Actions in Compliance with FERC Order No. 719
Wholesale Competition in Regions with Organized Electric Markets
Order Issued on October 18, 2008
Notice Published in the Federal Register on October 28, 2008
Effective Date December 29, 2008
Compliance Date April 28, 2009
Paragraph Requirement
#
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Comments
Section 1. Demand Response and Market Pricing During Periods of Operating Reserve
47
57
59
1
RTO required to accept bids from DRR on basis
comparable to any other resources, for ancillary
services that are acquired in a competitive
bidding process, if the demand response
resources: (1) are technically capable of
providing the ancillary service and meet the
necessary technical requirements; and (2)
submit a bid under the generally-accepted
bidding rules at or below the market-clearing
price, unless laws or regulations of the relevant
electric retail regulatory authority do not permit
a retail customer to participate. All accepted
bids would receive the market-clearing price.
Describe in the compliance filing their efforts to
develop adequate customer baselines in order to
depict a demand response resource’s normal
load on any given day.
R. Dillon
MWG
RTWG
R. Dillon
MWG
Filing Letter
While the Final Rule does not set forth a
standardized set of technical requirements for
demand response resources participating in
G. Wallaert
(NAESB
MWG
Filing Letter
Filing Letter
Tariff
Future Markets
for new,
competitive
ancillary services.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
Deadline for the filing is no later than April 28 which is 6 months after the date of publication in the Federal Register. Specific date for action items to be
assigned as plan develops.
Paragraph Requirement
#
61
81
85
86
ancillary services markets, each RTO, in
conjunction with its stakeholders, will develop
its own minimum requirements. The Final Rule
also requires that RTOs and ISOs will
coordinate with each other in the development
of such technical requirements and provide the
Commission with a technical and factual basis
for any necessary regional variations.
RTO is required to file a proposal to adopt
reasonable standards for system operators to call
on demand response resources and mechanisms
to measure, verify, and ensure compliance with
any such standards.
RTOs must incorporate new parameters into
their ancillary services bidding rules that allow
demand response resources to specify a
maximum duration in hours that the demand
response resources may be dispatched, a
maximum number of times that the demand
response resource may be dispatched during a
day, and a maximum amount of electric energy
reduction that the demand response resources
may be required to provide either weekly or
daily.
RTOs are free to propose additional parameters
as long as they do not provide undue preference
to demand response resources vis-à-vis supplyside resources and interested persons may raise
these additional bidding parameters with their
deliberations with the individual RTO.
RTOs must incorporate bidding parameters that
allow demand response resources to specify
limitations on the duration, frequency, and
amount of their service. RTOs and ISOs are
required to confer with each other on such
parameters and methods and to provide a
technical and factual basis for any necessary
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Standards)
R. Dillon
Timeframe1
meetings to
consider these
issues TBD.
MWG
RTWG
ORWG
Filing Letter
MWG
RTWG
ORWG?
Filing Letter
MWG
Filing Letter
MWG
RTWG
ORWG?
Filing Letter
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Comments
Paragraph Requirement
#
88
89
97
111
regional variations.
The new requirements for bidding rules pertain
only to demand response resources although the
RTO may propose to apply them more broadly.
All demand response resources can specify
operational limits in their bids as a way for these
resources to minimize the risk that they are
called on too frequently, thereby making
participation in ancillary services markets more
feasible.
The Commission will require RTOs in
cooperation with their customers and other
stakeholders to perform an assessment through
pilot programs or other mechanisms of the
technical feasibility and value to the market of
smaller demand response resources providing
ancillary services within one year of the
effective date. This report will include whether
smaller demand response resources can reliably
and economically provide operating reserves
and report these finding to the Commission.
Additional issues that were raised by
commenters such as the need for measurement
and verification standards and a definition of
what constitutes “small demand response
resource” should also be addressed.
The Final Rule requires that all RTOs modify
their tariff to eliminate any deviation charge to a
buyer in the energy market for taking less
electric energy in the real-time market than was
scheduled in the day-ahead market during a
real-time market period which the RTO has
declared an operating reserve shortage or makes
a generic request to reduce load in order to
avoid an operating reserve shortage. This
requirement does not apply to RTO wholesale
demand response program participants but
rather to market buyers who voluntarily provide
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
R. Dillon
MWG
Filing Letter
MWG
RTWG
ORWG?
Filing Letter
L. Nickell
MWG
RTWG
ORWG - lead
Filing by year
end 2009
Future
Markets
MWG
RTWG
ORWG?
SPP
Engineering?
Filing Letter
Timeframe1
Comments
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Due one year
after effective
date; ORWG
take lead in
developing
assessment in
time to report to
MOPC by midyear meeting
Future Market(day ahead)
Paragraph Requirement
#
127
154
158
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
additional demand response either during or
prior an RTO-directed operating reserve
shortage in an effort to improve system
reliability.
RTOs and ISOs are directed to modify their
tariffs to eliminate deviation charges for virtual
purchasers, during the same period as they are
eliminated for physical purchasers as set out
above, unless the RTO or ISO upon compliance
makes a showing that it would be appropriate to
assess such deviation charges for virtual
purchasers during this period. This approach
establishes a reasoned generic policy and still
provides an opportunity for each RTO or ISO,
on a case-by-case basis, to present a factual
record that the generic policy does not fit its
overall market design.
The Final Rule requires that RTOs amend their
market rules as necessary to permit an
Aggregator of Retail Customers (ARC) to bid
demand response on behalf of retail customers
directly into the RTOs organized markets,
unless the laws or regulations of the relevant
electric retail regulatory authority do not permit
a retail customer to participate.
RTOs will amend its tariff and market rules as
necessary to allow an ARC to bid demand
response into the RTOs organized markets in
accordance with the following criteria and
flexibilities:
a)
The ARC’s demand response bid
must meet the same requirements
as a demand response bid for any
other entity, such as an LSE.
b)
The bidder has only an
opportunity to bid demand
response in the organized market
ORWGspecifically
i). See
below.
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Filing Letter
Future Markets
Comments
MWG
RTWG
ORWG?
Filing Letter
We already
allow.
MWG
RTWG
ORWG?
SPP Legal
Filing Letter
We already
meet
requirement in
a., b., d., f., h.,
possibly h. and
k.
On e. and g.,
need to research
Attachment AH
Paragraph Requirement
#
c)
d)
e)
f)
g)
h)
i)
and does not have a guarantee that
its bid will be selected.
The term “relevant electric retail
regulatory authority” means the
entity that establishes the retail
electric prices and any retail
competition
policies
for
customers, such as the city council
for a municipal utility, the
governing board of a cooperative
utility, or the state public utility
commission.
An ARC can bid demand response
either on behalf of only one retail
customer or multiple retail
customers.
Except for circumstances where
the laws and regulations of the
relevant retail regulatory authority
do not permit a retail customer to
participate, there is no prohibition
on who may be an ARC.
An individual customer may serve
as an ARC on behalf of itself and
others.
The RTO may specify certain
requirements, such as registration
with the RTO, creditworthiness
requirements, and certification that
participation is not precluded by
the
relevant
electric
retail
regulatory authority.
The RTO may require the ARC to
be an RTO member if its
membership is a requirement for
other bidders.
Single aggregated bids consisting
of individual demand response
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Comments
on references to
relevant retail
regulatory
authority
Paragraph Requirement
#
j)
k)
164
194
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
SPP / Regulatory
and Legal
Filing Letter
MWG
RTWG
ORWG
SPP Legal
Filing Letter
Tariff
Timeframe1
Comments
from a single area, reasonably
defined, may be required by the
RTO.
An RTO may place appropriate
restrictions on any customer’s
participation
in
an
ARCaggregated demand response bid
to avoid counting the same
demand response more than once.
The market rules shall allow bids
from an ARC unless this is not
permitted under the laws or
regulations of relevant electric
retail regulatory authority.
With regard to SPP’s comments that there is no
retail access within SPP, the Commission noted
that its ARC requirements are not limited to
aggregation of retail customers who have retail
choice. The Commission will not prejudge
whether any nascent ARC program will satisfy
the requirements. Nor will they decide whether
a regulator of a traditional, vertically-integrated
monopoly utility may give permission for an
ARC to aggregate retail customer’s demand
responses for bidding into SPP’s markets. SPP
may explain in its compliance filing its situation
regarding retail choice but should also explain
how it would accommodate a bid from an ARC
consistent with the criteria listed.
Each RTO is required to reform or demonstrate
the adequacy of its existing market rules to
ensure that the market price for energy reflects
the value of energy during operating reserve
shortage. The RTO is also required to provide,
as part of the compliance filing, a factual record
that includes historical evidence for its region
C. Monroe
L. Nickell
R. Dillon
Systems
currently
accommodate.
Attachment AH
requires ARC to
attest that they
have relevant
regulatory
authority.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
VRLs are a
form of scarcity
pricing.
Paragraph Requirement
#
208
regarding the interaction of supply and demand
during periods of scarcity and the resulting
effects on market prices, an explanation of the
degree to which demand resources are
integrated into the various markets, the ability
of demand resources to mitigate market power
and how market power will be monitored and
mitigated, among other factors.
The Commission required each RTO to ensure
that the market price for energy accurately
reflect the value of energy during an operating
reserve shortage but given regional differences
did not want to prescribe one particular
approach, the four approaches below were
suggested or any other approach that achieves
the same objectives:
(1)
RTOs would increase the energy
supply and demand bid caps above
the current levels only during an
emergency.
(2)
RTOs would increase bid caps
above the current level during an
emergency only for demand bid
while keeping generation bid caps
in place.
(3)
RTOs would establish a demand
curve for operating reserves,
which has the effect of raising
prices in previous agreed-upon
way as operating reserves grow
short.
(4)
RTOs would set the marketclearing
price
during
an
emergency for all supply and
demand response resources equal
to the payment make to
participants in an emergency
demand response program.
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
A. McQueen
R. Dillon
MMU
MWG
ORWG
Filing Letter
Tariff
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Comments
Paragraph Requirement
#
235
247
195
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
The Independent Market monitor is to provide
the Commission with its view on any proposed
reforms. (regarding the above four approaches)
The Commission established 6 criteria to
evaluate and RTOs proposal designed to ensure
that the shortage pricing proposal achieves the
objectives of this requirement while protecting
customers form market power.
(1)
Improve reliability by reducing
demand and generation during
periods of operating reserve
shortage.
(2)
Make it more worthwhile for
customers to invest in demand
response technologies.
(3)
Encourage existing generation and
demand resources to continue to
be relied upon during an operating
reserve shortage.
(4)
Encourage entry of new generation
and demand resources.
(5)
Ensure that the principle of
comparability in treatment of and
compensation to all resources is
not discarded during periods of
operating reserve shortage.
(6)
Ensure market power is mitigated
and gaming behavior is deterred
during periods of operating reserve
shortages including, but not
limited to, showing how demand
resources discipline bidding
behavior to competitive levels.
EMA
??
Filing Letter
RTOs are also free to propose other pricing
reforms and associated mitigation that meet the
criteria herein. (above)
MWG
RTWG
ORWG
Filing Letter
Timeframe1
Comments
Paragraph Requirement
#
199
204
248
258
Existing rules should combine effectively with
the more vigilant monitoring required in this
rule to dissuade the exercise of market power.
Each RTO is required to address in its
compliance filing how its selected method of
shortage pricing interacts with its existing
market design.
RTOs are required to explain how its market
rules will reduce or avoid periods of operating
reserve shortage as well as how its market rules
will reliably reduce demand and increase
generation during periods of operating reserve
shortage.
The Commission will allow an RTO to phase in
any new pricing rules over a period of a few
years, provided that this period is not protracted.
Any phase-in must be justified as part of the
RTOs overall proposal to change its pricing
rules.
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
A. McQueen
MMU
RTWG
Filing Letter
R. Dillon
MWG
RTWG
Filing Letter
R. Dillon
MWG
RTWG
ORWG
Filing Letter
MWG
RTWG
Filing Letter
274
RTO will assess and report on any remaining
barriers to comparable treatment of demand
response resources that are within the
Commission’s jurisdiction and to submit its
findings and any proposed solutions along with
a timeline for implementation to the
Commission in its compliance filing 6 months
after publication date.
MWG
RTWG
ORWG?
274
Each RTOs Independent Market Monitor must
submit a report describing its views on these
issues to the Commission.
MWG
MMU
SPP Legal
274
In each RTOs report, any significant minority
views must by identified but not every opinion
of every stakeholder must be addressed.
MOPC
Timeframe1
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Comments
Paragraph Requirement
#
275
RTOs report should identify all known barriers
and provide an in-depth analysis of those that
are practical to analyze in the compliance time
frame given for analyzing the remainder. This
should include but is not limited to technical
requirements as well as performance
verifications limitations. It need not include a
formal cost-benefit analysis for each barrier and
proposal to overcome it.
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
C. Monroe
L. Nickell
B. Sugg
R. Dillon
MWG
RTWG
ORWG
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Comments
Section 2. Long-Term Power Contracting in Organized Markets
301, 303, 304
RTOs dedicate a portion of their Web sites for
market participants to post offers to buy or sell
electric energy on a long-term basis. The
Commission requires each RTO to submit a
compliance filing describing actions the RTO
has taken, or plans to take, to comply with the
requirement and providing information on the
bulletin board the RTO has chosen to
implement. The Commission declined to
mandate a specific for the Web site but will
leave the implementation to the RTO and their
stakeholders. This discretion includes decisions
over the amount and type of data to be posted
by participants, whether participants must
include a proposed price in their posting, as well
as password and security requirements, post the
disclaimer on the web site indicating they are
not responsible for the content posted by users
and outlining the terms and conditions under
which users may post offers to buy or sell under
long-term agreements.
B. Sugg
L. Nickell
A. McQueen
MMU
SPP Legal
SPP IT Apps
MWG
BPWG
CWG
Filing Letter
Project needs to
be opened for
this.
Paragraph Requirement
#
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
B. Sugg
L. Nickell
A. McQueen
MOPC
BOD
SPP IT and
Communications
Staff
Filing Letter
RTOs shall include provisions in their tariffs:
(1) obliging themselves to provide their MMUs
with access to market data, resources, and
personnel sufficient to enable them to carry out
their functions; (2) granting MMUs full access
to the RTO database; and (3) granting MMUs
exclusive control over MMU-created data.
MMUs may share data under their exclusive
control, subject to pertinent confidentiality
provisions.
A. McQueen
MMU
RTWG
Filing Letter
Tariff
329
Access to the RTO database includes access to
RTO operational information.
A. McQueen
MWG
RTWG
Filing Letter
339
MMUs are required to report to the RTO Board
of Directors with management representatives
on the board excluded from the oversight
function. MMUs are permitted to report to
management for administrative purposed, such
as pension management, payroll, and the like.
The Commission identifies the core MMU
duties as: (1) identifying ineffective market
A. McQueen
MMU
Filing Letter
A. McQueen
MMU
RTWG
Filing Letter
302
If an RTO, in consultation with its stakeholders,
believes that costs of the bulletin board will be
significant, it may explain in its compliance
filing how it plans to recover the costs,
including whether it plans to charge users of the
bulletin board.
Timeframe1
Comments
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
AG 3.1
Section 3. Market Monitoring Policies
328
329
341
A. McQueen
Filing Letter
AG 8.1 (check
to see if this
goes far
enough)
AG 8.2
MMU
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
AG 3.1 – does
not mention
exclusion of
SPP mgmt from
oversight
AG 1.3 – check
language
Paragraph Requirement
#
354
rules, (2) reviewing the performance of markets,
and (3) making referrals to the Commission. If
the internal market monitor is responsible for
carrying out any or all of these things, it must
report to the board (as must the external market
monitor).
Commission outlines the functions of the
MMU.
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
A. McQueen
MWG
RTWG
Filing Letter
360
The RTO shall include in its tariff that it may
require the MMU to submit its report in draft
form to the RTO for review and comment but it
may not alter the reports generated by the MMU
or dictate the MMUs conclusions.
A. McQueen
MMU
SPP Legal
Filing Letter
374
The Final Rule directs that if an RTO employs a
hybrid MMU structure; it may authorize its
internal MMU to conduct mitigation. However,
this solution works only if the external market
monitor is charged with the responsibility of
reviewing the quality and appropriateness of the
mitigation conducted by the internal market
monitor.
A. McQueen
R. Dillon
L. Nickell
MMU
MWG
RTWG
Filing Letter
Tariff
Timeframe1
Comments
meetings to
consider these
issues TBD.
regarding
referrals to the
commission
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
AG covers
generally –
needs
clarification
Not in tariff –
add section
Consider
whether to keep
GLDFs in
MMU or move
to SPP
Operations
External MM
does no
oversight and
internal MMU
does so this
should be
moved from
MMU to RTO
(operations)
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Comments
Difference between prospective and
retrospective mitigation: The Commission
makes it clear that it is only prospective
mitigation that affects the operation of the
market and therefore it is only prospective
mitigation that creates a potential conflict of
interest for an MMU. The Commission directs
that RTOs may allow their MMUs, regardless of
whether it uses a hybrid structure, to conduct
retrospective mitigation. (For these purposes,
the Commission considers prospective
mitigation to include only mitigation that can
affect market outcomes on a forward-going
basis, such as altering the prices of offers or
altering the physical parameters of the offer
(e.g., ramp rates and start-up times) at or before
the time they are considered in a market
solution. All other mitigation would be
considered retrospective. P. 375 Should any
question arise as to categorization whether for
existing or proposed tariff revisions, the RTO
may seek guidance from the Commission in its
compliance filing. P. 376
The Commission also directs that each RTOs
tariff shall clearly state which functions are to
be performed by MMUs and which by the RTO.
A. McQueen
MMU
MWG?
Filing Letter
Tariff?
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Review Market
Mitigation Plan
A. McQueen
MMU
MWG if
anything needs to
be clarified in the
rules or tariff
Filing Letter
Tariff
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Changes to be
made through
modification to
mitigation plan.
RTOs are directed to review their mitigation
tariff provisions with a view to making them as
non-discretionary as possible whether
performed by the MMU or by the RTO and to
reflect any needed changes in their compliance
filings.
A. McQueen
MMU
MWG
RTWG
Filing Letter
Tariff
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Need to review
mitigation plan
to see determine
if nondiscriminatory
enough.
Paragraph Requirement
#
375, 376
378
379
We do no
retrospective
mitigation on a
systematic basis
– only in the
context of an
investigation
Paragraph Requirement
#
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Comments
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Not specified in
tariff. AG
refers generally
to Standards of
Conduct.
Not specified in
tariff. AG
refers generally
to Standards of
Conduct.
Legal send draft
to MMU for
initial review.
380
Each RTO is directed to include in its tariff the
minimum ethics standards to be applicable to its
MMU (below from the NOPR) with certain
modifications as explained. (minimums listed
in P. 380)
A. McQueen
MMU
SPP Legal
Filing Letter
Tariff
384, 387
These are minimums and the RTO is free to
propose more stringent ones. P. 384 The ethics
requirements apply to both the MMU itself as
well as its employees. P. 387
A. McQueen
MMU
SPP Legal
Filing Letter
Tariff
392
RTOs shall include all MMU provisions in one
section of the tariff as well as inclusion of a
mission statement in the introductory portion of
the MMU portion of the tariff section, which
sets forth the goals to be achieved by the MMU,
including the protection of customers and
market participants by the identification and
reporting of market design flaws and market
power abuses.
SPP Legal
MMU
SPP Legal
Filing Letter
Tariff
RTOs shall also include in its tariff provisions a
statement that in the event of any inconsistency
between the centralized MMU section and
provisions set forth elsewhere, that the
provisions in the centralized MMU section
control, although the RTO should attempt to
avoid such consistencies.
The NOPR contained a proposal by the
Commission that MMUs report on aggregate
market performance no less than quarterly to the
Commission staff, to staff of interested state
commissions, and to the management and board
of the RTO. The Commission also proposed
that the MMUs make one or more of their staff
members available for regular conference calls
SPP
Regulatory
RTWG
Filing Letter
Tariff
Legal
MMU
MWG
RTWG
Filing Letter
Tariff?
393
395, 396
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Could reword
Section 1.2 of
AG into
mission
statement.
This may be
OK in tariff but
statement could
be added to
clarify.
Legal can start
discussion –
reports are done
monthly now.
Alan McQueen
would like to
Paragraph Requirement
#
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
with representatives of the Commission, state
commissions, and the RTO.
P. 395 The
Commission also proposed that market
participants by included in the dissemination of
reports which can be accomplished by posting
them to the RTO website. Participation by
market participants, Commission staff, state
commission staffs and attorneys general should
be included if they desire to attend. P. 396
397
398
There shall also be a provision in the RTO tariff
that the annual state of the market reports are a
requirement with the same group dissemination
as quarterly reports.
Also the Commission directed that the time
period for offer and bid data be reduced to three
months but that an RTO could produce the data
sooner with accompanying justification or, if it
demonstrates a potential for collusion concern, a
four-month lag period or some other mechanism
to delay the release of a report if the release
were otherwise to occur in the same season as
reflected in the data. In addition, the
Commission agrees that the practice of masking
the identity of participants should be retained.
Comments
formulate a
proposal to
report quarterly
to RSC.
A. McQueen
A. McQueen
MMU
MMU
Filing Letter
Tariff
Filing Letter
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
AG 7.2
Alan wants to
make this part
of the internal
process to
disseminate
other reports.
Is web posting
good enough to
satisfy this?
This has been
Discussion with
assigned within
FERC Staff by
the MMU to
R. Dillon has
organize project
confirmed that
to get this done.
FERC expects
us to comply
Not required to be with the
written into tariff. shortened time
frame even
though we do
not currently
Paragraph Requirement
#
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Comments
provide this
data publicly
422
475
It is assumed that the data to be released would
consist not only of physical offers and bids but
demand and virtual offers and bids as well.
However, if the RTO objects to such inclusion,
they may address this in their filings. Likewise,
if they want to release additional data, such as
system lambda, that should be addressed in the
filing also.
RTOs consider structuring the MMU section of
the tariff to include, preferably in this general
order:
-Introduction and Purpose
-Definitions
-Independence and Oversight
-Structure
-Duties of the Market Monitor
-Duties of the RTO
-Data Access, Collections and Retention
-Information Sharing
-Ethics
-RTO-Specific Provisions
-Protocol on Referrals of Investigations to the
Office of Enforcement
-Protocols on Referrals of Perceived Market
Design Flaws and Recommended Tariff
Changes to the Office of Energy Market
Regulation
Alan
McQueen
MMU
SPP
Communication
(web page
posting)
SPP IT
Filing Letter
See previous.
A. McQueen
MMU
Legal
RTWG
Filing Letter
Tariff
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
To the extent
that there are
deficiencies
previously
identified –
those will be
added and other
existing
sections will be
fit together as
close as
reasonably
possible to this
outline.
Paragraph Requirement
#
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
Section 4. Responsiveness of RTOs to Customers and Other Shareholders
477, 502, 503
The Commission establishes four criteria which
RTOs must possess to meet requirements of this
section. They are: (1) inclusiveness; (2) fairness
in balancing diverse interests; (3) representation
of minority interests; and, (4) ongoing
responsiveness. P. 477
S. Duckett
MMU
RTWG
Filing Letter
S. Duckett
RTWG
Filing Letter
Each RTO must include in a filing to the
Commission how it is fulfilling, or will fulfill,
these obligations. P. 502 RTO independence
remains fundamental and will be preserved but
the Commission finds that an RTO board must
be responsive to the concerns of customers and
stakeholders as it provides those entities with
confidence in the RTOs independent
governance processes. P. 503
556
The Commission will require each RTO to post
on its Web site a mission statement or
organizational charter. The Commission
encourages each RTO to include in its mission
statement, among other things, the
organization’s purpose, guiding principles, and
commitment to customers and other
stakeholders, and ultimately to the consumer
who benefits from and pay for electricity
services. The mission statement or
organizational charter may include additional
information, such as elements form the RTOs
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Comments
Paragraph Requirement
#
565
567
567
governing documents. The Commission does
not expect that any explicit statement of the
responsiveness objective would conflict with the
elements of the RTOs mission.
The Commission requires that each RTO make
a compliance filing that proposes changes to its
responsiveness practices and procedures to
comply with the responsiveness requirement or
that demonstrates that its practices and
procedures already satisfy the requirement for
responsiveness. The compliance filing must
also propose posting, or report of posting, of the
RTOs mission statement or organizational
charter on its respective Web site. This filing
shall be submitted within 6 months of
publication in the Federal Register.
The compliance filing should also include how
the RTO plans to satisfy, or currently satisfies,
each responsiveness criterion. It should include
for each criterion an explanation of the process
(e.g., stakeholder meetings, technical
conferences, board discussions) that the RTO
used to develop its compliance filing
demonstration and describe major dissenting
views.
In the event that an RTO completes its
responsiveness compliance requirements in less
than six months, they may file them ahead of
the specified due date. The Commission will
assess whether each filing satisfies the proposed
requirements and issue additional orders as
necessary.
SPP Staff
Assigned
Working
Group/SPP
Staff Group
Approval
Needed
Filing Letter
of Tariff Sheet
Revision
Timeframe1
S. Duckett
Check to see if
what is already
out there
complies-SPP
staff
Filing Letter
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
S. Duckett
May just need to
explain that we
already complymake sure
Filing Letter
Dates for MOPC
and BOD
meetings to
consider these
issues TBD.
Comments