FERC Filings

Comments of EPSA on FERC's Staff Report and Technical Conference Regarding Reactive Power and Voltage Control

Conclusion

EPSA appreciates the attention being devoted to reactive power and voltage support services, which are critical for system reliability. We strongly support the Commission’s effort to promote the availability of this critical reliability service by ensuring that all generators are compensated on terms and conditions that are fair, comparable and nondiscriminatory. Accordingly, EPSA urges the Commission to take all actions necessary to achieve that objective, including:

1. Harmonizing RTO and non-RTO areas by directing all transmission providers to amend their Open Access Transmission Tariffs (OATT) to ensure comparable treatment of IPPs;

2. Reviewing all existing interconnection agreements to confirm that IPPs are adequately compensated for the voltage support services they are obligated to provide;

3. Clarifying and expanding the reactive power payment provision, LGIA Article 9.6.3, by unequivocally stating that interconnecting generators are entitled to full compensation for all voltage support/stability enhancement services they provide; and

4. Directing transmission providers, or affiliates responsible for the commercial operation within a control area to execute commercial agreements with IPPs in their region, to address reactive compensation issues.

Respectfully submitted,

Nancy Bagot, Vice President of Regulatory Policy
Mark E. Bennett, General Counsel/Director of Policy
Electric Power Supply Association
1401 New York Ave, NW, 11th Floor
Washington, D.C. 20005
Phone: 202-628-8200

April 4, 2005