Purpose/Industry Need:
There is confusion regarding the Interchange Authority “function.”  The need for improved clarity became apparent when entities were recently asked to register in the Compliance Registry as “Interchange Authorities” and entities had difficulty determining which entities were performing the Interchange Authority tasks identified in the set of Coordinate Interchange standards.   The Interchange Authority activities in the Coordinate Interchange standards are performed by software systems and not a responsible entity.  The software, not a functional entity, performs the task of accepting and disseminating interchange data between entities. 

The Coordinate Interchange standards dealing with the Interchange Authority and the current Functional Model representations of the Interchange Authority do not reflect technological advances made since the Functional Model working group originally defined the Interchange Authority and advances made since the Coordinate Interchange standards were written.

The modifications in the set of Coordinate Interchange Standards should address the following: 

• Determine if the activities in the Coordinate Interchange standards correctly identify the responsible entity. 

• Consider requiring the Sink Balancing Authority responsibility for Interchange Authority functions, using an interchange transaction tool process as defined in the latest approved version of the e-Tag Specifications.

• The existing requirements are tool-neutral ― consider adding specific references to the e-Tagging process in the requirements

• Consider adding a requirement to have backup capability for use when the interchange transaction tool fails.

• Consider combining requirements into a fewer number of standards so that the resultant set of requirements follows a chronological sequence that is easier to follow.

• Address the directives issued by FERC in Order 693, and the stakeholder comments from the V0 drafting team and the Violation Risk Factors Drafting Team.

• Determine if there is industry-wide support for the Interchange Subcommittee’s Principles and definition supporting dynamic transfers and pseudo-ties, and if there is support, modify the requirements and add definitions accordingly.