Customer Views on Improving RTO Governance and Function - PowerPoint Presentation

1. Customer Views on Improving RTO Governance and FunctionCost Causation & Beneficiary AGreg PoulosNovember 9, 2020

2. Keys to Effective RTO Governance*Transmission Owners are voluntary members of RTOs. Establish some specific requirements and timeframes around membership; (e.g. significant exit fees)Tie incentives/adders for RTOs and transmission owners to documented benefits for consumers. Potentially, require that corporate RTO goals/compensation benefits align with benefits for consumers; Establish stable funding mechanisms for consumer advocate organizations to participate in stakeholder processes at the RTOs; Make consideration of the reasonableness of costs part of the RTO’s mission; Ensure that burdens of proof are appropriately aligned with consumer interests. For example, the burden of proof should be on the RTO and TOs - not on consumers; Require at least one member of each RTO Board be a representative of [direct] consumer interests;Ensure that RTO workforce is diverse across all aspects – including work experience, race, gender, etc.2*The bullet points on these pages are still in draft form and they are my personal perspective!

3. Keys ContinuedExplore ways to minimize administrative rule changes and maximize competition in RTOs and resist efforts to direct the market results to non-competitive outcomes; Mandate effective and independent market monitoring in all RTOs; Initiate efforts to increase transparency and consumer participation at FERC; Establish metrics (or methods) to evaluate and verify the independence of RTOs;Establish expected levels of accountability and oversight from each RTO as a quasi-regulatory body. For example, establish robust measurement and verification expectations to assess whether actions achieved the desired outcomes;Review voting and/or membership structures to ensure that retail customers have appropriate say;Board meetings should be public and available to stream remotely; RTO mission statements should include a statement how their actions ultimately affect consumer prices; andRTOs should strongly consider term limits for CEOs and board members.3

4. The 16 Member Offices of CAPS Delaware Division of the Public AdvocateDistrict of Columbia Office of the People’s CounselIllinois Citizens Utility Board Office of the IL AG (Public Utilities Bureau)Indiana Office of Utility Consumer CounselorKentucky Office of Rate InterventionMaryland Office of People’s CounselMichigan Michigan Department of Attorney GeneralNew Jersey Division of Rate CounselNorth Carolina Office of Attorney General, Utilities Section Public Staff – North Carolina Utilities Comm.Ohio Office of the Ohio Consumers’ CounselPennsylvania Office of the Consumer AdvocateTennessee Office of the Tennessee Attorney General - Consumer Advocate & Protection DivisionVirginia Office of the Attorney General – Insurance & Utilities Reg. SectionWest Virginia Consumer Advocate Division4

5. What is CAPS?Who We AreEstablished in 2013, Consumer Advocates of the PJM States, Inc., (CAPS) is a nonprofit organization whose members represent over 61-million consumers in the 13 PJM states and the District of Columbia. Regulatory rules vary greatly across our jurisdictions, but in each the electricity costs paid by consumers is at least partly determined by the tariff and rules under which PJM operates. PJM and its stakeholders set those rules and CAPS’ engagement is necessary to ensure that consumers’ voices are heard.MissionOur mission is to actively engage in the PJM stakeholder process and at the Federal Energy Regulatory Commission to ensure that the prices we pay for reliable, wholesale electric service are reasonable.5

6. Contact informationGreg Poulos,Executive Director, CAPSPhone: 614-507-7377E-mail: poulos@pjm-advocates.org6