FERC Filings
PROTEST AND REQUEST FOR CONSOLIDATION OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Docket No. RT01-85-000, Docket No. RT01-82-000, Docket No. RT01-83-000, Docket No. RT01-92-000
Introductions/Body/Conclusion
Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. §§ 385.211 and 385.214, the Electric Power Supply Association (EPSA) hereby files this protest and requests that the above-captioned proceedings be consolidated in one docket.
On June 1, 2001, pursuant to the Commission’s April 26th Order requiring them to do so, the California Independent System Operator (CAISO), Southern California Edison Company (SoCal Edison) and San Diego Gas & Electric Company (SDG&E), jointly, and Pacific Gas & Electric Company (PG&E), filed proposal for a regional transmission organization (RTO) (June 1st Filings). By Notice issued June 4, 2001, the Commission established June 19, 2001 as the deadline for comments and protests in response to the June 1st Filings.
On February 22, 2001 EPSA filed a timely Motion to Intervene, Protest and Request for Consolidation in these dockets in response to January 16, 2001 RTO filings made by the CAISO, PG&E, SoCal Edison, PG&E and the now-defunct California Power Exchange Corporation (Cal PX). In that filing EPSA asked that the filings be consolidated into one docket and objected to certain key aspects of the January 16th filings. Specifically, EPSA asserted that the CAISO Board did not meet the Commission’s independence requirements, a concern that has been reiterated in several subsequent EPSA filings. EPSA has asked the Commission to replace the CAISO Board with one that meets the independence requirements.
EPSA also focused on the critical need for a seamless regional grid throughout the West. In its June 1st Filing, PG&E states that it “strongly supports a multi-state RTO as the best approach to managing market solutions and increasing reliability.” PG&E reaffirms its commitment to “working with the California ISO and others in the West to achieve a FERC-approved Western RTO.” EPSA urges the Commission to require the California utilities to join Desert Star and/or RTO West to achieve the goal of a single western RTO.
The June 1st Filings are not significantly different from the January 16th filings made by the same entities. Once again, EPSA’s key concerns focus on the lack of an independent CAISO Board and the pressing need for a single Western RTO, neither of which is adequately addressed in the June 1st Filings. For those reasons, EPSA is incorporating by reference its February 22, 2001comments on the January 16th RTO filing and incorporating those arguments into this protest of the June 1st Filings.
As stated before, we urge the Commission to:
1. Order the CAISO Board be replaced by a Board that meets the Commission’s standards for independence; and
2. Require the California investor owned utilities to join Desert Star and/or RTO West in order to ensure the establishment of a unified and seamless regional market for the Western Interconnection.
The CAISO asserts that it “satisfies, or will satisfy upon the completion of ongoing reform effort, the requirements that Order No. 2000 establishes for RTOs.” This is simply not the case with respect to critical aspects of Order No. 2000, including independence and regional size and scope. The CAISO recently asserted that the “western market is interdependent and California is, and for the foreseeable future will remain, a net importer of electricity.” PG&E agrees, stating in its filing that:
California is a net importer of up to one-third of its daily energy needs. With that reality, it is not possible to solve the market dysfunction problems within California alone. The Western region is a series of markets that are integrally interconnected, and the Commission correctly recognizes that broad regional solutions are a necessary part of any long-term effort to maintain reliability, improve efficiency and lower costs.
Nonetheless, the CAISO, doggedly refuses to embrace a western-wide RTO, insisting in its filing that “formation of an Interconnection-wide RTO would not be prudent at this time.”
Given the CAISO’s intrangence, it is time for the Commission to act decisively. EPSA urges the Commission to consolidate these filings, require the establishment of an independent CAISO Board and require the development of a single RTO for the entire Western grid.
Respectfully submitted,
Julie Simon
Vice President of Policy
Electric Power Supply Association
1401 New York Avenue, NW
11th Floor
Washington, DC 20005
(202) 628-8200