2006 Activities
FERC’s implementation
of the Energy Policy Act of 2005, along with other major initiatives, made 2006 an extremely active year for TAPS. TAPS
2006 efforts included the following significant activities:
Legislation
TAPS’ legislative agenda and priorities for 2006 included maintaining visibility
and support in Congress and at FERC for the legislative victories we attained in the Energy Policy Act of 2005, educating
Commissioners, Members of Congress and staff on the need for and role of joint ownership in getting needed transmission built,
and promoting understanding of the need for greater accountability by Regional Transmission Organizations and Independent
System Operators. This agenda was accomplished, under the leadership of the TAPS Joint Ownership and RTO
Accountability Task Forces, through several rounds of meetings between groups of TAPS members and Capitol Hill offices, Executive
Branch officials, FERC Commissioners and staff and trade press and through related activities by TAPS’ Washington representatives.
Additionally, TAPS spearheaded and coordinated the revival of the “participant funding” coalition of public
and private utilities, large customers, independent transmission companies and others to continue to oppose use of this transmission
funding mechanism.
NERC/NAESB
TAPS has been active in the transformation of NERC to the Electric Reliability Organization
authorized by the Energy Policy Act of 2005 to establish and enforce mandatory reliability standards subject to FERC review.
This change has added importance to participating in the standards development process at NERC and, for the related
business practices, at NAESB. Since his “retirement” from Vermont Public Power Supply Authority
this summer, Bill Gallagher has mobilized and coordinated TAPS efforts to monitor and participate in NERC and NAESB activities
to protect the interests of TDUs. In particular, TAPS has worked to ensure TDU representation at both NERC
and NAESB, including on joint NERC/NAESB drafting teams.
As
FERC has moved to implement the reliability provisions of the Energy Policy Act, TAPS has also actively participated in NERC-related
filings at FERC (discussed below). FERC EPAct Implementation (FERC initiatives mandated, often with a one-year
date for completion of a final rule, by the Energy Policy Act of 2005)
Long Term Firm Transmission
Rights in Markets Operated by Regional Transmission Organizations and Independent System Operators (RM06-8/AD05-7)
TAPS Initial Comments (March 13, 2006) TAPS
Reply Comments (April 3, 2006) TAPS Limited Rehearing of
the July 20 final rule (August 21, 2006) TAPS/APPA Response to PJM’s unauthorized reply to rehearing applications
(September 29, 2006)
Promoting Transmission Investment through Pricing Reform (RM06-4) TAPS
Comments (January 11, 2006) TAPS Rehearing of the July 20, 2006 final rule (August 21, 2006)
Transactions Subject
to Section 203 Filing Requirements (RM05-34) - TAPS Rehearing of the December 23 final rule (January 6, 2006)
- TAPS Rehearing of the April 25, 2006 rehearing
order (May 24, 2006)
Reliability (RM05-30/RR06-1/RM06-16) - TAPS Limited Protest (May 4, 2006) of NERC Application to become the Electric
Reliability Organization
- TAPS
Limited Protest (October 2, 2006) of NERC governance compliance filing
- TAPS Limited Protest (November 17, 2006) of NERC non-governance
compliance filing
Prohibition of Energy Market Manipulation (RM06-3)/Market Behavior Rules (EL06-16) After
issuing its rule implementing new Section 222, FERC repealed (February 16, 2006) existing Market Behavior Rules (EL06-16).
TAPS (with APPA and SMUD) requested clarification or rehearing of the repeal order (March 12, 2006)
Electric Energy Market
Competition Interagency Task Force (AD05-17) OATT Reform, MBR Standards and Other Initiatives (aside from
EPAct Implementation) Preventing Undue Discrimination and
Preference in Transmission Service (RM05-25) (OATT Reform) and Available Transmission Capability (RM05-17) TAPS
Reply Comments (January 23, 2006) to Notice of Inquiry TAPS Initial Comments on NOPR (August 7, 2006) TAPS
Reply Comments (September 20, 2006) TAPS (John Krajewski, MEAN, and Cindy Bogorad) participates in October 4 and
November 8, 2006 informal technical conferences on conditional firm/redispatch service TAPS (Dave Geschwind, SMMPA)
participates in planning panel at the October 12, 2006 Technical Conference TAPS Supplemental Comments on Transparent
Dispatch Advocates Proposal and Conditional Firm Service (December 15, 2006)
Market-Based Rates for Public Utilities (RM04-7) TAPS/APPA
Initial Comments on NOPR (August 7, 2006) TAPS/APPA Reply Comments (September 20, 2006) Mark
Hegedus appears for TAPS/APPA at informal technical conferences held on November 14, 2006 and November 30, 2006
Standard of Review
for Modifications to Jurisdictional Agreements (RM05-35) Critical Energy Infrastructure Information
(RM06-23/24) Standards for Business Practices and Communications Protocols for Public Utilities
(RM05-5) Accounting and Financial Reporting for Public Utilities including RTOs (RM04-12) DOE
National
Interest Electric Transmission Corridors (DOE Proceeding)
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