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September 20, 2001=20



Formation of Northeast RTO=20
Challenged by Structural, Governance Issues=20



By Will McNamara
Director, Electric Industry Analysis=20


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[News item from Reuters] An administrative law judge at the Federal Energy =
Regulatory Commission (FERC) released a blueprint to establish a single ele=
ctricity transmission system for 11 Northeastern states, possibly as early =
as the end of 2002, based on the existing PJM Interconnection model. Region=
al transmission organizations (RTOs) are a priority for FERC, which is look=
ing for ways to make the nation's patchwork transmission grid seamless in m=
oving power between regions. An RTO is a combination of individual transmis=
sion operations that combine their assets under a common roof. FERC Judge P=
eter Young wrote in a 27-page report that there were "difficult substantive=
issues" in the path of creating an RTO for the Northeast. Young has held s=
ecret talks with the parties since then to prepare a report and business pl=
an to FERC commissioners, who are expected to issue a decision by Nov. 1.=
=20

Analysis: The complications now surfacing with regard to the formation of a=
single RTO in the Northeast are rather symptomatic of larger problems that=
may continually arise as the consolidation among transmission entities acr=
oss the United States continues. The Northeast region includes three distin=
ct transmission entities-the New England Independent System Operator (ISO),=
the New York ISO and the Pennsylvania-New Jersey-Maryland (PJM) Interconne=
ction-all of which were operating as separate organizations until two month=
s ago when they were essentially ordered to conjoin by FERC. The Northeast =
region consists of 11 states and the District of Columbia, and combining th=
e various markets in the region would reportedly create the largest electri=
c power market in the world. Thus, if we look at the Northeast situation as=
a national template, conjoining the various RTOs across the country into f=
our large regional entities, per FERC's directive, may be an arduous task. =
In addition, consolidation could add multiple layers of bureaucracy to what=
is already an extremely complex sector of the energy industry.=20

For background, it is important to realize that the current challenges asso=
ciated with forming a single transmission entity stem from a FERC order rel=
eased last July ordering all of the existing RTOs in the country to explore=
consolidation. The contentious order, which has sparked intense controvers=
y among certain utilities and existing RTOs, literally lays out the bluepri=
nt for how FERC wants the nation's transmission systems to be constructed. =
FERC has clearly directed four regional systems (in the Northeast, Southeas=
t, Midwest, and West) although no reference was made to the Electric Reliab=
ility Council of Texas (ERCOT), which exists outside of FERC's jurisdiction=
and essentially operates as its own transmission island. The commission ha=
d previously set a deadline of Dec. 15, 2001, for RTOs to become functional=
, so most of the transmission entities impacted by the order were in the mi=
dst of formulating their operational plans when the order was issued on Jul=
y 11.=20

In the Northeast region, FERC directed that a new Northeast RTO would be cr=
eated for this region and would essentially follow the template that has be=
en established by the PJM Interconnection, which as noted operates the whol=
esale transmission market in Pennsylvania, New Jersey and Maryland. In fact=
, FERC has often commented that PJM represents the most successful RTO that=
has been formed in the United States to date. FERC has said that PJM shoul=
d serve as the platform (or starting point) for mediation talks in the Nort=
heast. Under FERC's new order, the existing New England and New York ISOs w=
ould be required to join PJM. From the time that FERC's order was first rel=
eased, I suspected that these two entities would resist FERC's mandate to j=
oin PJM, as they have previously stated that a substantial amount of time a=
nd money has already been spent on forming their ISO entities, and consolid=
ation could nullify those efforts.=20

It appears that my projections are now coming true. While sincere efforts a=
re being made to consolidate the three transmission entities in the Northea=
st, the parties involved are realizing that conjoining three large and sepa=
rate transmission organizations is a very complicated process. The main obs=
tacles seem to surround structural and governing issues, which I expect wil=
l also be stumbling blocks for RTOs in the other three regions of the count=
ry as they proceed with their own consolidation efforts.=20

Moving forward, I will attempt to shed some light on the "difficult substan=
tive issues" surrounding the Northeast RTO (in the words of the FERC admini=
strative law judge). As negotiations continue in this area, various stakeho=
lders have been involved in the discourse, including energy companies, fina=
ncial investors and companies that seek to be involved in the management of=
the transmission assets in the area (namely, National Grid). As noted, gov=
ernance of the Northeast RTO board is the "thorniest" issue of all, again i=
n the words of Judge Peter Young. There has been little doubt that FERC has=
routinely praised the model used by the PJM system and in fact clearly sta=
ted in its order that the New England and New York ISOs should adopt the PJ=
M model. Now, however, new FERC Chairman Pat Wood has acknowledged that the=
commission may have been in error to express such strong support for only =
one model out of three. Nevertheless, FERC already has rejected the request=
s of the New England and New York ISOs to maintain their status as free-sta=
nding entities.=20

For instance, on the issue of how the RTO will be governed, the New England=
ISO reportedly believes that all three regions should be equally represent=
ed to ensure that the unique needs of each are given fair consideration. In=
other words, the New England ISO has expressed concerns, which are reporte=
dly shared by the New York ISO as well, that all three of the Northeast's m=
ajor grid operators may not get equal billing in a future board of director=
s tapped to run the new network. One concession made along these lines is t=
hat FERC has allowed the New England ISO to continue developing the Standar=
d Market Design, or SMD, for New England. The SMD, based on the PJM Interco=
nnection's market design and rules, will provide critical market improvemen=
ts in advance of the single Northeast market.=20

The leader of the New York ISO echoed these concerns and reportedly stated =
that any missteps in the formation of the single Northeast RTO "could make =
California's energy woes look almost insignificant by comparison." Further,=
William Museler, the New York ISO's CEO, pointed out that the New York ISO=
represents the largest electricity market of the three by far (posting a m=
arket value for 2000 of $5.2 billion compared to $1.7 billion for PJM and $=
0.6 billion for ISO New England). However, Museler acknowledges that the Ne=
w England ISO and PJM have unique areas in which they lead the Northeast re=
gion. For example, PJM leads the region in total load served and ISO New En=
gland leads the region in the number of states represented.=20

The other issue that is complicating the formation of a single Northeast RT=
O is of a structural nature. Specifically, complex software is needed to se=
t up a single entity in the region (and in other regions that are presently=
attempting to conjoin various entities). In fact, the selection and instal=
lation of this software may actually delay the formation of the Northeast R=
TO until the fourth quarter of 2004, according to Judge Young. In addition,=
Young reportedly said the software and technology needed to set up an RTO =
to keep electricity smoothly moving throughout the Northeast will rank seco=
nd only to that used by the banking industry.=20

While much of the debate surrounding the formation of a single RTO in the N=
ortheast may seem like policy minutia, it does have a very critical impact =
on real-world operations in the region. The problem may be particularly acu=
te in New England, a region where deficiencies in the transmission system h=
ave already begun to cause reliability problems. As I've discussed in previ=
ous columns (see the 8/23/01 IssueAlert, available at "< www.scientech.com/=
rci, for more information) New England has maintained an adequate supply of=
power generation but is suffering from a strained transmission system. The=
six-state region of New England covers about 8,000 miles of high-voltage t=
ransmission lines. As a whole, the region is capable of generating about 26=
,000 MW of electricity, and during the heat wave of the last few weeks cons=
umption peaked at 25,102 MW, creating an extremely tight situation for util=
ities such as NStar.=20

Leaders at the New England ISO, for instance, have acknowledged that transm=
ission constraints in the region have caused inefficient operation. Without=
necessary upgrades to the system, they say, electricity transmission to ar=
eas of short supply could add $125 million to $600 million per year to the =
price of delivering power through the region from 2002 through 2006. Power =
outages that occurred in the Boston area this summer highlighted fundamenta=
l deficiencies in the region's transmission and distribution systems, the i=
mprovements for which are dependent on large sums of capital investment and=
a conducive political environment. The bottom line may be that, without a =
comprehensive and functioning RTO in the region, investments to upgrade the=
transmission system in the area may be delayed, exposing the region to fur=
ther reliability problems.=20

Moreover, the challenges associated with forming one RTO in the Northeast m=
ay support the argument against consolidating RTOs, which comes mostly from=
the existing transmission entities and utility owners who argue that milli=
ons of dollars in start-up costs and infrastructure investment will be lost=
if their independent systems are nullified. In addition, these entities ha=
ve a real problem with losing their current autonomy and independent contro=
l over their own transmission systems. Thus, the FERC order regarding conso=
lidation will continue to be challenged and its implementation may be a lon=
g and involved process.=20


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