FERC Filings

MOTION TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Carolina Power & Light Company , Duke Energy Corporation, South Carolina Electric & Gas Company, GridSouth Transco, LLC - Docket No. RT01-74-000

4. Function 8: Interregional Coordination

In their RTO proposal, the Applicants summarily conclude that GridSouth “will satisfy” this critical RTO function. The entire basis for their claim that the filing satisfies this function is that they have “begun participating in” discussions with “neighboring RTOs” regarding information sharing, common practices and coordinating operations. They also make a vague reference to future participation in “inter-regional forums.”¹⁸ This aspect of the GridSouth proposal ignores the importance the Commission attached to it in Order No. 2000 and is clearly inadequate.

When discussing interregional coordination and its expectations for compliance filings under Order No. 2000, the Commission stated that “[a]n RTO proposal must explain how the RTO will ensure the integration of reliability and market interface practices.” ¹⁹ While not requiring uniform practices, the Commission emphasized that “RTO reliability and market interface practices must be compatible with each other, especially at the ‘seams.’” The objective that RTOs must accomplish is to “ensure that market activity is not limited because of different regional practices.”²⁰

Currently, reliability and commercial rules vary significantly from region to region. EPSA believes it is vitally important to the Commission’s goal of robust competitive markets that the differences not disrupt transactions flowing across regional boundaries. In its Order, the Commission correctly observed that to integrate market interface practices RTOs must develop “some level of standardization of inter-regional market standards and practices, including the coordination and sharing of data necessary for the calculation of TTC and ATC, transmission reservation practices and congestion management procedures, as well as other market coordination requirements.” ²¹

In establishing minimum requirements under Order No. 2000, the Commission concluded that “[i]f it is not possible to set forth the coordination mechanisms at the time an RTO application is filed, the RTO applicant must propose reporting requirements, including a schedule, for itself to provide follow-up details as to how it is meeting the coordination requirements of this function.”²² The GridSouth proposal falls far short of satisfying this requirement and, in conjunction with other deficiencies explained herein, provides clear grounds for denying GridSouth RTO status.

The GridSouth proposal creates serious uncertainty for market participants and other stakeholders regarding the likelihood that the Applicants will ultimately satisfy several key characteristics and functions contained in Order 2000. The Applicants’ proposal is generally deficient in several significant respects; the documents pursuant to which the RTO will be created are incomplete and unexecuted and critical details relating to rates, incentives and market structure are deferred. On balance, the Applicants have presented a blueprint for an airplane without wings. If it can’t fly, the Commission should not let it out of the hangar.¹⁸ Id.

¹⁹Order No. 2000 at 31,167.

²⁰Id.

²¹Id at 31,168.

²² Id at 31,167.

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