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<title>May 2001: Texas Public Utilities Commission Petitions FERC For Waiver Of 
PURPA Qualifying Facilities Rules</title>
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    <p align="left"><strong><small><font face="Arial">About The Author:</font></small></strong></p>
    <p align="left"><font face="Arial" style="font-size: 9pt">Robert A. Olson is a partner in the law firm of
    Brown, Olson &amp; Gould, P.C. which maintains a nationwide practice in energy law,
    public utility law and related commercial transactions.</font></p>
    <p><small><font face="Arial"><font style="font-size: 9pt">He can be reached at:</font><br>
    <br>
    <b><font color="#0000FF">Brown, Olson & Gould, PC</font></b><br>
2 Delta Drive<br>
    Suite 301<br>
Concord, NH 03301<br>
&nbsp;<a href="mailto:[email protected]">[email protected]</a><br>
    (603) 225-9716<br>
<a href="mailto:[email protected]"></a></font></small></p>
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    <img src="../images/statelin.gif" alt="STATELINE by Robert Olson" border="0" width="375" height="75">
</center><p align="left"><b><u><br>
    May 2001</u>
    <br>
    <font size="6">Texas Public Utilities Commission 
    Petitions FERC For Waiver Of
    PURPA Qualifying Facilities Rules<br>
    </font>
    </b><strong>by Robert Olson&nbsp; -- &nbsp; Brown, Olson and Wilson, P.C.<br>
    </strong><font face="Arial" size="2">(<em>originally published by PMA OnLine Magazine:
200</em>1/10/06)</font></p>
    <p align="left"></p>
    <center>
    <p ALIGN="left">On March 23, 2001, the Public Utilities Commission of Texas 
    (PUCT) filed a petition with the Federal Energy Regulatory Commission (FERC) 
    seeking a waiver of the FERC rules promulgated under section 210 of the 
    Public Utility Regulatory Policies Act of 1978 (PURPA). These FERC rules 
    require &quot;electric utilities&quot; to purchase power from qualifying cogeneration 
    and qualifying small power production facilities (QFs) at an avoided cost 
    rate and require electric utilities to sell power to QFs. The PUCT alleges 
    in its petition that the rules are unnecessary and are impediments to 
    competition in light of Texas legislation (SB 7), under which electric 
    retail competition will begin in January, 2002. Numerous entities have moved 
    to intervene in the docket, most of whom have also filed answers in support 
    or opposition. A number of potential intervenors have also sought to 
    consolidate the docket opened for the PUCT petition (Docket EL01-60) with a 
    docket opened for a petition filed by Texas QFs seeking a declaration from 
    FERC that the Texas electric utilities retain their PURPA purchase 
    obligations after they restructure themselves under SB 7 (Docket EL01-49).</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p ALIGN="left">Under SB 7, Texas electric utilities are not required to 
    divest their generation assets; however, they are required to unbundle into 
    three entities, which may be affiliated: a transmission and distribution 
    company (T&amp;D), a power generation company (PGC), and a retail electric 
    provider (REP). Under SB 7, the REP sells energy services to retail 
    customers, but is prohibited from owning or operating generation facilities. 
    The Texas law requires the affiliated REP to provide its residential and 
    small commercial customers with price protections. The PGC is prohibited 
    from selling energy to customers. The T&amp;D company remains an &quot;electric 
    utility&quot; under Texas law, but is not an &quot;electric utility&quot; under PURPA. The 
    PGC and REP are &quot;electric utilities&quot; under PURPA. Under Texas law, the T&amp;D 
    company is prohibited from selling power and may only purchase power for its 
    own consumption. </p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p ALIGN="left">In its petition, the PUCT argues the imposition of the PURPA 
    requirements on any of these entities would be unworkable, given the limited 
    tasks of each entity and that they need to function in a competitive market. 
    The PUCT also argues that the goal of PURPA &#8211; to stimulate the development 
    of QFs &#8211; would be met once competition starts. Finally, the PUCT argues that 
    the PURPA requirements would place PGCs at a competitive disadvantage to QFs 
    because the QFs would have the benefit of a regulatory-imposed obligation to 
    purchase, which would place affiliated REPs at a competitive disadvantage to 
    non-affiliated REPs, who are free from offering price protections to their 
    customers. The PUCT petition alleges that existing contracts for QF 
    purchases will be honored.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p ALIGN="left">Motions to intervene and oppositions to the PUCT&#8217;s petition 
    have been filed by several Texas QFs and trade associations. A number of 
    arguments have been advanced by the opponents. First, opponents argue 
    granting the PUCT&#8217;s petition would amount to an administrative repeal of a 
    federal statute, PURPA, in Texas and that such a wholesale waiver of the 
    PURPA QF requirements is unprecedented. The opponents contend FERC should 
    defer to Congress when addressing any fundamental changes in PURPA. They 
    also contend that PURPA preempts Texas legislation which may arguably be 
    interpreted as preventing PURPA&#8217;s implementation in Texas. They also contend 
    that waivers of FERC rules may only be sought on a single utility basis, and 
    cannot be sought en masse. </p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p ALIGN="left">Second, opponents assert that the QF development will not, 
    at least in the near term, be stimulated when retail competition is slated 
    to begin in 2002, but will be impaired, and that the PUCT bears the burden 
    of proving whether retail competition actually has stimulated QF development 
    before it could seek a waiver of the PURPA requirements, thus making the 
    request premature. Opponents cite a PUCT report concluding that the 
    wholesale market in one of Texas&#8217; regional districts is illiquid as a result 
    of short-term trading accounting for 5.7% of total energy consumption. </p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p align="left">The opponents also state market price will not be the same 
    as the avoided cost rate the QFs are entitled to under PURPA. Opponents also 
    surmise the QFs&#8217; market for power will be limited given the bilateral 
    contract nature of the market and the corporate relationship between 
    affiliated PGCs and REPs. Opponents further stress that the alleged 
    opportunity to sell energy with the advent of competition is not the same as 
    the PURPA requirement that electric utilities are obligated to buy QF power. 
    The opponents point out that QFs need the PURPA requirements in order to 
    foster a market for their power because QF power generating schedules are 
    often dependent on their steam host.</p>
    <center><font FACE="Palatino" SIZE="2"></font>
    <p ALIGN="left">Third, with regard to the protection of existing contracts, 
    opponents claim electric utilities have taken steps to abrogate QF contracts 
    in light of SB 7, and further note that most of the existing contracts 
    contain &quot;regulatory out&quot; clauses, which arguably could jeopardize the 
    contracts upon a change in the law. As an alternative, the opponents seek a 
    grandfathering for existing QFs for any waiver. Finally, the QFs argue that 
    PURPA can be harmonized with SB 7 by requiring affiliated REPs and/or 
    affiliated PGCs to maintain the PURPA obligations, on the basis that these 
    entities have inherited the obligation from their previous corporate 
    identity and on the basis that they remain &quot;electric utilities&quot; under the 
    terms of PURPA. The opponents further claim that a waiver of the PURPA 
    requirements would undermine the settled expectations of QF investors.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p ALIGN="left">Three electric utilities, Entergy Gulf States, Inc., TXU 
    Electric Company, and Reliant Energy, Incorporated, and a trade association 
    of investor-owned utilities, the PURPA Reform Group, have moved to intervene 
    and submitted comments in support of the PUCT&#8217;s petition. The supporters of 
    the petition argue the continuation of the PURPA requirements will provide 
    QFs with a competitive advantage, in that QFs will be able to choose from 
    the higher of two prices: the market price or the avoided cost set by 
    tariff. They also argue that the market price by definition is the &quot;avoided 
    cost.&quot; The supporters further contend that the only &quot;electric utility&quot; 
    subject to the PURPA requirements is the T&amp;D company, as only the T&amp;D 
    company is an &quot;electric utility&quot; under Texas law. Because the T&amp;D companies 
    are prohibited by state law from selling power, and may only buy power from 
    a REP, the supporters argue, it would be inefficient to require the T&amp;D 
    company to buy QF power. </p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p ALIGN="left">The supporters add that the T&amp;D company is not an &quot;electric 
    utility&quot; under PURPA, and therefore not obligated under PURPA to meet the QF 
    purchasing requirements. Additionally, the supporters argue that requiring 
    REPs or PGCs to buy unspecified amounts of QF power would create significant 
    complications for them in arranging their power supply and generation needs.
    </p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="left"></p>
    </font>
    <p align="left">The supporters argue that certain REPs may be more likely 
    targets of QF power sales than other REPs, placing these REPs at a 
    competitive disadvantage. With respect to the issue of existing contracts, 
    TXU Electric stated that Texas law provides that SB 7 not interfere with 
    existing contracts. In the event FERC refuses the waiver, the supporters ask 
    that FERC alternatively grant the PUCT latitude in implementing PURPA&#8217;s 
    rules to harmonize SB 7 with PURPA&#8217;s requirements. They also argue that the 
    QF industry is now a developed industry, no longer needing the protections 
    of PURPA.</p>
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    <hr color="#FFFF00">
    <blockquote>
      <p align="left"><font face="Arial">
      <small>Robert A. Olson is a partner in the law firm of Brown, Olson &amp; 
		Gould P.C.
      which maintains a nationwide practice in energy law, public utility law and related
      commercial transactions. He can be reached at:</small></font><p align="center">
      <font face="Arial"><small><font color="#0000FF"><b>Brown, Olson & Gould, PC</b></font><br>
2 Delta Drive, Suite 301<br>
Concord, NH 03301 <br>
      <br>
      <a href="mailto:[email protected]">[email protected]</a> | (603) 225-9716<a href="mailto:[email protected]"></a></small></font>
    
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