FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE MEDIATION REPORT FOR THE SOUTHEAST RTO

Operational Authority (Characteristic 3):

In the CGM Model, the control area operators will continue to physically control the system, but they will do so pursuant to operating procedures approved by the IMA and under the direction of the IMA. While the CGM RTO Operating Protocol Summary generally provides many of the details of this separation, the Protocol Summary is just a starting point and further details remain to be defined during the collaborative process.
EPSA strongly believes that there should be no balanced schedule requirements or financial penalties for imbalances. There is no evidence that such requirements improve the reliability of the transmission grid. Financial consequences of imbalance should be delivered through market price signals in the energy imbalance and other reliability markets. Maintenance of a balanced schedule requirement would frustrate market development and lead to higher energy balancing and ancillary services costs because:
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current transmission reservation and scheduling advantages enjoyed by load-serving entities could be maintained and the incumbent utilities’ network resources could preserve their competitive advantages given that not all generation resources would have equal access to the transmission grid; and

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no meaningful real-time balancing market would develop to efficiently clear the market or to send appropriate economic signals.