PPL Protests NorthWestern Energy's classification of Montana's Import Capacity

You would be excused for not knowing what a triannual market power study is, and how important it is to Montana consumers.  At its most basic level, this is the analysis completed by each utility and wholesale power provider to demonstrate to the Federal Energy Regulatory Commission that they do not have monopoly power and should not have the price they sell power for be regulated by the FERC.

NorthWestern Energy filed their triannual market power study in June of this year.  Given that NorthWestern Energy owns very little generation assets the exercise is more of a formality.  But PPL (Pennsylvania Power and Light, who acquired the majority of Montana's Powers Hydro after deregulation) disagrees in some assumptions of the study, and has filed a limited protest of NorthWestern Energy's study.

The third page of the protest demonstrates what PPL is after:

"Not completely scaling down the generation located in the NorthWestern BAA results in the SIL being understated for each of the four season.  Because PPL Companies and other generators located in NorthWestern's BAA may rely on NorthWestern's SIL in their own market power analyses, NorthWestern's Revised SIL Study must provide an accurate accounting of the import capacity into the NorthWestern BAA. (p.3, emphasis added)"

A little interpretation is in order.  First, SIL is Simultaneous Import Limits, and it expresses the amount of electricity that can be imported into Montana.  PPL has a lot to be concerned about.  All else constant, the lower the SIL value is, the more likely PPL the FERC is to believe that PPL has market power and regulate the price they sell energy for.

Of course, we have been here before, and I do not think that I stand alone in the Montana Energy community in thinking that PPL has monopoly power and has used it in the past to gouge Montana Consumers for millions.  Hopefully this batch of Public Service Commissioners will be bold enough to get involved and protect rate payers.