FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON STANDARDIZING GENERATOR INTERCONNECTION AGREEMENT AND PROCEDURES
INTERCONNECTION PRODUCTS
It is critically important that the Commission incorporate the provisions of Attachment A: “Generator Interconnection Products and Services” (“Attachment A”) to the Interconnection and Operating Agreement, and resolve whatever outstanding issues remain with respect to Attachment A. Industry participants must have a clear understanding of each interconnection product and service they have a right to receive, the nature of whatever study is necessary in order for the transmission provider to provide such product or service, and the rights, obligations, delivery implications, and other consequences both to the interconnecting generators and to the providers, that are associated with each such product or service.
Attachment A represents the culmination of an intense drafting and consensus-building process. The definitions stated and approach taken represent a thoughtful and well-reasoned means for resolving the difficult issues posed. EPSA strongly urges the Commission to adopt Attachment A as the cornerstone of any NOPR and Final Rule going forward.
Attachment A identifies two specific interconnection products – Energy Resource Interconnection Service (“ERIS”) and Network Resource Interconnection Service – as well as a third, more generally described alternative, Optional Interconnection Service. Hence, Attachment A adopts and implements two of the “best practices” identified by the Commission in the October 25, 2001 notice: (1) the offer of multiple interconnection products which will provide Generators the flexibility to select their preferred levels of deliverability, and (2) comparable treatment for all generator interconnections which will allow merchant generators to obtain access to load, and to serve load growth, on the same basis as a Transmission Provider who uses its own generation to serve native load.
Flexibility in the choice of interconnection products will promote efficient use of the transmission system, both by allowing each interconnecting generator to select the level of interconnection that it believes is most economic and by facilitating use of existing transmission capacity when available, and/or enhancement of that capacity when required for the delivery of output. An essential part of this flexibility is not only the ability to choose whether to be an Energy Resource or a Network Resource, with the deliverability implications each entails, but to negotiate with the Transmission Provider on a case-by-case basis an optional level of interconnection which meets the specific requirements of the Generator in reaching its intended market.
The guarantee of comparable treatment in obtaining interconnection to the transmission system will provide a powerful incentive for new entry, a necessary pre-requisite for competitive markets as demand continues to grow. Indeed, the essential feature of Network Resource Interconnection Service is the performance of studies based on the assumption that the interconnecting generator will have the exact same access to customers on the transmission provider’s system (assuming they pay the appropriate delivery service charge) as the provider’s own generators have to their network customers.
This comparability principle, in turn, should be carried through in the interconnection procedures and agreement. Thus, for example, when constructing upgrades pursuant to the Interconnection Agreement, the Transmission Provider should be required to use its best efforts, including, for example, the use of its eminent domain authority, where necessary to accomplish such construction.
EPSA would note, briefly, that the concern raised by some parties, that the document does not adequately take into account regional and geographic variations, has in fact been addressed in the document itself. The document accommodates regional differences in the same manner as the Commission accommodates variations from the pro forma open access transmission tariff. Parties, when making their compliance filings to implement whatever final rule the Commission adopts, will have the opportunity to demonstrate that a particular region’s approach to a given aspect of the interconnection process is equivalent, or superior, to the pertinent pro forma provisions.
Moreover, any objection that optional studies will slow down the process is met simply by allowing qualified third parties to perform the studies with data supplied by the transmission providers. And even if there were queuing implications or other uncertainty associated with such studies, as some have suggested, this would not provide a basis for prohibiting optional studies, but at most for determining that as of a given point in the process, no other party should be negatively impacted were the requesting generator to proceed along the path set forth in the optional study.