RTO Technology Vision by Chris Trayhorn, Publisher of mThink Blue Book, April 1, 2003 Perhaps we should not measure the role of technology in realizing the Federal Energy Regulatory Commission’s Standard Market Design by the volume of text that it is afforded in the commission’s “Notice of Proposed Rule Making.” A scant five pages outlines FERC’s technology vision. Experience teaches us in the technology business that you need to get your business requirements right if you want the technology to be right. So perhaps FERC is correct in spending the vast amount of text on the design of the market instead of the technology. But FERC has outlined a tall order in its technology blueprint for Standard Market Design (SMD). We need to manage expectations. SMD is a vision. The reality will be something less. But the key is to keep pushing the vision. FERC’s Vision FERC outlines three foundation attributes of the design’s technology: • Transparency: the ability to understand what the software does. • Testability: the ability to understand and compare performance. • Modularity: the ability to change software modules without changing other software. These three attributes are all reasonable, perhaps noble, objectives. FERC, however, frames them as somewhat equal. The reality is that there is more cause and effect than appears on the surface. There are also big differences in the achievability of any of these objectives in the near-term. First, lets take modularity. As FERC notes, achieving this objective requires standard interfaces. But actually it takes much more. It requires a common vision on design and architecture within the components that make up the software systems in an ISO/RTO. The data constructs and the methods utilized within the components must also be standardized, or else the data that crosses these “standard interfaces” will be useless. An example would be you picking up the phone and calling France. This is seamless and easy because long ago the interfaces between the U.S. network and the French system were standardized. But if the person who answers the phone knows only French, and you know only English, you are not going to get very far in the conversation. It is the same for systems. To make these systems really modular there will need to be a much deeper level of standards and integration. Modularity is much more intrusive into the design of software components than just interfaces. So what about testability? Certainly the notion of a standard benchmark test suite for similar components is a good idea. Testability in the context of SMD is really a proxy for certainty. That is, a known input will produce a known output. The proxy for certainty so far in ISO implementations has effectively been operational audits of the market systems that are part of many ISO/RTO tariffs. These audits are effective, but they do not provide the degree of cross market/operator benchmarking at which FERC is driving. FERC is shrewd in pushing this point since such benchmarking would be a subtle but effective pressure on vendors to conform and improve systems performance over time. If there is anything a vendor likes least, it is to see their name last in a published benchmark “bake off.” It is just too competitive out there. Which leads us to transparency. This element of SMD is actually quite easy to achieve yet so difficult to implement at the same time. Transparency is really documentation. Public domain documentation. In an industry standard framework and at an industry standard level of quality. For us working in this environment every day, such documentation would be a breath of fresh air. I will go out on a limb here. One significant act that FERC can take in regard to technology in SMD implementation is to mandate that all SMD implementation be documented at an industry standard level and placed into the public domain. Of course, there will be some screams from the system vendors notwithstanding their rhetoric in the market about supporting open standards, etc. That is because they all believe that the “special” elements of their systems are their competitive differentiator. And indeed in reality they may be right. Why else would so many ISO/RTO executives feel “locked in” to a vendor? I outlined FERC attributes in reverse order for a reason. They are not equal. You arrive at modularity through good design, be it mandated or market driven. Either way, you get standardization that then can be tested (compared) as FERC envisions. To be testable, you must already be transparent. So there is a natural sequence to these objectives. Modularity is the end point. Transparence is the starting point. If Not Now, When? So just how achievable is FERC’s vision in the medium- to long-term? (You will understand as you read on, the short-term prospects are dim). FERC’s basic vision of the technology is right. But as the saying goes, the devil is in the details. The details will likely be messy and expensive. First, one must recognize that the technical environment that SMD targets is not green field; it is legacy. A sizable number of ISO/RTOs are already operational. They have already made their first wave investments in market and operational systems. No matter how visionary SMD is, implementation will be incremental to their current environment. Second, green field or not, the ISO/RTOs can only implement this vision if the system vendors provide a suite of systems as envisioned in SMD. Which leads to the third element. Vendors are clearly not all that motivated to provide SMD “vision-like” technology fast or for free. Figure 1 outlines the continuum of ISO/RTO systems. If you look at currently operating ISO/RTOs, for the most part, their systems are unique. Unique in the sense that a single market operator, without modifications to their systems, could not just up and operate in another’s jurisdiction. The architectures of the systems are generally specific to the market the system serves. This is an artifact of the history and timing of each of the currently operating ISO/RTO’s start-up. Figure 1: ISO/RTO Continuum The next step up on the continuum is open documentation (read FERC transparency). The level of documentation of ISO/RTO systems is actually more available than many think. (Indeed it is remarkable the level of documentation on ISO/RTO in the public domain already). But it is also true that there are large holes in available documentation. Indeed, a survey would likely reveal that each ISO/RTO has a large degree of documentation regarding systems, processes, and operations residing in the cerebral cortices of a few and consequently very important individuals at each of the respective ISO/RTO and/or its vendor. As I outlined above, conforming this knowledge to software industry best practice in terms of form and substance and making it available in the public domain is a significant enabler for advancing the state of ISO/RTO transparency. Further up the continuum is the notion of componentization. This is the FERC modularity element. It is also the notion that has formed the foundation for best practice in software design and implementation for some time. But here is where the Standard Market Design vision starts to be more difficult. From the incumbent vendor’s perspective, breaking major portions of their offering into plug-and-play components is not trivial technically or commercially. Most of these systems have evolved from power engineering algorithms utilized during pre-deregulation. Without question, the focus has been on the technical elements of the algorithms instead of the eloquence of the integration design. It is not that a more “eloquent” architectural design is not viewed as preferable by these vendors. The question is who is going to pay and how long do they have to complete the migration. At the extreme end of the continuum is the notion of “plug-and-play.” FERC uses this language directly in the NOPR. Plug-and-play conjures up notions of the common RJ11 phone jack. No matter who manufactures your phone, the jack is the same. When you plug it into the wall — presto — dial tone (the play part). Reality Check This is where a reality check is needed. Plug-and-play, in the context of the pedestrian concept of plug-and-play, within and/or between ISO/RTO systems, will not occur anytime soon unless it is mandated by law (it is unclear if FERC has the authority to make such a mandate) and it is subsidized (it is very clear that the ratepayers and taxpayers would be the ones paying). Why? The answer lies in the current market realities. The fact is that there is little market gravity pulling vendors in FERC’s direction. First, the market is quite small relative to the potential wallet of spending in the future. Thus the return for making a strategic investment by any single vendor is not all that good. The risk of both time and future market success would likely send vendor corporate strategic planners looking for greener pastures for their scarce investment dollars. Second, the rework required to current vendor systems is extensive when one considers how much structural change is required to migrate current systems to a technical architecture that supports the objective of Standard Market Design. Last, the migration will require vendor cooperation and/or standards (not vision but detailed technical standards). The former is not likely and the latter will take a long time. If you review the record for Standard Market Design, the above reality check is not a surprise. FERC has been told in a number of technical conferences that there is a gap between vision and reality. It is, however, remarkable that nearly every presenter on the subject, be it a vendor, a market operator, or a market participant, points to the same general technical solution. There is a remarkable degree of convergence on a common view for integration in ISO/RTO systems looking forward. There are many names for this integration structure: common information bus, application integrating bus, and enterprise application integration (EAI), to name a few. The EAI approach is a predominant strategy in a number of industries. EAI is best suited to an environment that requires an integration of operational and business systems into a single system; that requires an integration of both established legacy applications with new applications; and finally, has the desire to implement systems that could be easily adapted in the future to new and changing application requirements. EAI uses the latest software advances to seamlessly integrate separate systems. It is an integrating platform that allows use of best-in-class tools for each operational requirement in an integrated manner. Figure 2 is purposely a different depiction of EAI than you have likely seen before. Indeed most pictures of EAI opt for the over-simplified “EAI Magic Bus” (EMB). You just plug the applications into the EMB and you have plug-and-play. Want to switch stuff around? No problem. Just unplug one component and plug in a new one. If it were only that simple. (See Larger Image) Figure 1: EAI Hierarchy EAI is a very powerful technology for integration. And indeed as a foundation for ISO/RTO systems in the future, it has the potential to take center stage. But it is not magic. Much design, architecture, and new development are required before the simple “magic bus” picture is anything close to reality. Conclusion Looking at the hundreds of pages on market design and the mere five pages on technology design in the SMD NOPR, one can really get an idea of what FERC is thinking. Technology is not considered the issue. Indeed, FERC is right. The technology frameworks and standards to achieve FERC’s vision are no longer bleeding edge technology. Transparent, testable, and modular systems have been the design and market norm for quite some time. Achieving FERC’s technology vision is a market issue. A market issue that starts with the very premise of SMD in the first place: A single standard design for electric wholesale markets in the United States. If such a standard did exist, then all the vendors would be in a race to provide the systems to implement this design. And operators would be in a race to ensure the new design cured the issues of the past five to 10 years of implementations. I am sure if that were the case, we would end up with modular, testable, and transparent systems. So perhaps FERC was prudent in spending only five pages on technology vision after all. As is frequently the case, technology is not the issue. Business design is. Filed under: White Papers Tagged under: Utilities About the Author Chris Trayhorn, Publisher of mThink Blue Book Chris Trayhorn is the Chairman of the Performance Marketing Industry Blue Ribbon Panel and the CEO of mThink.com, a leading online and content marketing agency. He has founded four successful marketing companies in London and San Francisco in the last 15 years, and is currently the founder and publisher of Revenue+Performance magazine, the magazine of the performance marketing industry since 2002.