UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
18 CFR Parts 141 and 388
[Docket No. RM95-9-000]
Real-Time Information Networks
NOTICE OF TECHNICAL CONFERENCE AND REQUEST FOR COMMENTS
(March 29, 1995)
AGENCY: Federal Energy Regulatory Commission.
ACTION: Notice of Technical Conference and Request for Comments.
SUMMARY: The Federal Energy Regulatory Commission (Commission),
is issuing this notice to announce a technical conference to be
scheduled at a later date, and, in preparation for that
conference, to request comments on: (1) whether real-time
information networks (RINs) or some other option is the best
method to ensure that potential purchasers of transmission
services receive access to information to enable them to obtain
open access transmission service on a non-discriminatory basis
from public utilities that own and/or control facilities used for
the transmission of electric energy in interstate commerce; and
(2) what standards should be adopted if the Commission requires
such public utilities to institute RINs systems.
DATES: Parties wishing to file comments must file an original
and 14 copies of their comments. In addition, commenters are
requested to submit a copy of their comments on a 3 inch
diskette, formatted for MS-DOS based computers. In light of our
ability to translate MS-DOS based materials, the text need only
be submitted in the format and version in which it was generated
(i.e., MS Word, Wordperfect, ASCII, etc.). It is not necessary
Docket No. RM95-9-000 - 2 -
to reformat word processor generated text to ASCII. For
Macintosh users, it would be helpful to save the documents in
Macintosh word processor format and then write them to files on a
diskette formatted for MS-DOS machines. Comments must be
received on or before [insert date that is 60 days after this
notice is published in the Federal Register].
ADDRESSES:
Send comments to:
Office of the Secretary
Federal Energy Regulatory Commission
825 North Capitol Street, N.E.
Washington, D.C. 20426
FOR FURTHER INFORMATION CONTACT:
Gary D. Cohen (Legal Information)
Electric Rates and Corporate Regulation
Office of the General Counsel
Federal Energy Regulatory Commission
825 North Capitol Street, N.E.
Washington, D.C. 20426
(202) 208-0321
Marvin Rosenberg (Technical Information)
Office of Economic Policy
Federal Energy Regulatory Commission
825 North Capitol Street, N.E.
Washington, D.C. 20426
(202) 208-1283
SUPPLEMENTARY INFORMATION: In addition to publishing the full
text of this document in the Federal Register, the Commission
also provides all interested persons an opportunity to inspect or
copy the contents of this document during normal business hours
in Room 3104 at 941 North Capitol Street, N.E., Washington, D.C.
20426.
Docket No. RM95-9-000 - 3 -
The Commission Issuance Posting System (CIPS), an electronic
bulletin board service, provides access to the text of formal
documents issued by the Commission. CIPS is available at no
charge to the user and may be accessed using a personal computer
with a modem by dialing (202) 208-1397. To access CIPS, set your
communications software to 19200, 14400, 12000, 9600, 7200, 4800,
2400, 1200, or 300 bps, full duplex, no parity, 8 data bits and 1
stop bit. The full text of this document will be available on
CIPS for 60 days from the date of issuance in ASCII and
Wordperfect 5.1 format. After 60 days, the document will be
archived, but still accessible. The complete text on diskette in
WordPerfect format may also be purchased from the Commission's
copy contractor, La Dorn Systems Corporation, also located in
Room 3104, 941 North Capitol Street, N.E., Washington, D.C.
20426.
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Real-time Information ) Docket No. RM95-9-000
Networks )
NOTICE OF TECHNICAL CONFERENCE AND REQUEST FOR COMMENTS
(March 29, 1995)
INTRODUCTION
The Commission is considering requiring each public utility
(or its agent) that owns and/or controls facilities used for the
transmission of electric energy in interstate commerce to create
a real-time information network (RIN) to ensure that potential
purchasers of transmission services have access to information to
enable them to obtain open access transmission services on a non-
discriminatory basis from the public utility. This initiative is
being taken in conjunction with the Commission's proposed rules,
1/ today being issued, that would require public utilities to
provide open access non-discriminatory transmission services
(Open Access NOPR) and would permit the recovery of legitimate
and verifiable stranded costs in certain circumstances.
The Commission's goal in this proceeding is to establish
uniform requirements for a RIN or other communications device at
the same time that the Commission adopts a rule requiring open
------------------
1/ See Promoting Wholesale Competition Through Open Access Non-
discriminatory Transmission Services by Public Utilities &
Recovery of Stranded Costs by Public Utilities and
Transmitting Utilities, Notice of Proposed Rulemaking,
Docket Nos. RM95-8-000 & RM94-7-001 (1995).
Docket No. RM95-9-000 - 2 -
access non-discriminatory transmission services. To accomplish
this objective, the Commission invites interested persons to file
comments and to participate in a Technical Conference in which
they can make presentations on their positions. Thereafter, the
Commission expects to hold informal conferences, enlisting
working groups to reach consensus on any remaining issues.
We expect that input from the Technical Conference and
informal conferences will be the basis for subsequent procedures.
This notice sets a timetable to be followed so that requirements
on RINS can be in place no later than the effective date of an
open access rule.
BACKGROUND
In the Open Access NOPR, the Commission is inviting comments
on a proposed rule that would require any public utility that
owns and/or controls facilities used for the transmission of
electric energy in interstate commerce to have on file an open
access transmission tariff.
To be effective, however, non-discriminatory open access
transmission service requires transmission customers to be able
to compete effectively with the public utility that owns or
controls the transmission. Customers must have simultaneous
access to the same information available to the transmission
owner. Thus, in this proceeding, the Commission expects to
require RINs or other options to ensure that potential and actual
transmission service customers receive access to information so
Docket No. RM95-9-000 - 3 -
that they can obtain service comparable to that provided by
transmission owners (or controllers) to themselves.
DISCUSSION
A. Objectives
As noted above, the Commission expects to undertake further
procedures in this docket after the Technical Conference and
informal conferences are held and input from those conferences is
evaluated. Nevertheless, to help participants focus on the
issues, the Commission here sets out its preliminary views. Any
requirement we establish must have safeguards to ensure that
public utilities owning and/or controlling transmission
facilities use the same procedures and meet the same substantive
requirements when they arrange transmission to support their
wholesale sales and purchases as are required for third parties.
Further, we expect that each public utility (or a control area
operator acting as its agent) that provides transmission service
must, at a minimum, give its customers electronic access in real
time to information on transmission capacity availability,
ancillary services, scheduling of power transfers, economic
dispatch, current operating and economic conditions, system
reliability, and responses to system conditions.
This means that public utilities or their agents must give
competitors and other users of the transmission system access to
the same information available to the public utility personnel
who trade (sell or purchase) power in the wholesale market, and
at the same time. Moreover, this information cannot be declared
Docket No. RM95-9-000 - 4 -
privileged (and kept from competitors) if it is available to the
company's own employees who trade wholesale power. Thus, if a
utility wishes to keep this information confidential, it must
assign control over this information to employees whose duties do
not involve trading in wholesale power, and it must implement
procedures to ensure that the traders do not get access to the
information unless and until that information becomes public.
The Commission invites parties to comment on the best way to
implement these requirements in their comments and in their
presentations at the Technical Conference and informal
conferences.
RINs should operate under industry-wide standards;
otherwise, each RIN could contain different information, have
different file formats, or use different means to transfer
information between utilities and customers. We are concerned
that some customers (those who need transmission service across
utility boundaries) might be forced to obtain information in
different and perhaps incompatible environments. Efficient
wholesale power markets require that information formats not
impede the ability of parties to make trades in a timely manner
within and across utility boundaries. Such impediments should be
eliminated, or at a minimum, reduced to the maximum extent
possible.
In addition, we request comments on the following questions:
Information availability: What information
should be available on a RIN? Possibilities
include transmission availability data,
scheduling information, information on
Docket No. RM95-9-000 - 5 -
economic dispatch, system reliability
conditions, service interruptions, and other
information that parties might suggest.
Would a RIN be appropriate, not only to
report transactions, but to conduct the
transactions themselves? If so, for what
kinds of transactions would this be
appropriate?
RINs standards: What standard formats would
be appropriate for transferring files
containing specific information? What are
appropriate communication protocols? How can
a RIN be designed to accommodate not only
today's needs, but also those in the future,
such as an ability to trade power and have
real-time price signals?
Attached to this notice is a Staff Discussion Paper that
gives Staff's preliminary views on some of the issues that need
to be addressed in this proceeding. We have attached this
document to help the parties focus on pertinent issues as early
in the process as possible.
B. Timetable for Comments, Technical Conference, and Informal
Conferences
The Commission's experience with Order No. 636 2/ and
electronic bulletin boards (EBBs) in the natural gas industry
3/ has taught us that when industry standards are needed, they
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2/ Pipeline Service Obligations and Revisions Governing Self-
Implementing Transportation; and Regulation of Natural Gas
Pipelines After Partial Wellhead Decontrol, 57 Fed. Reg.
13,267 (April 16, 1992), III FERC Stats. & Regs. Preambles
30,939 (April 8, 1992); order on reh'g, Order No. 636-A, 57
Fed. Reg. 36,128 (August 12, 1992), III FERC Stats. & Regs.
Preambles 30,950 (August 3, 1992).
3/ See Standards For Electronic Bulletin Boards Required Under
Part 284 of the Commission's Regulations, Order No. 563, 59
FR 516 (Jan. 5, 1994); III FERC Stats. and Regs.,
Regulations Preambles 30,988 (1993), order on reh'g, Order
(continued...)
Docket No. RM95-9-000 - 6 -
should be established as early as possible. We wish to avoid
systems being developed, and expenses being incurred, before
consensus can be reached on the best way to proceed.
These same considerations also persuade us that a case-by-
case approach to setting standards for electronic information
transfer is inappropriate. Public utilities should not be
required to invest extensive capital in a RIN or EBB that might
be obsolete in the near future. 4/
We intend, therefore, to have requirements in place no later
than the date when we issue any final rules on open access
transmission. In this way, we hope to avoid unnecessary
expenditures by public utilities.
At the Technical Conference, the Commission will focus on
determining exactly what information must be made available to
transmission customers and what standards are needed as to the
transfer of this information on a real-time basis from
transmission operators to their customers, including the public
utility itself for its wholesale transactions.
-------------
3/(...continued)
No. 563-A, 59 FR 23,624 (May 9, 1994); III FERC Stats. and
Regs., Regulations Preambles 30,994, reh'g denied, Order
No. 563-B, 68 FERC 61,002, Order No. 563-C, order
accepting modifications, Order No. 563-C, 68 FERC 61,362
(1994).
4/ We note that there is an extensive network already in place
to conduct intercompany transactions reliably. To the
maximum extent possible, we intend to build on the existing
institutional arrangements and ongoing efforts to help
better schedule, monitor, and model transactions involving
multiple control areas.
Docket No. RM95-9-000 - 7 -
The Technical Conference will be open to all interested
persons. The exact date, time, and location of the Technical
Conference will be announced in a subsequent notice.
To better organize the Technical Conference, interested
persons are invited to submit written comments. Comments must be
received on or before [insert a date 60 days following the
Federal Register publication date]. The comments should be no
more than 25 pages in length, double spaced on 8 " x 11" paper,
with standard margins. Parties must submit fourteen (14) written
copies of their comments. In addition, commenters are requested
to submit a copy of their comments on a 3 inch diskette,
formatted for MS-DOS based computers. In light of our ability to
translate MS-DOS based materials, the text need only be submitted
in the format and version in which it was generated (i.e., MS
Word, Wordperfect, ASCII, etc.). It is not necessary to reformat
word processor generated text to ASCII. For Macintosh users, it
would be helpful to save the documents in Macintosh word
processor format and then write them to files on a diskette
formatted for MS-DOS machines. The comments must be submitted to
the Office of the Secretary, Federal Energy Regulatory
Commission, 825 North Capitol Street, N.E., Washington, D.C.
20426, and their caption should refer to Docket No. RM95-9-000.
All written comments will be placed in the Commission's
public files and will be available for inspection or copying in
the Commission's Public Reference Room (Room 3104, 941 North
Capitol Street, N.E., Washington, D.C. 20426), during normal
Docket No. RM95-9-000 - 8 -
business hours. The Commission also will make all comments
publicly available on its EBB.
Following the Technical Conference, the Commission's Staff
will promptly schedule a series of informal conferences using, as
appropriate, working groups enlisting the participants at the
Technical Conference. 5/ The informal conferences are intended
to narrow or resolve issues and to help the Commission determine
what information must be made available, and what standards are
needed, for the delivery of pertinent information on a real-time
basis from transmission operators to their customers, including
the public utility itself.
Staff will designate what working groups are to be formed,
when they will meet, and what topics they will consider. Staff
will work with these working groups as needed. 6/ The working
groups will be invited to reach consensus on the issues and
report that consensus to the Commission. The working group
-------------
5/ The Commission made use of working groups in drafting the
Commission's standards for EBBs. See, e.g., Standards For
Electronic Bulletin Boards Required Under Part 284 of the
Commission's Regulations, Final Rule, Order No. 563-A, 59 FR
23624 (May 9, 1994); III FERC Stats. & Regs., Regulations
Preambles 30,994 (1994).
6/ To promote candor and productivity, Staff will set up and
sponsor these meetings, but, where appropriate, will not
attend the meetings while the parties discuss the issues.
The parties are instructed, however, to brief Staff fully on
their progress at any such meetings.
Docket No. RM95-9-000 - 9 -
reports should identify issues where no consensus is possible so
that the Commission may take appropriate action to resolve all
remaining technical issues.
By direction of the Commission.
( S E A L )
Lois D. Cashell,
Secretary.
Staff Discussion Paper
Electronic Bulletin Boards and Real-Time Information Networks
Introduction
The Commission has issued a Notice of Proposed Rulemaking,
proposing non-discriminatory open access transmission services.
The NOPR proposes that public utilities provide all potential
wholesale transmission users, including the wholesale power
marketing department of the transmission owner, simultaneous
access to transmission and ancillary services. Potential
customers' access to information on transmission capacity and
other matters pertaining to transmission services must be made
comparable to the information access available to the power
marketing department of the transmission owner and its
affiliates. Staff believes that electronic communication is
critical to achieving comparable access to information, which in
turn is a cornerstone of comparable access to transmission
service. Comparable access by customers to information as it
becomes available is the key to both a successful comparable
access program and competitive power markets for electricity.
Rapid transfer of information between a transmitting utility's
computers and those of its potential wholesale competitors is
necessary to achieve these goals.
The technical conference begins the process of determining
what information and procedures will be required to achieve
comparable access to information. We request comments or
concrete proposals that address the issues and questions raised
in this paper. Areas that need to be addressed include:
Information Needs. What specific information is
required to ensure that all eligible parties
(including the transmission owner) have comparable
access to information needed to conduct wholesale
power transactions over the transmission system?
Type of Information System. What types of
information systems are available to communicate
transmission information, and which of these are most
appropriate to achieve comparable access to
information?
Standards and Systems Development. What standard
record formats should be developed to exchange
information? What protocols are needed? Should
regional systems, or a national system, be developed?
This paper provides short discussions of Staff's
understanding of the major issues and options in these areas.
Each discussion is followed by a list of questions intended to
guide comments.
Docket No. RM95-9-000 - 2 -
Docket No. RM95-9-000 - 3 -
Information Needed for Comparability
Comparability requires that wholesale transmission customers
be provided with the same information that the transmission owner
or controller has about the availability and price of
transmission services, and that the information be provided at
the same time and cost. A customer, when making wholesale power
transactions using transmission services, should have the same
information the transmission owner has available to make
wholesale power transactions. This includes, but is not
necessarily limited to, the following types of information:
Availability of firm and non-firm transmission
services (including ancillary services), rates for
these services and the amount and terms of any
available rate discounts. Information on the
opportunity costs on constrained paths and the
incremental cost of expansion, if known.
Hourly transfer capacities with other interfacing
control areas on a time interval corresponding to the
interval that a transmission owner uses in committing
its own units. For example, if the interval is
weekly, hourly transfer capacities should be provided
each week as the transmission owner commits its own
units.
Hourly amounts of firm and non-firm power scheduled
over each of the owner's interfaces with other
control areas. These quantities should be the
amounts scheduled over the following hour. They
should be provided at some short interval before the
start of each hour (e.g., 15 minutes).
Transmission outages, or planned and forced unit
outages that may affect trans-mission availability,
as they become known, as well as anticipated and
actual interruptions of services.
Load flow data that would allow customers to do their
own preliminary review of incremental transfer
capability to accommodate long-term transfers.
Updates to load flow information should be made
available to customers whenever the transmission
owner updates its load flow information.
Transaction specific information on all requests for
transmission service (including requests by the
transmission owner's wholesale power marketing
personnel). This information should be sufficient to
permit customers to evaluate the current state of
transmission requests on the system and to monitor
Docket No. RM95-9-000 - 4 -
potential discrimination. This information should be
provided when requests are received and updated when
the status of a request changes.
Transmission capacity available for resale by
customers seeking to resell their rights to
transmission service, and announcements by
prospective buyers who are seeking to acquire rights
to transmission service. These requests should be
made available when received.
Staff believes that transmission-owning utilities have such
information available in the normal course of business under
today's current industry practices. We also believe this
information is important for any parties using transmission
services to perform wholesale power transactions. Accordingly,
comparability requires that such information be made available to
prospective customers and to the transmission owner's wholesale
power marketing department on the same basis. However, the list
is provided only as an example of our current understanding of
the information. We invite comment on additional information
that is needed, but not included in the list, as well as
information in the list that is not needed.
Current industry practice should not be the sole standard for
judging what information to consider for inclusion in information
networks. Consideration should be given to likely future
industry developments, and how these might affect information
needs. In particular, the role of electronic information in the
dispatch function may change significantly as power markets
change. Future networks may need to provide for the electronic
trading of power. The design of current systems should retain
sufficient flexibility to accommodate these types of future
developments. We invite comment on what developments might
affect the design of a current information network, and how
consideration of such developments might be considered in the
design of today's systems.
Questions Regarding Information Needed for Comparability
1. What information about capacity availability is needed? Is
this information needed with respect to interfaces with other
control areas and within a single control area?
2. How often does information on available capacity need to be
updated? What other information is necessary? In designing
RINs requirements, what consideration should the Commission
Docket No. RM95-9-000 - 5 -
give to NERC's interest in improving and communicating the
calculation of transfer capability in real-time. 7/
3. What information about transmission constraints should be
included? Is it possible to develop information about
anticipated constraints and their associated opportunity
cost? Could information on interruptions be conveyed after a
constraint has occurred?
4. Should the information include requests for transmission
capacity, offers of transmission capacity (from utility and
third party entitlement holders), rates and an index of
entitlement holders? How often does information need to be
updated? What other information is necessary to facilitate
the development of a secondary market for transmission
capacity?
5. Can requests for transmission service be submitted
electronically, through an EBB or an information network,
rather than by telephone or FAX? What specific information
is needed for electronic submission of transmission requests?
Systems for Communicating Transmission Information
Many kinds of information systems could support electronic exchange of
transmission information between a transmission-owning public utility and its
customers, potential customers, and the transmission owner's wholesale
marketing department. But there is a tradeoff between the cost of a system
and the capabilities it offers. We would like comment on the capabilities
needed in a system to communicate transmission information and what type of
system will best meet those needs. In order to provide technical background
for this discussion, we offer the following three categories as general system
types, from the simple to the more complex:
Electronic Bulletin Board (EBB). One simple method of elec-
tronically communicating information is to use EBB displays.
A user of this type of EBB simply connects to (logs onto)
the EBB and sees the information displayed. We believe this
simple type of EBB should also permit a user to post
information, such as a transmission request, to the EBB.
This type of information system may be adequate for small
customers who are not very active in the transmission market
and who have only an occasional need for small amounts of
timely information. However, as information needs increase,
the method of EBB displays may become inadequate. A major
disadvantage is that displayed information cannot be
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7/ See Report on Electric Utilities' Response to the Cold Wave
of January 1994, Report by NERC Blue Ribbon Task Force at 10
(Apr. 11, 1994).
Docket No. RM95-9-000 - 6 -
processed directly by the receiving party's own computer.
Thus, if the receiving party wants to use this information
in its own computer displays or as part of an analysis, it
must enter it again. Reentering information is slow, error-
prone and costly, particularly for users who need large
amounts of information from several different EBBs. For
this reason, even the simplest form of EBB should provide a
capability that permits users to capture the information
presented in the display on their computer systems.
EBBs with Standardized File Transfer. A second method of
communicating information is to allow users to transfer
files between the EBB and the user's computer system.
Downloading (transferring the file from the EBB to the
user's computer system) eliminates the need to reenter
information into a user's computer system when it is already
present on the EBB. Uploading (transferring a file from the
user's system to the EBB) permits information already
present in a file on a user's
computer to be sent to the EBB without manual reentry.
Therefore, the capability of transferring files
containing relevant information between the EBB and
its users solves the data reentry problem for
large and more sophisticated users.
File transfer capability also makes possible efficient
processing of information from several different EBBs.
Computer software can be programmed to dial each EBB
automatically and to transfer files from (or to) each EBB.
The user can then choose how to display the information, or
process it directly in a computer program. Third parties
can aggregate transmission information from multiple EBBs to
provide an information service for customers who prefer to
use a single EBB. Standard file formats and protocols for
the transfer of information are essential for the efficient
transfer of this information. Without standard formats and
transfer protocols, a user must develop separate methods and
programs for transferring files to and from each EBB.
Real-time Information Network (RIN) Connection. This type
of network permits a continuous information connection
between the transmission-owning public utility and users of
the transmission network. In contrast, displays and
downloads are means of distributing information to users who
connect intermittently to an EBB specifically to request
information. Continuous connection permits a user to have
all new information as soon as it becomes available, without
needing to make specific requests. A user can directly
monitor all new information, or use a computer program to
monitor new information selectively as it becomes available.
Docket No. RM95-9-000 - 7 -
The computer program can then identify time critical
information as soon as it is available and alert key company
staff of the need to take action.
To a customer, a RIN means the immediate receipt of
information when it becomes available. Only some customers
may need information immediately, and even these customers
will not need all information immediately. We believe,
however, that some customers will need this type of
information connection, and that the number of these
customers will increase over time as markets develop and
expand.
RINs would need standardized formats for information and
protocols for its transfer. Such standards may be
different, and more complex, than standards for file
downloads and uploads. However, the development of a RIN
could eliminate the need to develop separate file transfer
capabilities through EBB uploads and downloads. Such
networks could be designed to support both continuous
connection and intermittent access using the same formats
and transfer protocols.
Docket No. RM95-9-000 - 8 -
Questions Regarding the Means of Communicating Information
6. What information is sufficiently time sensitive to require real-time
transmission and receipt? What information is sufficiently unchanging
and time insensitive to permit efficient transmission by request? Should
the amount and timing of real-time information provided be a user option?
7. Is an EBB requirement necessary at all if transmission-owning public
utilities are required to provide information to, and receive information
and requests from, an information network? Would EBBs be developed
voluntarily, either by utilities or third parties, if data were available
through an information network?
8. What is the minimum acceptable transfer time for the network? Should it
be measured in milli-seconds, seconds or minutes? Should the transfer
time be a function of the information transferred?
9. Should EBBs and/or RINs be developed in several phases? If so, what
phases and timing are appropriate?
10. How can the development of EBBs and RINs be made flexible enough to
accommodate future information needs?
11. Should the network be developed using lines leased or can it use existing
Value Added Networks (VANs)?
Standards and System Development
Standardization of information, record formats, and protocols for the
exchange of information are crucial to computer-to-computer transfer of
information. Without standards, each utility could develop its own file
formats and protocols to govern the transfer of information. As experience
with the development of EBBs in the gas industry has shown, different formats
and communication methods impose significant costs on using information and
provide barriers to trade across multiple companies. Moreover, once companies
design their own information systems, they understandably tend to resist the
imposition of generic standards. It is therefore especially important to
reach consensus on what standards should govern the operation of electronic
information systems and how information systems should be developed in
accordance with those standards. We would also like comment on how the cost
of system development and use should be recovered.
Questions Regarding Standards and System Development
12. What standard information should be included in the datasets to be
exchanged electronically? What standard definitions and units should be
used for this information?
Docket No. RM95-9-000 - 9 -
13. What standard record formats and identification codes are needed to
exchange the information associated with comparable access?
14. What standard codes should be used to identify facilities,
interconnection points, and other locations?
15. What standard protocol(s) should be developed to download and upload
files, or to exchange information across the information network?
16. Should a regional or national information system be developed?
17. If some regional development of information systems is desirable, what
regional entities should develop and maintain the system? Do these
entities currently exist? If they do not exist, how should they be
developed?
18. What system development and usage costs should be borne by all
transmission users, and what costs should be paid for only by users of
the information system?