Last week FERC held a kickoff meeting on its Advance Notice of Proposed Rulemaking (ANOPR) for interconnection procedures. FERC staff proposes to have 6 weeks of meetings (up to 3 days per week) to discuss issues identified by the participants.   The purpose of the meetings is to try to develop consensus among industry participants on a standard interconnection agreement and procedures.  A list of issues is attached. This list was developed by EPSA and presented to FERC at last week's meeting.

At this week's meeting, the discussion will focus on the scope of interconnection rights and on interconnection study issues.  Donna Fulton will attend these meetings on behalf of Enron.  In preparation for the meetings, EPSA developed a position paper, which is attached.  Briefly, EPSA proposes:
 
    - Interconnecting Generator may elect, as part of its application for interconnection and study agreement, to be studied as an Energy Resource and/or as a Network/Capacity Resource; it may also request an "optional deliverability" study based on case-specific requirements.  The interconnecting generator may elect its level of interconnection following completion of the studies.
 
    - The rights of the interconnected generator will depend on the manner it is studied, the upgrades for which the generator has paid, and whether the transmission pricing system is based on physical rights or financial rights.
 
If you have any comments on the attached, please let me know as soon as possible.
 
Susan Lindberg
713.853.0596