FERC Filings
MOTION OF EPSA FOR LEAVE TO INTERVENE, PJM INTERCONNECTION, L.L.C
IV.
EPSA is concerned about both the substantive proposal made by PJM and the process by which PJM developed and filed this proposal. Focusing first on the process concerns, FERC has historically given PJM great deference because of its inclusive stakeholder process. In PJM Interconnection, L.L.C., 87 FERC 61,299, at 62,201, the Commission accepted PJM's proposal to establish an initial queue of projects seeking to interconnect with PJM, finding: "This proposal reflects the outcome of a stakeholder process and governance that the Commission approved, . . ." In this instance, however, the proposed unbundling project failed to gain approval by PJM's Members Committee. As the transmittal letter accompanying the PJM filing makes clear, the proposal failed to receive a two-thirds vote before the Members Committee on two occasions. Thus, the Commission should not defer to PJM's proposal. Rather, the Commission should carefully weigh and consider the arguments raised for and against the PJM proposal and make a decision on the merits of the case.
On the merits of the proposal itself, EPSA concurs with the comments filed by the Mid-Atlantic Power Supply Association (MAPSA), which has been active in the debates on this issue within PJM. MAPSA developed and submitted a Position Paper to PJM on September 23, 1999, highlighting the negative effects of PJM's budget allocation on both the competitive market and participants in that market and setting forth an alternative proposal under which transmission owners would be allocated an appropriate share of PJM's budget. EPSA urges the Commission to give careful consideration to MAPSA's proposal and make sure that all PJM participants are treated fairly and that the emerging competitive market in PJM is not stifled through this unbundled cost recovery process.