FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Entergy Services, Inc.-Docket No. RT01-75-000
C. Operational Authority (Characteristic No. 3)
Order No. 2000 directs that the RTO have operational authority for all transmission facilities under its control, and makes it clear that the RTO must have ultimate operational authority for all facilities located within its boundaries. Entergy’s proposal directly contradicts the Commission’s stated intent in Order No. 2000 by proposing that “both the Transco and the SPP [RTO] . . . have full operational authority over their respective transmission facilities.” In order to retain operational control over transmission facilities, an entity must meet and satisfy all of the minimum characteristics and functions of an RTO. Entergy acknowledges that the Transco is, in effect, “under the oversight, and within the umbrella of,” the SPP RTO, and does not, by itself, satisfy all of the required functions of an RTO.
In reality, Entergy’s proposal is backwards, reserving unilateral decision-making authority to the Transco, and rarely permitting the RTO to exercise any oversight ability, as opposed to having the SPP serve as the ultimate authority and delegate certain functions back to the Transco. Entergy has designed the Transco such that it exercises complete operational control over its transmission facilities, allowing the Transco to supersede final RTO authority over the operations of its transmission facilities. This directly contradicts the requirements of Order No. 2000. The RTO must have the ultimate and final operational control over all transmission facilities operating within its region, e.g., if the Transco performs the daily operation of its transmission facilities, then the RTO must have jurisdiction and oversight over those operations. While it may be appropriate for the Transco to exercise limited functional control over those transmission facilities situated within its control area, it should be permitted to do so only as an agent of the RTO, thereby ensuring that full operational authority rests with the RTO. The Commission should clarify that Order No. 2000 requires the oversight and control to be within the jurisdiction of the RTO, and that without such grant of authority, the Transco must be able to prove that standing alone, it satisfies the eleven requirements of an RTO.