6.6. ERMUSR 01-11-2005 - Laserfiche WebLink

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In addition, some entities are discussing "buy in" to existing regional transmission networks. Such responsible and innovative approaches to securing adequate transfer capability should be supported arrd encouraged as viable alternatives to RTOs. FERC Enjoys Significant Authority to Address Remaining Discrimination under the Current Order No. 888 GATT Regime Under Order No. 838's GATT regime, FERC jurisdictional TOs are obligated to provide transmission service on anon-discriminatory basis. There are undoubtedly some instances where residual discrimination still exists. Such discrimination can be addressed effectively, without the complications that RTOs introduce, by focusing on clarifying and enforcing open access rules. With its shift in emphasis away from the Order No. 888 OAT'T FERC Should undertake ~ regime in favor of RTO activities, FERC has relegated improvements a ComprehenSlVe look to ir^s open access rules to case-by-case adjudication. FERC should at Ways ItS Open undertake a comprehensive look at wa)s its open access regime aCC@SS regime COUId could be improved through clearer Hiles or changes to improve be ImprOVed through efficiency.2~ For example, lack of clarity or specificity with respect to calculation and posting of A~°ailable Transmission Capacity ClearerruleSOrChangBS ("ATC') has led to concerns by some APPA members about t0 Improve efflClency. manipulation of ATC calculations. To date, FERC has chosen to address these issues primarily on a case-by-case basis, rather than making and enforcing rule changes to assure that calculations are auditable and transparent. Similarly, protocols for processing transmission reservation queues and procedures regarding the exercise of rollover rights could use a fresh look. (~oolnote continued fror7a ~ireaious gage) power utilities jointly o~~n u-ansmission networks in states such as Georgia, ?Llichigan, Indiana, and iVlinnesota. Iu Vermont, the bulk transmission system is jointly owned b}' rrr~rnicipal, cooperative, and investor-owned utilities through Vermont F..lectric Transmission Company. In Wisconsin, public power systems are permitted to invest up to their load ratio share in ATC. See n. 1? above. 23 FERC Cornrnissioner Joseph Kelliher has suggested that Fl?KC consider strengthening its Order No. 888 transmission rule, and that it review claims of discrimination under that regime. "With RTO llevelopment Stalled, FERC Shorild Beef Up Order 888, Kelliher Suggests," I~resideFERC, August 23, 2004, at 1; "Kelliher: Eliminate Flaws in Open-Access Rule," Electric PouierDail~~, Septernbcr 29, 2004, at 3. Restructuring at the Crossroads: FERC Electric Policy Reconsidered 23