FERC Filings

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

II. PROTEST

From EPSA’s perspective, the critical issue in evaluating any RTO proposal is whether it will make the market more competitive than it is today. For example, will determination of available transmission capacity and control over all transmission services, including congestion management, be performed by a truly independent authority? Does the RTO proposal enable existing customers to transact over a wider geographic region? Does the proposal advance the principles of comparability by requiring all transmission customers, including native load, to utilize a single open access transmission tariff? Does the proposal facilitate new generation interconnection by adopting interconnection procedures consistent with the Commission’s “one-stop shopping” requirement? Will transmission planning be performed on a sufficiently regional basis? Will initial market design and authority over future changes to market rules be based on a truly neutral decision-making process or biased by for-profit transmission interests? Will market monitoring be done fairly and efficiently? With the exception of market monitoring, EPSA believes that Southern’s RTO proposal fails to advance the advent of competitive markets as compared to the status quo.

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