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FERC Filings

Intervention and Request for Comment of EPSA re: Southwest Power Pool Inc.

Introduction

Southwest Power Pool, Inc.

Docket No. RT04-1-000
Docket No. ER04-48-000


Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.211 and 385.214, the Electric Power Supply Association (“EPSA”) hereby moves to intervene and comment in the above-captioned proceeding. On October 15, 2003, Southwest Power Pool, Inc. (“SPP”) submitted to the Commission a request to be recognized as a Regional Transmission Organization (“RTO”) pursuant to the Commission’s requirements set forth in Order Nos. 2000 and 2000-A. SPP further asserts that it conforms with the guidance contained in the Commission’s White Paper on the Wholesale Market Platform issued April 28, 2003.

EPSA welcomes and supports SPP’s ongoing effort to establish a viable, well-functioning RTO in accordance with the Commission’s Orders and White Paper guidance. The current filing reflects significant progress, including important steps toward an independent board and the outlining of specific market development milestones. EPSA appreciates SPP’s effort to provide a schedule within which stakeholders can work to achieve the level of detail that is required for SPP to successfully operate as an RTO.

EPSA supports the direction SPP is headed, however certain critical elements must be resolved before SPP can become a fully functioning RTO. Of particular concern to EPSA is the need to have a transition plan for grandfathered contracts. EPSA has raised this issue in its response to every past SPP proposal; the significant segment of the market that grandfathered contracts monopolize in SPP remains a serious concern.

The Commission itself has recently noted the importance and difficulty associated with the grandfathered contracts issue in RTO development. Clearly, further stakeholder effort is needed to better define grandfathered contracts and establish a transition plan that will allow for the development of a well-functioning competitive market in SPP.