FERC Filings
EPSA Comments and Protest On MISO's Compliance Filing to Revise Schedule 2 of Open Access Transmission Tariff
INTRODUCTION
In its October 1 order, the Commission rejected MISO’s proposed Schedule 21, finding that certain provisions within it were unduly discriminatory and preferential. Also, the Commission found MISO’s Schedule 2 to be unjust, unreasonable and unduly discriminatory under section 206 of the Federal Power Act, and directed MISO to combine the compensation provisions for all reactive power suppliers, including both utilities and IPPs, in Schedule 2. After observing that all providers of reactive power “should be compensated for providing that service” the Commission further emphasized that “generators that provide that service should not be treated in an unduly discriminatory fashion.”
While the Commission focused on several specific aspects of both schedules , the central theme of the order was clear: incumbent utilities and IPPs must be subject to the same terms and conditions for reactive compensation. Moreover, proposed distinctions or differentiation between the two generator categories, if any, must not discriminate against or otherwise disadvantage IPPs. EPSA generally supports the proposed new Schedule 2, and believes that, if properly and quickly implemented, it will remedy the inequity of uncompensated reactive power.
However, while there may be administrative reasons for automatically granting “Qualified Generator” status to all existing generation resources under proposed new section II A. of Schedule 2, the Commission should consider improving the process by directing MISO to add terms that specify a definitive framework and timetable for the ongoing review of Qualified Generators to ensure that all parties, including existing utility generators, satisfy the applicable technical specifications. Additionally, EPSA urges the Commission to direct MISO to shorten from 60 to 15 days the time period for MISO to review IPP certifications of compliance with the applicable technical qualifications. Further the Commission should MISO to amend the definition of Qualified Generator to clarify that generation resources are not required to assume obligations associated with transmission customers. Finally, EPSA notes that in an order issued only last month, the Commission expressed its disfavor for imposing 'needs' tests on generators providing reactive power. Accordingly, EPSA believes that MISO's suggestion that generators within its footprint be subject to such a precondition is misplaced and should be rejected.