FERC Filings
EPSA's Motion to Intervene Out of Time in Entergy Services, Inc. Proceeding
Motion to Intervene Out of Time
EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for nearly 40 percent of the installed generating capacity in the United States, 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.
On September 2, 2005, Entergy Services Inc., submitted a Section 205 filing proposing modifications to its Open Access Transmission Tariff (OATT) Schedule 2 regarding reactive supply and voltage control services from generation sources. The instant filing proposes that Entergy’s schedule 2 be modified to do the following: (1) set to zero the charge currently levied by Entergy for the provision of reactive power from Entergy from Entergy’s own generating units, and (2) pass through to its transmission customers the costs that third party generators are currently charging Entergy for reactive power. Entergy requests an effective date of November 1, 2005, for its tariff modification.
Concurrent to the Section 205 filing, Entergy filed a Petition for Declaratory Order in Docket No. EL05-149-000 requesting that the Commission confirm that if Entergy does not compensate its own or affiliated generators for reactive power service provided to transmission customers within the generators’ specified power factor range or dead band, then Entergy need not compensate a non-affiliated generator for maintaining reactive power within the dead band on a prospective basis.
EPSA’s members are active participants in Entergy’s control area. EPSA and its members remain concerned about Entergy’s market power and the process by which it acquires resources to meet its service requirements. Additionally, EPSA commented on the Commission’s February 4, 2005 staff report, “Principles for Efficient and Reliable Reactive Power Supply and Consumption” (Report) in Docket No. AD05-1-000. Therefore, any proposal regarding compensation for reactive power is of significant interest to EPSA and its members. Reactive power OATT modifications as proposed by Entergy could prove to have far reaching impacts regarding compensation for ancillary services in general and reactive power specifically. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
EPSA submits that good cause exists for its motion to intervene out of time. Due to the need to coordinate discussion among our membership and review Entergy’s proposal as a case that may introduce issues of general policy regarding the compensation and treatment of reactive power, EPSA’s motion for intervention is delayed. Due to the policy ramifications of Entergy’s proposal and Petition for Declaratory Order, however, it is important that EPSA, as a national trade association representing competitive suppliers, retain the ability to comment on the proposed policy changes or developments that may occur in these proceedings.
EPSA will accept the record in the proceedings as it stands at the time this Motion is granted; EPSA does not seek to delay this proceeding, which is in a very early stages of consideration. EPSA, therefore, submits that its intervention out of time will not prejudice the other parties in this proceeding and otherwise will not disrupt the proceeding in any way. For all the aforementioned reasons, good cause exists to permit EPSA to intervene out of time.