Tres Amigas project overview

August 26, 2010

Michael Giberson

The Texas Tribune offers an up-to-date overview of the Tres Amigas project. Here is the intro:

Texas has always operated its own energy grid, separate from the two other grids that span the rest of the nation. But a project quietly emerging in eastern New Mexico would curb that independence — and affect energy prices for Texas consumers in ways that remain much in dispute.

The $2 billion project could connect all three grids (eastern, western, and Texas) as soon as 2013. They would meet near Clovis, N.M., just west of the Texas border. The Federal Energy Regulatory Commission has given a preliminary go-ahead to the proposal, known as Tres Amigas, which doubles as the name of the company running it. The federal commission’s chairman has praised it as a “prime example of the creativity and pioneering thinking that our country needs.”

But serious questions remain over whether the project would benefit Texas residents and businesses — whether electricity prices would rise or fall and whether the connections would allow other states to siphon off too much of Texas’ wind power.  (Links in source.)

I’m not convinced that “serious questions remain over whether the project would benefit Texas residents and businesses,” except for the Federal/State jurisdiction issue.  (Discussed here before.)  The general economic and reliability benefits from linking power systems are well demonstrated and not seriously questioned.

The article wraps up with a question to Tres Amigas CEO Phil Harris:

Asked if Tres Amigas would move forward if only two grids — eastern and western — signed up, Harris replied: “Yeah. That’s already proceeding.” Construction of that interconnection should begin next year. But he quickly added that his company was “extraordinarily confident” that Texans would reap economic value from the project. “If there’s no benefit,” he says, “obviously you wouldn’t want to do it.”

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Tres Amigas in the news

August 10, 2010

Michael Giberson

Tres Amigas, as seen by their hometown newspaper The Santa Fe New Mexican, “Supersized power hub in southeastern N.M. to link 3 major U.S. grids“:

Phil Harris is masterminding an electricity superhighway — a facility near Clovis that will connect the nation’s three main power grids for the first time.

The Tres Amigas Superstation will link the Western Interconnection, Eastern Interconnection and Texas Interconnection at a point in southeastern New Mexico. It also will provide the transmission capacity that power managers say is needed to handle the renewable energy expected from new solar and wind sources.

The hub will allow energy to flow between the grids via superconductor cables in underground pipelines and AC/DC converters….

One of the problems is the current system for delivering power across the country is complex and separated by region. The lack of connection limits competition in power markets, Harris said. “In the U.S., no one is in charge. We have over 4,000 entities involved with power.”

Those entities include investor-owned utilities such as Public Service Company of New Mexico, 800 municipal power companies, 900 electric cooperatives, renewable energy generators and power traders such as Goldman Sachs. Regulations vary by group. So do power interconnections.

“There’s no way you can get a single decision about what is best for America,” Harris said.

“People are paying more (for electricity) than they should because it is a constrained market,” he added.

Tres Amigas will make the power market more competitive. Harris is banking on it, to the tune of investing $1 million of his own money in the project, he said.

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The right market design for trade between power markets

May 7, 2010

Michael Giberson

Windpower Monthly has a great article describing changes in the market for transmission capacity between power systems in Europe and the benefits of the changes.  Here is a summary by way of selected quotes, but the full story is worth reading:

Most of the electricity cables connecting Europe were built when electricity systems in each country were monopolised by a single or, at most, a few companies, each operating within their individual monopoly supply areas. Each utility ran its own system and had its own generation backup for emergencies. There was no competitive pressure on the higher costs of such “island” systems since these could easily be passed on to customers who, in those days, had no alternative suppliers that they could switch to.

These interconnectors were built between neighbouring countries’ electricity grids not to enable trading and competition across borders but rather for the utilities to help each other out….  [As the Eurpopean power industry was liberalized] insufficient connection capacity between some of the national electricity networks [emerged as] one of the key problems.  [An] efficient allocation for the scarce interconnector capacity that is available is crucial to make improvements towards an integrated European electricity market.

Before the new [market coupling] system started, transmission capacity available on the two interconnectors was sold to electricity traders in tranches in annual, monthly and daily auctions, called explicit auctions. This happened completely separate from auctioning of electricity with the result that, due to the time lag in buying the transport capacity and the actual time of use, as well as other reasons, inefficiencies occurred.

Transport capacity could be bought ahead of time and hoarded, a form of market abuse. Or transmission capacity was bought for one direction, say from Germany to Denmark, which then turned out to be inappropriate because the price difference between the two was such that the electricity ought to flow in the other direction – from the low- to the high-price zone. In such instances, the electricity did then flow in the wrong direction, contradicting market forces, or not allowing extra capacity to be used – and traders and end users lost out.

Explicit auctions were implemented for interconnectors at most European borders, recounts [EMCC managing director Enno] Bšttcher. “Even though this can be considered as progress compared to the formerly applied first-come, first-served or pro-rata regimes, explicit auctions still have many disadvantages,” he says.

Today, explicit auction methods have become more sophisticated. The fundamental flaw, however, remains: that actual trade of electricity at energy exchanges in the different market areas is separate from transmission capacity, trading leading to market inefficiency. This can be reduced by combining cross-border transmission capacity allocation and electricity trade from one country or market area to another in a so-called market-coupling regime.

Market coupling uses implicit auctioning and focuses on the short term (day ahead), rather than months or a year ahead. The transmission capacity available on an interconnector the next day, as reported by the transmission system operators (TSOs), is matched with electricity bought or sold on the energy exchanges in the two countries involved for delivery the next day, creating a price for the transmission capacity and making it clear in which direction the market requires use of the transmission capacity of the cables.

In effect, market coupling is a charge placed on the power exported or imported between countries when the network interconnector capacity is optimised to reduce congestion.

The result of market coupling is that the interconnected power systems operate more efficiently, benefiting consumers and low-cost producers of power.

As Tres Amigas works out its design for the sale of transmission capacity across the proposed three-way transmission interconnection, market coupling should be among the designs contemplated.

Note that while day-ahead market coupling seems to work well between systems with relatively few interconnecting links, more complex transmission links between systems – say as exists between PJM and the Midwest ISO – may well call for still more extensive coordination. The market coupling principle seems sound, so probably forms an adequate foundation to build upon, but simple day-ahead coordination is likely insufficient. Real-time market coupling, anyone?

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Incentives for efficient use of storage in electric power systems

March 29, 2010

Michael Giberson

In the most recent Energy Journal, Ramteem Sioshonsi has an article examining the welfare effects of the incentives to use energy storage in electric power systems. (“Welfare Impacts of Electricity Storage and the Implications of Ownership Structure,” See volume 31:2 here.) He considers the incentives faced by consumers, generators, and merchant energy storage owners (companies lacking consumer or generator affiliates).

His theoretical analysis demonstrates:

[W]elfare-maximizing storage use benefits consumers while reducing producer profits, [and therefore] will result in consumers and producers having vastly different incentives to use storage from one another and from merchant storage owners.  This is because the three different agent types will use storage to maximize their net payoffs. In the case of consumers this would consist of the sum of arbitrage value and consumer surplus change, whereas producers would maximize the sum of generation and arbitrage profits.  Merchant storage operators, on the other hand, will maximize arbitrage profits only.  Because consumer surplus is enhanced by welfare-maximizing storage use, and since consumers that own storage would not consider the impact of storage use on generator profits, they will tend to have an incentive to overuse storage.  Conversely, because storage use reduces producer profits, generators will have an incentive to underuse storage.

A numerical analysis based loosely on ERCOT system characteristics in 2005 provides further elaboration of the model.

Our numerical example showed that for most reasonable storage device efficiencies merchant ownership of storage is welfare-maximizing compared to the alternatives of consumer or generator ownership….  When storage assets can be divided amongst agent types the socially optimal allocation of storage favors merchants, although some consumer ownership of storage can be beneficial since their overuse of storage can compensate for underuse by merchants.

Sioshonsi observes that as the number of storage operators increases, overall use of storage capability approaches the social welfare maximizing outcome.  This is, of course, the familiar effect of competition in markets on welfare.

Reading this paper I couldn’t help but think of the Tres Amigas proposal, which I think would be the first merchant energy storage project of any significant size if built. (Am I overlooking any large grid-connected merchant energy storage projects?)  While this article was far from an analysis of the welfare consequences of building the Tres Amigas project, it does suggest that the project’s storage capability would offer substantial public benefits.

Sioshonsi only considers use of energy storage to buy and sell energy, but grid-connected energy storage can also be used to provide transmission support services (generally called “ancillary services”).  When energy storage gets built as a transmission-system component and factored into regulated transmission rates, regulations tend to prevent that energy storage from being used for energy price arbitrage.  So, “transmission-system” energy storage assets will be underused relative to the public interest.  But markets for ancillary services are incomplete, meaning merchant incentives to supply ancillary services may also be underdeveloped.  Most of the regional, integrated power markets (i.e. RTOs) have substantially improved their ancillary services markets over the past several years, and the way forward here is to continue to improve ancillary services markets.

ASIDE: Sioshonsi also notes that an integrated utility with consumer loads and its own generation assets may inherently favor the socially optimum welfare use of storage assets, “since these entities would be concerned with both producer and consumer surplus.”  However, this expansive claim is just an add-on remark in the conclusion not examined in the body of the paper.  Suffice to say that if the interests of integrated utilities were always aligned with both producer and consumer surplus, we could dispense with both restructuring and regulation and let consumers live in the warm embrace of unregulated, integrated monopoly power companies.

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Tres Amigas gets half a loaf from FERC, tips on gaining other half

March 22, 2010

Michael Giberson

On March 18, the Federal Energy Regulatory Commission acted on the Tres Amigas project’s two regulatory requests submitted last October.  Tres Amigas has proposed to link the large scale power interconnections covering the eastern and western halves of the United States with the ERCOT interconnection in Texas.  The New Mexico-based project would facilitate trading power among the interconnections and aid development of electric power generation resources in all three areas.

In docket ER10-396-000, FERC granted the project’s request for negotiated rate authority subject to conditions intended “to ensure that the goals of open access are protected and that rates for transmission service on the Project remain just and reasonable by limiting Applicant’s ability to withhold the Project’s capacity from the market.”  Haven’t read the order yet, but when I have the chance I’ll let you know if I see something interesting.

In docket EL10-22-000, Tres Amigas requested the Commission agree not to assume federal jurisdiction over the parts of the ERCOT interconnection currently regulated by Texas just because the Tres Amigas project would allow ERCOT market participants to join in interstate commerce.  FERC concluded that the information submitted by Tres Amigas did not warrant a blanket disclaimer of jurisdiction and so denied the request. However, the Commission offered suggestions on how Tres Amigas may go about securing the jurisdictional assurance it wants without the Commission implicitly endorsing the various justifications the project offered in the company’s filing.

MORE: The FERC press release contains more information, and see Chairman Jon Wellinghoff’s statement, Commission Marc Spitzer’s statement, and Commissioner John Norris’s statement.  Mostly these statements say: we like innovative transmission infrastructure projects like this one, we support them as we can, we couldn’t quite swallow the jurisdictional request as presented, but that doesn’t mean we don’t like these kinds of projects.

The Wall Street Journal summarized the ruling, “Power Grid Connection Wins First Approval.” Bloomberg reports, “FERC Slows Tres Amigas Plan to Link U.S. Power Grids.”

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Tres Amigas wants to take cheap electric power away from hard-working Texas families

February 8, 2010

Michael Giberson

I spent the middle of last week in Austin at the University of Texas-Law conference on wind, solar and geothermal energy law, and as a side bonus got to hear some informal, Austin-based commentary on the Tres Amigas proposal to interconnect the Eastern, Western, and Texas electric grids. It will give you some idea of the thinking in the state capital that I heard the term “Dos Amigas” used more than a few times.

During the pre-conference “fundamentals” discussion, in response to a question that asked whether stronger transmission links to other states would help accommodate added growth in Texas wind power, a current member of the Public Utility Commission of Texas arose from the audience, climbed onto the dais, and took the microphone to say, among other things, “ERCOT is just fine the way it is.” The other main point of his comment was to suggest that the Southwest Power Pool, which has long covered the wind resource rich Texas Panhandle (with relatively weak links elsewhere, but a plan to beef up those links), would ably serve to sell the wind resource out of state while not compromising ERCOT’s jurisdictional status with respect to the feds.

Later in the conference a speaker offered a Texas policymaker’s view: ERCOT has its well-regarded CREZ plan to spend $5 billion on transmission enhancements primarily intended to allow wind generation in far west Texas, central west Texas, and the Texas panhandle to be delivered downstate to consumers in the Dallas, Houston, Austin, and San Antonio regions. If those lines link to Tres Amigas, then the prospect arises that consumers elsewhere will – in effect – “drink our milkshake.” Texas policymakers don’t want other consumers to drink our milkshake, especially after ERCOT consumers spend $5 billion to build there own transmission “straw” into the Panhandle region.  (Yeah, I watched “There Will Be Blood” a week or so ago, hence the milkshake and straw references. The presenter did not use this language.)

Peter Behr, writing for ClimateWire, has a more journalistic report on the debate over Tres Amigas. Behr reports that Occidental Petroleum – a large power consumer within the ERCOT region – has actively opposed the Tres Amigas project in filings at FERC, as has the Texas Industrial Energy Consumers. I haven’t read their filings, but apparently they believe ERCOT power prices will be higher on average with Tres Amigas than without, and as consumers they prefer lower prices.

In my opinion, however, they are more likely to get slightly lower (and somewhat less volatile) prices with better links to the rest of the grid.  That’s the way market expansion usually works.

Tres Amigas posts its FERC filings and related documents on its website. Here are links to a couple of the opposing views filed at FERC.  The “Supplemental Protest of Occidental…” includes the expert witness testimony that Behr discusses in his story:

Not all Texas policymakers oppose Tres Amigas. Member of Congress Randy Neugebauer (R-TX) sent FERC a letter indicating the project would encourage investment in renewable power and urging the Commission to give the project a “fair and deliberate view.”  And, as the ClimateWire story suggests, developers aiming to exploit the extensive power generation potential of the region are strongly behind the project.

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Posted by Michael Giberson

Energy storage on the grid: transmission equipment or market participant? (Again)

January 25, 2010

Michael Giberson

In the wholesale power markets world, commercial energy storage concepts are commonly somewhat of an afterthought. None of the large regional wholesale power markets integrated into transmission operations put too much effort into thinking about energy storage as they developed their market rules.

A part of the problem is that the transmission system and the rules that surround it is set up to move power from generation sources to electrical loads. Grid-connected energy storage devices are something of a hybrid: sometimes act like generators – supplying power – and sometimes act like loads – consuming power. They don’t always fit neatly into traditional categories. Further mixing things up, energy storage can contribute greatly to system reliability, usually treated as a matter for transmission-system based coordination rather than market transaction.

But as commercial-scale energy storage begins to arrive on the scene it has become more important to sort through these issues.

I’m just quoting myself from a post of 14 months ago on the topic of integrating energy storage players into regional power markets.  At the time the case involved American Electric Power’s desire to add a battery storage system as part of a transmission system upgrade in Texas, and a request that the energy storage device be treated as transmission facilities (and therefore have costs recovered through regulated transmission rates) rather than as an energy market participant of some sort.  The PUC of Texas permitted AEP its battery-storage-system-as-transmission-facility.

Last week FERC took initial action on a similar request (link goes to decision; see also FERC news release).  Western Grid Development LLC has proposed installing energy storage devices on the CAISO-managed transmission system and seeks to have its system treated as transmission facilities. The comments and protests filed in response to the Western Grid raise the same concerns heard in the AEP/Texas case.  Some parties object that storage inherently involves participation in energy buying and selling and therefore the systems ought to be energy market participants; Western Grid states that any purchase or sale of energy would be incidental to operation of the system in support of the transmission grid, done only at the direction of CAISO, and net revenues – if any – would be refunded to transmission ratepayers.

In FERC’s decision, it agreed that the facilities could be treated as transmission equipment so long as they are built and operated as described by Western Grid, and so long as the CAISO approves the project as part of the ISO’s regional transmission planning process.  (CAISO, by the way, filed a strong protest in response to the Western Grid request, so I expect Western Grid will have much work to do to gets its project off the ground, even with this preliminary approval by FERC.)

FERC was clear that this decision is limited to Western Grid’s project as proposed and does not suggest any general position on the treatment of energy storage devices on the grid.  In fact no general position may be available, given, as FERC explains, “electricity storage devices …do not readily fit into only one of the traditional asset functions of generation, transmission or distribution. Under certain circumstances, storage devices can resemble any of these functions or even load. For this reason, the Commission has addressed the classification of energy storage devices on a case-by-case basis.”

By the way, a number of the key people involved in Western Grid are also working together on the Tres Amigas project though (I think) no official links exist between the two companies.

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Texas and the Tres Amigas interconnection

January 13, 2010

Michael Giberson

Over the holiday NYTimes.com posted a story by ClimateWire reporter Peter Behr that does a pretty good job of describing the proposed Tres Amigas project (proposing to link the three main electric regions in the U.S. – Eastern, Western, and Texas) and surrounding issues.  Among other things, the story provides a good short summary of the Federal/Texas jurisdictional relationship, which stands as one challenge to success:

The developers have also asked FERC for a second ruling disclaiming jurisdiction over transmission providers that tie into the Tres Amigas lines and in effect, to maintain Texas’ jurisdictional independence. “Clearly, if we don’t the jurisdiction disclaimer, I can’t imagine how we get support for this in Texas,” [Tres Amigas attorney David] Raskin says.

Echoing the state’s Alamo heritage and a tenacious attachment to its independence, Texas’ largest utilities cut their power line connections with other states in 1935, after passage of the Federal Power Act in the New Deal, to keep Washington from asserting jurisdiction over their operations. (Texas had no state regulation of utilities before the 1970s, notes Judge Richard Cudahy of the 7th U.S. Circuit Court of Appeals).

In one famous showdown, a Texas utility — Central and Southwest Corp. — did create a transmission link between its divisions in Texas and Oklahoma to preserve its status as an interstate electric power holding company. At night on May 4, 1976, a technician opened a switch at a CSW substation sending power surreptitiously from Vernon, Texas to Altus, Okla., according to Cudahy’s account of the “midnight connection.”

Since Texas’ other major utilities were linked to CSW, their power was also flowing in interstate commerce. Several hours later, Texas utilities were informed of these events, and two of the largest responded in outrage by severing their transmission ties to CSW, at some risk to the state’s entire grid.

The Tres Amigas petition to FERC says that because energy is converted from an AC wave to a DC electronic pulse and then back into an AC wave synchronized with the receiving grid, the electrons in Texas are not “free flowing” into New Mexico or Oklahoma, preserving Texas’ separation.

The Tres Amigas jurisdictional request submitted to FERC offers more detail (FERC docket number EL10-22-000) and for further background I’d recommend the chapter on the subject by Darren Bush and David Spence in Electric Restructuring: The Texas Story (the book recently published by AEI Press edited by Lynne and Andy Kleit).

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The Benefits of the proposed Tres Amigas interconnection

December 10, 2009

Michael Giberson

Both of the Tres Amigas filings at FERC (see background) provide summaries of the anticipated benefits of the proposed interconnection between the Eastern, Western, and ERCOT interconnections.  Each of the five kinds of benefits listed below seem plausible to me.  While estimating the size of the benefits would require a lot of hard work, given the scale of the project and other generation and transmission projects under consideration for the surrounding area, it seems likely that the benefits will be substantial.

To a degree, of course, the investors in Tres Amigas hope that the project will capture some of the value created in the form of profits.  But to a degree such a project should inherently produce spillover benefits in the form of more efficient energy generation and lower cost provision of reliability services.  (A recent working paper discussing the economic effects of the NorNed interconnection suggests that in the NorNed case the interconnection produced mostly private benefits to the investors. I think there is reason to believe that the Tres Amigas case is different, but the point is worth further examination.)

Here is the version of “The Benefits of Tres Amigas” section appearing in the jurisdictional filing (the version in the transmission rate filing is essentially the same; emphasis added):

Tres Amigas will advance the public interest in several important ways. First, a new power marketing hub will be created in proximity to large amounts of existing and potential renewable generation, providing the developers of renewable (and other) generation expanded markets in which to sell their power. Tres Amigas will permit renewable generation being developed in each of the Eastern Interconnection, ERCOT and WECC to be delivered to markets that are currently only minimally accessible. This will enhance the value of new generation, creating additional incentives for its development. This benefit is particularly important because Tres Amigas will be located adjacent to areas of the country that have been identified as among the most promising from the standpoint of developing renewable wind, solar and geothermal power.

Second, marginal prices for energy in the three interconnections, which typically diverge because the markets are electrically separated, will move closer together, allowing electricity to be produced more efficiently and saving electric consumers large amounts of money. For example, the Petitioner’s studies show that marginal energy prices vary significantly between the Southwest Power Pool (in the Eastern Interconnection), ERCOT and the WECC at this time. Our studies show that energy prices vary by more than $50 per MwH in over 2,000 hours per year between the CAISO and ERCOT, over 1,600 hours per year between ERCOT and the Palo Verde hub, over approximately 1,500 hours per year between SPP and the CAISO, and over approximately 800 hours per year between ERCOT and the SPP. Accordingly, significant opportunities exist to produce power more efficiently.

Third, opportunities will exist to “firm up” intermittent and variable renewable energy by taking advantage of geographical diversity and onsite battery technology at Tres Amigas. Studies have shown that the quality of intermittent and variable renewable energy can be enhanced by aggregating sources from geographic locations that may experience high winds or sunshine at different times. In addition, Tres Amigas will expand the geographic reach of markets generally, offering additional opportunities to take advantage of load and resource diversity.

Fourth, the value of transmission investments made in the regions around Tres Amigas will be enhanced by allowing power to move more freely between the interconnections. Tres Amigas will permit power to move to and from different markets, expanding the potential use of the existing transmission grid and expansions thereto. Tres Amigas should provide system planners new opportunities to improve the efficiency and reliability of the electric system at a lower overall cost.

Fifth, electric system reliability in the area around Tres Amigas will be improved because Tres Amigas will connect the three asynchronous grids at a robust station with back-up power and voltage source converter technology that will provide substantial reactive power to the transmission system in each of the interconnections. This is particularly important because Tres Amigas will be located in a remote area, where a strong source of reactive power is necessary to support both new transmission and new renewable generation. Tres Amigas will allow more renewable generation to be interconnected in this important region and reduce the investment cost associated with transmission development in the area.

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More Tres Amigas interconnection details revealed in FERC filings

December 8, 2009

Michael Giberson

Today Tres Amigas LLC submitted two filings to the Federal Energy Regulatory Commission, one seeking assurance from FERC that linking the ERCOT system to the proposed interconnection project would not subject ERCOT to FERC jurisdiction, and the other seeking authority to sell transmission services at negotiated rates. According to the filings, affirmative answers to both requests are necessary for the project to proceed.

In the jurisdictional request, Tres Amigas said:

The relief requested in this Petition is essential for the Tres Amigas project to move forward. The ERCOT parties with whom the Petitioner has discussed interconnecting with Tres Amigas have made clear that they will not likely obtain approvals in Texas to construct transmission lines to Tres Amigas without this jurisdictional disclaimer, and without an ERCOT interconnection the unique benefits of Tres Amigas will be lost.

In the request for authority to sell transmission services, Tres Amigas said:

Although this filing is styled as a request for negotiated rates, it is in reality a request for authorization to proceed with the Tres Amigas Superstation (“Tres Amigas”). The Applicant cannot realistically use traditional, cost-based transmission service pricing. Cost-based pricing normally applies to transmission providers that have captive customers who bear responsibility for the cost of transmission under an individual or regional open access transmission tariff (“OATT”) or other transmission arrangement.

The Applicant has no captive customers and there is no regional transmission organization (“RTO”) OATT under which the costs of Tres Amigas can be recovered. The beneficiaries of the Tres Amigas project will be in all three interconnections and therefore will be spread over a geographical area that far exceeds the scope of any existing or proposed OATT with cost-based rates. The very purpose of Tres Amigas is to eliminate the barrier created by the current separation of the U.S. transmission system into three asynchronous grids, providing new transaction opportunities across much of the United States.

The risks associated with Tres Amigas also exceed those associated with a typical cost-based transmission project. As discussed in Section VI.A below, the Applicant is taking on the full market risk associated with this project. This risk is unique in that no one has constructed a facility like Tres Amigas before. The economic success of this project will depend on the market’s response to the availability of service through this facility and on the willingness and ability of third parties to construct transmission lines to Tres Amigas, factors over which the Applicant will have virtually no control.

The Applicant has invested two years of effort and considerable expense to develop an engineering solution to a long-recognized transmission system need. Thus far, Tres Amigas has received a positive response from throughout the industry and from public officials. However, if this application is not approved, the Applicant will have no means to recover the $1 billion or more projected initial investment required to design and build Tres Amigas, and the project cannot proceed.

The request for authority to sell transmission service contains extensive discussions concerning the company’s proposed business model.  I anticipate finding time later in the week for a careful review.

[Various other Tres Amigas-related posts here at Knowledge Problem can be found using this search link.]

UPDATE: The Tres Amigas jurisdicational filing is assigned FERC docket number EL10-22; the transmission rate filing is ER10-396.  Comments on both filings are due at FERC on December 29, 2009.

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