FERC Filings
MOTION TO INTERVENE AND COMMENT OF THE ELECTRIC POWER SUPPLY ASSOCIATION-RTO West-Docket s No. RT01-35-000, RT01-15-000
Specific Concerns with One-Stop Shopping for Transmission Service, Rate Pancaking and the Ability to Interconnect New Generation.
EPSA has serious concerns with the extent of control RTO West will have over transmission in the Northwest. The exclusion of particular facilities from RTO West’s control will have a serious impact on the interconnection to the transmission grid of vital new generation, and the Commission’s goal of one-stop shopping and eliminating rate pancaking. Simply put, the RTO will not be able to perform the various functions required of it, functions that are essential to the development of a competitive bulk power market, if the facilities necessary to do so are not under its control.
It is not clear from the RTO West filing that certain transmission facilities forming the backbone of transmission in the Northwest will be under the control of RTO West. The specific facilities to be included are not set forth in the filing. Rather, the filing only states that the facilities under the control of the RTO West will be those facilities that have a material impact on: (1) transfer capabilities of RTO West managed constraint paths between its congestion zones, (2) the ability to transfer electric power within a congestion zone, or (3) the ability to transfer electric power and energy into or out of the RTO West transmission system. Moreover, distribution facilities that meet the definition of grid transmission facilities, because the facilities may have secondary impacts on the transfer capability of some regional grid paths, can be retained by participating transmission owners.
Specifically, facilities which comprise the backbone of the transmission system in the Pacific Northwest and into Canada may be excluded. For example, Puget Sound is apparently proposing to reclassify, as distribution, high voltage lines (230 KV) which operate in parallel with the 500 KV lines to form the interconnection between the United States and Canada. Theses lower voltage parallel facilities have an effect on the transfer capability between the Northwestern U.S. and British Columbia and therefore should not be excluded from the RTO’s control. As such, the Commission should instruct RTO West that such exclusions are inappropriate. Finally, it is not clear from the TransConnect filing that the member companies will not seek to refunctionalize major facilities from transmission to distribution. As such, in reviewing the Stage 2 filing, the Commission should closely review the facilities under the control of RTO West to ensure that all facilities necessary for market participants to engage in any sales of electric energy subject to the Commission’s jurisdiction, requiring any transmission within, through or out of the RTO West region, are subject to the rates, terms and conditions of a single RTO West tariff.
In addition, merely because some facilities might be classified as distribution does not mean that those facilities are not essential to the transmission grid or the Commission’s goal of facilitating a competitive bulk power market. First, in order to meet the Commission’s goal of one stop shopping, RTO West must have the authority to schedule service over all facilities, regardless of classification, if needed to provide a transmission service. Second, new generation in the Northwest could be interconnected to low voltage facilities. Order No. 2000 requires that RTO West have direct authority over generation interconnection. Individual RTO West members should not be allowed to circumvent RTO West or Commission jurisdiction over new generation interconnection merely by withholding such facilities from RTO West’s control or reclassifying certain facilities as distribution.
For transmission under the control of RTO West, Section 4 of the Transmission Owners Agreement (“TOA”) provides that RTO West can resolve disputes, thus expediting the interconnection of facilities. EPSA supports this provision. The RTO must have the authority to set the standards under which generation will be interconnected to the transmission grid and to enforce the rules if problems occur. Simply put, interconnection policy cannot be left to the former transmission owners which may continue to have generation or marketing affiliates competing in the wholesale market with the generation seeking interconnection to the grid. However, if the generation is not interconnected to facilities under the control of the RTO, such protections will not be available. This concern is compounded for the transmission owners that are part of TransConnect. If the facilities to which new generation is interconnected are not part of TransConnect, there is a very real question as to the authority RTO West will have to enforce its standards for interconnecting to the grid.