FERC Filings
MOTION TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON TRANSLINK'S PROPOSAL TO FORM AN INDEPENDENT TRANMISSION COMPANY
OTHER CONSIDERATIONS
The TRANSLink filing contains a number of other additional proposals that EPSA finds worrisome. In particular:
- Operational Authority – As proposed, TRANSLink will exercise functional responsibility for the operation of the participating transmission systems. Non-jurisdictional entities, however, will retain the authority to exercise direct control of transmission operations, as well as monitor and control real and reactive power flows and voltage levels. In Commonwealth Edison, the Commission stated that “providing that an actual ITC filing meets the independence and scope requirements of Order No. 2000, assigning primary operational authority to the ITC should not conflict with Order No. 2000.” Before approving any operating protocols that relinquish any RTO functions to the ITC, the Commission should require TRANSLink to demonstrate that it has sufficient scope and configuration, not to mention independence, of an ITC.
- Ancillary Services – TRANSLink proposes to function as the provider of last resort for ancillary services, as well as provide a number of other ancillary services in conjunction to the MISO. It is most efficient for a large regional entity, in this case MISO, to supply such services. Approving the TRANSLink proposal has the potential to undermine MISO’s ancillary services markets. Consistent with the Commission’s wishes in Order 2000 to promote competitive ancillary services markets, TRANSLink should not be a substitute to providing a market for ancillary services.
- Planning and Expansion – TRANSLink proposes to be responsible for planning on its system as well as physical construction of new facilities, and announces its plans to coordinate with MISO in this process. In Commonwealth Edison Co. the Commission recognized that the “dual responsibilities” of the ITC and MISO for planning and expansion might satisfy the requirements of Order No. 2000. More recently, the Mediation Report for the Southeast RTO, attempted to strike a reasonable balance between those functions that should be performed by the RTO and those that can be performed by the ITC. The procedures regarding that balance should be established by the RTO be specified in its tariff and subject to the RTO’s review and approval. The Commission should guarantee that its standards for independence and scope and configuration are indeed met for any entity that is involved with planning and expansion of the grid.