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FERC Should Address the Concerns <br />Of Network Service Customers <br />The O ~T~IS of FERC jurisdictional TOs require them Lo plan for the <br />transmission needs of their net~~~~rk customers. Some O_~'I~"h net~~cork <br />customers, however, belie~~e that. their loads and resources have not been <br />treated equitably or °comparat~rl}~" to those of their TOs in transmission <br />panning and facilities construction. y~1`hile net~~~ork customers pay their <br />load ratio st-rare of u-ansrnission system costs, they can be put. on the <br />"margin" by their FERC:-jurisdictional TOs ~~-hen it comes to transmission <br />planning. Some have been told thtiy must pay the Iirll cost of all additional <br />transmission facilities nc°edcd to connect their new resources or to serve <br />their increased loads, even when they believe that the TO's own loads ~~~~ould <br />very likely benefit. from such facilities as well The joint transmission <br />planning that network customers had hoped would carne Keith the Ordc°r <br />No. 888 0.~1TT has not materialized. Similarly, generation developers have <br />had difficulty gaining access to the u,ansrnission system in some <br />regions, and in traving their generation projects designated as <br />FERC Could do much to assure ntit~~~ork resources. <br />adequate transmission infra- <br />structure development in non- FERC could do mach w assrirc adequate transmission <br />RTU reJI011S Of the COUntry infrastructure development in non-R"I'O regions of the <br />merely byvlgorouSly enforcing country n~~erely by eigorousle enforcing the joint planning <br />the joint planning and and transmission constrt.iction obligations FERC-jurisdictional <br />transmi$sion ConstruCt1011 `IOs have under their o~an existing OATTs. In so doing, <br />obligations FERC-jurisdictional FF,RC could promote the concept of joint participation in <br />TOS have under thelrOwn transmission systems and construction projects by both 'I'Os <br />eXlSting OATTS. and their net~~~ork service custorncrs on a proportional basis, <br />to reduce the capital outlays required by FERC-jurisdictional <br />TOs, and to make transmission o~,~nersl-rip more broadly <br />available to load-stirring utilities in these regions. Such joint. participation <br />in transmission system and facilities ownership is a logical extension of <br />FERC's current transmission system cost-allocation method, under which <br />neu~-ark service customers ah-tiadl' pay their load ratio share of their TO's <br />fixed transmission system costs, day after day, year after year. <br />24 Restructuring at the Crossroads: FERC Electric Policy Reconsidered <br />