FERC Filings
MOTION OF THE ELECTRIC POWER SUPPLY ASSOCIATION FOR LEAVE TO INTERVENE
IV.
Station power service should be treated in a fair and equitable manner for all competitive generators under non-discriminatory rules and terms. Echoing our comments in the PJM Interconnection (PJM) filing of August 24, 2000 (Docket No. ER00-3513-000), EPSA supports the petition made by NRG and urges the Commission to grant NRG the right to treat station power as net/negative generation in a non-discriminatory manner.
The Commission must send a clear message to the industry regarding the treatment of undue discriminatory conduct in the development of competitive wholesale electricity markets. Historically, vertically integrated utilities have treated station power as net/negative generation. Moreover, even as some vertically integrated utilities treat station power as net/negative generation for their own generation, these same utilities are trying to impose retail tariffs and rates for station power service on divested generation.
This can create inherent inequities and inefficiencies, i.e. station power rates, terms and conditions can vary, forcing inefficient siting and operating results.
For example, where station power costs are high, a less efficient generator elsewhere may run in place of an otherwise more efficient resource. Commission policies should not facilitate such market inefficiencies.
Even recent Commission-approved agreements in New York, PJM and New England allow station power to be treated as net/negative generation. Clearly, the treatment of such an essential element of power generation should not become an impediment to the development of robust, competitive regional power markets, as envisioned by the Commission.
This, as with uniform policies and practices for generator interconnection service, will assure that generators are able to enter and participate in competitive regional markets.
For these reasons, EPSA urges the Commission to accept NRG’s petition and allow station power service to be treated in a fair and equitable manner for all competitive generators under non-discriminatory rules and terms