FERC Filings

MOTION TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON TRANSLINK'S PROPOSAL TO FORM AN INDEPENDENT TRANMISSION COMPANY

BACKGROUND

In this proceeding, the TRANSLink Participants propose to create an ITC that will carry out certain transmission-related functions in cooperation with the MISO. Centered on the guidance provided in Commonwealth Edison Co., where the Commission approved the proposed hybrid or “binary” RTO model, the TRANSLink Participants ask the Commission to find that their proposal meets the minimum requirements of Order No. 2000. The TRANSLink Participants have established the fourth quarter of 2002 as the targeted date to commence commercial operations, assuming receipt of the required regulatory approvals, and ask the Commission for expeditious consideration of the filing.

As filed, the TRANSLink Participants propose to contract with one or more Commission-approved RTOs to perform certain RTO-required functions, recognizing that the Commission requires TRANSLink to demonstrate that it possesses certain characteristics of an RTO, even though it does not propose to establish TRANSLink as an RTO.

The Commission recently announced its intention to proceed with RTO development along two parallel tracks, with RTO geographic scope and governance issues addressed in pending “RT” dockets, leaving generator interconnection and market design matters for resolution in the Commission’s forthcoming rulemaking proceedings. Accordingly, EPSA focuses on independence and governance and associated market issues in this Protest. While recognizing that the Commission may elect to defer market design matters for later consideration, EPSA will provide comments on certain troubling aspects of the TRANSLink proposal.

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