"We view the [Entergy-ITC] transaction [as] an attempt to extract excess value."-Mississippi PSC
below 69 kV), and subdivide the low-voltage group by plant size (under 2 MW, 2 to 10 MW, and 10 to 20 MW). It would establish two different safe-harbor screening tests: an Appendix 1 ("super-expedited") screen, plus an Appendix 2 ("expedited") screen, applicable to the two smallest plant categories of low-voltage connections. Those units of 2 MW or less and connected at low voltage that pass the Appendix 1 screen would be home free without any further sign-off on safety or reliability-attracting protests from state PUCs and transmission owners.
By contrast, it is believed that the state PUCs that have adopted rules in this area limit their effect to plants no larger than 10 MW, or set even small thresholds for maximum plant capacity. Noting that, the Edison Electric Institute and the National Rural Electric Cooperative Association (NRECA) complain that FERC's 20-MW cutoff point is too high and that its screening requirements are too lax.
"It is arbitrary and capricious," says NRECA, "for the [FERC] to presume that a 2-MW facility is likely to have 'no impact' on a transmission provider's low-voltage system."
Many distribution circuits have a total capacity of less than 1 MW, as NRECA points out. "It should be obvious," the group adds, that you cannot interconnect a 1-MW unit with such a circuit without "expensive and extensive upgrades."
The engineering firm R.W. Beck takes the opposite tack, however, calling the Appendix 1 screen "too restrictive." But even more confusion abounds, as explained by the small generator coalition.
The coalition says the two screens were designed by the industry initially to work in tandem. The Appendix 1 screen was made especially tight, they say (likely leading to many "false positives"), since units of 2 MW or less that pass the screen would face no further test for safety or reliability. Thus, they would then put the units under 2 MW through the second screen to weed out those false positive results and create a more accurate process. Units failing the first screen but then passing the second one would still face review by the transmission owner for safety and reliability, with the transmission owner having the burden of proof.
All of this leaves the coalition dismayed and alarmed that the FERC did not understand the proper functioning of the two screens, as the group explains:
"Instead of implementing the screens in this manner [sequentially], or simply splitting the difference between the two sets of screens, the NOPR applies the primary [Appendix 1] screens to generators less than 2 MW and, inexplicably, applies the secondary screens to generators between 2 and 10 MW.
"This approach actually destroys the intended functionality of the screens."
Procedures and Property Rights
Overall, the energy industry voices many concerns to FERC, some of which have already been considered in discussions about FERC's rule for large-scale plant interconnections:
- Eligibility. Use total nameplate capacity to prevent multi-unit wind turbine developments, or other clustered gen units, from recharacterizing into separate projects with smaller capacities to gain coverage under the rule.
- PURPA Compliance. Don't require qualifying cogeneration facilities to