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

C. New Generator Interconnections

An important function for RTOs will be evaluating and implementing requests for new generator interconnections on its system. It is important that the authority to respond to and process new interconnection requests reside with the Transco, and not with regional utilities or control area operators. In its detailed, supplemental filing, the Applicants should clearly establish that GridFlorida must retain decisional authority over generator interconnections, as well as the authority to provide data, perform studies, and otherwise cooperate during the study process. EPSA is concerned, however, that where a Transco serves as the RTO and is permitted to exercise sole discretion over proposals for new merchant plants, there is a risk that the Transco will exercise market power by rejecting those plants that would decrease congestion revenues presently flowing to the Transco, or otherwise negatively affect the Transco’s revenue stream.

Moreover, as a for-profit entity, the Transco could have a legitimate business objective in maximizing profits for its members at the expense of new interconnecting generators. Allowing the Transco to exercise control over the construction of new merchant plants within its region creates an unacceptable potential for the exercise market power. EPSA believes that GridFlorida’s December 15th proposal on the planning and expansion function needs to consider independence both from transmission owners and how to create economic solutions to regional planning.

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