FERC-922, [AD19-16] Performance Metrics for ISOs, RTOs, and Utilities in Regions Outside ISOs and RTOs

In September 2008, the United States Government Accountability Office (GAO) issued a report recommending that the Commission, among other actions, work with Regional Transmission Organizations (RTOs), Independent System Operators (ISOs), stakeholders, and other experts to develop standardized metrics to track the performance of RTO/ISO operations and markets and publicly report those metrics. In accordance with the 2008 GAO Report, Commission staff developed a set of standardized metrics (the Common Metrics), sought and received OMB approval to collect information on those metrics from RTOs/ISOs, and later non-RTO/ISO utilities, and ultimately issued five public reports (Common Metrics Reports). In December 2017, the GAO issued a report on the RTOs/ISOs with centralized capacity markets. Among other recommendations, the GAO found that the Commission should take steps to improve the quality of the data collected for its Common Metrics Reports, such as implementing improved data quality checks and, where feasible, ensuring that RTOs/ISOs report consistent metrics over time by standardizing definitions. Furthermore, the GAO recommended that the Commission develop and document an approach to regularly identify, assess, and respond to risks that capacity markets face. In response to the 2017 GAO Report, Commission staff has proposed changes to the Common Metrics information collection. First, Commission staff proposes to improve the data collection process by creating a standardized information collection Input Spreadsheet (i.e., the reporting form) and an updated, more detailed User Guide, which will provide guidance on completing the information collection request, including information about who should respond; the timeline for responses; the metrics being collected, including important definitions and a description of the types of metrics and their structure in the information collection; and how to properly use the reporting form. Also, Commission staff proposes to update the list of Common Metrics to focus on centrally-organized energy markets and capacity markets, which involves adding capacity market metrics. The update eliminates previously-collected metrics on reliability, RTO/ISO billing controls and customer satisfaction, interconnection and transmission processes, and system lambda. Commission staff proposes eliminating these metrics because they provide limited information, do not significantly help Commission staff or the public draw any conclusions regarding the benefits of an RTO/ISO, and to reduce the reporting burden for respondents. The revised data collection, after additions and deletions, consists of twenty-nine Common Metrics. Without information allowing for a comparison of performance between ISOs/RTOs and regions outside of ISOs/RTOs, the Commission will not have the information necessary to identify the benefits of ISOs/RTOs based on actual performance of ISOs/RTOs and regions outside of ISOs/RTOs over the same time periods. Furthermore, as noted above, the GAO report specifically criticized the Commission's initial measures for evaluating ISO/RTO performance as "not comprehensive" because they "do not compare performance between RTO and non-RTO regions." Consequently, the Commission is seeking information from RTOs, ISOs and entities outside RTO and ISO regions.

The latest form for FERC-922, [AD19-16] Performance Metrics for ISOs, RTOs, and Utilities in Regions Outside ISOs and RTOs expires 2023-04-30 and can be found here.