FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Desert STAR, Inc.-Docket No. RT01-44-000

C. The Scope of DSTAR’s Authority Is Inadequate.

The scope of DSTAR’s authority over transmission facilities and interconnection are major unresolved issues. The fundamental problem with the current DSTAR proposal is that it does not provide DSTAR with the authority over all FERC-jurisdictional services, at all voltage levels and over all of the facilities owned by the Participating Transmission Owner (“PTO”) (not just those facilities over which the PTO has transferred operational control to the RTO).

Absent this clearly stated mandate, important transmission services (including generation interconnection) and important functions (including grid expansion) will remain under the control of vertically integrated market participants (the Transmission Owners (“TOs”)), who will continue to possess both motives and means to thwart non-discriminatory access, the interconnection of new generation to the grid, and the unbiased assessment of all competitive alternatives to new transmission facilities - all of which are discriminatory practices that Order No. 2000 is intended to eliminate.

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