FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Entergy Services, Inc.-Docket No. RT01-75-000
B. Scope and Regional Configuration (Characteristic No. 2)
An RTO must be “of sufficient scope and regional configuration to permit the RTO to effectively perform its required functions and to support efficient and nondiscriminatory power markets.” This requirement is designed to prevent the formation of RTOs that are either too limited in scope to satisfy the necessary functions or are an attempt to prevent the formation of a larger, more appropriately configured, RTO.
In order to satisfy all eleven requirements of an RTO, both the Transco and the SPP RTO must be fully integrated with one another. Entergy claims that the size of its Transco when combined with the SPP RTO, will be comparable to the New York, New England and PJM ISOs, and it encourages the Commission to consider the combined systems of both the Transco and the RTO when evaluating this criteria. Entergy does not propose that the configuration of its Transco alone would meet the configuration requirement for an individual RTO. Its Transco is made up almost exclusively of Entergy-owned transmission companies, which, when taken by themselves, do not meet the scope and configuration requirements of an RTO. The proposed structure of Entergy’s Transco within the SPP, e.g., that it has unilateral control over functions that reside properly within the authority of the RTO, does not promote a contiguous control area such as the Commission designed in Order No. 2000. The Commission should clarify that the scope and regional configuration characteristic for RTOs requires that primary decisional authority resides with the RTO, and not with the transmission owners (i.e., Entergy’s Transco) within its boundaries. If modified, however, to ensure appropriate conveyance of decisional authority to the RTO, EPSA believes that the SPP/Entergy Transco is reasonably sized to satisfy the scope and regional configuration requirement of Order No. 2000.