Submitted on behalf of Large-scale Solar Association (LSA)
Susan Schneider (email@example.com)
Please see attachment for mark-up.
Submitted on behalf of Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
Margaret McNaul (firstname.lastname@example.org)
Please see the attached document.
Submitted on behalf of Valley Electric Association, Inc.
Brad Van Cleve (email@example.com)
Valley Electric Association, Inc. (VEA) is concerned that the Tariff language as drafted implies that a PTO’s Local Transmission Revenue Requirement (TRR) will automatically be updated as new Local Transmission Facilities are built. This is not the case for VEA. TRR is defined in the Tariff as the “the total authorized revenue requirements” associated with facilities. VEA’s “authorized” Low Voltage TRR was established pursuant to a settlement in its FERC transmission rate case that established a stated rate. As a result, VEA’s Low Voltage TRR cannot change unless a transmission rate case is filed with FERC under Section 205 of the Federal Power Act.
Our attached comments are intended to clarify that the 15% cap on reimbursement for low voltage network upgrades related to generator interconnections is calculated based on the authorized Local TRR.
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