FERC has extended the comment deadline in Cedar Creek Wind Energy (Cedar Creek) and Milford Wind Corridor's (Milford) appeal of a decision by the North American Electric Reliability Corporation (NERC) that affirmed the Western Electricity Coordinating Council's (WECC) registration of the two wind farms as Transmission Owners (TO) and Transmission Operators (TOP). Another generator was so registered by WECC two years ago and, on appeal, estimated that the cost of complying with the TO/TOP reliability standards would be approximately $1 million per year. (That generator lost its appeal.)

In October, NERC concluded that Cedar Creek (which owns 72 miles of a sole-use 76-mile, 230 kV interconnection line that serves its 300 MW wind farm) and Milford (which owns a sole-use 88-mile, 345 kV interconnection line that serves its 203.5 MW wind farm) were appropriately registered for TO/TOP reliability functions. NERC reasoned that because the interconnection lines connect generating facilities that are registered for Generator Owner and Generator Operator functions to the transmission facilities that fall under a TO/TOP registration, the interconnection lines are material to the reliability of the bulk power system.

Many generation developers, owners, and operators should be aware of NERC's decision, and the subsequent appeal, because such reasoning, if upheld by FERC, would support a TO/TOP registration for any generator sized 20 MVA (single unit) or 75 MVA (multiple units) or greater that interconnects at a voltage of 100 kV or above.

Comments are due in this docket by December 7, 2010.