FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON STANDARDIZING GENERATOR INTERCONNECTION AGREEMENT AND PROCEDURES
DISPUTED PROVISIONS
EPSA strongly recommends that the Commission adopt each of the generator alternatives set forth in the two documents. As the Commission has noted on countless occasions, new generation projects enhance competition, promote product and service diversity, mitigate incumbent utility market power, and contribute to overall market liquidity. And as noted above, if merchant generation is to be built, it must be able expeditiously to interconnect to the grid pursuant to well-established, predictable and commercially reasonable rules. Those companies developing merchant generation and currently working to get that generation interconnected to the grid and delivered to customers put many hours of hard work into providing the Commission with interconnection agreement and interconnection procedures language that will accomplish these goals most efficiently and effectively. EPSA strongly believes that the generator alternatives represent the most commercially reasonable ways to get this much-needed new generation onto the grid as quickly as possible.
Put simply, the generators’ alternatives pose no material hardships on the interconnecting utilities; they do not differ from the types of contractual provisions that one would expect to see, and that in fact routinely occur, following true arms-length negotiations between willing parties; and they unquestionably represent the view of those best situated to determine how best to interconnect new generation; i.e., the interconnecting generators themselves. Generators know best what they need in the interconnection process; and provided there is no adverse effect on reliability, associated with a given generator proposal, the burden should be on the transmission providers, or on any other party who objects to the generator provision, to show why adopting the provision would detract from facilitating either the interconnection itself or the Commission’s goals in general.
The plain and simple fact is that not all transmission providers have the same incentive to facilitate wholesale competition. The Commission knows this; it has stated this; and many of its policies are designed to address the inescapable fact that not all parties want competition to flourish. Under these circumstances, then, it seems appropriate that, where the Commission will have to resolve which of the disputed provisions to adopt, it should require a showing of actual harm before rejecting any generator sponsored provision. Otherwise, EPSA believes it and the generator community have offered an approach that can work, and that is most consistent with the Commission’s “best interconnection practices” in particular, and its open access and competition policies in general.