FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON STANDARDIZING GENERATOR INTERCONNECTION AGREEMENT AND PROCEDURES

REMEDIAL AUTHORITY

The Commission should impose meaningful conditions and, if necessary, sanctions, on Transmission Providers that fail promptly to comply with the new requirements for interconnection and system access. EPSA recommends, for example, that the Commission make clear that adoption of the new pro forma interconnection rules is an element of the open access transmission obligation imposed by Order No. 888 that is a condition for granting or for maintaining a Transmission Provider’s market based rate authority. EPSA also urges the Commission to use its conditioning authority to ensure that municipal, cooperative or other utilities that are not subject to the Commission’s Section 205 jurisdiction also adopt the standard products, procedures and agreement as ultimately set forth in the Final Rule.

As the Commission noted in its October 25, 2001 Notice, interconnection is a component of transmission service. Just as the Commission has required reciprocity with respect to the adoption of open access tariffs by non-jurisdictional entities seeking to avail themselves of the benefits of the Commission’s pro forma open access transmission tariff, the Commission should take the same action with respect to interconnection service. No entity should be allowed to obtain transmission service on any jurisdictional transmission system without offering the same products, procedures and standard agreement promulgated by the Commission in this proceeding.

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