In response to a September 2008 report by the U.S. Government Accountability Office entitled “Electricity Restructuring: FERC Could Take Additional Steps to Analyze Regional Transmission Organizations’ Benefits and Performance,” the American Public Power Association said the report was constructive in pointing out the lack of evidence on the benefits of Regional Transmission Organizations (RTOs). APPA supports the GAO’s recommendation that the Federal Energy Regulatory Commission provide stronger oversight of RTO budgets and expenses and initiate performance measures to better quantify the benefits of RTO markets to consumers.

APPA believes, however, that the report itself is inconclusive in that it does not answer the fundamental question of whether consumers are better off as a result of RTO operation of electricity markets. APPA has commissioned a series of studies of these wholesale markets and these studies suggest evidence of undue market power, market manipulation, and higher electricity prices for consumers already reeling from a slumping U.S. economy. APPA recommends that the GAO conduct additional in-depth investigations into the design features of RTO markets.

APPA noted the report indicates that the broad disagreement about whether RTOs are in fact producing their expected consumer benefits remains unresolved because FERC “has not developed…comprehensive, standardized measures that Congress and the public could use to identify and track RTO performance.” APPA pointed to the GAO statement that “FERC officials share the view that RTOs have resulted in benefits to the economy, such as new efficiencies in operating the regional transmission grid, but FERC has not conducted an empirical analysis to measure whether these benefits were realized or developed a comprehensive set of publicly available, standardized measures that can be used to evaluate RTO performance.” 

 APPA agrees and shares the concern raised by the GAO finding that FERC assumes RTO markets are competitive and consumers are benefiting without providing the necessary data to support that assumption.

While many observers find that implementation of RTOs has resulted in some efficiencies in the operation of generation facilities, GAO pointed out that it has not been demonstrated that these savings have been passed on to consumers. As the GAO report states, “Lowering the cost of electricity production can result in lower electricity prices, higher profits for generators and others that sell electric power, or a combination of both effects.” APPA has previously raised serious questions about the level of generators’ profits and believes this would be a useful subject to pursue in further studies.

APPA applauded the report’s conclusions that FERC needs to conduct more stringent oversight of RTO performance, including budgets and expenses, and establish the metrics against which consumer benefits can accurately be measured. Until such analysis is conducted, no conclusions can be drawn about whether RTO-run electricity markets are successfully benefiting consumers.