FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON STANDARDIZING GENERATOR INTERCONNECTION AGREEMENT AND PROCEDURES
PRELIMINARY STATEMENT
EPSA applauds and very much appreciates the Commission’s efforts to adopt a standard generator interconnection agreement and procedures. Standardizing the interconnection process is urgently required in order to facilitate development of the rapidly emerging merchant generation industry and the much-needed competition that will result from merchant plant development. The Commission is absolutely correct that “standard interconnection procedures are essential for providing the right incentives for both transmission providers and generators.” Indeed, in order for the Commission’s effort at fostering wholesale competition to go anywhere, there must be incentives not only to encourage infrastructure investment, but also to dissuade any transmission provider from favoring its own generation, erecting further barriers to entry, or otherwise stymieing siting and other development path decisions. Moreover, in addition to its quickly adopting a pro forma interconnection agreement and standard procedures, it also is essential that the Commission require, if necessary through use of its conditioning authority, all public utilities that own, operate or control transmission facilities to adopt such agreement and such procedures as well, and that the Commission meaningfully sanction those transmission owners who deliberately fail to do so. Only then would the Commission have done what it could to remove decisively the regulatory and market uncertainty associated with the generator interconnection process that presently plagues the entire industry.
No doubt the Commission knows full well that the current regulatory and market uncertainty threatens seriously to forestall, if not undermine entirely, the potential for robust competition. Indeed, as is true of market design in general, in order for the necessary infrastructure investment to occur, and for new entry to be achieved, the interconnection process must proceed via known and predictable rules. Accordingly, EPSA respectfully requests the Commission to adopt, as soon as possible, the proposed consensus documents, including,
where applicable, the pro-competitive alternatives proposed by the generator drafting group. The Commission must not allow yet a further lengthy period during which time parties still will not know the acceptable levels of interconnection nor what rights and obligations they have going forward, nor the procedures required to be followed, nor the ground rules in effect once an interconnection agreement is executed. One way or another, the Commission must ensure that the products, procedures and agreement adopted will guarantee the certainty of comparable market access that potential market entrants require.