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Enron Mail |
FERC has clarified several aspects of interconnection policy in recent orders:
EPMI and DENA received a favorable FERC order after protesting numerous aspects of Arizona Public Service's proposed interconnection procedure (IP) and agreement (IA), including a must run provision for generators located in APS-specified load pockets and an unusual liability provision that basically insulated APS from most, if not all, of its actions. FERC held in favor of generators in the following provisions: -- Generators are not required to execute a transmission agreement in order to seek interconnection -- Immaterial changes to the request will not result in loss of queue spot -- Specific milestones must be added -- 60 days (rather than 30) allowed for execution (or FERC filing) of IA -- Generators will not be charged twice for imbalances if serving load -- Required system protection facilities must be identified in the study -- Elimination of the must run requirement (can be negotiated with a generator, subject to APS' filing with justification for proposal) -- Credits must be applied to any transmission service, firm or non-firm -- APS limited to obtaining information from generators that is necessary to satisfy APS reporting obligations, plus APS agrees to inform a generator of information that affects the generator -- APS' liability provision was eliminated in its entirety FERC issued some guidance on how evaluations are performed. In VEPCO, all pending higher-queued requests are included in the evaluation. Guidance on when studies and the related costs are complete. In VEPCO and CP&L, FERC stated that customers withdrawing from the queue do not have to pay for the possible additional study costs that lower queue projects may incur. These costs will be borne by those remaining in the queue until (in VEPCO) the customer either executes the IA or files it unexecuted at FERC. ((One caveat--This result was requested by EPMI/Duke in the APS protest. FERC stated it was granting our request, but then seemed to hold, with some confusing language, that the costs could be charged to the withdrawing customer's security. We are seeking clarification of this at FERC.)) Costs incurred after withdrawing from the queue. ComEd's procedure provides that "Applicant may withdraw its interconnection request at any time, as long as it pays Transmission Provider for all costs prudently incurred by Transmission Provider up to that point." FPL's unfiled procedures allow withdrawal at any time (expenses incurred to date must be paid.) Consumers includes similar procedures. What are "material changes" (lose of queue spot). FERC approved Consumer's provision that queue spot is lost for: (1) size increases < 15%; or (2) in-service date delay by more than 6 months; or (3) the site is moved and the move affects the interconnection to the system. Duke has filed provisions (unapproved yet) that queue spot would be lost for: (1) delay in-service more than 6 months; (2) change in site configuration that impacts flows; or (3) change in the point of interconnection by lesser of five miles or 25% of the length of line to which the facilities are connected. Remember; however, that most procedures and IAs will include milestones -- failure to comply can result in loss of queue spot. Availability of study data: Duke will make studies available on OASIS. CP&L will provide workpapers used in the studies on request.
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