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FERC Filings

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

Southern’s proposed RTO is a vague proposal, at best, and lacks sufficient detail to properly evaluate whether the proposal can fully satisfy the Commission’s minimum requirements for RTO status.

Southern’s RTO filing is not developed sufficiently such that EPSA can determine whether its proposal fully satisfies the Commission’s minimum characteristics and functions in order to qualify for RTO status. Southern’s filing has been structured as Petition for Declaratory Order pursuant to Section 207 of the Commission’s regulations, and although the Commission should provide guidance at this time, RTO status should not be granted until Southern makes a complete filing that demonstrates to the Commission that its proposal fully satisfies all aspects of Order No. 2000.