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Generator/Supplier Perspective on the Proposed New England RTO. Peter D. Fuller Mirant October 24, 2003. Generators and Suppliers Support:. A permanent, independent system operator Meeting Order 2000 Characteristics and with full and exclusive authority over Order 2000 functions
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Generator/Supplier Perspectiveon the Proposed New England RTO Peter D. Fuller Mirant October 24, 2003
Generators and Suppliers Support: • A permanent, independent system operator • Meeting Order 2000 Characteristics and with full and exclusive authority over Order 2000 functions • Responsible for market and tariff design • Independent of Market Interests • Accountable to stakeholders
Regional Transmission Organizations that span historical regional market boundaries • Mission to design and administer efficient and sustainable markets
Independence • TOA compromises ISO’s independence and authority on market and tariff design (rate design, cost allocation, generator interconnection) • TOA compromises ISO’s independence on operational control (outage scheduling and coordination) • Governance compromises ISO’s independence on market design (“jump ball”)
Other Issues • Separate billing will increase overall costs • ITC functions are hard-wired and become even firmer over time • TOA and OATT are under separate control and separate standards at FERC; divergence is all but inevitable
Other Issues, continued • Tariff and Market Participant Service Agreement do not advance the efficiency or sustainability of the market design • Proposal is limited to New England only
Way Forward • NEPOOL has rejected the proposal • NEPOOL has recommended FERC mediation/settlement • To succeed, an RTO proposal needs stakeholder support