FERC Filings
MOTION TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON TRANSLINK'S PROPOSAL TO FORM AN INDEPENDENT TRANMISSION COMPANY
TARIFF ADMINISTRATION
The Commission should not facilitate the further fragmentation and balkanization of the Midwest markets by allowing TRANSLink to offer its own open access transmission tariff, even though it is proposed to operate in seamless integration with the MISO Tariff. The proposal notes that “TRANSLink will have the exclusive authority to make filings under §205 of the FPA as needed, including proposals regarding performance-based or incentive rates.” TRANSLink’s proposed authority in this regard violates the Commission’s Order 2000 one-stop shopping requirement.
Order No. 2000 cannot be misconstrued. It plainly requires that:
the RTO be the sole provider of transmission service and sole administrator of its own open access tariff…with this, customers have nondiscriminatory and uniform access to regional transmission facilities. This type of access cannot be assured if customers are required to deal with several transmission owners with differing tariff terms and conditions.
Certainly the Commission cannot want separate tariffs for MISO, ARTO, now TRANSLink, and any other organizational entity that files an open access transmission tariff (OATT). Multiple overlaying tariffs in a regional market undermine the Commission’s efforts to achieve seamless, or most recently, standardized, market designs across regions. Rather, any tariff that would meet with Commission approval consistent with Appendix I of the MISO Agreement must be evaluated in the context of supporting the Commission’s standard market design goals.