FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION -Southwest Power Pool, Inc. - Docket No. RT01-34-000

Introduction

Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.211 and 385.214, the Electric Power Supply Association (“EPSA”) hereby moves to Intervene in and Protests the above-captioned proceeding. On October 13, 2000, Southwest Power Pool, Inc. (“SPP”) filed with the Commission a proposal for recognition as a Regional Transmission Organization (“RTO”) pursuant to the Commission’s requirements as set forth in Order Nos. 2000 and 2000-A. Although EPSA generally supports SPP’s efforts to comply with Order 2000 via changes to the SPP Tariff and the SPP Membership Agreement, certain elements of SPP’s proposal contradict the rules for the formation of RTOs as established in the RTO Orders, or do not go far enough in their efforts at compliance. EPSA urges the Commission not to accept portions of SPP’s proposal or to grant RTO status to SPP until SPP fully complies with the Commission’s mandates.
 Regional Transmission Organizations, III FERC Stats. and Regs., Regs. Preambles 31,089 (1999) (“Order No. 2000”); order on reh’g, III FERC Stats. and Regs., Regs. Preambles 31,092 (2000) (“Order No. 2000-A”)(collectively referred to where appropriate as the “RTO Orders”).

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