Why doesn’t the Functional Model include the FERC-defined Transmission Provider from Order 888?
For two reasons. First, many organizations are not FERC-jurisdictional, and their provision of transmission services may not align with FERC’s Transmission Provider. Second, FERC defines the Transmission Provider as an organization, not a function: “The public utility (or its Designated Agent) that owns, controls, or operates facilities used for the transmission of electric energy in interstate commerce and provides transmission service under the Tariff.” (from pro forma tariff) Thus, the FERC-defined Transmission Provider has actually “bundled” several functions that can today be performed by separate organizations. For instance, one can envision an organization that owns transmission and a separate organization that operates the transmission system. Both of these organizations could be within an RTO that provides transmission service through its tariff.
