FERC Filings
Motion of EPSA for Leave to Intervene and Comment on the Midwest Independent System Operator's Open Access Transmission and Energy Markets Tariff Filing
Preface
Pursuant to Sections 212 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. § 385.212 and 214, the Electric Power Supply Association (EPSA) respectfully files this motion for leave to intervene and comment in the above-captioned proceeding. In an advisory order issued on October 29, 2003 (Advisory Order), to allow it to further develop key tariff elements , the Commission accepted the Midwest Independent Transmission System Operator, Inc.’s (MISO) motion to withdraw the Open Access Transmission and Energy Markets Tariff (EMT) it filed on July 25, 2003. Thereafter, after months of diligent work with its stakeholders, on March 31, 2004, the MISO filed the revised EMT containing a more complete market design plan, including the abbreviated or omitted items from the previous tariff filing.
EPSA applauds the progress that MISO and its stakeholders have made, and the substantial steps taken to comply with the guidance provided in the Advisory Order. As the filing recognizes, further discussion of certain aspects of the proposed market design will be useful to continue to improve the Centralized Dispatch platform and related market features. Among other specific items discussed below, it is particularly important for the Commission to address the concerns relating to the continued existence of multiple control areas within the MISO footprint by requiring consolidation by a date certain. However, to avoid the increased costs associated with further delays, it is imperative that the Commission affirm and maintain the December 1, 2004 market implementation date set forth in the filing. Accordingly, subject to the constructive critique and suggested clarifications necessary to optimize the performance of the EMT, EPSA urges FERC to approve the MISO’s EMT expeditiously to enable consumers to enjoy the benefits that the MISO will deliver.