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Enron Mail |
Some things to consider --
A. Enron Response to Alliance Compliance Filing (pre-MISO/ARTO discussions) 1. Stakeholder Process a. Getting better, more meetings post EPSA letter 2. Day One Congestion Management (not much to discuss, already approved by FERC) 3. Key Issue - Many details left uncertain until ARTO filing 120 days prior to 12/15/01 RECOMMENDATION - Don't file right now. Talk with FERC staff about our Wish List for RTOs. Work through RTO process to implement. B. National Grid Operation of ARTO (Comments June 14/01) 1. Should Enron Oppose NG? Yes a. Unclear about how much control NG has in the process (complete tariff control?). b. There are issues about NG independence from market (NE and NY assets). No a. NG wants to be a Transco in the ultimate state. b. This is a mid-term solution that could work. c. If done right, better opportunity to deal with transmission issues than current structure. RECOMMENDATION - Enron should file comments on key open policy issues with for-profit Gridco model. We don't oppose, but we are concerned that controls must be in place to ensure well functioning markets. The Transco model is the best model for transmission operation. If this action by NG leads ultimately to a Transco, it is a good outcome. The operator of RTO tariff must be independent of all market players (NG owns generation and has distribution in New England). Transelect wrote "I believe quite strongly that FERC should deny this petition because the Grid is a significant owner of both distribution and generation assets in the Northeast (New England Electric and Niagara Mohawk). It is a very small step from this decision to one that would allow Southern to operate GridSouth, or one that would allow Entergy to operate the Florida RTO in exchange for FP&L operating the Entergy RTO. As a matter of National policy, transmission operators should be independent of either the wholesale or retail electric markets. As a business issue, many transmission owners are reluctant to divest of transmission because they retain hope that their transmission can be used to protect above market native generation. How would you like to try shipping power into the Northeast with the Grid, a major retail supplier and a significant generator, controlling access to the market?" We should make this argument very strongly. NG must have a plan to divest itself of the generation and distribution side of the business because NE and NY are economically viable markets impacted by the Alliance RTO. The Operator of RTO must have full authority to modify the tariff and operations of the RTO. The Transmission Providers should not be able to restrict or limit in any fashion the for-profit Gridco Operator beyond ensuring (1) technical proficency, (2) assets returned in reasonable manner, and (3) recovery of FERC approved revenue requirement.
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