FERC Filings

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

CONGESTION MANAGEMENT

As presented, the TRANSLink congestion management proposal is not consistent with Order No. 2000, which requires that congestion management be performed at a regional level “by the RTO itself or with another entity that is not affiliated with any market participant.” As demonstrated above, the independence of all market participants is questionable at best. The Commission should not allow such a critical function as congestion management to be performed by an entity that has strong affiliation to certain market participants.

The TRANSLink filing contains a number of holes that concern EPSA’s members and should be of concern to the Commission. For example, the details of how the Day One congestion management will work in conjunction with the MISO congestion management Day One protocols are not solidified, and the details pertaining to Day Two are all but nonexistent. Based on this information, or lack thereof, EPSA strongly urges the Commission to not approve TRANSLink’s proposal. Allowing the ITC to develop its own congestion management, particularly one that is not completely compatible with the MISO system, would undermine one of the most important functions of an RTO – an entity that is better suited to perform this function efficiently. Perhaps the Commission should defer consideration of TRANSLink’s congestion management proposal until the MISO congestion management system is solidified. Moreover, any congestion management proposal eventually needs to be consistent with the Commission’s evolving standard market design efforts.

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