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FERC Filings

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

1. Transmission Rates and Scheduling

Although the Umbrella Agreement states that “there shall be no pancaked rates for transmission service with respect to transactions using both the Transco and SPP systems,” the SPP Partnership RTO MOU (“Umbrella Agreement”) states that:

<sup>Transco will have the control over those portions of the tariff that affect the commercial terms and conditions of transmission service over Transco’s facilities. Transco shall possess the unilateral right, without receiving any SPP or Partnership RTO approval, to make filings at FERC proposing rate or rate structure changes (including incentive rate structures) involving transmission charges for service to load within the Transco or transmission service that does not cross any of the SPP transmission operator facilities. Transco also retains the right to unilaterally make filings at FERC for the purposes of implementing new transmission services that are not contained in the RTO Transmission Tariff . . . . <sup>30</sup> </sup>

While EPSA does not necessarily oppose the Transco’s unilateral authority to make filings at FERC for the purposes of implementing new transmission services that are not contained in the RTO tariff, the “exclusive and independent authority” of the RTO to propose rates, terms, and conditions for transmission service under Section 205 of the FPA cannot be shared with the Transco, in the manner in which Entergy proposes. The RTO may transfer certain of its functions to the Transco, but any such delegation of duty must be subject to the direct oversight and final authority of the RTO.

Furthermore, the Umbrella Agreement states that the “Transco will be responsible for conducting studies and scheduling transactions on the Transco’s system and shall be the provider of last resort for ancillary services.” The Transco should not be permitted to schedule transmission services independently of the RTO.