provided on Transmission Provider's OASIS site. This information is
to be posted within 30 days of the end of the calendar quarter.

3.6 Coordination With Affected Systems

    Transmission Provider will coordinate the conduct of any studies
required to determine the impact of the Interconnection Request on
Affected Systems with Affected System Operators and, if possible,
include those results (if available) in its applicable
Interconnection Study within the time frame specified in this LGIP.
Transmission Provider will include such Affected System Operators in
all meetings held with Interconnection Customer as required by this
LGIP. Interconnection Customer will cooperate with Transmission
Provider in all matters related to the conduct of studies and the
determination of modifications to Affected Systems. A Transmission
Provider which may be an Affected System shall cooperate with
Transmission Provider with whom interconnection has been requested
in all matters related to the conduct of studies and the
determination of modifications to Affected Systems.

3.7 Withdrawal

    Interconnection Customer may withdraw its Interconnection
Request at any time by written notice of such withdrawal to
Transmission Provider. In addition, if Interconnection Customer
fails to adhere to all requirements of this LGIP, except as provided
in Section 13.5 (Disputes), Transmission Provider shall deem the
Interconnection Request to be withdrawn and shall provide written
notice to Interconnection Customer of the deemed withdrawal and an
explanation of the reasons for such deemed withdrawal. Upon receipt
of such written notice, Interconnection Customer shall have fifteen
(15) Business Days in which to either respond with information or
actions that cures the deficiency or to notify Transmission Provider
of its intent to pursue Dispute Resolution.
    Withdrawal shall result in the loss of Interconnection
Customer's Queue Position. If an Interconnection Customer disputes
the withdrawal and loss of its Queue Position, then during Dispute
Resolution, Interconnection Customer's Interconnection Request is
eliminated from the queue until such time that the outcome of
Dispute Resolution would restore its Queue Position. An
Interconnection Customer that withdraws or is deemed to have
withdrawn its Interconnection Request shall pay to Transmission
Provider all costs that Transmission Provider prudently incurs with
respect to that Interconnection Request prior to Transmission
Provider's receipt of notice described above. Interconnection
Customer must pay all monies due to Transmission Provider before it
is allowed to obtain any Interconnection Study data or results.
    Transmission Provider shall (i) update the OASIS Queue Position
posting and (ii) refund to Interconnection Customer any portion of
Interconnection Customer's deposit or study payments that exceeds
the costs that Transmission Provider has incurred, including
interest calculated in accordance with section 35.19a(a)(2) of
FERC's regulations. In the event of such withdrawal, Transmission
Provider, subject to the confidentiality provisions of Section 13.1,
shall provide, at Interconnection Customer's request, all
information that Transmission Provider developed for any completed
study conducted up to the date of withdrawal of the Interconnection
Request.

3.8 Identification of Contingent Facilities

    Transmission Provider shall post in this section a method for
identifying the Contingent Facilities to be provided to
Interconnection Customer at the conclusion of the System Impact
Study and included in Interconnection Customer's Large Generator
Interconnection Agreement. The method shall be sufficiently
transparent to determine why a specific Contingent Facility was
identified and how it relates to the Interconnection Request.
Transmission Provider shall also provide, upon request of the
Interconnection Customer, the estimated Interconnection Facility
and/or Network Upgrade costs and estimated in-service completion
time of each identified Contingent Facility when this information is
readily available and not commercially sensitive.

3.10 Repeat Network Upgrades for Consideration in the Regional
Transmission Planning Process

    If Transmission Provider: (1) Identifies a Network Upgrade with
an interconnection study estimated cost of at least $30 million or
with a voltage of at least 200 kV as necessary to accomplish an
interconnection and the underlying interconnection request related
to such Network Upgrade is withdrawn; (2) if, within five years of
that withdrawal, Transmission Provider identifies a Network Upgrade
with an interconnection study estimated cost of at least $30 million
or with a voltage of at least 200 kV to address a similar
interconnection-related need as specified in (1) and the underlying
interconnection request with cost responsibility for the second
identified Network Upgrade is withdrawn; and (3) a similar
interconnection-related need is not addressed by any Network Upgrade
described in Appendix A of any executed Large Generator
Interconnection Agreement or any Large Generator Interconnection
Agreement that an Interconnection Customer has requested that
Transmission Provider file with the Commission unexecuted, then
Transmission Provider shall consider the interconnection-related
need addressed by the Network Upgrade(s) that Transmission Provider
identified in the interconnection queue cycles specified in (1) and
(2) in Long-Term Regional Transmission Planning.

Section 4. Queue Position

4.1 General

    Transmission Provider shall assign a Queue Position based upon
the date and time of receipt of the valid Interconnection Request;
provided that, if the sole reason an Interconnection Request is not
valid is the lack of required information on the application form,
and Interconnection Customer provides such information in accordance
with Section 3.4.3, then Transmission Provider shall assign
Interconnection Customer a Queue Position based on the date the
application form was originally filed. Moving a Point of
Interconnection shall result in a lowering of Queue Position if it
is deemed a Material Modification under Section 4.4.3.
    The Queue Position of each Interconnection Request will be used
to determine the order of performing the Interconnection Studies and
determination of cost responsibility for the facilities necessary to
accommodate the Interconnection Request. A higher queued
Interconnection Request is one that has been placed ``earlier'' in
the queue in relation to another Interconnection Request that is
lower queued.
    Transmission Provider may allocate the cost of the common
upgrades for clustered Interconnection Requests without regard to
Queue Position.

4.2 Clustering

    At Transmission Provider's option, Interconnection Requests may
be studied serially or in clusters for the purpose of the
Interconnection System Impact Study.
    Clustering shall be implemented on the basis of Queue Position.
If Transmission Provider elects to study Interconnection Requests
using Clustering, all Interconnection Requests received within a
period not to exceed one hundred and eighty (180) Calendar Days,
hereinafter referred to as the ``Queue Cluster Window'' shall be
studied together without regard to the nature of the underlying
Interconnection Service, whether Energy Resource Interconnection
Service or Network Resource Interconnection Service. The deadline
for completing all Interconnection System Impact Studies for which
an Interconnection System Impact Study Agreement has been executed
during a Queue Cluster Window shall be in accordance with Section
7.4, for all Interconnection Requests assigned to the same Queue
Cluster Window. Transmission Provider may study an Interconnection
Request separately to the extent warranted by Good Utility Practice
based upon the electrical remoteness of the proposed Large
Generating Facility.
    Clustering Interconnection System Impact Studies shall be
conducted in such a manner to ensure the efficient implementation of
the applicable regional transmission expansion plan in light of the
Transmission System's capabilities at the time of each study.
    The Queue Cluster Window shall have a fixed time interval based
on fixed annual opening and closing dates. Any changes to the
established Queue Cluster Window interval and opening or closing
dates shall be announced with a posting on Transmission Provider's
OASIS beginning at least one hundred and eighty (180) Calendar Days
in advance of the change and continuing thereafter through the end
date of the first Queue Cluster Window that is to be modified.

4.3 Transferability of Queue Position

    An Interconnection Customer may transfer its Queue Position to
another entity only if such entity acquires the specific Generating
Facility identified in the Interconnection Request and the Point of
Interconnection does not change.

4.4 Modifications

    Interconnection Customer shall submit to Transmission Provider,
in writing, modifications to any information provided in the
Interconnection Request. Interconnection Customer shall retain its
Queue Position if the modifications are in accordance with Sections
4.4.1, 4.4.2 or 4.4.5, or are determined not to be Material
Modifications pursuant to Section 4.4.3.
    Notwithstanding the above, during the course of the
Interconnection Studies, either Interconnection Customer or
Transmission Provider may identify changes to the planned
interconnection that may improve the costs and benefits (including
reliability) of the interconnection, and the ability of the proposed
change to accommodate the Interconnection Request. To the extent the
identified changes are acceptable to Transmission Provider and
Interconnection Customer, such acceptance not to be unreasonably
withheld, Transmission Provider shall modify the Point of
Interconnection and/or configuration in accordance with such changes
and proceed with any re-studies necessary to do so in accordance
with Section 6.4, Section 7.6 and Section 8.5 as applicable and
Interconnection Customer shall retain its Queue Position.

4.4.1

    Prior to the return of the executed Interconnection System
Impact Study Agreement to Transmission Provider, modifications
permitted under this Section shall include specifically: (a) A
decrease of up to 60 percent of electrical output (MW) of the
proposed project, through either (1) a decrease in plant size or (2)
a decrease in Interconnection Service level (consistent with the
process described in Section 3.1) accomplished by applying
Transmission Provider-approved injection-limiting equipment; (b)
modifying the technical parameters associated with the Large
Generating Facility technology or the Large Generating Facility
step-up transformer impedance characteristics; and (c) modifying the
interconnection configuration. For plant increases, the incremental
increase in plant output will go to the end of the queue for the
purposes of cost allocation and study analysis.

4.4.2

    Prior to the return of the executed Interconnection Facility
Study Agreement to Transmission Provider, the modifications
permitted under this Section shall include specifically: (a)
Additional 15 percent decrease of electrical output of the proposed
project through either (1) a decrease in plant size (MW) or (2) a
decrease in Interconnection Service level (consistent with the
process described in Section 3.1) accomplished by applying
Transmission Provider-approved injection-limiting equipment; (b)
Large Generating Facility technical parameters associated with
modifications to Large Generating Facility technology and
transformer impedances; provided, however, the incremental costs
associated with those modifications are the responsibility of the
requesting Interconnection Customer; and (c) a Permissible
Technological Advancement for the Large Generating Facility after
the submission of the Interconnection Request. Section 4.4.6
specifies a separate technological change procedure including the
requisite information and process that will be followed to assess
whether the Interconnection Customer's proposed technological
advancement under Section 4.4.2(c) is a Material Modification.
Section 1 contains a definition of Permissible Technological
Advancement.

4.4.3

    Prior to making any modification other than those specifically
permitted by Sections 4.4.1, 4.4.2, and 4.4.5, Interconnection
Customer may first request that Transmission Provider evaluate
whether such modification is a Material Modification. In response to
Interconnection Customer's request, Transmission Provider shall
evaluate the proposed modifications prior to making them and inform
Interconnection Customer in writing of whether the modifications
would constitute a Material Modification. Any change to the Point of
Interconnection, except those deemed acceptable under Sections
4.4.1, 6.1, 7.2 or so allowed elsewhere, shall constitute a Material
Modification. Interconnection Customer may then withdraw the
proposed modification or proceed with a new Interconnection Request
for such modification.

4.4.4

    Upon receipt of Interconnection Customer's request for
modification permitted under this Section 4.4, Transmission Provider
shall commence and perform any necessary additional studies as soon
as practicable, but in no event shall Transmission Provider commence
such studies later than thirty (30) Calendar Days after receiving
notice of Interconnection Customer's request. Any additional studies
resulting from such modification shall be done at Interconnection
Customer's cost.

4.4.5

    Extensions of less than three (3) cumulative years in the
Commercial Operation Date of the Large Generating Facility to which
the Interconnection Request relates are not material and should be
handled through construction sequencing.

4.4.6 Technological Change Procedures

    [Insert technological change procedure here]

Section 5. Procedures for Interconnection Requests Submitted Prior to
Effective Date of Standard Large Generator Interconnection Procedures

5.1 Queue Position for Pending Requests

5.1.1

    Any Interconnection Customer assigned a Queue Position prior to
the effective date of this LGIP shall retain that Queue Position.

<IP_ADDRESS>

    If an Interconnection Study Agreement has not been executed as
of the effective date of this LGIP, then such Interconnection Study,
and any subsequent Interconnection Studies, shall be processed in
accordance with this LGIP.

<IP_ADDRESS>

    If an Interconnection Study Agreement has been executed prior to
the effective date of this LGIP, such Interconnection Study shall be
completed in accordance with the terms of such agreement. With
respect to any remaining studies for which an Interconnection
Customer has not signed an Interconnection Study Agreement prior to
the effective date of the LGIP, Transmission Provider must offer
Interconnection Customer the option of either continuing under
Transmission Provider's existing interconnection study process or
going forward with the completion of the necessary Interconnection
Studies (for which it does not have a signed Interconnection Studies
Agreement) in accordance with this LGIP.

<IP_ADDRESS>

    If an LGIA has been submitted to FERC for approval before the
effective date of the LGIP, then the LGIA would be grandfathered.

5.1.2 Transition Period

    To the extent necessary, Transmission Provider and
Interconnection Customers with an outstanding request (i.e., an
Interconnection Request for which an LGIA has not been submitted to
FERC for approval as of the effective date of this LGIP) shall
transition to this LGIP within a reasonable period of time not to
exceed sixty (60) Calendar Days. The use of the term ``outstanding
request'' herein shall mean any Interconnection Request, on the
effective date of this LGIP: (i) That has been submitted but not yet
accepted by Transmission Provider; (ii) where the related
interconnection agreement has not yet been submitted to FERC for
approval in executed or unexecuted form, (iii) where the relevant
Interconnection Study Agreements have not yet been executed, or (iv)
where any of the relevant Interconnection Studies are in process but
not yet completed. Any Interconnection Customer with an outstanding
request as of the effective date of this LGIP may request a
reasonable extension of any deadline, otherwise applicable, if
necessary to avoid undue hardship or prejudice to its
Interconnection Request. A reasonable extension shall be granted by
Transmission Provider to the extent consistent with the intent and
process provided for under this LGIP.

5.2 New Transmission Provider

    If Transmission Provider transfers control of its Transmission
System to a successor Transmission Provider during the period when
an Interconnection Request is pending, the original Transmission
Provider shall transfer to the successor Transmission Provider any
amount of the deposit or payment with interest thereon that exceeds
the cost that it incurred to evaluate the request for
interconnection. Any difference between such net amount and the
deposit or payment required by this LGIP shall be paid by or
refunded to the Interconnection Customer, as appropriate. The
original Transmission Provider shall coordinate with the successor
Transmission Provider to complete any Interconnection Study, as
appropriate, that the original Transmission Provider has begun but
has not completed. If

Transmission Provider has tendered a draft LGIA to Interconnection
Customer but Interconnection Customer has not either executed the
LGIA or requested the filing of an unexecuted LGIA with FERC, unless
otherwise provided, Interconnection Customer must complete
negotiations with the successor Transmission Provider.

Section 6. Interconnection Feasibility Study

6.1 Interconnection Feasibility Study Agreement

    Simultaneously with the acknowledgement of a valid
Interconnection Request Transmission Provider shall provide to
Interconnection Customer an Interconnection Feasibility Study
Agreement in the form of Appendix 2. The Interconnection Feasibility
Study Agreement shall specify that Interconnection Customer is
responsible for the actual cost of the Interconnection Feasibility
Study. Within five (5) Business Days following the Scoping Meeting
Interconnection Customer shall specify for inclusion in the
attachment to the Interconnection Feasibility Study Agreement the
Point(s) of Interconnection and any reasonable alternative Point(s)
of Interconnection. Within five (5) Business Days following
Transmission Provider's receipt of such designation, Transmission
Provider shall tender to Interconnection Customer the
Interconnection Feasibility Study Agreement signed by Transmission
Provider, which includes a good faith estimate of the cost for
completing the Interconnection Feasibility Study. Interconnection
Customer shall execute and deliver to Transmission Provider the
Interconnection Feasibility Study Agreement along with a $10,000
deposit no later than thirty (30) Calendar Days after its receipt.
    On or before the return of the executed Interconnection
Feasibility Study Agreement to Transmission Provider,
Interconnection Customer shall provide the technical data called for
in Appendix 1, Attachment A.
    If the Interconnection Feasibility Study uncovers any unexpected
result(s) not contemplated during the Scoping Meeting, a substitute
Point of Interconnection identified by either Interconnection
Customer or Transmission Provider, and acceptable to the other, such
acceptance not to be unreasonably withheld, will be substituted for
the designated Point of Interconnection specified above without loss
of Queue Position, and Re-studies shall be completed pursuant to
Section 6.4 as applicable. For the purpose of this Section 6.1, if
Transmission Provider and Interconnection Customer cannot agree on
the substituted Point of Interconnection, then Interconnection
Customer may direct that one of the alternatives as specified in the
Interconnection Feasibility Study Agreement, as specified pursuant
to Section 3.4.4, shall be the substitute.
    If Interconnection Customer and Transmission Provider agree to
forgo the Interconnection Feasibility Study, Transmission Provider
will initiate an Interconnection System Impact Study under Section 7
of this LGIP and apply the $10,000 deposit towards the
Interconnection System Impact Study.

6.2 Scope of Interconnection Feasibility Study

    The Interconnection Feasibility Study shall preliminarily
evaluate the feasibility of the proposed interconnection to the
Transmission System.
    The Interconnection Feasibility Study will consider the Base
Case as well as all generating facilities (and with respect to
(iii), any identified Network Upgrades) that, on the date the
Interconnection Feasibility Study is commenced: (i) Are directly
interconnected to the Transmission System; (ii) are interconnected
to Affected Systems and may have an impact on the Interconnection
Request; (iii) have a pending higher queued Interconnection Request
to interconnect to the Transmission System; and (iv) have no Queue
Position but have executed an LGIA or requested that an unexecuted
LGIA be filed with FERC. The Interconnection Feasibility Study will
consist of a power flow and short circuit analysis. The
Interconnection Feasibility Study will provide a list of facilities
and a non-binding good faith estimate of cost responsibility and a
non-binding good faith estimated time to construct.

6.3 Interconnection Feasibility Study Procedures

    Transmission Provider shall utilize existing studies to the
extent practicable when it performs the study. Transmission Provider
shall use Reasonable Efforts to complete the Interconnection
Feasibility Study no later than forty-five (45) Calendar Days after
Transmission Provider receives the fully executed Interconnection
Feasibility Study Agreement. At the request of Interconnection
Customer or at any time Transmission Provider determines that it
will not meet the required time frame for completing the
Interconnection Feasibility Study, Transmission Provider shall
notify Interconnection Customer as to the schedule status of the
Interconnection Feasibility Study. If Transmission Provider is
unable to complete the Interconnection Feasibility Study within that
time period, it shall notify Interconnection Customer and provide an
estimated completion date with an explanation of the reasons why
additional time is required. Upon request, Transmission Provider
shall provide Interconnection Customer supporting documentation,
workpapers and relevant power flow, short circuit and stability
databases for the Interconnection Feasibility Study, subject to
confidentiality arrangements consistent with Section 13.1.
    Transmission Provider shall study the Interconnection Request at
the level of service requested by the Interconnection Customer,
unless otherwise required to study the full Generating Facility
Capacity due to safety or reliability concerns.

6.3.1 Meeting With Transmission Provider

    Within ten (10) Business Days of providing an Interconnection
Feasibility Study report to Interconnection Customer, Transmission
Provider and Interconnection Customer shall meet to discuss the
results of the Interconnection Feasibility Study.

6.4 Re-Study

    If Re-Study of the Interconnection Feasibility Study is required
due to a higher queued project dropping out of the queue, or a
modification of a higher queued project subject to Section 4.4, or
re-designation of the Point of Interconnection pursuant to Section
6.1 Transmission Provider shall notify Interconnection Customer in
writing. Such Re-Study shall take not longer than forty-five (45)
Calendar Days from the date of the notice. Any cost of Re-Study
shall be borne by the Interconnection Customer being re-studied.

Section 7. Interconnection System Impact Study

7.1 Interconnection System Impact Study Agreement

    Unless otherwise agreed, pursuant to the Scoping Meeting
provided in Section 3.4.4, simultaneously with the delivery of the
Interconnection Feasibility Study to Interconnection Customer,
Transmission Provider shall provide to Interconnection Customer an
Interconnection System Impact Study Agreement in the form of
Appendix 3 to this LGIP. The Interconnection System Impact Study
Agreement shall provide that Interconnection Customer shall
compensate Transmission Provider for the actual cost of the
Interconnection System Impact Study. Within three (3) Business Days
following the Interconnection Feasibility Study results meeting,
Transmission Provider shall provide to Interconnection Customer a
non-binding good faith estimate of the cost and timeframe for
completing the Interconnection System Impact Study.

7.2 Execution of Interconnection System Impact Study Agreement

    Interconnection Customer shall execute the Interconnection
System Impact Study Agreement and deliver the executed
Interconnection System Impact Study Agreement to Transmission
Provider no later than thirty (30) Calendar Days after its receipt
along with demonstration of Site Control, and a $50,000 deposit.
    If Interconnection Customer does not provide all such technical
data when it delivers the Interconnection System Impact Study
Agreement, Transmission Provider shall notify Interconnection
Customer of the deficiency within five (5) Business Days of the
receipt of the executed Interconnection System Impact Study
Agreement and Interconnection Customer shall cure the deficiency
within ten (10) Business Days of receipt of the notice, provided,
however, such deficiency does not include failure to deliver the
executed Interconnection System Impact Study Agreement or deposit.
    If the Interconnection System Impact Study uncovers any
unexpected result(s) not contemplated during the Scoping Meeting and
the Interconnection Feasibility Study, a substitute Point of
Interconnection identified by either Interconnection Customer or
Transmission Provider, and acceptable to the other, such acceptance
not to be unreasonably withheld, will be substituted for the
designated Point of Interconnection specified above without loss of
Queue Position, and restudies shall be completed

pursuant to Section 7.6 as applicable. For the purpose of this
Section 7.2, if Transmission Provider and Interconnection Customer
cannot agree on the substituted Point of Interconnection, then
Interconnection Customer may direct that one of the alternatives as
specified in the Interconnection Feasibility Study Agreement, as
specified pursuant to Section 3.4.4, shall be the substitute.

7.3 Scope of Interconnection System Impact Study

    The Interconnection System Impact Study shall evaluate the
impact of the proposed interconnection on the reliability of the
Transmission System. The Interconnection System Impact Study will
consider the Base Case as well as all generating facilities (and
with respect to (iii) below, any identified Network Upgrades
associated with such higher queued interconnection) that, on the
date the Interconnection System Impact Study is commenced: (i) Are
directly interconnected to the Transmission System; (ii) are
interconnected to Affected Systems and may have an impact on the
Interconnection Request; (iii) have a pending higher queued
Interconnection Request to interconnect to the Transmission System;
and (iv) have no Queue Position but have executed an LGIA or
requested that an unexecuted LGIA be filed with FERC.
    The Interconnection System Impact Study will consist of a short
circuit analysis, a stability analysis, and a power flow analysis.
The Interconnection System Impact Study will state the assumptions
upon which it is based; state the results of the analyses; and
provide the requirements or potential impediments to providing the
requested interconnection service, including a preliminary
indication of the cost and length of time that would be necessary to
correct any problems identified in those analyses and implement the
interconnection. For purposes of determining necessary
Interconnection Facilities and Network Upgrades, the System Impact
Study shall consider the level of Interconnection Service requested
by the Interconnection Customer, unless otherwise required to study
the full Generating Facility Capacity due to safety or reliability
concerns. The Interconnection System Impact Study will provide a
list of facilities that are required as a result of the
Interconnection Request and a non-binding good faith estimate of
cost responsibility and a non-binding good faith estimated time to
construct.

7.4 Interconnection System Impact Study Procedures

    Impact Study with any Affected System that is affected by the
Interconnection Request pursuant to Section 3.6 above. Transmission
Provider shall utilize existing studies to the extent practicable
when it performs the study. Transmission Provider shall use
Reasonable Efforts to complete the Interconnection System Impact
Study within ninety (90) Calendar Days after the receipt of the
Interconnection System Impact Study Agreement or notification to
proceed, study payment, and technical data. If Transmission Provider
uses Clustering, Transmission Provider shall use Reasonable Efforts
to deliver a completed Interconnection System Impact Study within
ninety (90) Calendar Days after the close of the Queue Cluster
Window.
    At the request of Interconnection Customer or at any time
Transmission Provider determines that it will not meet the required
time frame for completing the Interconnection System Impact Study,
Transmission Provider shall notify Interconnection Customer as to
the schedule status of the Interconnection System Impact Study. If
Transmission Provider is unable to complete the Interconnection
System Impact Study within the time period, it shall notify
Interconnection Customer and provide an estimated completion date
with an explanation of the reasons why additional time is required.
Upon request, Transmission Provider shall provide Interconnection
Customer all supporting documentation, workpapers and relevant pre-
Interconnection Request and post-Interconnection Request power flow,
short circuit and stability databases for the Interconnection System
Impact Study, subject to confidentiality arrangements consistent
with Section 13.1.

7.5 Meeting With Transmission Provider

    Within ten (10) Business Days of providing an Interconnection
System Impact Study report to Interconnection Customer, Transmission
Provider and Interconnection Customer shall meet to discuss the
results of the Interconnection System Impact Study.

7.6 Re-Study

    If Re-Study of the Interconnection System Impact Study is
required due to a higher queued project dropping out of the queue,
or a modification of a higher queued project subject to 4.4, or re-
designation of the Point of Interconnection pursuant to Section 7.2
Transmission Provider shall notify Interconnection Customer in
writing. Such Re-Study shall take no longer than sixty (60) Calendar
Days from the date of notice. Any cost of Re-Study shall be borne by
the Interconnection Customer being re-studied.

Section 8. Interconnection Facilities Study

8.1 Interconnection Facilities Study Agreement

    Simultaneously with the delivery of the Interconnection System
Impact Study to Interconnection Customer, Transmission Provider
shall provide to Interconnection Customer an Interconnection
Facilities Study Agreement in the form of Appendix 4 to this LGIP.
The Interconnection Facilities Study Agreement shall provide that
Interconnection Customer shall compensate Transmission Provider for
the actual cost of the Interconnection Facilities Study. Within
three (3) Business Days following the Interconnection System Impact
Study results meeting, Transmission Provider shall provide to
Interconnection Customer a non-binding good faith estimate of the
cost and timeframe for completing the Interconnection Facilities
Study. Interconnection Customer shall execute the Interconnection
Facilities Study Agreement and deliver the executed Interconnection
Facilities Study Agreement to Transmission Provider within thirty
(30) Calendar Days after its receipt, together with the required
technical data and the greater of $100,000 or Interconnection
Customer's portion of the estimated monthly cost of conducting the
Interconnection Facilities Study.

8.1.1

    Transmission Provider shall invoice Interconnection Customer on
a monthly basis for the work to be conducted on the Interconnection
Facilities Study each month. Interconnection Customer shall pay
invoiced amounts within thirty (30) Calendar Days of receipt of
invoice. Transmission Provider shall continue to hold the amounts on
deposit until settlement of the final invoice.

8.2 Scope of Interconnection Facilities Study

    The Interconnection Facilities Study shall specify and estimate
the cost of the equipment, engineering, procurement and construction
work needed to implement the conclusions of the Interconnection
System Impact Study in accordance with Good Utility Practice to
physically and electrically connect the Interconnection Facility to
the Transmission System. The Interconnection Facilities Study shall
also identify the electrical switching configuration of the
connection equipment, including, without limitation: The
transformer, switchgear, meters, and other station equipment; the
nature and estimated cost of any Transmission Provider's
Interconnection Facilities and Network Upgrades necessary to
accomplish the interconnection; and an estimate of the time required
to complete the construction and installation of such facilities.
The Facilities Study will also identify any potential control
equipment for requests for Interconnection Service that are lower
than the Generating Facility Capacity.

8.3 Interconnection Facilities Study Procedures

    Transmission Provider shall coordinate the Interconnection
Facilities Study with any Affected System pursuant to Section 3.6
above. Transmission Provider shall utilize existing studies to the
extent practicable in performing the Interconnection Facilities
Study. Transmission Provider shall use Reasonable Efforts to
complete the study and issue a draft Interconnection Facilities
Study report to Interconnection Customer within the following number
of days after receipt of an executed Interconnection Facilities
Study Agreement: Ninety (90) Calendar Days, with no more than a
20 percent cost estimate contained in the report; or one
hundred eighty (180) Calendar Days, if Interconnection Customer
requests a 10 percent cost estimate.
    At the request of Interconnection Customer or at any time
Transmission Provider determines that it will not meet the required
time frame for completing the Interconnection Facilities Study,
Transmission Provider shall notify Interconnection Customer as to
the schedule status of the Interconnection Facilities Study. If
Transmission Provider is unable to complete the Interconnection
Facilities Study and issue a draft Interconnection Facilities Study
report within the time required, it

shall notify Interconnection Customer and provide an estimated
completion date and an explanation of the reasons why additional
time is required.
    Interconnection Customer may, within thirty (30) Calendar Days
after receipt of the draft report, provide written comments to
Transmission Provider, which Transmission Provider shall include in
the final report. Transmission Provider shall issue the final
Interconnection Facilities Study report within fifteen (15) Business
Days of receiving Interconnection Customer's comments or promptly
upon receiving Interconnection Customer's statement that it will not
provide comments. Transmission Provider may reasonably extend such
fifteen-day period upon notice to Interconnection Customer if
Interconnection Customer's comments require Transmission Provider to
perform additional analyses or make other significant modifications
prior to the issuance of the final Interconnection Facilities
Report. Upon request, Transmission Provider shall provide
Interconnection Customer supporting documentation, workpapers, and
databases or data developed in the preparation of the
Interconnection Facilities Study, subject to confidentiality
arrangements consistent with Section 13.1.

8.4 Meeting With Transmission Provider

    Within ten (10) Business Days of providing a draft
Interconnection Facilities Study report to Interconnection Customer,
Transmission Provider and Interconnection Customer shall meet to
discuss the results of the Interconnection Facilities Study.

8.5 Re-Study

    If Re-Study of the Interconnection Facilities Study is required
due to a higher queued project dropping out of the queue or a
modification of a higher queued project pursuant to Section 4.4,
Transmission Provider shall so notify Interconnection Customer in
writing. Such Re-Study shall take no longer than sixty (60) Calendar
Days from the date of notice. Any cost of Re-Study shall be borne by
the Interconnection Customer being re-studied.

Section 9. Engineering & Procurement (`E&P') Agreement

    Prior to executing an LGIA, an Interconnection Customer may, in
order to advance the implementation of its interconnection, request
and Transmission Provider shall offer the Interconnection Customer,
an E&P Agreement that authorizes Transmission Provider to begin
engineering and procurement of long lead-time items necessary for
the establishment of the interconnection. However, Transmission
Provider shall not be obligated to offer an E&P Agreement if
Interconnection Customer is in Dispute Resolution as a result of an
allegation that Interconnection Customer has failed to meet any
milestones or comply with any prerequisites specified in other parts
of the LGIP. The E&P Agreement is an optional procedure and it will
not alter the Interconnection Customer's Queue Position or In-
Service Date. The E&P Agreement shall provide for Interconnection
Customer to pay the cost of all activities authorized by
Interconnection Customer and to make advance payments or provide
other satisfactory security for such costs.
    Interconnection Customer shall pay the cost of such authorized
activities and any cancellation costs for equipment that is already
ordered for its interconnection, which cannot be mitigated as
hereafter described, whether or not such items or equipment later
become unnecessary. If Interconnection Customer withdraws its
application for interconnection or either Party terminates the E&P
Agreement, to the extent the equipment ordered can be canceled under
reasonable terms, Interconnection Customer shall be obligated to pay
the associated cancellation costs. To the extent that the equipment
cannot be reasonably canceled, Transmission Provider may elect: (i)
To take title to the equipment, in which event Transmission Provider
shall refund Interconnection Customer any amounts paid by
Interconnection Customer for such equipment and shall pay the cost
of delivery of such equipment, or (ii) to transfer title to and
deliver such equipment to Interconnection Customer, in which event
Interconnection Customer shall pay any unpaid balance and cost of
delivery of such equipment.

Section 10. Optional Interconnection Study

10.1 Optional Interconnection Study Agreement

    On or after the date when Interconnection Customer receives
Interconnection System Impact Study results, Interconnection
Customer may request, and Transmission Provider shall perform a
reasonable number of Optional Studies. The request shall describe
the assumptions that Interconnection Customer wishes Transmission
Provider to study within the scope described in Section 10.2. Within
five (5) Business Days after receipt of a request for an Optional
Interconnection Study, Transmission Provider shall provide to
Interconnection Customer an Optional Interconnection Study Agreement
in the form of Appendix 5.
    The Optional Interconnection Study Agreement shall: (i) Specify
the technical data that Interconnection Customer must provide for
each phase of the Optional Interconnection Study, (ii) specify
Interconnection Customer's assumptions as to which Interconnection
Requests with earlier queue priority dates will be excluded from the
Optional Interconnection Study case and assumptions as to the type
of interconnection service for Interconnection Requests remaining in
the Optional Interconnection Study case, and (iii) Transmission
Provider's estimate of the cost of the Optional Interconnection
Study. To the extent known by Transmission Provider, such estimate
shall include any costs expected to be incurred by any Affected
System whose participation is necessary to complete the Optional
Interconnection Study. Notwithstanding the above, Transmission
Provider shall not be required as a result of an Optional
Interconnection Study request to conduct any additional
Interconnection Studies with respect to any other Interconnection
Request.
    Interconnection Customer shall execute the Optional
Interconnection Study Agreement within ten (10) Business Days of
receipt and deliver the Optional Interconnection Study Agreement,
the technical data and a $10,000 deposit to Transmission Provider.

10.2 Scope of Optional Interconnection Study

    The Optional Interconnection Study will consist of a sensitivity
analysis based on the assumptions specified by Interconnection
Customer in the Optional Interconnection Study Agreement. The
Optional Interconnection Study will also identify Transmission
Provider's Interconnection Facilities and the Network Upgrades, and
the estimated cost thereof, that may be required to provide
transmission service or Interconnection Service based upon the
results of the Optional Interconnection Study. The Optional
Interconnection Study shall be performed solely for informational
purposes. Transmission Provider shall use Reasonable Efforts to
coordinate the study with any Affected Systems that may be affected
by the types of Interconnection Services that are being studied.
Transmission Provider shall utilize existing studies to the extent
practicable in conducting the Optional Interconnection Study.

10.3 Optional Interconnection Study Procedures

    The executed Optional Interconnection Study Agreement, the
prepayment, and technical and other data called for therein must be
provided to Transmission Provider within ten (10) Business Days of
Interconnection Customer receipt of the Optional Interconnection
Study Agreement. Transmission Provider shall use Reasonable Efforts
to complete the Optional Interconnection Study within a mutually
agreed upon time period specified within the Optional
Interconnection Study Agreement. If Transmission Provider is unable
to complete the Optional Interconnection Study within such time
period, it shall notify Interconnection Customer and provide an
estimated completion date and an explanation of the reasons why
additional time is required. Any difference between the study
payment and the actual cost of the study shall be paid to
Transmission Provider or refunded to Interconnection Customer, as
appropriate. Upon request, Transmission Provider shall provide
Interconnection Customer supporting documentation and workpapers and
databases or data developed in the preparation of the Optional
Interconnection Study, subject to confidentiality arrangements
consistent with Section 13.1.

Section 11. Standard Large Generator Interconnection Agreement (LGIA)

11.1 Tender

    Interconnection Customer shall tender comments on the draft
Interconnection Facilities Study Report within thirty (30) Calendar
Days of receipt of the report. Within thirty (30) Calendar Days
after the comments are submitted, Transmission Provider shall tender
a draft LGIA, together with draft appendices. The draft LGIA shall
be in the

form of Transmission Provider's FERC-approved standard form LGIA,
which is in Appendix 6. Interconnection Customer shall execute and
return the completed draft appendices within thirty (30) Calendar
Days.

11.2 Negotiation

    Notwithstanding Section 11.1, at the request of Interconnection
Customer Transmission Provider shall begin negotiations with
Interconnection Customer concerning the appendices to the LGIA at
any time after Interconnection Customer executes the Interconnection
Facilities Study Agreement. Transmission Provider and
Interconnection Customer shall negotiate concerning any disputed
provisions of the appendices to the draft LGIA for not more than
sixty (60) Calendar Days after tender of the final Interconnection
Facilities Study Report. If Interconnection Customer determines that
negotiations are at an impasse, it may request termination of the
negotiations at any time after tender of the draft LGIA pursuant to
Section 11.1 and request submission of the unexecuted LGIA with FERC
or initiate Dispute Resolution procedures pursuant to Section 13.5.
If Interconnection Customer requests termination of the
negotiations, but within sixty (60) Calendar Days thereafter fails
to request either the filing of the unexecuted LGIA or initiate
Dispute Resolution, it shall be deemed to have withdrawn its
Interconnection Request. Unless otherwise agreed by the Parties, if
Interconnection Customer has not executed the LGIA, requested filing
of an unexecuted LGIA, or initiated Dispute Resolution procedures
pursuant to Section 13.5 within sixty (60) Calendar Days of tender
of draft LGIA, it shall be deemed to have withdrawn its
Interconnection Request. Transmission Provider shall provide to
Interconnection Customer a final LGIA within fifteen (15) Business
Days after the completion of the negotiation process.

11.3 Execution and Filing

    Within fifteen (15) Business Days after receipt of the final
LGIA, Interconnection Customer shall provide Transmission Provider
(A) reasonable evidence that continued Site Control or (B) posting
of $250,000, non-refundable additional security, which shall be
applied toward future construction costs. At the same time,
Interconnection Customer also shall provide reasonable evidence that
one or more of the following milestones in the development of the
Large Generating Facility, at Interconnection Customer election, has
been achieved: (i) The execution of a contract for the supply or
transportation of fuel to the Large Generating Facility; (ii) the
execution of a contract for the supply of cooling water to the Large
Generating Facility; (iii) execution of a contract for the
engineering for, procurement of major equipment for, or construction
of, the Large Generating Facility; (iv) execution of a contract for
the sale of electric energy or capacity from the Large Generating
Facility; or (v) application for an air, water, or land use permit.
    Interconnection Customer shall either: (i) Execute two originals
of the tendered LGIA and return them to Transmission Provider; or
(ii) request in writing that Transmission Provider file with FERC an
LGIA in unexecuted form. As soon as practicable, but not later than
ten (10) Business Days after receiving either the two executed
originals of the tendered LGIA (if it does not conform with a FERC-
approved standard form of interconnection agreement) or the request
to file an unexecuted LGIA, Transmission Provider shall file the
LGIA with FERC, together with its explanation of any matters as to
which Interconnection Customer and Transmission Provider disagree
and support for the costs that Transmission Provider proposes to
charge to Interconnection Customer under the LGIA. An unexecuted
LGIA should contain terms and conditions deemed appropriate by
Transmission Provider for the Interconnection Request. If the
Parties agree to proceed with design, procurement, and construction
of facilities and upgrades under the agreed-upon terms of the
unexecuted LGIA, they may proceed pending FERC action.

11.4 Commencement of Interconnection Activities

    If Interconnection Customer executes the final LGIA,
Transmission Provider and Interconnection Customer shall perform
their respective obligations in accordance with the terms of the
LGIA, subject to modification by FERC. Upon submission of an
unexecuted LGIA, Interconnection Customer and Transmission Provider
shall promptly comply with the unexecuted LGIA, subject to
modification by FERC.

Section 12. Construction of Transmission Provider's Interconnection
Facilities and Network Upgrades

12.1 Schedule

    Transmission Provider and Interconnection Customer shall
negotiate in good faith concerning a schedule for the construction
of Transmission Provider's Interconnection Facilities and the
Network Upgrades.

12.2 Construction Sequencing

12.2.1 General

    In general, the In-Service Date of an Interconnection Customers
seeking interconnection to the Transmission System will determine
the sequence of construction of Network Upgrades.

12.2.2 Advance Construction of Network Upgrades That Are an Obligation
of an Entity Other Than Interconnection Customer

    An Interconnection Customer with an LGIA, in order to maintain
its In-Service Date, may request that Transmission Provider advance
to the extent necessary the completion of Network Upgrades that: (i)
Were assumed in the Interconnection Studies for such Interconnection
Customer, (ii) are necessary to support such In-Service Date, and
(iii) would otherwise not be completed, pursuant to a contractual
obligation of an entity other than Interconnection Customer that is
seeking interconnection to the Transmission System, in time to
support such In-Service Date. Upon such request, Transmission
Provider will use Reasonable Efforts to advance the construction of
such Network Upgrades to accommodate such request; provided that
Interconnection Customer commits to pay Transmission Provider: (i)
Any associated expediting costs and (ii) the cost of such Network
Upgrades.
    Transmission Provider will refund to Interconnection Customer
both the expediting costs and the cost of Network Upgrades, in
accordance with Article 11.4 of the LGIA. Consequently, the entity
with a contractual obligation to construct such Network Upgrades
shall be obligated to pay only that portion of the costs of the
Network Upgrades that Transmission Provider has not refunded to
Interconnection Customer. Payment by that entity shall be due on the
date that it would have been due had there been no request for
advance construction. Transmission Provider shall forward to
Interconnection Customer the amount paid by the entity with a
contractual obligation to construct the Network Upgrades as payment
in full for the outstanding balance owed to Interconnection
Customer. Transmission Provider then shall refund to that entity the
amount that it paid for the Network Upgrades, in accordance with
Article 11.4 of the LGIA.

12.2.3 Advancing Construction of Network Upgrades That Are Part of an
Expansion Plan of the Transmission Provider

    An Interconnection Customer with an LGIA, in order to maintain
its In-Service Date, may request that Transmission Provider advance
to the extent necessary the completion of Network Upgrades that: (i)
Are necessary to support such In-Service Date and (ii) would
otherwise not be completed, pursuant to an expansion plan of
Transmission Provider, in time to support such In-Service Date. Upon
such request, Transmission Provider will use Reasonable Efforts to
advance the construction of such Network Upgrades to accommodate
such request; provided that Interconnection Customer commits to pay
Transmission Provider any associated expediting costs.
Interconnection Customer shall be entitled to transmission credits,
if any, for any expediting costs paid.

12.2.4 Amended Interconnection System Impact Study

    An Interconnection System Impact Study will be amended to
determine the facilities necessary to support the requested In-
Service Date. This amended study will include those transmission and
Large Generating Facilities that are expected to be in service on or
before the requested In-Service Date.

Section 13. Miscellaneous

13.1 Confidentiality

    Confidential Information shall include, without limitation, all
information relating to a Party's technology, research and
development, business affairs, and pricing, and any information
supplied by either of the Parties to the other prior to the
execution of an LGIA.
    Information is Confidential Information only if it is clearly
designated or marked in writing as confidential on the face of the
document, or, if the information is conveyed orally or by
inspection, if the Party providing

the information orally informs the Party receiving the information
that the information is confidential.
    If requested by either Party, the other Party shall provide in
writing, the basis for asserting that the information referred to in
this Article warrants confidential treatment, and the requesting
Party may disclose such writing to the appropriate Governmental
Authority. Each Party shall be responsible for the costs associated
with affording confidential treatment to its information.

13.1.1 Scope

    Confidential Information shall not include information that the
receiving Party can demonstrate: (1) Is generally available to the
public other than as a result of a disclosure by the receiving
Party; (2) was in the lawful possession of the receiving Party on a
non-confidential basis before receiving it from the disclosing
Party; (3) was supplied to the receiving Party without restriction
by a third party, who, to the knowledge of the receiving Party after
due inquiry, was under no obligation to the disclosing Party to keep
such information confidential; (4) was independently developed by
the receiving Party without reference to Confidential Information of
the disclosing Party; (5) is, or becomes, publicly known, through no
wrongful act or omission of the receiving Party or Breach of the
LGIA; or (6) is required, in accordance with Section 13.1.6, Order
of Disclosure, to be disclosed by any Governmental Authority or is
otherwise required to be disclosed by law or subpoena, or is
necessary in any legal proceeding establishing rights and
obligations under the LGIA. Information designated as Confidential
Information will no longer be deemed confidential if the Party that
designated the information as confidential notifies the other Party
that it no longer is confidential.

13.1.2 Release of Confidential Information

    Neither Party shall release or disclose Confidential Information
to any other person, except to its Affiliates (limited by the
Standards of Conduct requirements), employees, consultants, or to
parties who may be or considering providing financing to or equity
participation with Interconnection Customer, or to potential
purchasers or assignees of Interconnection Customer, on a need-to-
know basis in connection with these procedures, unless such person
has first been advised of the confidentiality provisions of this
Section 13.1 and has agreed to comply with such provisions.
Notwithstanding the foregoing, a Party providing Confidential
Information to any person shall remain primarily responsible for any
release of Confidential Information in contravention of this Section
13.1.

13.1.3 Rights

    Each Party retains all rights, title, and interest in the
Confidential Information that each Party discloses to the other
Party. The disclosure by each Party to the other Party of
Confidential Information shall not be deemed a waiver by either
Party or any other person or entity of the right to protect the
Confidential Information from public disclosure.

13.1.4 No Warranties

    By providing Confidential Information, neither Party makes any
warranties or representations as to its accuracy or completeness. In
addition, by supplying Confidential Information, neither Party
obligates itself to provide any particular information or
Confidential Information to the other Party nor to enter into any
further agreements or proceed with any other relationship or joint
venture.

13.1.5 Standard of Care

    Each Party shall use at least the same standard of care to
protect Confidential Information it receives as it uses to protect
its own Confidential Information from unauthorized disclosure,
publication or dissemination. Each Party may use Confidential
Information solely to fulfill its obligations to the other Party
under these procedures or its regulatory requirements.

13.1.6 Order of Disclosure

    If a court or a Government Authority or entity with the right,
power, and apparent authority to do so requests or requires either
Party, by subpoena, oral deposition, interrogatories, requests for
production of documents, administrative order, or otherwise, to
disclose Confidential Information, that Party shall provide the
other Party with prompt notice of such request(s) or requirement(s)
so that the other Party may seek an appropriate protective order or
waive compliance with the terms of the LGIA. Notwithstanding the
absence of a protective order or waiver, the Party may disclose such
Confidential Information which, in the opinion of its counsel, the
Party is legally compelled to disclose. Each Party will use
Reasonable Efforts to obtain reliable assurance that confidential
treatment will be accorded any Confidential Information so
furnished.

13.1.7 Remedies

    The Parties agree that monetary damages would be inadequate to
compensate a Party for the other Party's Breach of its obligations
under this Section 13.1. Each Party accordingly agrees that the
other Party shall be entitled to equitable relief, by way of
injunction or otherwise, if the first Party Breaches or threatens to
Breach its obligations under this Section 13.1, which equitable
relief shall be granted without bond or proof of damages, and the
receiving Party shall not plead in defense that there would be an
adequate remedy at law. Such remedy shall not be deemed an exclusive
remedy for the Breach of this Section 13.1, but shall be in addition
to all other remedies available at law or in equity. The Parties
further acknowledge and agree that the covenants contained herein
are necessary for the protection of legitimate business interests
and are reasonable in scope. No Party, however, shall be liable for
indirect, incidental, or consequential or punitive damages of any
nature or kind resulting from or arising in connection with this
Section 13.1.

13.1.8 Disclosure to FERC, Its Staff, or a State

    Notwithstanding anything in this Section 13.1 to the contrary,
and pursuant to 18 CFR 1b.20, if FERC or its staff, during the
course of an investigation or otherwise, requests information from
one of the Parties that is otherwise required to be maintained in
confidence pursuant to the LGIP, the Party shall provide the
requested information to FERC or its staff, within the time provided
for in the request for information. In providing the information to
FERC or its staff, the Party must, consistent with 18 CFR 388.112,
request that the information be treated as confidential and non-
public by FERC and its staff and that the information be withheld
from public disclosure. Parties are prohibited from notifying the
other Party prior to the release of the Confidential Information to
FERC or its staff. The Party shall notify the other Party to the
LGIA when it is notified by FERC or its staff that a request to
release Confidential Information has been received by FERC, at which
time either of the Parties may respond before such information would
be made public, pursuant to 18 CFR 388.112. Requests from a state
regulatory body conducting a confidential investigation shall be
treated in a similar manner, consistent with applicable state rules
and regulations.

13.1.9

    Subject to the exception in Section 13.1.8, any information that
a Party claims is competitively sensitive, commercial or financial
information (``Confidential Information'') shall not be disclosed by
the other Party to any person not employed or retained by the other
Party, except to the extent disclosure is (i) required by law; (ii)
reasonably deemed by the disclosing Party to be required to be
disclosed in connection with a dispute between or among the Parties,
or the defense of litigation or dispute; (iii) otherwise permitted
by consent of the other Party, such consent not to be unreasonably
withheld; or (iv) necessary to fulfill its obligations under this
LGIP or as a transmission service provider or a Control Area
operator including disclosing the Confidential Information to an RTO
or ISO or to a subregional, regional or national reliability
organization or planning group. The Party asserting confidentiality
shall notify the other Party in writing of the information it claims
is confidential. Prior to any disclosures of the other Party's
Confidential Information under this subparagraph, or if any third
party or Governmental Authority makes any request or demand for any
of the information described in this subparagraph, the disclosing
Party agrees to promptly notify the other Party in writing and
agrees to assert confidentiality and cooperate with the other Party
in seeking to protect the Confidential Information from public
disclosure by confidentiality agreement, protective order or other
reasonable measures.

13.1.10

    This provision shall not apply to any information that was or is
hereafter in the public domain (except as a result of a Breach of
this provision).

13.1.11

    Transmission Provider shall, at Interconnection Customer's
election, destroy,

in a confidential manner, or return the Confidential Information
provided at the time of Confidential Information is no longer
needed.

13.2 Delegation of Responsibility

    Transmission Provider may use the services of subcontractors as
it deems appropriate to perform its obligations under this LGIP.
Transmission Provider shall remain primarily liable to
Interconnection Customer for the performance of such subcontractors
and compliance with its obligations of this LGIP. The subcontractor
shall keep all information provided confidential and shall use such
information solely for the performance of such obligation for which
it was provided and no other purpose.

13.3 Obligation for Study Costs

    Transmission Provider shall charge and Interconnection Customer
shall pay the actual costs of the Interconnection Studies. Any
difference between the study deposit and the actual cost of the
applicable Interconnection Study shall be paid by or refunded,
except as otherwise provided herein, to Interconnection Customer or
offset against the cost of any future Interconnection Studies
associated with the applicable Interconnection Request prior to
beginning of any such future Interconnection Studies. Any invoices
for Interconnection Studies shall include a detailed and itemized
accounting of the cost of each Interconnection Study.
Interconnection Customer shall pay any such undisputed costs within
thirty (30) Calendar Days of receipt of an invoice therefor.
Transmission Provider shall not be obligated to perform or continue
to perform any studies unless Interconnection Customer has paid all
undisputed amounts in compliance herewith.

13.4 Third Parties Conducting Studies

    If (i) at the time of the signing of an Interconnection Study
Agreement there is disagreement as to the estimated time to complete
an Interconnection Study, (ii) Interconnection Customer receives
notice pursuant to Sections 6.3, 7.4 or 8.3 that Transmission
Provider will not complete an Interconnection Study within the
applicable timeframe for such Interconnection Study, or (iii)
Interconnection Customer receives neither the Interconnection Study
nor a notice under Sections 6.3, 7.4 or 8.3 within the applicable
timeframe for such Interconnection Study, then Interconnection
Customer may require Transmission Provider to utilize a third party
consultant reasonably acceptable to Interconnection Customer and
Transmission Provider to perform such Interconnection Study under
the direction of Transmission Provider. At other times, Transmission
Provider may also utilize a third party consultant to perform such
Interconnection Study, either in response to a general request of
Interconnection Customer, or on its own volition.
    In all cases, use of a third party consultant shall be in accord
with Article 26 of the LGIA (Subcontractors) and limited to
situations where Transmission Provider determines that doing so will
help maintain or accelerate the study process for Interconnection
Customer's pending Interconnection Request and not interfere with
Transmission Provider's progress on Interconnection Studies for
other pending Interconnection Requests. In cases where
Interconnection Customer requests use of a third party consultant to
perform such Interconnection Study, Interconnection Customer and
Transmission Provider shall negotiate all of the pertinent terms and
conditions, including reimbursement arrangements and the estimated
study completion date and study review deadline. Transmission
Provider shall convey all workpapers, data bases, study results and
all other supporting documentation prepared to date with respect to
the Interconnection Request as soon as soon as practicable upon
Interconnection Customer's request subject to the confidentiality
provision in Section 13.1. In any case, such third party contract
may be entered into with either Interconnection Customer or
Transmission Provider at Transmission Provider's discretion. In the
case of (iii) Interconnection Customer maintains its right to submit
a claim to Dispute Resolution to recover the costs of such third
party study. Such third party consultant shall be required to comply
with this LGIP, Article 26 of the LGIA (Subcontractors), and the
relevant Tariff procedures and protocols as would apply if
Transmission Provider were to conduct the Interconnection Study and
shall use the information provided to it solely for purposes of
performing such services and for no other purposes. Transmission
Provider shall cooperate with such third party consultant and
Interconnection Customer to complete and issue the Interconnection
Study in the shortest reasonable time.

13.5 Disputes

13.5.1 Submission

    In the event either Party has a dispute, or asserts a claim,
that arises out of or in connection with the LGIA, the LGIP, or
their performance, such Party (the ``disputing Party'') shall
provide the other Party with written notice of the dispute or claim
(``Notice of Dispute''). Such dispute or claim shall be referred to
a designated senior representative of each Party for resolution on
an informal basis as promptly as practicable after receipt of the
Notice of Dispute by the other Party. In the event the designated
representatives are unable to resolve the claim or dispute through
unassisted or assisted negotiations within thirty (30) Calendar Days
of the other Party's receipt of the Notice of Dispute, such claim or
dispute may, upon mutual agreement of the Parties, be submitted to
arbitration and resolved in accordance with the arbitration
procedures set forth below. In the event the Parties do not agree to
submit such claim or dispute to arbitration, each Party may exercise
whatever rights and remedies it may have in equity or at law
consistent with the terms of this LGIA.

13.5.2 External Arbitration Procedures

    Any arbitration initiated under these procedures shall be
conducted before a single neutral arbitrator appointed by the
Parties. If the Parties fail to agree upon a single arbitrator
within ten (10) Calendar Days of the submission of the dispute to
arbitration, each Party shall choose one arbitrator who shall sit on
a three-member arbitration panel. The two arbitrators so chosen
shall within twenty (20) Calendar Days select a third arbitrator to
chair the arbitration panel. In either case, the arbitrators shall
be knowledgeable in electric utility matters, including electric
transmission and bulk power issues, and shall not have any current
or past substantial business or financial relationships with any
party to the arbitration (except prior arbitration). The
arbitrator(s) shall provide each of the Parties an opportunity to be
heard and, except as otherwise provided herein, shall conduct the
arbitration in accordance with the Commercial Arbitration Rules of
the American Arbitration Association (``Arbitration Rules'') and any
applicable FERC regulations or RTO rules; provided, however, in the
event of a conflict between the Arbitration Rules and the terms of
this Section 13, the terms of this Section 13 shall prevail.

13.5.3 Arbitration Decisions

    Unless otherwise agreed by the Parties, the arbitrator(s) shall
render a decision within ninety (90) Calendar Days of appointment
and shall notify the Parties in writing of such decision and the
reasons therefor. The arbitrator(s) shall be authorized only to
interpret and apply the provisions of the LGIA and LGIP and shall
have no power to modify or change any provision of the LGIA and LGIP
in any manner. The decision of the arbitrator(s) shall be final and
binding upon the Parties, and judgment on the award may be entered
in any court having jurisdiction. The decision of the arbitrator(s)
may be appealed solely on the grounds that the conduct of the
arbitrator(s), or the decision itself, violated the standards set
forth in the Federal Arbitration Act or the Administrative Dispute
Resolution Act. The final decision of the arbitrator must also be
filed with FERC if it affects jurisdictional rates, terms and
conditions of service, Interconnection Facilities, or Network
Upgrades.

13.5.4 Costs

    Each Party shall be responsible for its own costs incurred
during the arbitration process and for the following costs, if
applicable: (1) The cost of the arbitrator chosen by the Party to
sit on the three member panel and one half of the cost of the third
arbitrator chosen; or (2) one half the cost of the single arbitrator
jointly chosen by the Parties.

13.5.5 Non-Binding Dispute Resolution Procedures

    If a Party has submitted a Notice of Dispute pursuant to section
13.5.1, and the Parties are unable to resolve the claim or dispute
through unassisted or assisted negotiations within the thirty (30)
Calendar Days provided in that section, and the Parties cannot reach
mutual agreement to pursue the section 13.5 arbitration process, a
Party may request that Transmission Provider engage in Non-binding
Dispute Resolution pursuant to this section by providing written
notice to Transmission Provider (``Request for Non-binding Dispute
Resolution''). Conversely, either Party may file a Request for Non-
binding Dispute Resolution pursuant to this section without first
seeking mutual

agreement to pursue the section 13.5 arbitration process. The
process in section 13.5.5 shall serve as an alternative to, and not
a replacement of, the section 13.5 arbitration process. Pursuant to
this process, a Transmission Provider must within 30 days of receipt
of the Request for Non-binding Dispute Resolution appoint a neutral
decision-maker that is an independent subcontractor that shall not
have any current or past substantial business or financial
relationships with either Party. Unless otherwise agreed by the
Parties, the decision-maker shall render a decision within sixty
(60) Calendar Days of appointment and shall notify the Parties in
writing of such decision and reasons therefore. This decision-maker
shall be authorized only to interpret and apply the provisions of
the LGIP and LGIA and shall have no power to modify or change any
provision of the LGIP and LGIA in any manner. The result reached in
this process is not binding, but, unless otherwise agreed, the
Parties may cite the record and decision in the non-binding dispute
resolution process in future dispute resolution processes, including
in a section 13.5 arbitration, or in a Federal Power Act section 206
complaint. Each Party shall be responsible for its own costs
incurred during the process and the cost of the decision-maker shall
be divided equally among each Party to the dispute.

13.6 Local Furnishing Bonds

13.6.1 Transmission Providers That Own Facilities Financed by Local
Furnishing Bonds

    This provision is applicable only to a Transmission Provider
that has financed facilities for the local furnishing of electric
energy with tax-exempt bonds, as described in Section 142(f) of the
Internal Revenue Code (``local furnishing bonds''). Notwithstanding
any other provision of this LGIA and LGIP, Transmission Provider
shall not be required to provide Interconnection Service to
Interconnection Customer pursuant to this LGIA and LGIP if the
provision of such Transmission Service would jeopardize the tax-
exempt status of any local furnishing bond(s) used to finance
Transmission Provider's facilities that would be used in providing
such Interconnection Service.

13.6.2 Alternative Procedures for Requesting Interconnection Service

    If Transmission Provider determines that the provision of
Interconnection Service requested by Interconnection Customer would
jeopardize the tax-exempt status of any local furnishing bond(s)
used to finance its facilities that would be used in providing such
Interconnection Service, it shall advise the Interconnection
Customer within thirty (30) Calendar Days of receipt of the
Interconnection Request.
    Interconnection Customer thereafter may renew its request for
interconnection using the process specified in Article 5.2(ii) of
the Transmission Provider's Tariff.

Appendix 1 to LGIP--Interconnection Request for a Large Generating
Facility

    1. The undersigned Interconnection Customer submits this request
to interconnect its Large Generating Facility with Transmission
Provider's Transmission System pursuant to a Tariff.
    2. This Interconnection Request is for (check one):

__ A proposed new Large Generating Facility.
__ An increase in the generating capacity or a Material Modification
of an existing Generating Facility.

    3. The type of interconnection service requested (check one):

__ Energy Resource Interconnection Service
__ Network Resource Interconnection Service

    4. __ Check here only if Interconnection Customer requesting
Network Resource Interconnection Service also seeks to have its
Generating Facility studied for Energy Resource Interconnection
Service
    5. Interconnection Customer provides the following information:
    a. Address or location or the proposed new Large Generating
Facility site (to the extent known) or, in the case of an existing
Generating Facility, the name and specific location of the existing
Generating Facility;
    b. Maximum summer at __ degrees C and winter at __ degrees C
megawatt electrical output of the proposed new Large Generating
Facility or the amount of megawatt increase in the generating
capacity of an existing Generating Facility;
    c. General description of the equipment configuration;
    d. Commercial Operation Date (Day, Month, and Year);
    e. Name, address, telephone number, and email address of
Interconnection Customer's contact person;
    f. Approximate location of the proposed Point of Interconnection
(optional);
    g. Interconnection Customer Data (set forth in Attachment A) and
    h. Primary frequency response operating range for electric
storage resources.
    i. Requested capacity (in MW) of Interconnection Service (if
lower than the Generating Facility Capacity).
    6. Applicable deposit amount as specified in the LGIP.
    7. Evidence of Site Control as specified in the LGIP (check one)

__ Is attached to this Interconnection Request
__ Will be provided at a later date in accordance with this LGIP

    8. This Interconnection Request shall be submitted to the
representative indicated below: [To be completed by Transmission
Provider]
    9. Representative of Interconnection Customer to contact: [To be
completed by Interconnection Customer]
    10. This Interconnection Request is submitted by:

Name of Interconnection Customer:
-----------------------------------------------------------------------
By (signature):--------------------------------------------------------
Name (type or print):--------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

Attachment A to Appendix 1 Interconnection Request

Large Generating Facility Data Unit Ratings

kVA ___ [deg]F ___ Voltage ___
Power Factor ___
Speed (RPM) ___ Connection (e.g., Wye) ___
Short Circuit Ratio ___ Frequency, Hertz ___
Stator Amperes at Rated kVA ___ Field Volts ___
Max Turbine MW ___ [deg]F ___

    Primary frequency response operating range for electric storage
resources:

Minimum State of Charge: ___-------------------------------------------
Maximum State of Charge: ___-------------------------------------------

Combined Turbine-Generator-Exciter Inertia Data

Inertia Constant, H = ___ kW sec/kVA
Moment-of-Inertia, WR\2\ = ___ lb. ft.\2\

Reactance Data (Per Unit-Rated KVA)

------------------------------------------------------------------------
                                      Direct axis      Quadrature  axis
------------------------------------------------------------------------
Synchronous--saturated..........  Xdv ___             Xqv ___
Synchronous--unsaturated........  Xdi ___             Xqi ___
Transient--saturated............  X'dv ___            X'qv ___
Transient--unsaturated..........  X'di ___            X'qi ___
Subtransient--saturated.........  X''dv ___           X''qv ___
Subtransient--unsaturated.......  X''di ___           X''qi ___
Negative Sequence--saturated....  X2v ___
Negative Sequence--unsaturated..  X2i ___
Zero Sequence--saturated........  X0v ___
Zero Sequence--unsaturated......  X0i ___
Leakage Reactance...............  Xlm ___
------------------------------------------------------------------------

Field Time Constant Data (SEC)

Open Circuit................  T'do ___              T'qo ___
Three-Phase Short Circuit     T'd3 ___              T'q ___
 Transient.
Line to Line Short Circuit    T'd2 ___
 Transient.
Line to Neutral Short         T'd1 ___
 Circuit Transient.
Short Circuit Subtransient..  T''d ___              T''q ___
Open Circuit Subtransient...  T''do ___             T''qo ___

Armature Time Constant Data (SEC)

    Three Phase Short Circuit--Ta3 ___
    Line to Line Short Circuit--Ta2 ___
    Line to Neutral Short Circuit--Ta1 ___

    Note: If requested information is not applicable, indicate by
marking ``N/A.''

MW Capability and Plant Configuration Large Generating Facility Data

Armature Winding Resistance Data (Per Unit)

    Positive--R1 ___
    Negative--R2 ___
    Zero--R0 ___
    Rotor Short Time Thermal Capacity I2\2\t = ___
    Field Current at Rated kVA, Armature Voltage and PF = ___ amps
    Field Current at Rated kVA and Armature Voltage, 0 PF = ___ amps
    Three Phase Armature Winding Capacitance = ___ microfarad
    Field Winding Resistance = ___ ohms ___ [deg]C
    Armature Winding Resistance (Per Phase) = ___ ohms ___ [deg]C

Curves

    Provide Saturation, Vee, Reactive Capability, Capacity
Temperature Correction curves. Designate normal and emergency
Hydrogen Pressure operating range for multiple curves.

Generator Step-Up Transformer Data Ratings

Capacity; Self-cooled/Maximum Nameplate
___/___ kVA
Voltage Ratio (Generator Side/System side/Tertiary)
___/___/___ kV
Winding Connections (Low V/High V/Tertiary V (Delta or Wye))
___/___/___
Fixed Taps Available ___-----------------------------------------------
Present Tap Setting ___------------------------------------------------

Impedance

    Positive; Z1 (on self-cooled kVA rating) ___ % ___ X/
R
    Zero; Z0 (on self-cooled kVA rating) ___ % ___ X/R

Excitation System Data

    Identify appropriate IEEE model block diagram of excitation
system and power system stabilizer (PSS) for computer representation
in power system stability simulations and the corresponding
excitation system and PSS constants for use in the model.

Governor System Data

    Identify appropriate IEEE model block diagram of governor system
for computer representation in power system stability simulations
and the corresponding governor system constants for use in the
model.

Wind Generators

    Number of generators to be interconnected pursuant to this
Interconnection Request: ______
Elevation: _____-------------------------------------------------------
______
Single Phase-----------------------------------------------------------
______ Three Phase
    Inverter manufacturer, model name, number, and version:
______-----------------------------------------------------------------
    List of adjustable setpoints for the protective equipment or
software:
 ______----------------------------------------------------------------

    Note: A completed General Electric Company Power Systems Load
Flow (PSLF) data sheet or other compatible formats, such as IEEE and
PTI power flow models, must be supplied with the Interconnection
Request. If other data sheets are more appropriate to the proposed
device, then they shall be provided and discussed at Scoping
Meeting.

Induction Generators

(*) Field Volts:-------------------------------------------------------
(*) Field Amperes:-----------------------------------------------------
(*) Motoring Power (kW):-----------------------------------------------
(*) Neutral Grounding Resistor (If Applicable):------------------------
(*) I2\2\t or K (Heating Time Constant):--------------------
(*) Rotor Resistance:--------------------------------------------------
(*) Stator Resistance:-------------------------------------------------
(*) Stator Reactance:--------------------------------------------------
(*) Rotor Reactance:---------------------------------------------------
(*) Magnetizing Reactance:---------------------------------------------
(*) Short Circuit Reactance:-------------------------------------------
(*) Exciting Current:--------------------------------------------------
(*) Temperature Rise:--------------------------------------------------
(*) Frame Size:--------------------------------------------------------
(*) Design Letter:-----------------------------------------------------
(*) Reactive Power Required In Vars (No Load):-------------------------
(*) Reactive Power Required In Vars (Full Load):-----------------------
(*) Total Rotating Inertia, H: ______ Per Unit on KVA Base-------------

    Note: Please consult Transmission Provider prior to submitting
the Interconnection Request to determine if the information
designated by (*) is required.

Appendix 2 to LGIP--Interconnection Feasibility Study Agreement

    This agreement is made and entered into this __ day of ______,
20 __ by and between ______, a ______ organized and existing under
the laws of the State of ______, (``Interconnection Customer,'') and
______ a ______ existing under the laws of the State of ______,
(``Transmission Provider ''). Interconnection Customer and
Transmission Provider each may be referred to as a ``Party,'' or
collectively as the ``Parties.''

Recitals

    Whereas, Interconnection Customer is proposing to develop a
Large Generating Facility or generating capacity addition to an
existing Generating Facility consistent with the Interconnection
Request submitted by Interconnection Customer dated ______; and
    Whereas, Interconnection Customer desires to interconnect the
Large Generating Facility with the Transmission System; and
    Whereas, Interconnection Customer has requested Transmission
Provider to perform an Interconnection Feasibility Study to assess
the feasibility of interconnecting the proposed Large Generating
Facility to the Transmission System, and of any Affected Systems;
    Now, therefore, in consideration of and subject to the mutual
covenants contained herein the Parties agreed as follows:
    1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated in
Transmission Provider's FERC-approved LGIP.
    2.0 Interconnection Customer elects and Transmission Provider
shall cause to be performed an Interconnection Feasibility Study
consistent with Section 6.0 of this LGIP in accordance with the
Tariff.
    3.0 The scope of the Interconnection Feasibility Study shall be
subject to the assumptions set forth in Attachment A to this
Agreement.
    4.0 The Interconnection Feasibility Study shall be based on the
technical information provided by Interconnection Customer in the
Interconnection Request, as may be modified as the result of the
Scoping Meeting. Transmission Provider reserves the right to request
additional technical information from Interconnection Customer as
may reasonably become necessary consistent with Good Utility
Practice during the course of the Interconnection Feasibility Study
and as designated in accordance with Section 3.4.4 of the LGIP. If,
after the designation of the Point of Interconnection pursuant to
Section 3.4.4 of the LGIP, Interconnection Customer modifies its
Interconnection Request pursuant to Section 4.4, the time to
complete the Interconnection Feasibility Study may be extended.
    5.0 The Interconnection Feasibility Study report shall provide
the following information:

--Preliminary identification of any circuit breaker short circuit
capability limits exceeded as a result of the interconnection;
--preliminary identification of any thermal overload or voltage
limit violations resulting from the interconnection; and
--preliminary description and non-bonding estimated cost of
facilities required to interconnect the Large Generating Facility to
the Transmission System and to address the identified short circuit
and power flow issues.

    6.0 Interconnection Customer shall provide a deposit of $10,000
for the performance of the Interconnection Feasibility Study.
    Upon receipt of the Interconnection Feasibility Study
Transmission Provider shall charge and Interconnection Customer
shall pay the actual costs of the Interconnection Feasibility Study.
    Any difference between the deposit and the actual cost of the
study shall be paid by or refunded to Interconnection Customer, as
appropriate.
    7.0 Miscellaneous. The Interconnection Feasibility Study
Agreement shall include standard miscellaneous terms including, but
not limited to, indemnities, representations, disclaimers,
warranties, governing law, amendment, execution, waiver,
enforceability and assignment, that reflect best practices in the
electric industry, and that are consistent with regional practices,
Applicable Laws and Regulations, and the organizational nature of
each Party. All of these provisions, to the extent practicable,
shall be consistent with the provisions of the LGIP and the LGIA.
    In witness whereof, the Parties have caused this Agreement to be
duly executed by their duly authorized officers or agents on the day
and year first above written.

[Insert name of Transmission Provider or Transmission Owner, if
applicable]

By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------
[Insert name of Interconnection Customer]
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

Attachment A to Appendix 2--Interconnection Feasibility Study Agreement

Assumptions Used in Conducting the Interconnection Feasibility Study

    The Interconnection Feasibility Study will be based upon the
information set forth in the Interconnection Request and agreed upon
in the Scoping Meeting held on ______:
    Designation of Point of Interconnection and configuration to be
studied.
    Designation of alternative Point(s) of Interconnection and
configuration.
    [Above assumptions to be completed by Interconnection Customer
and other assumptions to be provided by Interconnection Customer and
Transmission Provider]

Appendix 3 to LGIP--Interconnection System Impact Study Agreement

    This Agreement is made and entered into this __ day of ______,
20__ by and between ______, a ______ organized and existing under
the laws of the State of ______, (``Interconnection Customer,'') and
______ a ______ existing under the laws of the State of ______,
(``Transmission Provider ''). Interconnection Customer and
Transmission Provider each may be referred to as a ``Party,'' or
collectively as the ``Parties.''

Recitals

    Whereas, Interconnection Customer is proposing to develop a
Large Generating Facility or generating capacity addition to an
existing Generating Facility consistent with the Interconnection
Request submitted by Interconnection Customer dated ______; and
    Whereas, Interconnection Customer desires to interconnect the
Large Generating Facility with the Transmission System;
    Whereas, Transmission Provider has completed an Interconnection
Feasibility Study (the ``Feasibility Study'') and provided the
results of said study to Interconnection Customer (This recital to
be omitted if Transmission Provider does not require the
Interconnection Feasibility Study.); and
    Whereas, Interconnection Customer has requested Transmission
Provider to perform an Interconnection System Impact Study to assess
the impact of interconnecting the Large Generating Facility to the
Transmission System, and of any Affected Systems;
    Now, therefore, in consideration of and subject to the mutual
covenants contained herein the Parties agreed as follows:
    1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated in
Transmission Provider's FERC-approved LGIP.
    2.0 Interconnection Customer elects and Transmission Provider
shall cause to be performed an Interconnection System Impact Study
consistent with Section 7.0 of this LGIP in accordance with the
Tariff.
    3.0 The scope of the Interconnection System Impact Study shall
be subject to the assumptions set forth in Attachment A to this
Agreement.
    4.0 The Interconnection System Impact Study will be based upon
the results of the Interconnection Feasibility Study and the
technical information provided by Interconnection Customer in the
Interconnection Request, subject to any modifications in accordance
with Section 4.4 of the LGIP. Transmission Provider reserves the
right to request additional technical information from
Interconnection Customer as may reasonably become necessary
consistent with Good Utility Practice during the course of the
Interconnection Customer System Impact Study. If Interconnection
Customer modifies its designated Point of Interconnection,
Interconnection Request, or the technical information provided
therein is modified, the time to complete the Interconnection System
Impact Study may be extended.
    5.0 The Interconnection System Impact Study report shall provide
the following information:

--identification of any circuit breaker short circuit capability
limits exceeded as a result of the interconnection;
--identification of any thermal overload or voltage limit violations
resulting from the interconnection;
--identification of any instability or inadequately damped response
to system disturbances resulting from the interconnection and
--description and non-binding, good faith estimated cost of
facilities required to interconnect the Large Generating Facility to
the Transmission System and to address the identified short circuit,
instability, and power flow issues.

    6.0 Interconnection Customer shall provide a deposit of $50,000
for the performance of the Interconnection System Impact Study.
Transmission Provider's good faith estimate for the time of
completion of the Interconnection System Impact Study is [insert
date].
    Upon receipt of the Interconnection System Impact Study,
Transmission Provider shall charge and Interconnection Customer
shall pay the actual costs of the Interconnection System Impact
Study.
    Any difference between the deposit and the actual cost of the
study shall be paid by or refunded to Interconnection Customer, as
appropriate.
    7.0 Miscellaneous. The Interconnection System Impact Study
Agreement shall include standard miscellaneous terms including, but
not limited to, indemnities, representations, disclaimers,
warranties, governing law, amendment, execution, waiver,
enforceability and assignment, that reflect best practices in the
electric industry, that are consistent with regional practices,
Applicable Laws and Regulations and the organizational nature of
each Party. All of these provisions, to the extent practicable,
shall be consistent with the provisions of the LGIP and the LGIA.]
    In witness thereof, the Parties have caused this Agreement to be
duly executed by their duly authorized officers or agents on the day
and year first above written.

[Insert name of Transmission Provider or Transmission Owner, if
applicable]
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------
[Insert name of Interconnection Customer]
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

Attachment A To Appendix 3--Interconnection System Impact Study
Agreement

Assumptions Used in Conducting the Interconnection System Impact Study

    The Interconnection System Impact Study will be based upon the
results of the Interconnection Feasibility Study, subject to any
modifications in accordance with

Section 4.4 of the LGIP, and the following assumptions:
    Designation of Point of Interconnection and configuration to be
studied.
    Designation of alternative Point(s) of Interconnection and
configuration.
    [Above assumptions to be completed by Interconnection Customer
and other assumptions to be provided by Interconnection Customer and
Transmission Provider]

Appendix 4 to LGIP--Interconnection Facilities Study Agreement

    THIS AGREEMENT is made and entered into this day __ of ______,
20__ by and between ______, a ______ organized and existing under
the laws of the State of ______, (``Interconnection Customer,'') and
______ a ______ existing under the laws of the State of ______,
(``Transmission Provider ''). Interconnection Customer and
Transmission Provider each may be referred to as a ``Party,'' or
collectively as the ``Parties.''

Recitals

    Whereas, Interconnection Customer is proposing to develop a
Large Generating Facility or generating capacity addition to an
existing Generating Facility consistent with the Interconnection
Request submitted by Interconnection Customer dated ______; and
    Whereas, Interconnection Customer desires to interconnect the
Large Generating Facility with the Transmission System;
    Whereas, Transmission Provider has completed an Interconnection
System Impact Study (the ``System Impact Study'') and provided the
results of said study to Interconnection Customer; and
    Whereas, Interconnection Customer has requested Transmission
Provider to perform an Interconnection Facilities Study to specify
and estimate the cost of the equipment, engineering, procurement and
construction work needed to implement the conclusions of the
Interconnection System Impact Study in accordance with Good Utility
Practice to physically and electrically connect the Large Generating
Facility to the Transmission System.
    Now, therefore, in consideration of and subject to the mutual
covenants contained herein the Parties agreed as follows:
    1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated in
Transmission Provider's FERC-approved LGIP.
    2.0 Interconnection Customer elects and Transmission Provider
shall cause an Interconnection Facilities Study consistent with
Section 8.0 of this LGIP to be performed in accordance with the
Tariff.
    3.0 The scope of the Interconnection Facilities Study shall be
subject to the assumptions set forth in Attachment A and the data
provided in Attachment B to this Agreement.
    4.0 The Interconnection Facilities Study report (i) shall
provide a description, estimated cost of (consistent with Attachment
A), schedule for required facilities to interconnect the Large
Generating Facility to the Transmission System and (ii) shall
address the short circuit, instability, and power flow issues
identified in the Interconnection System Impact Study.
    5.0 Interconnection Customer shall provide a deposit of $100,000
for the performance of the Interconnection Facilities Study. The
time for completion of the Interconnection Facilities Study is
specified in Attachment A.
    Transmission Provider shall invoice Interconnection Customer on
a monthly basis for the work to be conducted on the Interconnection
Facilities Study each month. Interconnection Customer shall pay
invoiced amounts within thirty (30) Calendar Days of receipt of
invoice. Transmission Provider shall continue to hold the amounts on
deposit until settlement of the final invoice.
    6.0 Miscellaneous. The Interconnection Facility Study Agreement
shall include standard miscellaneous terms including, but not
limited to, indemnities, representations, disclaimers, warranties,
governing law, amendment, execution, waiver, enforceability and
assignment, that reflect best practices in the electric industry,
and that are consistent with regional practices, Applicable Laws and
Regulations, and the organizational nature of each Party. All of
these provisions, to the extent practicable, shall be consistent
with the provisions of the LGIP and the LGIA.
    In witness whereof, the Parties have caused this Agreement to be
duly executed by their duly authorized officers or agents on the day
and year first above written.

[Insert name of Transmission Provider or Transmission Owner, if
applicable]

By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

[Insert name of Interconnection Customer]

By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

Attachment A To Appendix 4--Interconnection Facilities Study Agreement

Interconnection Customer Schedule Election for Conducting the
Interconnection Facilities Study

    Transmission Provider shall use Reasonable Efforts to complete
the study and issue a draft Interconnection Facilities Study report
to Interconnection Customer within the following number of days
after of receipt of an executed copy of this Interconnection
Facilities Study Agreement:

--Ninety (90) Calendar Days with no more than a 20
percent cost estimate contained in the report, or
--one hundred eighty (180) Calendar Days with no more than a 10 percent cost estimate contained in the report.

Attachment B to Appendix 4--Interconnection Facilities Study Agreement

Data Form To Be Provided by Interconnection Customer With the
Interconnection Facilities Study Agreement

    Provide location plan and simplified one-line diagram of the
plant and station facilities. For staged projects, please indicate
future generation, transmission circuits, etc.
    One set of metering is required for each generation connection
to the new ring bus or existing Transmission Provider station.
Number of generation connections:
    On the one line diagram indicate the generation capacity
attached at each metering location. (Maximum load on CT/PT)
    On the one line diagram indicate the location of auxiliary
power. (Minimum load on CT/PT) Amps
    Will an alternate source of auxiliary power be available during
CT/PT maintenance? __Yes __No
    Will a transfer bus on the generation side of the metering
require that each meter set be designed for the total plant
generation? __Yes __No (Please indicate on one line diagram).
    What type of control system or PLC will be located at
Interconnection Customer's Large Generating Facility?
-----------------------------------------------------------------------

    What protocol does the control system or PLC use?
-----------------------------------------------------------------------

    Please provide a 7.5-minute quadrangle of the site. Sketch the
plant, station, transmission line, and property line.

    Physical dimensions of the proposed interconnection station:
-----------------------------------------------------------------------

    Bus length from generation to interconnection station:
-----------------------------------------------------------------------

    Line length from interconnection station to Transmission
Provider's transmission line.
-----------------------------------------------------------------------

    Tower number observed in the field. (Painted on tower leg) *
-----------------------------------------------------------------------

    Number of third party easements required for transmission lines
*:
-----------------------------------------------------------------------

    * To be completed in coordination with Transmission Provider.
    Is the Large Generating Facility in the Transmission Provider's
service area? __Yes __No
    Local provider:
-----------------------------------------------------------------------

    Please provide proposed schedule dates:
Begin Construction:
Date:------------------------------------------------------------------
Generator step-up transformer receives back feed power
Generation Testing-----------------------------------------------------
Date:------------------------------------------------------------------
Commercial Operation
Date:------------------------------------------------------------------

Appendix 5 to LGIP--Optional Interconnection Study Agreement

    This Agreement is made and entered into this __ day of ______,
20__ by and between ______, a ______ organized and existing under
the laws of the State of ______, (``Interconnection Customer,'') and
______ a ______ existing under the laws of the State of ______,
(``Transmission Provider ''). Interconnection Customer and
Transmission Provider each may be referred to as a ``Party,'' or
collectively as the ``Parties.''

Recitals

    Whereas, Interconnection Customer is proposing to develop a
Large Generating Facility or generating capacity addition to an
existing Generating Facility consistent with the Interconnection
Request submitted by Interconnection Customer dated ______;
    Whereas, Interconnection Customer is proposing to establish an
interconnection with the Transmission System; and
    Whereas, Interconnection Customer has submitted to Transmission
Provider an Interconnection Request; and
    Whereas, on or after the date when Interconnection Customer
receives the Interconnection System Impact Study results,
Interconnection Customer has further requested that Transmission
Provider prepare an Optional Interconnection Study;
    Now, therefore, in consideration of and subject to the mutual
covenants contained herein the Parties agree as follows:
    1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated in
Transmission Provider's FERC-approved LGIP.
    2.0 Interconnection Customer elects and Transmission Provider
shall cause an Optional Interconnection Study consistent with
Section 10.0 of this LGIP to be performed in accordance with the
Tariff.
    3.0 The scope of the Optional Interconnection Study shall be
subject to the assumptions set forth in Attachment A to this
Agreement.
    4.0 The Optional Interconnection Study shall be performed solely
for informational purposes.
    5.0 The Optional Interconnection Study report shall provide a
sensitivity analysis based on the assumptions specified by
Interconnection Customer in Attachment A to this Agreement. The
Optional Interconnection Study will identify Transmission Provider's
Interconnection Facilities and the Network Upgrades, and the
estimated cost thereof, that may be required to provide transmission
service or interconnection service based upon the assumptions
specified by Interconnection Customer in Attachment A.
    6.0 Interconnection Customer shall provide a deposit of $10,000
for the performance of the Optional Interconnection Study.
Transmission Provider's good faith estimate for the time of
completion of the Optional Interconnection Study is [insert date].
    Upon receipt of the Optional Interconnection Study, Transmission
Provider shall charge and Interconnection Customer shall pay the
actual costs of the Optional Study.
    Any difference between the initial payment and the actual cost
of the study shall be paid by or refunded to Interconnection
Customer, as appropriate.
    7.0 Miscellaneous. The Optional Interconnection Study Agreement
shall include standard miscellaneous terms including, but not
limited to, indemnities, representations, disclaimers, warranties,
governing law, amendment, execution, waiver, enforceability and
assignment, that reflect best practices in the electric industry,
and that are consistent with regional practices, Applicable Laws and
Regulations, and the organizational nature of each Party. All of
these provisions, to the extent practicable, shall be consistent
with the provisions of the LGIP and the LGIA.
    In witness whereof, the Parties have caused this Agreement to be
duly executed by their duly authorized officers or agents on the day
and year first above written.

[Insert name of Transmission Provider or Transmission Owner, if
applicable]

By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------
By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

[Insert name of Interconnection Customer]

By:--------------------------------------------------------------------
Title:-----------------------------------------------------------------
Date:------------------------------------------------------------------

Appendix 6 to LGIP--Large Generator Interconnection Agreement (See
LGIA)

Appendix 7--Interconnection Procedures for a Wind Generating Plant

    Appendix 7 sets forth procedures specific to a wind generating
plant. All other requirements of this LGIP continue to apply to wind
generating plant interconnections.

A. Special Procedures Applicable to Wind Generators

    The wind plant Interconnection Customer, in completing the
Interconnection Request required by section 3.3 of this LGIP, may
provide to the Transmission Provider a set of preliminary electrical
design specifications depicting the wind plant as a single
equivalent generator. Upon satisfying these and other applicable
Interconnection Request conditions, the wind plant may enter the
queue and receive the base case data as provided for in this LGIP.
    No later than six months after submitting an Interconnection
Request completed in this manner, the wind plant Interconnection
Customer must submit completed detailed electrical design
specifications and other data (including collector system layout
data) needed to allow the Transmission Provider to complete the
System Impact Study.

United States of America--Federal Energy Regulatory Commission

Building for the Future Through Electric Regional Transmission
Planning and Cost Allocation and Generator Interconnection

Docket No. RM21-17-000

(Issued April 21, 2022)

DANLY, Commissioner, dissenting:

    1. I welcome long term transmission planning reform. I would
prefer that Regional Transmission Organizations (RTOs) and other
interested public utilities simply file their own proposals under
section 205 of the Federal Power Act (FPA). They are fully capable
of proposing rate changes and reforms on their own.\1\
---------------------------------------------------------------------------

    \1\ See, e.g., New England Power Pool Participants Committee
October 12, 2021 Comments at 4-8 (detailing past and current
transmission planning activities).
---------------------------------------------------------------------------

    2. This Notice of Proposed Rulemaking (NOPR) goes far beyond
that. It contemplates a Federal Power Act section 206 finding that
existing transmission planning across the nation--in every region,
for every utility and market--is so unjust and unreasonable that it
must be replaced with mandatory, pervasive, and invasive
``reforms.'' \2\ But let us be clear. The NOPR's primary purpose is
to achieve narrow environmental policy objectives, not to address
legitimate requirements under the Federal Power Act like ensuring
just and reasonable rates or reliability. After all, as the NOPR
itself repeatedly admits, it is ``driven by changes in resource mix
and demand,'' \3\ notwithstanding its references to genuine problems
with existing transmission planning.\4\
---------------------------------------------------------------------------

    \2\ Building for the Future Through Elec. Reg'l Transmission
Planning & Cost Allocation & Generator Interconnection, 179 FERC ]
61,028 (2022) (``NOPR''); see also Building for the Future Through
Elec. Reg'l Transmission Planning & Cost Allocation & Generator
Interconnection, 176 FERC ] 61,024 (2021) (``ANOPR'').
    \3\ The NOPR uses the phrase ``driven by changes in the resource
mix and demand'' 116 times. These are code words for ``renewables.''
See NOPR, 179 FERC ] 61,028 at P 45 (detailing ``[t]hese changes in
the resource mix and demand,'' almost all of which involve the
transition to renewable resources).
    \4\ See id. PP 37-41, 48-49. Nearly every other preliminary
finding related to current transmission planning is tied to
``changes in the resource mix and demand.''
---------------------------------------------------------------------------

    3. The majority seeks to establish policies designed to
encourage the massive transmission build-out that will doubtless be
required to transition to an aspirational renewable future. To do
so, they need to socialize the costs of this transmission across as
broad a population of ratepayers as possible. Thus, they seek to use
the FPA, a statute that sounds in rate regulation and reliability,
as a tool to achieve a particular (and inapposite) policy goal. In
this regard, it is much like the majority's recent foray into
transforming our pipeline certification process into a comprehensive
environmental review.\5\ Accordingly, I must dissent.
---------------------------------------------------------------------------

    \5\ See Certification of New Interstate Nat. Gas Facilities, 178
FERC ] 61,107, order dismissing reh'g requests, Certification of New
Interstate Nat. Gas Facilities, 179 FERC ] 61,012 (2022); see also
Certification of New Interstate Nat. Gas Facilities, 178 FERC ]
61,197 (2022).

---------------------------------------------------------------------------

    4. I normally would not oppose a NOPR. What is wrong with asking
questions and seeking a record to consider reforms? But this NOPR is
a boondoggle. It seeks to change virtually all aspects of
transmission planning, including in non-RTO regions and it does so
for the specific, though unstated, purpose of suborning the
transmission planning process so it can be wielded as a tool to
support the development of a specific set of favored generation
resources. How does it do this? The NOPR proposes to require regions
to factor in any state or even ``local'' (!) public policy (read,
renewable) goals, no matter how far-fetched.\6\ If San Francisco,
for example, passes an ordinance that all its energy must be solar
no matter the cost, CAISO and perhaps all western regional planning
now must take that into account in their transmission plans. And
what if the local policy is unreasonable? Or what if a state has far
more aggressive goals than another state? No matter: All must plan
for the dreams of others.
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    \6\ NOPR, 179 FERC ] 61,028 at PP 104, 106.
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    5. The Federal Power Act requires just and reasonable rates.
That prohibits the Commission from charging ratepayers for unneeded
transmission projects to accommodate someone else's view of what
types of generation might be preferable. And we are not talking
about economic or reliability projects. The transmission at issue
here is that required to accommodate state and local laws
establishing the composition of their generation fleets. Choosing
their own generation mix is undoubtedly their right, since such
choices are unambiguously reserved to the states under the FPA, but
the FPA does not require the Commission to accommodate these
policies under either of its core statutory obligations: To ensure
just and reasonable rates and to ensure reliability. In fact, it is
quite the opposite, the NOPR risks further undue discrimination.
Nevertheless, the NOPR starts from the premise that such projects
must be considered in regional planning.
    6. Even if no transmission projects are ever selected under the
new regional planning regime, the process imposed by the NOPR itself
will substantially increase customer costs. As Arizona's largest
utility commented in the record, ``[w]hile [Arizona Public Service
Company] acknowledges the Commission's desire to construct
transmission for a quicker transition to a clean energy mix,
unbound[ed] study work would lengthen timelines, thereby increasing
the associated costs, for both the transmission planning process and
the generator interconnection process.'' \7\
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    \7\ Arizona Public Service Company October 12, 2021 Comments at
4.
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    7. The NOPR not only is too expansive, it also is too specific.
It proposes scores of detailed mandates. One such mandate, for
example, is that four is the minimum number of planning scenarios a
public utility must study, and that if one of the scenarios is a
``base case,'' that one must be ``most likely.'' \8\ ``[A]t least
one of the four distinct'' scenarios ``must account for uncertain
operational outcomes . . . during high-impact, low-frequency
events'' but we do ``allow'' utilities ``to determine which . . .
high-impact, low-frequency event should be modeled.'' \9\ Woe unto
the utility that conducts long term planning by considering a fewer
number of scenarios, but you do get to pick your favorite high-
impact, low-frequency event.
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    \8\ NOPR, 179 FERC ] 61,028 at P 123.
    \9\ Id. P 124 (emphasis added).
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    8. Entire sections of the NOPR read like a think tank's wish
list rather than a rigorous analysis of whether such Nice-to-Have
ideas are required for just and reasonable, non-discriminatory
ratemaking. For some reason, the NOPR proposes that dynamic line
ratings and advanced power flow control devices must be the default
when studying any new transmission or generation solution ``in all
aspects of the regional transmission planning processes, including
the existing regional transmission planning processes for near-term
regional transmission needs.'' \10\ Never mind that we already have
a Notice of Inquiry on dynamic line ratings.\11\ And I thought this
proceeding was about long-term planning? For some other reason, the
NOPR has a section on ``Specificity of Data Inputs'' \12\ which
defines the ``best available data'' everyone in the industry must
use in their planning, particularly endorsing ``the most recent data
on renewable energy potential and distributed energy resources
developed by national labs.'' \13\ The NOPR also considers a mandate
to establish a ``periodic forum'' to study best practices and
additional reforms.\14\ Why would this need to be mandated? Must the
Commission control everything? Is no one in the industry capable of
such foresight absent our intervention? And, by the way, the NOPR
also proposes (in the name of ``transparency'') to require new
levels of ``enhancements'' and oversight for local transmission
planning, by requiring utilities to incorporate detailed tariff
amendments to describe their local planning processes.\15\ It also
obligates them to consider, among other things, requirements for how
utilities should be ``right-sizing'' transmission facilities, and
whether we should mandate information requirements on ``estimated
in-kind replacements of . . . existing transmission.'' \16\ Does
this not seem like overly prescriptive regulatory meddling?
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    \10\ Id. P 274.
    \11\ Implementation of Dynamic Line Ratings, 178 FERC ] 61,110
(2022).
    \12\ NOPR, 179 FERC ] 61,028 at PP 91, 127-134.
    \13\ Id. P 131 & n.247 (citing National Renewable Energy
Laboratory's Renewable Energy Potential model and Distributed
Generation Market Demand model).
    \14\ Id. P 255.
    \15\ Id. PP 7, 400-415.
    \16\ Id. PP 414-415.
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    9. And yet--notwithstanding its bulk and granularity--the NOPR
fails to clarify the single most critical question confronting
individual states and consumers: Will unwilling states' ratepayers
be required to pay for their neighboring state's new transmission
project which is being built solely for the purpose of achieving
that neighboring state's (or locality's) public policy goals? The
NOPR leaves open what happens if states cannot voluntarily agree on
such issues,\17\ but many will seek to have the RTO allocate costs
as it sees fit, including to unwilling states. I oppose forcing the
ratepayers in states with different public policy goals to pay for
another state's plans.
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    \17\ Id. P 310.
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    10. According to a 2018 summary by the National Conference of
State Legislatures, 24 states either did not have any renewable
portfolio standard or it had expired or was set to expire: Alabama,
Alaska, Arkansas, Florida, Georgia, Idaho, Iowa (expired), Kansas
(expired), Kentucky, Louisiana, Michigan (expired in 2021),
Mississippi, Missouri (expired in 2021), Montana (expired),
Nebraska, North Carolina (expired in 2021), North Dakota (expired),
Oklahoma (expired), Pennsylvania (expired in 2021), South Dakota
(expired), Tennessee, West Virginia, Wisconsin (expired), and
Wyoming.\18\ Renewable standards in an additional 3 states were
voluntary: Indiana, South Carolina, and Utah.\19\ That 27 states
lack mandatory renewable portfolio standards rather suggests that
the country is divided on this issue.
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    \18\ See State Renewable Portfolio Standards & Goals, National
Conference of State Legislatures (Aug. 13, 2021), https://www.ncsl.org/research/energy/renewable-portfolio-standards.aspx.
    \19\ See id.
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    11. Not surprisingly, states are among the primary opponents of
the reforms contemplated in the ANOPR, many of which have survived
through to the issuance of today's NOPR. The Utah Public Service
Commission correctly commented ``that FERC seeks to reshape
transmission planning and cost allocation for the purpose of
expanding the transmission system `in areas with high degrees of
renewable resources' that require `extensive' and `more expensive'
new transmission facilities.'' \20\ The Utah Public Service
Commission explained that:
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    \20\ Utah Public Service Commission October 8, 2021 Comments at
2 (citing ANOPR, 176 FERC ] 61,024 at P 40).

[I]ncreased development and integration of renewable generation is a
highly charged political question and a matter of significant
political interest. Different states' legislatures have made
different policy choices. Some states, like California, have enacted
very ambitious laws that require revolutionary changes to their
generation mixes. As the [ANOPR] makes clear, these changes require
significant investment in, among other things, new transmission
infrastructure to wheel renewable generation.
* * * * *
    The [Utah Public Service Commission] is deeply concerned the
[ANOPR] advertises an interest in rewriting the rules governing
transmission planning and cost allocation to better facilitate
policy choices, not of Congress, but of particular state
legislatures. More specifically, the [Utah Public Service
Commission] is opposed to any rule change that would allow such
preferences to impose costs on ratepayers in other states.\21\
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    \21\ Id. at 2-3.

    12. Different policy goals are a critical reason for state
opposition to a federal transmission planning regime, but certainly
---------------------------------------------------------------------------
not the only one. The Louisiana Public Service Commission explained:

the Commission proposes to change transmission planning and cost
allocation to support a new fleet of renewable generating resources
in preference to other types of generation. But it is not within the
Commission's FPA authority, or within the ambit of sound
transmission planning, to dictate the choice of generating resources
and then determine what planning and cost allocation metrics will
lead to the appearance of an economic transmission build-out to
support those resources. This approach interferes with the
jurisdiction and authority of the states, fails to recognize
regional differences, and could stifle innovation and the
development of the most reliable and beneficial solutions at the
least delivered energy and capacity cost.
    Many of the ANOPR's proposals would not achieve just and
reasonable rates, and, in fact, could lead in the opposite
direction. They would dramatically increase costs imposed on
consumers while potentially jeopardizing the reliability of the
grid. Renewable resources are inherently intermittent and not
dispatchable. They do not and will not have the same reliability
benefits as thermal generation without significant technological
investment and/or duplicative back-up power costs. Consumer costs
should not increase without a corresponding benefit, and certainly
not in the face of diminished reliability, one of the bedrock
principles of electric rate regulation.\22\
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    \22\ Louisiana Public Service Commission October 12, 2021
Comments at 2-3.

    13. I also attended the meetings of the joint federal-state task
force on electric transmission in which numerous state commissioners
voiced their concern that federal transmission planning regimes
would be imposed upon the states, that the Commission would insist
on uniformity throughout the country, and most importantly, that the
Commission might require their state's ratepayers to shoulder the
costs of another state's transmission projects.\23\ It should go
without saying that the Commission would be wise to proceed with
caution before acting in the face of state opposition.
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    \23\ See, e.g., Joint Fed.-State Task Force on Elec.
Transmission, 175 FERC ] 61,224 (2021) (establishing task force);
see Joint Fed.-State Task Force on Elec. Transmission, FERC (last
updated Apr. 4, 2022), https://www.ferc.gov/TFSOET.
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    14. The NOPR raises another serious issue: I do not know how
most of these proposals are supposed to work in non-RTO regions.
Nor, apparently, does anyone else. This may explain the repeated
entreaties for the Commission to allow regional variation in
transmission planning. For example:

the [Sponsors of the Southeastern Regional Transmission Planning
Process (SERTP Sponsors)] are concerned that a one-size-fits-all
adoption of some of the items contemplated in the ANOPR could prove
counter-productive or unworkable in the SERTP's expansive, twelve-
state, non-RTO footprint. The SERTP Sponsors respectfully submit
that the Commission's rules concerning regional transmission
planning should continue to accommodate varying approaches to
transmission and system planning in recognition of the inherent
variability of existing market structures, state policies and