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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.

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ferc docket no rm10 23 000

FERC DocketNo. RM10-23-000

Transmission Planning and Cost Allocation by

Transmission Owning and Operating Public Utilities

ferc docket no rm10 23 0001

FERC Docket No. RM10-23-000

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.

ferc docket no rm10 23 0002

FERC Docket No. RM10-23-000

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.

ferc docket no rm10 23 0003

FERC Docket No. RM10-23-000

It is reasonable to include in transmission policy and planning requirements state energy policies, such as renewable mandates.

ferc docket no rm10 23 0004

FERC Docket No. RM10-23-000

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 docket no rm10 23 0005

FERC Docket No. RM10-23-000

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 docket no rm10 23 0006

FERC Docket No. RM10-23-000

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.

ferc docket no rm10 23 0007

FERC Docket No. RM10-23-000

Comments are due at FERC on September 29, 2010.

Questions?