FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Comments Regarding Retail Electric Competition-V010003

IX. Comparable Transmission Service

The development of a seamless national transmission system wherein all transmission usage is accorded fully comparable treatment is vitally important to the growth of a competitive power industry. EPSA believes that the establishment of RTOs represents one of the next step towards that end. The prospect of real competition continues to be threatened by, among other things, the manifest lack of comparability between certain wholesale and retail transmission pricing and access policies resulting from the discriminatory exemption of all native load from open access rules. The elimination of residual discrimination will occur only when all uses of the transmission grid are under the same rate schedules, terms and conditions.

With actual comparability, the transmission owner’s interest would be to operate the grid as a stand-alone business and maximize throughput, rather than to use transmission to increase the return on its investment in power generation, marketing and sales. With its incentives aligned in this manner, the transmission operator could be expected to pursue those regional combinations that make the most business sense. Thus, comparability is critical if competitive power markets are to achieve their full potential.

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