The Federal Energy Regulatory Commission should not only reinstate performance metrics for regional transmission organizations (ISOs) and independent system operators (ISOs), it should also expand certain of the proposed metrics to include additional data, the American Public Power Association recently said.
In July, FERC staff issued for public comment a revised set of performance metrics for regional transmission organizations (RTOs) and independent system operators (ISOs), as well as a set of metrics that are also applicable to utilities located outside of an RTO or ISO.
The Association noted in Sept. 9 comments in the proceeding that it has long supported the use of RTO/ISO performance metrics and consistent reporting of those metrics and expressed support for the reinstatement of the performance metrics.
Along with reinstating the metrics, the public power trade group said that FERC should expand certain of the proposed metrics to include additional data, including the metrics relating to price-cost markups, congestion management, revenues for new generation, and the amount of new capacity added each year.
The Association “submits that the value of the Commission’s effort would be greatly improved by an expansion of the data collected and a more in-depth review and analysis of the collected information by Commission Staff,” it said.
The Association pointed out that the proposed RTO/ISO performance metrics include only information that is already collected and reported by at least some of the RTOs/ISOs -- primarily by the market monitors in their reports on the RTO/ISO markets, as have past metrics.
“While there are certainly benefits to having that data reported in a consistent manner for all RTO/ISOs, the Commission should not limit RTO/ISO performance metrics to information currently collected by the RTOs/ISOs or their market monitors. Instead, the Commission should determine which data are needed for a full evaluation of RTO/ISO performance and require the RTOs and ISOs to provide this information,” the Association told the Commission.
The Association also said that FERC should improve or expand Commission staff quality checks of the data submitted and identify opportunities to compare the collected RTO/ISO metrics information with aggregate data on non-RTO/ISO regions available from other sources.
Association recommends adding metrics
In addition to the proposed metrics, the Association said FERC should also add the following metrics for all RTOs/ISOs, both with and without capacity markets:
- A comprehensive transmission metric that includes more detailed data on transmission costs;
- Aggregated data on cost recovery by existing capacity resources;
- The market share of capacity for the largest three generation owners for both the total RTO/ISO and by zone, but without necessarily identifying the owners;
- The relative shares of virtual trades and associated profits by financial and physical entities, the portion of virtual trades that enhance efficiency, and the relative shares of financial trading rights and similar instruments held by financial and physical entities;
- A governance metric showing the number of proposals and percentage of total proposals for market rule changes that were submitted to the Commission each year that had received a vote opposing the proposal by one or more stakeholder committees; and
- Retention of the RTO/ISO metric on customer satisfaction, with such data broken down by sector.
