FERC Filings
MOTION TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION -GridFlorida LLC, Florida Power & Light Co.,Florida Power Corporation,Tampa Electric Co.-Docket No. RT01-67-000
II. Protest
From EPSA’s perspective, the critical issue in evaluating any RTO proposal is whether it will make the market more competitive than it is today. To determine this, several key questions must be affirmatively answered: will the determination of available transmission capacity (“ATC”) and control over all transmission services, including congestion management, be performed by a truly independent authority? Does the RTO proposal enable existing customers to transact over a wider geographic region? Does the proposal advance the principles of comparability by requiring transmission customers, including native load, to utilize a single open access transmission tariff? Does the proposal facilitate new generation interconnection by adopting interconnection procedures consistent with the Commission’s “one stop shopping” requirement? Will transmission planning be performed on a sufficiently regional basis? Will initial market design and authority over future changes to market rules be based on a truly neutral decision-making process or biased by for profit transmission interests? Will market monitoring be done fairly and efficiently? As explained below, EPSA believes that GridFlorida’s RTO proposal largely presents the status quo, and would not significantly advance the development of competitive markets.
EPSA appreciates the Applicants’ attempts to address the critical objectives outlined in Order No. 2000, and the use of a for-profit transmission company as a means to achieve them. While the Applicants assert that the filing is complete, they indicate that it does not include “implementation details,” and intend to make a supplemental filing on December 15, 2000.
The sections of the filing for which the Applicants request expedited approval are limited to the Board selection process, the qualification and independence criteria for Directors and Officers, and authority to commence hiring GridFlorida employees. The Applicants further request that the Commission give interested parties 30 days to submit comments on the key “implementation details” after they are filed on December 15, 2000.
EPSA believes that it could better comment on significant aspects of the proposal after it has an opportunity to review additional details that may be critical to the ability of the application to satisfy compliance with Order 2000. Applicants have also placed great importance on the collaborative stakeholder process that is to occur prior to the December 15, 2000 supplemental filing. Therefore, in addition to issues related to Commission review of the Board selection and other aspects of the governance process, EPSA comments on the status and effectiveness of the stakeholder collaborative process. We address certain key issues that should be reflected in any subsequent filings and reserve our right to submit further comments in response to the subsequent filings. Due to the absence of details relating to significant aspects of the proposal, EPSA believes that a determination that the proposal satisfies Order No. 2000 is premature.