NECPUC and VDPS appreciate the opportunity to respond to the Commission's ANOPR for Generator Interconnection Standards. We also commend the Commission for its willingness to address head-on the difficult issues associated with generation interconnection. Standardization of the terms, business practices and time frames associated with interconnection issues will ultimately reduce costs to consumers by providing greater certainty to non-utility generators and to their host transmission companies. The final rule will help eliminate unnecessary delays in the process and avoid reopening legal battles over issues that have been resolved.

In these comments, NECPUC and VDPS address limited issues raised by the Commission's identification of the two-tiered PJM model for generation interconnection as a best practice model for national standards. We respectfully request that the Commission consider using the New England and New York minimum interconnection standard as a best practice model instead because it is best suited to a truly competitive generation market. NECPUC and VDPS are concerned that the standard currently proposed is inherently discriminatory, creates unnecessary barriers to entry for competitive generators, and that it could detract from a hard won and competition-friendly standard that is currently being used in New England and in New York. In addition, the standard proposed in the ANOPR, when coupled with the Commission's current pricing policy, could damage the congestion management programs of all three Northeast ISO regions and lead to the uneconomic construction of transmission. Finally, we ask the Commission to recognize that there may be good cause to allow certain states or regions of the country to vary from a standard, and to provide a mechanism for variance when such cause is shown.

CONCLUSION

As set forth above, NECPUC and VDPS respectfully request that the Commission consider using the New England and New York minimum interconnection standard as a best practice model rather than the PJM approach. The New England/New York standard is best suited to a truly competitive generation market insofar as it does not create unnecessary barriers to entry for competitive generators, lead to the uneconomic construction of transmission, or unfairly socialize upgrade costs in a manner that interferes with price signals to economically relieve transmission congestion. Finally, NECPUC and VDPS ask the Commission to recognize that there may be good cause to allow certain states or regions of the country to vary from a standard, and to provide a mechanism for variance when such cause is shown.