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Comments on Regional State Committee Proposal

Comments on Regional State Committee Proposal. Mass Restructuring Roundtable June 18, 2004 Peter Zschokke National Grid VP, State Regulatory Policy, US Transmission. Benefits from RSC Formation.

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Comments on Regional State Committee Proposal

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  1. Comments on Regional State Committee Proposal Mass Restructuring Roundtable June 18, 2004 Peter Zschokke National Grid VP, State Regulatory Policy, US Transmission

  2. Benefits from RSC Formation • Organization to promote policy prescriptions favored by all/majority of States • Avenue to create better understanding of regional needs by the States • RSC filing stakes out a broad area for review • Siting?

  3. How can RSC be Heard? • RTO-New Englandfiling • Stakeholder Process before filing • Able to submit comments to an ISO/TO filing with deference provided by FERC to those comments • RSC right to have TOs submit alternative RSC proposal as part of TO regional cost allocation filing • Existing Tariffs and RTO Tariff • Able to file complaint that present tariff terms and rates are unjust and unreasonable (“206 rights”) • Deference provided by FERC

  4. The Difficult Part: 205 Rights I • RSC filing requests use of RTO/TO 205 rights • Is it necessary? • See prior slide • Is it legal? • RSC not a public utility • RTO-NE Order rejects request for broader RSC 205 rights • SPP RTO Order suggests that an RSC might require an RTO to make certain filings, but Commissioner Kelleher’s concurring opinion questions whether FERC has this authority

  5. The Difficult Part: 205 Rights II • What does it mean for RTO independence? • Would it allow RSC to file a change to rules that the RTO regards as necessary for markets? • NE RSC filing has a broad scope • Resource Adequacy, System Planning & “[changes] to implement any policies recommended by the NE RSC” • FERC denied request in original RTO approval

  6. Conclusion • Welcome the regional forum/dialogue • Encourage States to focus their efforts within the scope of the RSC • RSC has numerous avenues to be heard, with full understanding that FERC will give deference to their proposals • It is not necessary for RSC to use RTO/TO 205 rights to accomplish their objectives

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