FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Entergy Services, Inc.-Docket No. RT01-75-000
F. Congestion Management (Function No. 2)
Order No. 2000 requires an RTO to manage transmission congestion through the development and operation of market mechanisms. No single particular method of congestion management is required, and RTOs are given substantial flexibility in developing mechanisms for congestion management, although an RTO may not compromise its independence and be held captive to demands for particular congestion management systems by Market Participants.
As proposed, the Umbrella Agreement states that “[t]he Transco and the SPP agree to work together in an effort to develop a single regional approach to congestion management. If the SPP so requests, Transco agrees to make its congestion management system available to SPP members at cost.” SPP also has the option of developing its own separate congestion management system, subject to coordination with the Transco’s own congestion management system. The implementation and management of a congestion management system is critical to ensuring the non-discriminatory operation of the RTO’s markets. The RTO must be charged with the sole authority to operate and manage congestion for the entire region. Two congestion management systems would lead to a balkanization of the grid and, likely, inefficient utilization of the grid in the region, as the systems could in fact be sending confusing price signals. The Commission should reject such request as inconsistent with Order No. 2000 requirement that there be only one RTO-wide congestion management system operating in the SPP RTO.
Moreover, Entergy conditioned its participation in the SPP RTO “on final development of an acceptable congestion management approach . . . .” The Commission should require that the SPP RTO, in a non-discriminatory manner and with input from stakeholders, including Entergy, develop a congestion management system by a date certain for filing with the Commission. The Commission must require the RTO, and not the individual control area operators, to possess sole responsibility for the operation of each regions’ congestion management system.