FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE MEDIATION REPORT FOR THE SOUTHEAST RTO
Independence/Governance (Characteristic 1):
EPSA supports the CGM Model because it meets the Commission’s independence/governance requirements of Order No. 2000. For example, under the CGM Model the Stakeholder Advisory Committee (SAC) is the entity that selects the Independent Market Administrator (IMA). EPSA believes that this selection process best adheres to the ideal of independent selection without transmission owner (TO) control over the process. While EPSA prefers the CGM model’s use of the SAC as compared to the SeTrans model, EPSA does have concerns about the makeup of the SAC. EPSA strongly believes that all stakeholder advisory committees should reflect fair representation between stakeholder groups. Therefore, the composition of the CGM Model’s Board Selection Committee and SAC should be modified to ensure equal representation.
EPSA is also concerned about the specific delineation of functions in the CGM Model between the Transco, the IMA and independent transmission companies (ITCs). The CGM Model does not currently contain adequate details with regard to this delineation of functions. Additionally, it is not clear under the CGM how permanent the IMA will be on a going-forward basis. EPSA suggests that the permanence of the IMA is a significant detail that must be addressed by the Commission or the collaborative stakeholder process.
