FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Southern Company Services, Inc.-Docket No. RT00-77-000
- Southern’s RTO filing fails to provide sufficient detail on the operational authority of the RTO; the Commission should require Southern to file an operating agreement.
- Introduction
- I. MOTION TO INTERVENE
- II. PROTEST
- Southern’s proposed RTO is a vague proposal, at best, and lacks sufficient detail to properly evaluate whether the proposal can fully satisfy the Commission’s minimum requirements for RTO status.
- Only the RTO should have the authority to interrupt a generator, and all generators should be treated on a non-discriminatory basis.
- Southern’s proposed RTO fails to provide comparability to all users of the system and will continue to maintain the discrimination that exists against non-load serving entities.
- Southern’s proposal to collect the RTO costs through an access charge that will not be assessed against Southern’s native load is discriminatory and should be rejected
- Southern has not demonstrated that its performance-based incentives are warranted.
- Southern’s congestion management proposal is flawed due to its allocation of firm transmission rights and congestion costs.
- The proposed planning protocol does not adequately consider generation solutions and is biased towards wires solutions.
- The proposed structures of the Southern RTO and the proposed governance fail to provide for the independence of an RTO.
- The proposed configuration of the Southern RTO is indicative of Southern’s objective of maintaining dominance in its region, not of any public interest objective.
- A Southern Gridco Would Exert Undue Influence Over The Establishment Of Power Markets And The Development Of Market Policies and Rules.
- Generators interconnecting to transmission facilities 40 kV and higher are interconnecting directly to the RTO and are not subject to the operational control of the transmission owners.
- The lack of stakeholder participation has not resulted in the development of a meaningful proposal.
- Interregional Coordination and Seams Issues (Function 8)
- Market Monitoring (Function 6)
- III. CONCLUSION