Bob Harshbarger Volunteer Order 771 January 16, 2013 Still Icy-Cold Salt Lake

Moment for Raymond Why cant you hear a pterodactyl go to the bathroom? Because the p is silent.

3 Final Order 18 CFR Part 366 Docket No. RM11–12–000 Availability of e-Tag Information to Commission Staff December 20, 2012 FERC Order 771

4 The basis for accessing e-Tag information related to wholesale electricity market transactions is provided by: –The Commissions anti-manipulation authority under FPA section 222, and –The Commissions investigative authority under FPA section 307(a). And not by the Commissions reliability authority under FPA section 215 FERC Order 771 (paragraph 14)

5 Access to e-Tag data will help the Commission in its efforts to: –detect market manipulation and anticompetitive behavior, –monitor the efficiency of markets, and –better inform Commission policies and decision making. FERC Order 771 (paragraph 27)

6 The Commission will not require NERC [or NAESB] or individual market participants to provide complete e-Tag data directly to the Commission. The Commission will instead require: –e-Tag Authors, through their [Tag] Agent Service, and –[Sink] Balancing Authorities, through their [Tag] Authority Service, Ensure that the Commission is included as an entity on an e-Tag with view-only rights on the e-Tags [via the e-Tag Carbon Copy List (CC List)]. FERC Order 771 (in the WECC, thats the WIT) (paragraphs 31 & 41)

7 The Commission will require e-Tag Authors and Balancing Authorities to make available to an RTO, ISO, or MMU access to complete e-Tags, upon request to the e-Tag Author and Balancing Authority. FERC Order 771 (paragraph 52)

8 The Commission will access the e-Tags by contracting with a commercial vendor. The commercial vendor will provide data management services and receive e-Tags addressed to the Commission. January 3, 2013, Combined Synopsis/ Solicitation for e-Tag Services for the Federal Energy Regulatory Commission (FERC); RFP FERC-13-R-0024 was issued. FERC Order 771 (paragraph 1)

9 Which transactions or e-Tags? –e-Tags for interchange transactions scheduled to flow into, out of, or within the United States portion of the Eastern or Western Interconnection, or into the Electric Reliability Council of Texas and from the United States portion of the Eastern or Western Interconnection, or from the Electric Reliability Council of Texas into the United States portion of the Eastern or Western Interconnection; FERC Order 771 (foot note 2 to paragraph 1)

10 What parts of an e-Tags? –information on every aspect, including: o all applicable e-Tag-IDs, o transaction types, o market segments, o physical segments, o profile sets, o transmission reservations, and o energy schedules. FERC Order 771 (foot note 2 to paragraph 1)

11 When? From the Federal registry version of the order: –DATES: Effective Date: This Final Rule will become effective February 26, [also paragraph 73] –E-Tag Authors and Balancing Authorities will be required to ensure Commission access to e-Tag data under this final Rule by no later than March 15, (paragraphs 1 & 41) FERC Order 771

12 Suggestion – tag authors might want to contact their Tag Agent Service provider and ask for an automatic FERC insertion into the CC List. Suggestion – the BAs in the United States portion of the western interconnection may want to have a new WIT validation to ensure FERC inclusion. FERC Order 771

13 The Order may not require the most efficient process, but given the short time frame, the process it is achievable. FERC may register as a PSE in the Electric Industry Registry. It is possible to modify the EIR and e-Tag specification to achieve a more efficient process. FERC Order 771

Questions?