FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION -Southwest Power Pool, Inc. - Docket No. RT01-34-000
C. Congestion Management
One of the most important roles for emerging RTOs will be addressing transmission congestion and the associated costs. While the SPP RTO’s proposed “hybrid” approach to congestion management appears to be a step in the right direction, EPSA is concerned that the specifics of the proposal are lacking. In this regard, SPP indicates that it is still in the process of developing the rules and procedures to implement the hybrid proposal and that it has hired a consulting firm to assist with the development of those rules. Obviously, the compatibility of the hybrid approach with the Commission’s requirements will depend on the development of specific rules. In addition, SPP must coordinate the development of its real-time balancing market and congestion management to assure that the implementation of the real-time balancing market, which will proceed development of congestion management rules, will not limit the design or implementation options for congestion management.
Likewise, the SPP proposal lacks specificity regarding financial transmission rights. Specifically the proposal merely commits to the development of “physical and financial ownership rights” (Bittle Testimony at 10) but in describing those rights simply states “the details need to be worked out.” (Bittle Testimony at 12) EPSA is concerned with this lack of specificity. In this regard the Commission should ensure that the rules which are developed do not favor historic usage in the allocation of FTRs. If new markets entrants cannot obtain FTRs on a reasonable basis, the status quo will be perpetuated. Indeed, a congestion management system that applies to only a small percentage of existing transactions within SPP is not very effective. Congestion management should apply equally to all transactions within SPP.