FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Southern Company Services, Inc.-Docket No. RT00-77-000

Southern’s RTO filing fails to provide sufficient detail on the operational authority of the RTO; the Commission should require Southern to file an operating agreement.

Southern’s proposal indicates that the Gridco will have operational authority over the transmission facilities owned by Southern Companies through an operating agreement. However, Southern has not provided a form of the operating agreement, making it impossible to evaluate the extent to which operational control truly will be transferred.
The Commission has concluded that the RTO should serve as the security coordinator. In order to ensure that the security coordinator has the ability to perform its functions and to ensure that all generators are treated in a non-discriminatory manner, all generators, including all of Southern’s generation facilities, should have the same interconnection and operating agreement with the RTO.
Furthermore, it is unclear what safeguards can ensure that the for-profit motives of a transco and its board will not bias system operation and market outcomes. Ideally, the for-profit independent transmission company would not also be the system operator. Minimally, however, the oversight of transco/system operator performance in implementation of system operation and physical clearing of the ancillary service markets and congestion management would not reside within the transco or the transco board, but such authority should be held by a truly neutral cross RTO entity with nothing to hide.

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