FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Southern Company Services, Inc.-Docket No. RT00-77-000
The proposed configuration of the Southern RTO is indicative of Southern’s objective of maintaining dominance in its region, not of any public interest objective.
Order No. 2000 requires that an RTO serve an appropriate region – “a region of sufficient scope and configuration to permit the RTO to effectively perform its required functions and to support efficient and non-discriminatory power markets.” Southern fails to adequately address the issue of whether the RTO can “effectively support non-discriminatory power markets.” Although there are five other transmission owners (all public power entities) that are identified in the Petition as potential participants in Southern’s RTO, they are small, even when combined, when compared to Southern. One investor-owned utility (which is still maintaining significant control) does not make an RTO.
Moreover, Southern’s generation dominance in the region, coupled with its ability to reserve transmission for native load and future resources, will not lead to the development of competitive power markets in the Southeast. Although Southern claims there are numerous wholesale plants under development on its system by totaling the magnitude of its requests for interconnection, many of those plants might not be built. A request for interconnection is not a commitment to build and Southern does not attempt to identify or exclude requests that may constitute alternative scenarios for developers.
Southern’s RTO maintains the status quo in the region. In short, Southern has failed to make the clear demonstration of any benefit arising from its proposed configuration that indicates that the formation of the RTO is in the public interest. The Commission should set for hearing the proposed configuration and investigate whether the public interest would be better served by a different configuration, compelling Southern to act accordingly. Southern’s proposed RTO is not of sufficient scope that it will dilute Southern’s dominance and it does not, and cannot, include adequate precautions that will deter the exercise of market power by Southern.