FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE RTO WEST STAGE 2 FILING
INTRODUCTION
Avista Corporation,
Bonneville Power Administration,
Idaho Power Company,
NorthWestern Energy, L.L.C.,
Nevada Power Company,
PacifiCorp,
Portland General Electric Company,
Puget Sound Energy, Inc.,
Sierra Pacific Power Company
Docket No. RT01-35-005
The Electric Power Supply Association (EPSA) hereby files comments in the above-captioned proceeding in response to the “Stage 2 Filing and Request for Declaratory Order Pursuant to Order No. 2000” (RTO West Stage 2 Filing or Stage 2 Filing) made on March 29, 2002, by Avista Corporation, Bonneville Power Administration, Idaho Power Company, NorthWestern Energy, L.L.C. (formerly the Montana Power Company), Nevada Power Company, PacifiCorp, Portland General Electric Company, Puget Sound Energy, Inc., and Sierra Power Company (collectively, the Filing Utilities). The Stage 2 Filing represents the efforts of the Filing Utilities to form a Regional Transmission Organization (RTO) in the Northwestern United States (hereinafter RTO West).
EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. These suppliers, who account for more than a third of the nation’s installed generating capacity, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.
EPSA supports the progress that RTO West has made and believes that the current proposal goes a long way toward the development of a fully competitive market in the Northwest. This is a good start for RTO West development; it is imperative that the plan continues to move forward to achieve full RTO operations. However, there are flaws in the Stage 2 Filing that could result in a discriminatory and disjointed market in the Northwest, inhibiting the development of a unified regional market for the Western Interconnection. These inadequacies are described in detail in the comments of the Northwest IPPs/Marketers Group (“IPP/Marketers”) that are being contemporaneously filed in this docket. EPSA supports the recommendations and conclusions of the IPP/Marketers. As a national trade association, however, EPSA’s comments address broader policy concerns with the independence, authority and design of the RTO West proposal. EPSA also addresses the need for FERC direction in achieving timely resolutions of seams issues between the RTO West and the other two emerging ISOs in the Western Interconnection.