FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Southern Company Services, Inc.-Docket No. RT00-77-000
Generators interconnecting to transmission facilities 40 kV and higher are interconnecting directly to the RTO and are not subject to the operational control of the transmission owners.
Southern’s petition proposes to assign control of “transmission facilities with a high side voltage of 40 kV or more and transformation facilities with a high side voltage of 40 kV or more and a capacity of 500 kVA or more, excluding generator step-up substations and those substations serving auxiliary equipment for generating plants.” The meaning of Southern’s exclusion is not clear. Order No. 2000, in evaluating whether an RTO was of sufficient scope, indicated that the Commission would examine whether an RTO provides “one-stop shopping and further requires the RTO to serve as the interconnection authority.” The Commission should require Southern to clarify that generators connected to, and connecting to, the 40 kV system and higher will need only make a request for interconnection service to the RTO and will not be required to arrange interconnection or transmission service from any other transmission provider except the RTO in order to accomplish the delivery of their energy to the RTO system.
If the Commission accepts Southern’s proposed distinction between those facilities that are to be transferred to the RTO, and those that will not be, the Commission should emphasize that solely the RTO OATT is to govern interconnection to the RTO facilities and that all facilities necessary to accomplish a safe and reliable interconnection are under the control of the RTO or generator, not the transmission owners. Indeed, the Commission has recognized that an RTO should serve as a one-stop shop for interconnecting generators.