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2004 Activities

White Paper

 

“Effective Solutions for Getting Needed Transmission Built at Reasonable Cost” (TAPS, June 2004), takes an in-depth look at the reasons that transmission investment has been lagging in recent years, ways to increase transmission investment, and ways to pay for it.  It focuses on structural solutions (inclusive stand alone transmission companies and shared transmission systems) as well as regulatory tools. 

 

The White Paper was distributed to state regulators, Members of Congress, Administration officials and the media.  TAPS members have made presentations regarding the White Paper to various interested groups (ELCON, Energy Bar Association, Bond Market Association (Roy Thilly, WPPI); NARUC Electricity Committee (Duncan Kincheloe, MPUA)).

Legislation

 

The Energy Bill, which failed to pass the Senate, was a major focus of TAPS efforts this year.  We actively lobbied TAPS legislative priorities as Congressional leaders tried repeatedly, but to no avail, to pass, first, the conference report on H.R. 6 and, then, modified versions of the bill. 

 

Among the issues of key importance to TAPS were the Native Load/Service Obligation provision designed to protect existing transmission rights and the reliability title, which authorized enforceable, mandatory reliability standards. 

 

TAPS also continued to be a leader in an “Anti-Participant Funding” coalition of public and private utilities, large customers, independent transmission companies and others that opposed provisions that would mandate “one size fits all” formulas for pricing transmission upgrades and expansions.

 

NERC

 

TAPS continued to participate jointly with APPA in the NERC stakeholder group supporting legislation to create a self-regulating reliability organization under FERC supervision.  TAPS also actively participated at NERC in the development of the Version 0 NERC standards. 

 

DOE

 

September 20, 2004 TAPS Comments on Designation of National Interest Electric Transmission Bottlenecks, attaching White Paper

 

FERC 

 

Interim Generator Market Power Screens (AEP et al.); Conference on Supply Margin Assessment (PL02-8-000) 

  • January 15, 2004, Technical Conference on SMA (Jesse Tilton, ElectriCities appearing on behalf of TAPS/APPA)
  • February 4, 2004, TAPS/APPA Post-Technical Conference Comments
  • May 14, 2004, TAPS/APPA Request for Rehearing and Clarification
  • TAPS/APPA Intervention in pending petitions for review

Market-Based Rates for Public Utilities (RM04-7)

  • June 9, 2004 Technical Conference on Generation Market Power (Fred Bryant, FMPA, appears for TAPS)
  • June 30, 2004 TAPS/APPA Joint Comments
  • December 7, 2004 Technical Conference on Transmission Market Power (Anne Kimber, MMTG, appears for TAPS)

Market Behavior Rules (EL01-118)

  • TAPS/APPA Intervention in pending petitions for review

Compensation for Generating Units Subject to Local Market Power Mitigation In Bid-Based Markets (PL04-2-000); PJM Interconnection (EL03-236-000)

  • February 4, 2004 Technical Conference regarding general policy issues raised by adequacy of revenue recovery for generation located in load pockets (Roy Thilly, WPPI, appears for TAPS/APPA)
  • February 18, 2004, Roy Thilly submits letter on adverse competitive impacts of permissive spot market bid thresholds
  • June 7, 2004, APPA, NRECA, TAPS, TDU Systems, and Consumer Federation of America jointly request for rehearing of order in the PJM (not generic) docket that distinguished between “warranted” and “unwarranted” market power exercise and blamed load for load pocket problems

Solicitation Processes for Public Utilities/Acquisition and Disposition of Merchant Generations Assets by Public Utilities (PL04-6/PL04-9)

  • July 1, 2004 TAPS Comments, attaching the TAPS White Paper

Reporting Requirement for Changes in Status for Public Utilities with Market-Based Rate Authority

  • November 15, 2004 TAPS Comments

Electric Creditworthiness Standards (AD04-8-000)

  • July 14, 2004 Technical Conference (Raj Rao, IMPA, appears for TAPS)

Generator Interconnection Rulemaking (RM01-2/RM02-12)

  • Following up on TAPS August 25, 2003 Request for Rehearing of Order 2003, TAPS members (Gayle Mayo, IMPA; Ray Wahle, MRES; Bob Williams, FMPA) met with FERC Staff on February 4, 2004 to stress need for load specific deliverability, tied to long term transmission rights for network resources
  • April 5, 2004 TAPS Request for Rehearing of Order 2003-A

Interconnection for Wind Energy and Other Alternative Technologies (PL04-15) Assessing the State of Wind Energy in Wholesale Electric Markets (AD04-13)

  • November 1, 2004 TAPS Post Technical Conference Comments (in PL04-15)
  • November 12, 2004 TAPS Pre-Technical Conference Comments (in AD04-13)
  • December 1, 2004 Technical Conference in Denver (John Krajewski, MEAN, appears for TAPS)

Financial Reporting and Cost Accounting, Oversight and Recovery Practices for Regional Transmission Organizations and Independent System Operators, (RM04-12)

  • November 9, 2004 TAPS Comments

Reliability

  • TAPS participated (through Gayle Mayo, IMPA), in May 14, 2004 U.S-Canada Outage Power System Task Force Workshop, advocating enforceable standards