Latest News
Duquesne's Proposed Timetable to Join MISO is Unreasonable, EPSA Says
WASHINGTON, D.C. - The Electric Power Supply Association (EPSA) today filed comments with the Federal Energy Regulatory Commission (FERC) requesting leave to intervene and comment in Duquesne Light Company's filing to integrate into the Midwest Independent Transmission System Operator (MISO) upon its withdrawal from PJM Interconnection (PJM). In its July 3, 2008 filing, Duquesne Light Company requested a date of October 1, 2008, for integration of their transmission facilities into MISO as a new transmission-owning member of that regional market.
In its comments, EPSA pointed out that, "Duquesne's proposed October 1, 2008 date for integration into MISO is premature based on the considerations and requirements that have not been resolved or even contemplated in some cases. The issues surrounding Duquesne's exit from PJM and entrance into MISO require more attention and further action on Duquesne's part to ensure a transition that will not upset either market." EPSA's concerns include the fact that Duquesne has not yet provided the entities within its service territory a certain integration date and therefore, those entities are unsure of how to prepare for a potential October 1, 2008 date. Additionally, Duquesne has not addressed the problem of how it or suppliers in its control area will comply with both MISO's Module E and PJM's RPM rules for capacity requirements. Further, Duquesne has provided no impact studies for either PJM or MISO, leaving a number of questions about how physical flows will occur through Duquesne's load zone unanswered.
"EPSA recommends, at the very least, that Duquesne's integration be delayed until the start of MISO's next planning year - June 1, 2009 - in order to allow sufficient time for all of these issues to be properly resolved," said John E. Shelk, president and CEO of EPSA. "If Duquesne is to eventually join MISO, it makes the most sense that they should integrate at the start of a planning year, rather than at the startup of MISO's ancillary service markets. Next June, MISO is implementing a new capacity construct; valuable resources should not be devoted to the integrating into the current construct for a matter of only months." Shelk added, "Duquesne should also complete all of the Commission set pre-filing requirements at least 60 days before its integration into MISO." Not coincidentally, the start of the PJM and MISO planning years are aligned. "The June 1, 2009 start date makes even more sense when considering Financial Transmission Rights (FTR) and Auction Revenue Rights (ARR)," EPSA said.
EPSA's comments further expressed concern surrounding the fact that, "Duquesne asserts that it has no requirement to hold third-parties within its service territory harmless from the consequences of its withdrawal." "Load Serving Entities (LSE) should have ample time to procure capacity from Module E and review and respond to Duquesne integration plans; the uncertainty surrounding Duquesne's integration date is grossly unfair to LSEs that intend to make a good faith effort to comply with the specifications of MISO's tariff," EPSA said.
EPSA Comments on Duquesne's Proposed Timetable to Join MISO (Docket No. ER08-1235-000)
CONTACT: JOHN SHELK
(202) 349-0154or 703-472-8660
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.