FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION -Southwest Power Pool, Inc. - Docket No. RT01-34-000
B. The RTO Proposal Violates The Rule of Comparability Announced in Order 888
In order to reflect true comparability, all transmission service must be reserved and provided pursuant to the same system wide tariff, including existing bundled retail load. EPSA recognizes that some transition period for bundled load may be necessary as part of an overall cost shift mitigation plan. Nevertheless, the transition period of three years for bundled customers with choice and eight years for bundled customers without choice is excessive. This is further evidence that SPP has disregarded the importance of bringing all transmission customers in the SPP RTO’s territory under the RTO tariff as quickly as possible. SPP’s reference to previously approved tariffs holds little weight, as other regions affected with similar concerns have put forth proposals to bring all load under the same tariff effective immediately upon commencement of RTO services.
In its recent “Staff Report to the Federal Energy Regulatory Commission on the Bulk Power Markets in the United States, Part II” Commission staff addressed these issues and reached conclusions which should form the basis for the Commission’s review of current RTO proposals. In that report, the staff outlined the advantages of putting all uses of the transmission system under a single tariff and states that a single tariff would:
Reduce the advantage of network service over point-to-point service by requiring that native load be served under the same tariff provisions as other transmission services. Given that all transactions serve load of one sort or another, all load would be treated in the same manner.
The SPP RTO proposal, with its large number of grandfathered contracts and the fact that 92% of native load is exempt from the proposed tariff, would perpetuate the problems addressed by the staff report rather than cure them.
<sup></sup> See, for example, RTO West, Docket No. RT01-35-000 and Grid Florida Docket No. RT01-67-000.
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