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Public Comment Submitted to the Colorado PUC[PDF]
The Colorado Public Utilities Commission (PUC) docket #16I-0816E concerns a proposal by the Mountain West Transmission Group (MWTG) to join the Southwest Power Pool (SPP), a Regional Transmission Organization (RTO).
Although it is certainly desirable for Colorado to move forward with equal-access pooled transmission assets and competitive wholesale electricity markets, we think there may be a better way (more in the public interest) than joining SPP. Also see the Op-Ed to this effect.
Questions and Comments about the MWTG Proposal to Join SPP
respectfully submitted to the Commissioners
- Broad input - A change to our energy landscape this far-reaching must have broad Stakeholder input and public hearings. There are other options in addition to the plan of self-interested utilities. We have an opportunity to design a forward-looking electricity market that benefits all Coloradans.
- IOU-owned generation - Will their fossil generation be competing fairly in the generation dispatch order with IPPs? (or doesn't it work that way in SPP?)
- Retail electricity choice - Does SPP support it? (no) Surely we want retail choice in Colorado, because electricity is no longer a "natural monopoly".
- Alternatives - It may be better to form our own new ISO/RTO because:
- SPP is in the Eastern Interconnection with limited power exchange points. If the goal is more power exchange, we don't need to join SPP to do that.
- Someone should start another ISO/RTO in the Western Interconnection, and the MWTG is well- positioned to form the charter membership. Other western areas might join, including some who have or will join CAISO's Energy Imbalance Market (EIM).
- Wouldn't it be better to start a new 21st century RTO rather than struggle to update an old RTO with roots in a different energy era? CAISO and NYISO and others are struggling to update their rules, and they're already more "modern" than SPP. "Build the plane on the ground rather than try to fix it in flight."
- Nevada must move from a regulated monopoly to a competitive electricity market as a result of the 2016 election. How is Nevada likely to implement its market? Join CAISO? Maybe Colorado should join CAISO too, or maybe Nevada would join our new ISO/RTO.
- A new ISO/RTO in the Western Interconnection would have more opportunities and freedom to expand in the future than if we were tethered to SPP and its history.
- Governance - SPP has deep roots, and Colorado would have only the tiniest influence on its governance. Their current Board Chair was elected in 2000! The CAISO and PJM governance models are much better (more transparent, more Stakeholder-oriented).
- Structure - Joining SPP without unbundling vertically-integrated monopolies (as ERCOT did) leaves the same perverse incentives in place to build more and more transmission without investigating other and/or non-wire alternatives.
Bottom line - Joining SPP might entrench us in the past rather than position us to prosper in the future. Let's explore all our options, including through non-utility Stakeholder input, public hearings, and Staff research.
Thank you for your consideration!