From: Barkovich,
Barbara
Sent: Friday, July 28, 2006 2:33 PM
To: Hinman,
Cynthia
Cc: Edson, Karen
Subject: Here are some preliminary
comments on Market Initiatives Ranking Process
I regret that I have not had
more time to respond on the Market Initiatives Ranking Process. However,
here are some preliminary thoughts:
1. The Ranking Criteria in general
show little interest in the Market Participant perspective, although MPs are
affected by all the ISO does. MPs have interest in far more than "ease or
difficulty" of implementation of initiatives. They are also affected by
increases in market efficiency, correction of market design flaws,
infrastructure development, and stable market rules and their input should be
solicited and weighed in evaluating market design changes in all of these
areas.
2. The criteria do not make it clear that if a market design
change is mandated by FERC, the ISO must implement it.
3. ISO reputation
does not appear from the outside to be a criterion on a par with grid
reliability or FERC mandates. Should it be included at all?
Furthermore, it is described as related to Customer Care. I don't think
customers would agree with that characterization.
4. Among the
Feasibility Criteria, complexity for the ISO does not appear to be on a par with
some of the other criteria.
5. The document says that "the evaluation
based on different criteria will be performed in consultation with those most
familiar with the implications of the project with respect to the relevant
criteria. Market Participants also have familiarity with the implications
and may disagree, for example, with the evaluation by the ISO, especially its
DMM, on market efficiency impacts. MPs should be able to provide input on
such matters that is considered by the ISO along with input from its staff.