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NOTHING BUT TROUBLE FOR THE FERC. In her comments representing the Electricity Consumers Resource Council, she noted:
"FERC should not authorize reallocation of RTO functions from MISO to ITCs such that neither meet the minimum [test], or ¼ Order 2000 will become a dead letter.
"The ComEd ITC proposal should be rejected because it will emasculate MISO of key RTO functions, including ¼ congestion management.
"The suggestion that incumbent utilities in the Midwest retain this responsibility blatantly undermines FERC's RTO initiatives."
Regional Transmission Organizations -
SPP Move Seen as "Too Much Too Soon"
By Carl J. Levesque, associate editor, and Bruce W. Radford,editor-in-chief, of Public Utilities Fortnightly.
Co-ops, PUCs and power marketers fight bid by Southwest Power Pool to qualify as first RTO.
The Southwest Power Pool waited only 10 days after the Federal Energy Regulatory Commission had released its Order 2000 on regional transmission organizations before applying to the FERC to qualify as an RTO, and the rush drew protests from rural electric cooperatives, state public utility commissions (PUCs) and power
Some saw the plan as "business as usual." Others called it "too much too soon." See FERC Docket No. ER00-975, application filed Dec. 30, 1999, protests filed Jan. 18-31, 2000.
DYNEGY PROTESTED THE EXEMPTIONS GRANTED TO NATIVE LOAD. Such customers were excused from taking service under the regional tariff. Dynegy said that would allow participating utilities to continue using the grid "unconstrained by OASIS [the open-access, same-time information system] to which all other transmission users are subject." Dynegy also noted that SPP would not transfer operational control of dispatch and scheduling to SPP, as stipulated in Order No. 2000. That objection was repeated by the Golden Spread Electric Cooperative Inc. and Kansas Electric Power Cooperative Inc.
Three other cooperatives - East Texas Electric Co-op Inc., Northeast Texas Electric Co-op. Inc. and Tex-La Electric Co-op of Texas Inc. - expressed disapproval that SPP had not submitted a revised transmission tariff for RTO operations. They pointed out that when SPP earlier had filed a modified and expanded regional tariff, the commission had said that changes would be required later if the SPP were to seek approval as an RTO or ISO. (See FERC Docket No. ER99-4392-000.)
SPP's failure, the co-ops argued, "should be fatal to its application."
A KEY PROTEST WAS FILED BY THE STATE PUCS of Arkansas, Kansas and Missouri, which together complained of some areas lacking in detail and others not complying with the RTO rule:
* Independence from Owners. No clear idea in many situations on how the RTO and transmission owners (TOs) share responsibility, not only in control area operations, but particularly in new grid construction, where expansion might involve two or more transmission owners.
* Rate Pancaking. Some SPP members would remain outside the RTO.
* Congestion Management. Bilateral trades for redispatch would not disclose in public the true price for relieving
* Rate Setting. Procedures for seeking changes in revenue requirement and pricing structures would overlap. The PUCs said transmission owners should first submit rate requests to the RTO, which would then forward