25 October 2001

To: John Schelk, Enron

From: Enron Community Forum

Request (25 October):

1. The Barton discussion draft says that FERC's hands would be tied and that
they would have to approve a proposed RTO, as to size and scope, if the
proposed RTO owns or has operational control over transmission facilities
that serve at least 40,000 MW of load. Southern's CEO testified in Congress
recently that their load is over 35,000.  I assume the 40,000 MW minimum
would permit the SeTrans proposal to meet the proposed statutory minimum
since it is Southern plus a few munis, as I understand it.  Is this correct?

2. Who would know how many RTOs there would be if each were
just over the 40,000 MW minimum?

Response:

The load served by the transmission facilities in the proposed SeTrans
exceeds 40,000 Mw on a peak basis.  Specifically, the peak loads in Mw
recorded for 2000 by the members of SeTrans are:

Southern Co.		 31,702
Ala. Electric Coop.	   1,756
Ga. Trans. Corp              7,052
MEAG			   1,300 (est.)
City of Dalton                   NA
City of Tallahassee           550
South Mississippi           1,206 (2001 est.)
Jacksonville EA             2,614
Santee Cooper                3,600

Total			 50,230

2. Other conceivable RTOs above the 40,000 Mw threshold: 13.

Based on existing control areas or regional markets, and coincidence of
across those areas, a rough grouping of smaller RTOs can be envisioned with
transmission facilities capable of serving load in the range specified in
Rep. Barton's draft.  Peak load was used as a proxy for capacity of
transmission facilities. Intellbridge projects that based on the Barton
draft, a total of 14 RTOs - SeTrans and 13 others -- could be created.

However, the creation of hypothetical RTOs serving 40,000 Mw of load may
result in artificial groupings that would not be validated by commercial
arrangements. Existing transmission interties and supply contracts
necessitate the recognition of a new set of likely RTOs that are based in
part on current arrangements. Groupings with loads of between 40,000 Mw and
50,000 Mw seemed more likely to result.

 It also appears highly unlikely that the PJM Interconnect, now with a load
exceeding 50,000, would be subject to change. Two utilities in Pennsylvania
tied to but not part of PJM were added to form a Mid-Atlantic RTO.

Based on existing control areas or regional markets, and coincidence of
across those areas, a rough grouping of smaller RTOs can be envisioned with
transmission facilities capable of serving load in the range specified in
Rep. Barton's draft.  Peak load was used as a proxy for capacity of
transmission facilities.

Northeast Power Coordinating Council
ISO New England and NYISO, the U.S. Control Areas within the Northeast Power
Coordinating Council (NPCC), had a coincident summer peak of just fewer than
50,000.  ISO New England itself peaked at 21,919 MW, and NYISO at 28,138 MW.


Florida Reliability Coordinating Council
The FRCC's all time summer peak was 38,730 Mw, near the 40,000 Mw threshold.
Power is frequently exported north from the state when peaks in the Southern
Co. control area are not coincident with those in Florida.  NERC forecast
FRCC's 2001 summer internal peak demand to be 38,478 Mw.

Southwest Power Pool
The Southwest Power Pool (SPP), which had at one point discussed the
possibility of forming its own RTO rather than merging with Midwest ISO,
fits neatly into the 40,000 MW range specified in Rep. Barton's draft.  SPP
experienced peak demand of 40,101 MW during summer 2000.

Western States: Three RTOs
The Western Systems Coordinating Council reported peak demand for 2000 of
130,892 MW.  Three smaller RTOs could likely be carved out of the WSCC.

	*	Northwest Power Pool (NWPP): Net internal demand for the
Northwest Power Pool reported an annual peak of 57,107 MW during winter
2000-2001.  Without Canadian demand (with a winter peak of roughly 17,607
MW) the Northwest Power Pool would fall near the 40,000 MW threshold
specified by Barton's draft.

	*	California: The California system experienced a year 2000
peak demand of 51,213 MW during the summer.  Subtracting Mexican demand puts
the figure at just under 50,000 MW.

	*	Arizona, New Mexico, Southern Nevada (AZ/NM/SNV) and Rocky
Mountain Power Area (RMPA): The remaining reliability areas would not, on
their own, meet Barton's 40,000 MW threshold.  AZNM-SNV served only 21,724
MW at its summer 2000 peak, and RMPA, which can vacillates between having a
winter and summer peak, served 7,640 MW during summer 2000.  According to
the WSCC forecasts, the two regions could see a peak demand near 40,000 by
2010.

An alternative (though less likely) configuration could involve a
combination of Southern California with AZNM-SNV and RMPA, leaving Northern
California with NWPP.

Mid-Continent Area Power Pool (MAPP) and Mid-American Interconnected Network
(MAIN): Separate RTOs, Few Changes
In the Mid-Continent Area Power Pool (MAPP), U.S. systems had a year 2000
summer peak of 26,308 MW.  Load from Canadian systems brings the peak up to
just over 30,000 MW.

The Mid-American Interconnected Network (MAIN) experienced a summer 2000
peak demand of 52,214 MW, which would put it above the 40,000 threshold.
Shifting Wisconsin's MAIN members -- Wisconsin Electric Power, Wisconsin
Public Power and Wisconsin Public Service --  into the MAPP area reduces put
peak load for both MAPP and MAIN to close to the Barton bill's 40,000 Mw
mark.  Those three utilities had a 1999 coincident peak of roughly 8500 Mw.

Southeast and Northeast Central States: Five RTOs
The degree which to the transmission system is tied together east of the
Mississippi River necessitates approximately five groupings for RTOs in
addition to the NPCC. These can best be described as the Virginia-Carolina
area (now known as the NERC subregion VACAR), the Mid-Atlantic region (now
PJM), a Tennessee-Kentucky RTO (the TVA area is now a NERC subregion) and
two groupings for the East Central Area Reliability Council, North ECAR and
Central ECAR.

To illustrate how complex it is to redraw boundaries when systems are
physically connected, the approximate load in Mw by utility of these
fictional groupings is listed below.  Other considerations may play a larger
role in the creation of RTOs.

 <<...OLE_Obj...>>              <<...OLE_Obj...>>


 <<...OLE_Obj...>>              <<...OLE_Obj...>>

 <<...OLE_Obj...>>

Sources:
FERC Form 714
Foster Electric Report
WSCC 2001 Information Summary
<http://www.wscc.com/files/2001_Information_Summary_2001.pdf>
WSCC Summer Assessment 2001 <http://www.wscc.com/files/wisrrptg.pdf>
MAPP Annual Report
<http://www.mapp.org/news/Annual_Reports/Annual_Reports/2000stats.pdf>
NERC 2001 Summer Assessment
<ftp://www.nerc.com/pub/sys/all_updl/docs/pubs/summer2001.pdf>
NYISO
ISO-NE
PJM

For more information, or to speak with an industry expert, please contact
Senior Vice President Kelley Kenyan at (202) 298-6300 x256, or
kkenyan@intellibridge.com

 <<101025 Size of RTOs.doc>>


 - 101025 Size of RTOs.doc