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

1. Scope of proposed balancing market may be much smaller than scope of GridFlorida Transmission Tariff

In the proposed Participating Owners Agreement, GridFlorida’s proposal will allow market participants to operate their own control area and “opt-out” of the real-time balancing dispatch services provided by GridFlorida. While EPSA awaits more information in the December 15th filing, this is an area that will require scrutiny. Detail obtained so far indicates an intent of one or more of the Applicants to exercise this ‘opt out’ feature and get the benefits of RTO for its wires without submitting its control area to be part of the GridFlorida real time energy dispatch.

Such an approach would by definition reduce the effective scope of the GridFlorida imbalance market and undermine the efficacy of regional ancillary markets. In the event one or more of the Applicants retained real time dispatch control, it may then be possible for such entities to execute significant gaming opportunities. EPSA and its member companies will continue their efforts in the collaborative process to articulate their concerns and seek resolution outside of the Commission process, but progress thus far demonstrates little interest on the part of Applicants to address the merits of this issue and no interest in movement on this issue. More detail on the balancing market proposal, and its relationship to the congestion management proposal, are needed to ensure that market participants are treated fairly and that sufficient liquidity develops for a successful market.

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