FERC Docket No. RM10-23-000. Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities. FERC Docket No. RM10-23-000. These comments respond to FERC’s proposed reforms concerning transmission planning and cost allocation.
Transmission Planning and Cost Allocation by
Transmission Owning and Operating Public Utilities
These comments respond to FERC’s proposed reforms concerning transmission planning and cost allocation.
FERC’s proposed rule provides that the local and regional transmission planning process now include transmission needs driven by public policy requirements, such as intrastate renewable mandates.
The proposed rule would also remove from FERC-approved tariffs a right of first refusal for an incumbent transmission provider for the construction and ownership of new facilities.
Support FERC’s proposal to adopt a beneficiary-pays approach to transmission cost recovery.
It is reasonable to include in transmission policy and planning requirements state energy policies, such as renewable mandates.
If FERC is to include the addition of the state energy policies and mandates, FERC must determine each individual state’s ability to meet its renewable mandates on an intrastate basis.
If state energy programs are to be included in the transmission planning process, individual states must be provided stakeholder status in the planning process.
FERC’s proposal to eliminate the right of first refusal has merit and should be pursued further if it can be demonstrated that real customer savings can be realized.
FERC must establish criteria to determine whether the merchant provider has the access to the necessary capital to meet its obligations.
FERC must ensure that the merchant transmission provider is required to adhere to all applicable state requirements.
FERC must arrive at appropriate sanctions if a merchant provider fails to deliver.
Comments are due at FERC on September 29, 2010.