Electricity Markets

FERC staff seeks OMB approval of RTO/ISO performance metrics

Staff at the Federal Energy Regulatory Commission is seeking Office of Management and Budget (OMB) approval for the proposed reinstatement and revision of performance metrics for independent system operators, regional transmission organizations and regions outside ISOs and RTOs. FERC staff made the request on Jan. 24.

FERC staff last summer issued draft performance metrics. The American Public Power Association, the Transmission Access Policy Study Group (TAPS) and several other parties offered comments on the draft performance metrics.

In its comments, the Association said that FERC should not only reinstate performance metrics for RTOs and ISOs, it should also add additional metrics, and expand certain of the proposed metrics to include additional data.

The metrics submitted to OMB in January through a FERC notice were the same as those proposed in July 2019, other than minor revisions and clarifications (Docket No. AD19-16-000). 

According to the FERC notice, after approval by OMB a formal request for information will be issued with responses due within ninety days. Commission staff said that when it receives the responses, it intends to undertake additional, improved quality checks on the data, as recommended by the Government Accountability Office.

The Commission staff responses to the comments on the July draft metrics include:

  • No expansion of the metrics beyond those originally proposed is warranted, and “[s]ome of the additional metrics recommended by commenters may be calculated by certain RTOs/ISOs or non-RTO/ISO utilities but not by others, thus losing the commonality and comparability of the Common Metrics desired by Commission staff.” (Requests for additional metrics were submitted by the Association for data on transmission costs, cost recovery by existing capacity resources, market concentration, and financial entity profitability; by the California Independent System Operator for congestion revenue right auction efficiency; and by the competitive transmission developers for transmission costs);
  • No significant changes will be made to the metrics at this time. The Association, TAPS, and the PJM market monitor recommended changes to a number of the metrics themselves;
  • The recommended additional metrics and changes to the metrics will be researched and discussed in a collaborative process prior to the next iteration; and
  • In response to requests from a number of parties, including the Association and TAPS, for clarifications to the metrics, some revisions to the metric definitions and descriptions were made. These revisions include improvements in the definition of congestion charges and congestion revenue, and the measure of the effectiveness of congestion hedges, as recommended by TAPS and the Association.

OMB approval would cover a three-year period and reports on the metrics would be submitted in the first and third year of that period.

FERC staff projects that in addition to the RTO/ISOs, six non-RTO/ISO utilities, covering ten Balancing Authority Areas, would provide responses.

Comments on the metrics may be submitted to OMB by March 2, and should address:

  • Whether the collection of information is necessary for the proper performance of the functions of the Commission, including whether the information will have practical utility;
  • The accuracy of the agency’s estimate of the burden and cost of the collection of information, including the validity of the methodology and assumptions used;
  • Ways to enhance the quality, utility, and clarity of the information collection; and
  • Ways to minimize the burden of the collection of information on those who are to respond, including the use of automated collection techniques or other forms of information technology.