FERC Filings

EPSA Comments and Protest On MISO's Compliance Filing to Revise Schedule 2 of Open Access Transmission Tariff

CONCLUSION

For the reasons explained above, EPSA urges the Commission to carefully review the process outlined in proposed new section II. Qualified Generator, A. General Qualifications, and section II. C, and MISO’s November 16 supplemental letter, and: (1) direct MISO to amend section II. A “Qualified Generator” by including a definitive framework and timetable for reviewing the qualifications of all generators who provide reactive power; (2) shorten the time period specified in section II.C. from 60 to 15 days, and provide for compensation payments covering the entire period for qualified generators; (3) clarify that IPPs are not required to satisfy a “needs test” as a precondition for recovery under Schedule 2; (4) direct MISO to amend the definition of Qualified Generator in sec.1.46b as described herein to clarify that generation resources are not required to assume obligations associated with transmission customers and (5) accept the compliance filing, with the modifications described above, to become effective January 1, 2005. These modifications will help to ensure that the provisions in Schedule 2 are applied in a manner that does not create potentially discriminatory and preferential outcomes, and that IPPs begin to receive compensation as soon as administratively possible.

Respectfully submitted,

John K. Hawks, Acting Vice President of Policy
Mark E. Bennett, Director of Policy
Electric Power Supply Association
1401 New York Ave, NW
11th Floor
Washington, D.C. 20005
Phone: 202-628-8200

November 22, 2004