UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Reform of Generator Interconnection)

Procedures and Agreements)Docket No. RM17-8-000

MOTION OF THE ISO/RTO COUNCIL
TO EXTEND THE COMMENT PERIOD

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy
Regulatory Commission (“Commission”), 18 C.F.R. § 385.212 (2016), the ISO/RTO Council
(“IRC”)1 respectfully submits this Motion to extend the period for filing comments in
response to the Notice of Proposed Rulemaking (“NOPR”)2 in the above-captioned

proceeding by thirty days, so that comments may be filed on or before April 13, 2017.

I.MOTION FOR EXTENSION OF TIME

In the NOPR, the Commission proposes, and seeks comments on, revisions to the
Commission’s regulations, the pro forma Large Generator Interconnection Procedures
(“LGIP”) and the pro forma Large Generator Interconnection Agreement (“LGIA”) to
incorporate fourteen proposed reforms designed to improve certainty, promote more
informed interconnection, and enhance interconnection processes.3 The proposed reforms, as

1 The IRC is comprised of the Alberta Electric System Operator (“AESO”), the California Independent System
Operator Corporation (“CAISO”), the Electric Reliability Council of Texas, Inc. (“ERCOT”), the

Independent Electricity System Operator (“IESO”), ISO New England Inc. (“ISO-NE”), the Midcontinent Independent System Operator, Inc. (“MISO”), the New York Independent System Operator, Inc. (“NYISO”), PJM Interconnection, L.L.C. (“PJM”), and the Southwest Power Pool, Inc. (“SPP”). ERCOT, AESO, and IESO are not FERC-jurisdictional and are not joining in this Motion.

2 Notice of Proposed Rulemaking, Reform of Interconnection Procedures and Agreements, 157 FERC ¶ 61,212 (2016), 82 Fed.Reg. 4464. The NOPR was published in the Federal Register on January 13, 2017. Comments are due on March 14, 2017.

3 NOPR at P 5.

the Commission explains, are in response to concerns expressed about the potential shortcomings in the existing interconnection processes in the Petition for Rulemaking submitted by the American Wind Energy Association (“AWEA Petition”) on June 19, 2015, and the comments submitted in response to the Commission’s Technical Conference held on May 13, 2016, to discuss issues relating to the AWEA Petition and other generator interconnection issues, including interconnection of electric storage resources.4 The proposed reforms are also driven by “a number of developments that impact generator interconnections, including the changing resource mix, the emergency of new technologies, and state and federal policies that have impacted the resource mix.”5

The IRC believes that an extended comment period will enable better, more detailed responses to the Commission’s extensive proposals. Each proposal raises a number of questions to which the IRC’s members would like to respond. In addition, the matters addressed in the NOPR are critical to the future of the energy industry, and therefore warrant thorough consideration by all commenters.

The IRC makes this request to ensure that it, its members, and all commenters have sufficient time to coordinate and prepare reasoned comments to address important issues that will inform the Commission in developing any final rule. The IRC’s request to extend the period in which to file initial comments by thirty days is relatively short and is in no way intended to delay the proposals that are presented in the NOPR, nor will any parties be prejudiced by such an extension of time.

4 NOPR at PP 3-4.

5Id. at P 2.

/s/ Margoth Caley

Raymond W. Hepper

Vice President, General Counsel, and Secretary Theodore J. Paradise

Assistant General Counsel, Operations and Planning

Margoth Caley

Senior Regulatory Counsel

ISO New England Inc.

One Sullivan Road

Holyoke, Massachusetts 01040

mcaley@iso-ne.com

/s/ Anna McKenna

Roger E. Collanton, General Counsel Anna McKenna

Assistant General Counsel, Regulatory

California Independent System Operator Corporation

250 Outcropping Way
Folsom, California 95630

amckenna@caiso.com

/s/ Stephen G. Kozey

Stephen G. Kozey
Senior Vice President
Joseph G. Gardner

Vice President & Chief Compliance Officer

Midcontinent Independent System Operator, Inc.

720 City Center Drive
Carmel, Indiana 46032

February 10, 2017
3

/s/ Sara Keegan

Robert E. Fernandez, General Counsel Raymond Stalter

Director of Regulatory Affairs Sara B. Keegan

Senior Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard
Rensselaer, NY 12144

skeegan@nyiso.com

/s/ Craig Glazer

Craig Glazer

Vice President-Federal Government Policy

James M. Burlew, Senior Counsel

PJM Interconnection, L.L.C.

Suite 600

1200 G. Street, N.W. Washington, D.C. 20005 202-423-4743

Craig.Glazer@pjm.com
James.Burlew@pjm.com

/s/ Paul Suskie

Paul Suskie

Executive Vice President & General Counsel

Tessie Kentner
Senior Attorney

Southwest Power Pool, Inc.

201 Worthen Drive

Little Rock, Arkansas 72223-4936

psuskie@spp.org