September 6, 1996

The Honorable Lois Cashell
Secretary
Federal Energy Regulatory Commission
888 First Street, N. E.
Washington, D. C. 20426

Reference: Docket No. RM95-9-000
Open Access Same-time Information System (OASIS)

The Honorable Lois Cashell:

This letter is submitted to the Federal Energy Regulatory Commission (FERC) by the How Working Group on the Open Access Same-time Information System (OASIS). On behalf of the electric industry, we respectfully request the Commission consider an extension of the November 1, 1996, deadline for implementation of Phase 1 OASIS. The proposed alternative schedule is in two steps:

1. All OASIS nodes required by FERC under Order 889 will be operational and available for public access at or before 8 a.m., local time at the provider, December 2, 1996. After this time, users will be able to access and download all required OASIS information. Users will also be able to submit electronic forms and upload data, as required by the OASIS Standards and Communication Protocols. However, all user interactions will be on a test basis only - no transmission service reservations will be executed on the OASIS and no OASIS transactions will be binding to any party. This step can best be thought of as a test of the OASIS system and an opportunity for users to develop and test their own capabilities to use the system in a harm-free manner. This period also allows adequate training of Transmission Provider personnel.
   
   
2. All OASIS nodes will begin commercial operation at 8 a.m., local time at the provider, January 3, 1997. All transactions at this point become binding, according to Order 889, applicable tariffs, and service agreements. The system may be closed to users on December 30 to January 2 while all test data are cleared from the OASIS databases and the system is prepared for a "clean" system start at 8 a.m. on the 3rd.

• A significant number of nodes are at risk of not reaching full compliance with Phase 1 OASIS functional requirements by November 1. This fact can be attributed to the technical complexity of the task, particularly in creating necessary standardization of the OASIS transaction processes across regions and in developing the back-end operating processes. To the best of our knowledge, all public utilities under FERC jurisdiction have been working in earnest since the issuance of Orders 888 and 889 (many started before this) to meet the November 1 deadline. We do not know of a single node that has been unnecessarily delayed for any reason other than the enormity of the technical challenges.
  
  
• A rushed startup, in which a significant number of nodes are completed at the last moment and inadequately tested before the November 1 deadline, will likely result in chaotic and, in some cases, commercially invalid uses of the OASIS for transmission and ancillary service transactions in the initial weeks. Input from Transmission Providers, Transmission Customers and other potential users of OASIS indicates that no one is willing to sacrifice the integrity and quality of transactions on the OASIS in order to achieve the November 1 deadline.
  
  
• The two step process allows for a reasonable test period in which transactions can be carried out on a trial basis. This allows users to develop and test systems to access the OASIS. This also allows Transmission Providers to adequately train personnel and evaluate the effectiveness of the back-end interface to scheduling of interchange and power system operation.
  
  
• Beginning commercial operation in January has the added advantage of simplifying accounting processes, since all activity will fall into a new month, beginning January, 1997.
  
  
• With this proposed schedule, the major development and testing of OASIS are still completed prior to peak load periods, which typically begin in mid to late January. Beginning on a Friday allows reservations to be made beginning in the first full week in January.

This schedule is achievable with the July 26 submission of the Standards and Communication Protocol document. We are presuming there will not be major changes to the Standards and Communication Protocol document as submitted to the Commission in July. While considering this request for an extension, we also request that the Commission clarify the activation date of the Standards of Conduct, which was originally tied to the OASIS startup date.

Thank you for your timely consideration of this request.

Respectfully,

Gerry Cauley
Manager, Grid Operation & Planning
Power Delivery Group
and
Facilitator, How Working Group

cc: W. Booth (FERC), M. Rosenberg (FERC), D. Nevius (NERC)