SPP Answer Sample Clauses

SPP Answer. SPP asserts that the Flat Ridge GIA conforms to the pro forma GIA in the Tariff. SPP asserts that the terms set forth in the appendices of the Flat Ridge GIA are consistent with the requirements of SPP’s GIP.28 SPP states that while negotiating the Flat Ridge GIA it explained to Flat Ridge that in order to begin operations in advance of the completion of the Blackberry-Wolf Creek upgrade, Flat Ridge will be required to pursue limited operations. SPP states that it also explained to Flat Ridge that a limited operations impact study is required in order to determine if limited operations is an option and if so to what extent. SPP asserts that despite Flat Ridge learning in the summer of 2020 that the Flat Ridge project would be required to operate at limited capacity prior to the completion of the Blackberry-Wolf Creek upgrade, Flat Ridge did not submit its request for a limited operations impact study until February 12, 2021. SPP states that, consistent with article 5.9 of the Flat Ridge GIA, it is working to determine the extent to which the Flat Ridge project may operate in advance of the completion of the Blackberry-Wolf Creek upgrade. If the results of limited operation impact study show that the Flat Ridge project can in fact operated in a limited capacity in advance of completion of the Blackberry-Wolf Creek upgrade, then SPP will initiate the process of amending the Flat Ridge GIA to include the results of the limited operations impact study. If, however, the results of the limited operations impact study show that the Flat Ridge project cannot operate at a limited capacity prior to the completion of the Blackberry-Wolf Creek upgrade due to insufficient interconnection capacity, then the Flat Ridge project will not be able to begin operations until the Blackberry-Wolf Creek upgrade is placed into service.29 In response to Flat Ridge’s assertion that it is not clear whether Flat Ridge would be able to rely on the results of the limited operations impact study,30 SPP states that there is no guarantee that any level of interconnection service will be available prior to 26 Id. at 11. 27 Id. at 12-13. 28 SPP Answer at 3. 29 Id. at 3-4. 30 Id. at 4 (citing Flat Ridge Protest at 4). the completion of contingent facilities identified in the Flat Ridge GIA. SPP explains that article 5.9 of the Flat Ridge GIA provides that, at the request of an interconnection customer, SPP will perform a study to determine whether the generation facility may operate prior to ...
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SPP Answer. SPP states that Western Farmers’ comments largely paraphrase arguments from the Complaint proceeding and that Western Farmers does not request any specific relief in the instant proceeding.13 SPP asserts that Western Farmers’ comments do not protest SPP’s filing or request that the Commission reject the Western Farmers Agreement.14 SPP maintains that Western Farmers executed the Western Farmers Agreement on August 12, 2019, ten days prior to filing the Complaint, and that Western Farmers points to no material circumstances that have changed since then that would render the Western Farmers Agreement unjust and unreasonable.15 SPP argues that Western Farmers’ comments provide no basis for rejection of the Western Farmers Agreement and that the Commission should accept the Western Farmers Agreement.16
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SPP Answer. SPP argues that the Commission should accept the unexecuted AECC Agreement. SPP states that, under the SPP Tariff, an Attachment AO agreement is required in order 13 AECC Answer at 2. 14 Id. at 3 (citing Sw. Power Pool, Inc., Filing, Docket No. ER15-899-000, at 2 (filed Jan. 23, 2015) (“The Midcontinent Independent System Operator, Inc. (“MISO”) utilizes Local Balancing Authorities (“LBA”) to perform tasks within the MISO Balancing Authority. Entergy Louisiana is an LBA within the MISO Balancing Authority.”)).
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SPP Answer. 14. SPP argues that the Commission should accept the unexecuted AECC Agreement.
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