FERC Filings

EPSA's Comments and Motion to Intervene in Duke's ITE Proposal

Conclusion

WHEREFORE, for the reasons set forth above, EPSA respectfully requests that the Commission grant its motion to intervene in this matter. EPSA generally supports the retention of ITEs in order to enhance open access in non-RTO markets. While the ITE is not a panacea to the problems that currently restrict true open access, EPSA believes that the ITE concept is an important tool that the Commission can use alongside to other measures— such as Order 888 reform – to enhance open access and, hence, competition. That said, in order for the ITE concept to have any real positive effect on open access, the relationship between the ITE and the transmission owner that hires it must be structured in such a way as to ensure that the ITE has the freedom to perform in a truly independent manner and that the ITE is able to independently administer the full host of OATT functions that provide real, non-discriminatory open access.

EPSA believes that the Duke IE proposal is a significant step in the right direction, and offers provisions that improve on the flawed Entergy ICT proposal. EPSA urges the Commission to review the Duke proposal in light of the core principles outlined herein.

Respectfully submitted,

Nancy Bagot , Vice President of Regulatory Policy
Jack Cashin, Senior Manager of Policy
Electric Power Supply Association
1401 New York Ave, NW
11th Floor
Washington, D.C. 20005
Phone: 202-628-8200

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