The Federal Energy Regulatory Commission has invited post-workshop comments on issues covered during its June 29 technical conference on PURPA. The first group of questions focuses on the use of the so-called “one-mile rule” to determine the size of an entity seeking QF certification. Specifically, FERC is seeking comments on:
- Whether the presumption inherent in the one-mile rule should be made rebuttable, and if so, who should benefit from the presumption and who should bear the burden of rebutting the presumption (i.e., the QF or the utility).
- Whether FERC should consider modifying the referenced one-mile distance.
- Whether FERC should consider a more fact-based analysis.
The second group of questions pertains to minimum standards for purchase contracts under PURPA. Specifically, FERC is seeking comments on:
- The appropriate minimum term of PURPA contracts and/or other contract terms that a developer needs to secure financing.
- How establishing a minimum term and other conditions would affect QF development.
- Whether the size threshold for standard contracts (currently 100 kW) should be revised — and if so, how.
- Whether utility data submission requirements to state commissions for the purpose of determining avoided-cost rates are being adhered to, and whether this information is helpful in calculating avoided cost rates.