FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Entergy Services, Inc.-Docket No. RT01-75-000
D. Short-Term Reliability (Characteristic No. 4)
Order No. 2000 requires an RTO to have “exclusive authority for maintaining the short-term reliability of the grid that it operates.” In other words, the RTO has the sole authority to: (1) receive, confirm and implement all interchange schedules; (2) order redispatch of any generator connected to transmission facilities it operates if necessary for the reliable operation of those facilities; (3) approve and disapprove all requests by non-RTO-owned transmission facilities for scheduled outages to ensure accommodation within reliability standards; and (4) report to the Commission if a regional reliability council’s standards hinder the RTO’s ability to provide reliable, non-discriminatory and efficiently priced transmission service.
Despite the Commission’s directives, the Transco proposal improperly retains the authority to maintain the short-term reliability of transmission facilities within its control area, absent oversight and final determination by the RTO. For example, the Transco will be permitted to provide redispatch alternatives to the RTO as Security Coordinator for transactions that will affect the Transco’s flow gates. However, the Transco is not an RTO, and the Commission should clarify that the RTO possesses the ultimate determination on the propriety of any curtailments or redispatch. If the functions and responsibilities of the RTO are assigned to the Transco, then a hole will be created within the RTO’s structure. Order No. 2000 is explicit in its requirement that a control area operator, such as the Transco, must be subject to the limitations, jurisdiction and oversight of the RTO. EPSA requests that the Commission reject Entergy’s proposal and require that the ultimate authority to monitor and control short-term reliability reside with the RTO, not the Transco.