FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
COMPARABILITY REQUIRES THAT ALL TRANSMISSION CUSTOMERS RESERVE, SCHEDULE AND PAY FOR TRANSMISSION SERVICE ON THE SAME BASIS
CBM goes to the heart of the Commission's comparability requirement. CBM not only allows transmission providers to withdraw scarce capacity from their competitors, it also allows them to offer superior products that none of their competitors can match. To achieve the "Golden Rule" of comparability articulated so clearly in Order No. 888, transmission providers and other market participants should be required to reserve, schedule and pay for transmission service under the same rates, terms and conditions of service.
CBM should be treated as all other transmission capacity. If transmission providers or any other market participants need firm transmission service, that capacity should be reserved and paid for under the Open Access Transmission Tariff. Thus, CBM should be returned to the ATC or auctioned as firm capacity. If transmission providers or any other market participants need generation reserves, those should be obtained through unit and capacity commitments.
Some have argued that eliminating CBM will lead to the installation of excess generating capacity within a power pool with an installed capacity requirement, such as PJM. As explained in the attached comments of Dr. Roy Shanker, this is not a necessary result of eliminating CBM. As Dr. Shanker explains, "if CBM was assumed to support reliability prior to the sale of the associated transmission capacity on a long term firm basis, such support must of necessity still be available after the sale." Instead of relying on CBM, the total generation resources relied upon by the pool will consist of two pieces: dedicated resources and diversity resources that can utilize the transfer capability formerly reserved as CBM. (See, Comments of Dr. Roy Shanker, Appendix B.)