Agree.

Jim

 -----Original Message-----
From: 	Yeung, Charles  
Sent:	Friday, August 17, 2001 3:35 PM
To:	Steffes, James D.; Novosel, Sarah; Shelk, John
Subject:	Reliability Title on Transmission

I don't think the key to effective legislation to continue the opening of the transmission grid is the authority of FERC to order RTOs in itself.   It is the end state that the we hope the RTO orders can deliver that is key.  It would be a more powerful approach to line up the end state model we want for the grid into legislation - rather than fight for the ability to order formation of RTOs - then fight in settlement over what the RTO structures should be.  We should get into legislation the elimination of the fundamental drivers of discrimination that goes on today and what the utlities are trying to continue into the RTO paradigm.  We want:

1. Non-discriminatory transmission control operators - translated into real world terms as a single control area and indepdendent Security Coordinators.

2. A single transmission tariff - or comparable access rules and requirements for all generators and loads.

If the jurisdictional entities are held to these key requirements - then NERC or EISB which has the "authority" over the non-jurisdictional entities would begin to work in our favor. TLR rules, tagging rules, ATC calculations, redispatch - would have to be applied in the same fashion for marketers, IPPs, IOUs, Coops, Munis, BPA/TVA, etc.

These are two of the key differences between the gas industry and the electric industry.  Pipelines were separated from LDCs and producers, and there is no native load exception to inter-state pipeline access.

I think the reliability arguments some may bring up agianst these two fundamental changes are contestable and "winnable".  This should take away the FERC fear of jeopardizing reliability.