UNITED STATES OF AMERICA BEFORE THEDelegation Agreement • February 13th, 2009
Contract Type FiledFebruary 13th, 2009Southwest Power Pool, Inc. (“SPP”) submits this motion for a stay of certain provisions of the Federal Energy Regulatory Commission’s (“Commission”) December 19, 2008 order regarding the delegation agreement between the North American Electric Reliability Corporation (“NERC”) and the SPP Regional Entity.1 Specifically, SPP seeks a stay of the Commission’s directive in the December 19 Order that the SPP Regional Entity must pay all of its statutory expenses out of the separately maintained account for the Regional Entity rather than reimbursing SPP for shared expenses.2 SPP has sought rehearing of the December 19 Order3 because the directives of the order are not necessary to ensure that non-statutory funding will be kept separate from funding for statutory activities and they would impose substantial inefficiencies on SPP’s operations. In order to prevent SPP from implementing inefficient and unnecessary operation procedures while SPP’s request for rehearing is pending, SPP seeks a sta