Hi! I’m the Rush Chairman. Damn glad to meet ya.


Three nights and two days inside hotel meeting spaces… that is the Winter NARUC meeting in DC. A gauntlet to be sure but there is no single event of which I know that brings together so many from industry and regulation in the energy space. It was also kind of my “coming out” party as “incoming” Executive Director of WPTF. For most of the time in the halls and receptions, I was tied to the hip with Gary Ackerman as we sought to speak with as many Western regulators and other folks of significance in our space.

So, what were the major themes of this NARUC conference? Well, to some extent it was just to meet the new FERC Commissioners and get a sense of them as there are four new ones since the last meeting in Washington. At different times in the conference, you could see each of the new folks as well as the veteran of the group, Cheryl LaFleur. The big “issue”, I suppose, was what was FERC going to do with “resiliency” after the denial of DoE’s NOPR. But that is such an “Eastern” thing that I didn’t really pay any attention.

No, what was most informative to me was the perspectives I got from folks who were from member companies as well as the Western state regulators outside of California. The discussions with the latter indicated a keen interest in market development, even if what was going to develop was as unclear to them as it is to the rest of us. There were the Commissioners from Wyoming, Colorado, Washington and Utah I met who were very engaged on the subject and interested to hear different perspectives. I met a senior staffer from the Nevada PUC who was equally focused on the subject of market development in the West. Speaking with them, I realized they were somewhat in the same situation as was I in taking – in a great deal of information – but I was impressed with their acuity and earnestness.

Then there were the discussions I had with several member representatives on things California like the chances for rationalizing the “Resource Adequacy” (RA) procurement rules, especially in view of the issue being taken up at the CPUC. We talked about what role the CAISO might play in such an effort and what role the Commissioners and staff at the CPUC might take. One member rep told me of a rumor that the unions were talking of legislation to have the natural gas plants that were needed to keep the CAISO grid reliable designated – by whom I’m not sure – and then given cost of service payments. Pick the survivors and give them money? How 1950s, I thought. This disturbing rumor did help to underpin the crazy nature of RA procurement in the Golden State.

I was so busy meeting with members and regulators in the hall ways that I did miss one presentation that I would have liked to have attended. It was a small meeting that CAISO had in a meeting space off the main area. As I raced by I saw 20 people in the room including several Commissioners from Western states, an EIM Board member, and a California Commissioner. Clearly, CAISO’s plans for regionalization – even without fixing the governance – was one topic that had to be prominently on the agenda. The related issue of CAISO’s RC platform was being discussed but I had to run to a meeting before I could hear much of the discussion. What probably was not discussed was CAISO’s plan for changes to the Congestion Revenue Rights (CRR).

This was not a topic of much discussion at NARUC but it is one that WPTF’s CAISO Committee has to watch carefully. I suspect that the effort CAISO is undertaking is an attempt to blunt the more draconian proposals being discussed by the CAISO market monitor.  What I was hearing sounded like a mirror image of what is going on in PJM. Are we in for a FERC discussion on CRRs (FTRs, TCCs) across the RTOs? Who knows but it is beginning to boil in CAISO.

The CAISO is certainly correct that there are improvements that can be made to the CRR market. Updating the model to include more current load assumptions and better synchronization with outages would be truly helpful to everyone. But the CAISO proposals which will decrease the transparency of the transmission model and the elimination of node paths seem more than problematic and likely to diminish the ability to hedge congestion. I’m glad this has the full attention of the WPTF CAISO Committee.

Well that’s enough for now. I’m still digesting everything I took in at NARUC but the socialization was great… now where did I put my car keys?