FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Entergy Services, Inc.-Docket No. RT01-75-000

II. PROTEST

EPSA supports the establishment of independent, for-profit transmission companies. For Transcos that operate under the auspices of a broader RTO, such as the Entergy proposal, it is critical to insure that adequate authority over transmission functions, such as transmission planning and congestion management remain with the RTO and not the Transco. Although Entergy claims that its Transco proposal, when combined with the SPP RTO, “will comply with [the four] minimum characteristics on the date the RTO commences operations,” upon review of the details of its proposal, it is clear that Entergy’s proposal fails to meet these minimum characteristics, and as a result, does not meet the Commission’s requirements for an RTO.

It is undisputed that Entergy’s initial Transco proposal lacked certain of the characteristics that Order No. 2000 requires of an RTO. In this revised proposal, Entergy has attempted to avoid the requirements of an RTO by placing its Transco under the umbrella of the SPP RTO. In doing so, Entergy has reserved for its Transco certain of the functions and characteristics that must instead be the responsibility of the RTO. Entergy’s proposed Transco is not an RTO and no where in Entergy’s proposal does it suggest that the Transco should be an RTO; therefore, it should not be permitted to reserve the rights and responsibilities of one.

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