FERC Filings

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

PREFACE

Pursuant to Section 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. § 385.211, the Electric Power Supply Association (EPSA) respectfully files these comments and protest in the above-captioned proceeding. EPSA applauds the Commission’s resolve to ensure that RTO/ISO tariffs contain provisions for fair and equitable compensation for reactive power that are not unduly discriminatory or preferential. In its October 1 order, the Commission unequivocally rejected tariff provisions for reactive power compensation that place utilities and IPPs into separate categories, with separate requirements. Subject to the comments, protest and suggestions made below, EPSA supports the proposal to combine the provisions for both utilities and IPPs in Schedule 2 of MISO’s tariff. With the modifications explained below, EPSA urges the Commission to direct MISO to implement the proposed provisions on Jan. 1, 2005.

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