FERC’s implementation of the Energy Policy Act of 2005, along with other major initiatives, made 2006 an extremely active year for TAPS.  TAPS 2006 efforts included the following significant activities:


TAPS’ legislative agenda and priorities for 2006 included maintaining visibility and support in Congress and at FERC for the legislative victories we attained in the Energy Policy Act of 2005, educating Commissioners, Members of Congress and staff on the need for and role of joint ownership in getting needed transmission built, and promoting understanding of the need for greater accountability by Regional Transmission Organizations and Independent System Operators.  This agenda was accomplished, under the leadership of the TAPS Joint Ownership and RTO Accountability Task Forces, through several rounds of meetings between groups of TAPS members and Capitol Hill offices, Executive Branch officials, FERC Commissioners and staff and trade press and through related activities by TAPS’ Washington representatives.  Additionally, TAPS spearheaded and coordinated the revival of the “participant funding” coalition of public and private utilities, large customers, independent transmission companies and others to continue to oppose use of this transmission funding mechanism. 


TAPS has been active in the transformation of NERC to the Electric Reliability Organization authorized by the Energy Policy Act of 2005 to establish and enforce mandatory reliability standards subject to FERC review.  This change has added importance to participating in the standards development process at NERC and, for the related business practices, at NAESB.  Since his “retirement” from Vermont Public Power Supply Authority this summer, Bill Gallagher has mobilized and coordinated TAPS efforts to monitor and participate in NERC and NAESB activities to protect the interests of TDUs.  In particular, TAPS has worked to ensure TDU representation at both NERC and NAESB, including on joint NERC/NAESB drafting teams.

As FERC has moved to implement the reliability provisions of the Energy Policy Act, TAPS has also actively participated in NERC-related filings at FERC (discussed below).


EPAct Implementation (FERC initiatives mandated, often with a one-year date for completion of a final rule, by the Energy Policy Act of 2005)

Long Term Firm Transmission Rights in Markets Operated by Regional Transmission Organizations and Independent System Operators (RM06-8/AD05-7)

  • TAPS Initial Comments (March 13, 2006)
  • TAPS Reply Comments (April 3, 2006)
  • TAPS Limited Rehearing of the July 20 final rule (August 21, 2006)
  • TAPS/APPA Response to PJM’s unauthorized reply to rehearing applications (September 29, 2006)

Promoting Transmission Investment through Pricing Reform (RM06-4) 

  • TAPS Comments (January 11, 2006)
  • TAPS Rehearing of the July 20, 2006 final rule (August 21, 2006)

Transactions Subject to Section 203 Filing Requirements (RM05-34)

  • TAPS Rehearing of the December 23 final rule (January 6, 2006)
  • TAPS Rehearing of the April 25, 2006 rehearing order (May 24, 2006)

Reliability (RM05-30/RR06-1/RM06-16)

  • TAPS Limited Protest (May 4, 2006) of NERC Application to become the Electric Reliability Organization
  • TAPS Limited Protest (October 2, 2006) of NERC governance compliance filing
  • TAPS Limited Protest (November 17, 2006) of NERC non-governance compliance filing

Prohibition of Energy Market Manipulation (RM06-3)/Market Behavior Rules (EL06-16)

  • After issuing its rule implementing new Section 222, FERC repealed (February 16, 2006) existing Market Behavior Rules (EL06-16).  TAPS (with APPA and SMUD) requested clarification or rehearing of the repeal order (March 12, 2006)

Electric Energy Market Competition Interagency Task Force (AD05-17)

  • TAPS Comments on draft Task Force Report (June 26, 2006)

OATT Reform, MBR Standards and Other Initiatives (aside from EPAct Implementation)

Preventing Undue Discrimination and Preference in Transmission Service (RM05-25) (OATT Reform) and Available Transmission Capability (RM05-17)

  • TAPS Reply Comments (January 23, 2006) to Notice of Inquiry
  • TAPS Initial Comments on NOPR (August 7, 2006)
  • TAPS Reply Comments (September 20, 2006)
  • TAPS (John Krajewski, MEAN, and Cindy Bogorad) participates in October 4 and November 8, 2006 informal technical conferences on conditional firm/redispatch service
  • TAPS (Dave Geschwind, SMMPA) participates in planning panel at the October 12, 2006 Technical Conference
  • TAPS Supplemental Comments on Transparent Dispatch Advocates Proposal and Conditional Firm Service (December 15, 2006)

Market-Based Rates for Public Utilities (RM04-7)

  • TAPS/APPA Initial Comments on NOPR (August 7, 2006)
  • TAPS/APPA Reply Comments (September 20, 2006)
  • Mark Hegedus appears for TAPS/APPA at informal technical conferences held on November 14, 2006 and November 30, 2006

Standard of Review for Modifications to Jurisdictional Agreements (RM05-35)

  • TAPS Comments (February 3, 2006)

Critical Energy Infrastructure Information (RM06-23/24)

  • TAPS/APPA Comments (November 2, 2006)

Standards for Business Practices and Communications Protocols for Public Utilities (RM05-5)

  • TAPS Supplemental Comments (April 14, 2006)

Accounting and Financial Reporting for Public Utilities including RTOs (RM04-12)

  • TAPS Rehearing of December 16, 2005 final rule (January 17, 2006)

National Interest Electric Transmission Corridors (DOE Proceeding)

  • TAPS Comments (March 6, 2006)