FERC Filings

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

Southern has not demonstrated that its performance-based incentives are warranted.

As Southern’s RTO proposal simply maintains the status-quo in the region, it is unclear why the Southern RTO should be entitled to performance-based rates and incentive pricing proposals. Although the Commission has indicated its willingness to consider the implementation of performance-based rates and incentive pricing proposals, it indicated that there must be a sharing of efficiency gains and benefits. EPSA believes that customers should receive a quantifiable benefit from the implementation of an incentive or performance-based rate. These rate proposals should only be considered in the context of a comprehensive Section 205 filing, complete with cost support, illustrations of their implementation, and a quantification of the benefits being confirmed. Because the Southern RTO has not shown, how it provides any efficiency gains or sharing of benefits, consideration of Southern’s performance-based incentives at this time, therefore, is premature. The Commission should reserve judgment on Southern’s proposed transmission pricing until it is presented with a detailed rate proposal.

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