“Non-Transmission Alternatives”: FERC’s “Comparable Consideration” Needs Correction

The Order 1000 compliance process has revealed a gap between FERC’s aspirations and industry practice.  Order 1000 requires transmission providers to assess only those NTAs that have proponents, thus authorizing transmission providers to disregard NTAs that lack proponents.  In doing so, Order 1000 violates the Federal Power Act’s just and reasonable standard.  Consideration of NTAs is a “practice … affecting” jurisdictional rates for transmission service and wholesale sales.”  For those rates to be just and reasonable, they must be based on costs that emerge from a prudent process.

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See editorial written by Robert Marritz in ElectricityPolicy.com.