Transmission Access Policy Study Group
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2005 Activities

Legislation

 

The Energy Policy Act of 2005, which was enacted into law this summer, was a major focus of TAPS efforts this year.  We actively lobbied TAPS legislative priorities as the bill proceeded through both the House and the Senate, and through Conference.  Among the issues of key importance to TAPS were the Native Load/Service Obligation provision designed to protect existing transmission rights, facilitate the planning and expansion of the grid to meet the needs of load serving entities and enable them to obtain long term transmission rights for long term power supply arrangements, 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 successfully opposed provisions that would have mandated “one size fits all” formulas for pricing transmission upgrades and expansions.

 

NERC/NAESB

 

TAPS continued to participate in the NERC stakeholder group supporting legislation to create a self-regulating reliability organization under FERC supervision.  TAPS also increased its efforts to monitor and participate in NERC activities to protect the interests of TDUs.  This summer, Jake Langthorn, previously of the Oklahoma Municipal Power Agency, was retained to coordinate these efforts.  TAPS actively participated at NERC and NAESB in the development of the Version 0 NERC standards and on other issues of interest to TDUs, such as the discriminatory treatment of non-control area energy imbalances (which are subject to penalties) as compared with inadvertent energy.  Our efforts have had some impact.  We understand that the NAESB’s Inadvertent Interchange Payback Task Force final report is being changed in response to the efforts of TAPS and its members. 

 

Electric Energy Market Competition Interagency Task Force

 

November 29, 2005 Comments of the Transmission Access Policy Study Group, FERC Docket No. AD05-17-000.

 

FERC 

 

Reopening the Order 888 OATT (RM05-25)

  • November 22, 2005 TAPS files Comments in response to FERC Notice of Inquiry

Long Term Rights (AD05-7)

  • June 27, 2005 TAPS Comments in response to Notice of Inquiry
  • August 9, 2005 Supplemental TAPS Comments on definition of load serving entity, in light of EPAct 2005

Transmission Investment/Pricing Policies (AD05-5/ PL03-1)

  • April 22, 2005 Technical Conference (Roy Thilly, WPPI, appears for TAPS
  • May 5, 2005 TAPS Post-Technical Conference Comments

RTO Accountability (RM04-12)

  • August 26, 2005 TAPS Comments on Accounting and Financial Reporting NOPR

Available Transmission Capability (RM05-17)

  • August 15, 2005 TAPS Comments in response to the FERC Notice of Inquiry

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

  • TAPS Comments Following the December 7 Transmission Market Power Technical Conference (January 21, 2005); and Supplement Responding to MidAmerican (February 15, 2005)
  • January 27, 2005 Technical Conference on Generation Market Power (Mark Hegedus appears for APPA and TAPS)
  • January 28, 2005 Technical Conference on Affiliate Abuse (Terry Huval, LUS, appears for TAPS)
  • March 14, 2005 APPA/TAPS Follow-Up Comments on Generation Market Power

Market Behavior Rules (EL06-16)

  • December 29, 2005 Comments of TAPS (jointly with APPA) regarding FERC’s proposed repeal of the Market Behavior Rules in light of EPAct 2005’s Market Manipulation Provision

Reference Prices (PL05-6)

  • April 15, 2005 TAPS Comments on Notice of Inquiry as to whether process for setting reference prices represents an unlawful delegation of FERC’s ratemaking authority
  • June 3, 2005 TAPS Supplemental Comments

Revision of Merger Regulations to Implement EPAct 2005 (RM05-34)

  • November 7, 2005 TAPS Comments
  • November 8, 2005 TAPS Comments on a connected issue in the proposed PURPA revised regulations (RM05-36)

Wind Transmission and Imbalance (AD04-13, RM05-7, RM05-10)

  • January 28, 2005 TAPS Post-Technical Conference Comments, following up on the December 1, 2004 Denver Wind Conference
  • March 16-17 Workshop on Potential New Wholesale Transmission Services (Conditional Firm Service) in Portland to accommodate wind (Cindy Bogorad appears for TAPS)
  • April 13, 2005 TAPS Post-Workshop Comments regarding Conditional Firm Service
  • May 26, 2005 TAPS Wind Imbalance Comments

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

  • April 5, 2004 TAPS Request for Rehearing of Order 2003 (focusing on load-specific vs. aggregate deliverability and clarifications regarding crediting) 
  • TAPS has intervened in the Order 2003 petitions for review

Reliability (RM05-30)

  • October 7, 2005 TAPS Comments on Rules Concerning Certification of the Electric Reliability Organization, and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards

NAESB (RM05-5)

  • July 1, 2005 TAPS Comments on NAESB’s initial filing of business practices

Critical Energy Infrastructure Information (RM02-4, PL02-1)

  • April 4, 2005 TAPS submits comments expressing concerns with the processing time for CEII requests and the extent of CEII designations