Comments on Regional State Committee Proposal

1
Comments on Regional State Committee
Proposal

• Mass Restructuring Roundtable
• June 18, 2004
• Peter Zschokke
• National Grid
• VP, State Regulatory Policy, US Transmission

2
Benefits from RSC Formation

• Organization to promote policy prescriptions
  favored by all/majority of States
• Avenue to create better understanding of regional
  needs by the States
• RSC filing stakes out a broad area for review
• Siting?

3
How can RSC be Heard?

• RTO-New England filing
• Stakeholder Process before filing
• Able to submit comments to an ISO/TO filing with
  deference provided by FERC to those comments
• RSC right to have TOs submit alternative RSC
  proposal as part of TO regional cost allocation
  filing
• Existing Tariffs and RTO Tariff
• Able to file complaint that present tariff terms
  and rates are unjust and unreasonable (206
  rights)
• Deference provided by FERC

4
The Difficult Part 205 Rights I

• RSC filing requests use of RTO/TO 205 rights
• Is it necessary?
• See prior slide
• Is it legal?
• RSC not a public utility
• RTO-NE Order rejects request for broader RSC 205
  rights
• SPP RTO Order suggests that an RSC might require
  an RTO to make certain filings, but Commissioner
  Kellehers concurring opinion questions whether
  FERC has this authority

5
The Difficult Part 205 Rights II

• What does it mean for RTO independence?
• Would it allow RSC to file a change to rules that
  the RTO regards as necessary for markets?
• NE RSC filing has a broad scope
• Resource Adequacy, System Planning changes
  to implement any policies recommended by the NE
  RSC
• FERC denied request in original RTO approval

6
Conclusion

• Welcome the regional forum/dialogue
• Encourage States to focus their efforts within
  the scope of the RSC
• RSC has numerous avenues to be heard, with full
  understanding that FERC will give deference to
  their proposals
• It is not necessary for RSC to use RTO/TO 205
  rights to accomplish their objectives