FERC Filings
REQUEST FOR REHEARING OF EPSA, RM99-2-001
II. Conclusion
WHEREFORE, EPSA requests that the Commission: (1) require that any RTO proposal clearly set forth the nature and scope of the RTO's responsibility for the interconnection of new generators to the transmission grid, and clarify that new generators will not be required to negotiate separately with both the RTO and individual transmission owners/providers in order to obtain interconnection service; and (2) where an RTO proposes transmission rates based on the levelized cost of facilities used to provide the applicable transmission service, require that any proposed switch to levelized rates must be based on the net (depreciated original) plant costs, as opposed to the gross (undepreciated original) costs.
January 19, 2000
Respectfully submitted,
_____________________________
Lynne H. Church, Executive Director
Larry F. Eisenstat
Julie Simon, Director of Policy
Michael J. Rustum
Electric Power Supply Association
Dickstein Shapiro Morin
1401 H Street, N.W., Suite 760
& Oshinsky, LLP
Washington, D.C. 20005
2101 L Street, N.W.
Washington, D.C. 20037
Attorneys for the Electric Power
Supply Association
CERTIFICATE OF SERVICE
Pursuant to Rule 2010 of the Commission's Rules of Practice and Procedure, I hereby certify that I have this day served a copy of the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Washington, D.C. this 19th day of January, 2000.
____________________________
Michael J. Rustum
12. If applied consistently from the beginning of an asset's life, both the straight-line depreciation and the levelized charge methodologies will recover the identical transmission costs on a present value basis.
13. Order 2000, mimeo at 570.
14. Inquiry Concerning the Commission's Pricing Policy for Transmission Services Provided by Public Utilities Under the Federal Power Act, III FERC Stats. & Regs. 31,005, at 31,141 (1994) ("Pricing Policy Statement"), Order on Reconsideration, 71 FERC 61,195 (1995).
15. Order No. 888, at 31,769.
16. Pricing Policy Statement, at 31,141.