E. Inadequate Information for Real-Time Monitoring of Markets

As discussed earlier, Staff attempted to obtain data from transmission providers and NERC regions for this report, only to be told that the information sought was either not compiled or would not be compiled for several months. Staff was informed by the NERC regions that export and import data were not available and that the peak load data for 2000 would not be available for several months. In addition, we attempted to obtain from several transmission providers system-wide snapshots for days when TLRs were called, but were informed that snapshot data were not retained.

While section 37.6 of the Commission's regulations sets forth a number of posting and record-keeping requirements concerning individual transmission requests and transactions, as well as the capacity available to fulfill those transactions, the regulations do not require keeping aggregate load or import/export data. Moreover, while NERC requires load and peak data, these data are not required to be compiled on a real-time basis and there are no archival requirements. Thus, some NERC regions will not have non-coincident peak load data available for the summer of 2000 for several months while the regions compile such data from their individual members.

Because of this lack of data, as well as the lack of accurate data on TLRs and curtailments discussed above, it will be difficult for the Commission to monitor and react to market inefficiencies and problems, particularly in the active summer months, within a time frame in which quick action could be taken. This points out a gap in existing regulations regarding what information should be retained and made public in real-time to ensure that the market runs transparently and efficiently.

Information Needs

Information transparency is necessary for a market to function efficiently. For this to happen, all participants must have equal and timely access to the information they need to make business decisions. This information already exists and is used by transmission providers to calculate operating parameters, such as Available Transmission Capacity (ATC), of their system. The general algorithm(s) used to calculate ATC and the underlying input data, such as Transmission Reserve Margin (TRM), Capacity Benefit Margin (CBM), projected load and system contingencies should be available on the transmission providers' OASIS sites. Detailed information, such as the load flow input data and the calculated solution, should be available upon request.

Market participants are particularly concerned about ATC calculations for the peak summer period. Transmission providers calculate ATC far in advance of the summer and then post these calculations on their OASIS sites. Typically, these calculations are very conservative, given the uncertainty that all maintenance and upgrades to the system may not be completed. Therefore, transmission providers normally use multiple contingencies which result in a smaller available amount of ATC.

As summer approaches, the uncertainty usually decreases since the estimates of available transmission and generation become more accurate. In addition, the weather forecasts for the summer months are more accurate the nearer the time to those months. Therefore, transmission providers recalculate the contingencies in the ATC and additional ATC is typically made available. To ensure that market participants have up-to-date knowledge of these changes and fair access to the additional ATC, transmission providers should publish on their OASIS sites the anticipated dates they will re-calculate ATC for the summer season.

It appears that many vertically integrated transmission owners may have incentives to resist efforts to make this information transparent and standardized, including information on the manner in which "native load" is handled in making these calculations. These incentives would also exist for transmission owners belonging to RTOs which allow them to individually calculate, or provide information to assist in calculating, ATC. As a consequence, the Commission may wish to eliminate the native load exemption and have all transactions under the same tariff. Given that all transactions serve load of one sort or another, all load would be treated in the same manner. This would provide all transmission owners the proper incentives to make relevant information available.

It has become apparent during this investigation that the Commission could benefit by having access to existing transmission information to provide a clearer understanding of the current market, as well as to assist in future studies. Transmission providers retaining and archiving the data listed below would meet this goal, as well as reduce the burden of future data requests on market participants and transmission providers. The following information would assist regulators' efforts to provide market oversight.

• Transaction data. This includes the number of transactions, the amount of each transaction in megawatts, and all connected paths from the Point of Receipt (POR) to the Point of Delivery (POD).
• TLR curtailment data. This includes the amount of curtailment on each transaction caused by a TLR, and the amount of relief on the congested flowgate.
• Retention by control areas of archived curtailment data for 3 years.
• Current network status. This is the real-time condition of the transmission network including transmission and generation outages.

The Commission could obtain all of the above information by having read-only access to the NERC Interchange Distribution Calculator (IDC).

It would also be useful for the Commission to have access, on an as-needed basis, to some other information that Security Coordinators have. First, it would help to have access to the daily reports from each Security Coordinator, which include the load, generation, scheduled transactions and tie-line flow data in each control area. Second, it would help to have access to standardized, historical TLR information. When transmission operators invoke a TLR Level 3 and above, they should retain the following system information in a standard format for 3 years: megawatt and megavar values for all generators, loads, flows and limits on all flowgates and tie-lines within their control area.