-ith their own corporate goals and philosophies, creating <br />jagged RTO-to-RTO "learns." These learns raise the costs of affected <br />RTOs and market participants, as they-~ have to make additional <br />business judgments and investments to compensate for less-than- <br />opti~nal regional configurations. <br />msis a on ~ammg ose <br />RTOS that fit best with worse }'et, such decisions can have a "ripple effect." For example, <br />their OWn Corporate Borne IOU transmission providers are no~~~ proposing to reform the <br />goals and phllOSOphIBS, horde°rs of their current Regional Reliability Councils to better tit <br />Creating jagged RTO-to- ~~ith the RTO membership decisions their various subsidiaries have <br />RTO "Seams." made. Reliability concerns should trump the corporate inter°ests of <br />individual R7'O members, not rice versa. <br />The Bottom .Line: RTOs Should Be a Boon to <br />Electric Consumers, Not a Drag on Them <br />Pot residential electric consumers, RTOs arc a pocketbook issue, <br />although rite vast majority of them do not realize it. Pot industrial and <br />commercial customers, RTO polio- is a vital economic issue that could <br />make the difference bet~~,een being profitable (thus staying in business), <br />and shutting do~ti~n operations or leaving the community. Reliable, <br />reasonably priced electric service is a national economic development <br />and jobs issue. APPt~ members in KTO regions are deeply concerned <br />about RTO cost and service issues because they directly impact the <br />economies of their local communities. <br />18 Restructuring at the Crossroads: FERC Electric Policy Reconsidered <br />