FERC Filings
PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Southwest Power Pool, Inc.- Docket No. RT01-34-002
Introduction/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 moves to protest the above-captioned proceeding. On May 25, 2001, Southwest Power Pool, Inc. (“SPP”) submitted to the Commission a compliance filing, again seeking recognition as a Regional Transmission Organization (“RTO”) pursuant to the Commission’s requirements as set forth in Order Nos. 2000 and 2000-A.
Although EPSA generally supports the SPP’s ongoing efforts to comply with the Orders, its current filing still does not substantively address the issues raised in EPSA’s November 20, 2000 Motion to Intervene and Protest in response to an earlier SPP RTO proposal. The latest SPP proposal is still at odds with the Commissions’s requirements for the formation of RTOs, established in the RTO Orders, and their compliance efforts do not go far enough.
EPSA again urges the Commission not to accept portions of the SPP’s proposal, or to grant RTO status to the SPP until it fully complies with the Commission mandates.
On October 13, 2000, pursuant to the Commission’s Order No. 2000, the SPP filed its RTO proposal with the Commission. On November 20th EPSA filed a timely Motion to Intervene and Protest in response to the October 13th filing made by the SPP. In that filing EPSA asserted that the SPP proposal had excessive grandfathering of existing transmission uses, primarily for native load, hindering the growth of comparable open access.
Additionally, the comments raised concerns about the SPP’s lack of specifics regarding its congestion management system, an unmanageable governance structure weighted toward transmission owners, and the failure of SPP tariff to address interconnection provisions. Finally, the comments submitted that the SPP RTO Proposal violates Order No. 2000’s with respect to the transmission owner’s control over rate methodology.
On March 28, 2001 the Commission issued an Order in Docket Nos. RT01-34 and RT01-75 finding that SPP still fails to satisfy its scope and configuration requirements. The Commission also required additional evidence of the SPP’s discussions with adjoining entities about expanding the SPP, evidence of SPP membership agreements with non-jurisdictional entities, operating protocols between SPP and Entergy, and further documentation on congestion management and balancing. On May 25, 2001 the SPP made this compliance filing in response to the Commission March 28th Order.
The May 25th filing is not significantly different from the October 13th filing and consequently, the key concerns EPSA raised in its Motion to Intervene and Protest remain. For those reasons, EPSA incorporates by reference its November 20th comments on the October 13th filing and incorporates those arguments into this protest to the May 25th filing. EPSA is especially concerned that SPP’s March 25th Proposal fails to properly address the transition from existing grandfathered contractual arrangements for bundled retail load to a system where all transmission service is provided under the RTO Tariff.
EPSA urges the Commission to deny the SPP RTO status and compel the SPP to address the issues EPSA put forth in its November 20th filing.
June 18, 2001
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