FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Southern Company Services, Inc.-Docket No. RT00-77-000
The proposed planning protocol does not adequately consider generation solutions and is biased towards wires solutions.
Southern’s planning protocol raises several concerns. In particular, Southern’s planning protocol proposes that the existing transmission owners should have a right of first refusal to build transmission upgrades. Only if the transmission owner “chooses not to” or “is not able to,” then the RTO will build it itself or negotiate with contractor to build it itself. The Commission should eliminate this right of first refusal. This blanket right does not consider performance standards, schedule, or cost considerations. It is neither just nor reasonable to continue to bestow monopoly power upon the transmission owners with respect to the construction of new facilities.
Moreover, Southern’s planning does not provide for adequate stakeholder participation. The RTO will have two committees to review the planning process, each consisting of one RTO representative, one representative from each Transmission Owner (“TO”) (again, given Southern’s five transmission-owning operating companies that is five votes for Southern), and one market participant representative. This near total dominance by Southern and lack of stakeholder participation will almost certainly compromise the independence of the RTO and frustrate the development of a competitive market in the southeast.
It also appears that Southern’s planning protocol is biased towards a wires solution and does not adequately consider the benefits of generation additions/alternatives or provide adequate incentives for generators or demand response initiatives to relieve congestion through new construction. The planning protocol does include a vague reference to “encouraging investment actions for preventing and relieving congestion internally to the RTO and RTO interfaces.” In addition, Southern’s Petition and the attached discussion of its proposed locational marginal pricing do not provide sufficient detail to ascertain where generation solutions are being properly valued. The remainder of the planning protocol, however, tends to focus on transmission planning in isolation, addressing interconnecting generators only when focusing on interconnection and the construction of the wires to provide service from the facility. Of particular concern with respect to this function is the statement that “[t]he RTO must review and approve any new facility or improvement for inclusion in the RTO’s rates.” The ultimate authority of the Commission over this issue should be clarified and the RTO should be required to employ the Commission’s policies in making its determination, including its determination of whether a facility provides system benefits.