Flat Ridge Answer Sample Clauses

Flat Ridge Answer. Flat Ridge alleges that SPP’s answer reflects a failure by SPP to follow the requirements of the GIA regarding the limited operation impact study. Flat Ridge alleges that SPP has been unable to inform Flat Ridge when the limited operation impact study will be run and when results will be available. Flat Ridge also contends that the statement in SPP’s answer that limited operation impact study results would need to be refreshed each time a network upgrade is completed or a new generator comes on line is inconsistent with the rights of the interconnection customer under article 5.9 of the GIA. Flat Ridge argues that the limited operation impact study will not determine the extent of permitted operations because the results will continually need to be refreshed and that the Flat Ridge project will not be permitted to operate without such refreshments.43 Furthermore, Flat Ridge alleges that SPP has not clearly documented a process for 41 Evergy Answer at 1-2. 42 Id. at 2. 43 Flat Ridge Answer at 3-6. obtaining timely limited operation impact study results in its answer, its Tariff, or a business practice manual. Flat Ridge argues that SPP’s statements about how it will handle the negotiation process for the Shared FCA are inadequate for addressing the timing issues that Flat Ridge identified in its protest. According to Flat Ridge, negotiations of the GIAs for other projects have apparently been repeatedly extended based on information in the SPP interconnection queue on SPP’s OASIS. Flat Ridge argues that, under good utility practice and tariff administration, the GIAs of these other Group 8 projects should contain synchronized dates for negotiation and execution of the Shared FCA.44 Flat Ridge alleges that delays in the Group 8 study process have been allowed for only certain projects in Group 8. Flat Ridge argues that the Flat Ridge project is one of only a few in the Group 8 cluster that has been brought to GIA execution while nine other Group 8 projects are still in the process of GIA negotiations. Flat Ridge contends that the Group 8 cluster study was applicable to all the projects and therefore similarly situated projects should have been required to either execute a GIA or request that it be filed unexecuted at the same time. Flat Ridge alleges that synching up the negotiation of GIA for the entire cluster would provide transparency and certainty related to the Shared FCA. Flat Ridge argues that singling out the Flat Ridge project to move forward and p...
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Flat Ridge Answer. Flat Ridge alleges that SPP’s answer reflects a failure by SPP to follow the requirements of the GIA regarding the limited operation impact study. Flat Ridge alleges that SPP has been unable to inform Flat Ridge when the limited operation impact study will be run and when results will be available. Flat Ridge also contends that the statement in SPP’s answer that limited operation impact study results would need to be refreshed each time a network upgrade is completed or a new generator comes on line is inconsistent with the rights of the interconnection customer under article 5.9 of the GIA. Flat Ridge argues that the limited operation impact study will not determine the extent of permitted operations because the results will continually need to be refreshed and that the Flat Ridge project will not be permitted to operate without such refreshments.43 Furthermore, Flat Ridge alleges that SPP has not clearly documented a process for
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