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) 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) Available Transmission Capability (RM05-17) 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) 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
|
|