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Comments on Tariff revisions

Interconnection process enhancements 2021

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Comment period
Dec 02, 10:30 am - Dec 15, 05:00 pm
Submitting organizations
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LSA
Submitted 12/16/2022, 01:15 pm

Submitted on behalf of
Large-scale Solar Association (LSA)

Contact

Susan Schneider (schneider@phoenix-co.com)

1. Please provide a summary of your organization’s comments on the IPE 2021 phase 2 tariff revisions.

Please see attachment for mark-up.

2. Please provide your organization’s comments on section 8.9.2 Second Component: Allocating TP Deliverability.
3. Please provide your organization’s comments on section 14.3.2.4 Local Transmission Facilities.
4. Please provide your organization’s comments on Appendix F, Schedule 3 Section 12.1 Division of Costs.
5. Please provide any additional comments on the IPE 2021 phase 2 tariff revisions.
Attachments

Six Cities
Submitted 12/15/2022, 06:47 pm

Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California

Contact

Margaret McNaul (mmcnaul@thompsoncoburn.com)

1. Please provide a summary of your organization’s comments on the IPE 2021 phase 2 tariff revisions.

Please see the attached document.

2. Please provide your organization’s comments on section 8.9.2 Second Component: Allocating TP Deliverability.

Please see the attached document.

3. Please provide your organization’s comments on section 14.3.2.4 Local Transmission Facilities.

Please see the attached document.

4. Please provide your organization’s comments on Appendix F, Schedule 3 Section 12.1 Division of Costs.

Please see the attached document.

5. Please provide any additional comments on the IPE 2021 phase 2 tariff revisions.

Please see the attached document.

Valley Electric Association, Inc.
Submitted 12/15/2022, 01:44 am

Submitted on behalf of
Valley Electric Association, Inc.

Contact

Brad Van Cleve (bvc@dvclaw.com)

1. Please provide a summary of your organization’s comments on the IPE 2021 phase 2 tariff revisions.

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.  

 

2. Please provide your organization’s comments on section 8.9.2 Second Component: Allocating TP Deliverability.
3. Please provide your organization’s comments on section 14.3.2.4 Local Transmission Facilities.
4. Please provide your organization’s comments on Appendix F, Schedule 3 Section 12.1 Division of Costs.
5. Please provide any additional comments on the IPE 2021 phase 2 tariff revisions.
Attachments
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