May [19], 2000



June [__], 2000

The Honorable David P. Boergers, Secretary

Federal Energy Regulatory Commission

888 First Street, N.E.

Washington, D.C. 20426

Re: Southwest Power Pool, Inc., Docket No. ER00-____

Amendments to Open Access Transmission Tariff

Dear Mr. Boergers:

In accordance with section 205 of the Federal Power Act, 16 U.S.C. § 824d, and section 35.13 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of Practice and Procedure, 18 C.F.R. § 35.13, Southwest Power Pool, Inc. (“SPP”), hereby submits certain revisions to its Open Access Transmission Tariff (“Tariff”). By this filing, SPP proposes to amend its Tariff to add a new Attachment V prescribing coordinated procedures for customers seeking interconnection of generation.

SPP requests that the Commission accept the proposed Attachment V to become effective on June [__], 2000. Commission acceptance is warranted because:

• The procedures improve SPP’s Tariff by adding specific procedures governing how generators interconnect with the transmission system.

• The procedures are modeled on interconnection procedures previously accepted by the Commission.

Moreover, prompt adoption and effectiveness of the procedures will limit grandfathering issues which have been contentious in other regions.

I. NATURE OF FILING

The purpose of this filing is to amend SPP’s Tariff to include a new Attachment V (and related appendices) which set forth generation interconnection procedures. SPP’s Tariff currently does not contain procedures for requesting interconnection services or the criteria under which such requests are evaluated. As explained in Part II, the generation interconnection procedures in this filing were developed after an extensive study process involving working groups and committees comprised of members representing SPP’s diverse Membership. The procedures improve the pro forma transmission tariff which does not directly or explicitly deal with interconnection procedures for new generators. By filling this gap, this filing will put in place clear procedures to facilitate the interconnection of new generation in the SPP Region.

As discussed below, SPP’s proposal to include these procedures in its Tariff is consistent with Commission policy[1] and Commission precedent encouraging the inclusion of interconnection procedures in open access transmission tariffs.[2] Indeed, Attachment V is modeled in large part on the interconnection procedures accepted by the Commission in PJM. Including the proposed procedures in SPP’s Tariff will ensure that interconnection requests in the SPP Region are encouraged and continue to be treated in a non-discriminatory manner.[3] Further, by identifying the information SPP requires to evaluate interconnection requests and by providing time frames for the study of such requests, any uncertainty over the generation interconnection process should be eliminated.

The Attachment V procedures apply only to requests for interconnection. A customer seeking to be placed in the queue for transmission service on SPP’s transmission system must submit a separate request pursuant to the applicable provisions of SPP’s Tariff. See Tariff Sections 17 and 18 and Forms of Application for Transmission Service in Attachment Q.[4]

II. PROCESS RESULTING IN THE COORDINATED GENERATION INTERCONNECTION PROCEDURES

This filing is the culmination of an extended collaborative process undertaken by various SPP working groups and committees with members from all industry segments to develop coordinated procedures governing the generation interconnection process.

SPP’s Tariff, which became effective on June 1, 1998, is largely based on the Commission’s pro forma open access tariff and, like the pro forma tariff, contains no explicit provisions for the interconnection of generation to the transmission system. When the Tariff was implemented it was expected that prospective generation customers would use the procedures of individual transmission owners for interconnection. However, the interconnection procedures vary for transmission owners within the SPP Region and interconnection requests may affect more than one transmission owner, thereby creating problems with continued reliance on the individual transmission owner procedures when transmission is provided under a regional tariff.

In response to this situation, in early 1999, SPP’s Transmission Assessment Working Group (“TAWG”) began reviewing existing generation interconnection procedures, including procedures that had been accepted by the Commission.[5] Based on that review, the TAWG presented an initial draft of generation interconnection procedures to SPP’s Engineering & Operating Committee and Commercial Practices Committee.[6] Both committees provided numerous comments and suggestions on the draft procedures. These comments were incorporated into a revised draft which was again reviewed by both committees in the fall of 1999. Based on this review and input, with some minor modifications, the TAWG completed its development of the interconnection procedures and sent them to SPP’s Regional Tariff Working Group (“RTWG”) for further review.

The RTWG, consisting of members representing SPP’s diverse Membership, addressed some remaining issues and approved a final version of the interconnection procedures on April 13, 2000.[7] On May 3, 2000, SPP’s Commercial Practices Committee recommended that the SPP Board of Directors approve the interconnection procedures for filing with the Commission as an attachment to the SPP Tariff. The SPP Board of Directors, reflecting the diverse perspectives and experiences of the SPP Membership,[8] as well as seven independent, nonstakeholder Directors, approved the Commercial Practices Committee’s recommendation, without dissension, on May 11, 2000.

Therefore, in developing these procedures, SPP followed a true collaborative process with members from all industry segments involved including the generation, marketing, customer, and transmission owning segments. And, SPP’s diverse Membership as reflected in the composition of its Board of Directors voted for this filing. Accordingly, SPP urges the Commission to accept the proposed procedures without modification.[9]

III. DESCRIPTION OF THE COORDINATED GENERATION INTERCONNECTION PROCEDURES

A. Overview Of The Procedures

Like the procedures accepted by the Commission in PJM (87 FERC at 62,196-97), the procedures set forth in the new Attachment V of the SPP Tariff will be applicable to all requests for interconnection of generation to the SPP transmission system. The procedures thus will be applicable not only to additions of new generation, but also to increases in the capacity of existing generating plants. Id. As a result, the new procedures will not discriminate in favor of, or against, any new generation.[10]

An entity desiring to connect generation to the SPP transmission system (“Generation Interconnection Customer”), must submit to SPP both a Generation Interconnection Request and an executed Feasibility Study Agreement in the form contained in Appendix E to Attachment V, under which the customer must agree to reimburse SPP for the actual cost of the Feasibility Study. The normal interconnection process will consist of a request by the Generation Interconnection Customer (Section 1.1) that initiates the Feasibility Study (Section 1.2). The study process would then progress through the System Impact Study (Sections 1.3-1.5) and the Facilities Study (Sections 1.7-1.8).[11] Third party studies may be used for any or all studies upon mutual agreement between the customer and SPP.[12] The Generation Interconnection Customer may expedite the study process at the time it submits its initial request by requesting either an Expedited System Impact Study (which combines in one study the feasibility and impact studies) (Section 1.6) or an Expedited Generation Interconnection Study (which combines in one study the feasibility, impact and facility studies) (Section 1.9).

Prepayments for all studies must be made by the Interconnection Customers based on estimates by SPP on an individual request basis.[13] The customer is responsible for SPP’s actual study costs including any actual costs in excess of prepaid amounts. Prepaid amounts in excess of actual costs will be refunded.[14] Adjustments to the study cost estimates may be made by SPP during or after the study. The Generation Interconnection Customer may terminate its Generation Interconnection Request at any time during the study process upon written notice to SPP. Any such termination does not relieve the Generation Interconnection Customer of study costs incurred or committed to be incurred by SPP. All interconnection requests shall be deemed complete once the completed application and appropriate prepayment have been received by SPP.

Upon completion of the study process SPP will provide the interconnection customer and affected transmission owner with a Generation Interconnection Agreement that will specify the transmission owners responsible for the construction of necessary facilities and upgrades.[15] Section 1.10. The interconnection customer will retain its first-come, first-served interconnection priority under Section 1.11 by executing the interconnection agreement and providing reasonable security equal to the estimated cost of new facilities or upgrades. Section 1.10.2.[16] The customer must also complete a Notice to Proceed obligating it to pay for the necessary facilities and upgrades related to the interconnection as specified in the interconnection agreement. Sections 1.10.3 and 2. SPP will file the Interconnection Agreement with the Commission consistent with Commission regulations. Section 1.10.4.[17]

B. Detailed Description Of Procedures

1. Generation Interconnection Requests

A Generation Interconnection Customer must submit a Generation Interconnection Request to SPP that describes the project, including, among other things, the location, size, and planned date that the generation will be in service. Section 1.1. To facilitate the Feasibility Study, the customer must cooperate by supplying any additional information reasonably prescribed by SPP and contained in the NERC Planning Standards or the SPP Criteria. Id.

2. Study Procedures

Sections 1.2 through 1.9 of Attachment V set forth the study procedures by which SPP, in coordination with affected Transmission Owners, will evaluate Generation Interconnection Requests. SPP, in accordance with Attachment O to its Tariff, is responsible for the coordination of all studies conducted pursuant to Attachment V. Section 1.12. The affected Transmission Owners are responsible for all estimates of costs and construction times required by Feasibility Studies, System Impact Studies, and Facilities Studies, and for all determinations regarding distribution facilities. Id.[18]

a. Feasibility study

Similar to the study procedures approved in PJM, the Feasibility Study (Section 1.2) is intended to provide customers with a quick, preliminary estimate of the type and cost of facilities and upgrades that will be necessary to accommodate an Interconnection Request. See PJM, 87 FERC at 62,197. SPP will use due diligence to complete a Feasibility Study within the 30 day time-frame prescribed in Appendix A. Id. Customers desire this initial quick, preliminary estimate so that they can determine whether to continue plans for a proposed generation project before more extensive and expensive system impact and facility studies are pursued. The initial Feasibility Study also may narrow the number of projects that decide to proceed to the more extensive study stages, thus lessening the time and complexity of evaluating potential generation projects.[19]

b. System impact study

Once the Feasibility Study is complete, SPP will tender a System Impact Study Agreement to the affected customer. Section 1.3. To retain its queue position,[20] the customer, within 15 days of receiving the agreement, must execute the agreement and return it to SPP[21] and pay the appropriate prepayment based on SPP’s estimate of the actual study costs included in the agreement. Section 1.3.2.[22]

Unlike the preliminary Feasibility Study, a System Impact Study may evaluate more than one Interconnection Request in a single study. Section 1.4.1.[23] The System Impact Studies will identify the system constraints relating to the requests being evaluated, identify the necessary facilities and upgrades to accommodate each request, and provide a refined estimate of each customer’s cost responsibility for the necessary facilities and upgrades. Id.[24]

SPP will use due diligence to complete System Impact Studies within the time frames specified in Appendix A to Attachment V (60-90 days from receipt of an executed System Impact Study Agreement for a System Impact Study and 60-120 days from receipt of a Generation Interconnection Request for an Expedited System Impact Study). Section 1.4.2. These time-frames are consistent with the Commission’s recognition that studies concerning interconnection requests may require more than 60 days. PJM, 87 FERC at 62,198.[25] When completed, SPP will provide a copy of the study and all work papers to all affected customers and transmission owners. Section 1.4.2.

c. Facilities study

Within 30 days of completing the System Impact Study or Expedited System Impact Study, SPP will provide the customer a Facilities Study Agreement. Sections 1.7-1.7.1. SPP will provide the customer with an estimate of the time needed to complete the Facilities Study,[26] the estimated cost of the study, and, where more than one request is being evaluated, the customer’s allocated cost responsibility for the study. Section 1.7.1.[27] These procedures are similar to those approved for facilities studies by PJM. 87 FERC at 62,197-98.

To retain its queue position, the customer must execute the Facilities Study Agreement within 15 days and also prepay the estimated amount of its study cost responsibility. Section 1.7.2. If a participating customer fails to execute the Facilities Agreement or to pay the prepayment, its interconnection request shall be deemed terminated and withdrawn. Id. If such a withdrawn request was to be included in a Facilities Study evaluating more than one request, the costs of the study shall be reallocated among the remaining participating customers. Id. See Section 36.6 of PJM’s approved interconnection procedures.

Similar to the procedures approved in PJM, SPP will conduct the Facilities Studies in coordination with the affected Transmission Owners. Section 1.8. 87 FERC at 62,197. The completed Facilities Studies will contain good faith estimates of the cost to each affected Interconnection Customer for the facilities and upgrades necessary to accommodate each Interconnection Request and the time required to complete construction of those facilities and upgrades. Id. [28]

3. Generation Interconnection Agreement

After completion of the Facilities Study or an Expedited Generation Interconnection Study, SPP will provide a Generation Interconnection Agreement to be executed by SPP, the Interconnection Customer, and the Transmission Owner. Section 1.10. The Generation Interconnection Agreement will specify the Transmission Owners responsible for construction of facilities and upgrades determined consistent with Attachments J (Recovery of Costs Associated with New Facilities) and O (Coordinated Planning Procedures) to SPP’s Tariff. Section 1.10.1.[29] To retain the priority assigned to its interconnection request pursuant to Section 1.11, the customer must execute and return the interconnection agreement to the Transmission Owner within 60 days of completion of the Facilities Study (or Expedited Generation Interconnection Study) as provided in Appendix A to Attachment V. Section 1.10.2(a). See Section 36.8.4(a) of PJM’s approved interconnection procedures. Alternatively, if the customer does not agree with the terms and conditions of the interconnection agreement, it may request dispute resolution under existing Tariff procedures or that an unexecuted agreement be filed with the Commission. Id.[30]

At the time the customer executes and returns the Generation Interconnection Agreement to the Transmission Owner (or requests dispute resolution or that the agreement be filed unexecuted), the customer must provide SPP (for the benefit of the affected Transmission Owners) security (a letter of credit or other reasonable form of security) in an amount equivalent to the estimated costs of the new facilities or upgrades for which the customer is responsible.[31] Section 1.10.2(b). See Section 36.8.4(b) of PJM’s approved procedures. SPP shall provide the affected Transmission Owner with a copy of the letter of credit or other form of security. Id.

If a customer fails to timely execute the Interconnection Agreement (or request dispute resolution or that the agreement be filed unexecuted), fails to meet the requirements set forth in Section 1.10.3, or fails to provide the security prescribed in Section 1.10.2, that customer’s interconnection request shall be deemed terminated and withdrawn. Section 1.10.2(c). See Section 36.8.4(c) of PJM’s approved procedures.[32]

SPP, in coordination with the Transmission Owner, shall submit to the Generation Interconnection Customer a Notice to Proceed upon completion of the Facility/Generation Interconnection Study process. Section 1.10.3. This notice must be completed and returned to SPP and obligates the customer to pay for facilities consistent with SPP’s Tariff. Id. Termination and withdrawal of an interconnection request shall not relieve the customer from reimbursing SPP (for the benefit of the affected Transmission Owner) for the actual costs incurred prior to such termination and withdrawal. Id.

Consistent with applicable Commission regulations, SPP will file an executed interconnection agreement with the Commission. Section 1.10.4. In the event the interconnection customer has requested dispute resolution or that the interconnection agreement be filed unexecuted, construction of facilities and upgrades may be deferred until any disputes are resolved. Id.

4. Priorities and Grandfathered Requests

Each interconnection request received after the Attachment V procedures become effective will be assigned a priority for queue placement on a first-come, first-served basis based on the chronological sequence in which the request was received.[33] Section 1.11. A request that is deemed terminated and withdrawn under Section 1.10.2(c) will lose its priority and will not be included in any further studies; however, an entity may later submit a new request or resubmit a withdrawn or terminated request and receive a new priority based on the time of resubmission. Id.

Similar to the procedures approved in PJM (87 FERC at 62,199-200) and ComEd (slip op. at 3), Section 4 of Attachment V establishes procedures for assigning priorities to an entity that had “pre-existing, continuing plans” to interconnect new generation or increase the capacity of existing generation in the SPP Region prior to the date Attachment V is accepted for filing. SPP will assign a priority to such a request based on the date the request was initiated with the Transmission Owner to which the entity is interconnecting. Section 4. Within 30 days after the Attachment V procedures are accepted for filing, any entity that believes its priority should be based on a date prior to such acceptance may submit to SPP documentation (certified by an officer of the entity and confirmed by the affected transmission owner(s)) that reasonably demonstrates that on the date the entity believes the priority of its request should be based, it could have provided all of the information required under Section 1 of Attachment V. Id.[34] SPP, within 30 days, will notify the entity of SPP’s determination provided, based on the documentation, of the date on which the priority of the entity’s request for interconnection shall be based. Id. SPP will post the priority date on its OASIS as required by Commission regulations.

5. Confidentiality

Section 3 provides that until each study required under Attachment V is complete, SPP will keep confidential all information provided to it by Generation Interconnection Customers relating to such study. SPP will give notice through OASIS when a study is completed and will make the completed study public and available upon request. Id. However, the identity of the Generation Interconnection Customer shall remain confidential until the earlier of the date the Generation Interconnection Agreement is filed with the Commission or the customer permits the study to be made available. Id.[35] Transmission Owner(s) participating in such studies shall keep all information provided by interconnection customers confidential and shall use such information solely for the purpose of the study for which it was provided. Id.

C. Definitional Sections

New definitions are added to Section 1 of SPP’s Tariff to define or clarify terms used in the new Attachment V.

IV. REQUESTED EFFECTIVE DATE AND REQUEST FOR WAIVER

SPP requests that the Tariff amendments be allowed to go into effect on the day after the date of filing. The amendment is necessary to fill the hole concerning interconnection procedures in the pro forma tariff. Moreover, because there are generators today in the SPP Region that require these procedures, it is important that this gap be filled quickly to limit the grandfathering issue. This filing also has no impact on rates. Pursuant to section 35.11 of the Commission’s regulations, SPP requests waiver of section 35.3 (and any other necessary waivers) to allow this effective date. The Commission has accepted similar generation interconnection provisions for filing to be effective one day after filing.[36]

V. ADDITIONAL INFORMATION

A. Information Required By Section 35.13 Of The Commission’s Regulations

SPP submits this filing under the Commission’s abbreviated filing requirements. Consistent with section 35.13, SPP provides the following information:[37]

(1) Documents submitted with this filing:

In addition to this transmittal letter, the following documents are including with this filing: (a) the revised tariff sheets to SPP’s currently effective Tariff, along with redlined versions of those sheets, as Exhibits I and II, respectively; and (b) a form of notice suitable for publication in the Federal Register, as Exhibit III. Additionally, an electronic copy of the form of notice is included on the enclosed diskette.

(2) Effective date:

SPP requests an effective date of June [__], 2000 for the tariff sheets submitted herewith. See supra Part IV.

(3) Names and addresses of persons to whom this filing has been mailed:

A copy of this filing has been served on all SPP Members and customers, as well as on all state commissions within the region. In addition, a copy of this filing will be posted on the SPP web page ().

(4) Description of filing:

A description of the changes, along with the reasons for the changes, is provided above.

(5) Requisite agreements:

The SPP Board of Directors approved these changes at the May 11, 2000 meeting.

(6) Form of notice:

A form of notice suitable for publication in the Federal Register is attached hereto as Exhibit III. In addition, an electronic version of the notice is included on the enclosed diskette.

B. Communications

SPP requests that all correspondence and communications with respect to this filing should be sent to, and that the Secretary include on the official service list, the following:

Michael E. Small Nicholas A. Brown

General Counsel of Senior Vice President and

Southwest Power Pool Corporate Secretary

Wright & Talisman, P.C. Southwest Power Pool

1200 G Street, N.W. 415 N. McKinley

Suite 600 Suite 700; Plaza West

Washington, D.C. 20005 Little Rock, AR 72205

(202) 393-1200 phone (501) 664-0146 phone

(202) 393-1240 fax (501) 664-9553 fax

small@ e-mail nbrown@ e-mail

VI. CONCLUSION

For the reasons stated above, SPP requests the Commission to accept the amendments to SPP’s Tariff reflected in this filing to be effective June [__], 2000.

Respectfully submitted,

WRIGHT & TALISMAN, P.C.

By_________________________________

Michael E. Small

Douglas O. Waikart

1200 G Street, N.W.

Suite 600

Washington, D.C. 20005-3802

(202) 393-1200

Attorneys for

Southwest Power Pool, Inc.

K:\SPP\1001-172-258.doc

Exhibit I

Revised Tariff Sheets

Exhibit II

Red-Lined Tariff Sheets

Exhibit III

Notice of Filing

UNITED STATES OF AMERICA

BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

PJM Interconnection, L.L.C. ) Docket No. ER00-____

NOTICE OF FILING

Take notice that on June [__], 2000, Southwest Power Pool, Inc., (“SPP”) submitted proposed amendments to its Open Access Transmission Tariff adding a new Attachment V prescribing coordinated procedures for customers seeking interconnection of generation. SPP requests that the Commission accept the proposed revisions to become effective on June [__], 2000.

Copies of this filing were served upon all SPP Members and customers, as well as on all state commissions within the SPP region.

Any person desiring to be heard or to protest this filing should file a petition to intervene or protest with the Federal Energy Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426, in accordance with Rules 210, 211 and 214 of the Commission's Rules of Practice and Procedure (18 C.F.R. §§ 385.210, 385.211, 385.214). All such petitions or protests should be filed on or before _____________________. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Any person wishing to become a party must file a petition to intervene. Copies of this application are on file with the Commission and are available for public inspection. This filing may also be viewed on the Internet at (call 202-208-2222 for assistance).

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[1] Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Servs. by Pub. Utils., 1991-96 FERC Stats. & Regs., Regs. Preambles ¶ 31,036, at 31,770 (1996) (“Order No. 888”) (Commission allows modifications to the pro forma tariff that are “consistent with, or superior to, those in the compliance tariff”).

[2] See PJM Interconnection, L.L.C., 87 FERC ¶ 61,299, order on compliance filing, 89 FERC ¶ 61,012 (1999) (“PJM”); Ameren Operating Companies, 89 FERC ¶ 61,041 (1999) (“Ameren”). The Commission very recently recognized the importance of including interconnection procedures in open access transmission tariffs. Commonwealth Edison Co. and Commonwealth Edison Co. of Indiana, 91 FERC ¶ 61,083, slip op. at 9 (April 26, 2000) (“ComEd”); Entergy Services, Inc., 91 FERC ¶ 61,149, slip op. at 7, 10 (May 18, 2000) (“Entergy”).

[3] See, e.g., Central Hudson Gas & Elec. Co., 86 FERC ¶ 61,062, at 61,211 (1999) (directing New York ISO to include in the ISO tariff “procedures for merchant generators to arrange an interconnection in circumstances where they will not be separately obtaining transmission service”).

[4] See Entergy, slip op. at 8 (Commission clarifies that there are no transmission delivery rights, beyond the receipt point, conveyed by an interconnection); see also Tennessee Power Co., 90 FERC ¶ 61,238, at 61,761-62 (Customer must make a separate application under the pro forma tariff for the delivery component of transmission service since interconnection alone conveys no right to delivery service); ComEd, slip op. at 6-7 (Request for transmission service not deemed an interconnection application for purposes of queue priority.).

[5] The TAWG is responsible for planning criteria to evaluate transmission additions, seasonal ATC calculations, seasonal flowgate ratings, oversight of coordinated planning efforts, and oversight of transmission contingency evaluations. The TAWG develops recommendations for the Engineering and Operating Committee regarding changes to SPP criteria and works with individual transmission owners on issues of coordinated planning and NERC and SPP compliance. The TAWG reflects the diverse perspectives and experiences of the following representatives of SPP’s transmission using and transmission owning Members: Mr. Howard Conus, Sr. Engineer, City Utilities of Springfield; Mr. Bill Dowling, Vice President of Energy Mgmt. & Supply, Midwest Energy, Inc.; Mr. Joe Z. Durham, Electrical Engineer, Southwestern Power Admin.; Mr. Ronnie Frizzell, Principal Planning Engineer, Arkansas Electric Cooperative Corp.; Mr. John Fulton, Manager of Trans. Reliability Assessment, Southwestern Public Serv. Co.; Mr. Mike Gevaza, Mgr., Pwr. Del. Plan., OG+E Electric Services; Mr. Jim Kistner, Associated Electric Cooperative, Inc.; Mr. Cory Larson, System Operations Engineer, Empire District Elect. Co.; Mr. Dave Macey, Mgr., Sys. Engin. & Interconn., UtiliCorp United Inc.; Mr. Mark McCulla, Entergy Services; Mr. Matt McGee, Central & South West-TOK; Mr. John A. Payne, Sr. Engineer, KPL, Western Resources, Inc.; Mr. James Simms, Operations Engineer, Cleco Corporation; Mr. Curtis Stepanek, Engineer, Union Electric Company; Mr. Jim Useldinger, Supv., Trans. Planning, Kansas City Power & Light; Mr. Noman Williams, Supervising Engineer, Sunflower Electric Power Corp.; Mr. Jeffry Wilson, ENRON Power Marketing, Inc.

[6] The Engineering and Operating Committee and Commercial Practices Committee report to and are subject to the control of SPP’s Board of Directors. Representatives to the Engineering and Operating Committee are the officer or employee of each SPP Member in charge of engineering and/or operating activities. Representatives to the Commercial Practices Committee are the officer or employee of each SPP Member in charge of ensuring commercially viable processes associated with interconnected electric system operation. SPP currently has 55 Members, including 12 investor-owned utilities, 7 municipal systems, 8 generation and transmission cooperatives, 3 state authorities, 1 federal power marketing agency, 1 wholesale generator and 23 power marketers.

[7] The RTWG reflects the diverse perspectives and experiences of the following Member representatives: Mr. Gene Anderson, Director-Engineering, Oklahoma Municipal Power Authority; Mr. James Armke, Director of Trans. Planning, Central & South West-TOK; Mr. Ricky Bittle, Director-Plann., Rates & Dispatch., Arkansas Electric Cooperative Corp.; Mr. Marvin L. Carraway, General Manager, City of Clarksdale; Mr. Bill Dowling, Vice President of Energy Mgmt. & Supply, Midwest Energy, Inc.; Mr. Mark Foreman, Tenaska Power Services Co.; Mr. John Gunesch Jr., Supervisor, Costing, OG+E Electric Services; Mr. Richard Ingersoll, Vice President, ENRON Power Marketing, Inc.; Mr. Ron Kite, Sr. Wholesale Regulatory Analyst, Kansas City Power & Light; Mr. Mike Proctor, Chief Economist, Electric Department, Missouri Public Service Commission; Mr. Dennis Reed, KPL, Western Resources, Inc.; Mr. Gary Roulet, Dir. - Sys. Planning, Western Farmers Electric; Mr. Max Sherman, Director, Power Marketing, Aquila Energy; Mr. James Sherwood, Director, Division of Rates & Repayments, Southwestern Power Admin.; Mr. Charles Yeung, ENRON Power Marketing, Inc.

[8] SPP’s 21-person Board of Directors is composed of seven directors that are representatives of Transmission Owning Members (including three non-investor owned utility representatives), seven directors that are representatives of Transmission Using Members (consisting of two municipal Members, two cooperative Members, and three marketers and/or independent power producers and/or other Members). SPP Bylaws, Section 4.2.1.

[9] See PJM, 87 FERC at 62,199 (Commission accepts without modification interconnection procedures “which were the outcome of a lengthy stakeholder process”).

[10] For requests involving less than 10 megawatts, SPP plans to develop streamlined procedures. See Attachment V, Section 1.13. SPP, on a non-discriminatory basis, may waive the Attachment V procedures for any request less than 10 megawatts. Id. Generally, increases in generation of 10 MW or less do not require extensive studies or major upgrades. Moreover, generating units frequently are re-rated by only a few megawatts. Accordingly, requests involving such small increases in generation should need not be subject to the extensive procedures set forth in new Attachment V. See PJM, 87 FERC at 62,197, n.14.

[11] All Studies will be coordinated by SPP in conjunction with affected transmission owners. Section 1.12. Time frames for the preparation of studies are provided in Appendix A to Attachment V. These represent the specific time frames in which SPP estimates the studies will be completed. Entergy, slip op. at 9 (interconnection procedures must include specific estimated time frames for study completion). SPP’s time frames are consistent with the Commission’s recognition that studies concerning generation interconnection requests will often require more than 60 days. Id.; PJM, 87 FERC at 62,198. See also ComEd, slip op. at 11 (Tariff provision establishing an “outside limit for study completion” is superior to pro forma tariff).

[12] See PJM, 87 FERC at 62,199 (use of third party studies left to discretion of transmission provider).

[13] Prepayment is in lieu of nonrefundable deposits approved by the Commission in PJM. 87 FERC at 62,197-98. Like nonrefundable deposits, prepayment of study costs should limit requests to “serious proposals” and discourage generators from using SPP as a consultant to study the feasibility of projects they do not seriously contemplate constructing. Id. at 62,198.

[14] See PJM, 87 FERC at 62,197; Entergy, slip op. at 12. Deposit amounts in excess of actual study costs refunded.

[15] The Commission has found that involvement of the transmission owners in the interconnection agreement is appropriate given that “interconnection of new generation requires physical changes to the facilities” of the transmission owner. PJM, 87 FERC at 62,199.

[16] Special procedures are established in Section 4 of Attachment V for the assignment of priorities to grandfathered requests arising prior to the effective date of the Attachment V procedures. See discussion of “Priorities and Grandfathered Requests,” infra.

[17] The Commission has not required the inclusion of standardized, pro forma study or interconnection agreements in interconnection procedures. See, e.g., ComEd, slip op. at 8-9.

[18] As recognized by the Commission, the Transmission Owners are the parties most knowledgeable about the transmission system and their involvement in the study process is reasonable. PJM, 87 FERC at 62,199.

[19] A form of Feasibility Study Agreement is contained in Appendix E to Attachment V.

[20] Each Generation Interconnection Request will be placed in a queue and assigned a “first-come, first-served” priority based on the chronological sequence in which it was received. See Section 1.11, discussed infra.

[21] See ComEd, slip op. at 7 (Fifteen day period for response to system impact study consistent with pro forma tariff.)

[22] The inclusion of an estimate of study costs in the agreement is consistent with the pro forma tariff. ComEd, slip op. at 10. Similar to the procedures approved in PJM, the customer’s study cost responsibility for both the System Impact Study and Facilities Study (discussed in detail infra) will be allocated on the following basis: (1) the Interconnection Customer will be responsible for 100% of the study costs associated with evaluating the facilities necessary to physically connect the generating unit to the substation (Attachment Facilities) and other necessary Direct Assignment Facilities and (2) for the study costs associated with evaluating system upgrades necessary to accommodate its Interconnection Request, the Interconnection Customer will be responsible for such study costs in proportion to its projected upgrade cost responsibility (as determined in the Feasibility Study or System Impact Study, respectively). See Sections 1.3.1, 1.7.2.

[23] For all requests for interconnection received prior to the date the Attachment V procedures become effective, SPP will commence System Impact Studies as though all such requests were received at the same time. Section 1.5.

[24] If requested by the customer at the time of the initial interconnection request, SPP will prepare an Expedited System Impact Study that combines the Feasibility Study and System Impact Study as provided in Attachment V. Section 1.6.

[25] SPP will notify the affected customers and transmission owners if it is unable to complete an impact study within the Appendix A timeframes and provide an estimated completion date and the reasons additional time is required. Section 1.4.2. Id.; see also ComEd, slip op. at 11; Entergy, slip op. at 9.

[26] Appendix A to Attachment V reflects an estimated time frame of 60 days for study completion.

[27] As previously noted, cost responsibility for the Facilities Study is determined pursuant to Section 1.7.2 on the same basis specified in Section 1.3.1 for System Impact Study cost responsibility.

[28] An Expedited Generation Interconnection Study process is available to interconnection customer that desire to complete feasibility, impact, and facility studies in one study within an estimated time-frame of 90-120 days from receipt of an interconnection request. See Attachment V, Section 1.9, Appendix A.

[29] Section 2 of Attachment V provides that the Generation Interconnection Agreement will specify the interconnection customer’s responsibility for the costs of facilities or system upgrades necessary to accommodate the customer’s interconnection request. See ComEd, slip op. at 16 (Commission accepts tariff provision providing that costs of interconnection facilities and system upgrades borne by customer will be specified in interconnection agreement).

[30] See ComEd, slip op. at 13-14 (Applicant has option of requesting transmission provider to file unexecuted interconnection agreement without losing its position in queue). The Commission has noted the desirability of dispute resolution procedures to resolve differences concerning new facilities or system upgrades related to interconnection of generation. PJM, 87 FERC at 62,199.

[31] ComEd, slip op. at 15-16 (Requirement of reasonable credit support consistent with pro forma tariff).

[32] If a terminated and withdrawn request was included in a Facilities Study that evaluated more than one interconnection request, SPP will reevaluate the need for the facilities and upgrades indicated by the Facilities Study, redetermine the cost responsibility of each remaining customer for the necessary facilities and upgrades, and enter into an amended interconnection agreement with each remaining customer setting forth the customers’ revised cost obligations. Id.

[33] This is the same basis approved by the Commission for establishing priorities in PJM. 87 FERC at 62,200; see also ComEd, slip op. at 6 (Queue priority established by the date on which interconnection request is received).

[34] See PJM, 87 FERC at 62,201 (Commission accepts similar procedures in Art. IV, Section 39.2 of PJM Tariff for assigning earlier priority based on pre-existing interconnection plans).

[35] The Commission has approved interconnection procedures that do not name the applicant on OASIS. PJM, 87 FERC at 62,201 (OASIS reflects only the location and size of study project without identifying applicant).

[36] See PJM Interconnection, L.L.C., 87 FERC ¶ 61,299, at 62,204 (1999); see also Indianapolis Power & Light Co., 90 FERC ¶ 61,180, at 61,587 (2000) (Commission waives 60-day notice requirement to allow open access tariff provisions to become effective one day after filing.).

[37] As this filing does not include any rates, the provisions of section 35.13 pertaining to rates are not addressed here.

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