FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Desert STAR, Inc.-Docket No. RT01-44-000
- I. MOTION TO INTERVENE
- A. The DSTAR Governance Structure Does Not Meet Order No. 2000’s Independence Criteria.
- C. The Scope of DSTAR’s Authority Is Inadequate.
- II. PROTEST
- B. The Scope and Configuration of the DSTAR Region are Inappropriate.
- D. The DSTAR Proposal Would Provide Undue and Unwarranted Preferential Treatment to Vertically Integrated Market Participants
- E. The DSTAR Proposal for “Local Generation Resources” Is Confiscatory, Unreasonable, and Would Distort Incentives for Grid Expansion, Generation Expansion and Demand-Side Elasticity.
- F. Congestion Management
- G. Market Monitoring
- III. CONCLUSION