Motion of L.M. Marlowe for the Establishment of Settlement Procedures and Convening of a Settlement Conference, or, in the Alternative, for the Appointment of a Settlement Judge
Read topic-matched comments in EL26-67
Topics in the text: Cost allocation · Reliability and curtailment
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Opening text
opening text · Topic match: Cost allocation
It is offered for the public benefit — to improve grid reliability, transparency in large-load cost allocation, and the protection of ratepayers from systemic waste and undue cost- shifting — and seeks a timely and durable resolution of the matters presented.Read this passage Filed comments: Cost allocation
I. Introduction and Relief Requested
printed heading · Topic match: Reliability and curtailment
Movant proposes that any such settlement procedures be directed, in the first instance, to the discrete and shared technical questions common to these dockets — large-load observability, cost-allocation and cost- causation, curtailment priority, and boundary-verification methodology — rather than…Read this passage Filed comments: Reliability and curtailment
II. The Commission’s Authority to Convene Settlement at Any Time
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The Commission’s Authority to Convene Settlement at Any Time Rule 601 provides that the Commission or other decisional authority “may convene a conference of the participants in a proceeding at any time for any purpose related to the conduct or disposition of the proceeding, including … the…Read this passage
III. Settlement Is Timely, Not Premature
printed heading · Topic match: Reliability and curtailment
Settlement Is Timely, Not Premature Any suggestion that a movement toward resolution is premature is not consistent with the documented condition of the system at issue.Read this passage Filed comments: Reliability and curtailment
IV. Settlement Serves the Public Interest and Commission Policy
printed heading · Topic match: Cost allocation
Settlement in these proceedings would allow the participants — the RTO/ISOs, transmission owners, large-load and generation interests, State representatives, ratepayer advocates, and intervenors such as Movant — to work toward mutually acceptable reliability, observability, and cost-allocation…Read this passage Filed comments: Cost allocation
V. Conclusion
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Conclusion For the foregoing reasons, Movant respectfully requests that the Commission establish settlement procedures and convene a settlement conference pursuant to Rule 601, or, in the alternative, appoint a settlement judge pursuant to Rule 603, to facilitate the resolution of these proceedings.Read this passage