[Tdstf] Developer Selection Task Force: Cost Recovery Language

[Noailles, Liam D]

Sharon,

I don’t know if a special call is necessary, but I am not against it.  I think that everyone agrees that a winning developer is eligible to utilize regional cost allocation as you say below. There is a slightly confusing distinction between eligibility to use cost allocation and the method and process for recovering the costs. WestConnect tariffs do not provide for the recovery of costs associated with transmission projects that are eligible for regional cost allocation.

For instance, if LSPower was selected as the developer of a project eligible for regional cost allocation, LSPower could not collect revenues under any of the Jurisdictional TO tariffs. Also, the PMC will not collect transmission revenues for approved projects- that is not part of the PPA.

I assume LSPower would need an approved contract or tariff or something to recover the costs from beneficiaries/transmission customers- something filed with FERC. I believe that all of the incumbents will have similar issues as beneficiaries are not necessarily their transmission customers, and there are a number of complicating factors.

To me it has always been a “cross that bridge when we get to it” issue as the decision really lies with the transmission developer and there may be different approaches depending on the particular project, set of beneficiaries, business model, etc.  I do not believe that this subgroup will “solve”  this and really do not believe that it is the place for this group or the PMC generally to dictate how a selected developer will recover its costs. It is outside of the scope of Order 1000.

That said, I believe that this is an important topic for everyone to understand, and it may impact how folks think about the selection process that we are developing.

Liam Noailles
Xcel Energy | Responsible By Nature
Manager, Federal Regulatory Affairs
1800 Larimer Street, Suite 14   Denver, CO 80202
P: 303.571.2794    C: 720.984.5959

From: Tdstf [mailto:tdstf-bounces at mailman.swcp.com] On Behalf Of Sharon Segner
Sent: Thursday, May 26, 2016 7:10 AM
To: 'Heidi Pacini'; 'tdstf at westconnect.com'
Cc: 'Michael R. Engleman'
Subject: Re: [Tdstf] Developer Selection Task Force: Cost Recovery Language

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Heidi,
Ferc was abundantly clear that if a project makes its way through the regional process, the project developer will be eligible to use the regional cost allocation framework.

I would like to propose that we have a special call on this topic, so the task force has clear understanding of what this means and doesn't mean.

Sharon



-----Original Message-----
From: Heidi Pacini [heidi at pacenergies.com<mailto:heidi at pacenergies.com>]
Sent: Wednesday, May 25, 2016 08:39 PM Eastern Standard Time
To: tdstf at westconnect.com<mailto:tdstf at westconnect.com>
Subject: [Tdstf] Developer Selection Task Force: Cost Recovery Language


WestConnect Developer Selection Task Force Members,

Please see the email below and the attached document related to today’s discussion regarding cost allocation versus cost recovery in the WestConnect process.

Thank you!

Heidi Pacini | 661.256.2483 office | 303.229.9401 mobile | Heidi at PacEnergies.com<mailto:Heidi at PacEnergies.com>

From: Noailles, Liam D [mailto:Liam.D.Noailles at xcelenergy.com]
Sent: Wednesday, May 25, 2016 11:56 AM
To: Heidi Pacini <heidi at pacenergies.com<mailto:heidi at pacenergies.com>>
Subject: cost recovery


iii. Commission Determination

344. We find that the comments concerning cost recovery are outside the scope of the instant proceeding. Order No. 1000 did not specify how costs can be recovered for transmission projects that are selected in the regional transmission plan for purposes of cost allocation, a conclusion affirmed in Order No. 1000-A.610 Further, while the Commission stated that, to the extent that cost recovery provisions are considered in connection with a cost allocation method or methods for a regional or interregional transmission facility, public utility transmission providers may include cost recovery provisions in their compliance filings,611 Filing Parties did not include cost recovery provisions in their compliance filings. Therefore, we dismiss the comments concerning cost recovery because they are outside the scope of the instant proceeding.

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