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FERC Filings

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

II. PROTEST

At the outset, EPSA wishes to commend DSTAR for its apparent commitment to require that virtually all transmission service over the DSTAR grid, including transmission service that is used to meet native load requirements, be taken under the RTO tariff.<sup>3</sup> EPSA strongly believes that by requiring load serving entities to take transmission service under the same terms and conditions as other transmission users will significantly improve the competitive environment in the Southwest. Implementation of this proposal in other regions of the country will go a long way to eliminating one of the major impediments to the development of competitive bulk power markets. The development of a seamless national transmission system wherein all transmission usage is accorded fully comparable treatment is vitally important to the growth of a competitive electric power industry.

EPSA also wishes to commend DSTAR and the jurisdictional utilities for the stakeholder process that they have supported, for the receptiveness of both DSTAR and the jurisdictional utilities to the concerns that EPSA members and other non-incumbents have raised, and for the commitment of DSTAR and the jurisdictional utilities to the creation of an RTO that will maximize reliance on the use of market mechanisms and decentralized coordination rather than centralized command-and-control.

As noted above, the DSTAR filing is informational only. The filing entities do not seek Commission approval of any aspect of the filing and represent that the current DSTAR documents and proposals may change before DSTAR’s actual RTO filing. Accordingly, EPSA will reserve more detailed comments until the filing entities’ RTO filings. However, without intending to be exhaustive, EPSA has identified several key concerns with the current state of the DSTAR proposal that EPSA believes must be addressed for the filing entities to make an Order No. 2000-compliant filing.

<sup>3</sup>The only exception is transmission service provided under a pre-existing contract by a Participating Transmission Owner to a transmission customer that is not a Participating Transmission Owner in cases where such a pre-existing contract cannot be changed without the consent of the transmission customer.