FERC Filings
EPSA's Motion to Intervene and Comment on MISO's Proposed Schedule 21
INTRODUCTION
EPSA has vigorously supported the Commission’s effort to develop a seamless wholesale power marketplace through the establishment of Regional Transmission Organizations (RTO’s) whose boundaries mirror prevailing operational and trading patterns. The MISO officers and staff are to be commended for their resolve in developing workable and fair reactive power provisions while continually adhering to the hallmark of a true RTO: independence. Of course, successful RTO development requires balancing a multitude of competing interests for which stakeholder compromise is essential. In this regard, the MISO’s role in providing the forum to vet issues and facilitating compromises when rational players are willing to seek and find them is critical. If compromises cannot be reached, it is the MISO’s responsibility to assemble a tariff that weighs all of the competing interests and, in its independent judgment, creates the best result for stakeholders and customers alike by enhancing reliability, price transparency, non-discriminatory treatment and value maximization.
MISO has done this in the current Schedule 21 filing. While the Schedule 21 filed by MISO requires all stakeholders to compromise on certain features, MISO has taken the lead role in offering a tariff that is workable for the footprint. EPSA urges the Commission to provide the approvals necessary for the proposed Schedule 21 to become effective on October 1, 2004, as the MISO has requested. In addition, EPSA asks FERC to order MISO to make changes to the existing Schedule 2, so that the terms and conditions of service are comparable.
While EPSA recognizes the need to compromise to reach a workable Schedule 21, certain stakeholders have expressed reservations, and suggested additional conditions, that threaten to undermine the progress reflected in Schedule 21. In the comments below, EPSA explains that the Commission should approve MISO’s Schedule 21 because, when implemented, its provisions would:
Enhance reliability for the Midwest ISO grid
Provide comparability among all generators in the footprint
Eliminate a potential seams between RTOs
Protect consumers
Enhance market transparency