FERC Issues Deficiency Letter to Arizona Public Service Company Requesting Additional Information

Strategic Insights -

Arizona Public Service Company's (APS) filing to revise its Open Access Transmission Tariff (OATT) to clarify power factor requirements for non-synchronous generators remains deficient, according to a deficiency letter issued by the Federal Energy Regulatory Commission (FERC) on October 1, 2021. The letter requests additional information to assess whether the proposed revisions are "consistent with or superior to" FERC's pro forma OATT. APS was required to file responses to FERC's inquiries within 30 days of receiving the letter.

Key Takeaways:

  • FERC issued a deficiency letter to APS on October 1, 2021, requesting additional information to process the filing.
  • APS proposes to revise FERC's pro forma Large Generator Interconnection Agreement (LGIA) and Small Generator Interconnection Agreement (SGIA) to provide that non-synchronous interconnection customers must be capable of operating at a power factor range of at least 0.95 leading to 0.95 lagging.
  • APS's current method for compensating interconnection customers for operating outside of the specified power factor range is unclear, and FERC requires additional information to assess the proposed revisions.
  • APS must respond to FERC's deficiency letter within 30 days by making an amendment filing in accordance with the Commission's electronic tariff requirements.
  • Failure to respond within the specified time period may result in an order rejecting the filing, and a new filing date will not be assigned to the case until receipt of the amendment filing.

Statistics:

  • FERC issued a deficiency letter to APS on October 1, 2021.
  • APS was required to file responses to FERC's inquiries within 30 days of receiving the letter.
  • The proposed revisions to FERC's pro forma LGIA and SGIA aim to clarify power factor requirements for non-synchronous generators.
  • APS's current method for compensating interconnection customers for operating outside of the specified power factor range is unclear.

Sources:

  • FERC Correspondence With Applicant | Deficiency Letter, FERC Correspondence With Applicant | Request for Additional Information, issued October 1, 2021.
  • Arizona Public Service Company, Deficiency Response, filed August 6, 2021.
  • 18 C.F.R. § 375.307(a)(1)(v).
  • Duke Power Company, 57 FERC P 61,215 (1991).
  • Electronic Tariff Filings, 130 FERC P 61,047, at PP 3-8 (2010).