UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Refinements to Policies and Procedures ) For Market-Based Rates for Wholesale ) Docket No. RM Sales of Electric Energy, Capacity, and ) Ancillary Services by Public Utilities ) COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION The Electric Power Supply Association ( EPSA ) 1 respectfully submits the following comments in response to the Federal Energy Regulatory Commission s ( FERC or Commission ) June 19, 2014 Notice of Proposed Rulemaking ( NOPR ) regarding Refinements to Policies and Procedures for Market-Based Rates for Wholesale Sales of Electric Energy, Capacity, and Ancillary Services by Public Utilities ( NOPR or MBR Refinements NOPR ). 2 The NOPR proposes amendments to Subpart H to Part 35 of Title 18 of the Code of Federal Regulations ( CFR ) to streamline and simplify the market-based rate regulations and requirements and reduce the burdens on market participants seeking to comply with the Part 35 regulations. 1 EPSA is the national trade association representing competitive power suppliers, including generators and marketers. Competitive suppliers, which, collectively, account for 40 percent of the installed generating capacity in the United States, provide reliable and competitively priced electricity from environmentally responsible facilities. EPSA seeks to bring the benefits of competition to all power customers. The comments contained in this filing represent the position of EPSA as an organization, but not necessarily the views of any particular member with respect to any issue. 2 Refinements to Policies and Procedures for Market-Based Rates for Wholesale Sales of Electric Energy, Capacity, and Ancillary Services by Public Utilities, 147 FERC 61,232 (June 19, 2014).

2 As discussed in more detail herein, EPSA supports the Commission s effort but has some concerns and requests some clarifications. I. COMMUNICATIONS All pleadings, correspondence and other communications concerning this proceeding should be directed to: Nancy Bagot, Vice President of Regulatory Affairs Electric Power Supply Association 1401 New York Avenue, N.W., 12 th Floor Washington, D.C (202) II. COMMENTS EPSA generally supports the proposed revisions, with some clarifications, as discussed below. While the Commission has been operating under the current market-based rate regulations as implemented by Order No. 697 and its progeny, 3 EPSA appreciates the Commission s efforts to revise the market-based rate regulations to streamline and simplify the process for obtaining and maintaining market-based rate authority and reducing the regulatory burdens on market-based rate applicants and market participants. As such, EPSA supports the proposed regulations herein, with the concerns and clarifications discussed below. EPSA appreciates the Commission s efforts to continually review the market-based rate regulations and requirements to ensure that they remain 3 Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities, Order No. 697, FERC Stats. & Regs. 31,252, clarified, 121 FERC 61,260 (2007) (Clarifying Order), order on reh g, Order No. 697-A, FERC Stats. & Regs. 31,268, clarified 124 FERC 61,055, order on reh g, Order No. 697-B, FERC Stats. & Regs. 31,285 (2008), order on reh g, Order No. 697-C, FERC Stats. & Regs. 31,291 (2009), order on reh g, Order No. 697-D, FERC Stats. & Regs. 31,305 (2010), aff d sub. nom. Mont. Consumer Counsel v. FERC, 659 F.3d 910 (9 th Cir. 2011), cert. denied, 133 S. Ct. 26 (2012). 2

3 relevant and useful while not becoming overly burdensome upon market participants. A. Horizontal Market Power The Commission seeks comment on several proposed changes to the horizontal market power indicative screens, particularly as they apply to sellers in the RTO/ISO markets. Specifically, EPSA comments on the proposed amendments related to the treatment of monitoring and mitigation of sellers in RTO/ISO markets, the treatment of fully-committed long-term generation capacity, and the relevant market to review for generation-only balancing authority areas. i. RTO/ISO Markets with Commission-Approved Market Monitoring and Mitigation The Commission seeks comment on a proposal to allow market-based rate sellers in RTO/ISO markets with Commission-approved market monitoring and mitigation plans to address any horizontal market power issues by stating in their applications that such sellers are relying on the Commission-approved market power and mitigation rules, protocols, and tariffs of the relevant RTO/ISO to address any market power issues they may have. Additionally, such sellers would need to provide an asset appendix and describe their generation and transmission assets. 4 EPSA generally supports this proposal. EPSA agrees with the Commission s assessment that the submission of indicative screens for sellers in RTO/ISO markets yields little practical benefit because, according to current 4 MBR Refinements NOPR at PP

4 market power screen rules, if a seller in an RTO/ISO market does fail the indicative screens, the Commission has allowed such sellers to rely on Commission-approved market monitoring and mitigation as a default. As such, requiring such sellers to submit indicative screens and market power analysis is an unnecessary burden when such sellers opt to rely on the Commissionapproved monitoring and mitigation. Therefore, EPSA supports this proposed amendment. ii. Fully-Committed Long-Term Generation Capacity The Commission seeks comment on a clarification that when all generation owned or controlled by a seller and its affiliates is in the relevant balancing authority area, including any first-tier markets or where such capacity is fully committed, sellers may state that their capacity is fully committed instead of submitting the indicative screens to satisfy the horizontal market power concerns. Furthermore, the Commission clarifies that the qualification of fully committed will only apply to a seller s capacity that is committed so that none of the excluded capacity is available to the seller or their affiliates for one year or longer. 5 Additionally, the Commission proposes to require that sellers claiming their relevant capacity is fully committed to provide information about the amount of generation capacity that is fully committed, the names of their counterparties, the length of the long-term contract, the expiration date of the contract, and a representation that the contract is for firm sales for one year or longer. Finally, and as discussed more fully below, the Commission notes that a 5 MBR Refinements NOPR at P 43. 4

5 change in status filing is required when a long-term firm sales agreement expires if it results in a net increase of 100 MW or more. 6 EPSA generally supports this proposal and agrees with the Commission s assessment that the study of uncommitted generation in indicative screens becomes a purely mathematical task providing no significant additional information when sellers fully-committed long-term capacity is deducted from the indicative screens. However, EPSA requests clarification that the proposed term fully-committed would also apply to circumstances where a seller retains the right to sell capacity to a second buyer, but only when the first buyer under the long-term contract waives the right to purchase. In other words, if the buyer under a long-term contract has the right to call on the full output of the seller s generation, and the seller may only offer the capacity to a second buyer when the first buyer foregoes its purchase right, then that capacity should be considered fully-committed and thus, excluded from the indicative screens. iii. Relevant Markets for Generation-Only Balancing Authority Areas The Commission seeks comment on a proposal to make the default relevant geographic market for an IPP seller located in a generation-only balancing authority area ( BAA ) the BAAs of each transmission provider to which that seller s generation-only BAA is directly interconnected. Additionally, the Commission proposes that such a seller must include all of its uncommitted generation capacity from the generation-only BAA in the BAAs of each transmission provider to which such seller is directly interconnected in its 6 MBR Refinements NOPR at P 44. 5

6 horizontal market power studies since all such uncommitted capacity could potentially be sold in each market that is directly interconnected to such seller s generation-only BAA. 7 EPSA generally supports this proposal, but suggests consistency in the evaluation of nested BAAs. Consistent with the analysis for generation-only BAAs connected to a trading hub, and the provisions to then analyze first-tier BAAs, we request clarification that the Commission will implement the proposal in such a manner as to ensure that as long as there is network deliverability from the nested BAA through the interconnected BAA and to the first-tier BAA, that first-tier BAAs should be included in the indicative screens for all generation-only BAAs. This would more accurately reflect the geographic area in which the energy from the nested BAA is available and with which it can compete and be consistent with the analysis for an IPP BAA which was connected to a trading hub. iv. Capacity Ratings The Commission seeks comments on the applicability of using either nameplate capacity or five-year historical average capacity ratings during peak hours to determine the capacity rating for an applicant s solar technology generation resources. 8 EPSA suggests that using peak hours will not provide a better measure of capacity for solar technology generation resources, and consistent with other intermittent energy resources, such as wind, a historical average capacity rating 7 MBR Refinements NOPR at PP MBR Refinements NOPR at P 70. 6

7 during peak hours would more accurately represent output of the facility incorporating the variability of output given environmental and weather events which affect solar generation resources output. B. Vertical Market Power The Commission seeks comment on whether to relieve sellers of the obligation to file quarterly land acquisition reports and of the obligation to provide information on sites for generation capacity development in initial applications for market-based rate authority and triennial updates. 9 EPSA supports this proposal and agrees that such a requirement is unnecessary and increases the burden on applicants and sellers without a corresponding benefit. In supporting this proposal, EPSA notes that the purpose of the initial applications, triennial updates, and notices of change in status, is to identify for the Commission material facts and changes relevant to a seller s grant of market-based rate authority. Requirements that sellers file quarterly land acquisition reports are not only unduly burdensome, but also fail to further the purpose of the triennial updates and notices of change in status filings. As such, EPSA supports this proposal and finds that it furthers the Commission s stated goal of reducing the regulatory burdens on market-based rate applicants and sellers. C. Notices of Change in Status Currently, market-based rate sellers are required to submit a notice of change in status to the Commission when sellers acquire 100 MW or more of capacity in the geographic market that was the subject of the horizontal market 9 MBR Refinements NOPR at PP

8 power analysis on which the Commission relied in granting market-based rate authority. 10 i. Geographic Focus of 100 MW Threshold The Commission seeks to clarify in this NOPR that the 100 MW reporting threshold that triggers the notice of change in status requirement is not limited only to markets previously studied, but would be triggered if a seller experiences a cumulative net increase of 100 MW or more in any relevant geographic market. This proposed clarification for the 100 MW threshold would also apply to the cumulative capacity in any relevant geographic market, including what capacity could be imported from first-tier markets. However, this would not apply where a seller acquires less than 100 MW in one market and less than 100 MW in another market, so long as the two markets are not first-tier to each other. 11 EPSA comments that this proposal, if adopted, runs counter to the Commission s stated objective of reducing the regulatory burden on marketbased rate sellers and applicants and would in fact require much more extensive tracking and reporting than is required under the current regulations. EPSA notes that the 100 MW threshold could prove extremely cumbersome to track, particularly if a seller transacts in a market with more than one first-tier market. EPSA seeks clarification that the 100 MW threshold would only apply to 100 MW changes in each market separately and would not be aggregated across first-tier markets. For instance, applying EPSA s clarification, if a seller studies a market with multiple first-tier markets and the seller experiences an increase in one first- 10 Order No. 697-A, FERC Stats. & Regs. 31,268 at P MBR Refinements NOPR at PP

9 tier market of 30 MW, and another increase of 70 MW in another first-tier market, then no change in status requirement would be triggered because the seller did not experience an increase of 100 MW or more in any one of the separate and distinct first-tier markets. Additionally, EPSA notes that any increase in MW in a first-tier market would already be reflected in the analysis of that particular first-tier market. As such, amending the current regulations to require sellers to account for such increases separately would be redundant and serve to substantially increase the burden on such sellers unnecessarily. ii. Long-Term Contracts in 100 MW Threshold The Commission proposes to require sellers to report all long-term firm purchases of energy and capacity in their horizontal market power indicative screens, regardless of whether the seller has acquired control over the generation capacity supplying the power. 12 EPSA questions the utility of this proposal and seeks clarification of how this requirement would differ from the reporting required in the Electric Quarterly Reports ( EQR ). It appears that the information required to be reported by this proposal would duplicate the information provided by sellers contained in the EQRs which are required to be filed under current Commission regulations. 13 Requiring duplicative information from purchasers in the triennial updates or notices of change in status runs counter to the Commission s stated goal of streamlining the filing process and reducing the regulatory burdens on sellers 12 MBR Refinements NOPR at P C.F.R b (2014). 9

10 without a clear commensurate benefit. EPSA would suggest that if the Commission is seeking this information, which appears to duplicate the information available on the EQR, then the Commission should not adopt the proposed revision but just refer to the EQR data. Additionally, EPSA requests clarification that in evaluating long-term contracts for the indicative screens and reporting purposes, sellers are still permitted to make conservative assumptions in their initial application and triennial updates. Specifically, EPSA notes that Order No. 697 permitted sellers to make simplifying assumptions in their market power analysis. 14 EPSA notes that many sellers with long-term contracts choose to make such simplifying assumptions in order to avoid the expiration of a long-term contract triggering the need for a change in status filing, thus limiting the regulatory burden on the seller. As such, EPSA seeks clarification that such simplifying assumptions are still permissible in the indicative screens. iii. New Affiliation and Behind-the-Meter Generation in 100 MW Threshold The Commission seeks comment on a proposal to amend the regulations to alleviate the need for a seller to file a notice of change in status when a seller has a new affiliation that would not result in a cumulative net increase of 100 MW or more of nameplate capacity in any relevant geographic market. Until such new affiliation results in a cumulative net increase of 100 MW or more, such seller would not be required to file a notice of change in status Order No. 697 at P MBR Refinements NOPR at P

11 Additionally, the Commission clarifies that, in interpreting the Notice of Change in Status requirement, the term all assets includes behind-the-meter generation and qualifying facilities. However, the Commission proposes to allow for the aggregation of a seller s behind-the-meter generation and qualifying facilities under 20 MW by balancing authority area and market on the list of generation assets. 16 EPSA seeks clarification that wholly self-consumed behind-the-meter generation will not count towards the 100 MW aggregation of behind-the-meter generation for purposes of triggering a notice of change in status filing. Specifically, if a seller has behind-the-meter generation that is used solely to operate equipment for production, such as an oil or gas operation that uses behind-the-meter generation for operations that produce oil or gas, such behindthe-meter generation should not be counted toward the 100 MW threshold because that behind-the-meter generation is never offered or sold into the market. Therefore, the Commission should clarify that any such behind-themeter generation that is wholly self-consumed would not count towards the 100 MW threshold. iv. Clarification of 100 MW Threshold Reporting as a Trigger or a Ratchet Sellers are required to report a change in status when an additional 100 MW threshold in a relevant geographic market is attained. It has been unclear whether the change in status reporting requirement is then reset and a change in status reporting requirement is necessary when another 100 MW of controlled 16 MBR Refinements NOPR at P

12 generation is obtained ( ratchet ), or once the 100 MW threshold is attained, if all new controlled generation in excess of 100 MW must be reported ( trigger ). EPSA seeks Commission clarification that the change in status reporting requirement is a ratchet, and that change in status filings must be submitted each time a seller attains a cumulative 100 MW of controlled generation. D. Asset Appendix The Commission proposed several amendments to the requirement that market-based rate sellers and applicants file an asset appendix that lists all affiliates that have market-based rate authority and identifies any assets owned or controlled by the seller and any affiliates. In this NOPR, the Commission proposed to change the existing columns contained in the asset appendix, clarify what information is and is not permissible in the existing columns, and how to treat the waiver of the OATT requirement, among other changes discussed below. 17 i. Electronic Format The Commission proposes to require sellers to submit Appendix B asset lists in an electronic format that can be searched, sorted, and otherwise accessed and reviewed electronically. 18 EPSA does not oppose this proposal, however we request further clarifications regarding what specific fields would be required in this electronic form. Additionally, EPSA requests further clarifications on what methodology should be used to submit the electronic forms. EPSA notes that the Commission 17 MBR Refinements NOPR at PP 112, 116, and MBR Refinements NOPR at PP

13 could revisit the challenges market participants faced when implementing the revised EQR requirements to avoid any unnecessary confusion over implementation of any new electronic reporting format. As such, while EPSA is not opposed to such a proposal, further clarification and guidance is imperative to ensure a smooth transition and reduction of burdens on sellers. The Commission also proposes to clarify that the asset lists should not include any extraneous information other than what is required in the specific columns; this would include footnotes and other comments on the assets listed in the columns. 19 EPSA opposes this proposed clarification. EPSA notes the reason sellers include footnotes and other extraneous information is to explain and clarify the information listed in the asset appendix and ensure that all information is accurate so as to avoid any allegations that the sellers have misled the Commission. Providing that extraneous information on the chart allows a direct explanation that does not require Commission staff to reference back to a transmittal letter or another, separate document to explain or clarify the information contained in the asset appendix. Instead of prohibiting the use of footnotes, EPSA proposes that the Commission add a separate column to the asset appendix and proposed electronic form for explanatory notes and clarifications. ii. Searchable Database The Commission seeks comment on the benefits of developing a public searchable database of the information contained in the asset appendices. The Commission indicates that such a public database would eventually replace the 19 MBR Refinements NOPR at P

14 pre-formatted spreadsheet currently required. Specifically, the Commission seeks comment on the usefulness of such a database, how such a database could be created and maintained, and how often such a database should be updated. 20 EPSA does not oppose this proposal, however, we are concerned that such proposal raises more questions. Specifically, EPSA has concerns about how such a database will be updated. Will sellers be responsible for updating the database or will that responsibility fall to Commission staff? Additionally, if information in the database is updated by multiple parties, EPSA questions how the accuracy of any information contained in such a database will be ensured. Finally, EPSA seeks clarification on the use of a public database versus the asset appendix that is currently required under the Commission s regulations. Would a public database as proposed eventually replace the asset appendix, since such a database, as proposed, seems to contain duplicative information to the asset appendix? If both a public database and an asset appendix are going to be required of all market-based rate applicants and sellers, then such requirements would run counter to the Commission s stated intentions to streamline the information required and reduce the regulatory burden on marketbased rate applicants and sellers. If sellers are to ultimately use a public database for documentation of assets, which may replace the asset appendix, it may be reasonable that the seller updates and maintains their data on the database and that the database is revised by the seller upon the filing of triennial updates or notices of change in status, with an attestation of accuracy 20 MBR Refinements NOPR at P

15 accompanying the submittal. EPSA notes that we are not necessarily opposed to the addition of a public database requirement, but note that such a requirement should replace the requirement that sellers file an asset appendix as part of their initial application and triennial updates. E. Corporate Organizational Charts The Commission proposes to require sellers to provide an organizational chart as part of its initial application, triennial update, and notice of change in status, as well as a written description of the seller s affiliates and upstream ownership or corporate structure. 21 The Commission explains that such an organization chart would be similar to what the Commission requires from FPA section 203 applicants, and states that it does not believe such a requirement increases the burden on sellers or applicants because most sellers have this organizational chart available. 22 EPSA opposes this proposal and rejects the Commission s assertion that most sellers have this [information] available. Given the number of affiliates many market-based rate sellers have, 23 it poses a serious challenge to require all sellers to include organizational charts and written descriptions of their affiliates as part of the application and triennial update process. EPSA proposes that, if the Commission insists on implementing such a new and sweeping requirement, then the Commission should limit the requirement to include only public utilities 21 MBR Refinements NOPR at P MBR Refinements NOPR at P For example, EPSA members have hundreds of market-based rate sellers, without accounting for various intermediate holding companies, upstream owners, and energy affiliates. 15

16 subject to FERC jurisdiction rather than all affiliates within a seller s corporate structure. Additionally, EPSA requests clarification of how the Commission would treat sellers that are part of joint ventures under this proposed requirement. Would sellers be required to include organizational charts and written descriptions of all entities with which they are engaged in joint ventures as well as affiliates? EPSA would request that the Commission carve out joint ventures or, at a minimum, clarify how joint ventures would be treated under this new proposed requirement. EPSA further notes that, as indicated above, not all market-based rate sellers have these organizational charts readily available and it would take considerable time and effort for sellers to create such information, particularly given the extensive number of affiliates that some sellers have within their corporate structure. As stated above, many EPSA members that have marketbased rate authority have hundreds of affiliates. Furthermore, even if a marketbased rate seller has organizational charts, often those charts are not developed and used for the purpose of showing control, but rather to demonstrate how finances flow throughout the various companies. Consequently, the charts would require significant revisions to comply with the Commission s requirement. Further, when organizational charts are required, such as for a section 203 filing, these organizational charts are done specifically for the required submittal and often by a third party. 16

17 Adopting a new requirement that all sellers produce organizational charts that demonstrate the chain of control for the seller and all the seller s affiliate and upstream owners will be unduly burdensome and extremely costly. Such a requirement would also run counter to the Commission s stated goal of reducing the burdens on applicants and sellers and streamlining the application and triennial update process. As such, and for all the reasons stated above, EPSA opposes the proposal to require sellers to provide organizational charts of the seller s affiliates and upstream ownership or corporate structure. F. Waivers of Part 101 and Part 141 The Commission proposes to clarify that any waiver of Part 101 granted to a seller is limited and such waiver granted to hydropower licensees is not granted with respect to licensed hydropower projects. Furthermore, the Commission seeks to clarify that hydropower licensees that received a waiver of Part 101 of the Commission s regulations as part of their market-based rate authorization under Part II of the FPA are cautioned that such waivers do not relieve them of the obligation to comply with the Uniform System of Accounts with respect to their licensed projects. 24 EPSA opposes the proposed clarification that hydropower licensees with a waiver of Part 101 are not relieved of the obligation to comply with the Uniform System of Accounts regarding their licensed hydropower projects. A requirement that hydropower licensees bring their accounts into conformance with the Uniform System of Accounts is not only unnecessary, but presents a significant burden, and, the Commission has failed to demonstrate why such a requirement 24 MBR Refinements NOPR at P

18 would present sufficient benefits as to outweigh the significant cost and burden required to bring such accounts into conformance with the Uniform System of Accounts. The Commission approved the waivers of the Uniform System of Accounts in Order No. 697 finding that such a compliance requirement would serve little purpose for entities that do not sell at cost-based rates and do not have captive customers. 25 Hydropower licenses with market-based rate authorizations are neither selling at cost-based rates, not do they have captive customers. Licensees can satisfy FPA Part I statutory requirements by employing the Generally Accepted Account Principles. EPSA posits that affected hydropower licensees that currently keep accounts in accordance with the Generally Accepted Accounting Principles provide the same information as those kept using the Uniform System of Accounts. As such, EPSA opposes the proposed clarification and seeks a further clarification that such hydropower licensees meet the requirements if they follow the Generally Accepted Account Principles. If the Commission does not grant such a clarification, the Commission should specify that the compliance will only apply prospectively. Further, the Commission should clarify which specific accounts it would expect licensees to maintain. In doing so, the Commission should limit the number of accounts it deems necessary for a hydropower licensee to carry out its responsibilities under Part I to the greatest extent possible. This would help minimize the cost and burden for companies that are otherwise exempt from the requirements of the Uniform System of Accounts. 25 Order No, 697 at P

19 III. CONCLUSION Wherefore, EPSA respectfully requests that the Commission adopt the revisions proposed in the NOPR, with the clarifications discussed above. Respectfully Submitted, Nancy Bagot, Vice President of Regulatory Affairs Melissa Mitchell, Director of Regulatory Affairs and Counsel Electric Power Supply Association 1401 New York Avenue, NW, 12th Floor Washington, DC 2000 (202) September 23,

20 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the comments via upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Washington, D.C. September 23, Nancy Bagot, VP of Regulatory Affairs 20

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