FERC Filings
MOTION TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Carolina Power & Light Company , Duke Energy Corporation, South Carolina Electric & Gas Company, GridSouth Transco, LLC - Docket No. RT01-74-000
3. Function 7: The Planning and Expansion Process and Generator Interconnection
In addressing the criteria relating to geographic scope and configuration under Order No. 2000, the Commission indicated that it would examine whether an RTO provides “one-stop shopping and further requires the RTO to serve as the interconnecting authority.” The Commission further emphasized the central role the RTO must play in processing interconnection requests. However, the “Planning Protocol” (Attachment P) the Applicants propose is ambiguous and raises concerns regarding the handling of interconnection requests, and the planning process.
The Protocol states that GridSouth will have “overall responsibility” for the expansion of the transmission system, including the review and approval of proposed generator interconnections. However, under this scheme, it appears that the transmission owners will continue to play a central role in the coordination of interconnection requests.<sup>16</sup> The absence of provisions confirming cost-allocation and responsibility makes this particularly troubling. Further, Article V of the Protocol and the operating procedures raises questions concerning whether generators would be required to renegotiate existing interconnection agreements.
The Protocol establishes a “Reliability Planning Committee” (“RPC”) to “provide a vehicle through which coordinated reliability planning activities will be conducted.” (§3.3) The RPC will “establish procedures, standards and requirements associated with the regional transmission planning process,” and develop “Facility Connection Requirements” which parties seeking to interconnect with the GridSouth system must meet. (§3.3)
GridSouth may invite “other Stakeholder representatives” to participate in working subcommittees, and the protocol invites Stakeholder “input.” However, their role is clearly subordinate to the RPC itself, which is comprised of only GridSouth staff and representatives of the transmission owners. In contrast, Order No. 2000 envisions that only the RTO OATT, and procedures and standards the RTO itself independently develops, should govern interconnection requests.
In Order No. 2000, the Commission emphasized that RTO proposals must address three specific requirements to demonstrate that it satisfied this function: (1) encourage market-motivated operating and investment actions; (2) accommodate efforts to create multi-state agreements to review and approve new transmission facilities; and (3) file a plan with specific milestones. The GridSouth proposal clearly falls short of all three of these requirements. Accordingly, EPSA urges the Commission to consider the potential impact of the RPC’s activities on market participants, and whether the extensive role given to the transmission owners themselves is appropriate in assessing the adequacy of this aspect of the proposal.
<sup>16</sup> The Protocol only provides a general outline for the process; the Applicants state that GridSouth will file a Tariff with interconnection procedures at some point in the future.