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Ferc Pro Forma Interconnection Agreement

26. EEI also argues that the previous option for the construction of provisions “would ensure that the transmission provider meets the appointments desired by the interconnection customer and provides an option . . . . the transmission provider has not reacted. [67] The IEEE further states that Regulation 845 is unfair and inappropriate, as the more liaison customers make use of the construction option, the transmission provider`s ability to make decisions about its own wealth or the location of assets “will gradually diminish”. [68] 144. Secondly, with regard to the retirement of the initial alternator as part of an excess connection agreement, AWEA asks the Commission to clarify that, during the additional one year prior to the departure of the original alternator, a new alternator may, under existing RTO/ISO rules, request repowering or replacing instead of interconnection at the time of interconnection. In addition, AWEA calls on the Commission to clarify that if the pension and replacement procedure is successful, the excess interconnected could continue to work after the expiry of the additional one-year period. [295] AWEA also calls on the Commission to clarify that rules and procedures for replacement or repowering schemes are also available to customers of excess liaison services. [296] 146. We find that AWEA`s description of the multiphase model does not match the excess connection service described in The 845. In Regulation 845, the Commission found that the use of an excess interconnection service was appropriate when link customers do not use the full production capacity of their interconnection network service because of the nature of their operation.

[299] The Commission also accepted CAISO`s argument that “the initial liaison client . . . . reduces the production capacity of its facility compared to what was originally proposed for interconnection and would not retain the rights to the transport capacity thus created.” [300] Furthermore, to find that there are no substantial doubts about the potential of a hort liaison service, we have relied on the fact that, at present, an initial link customer can only provide one interconnection service based on the production capacity of the production facility it is building and continuing to operate. [301] Given that, based on these findings, AWEA`s proposed “multi-phase” model is based on the idea that the initial link client would deliberately provide a quantity of interconnection services greater than the size of the production facility it is building and continues to operate, we find that this approach would not be compatible with the excess interconnection service provided by Regulation 845. 34. Article 5.2, paragraph 9, of the pro forma LGIA, which Regulation 845 has not amended, states that “[d.nless Parties otherwise agree, Interconnection Customer is transfer ownership of Transmission Provider`s Interconnection Facilities and Stand Alone Network Upgrades to Transmission Provider.” Eversource Energy Service Company (Eversource) provided a comment in response to NOPR and asked the Commission to grant a flat-rate authorization in accordance with Section 203 of the VPA [85] for the transfer of the transportation provider`s interconnection facilities and/or stand-alone network upgrades that were established in accordance with the construction option. [86] Eversource submitted, in particular, that when electricity passes through transmission facilities in intergovernmental trade, such “entities are considered [the Commission`s jurisdiction] even if they are not in service otherwise” and that the administrative authorization required by Section 203 of the VPA is “an additional undertaking”.

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