The debate boils down to this: renewable generators see Valley Electric's system as a good place to locate renewable infrastructure — but it is small, and located in Nevada, and at least one commissioner said its ratepayers should not have to bear the costs of system improvements that will benefit others. "The location of Valley Electric has led to a volume of interconnection requests to meet California’s renewable targets that is grossly disproportionate to its customer base," former Chairman Cheryl LaFleur wrote in her dissent. "It is simply unfair to require the 0.27 percent of CAISO’s customer base in Nevada to bear the costs of these interconnections." For some comparison: Valley Electric has an annual gross load of 545 GWh, according to the commission's order—less than 1% of the system's annual gross load. Pacific Gas & Electric, however, is CAISO’s largest PTO and has an annual gross load of 91,500 GWh. CAISO's proposal would have set a new "Certified Small PTO" for whom low-voltage, generator-interconnection-driven network upgrade costs would be allocated regionally, rather than locally. The interconnection costs for Vallery Electric's system, said LaFleur, "are not remotely commensurate with the benefits they receive." The two new Republican members, Chairman Neil Chatterjee and Commissioner Robert Powelson, disagreed. They noted that FERC has previously considered proposals regarding alternative cost allocation methodologies for network upgrades assigned to low-load zones. "However, CAISO has not demonstrated that its proposal allocates the costs of network upgrades to those that benefit from the network upgrades," they wrote in FERC's order.
The Federal Energy Regulatory Commission has rejected a proposal by the California Independent System Operator (CAISO) to allocate renewable interconnection costs regionally, rather than locally. The Valley Electric system, based in Nevada, has has an annual gross load of 545 GWh, compared to Pacific Gas & Electric, CAISO’s largest participating transmission owner, which has 91,500 GWh. "It is simply unfair to require the 0.27% of CAISO’s customer base in Nevada to bear the costs of these interconnections", said former chairman Cheryl LaFleur.