Comments on Draft of NWRTO Articles of Incorporation

[Carl Imparato for Power Marketer Group - July 8, 2000]

1.	Section III.B:  The specific purposes of the corporation, as listed, may not be consistent with Order 2000.  Why not simply delete the entire section and have it state that:  “The specific purpose of the corporation is to provide the services and conform to the standards specified in FERC Order 2000 and regulations promulgated thereunder.”

2.	If Section III.B is not changed as noted above, then:

•	Section 6 should be reworded:  “To effectively manage constraints on the RTO Transmission System and to take such actions as are required to relieve transmission congestion and avoid or minimize outages on the RTO Transmission System or on interconnected transmission facilities.”

•	Section 9 should be reworded, because the RTO will not operate an OASIS per se (since OASIS is an Order 888/889-specific concept that does not make sense in the RTO model), but will operate “an RTO website that meets FERC requirements.”

•	Section 10 must be reworded to eliminate the phrase “and shall not include in its tariffs (or permit its tariffs to include) any provisions for the use of any local distribution facilities)”. This language is clearly inconsistent with: (i) the generation interconnection obligations of the RTO, (ii) the planning obligations of the RTO (in which the RTO must play a key role in ensuring the fair evaluation of transmission, distribution, generation, distributed generation and DSM alternatives) and (iii) the retail access obligations of the RTO.  All of these require FERC-jurisdictional services to be managed at all voltage levels, not just at the transmission level). 

3,	Section III.C:  The reference to “the TCAs and other contracts, tariffs and protocols…” should be changed to “the RTO Tariff and other contracts.”  Clearly, the RTO Tariff, and not the TCA, must be the guiding document for the RTO.

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