NERC ERO IESO Comment 13 Jan 06 - final

Mr. David Cook, Vice President & General Counsel North American Electric Reliability Council 116-390 Village Boulevard Princeton, NJ 08540-5731 Subject: Draft ERO Application Comments Dear David: The Independent Electricity System Operation (“IESO”) for Ontario appreciates the opportunity to provide comments on the proposed draft ERO application (“Draft”). The IESO asks that NERC accept this submission in a manner of providing broad comments rather than restricting our remarks to specific sections as presumed in the provided NERC Comment Form. The IESO is a member of the ISO/RTO Council (“IRC”) and is a signatory to the submission filed by the IRC in respect of Draft. The IESO also participated in and supports the positions contained in the submission filed by the Canadian Electricity Association (“CEA”). The IESO’s submission is intended to complement these submissions while focusing on Ontario-specific aspects. General Comments For many years the IESO has actively promoted the need for mandatory and enforceable reliability standards that would apply to all owners, users and operators of the North American interconnected bulk power system. The IESO fully supports the creation of an Electric Reliability Organization (“ERO”) through which such standards would be developed and also enforced. This mandatory enforcement concept is consistent with the IESO’s enforcement of NERC, NPCC and its own reliability standards. The IESO ...