133. I reject the requests for clarification and technical conference from the EEI, Southern and GSP regarding the potential impact on the queue of the accelerated process of excess interconnection service, both as regards interconnection applications and transmission planning. Although the Commission agrees with SPG that, for a given transport provider, the same staff who would be responsible for processing the non-surplus interconnection maintenance queue would probably also be responsible for managing the excess interconnection service process, but this fact does not justify the approval of the requests for clarification. As stated in Regulation No 845, transmission providers regularly carry out similar studies outside the interconnection process, without there being a significant delay for other interconnection customers. [12] Prior to Order No. 845, this construction option was available to an interswitching customer only if the transmission provider did not approve the construction schedule preferred by the interswitching customer. The Commission found that Regulation No 845 does not address delays and inefficiencies caused by `speculative` interconnection applications. [341] It argues that currently, a speculative interconnection customer can “stay in the queue for years” and withdraw “at the last moment.” [342] Southern submitted that this is a concern given that interswitching customers have suspended or terminated (at their request) half of the interconnection agreements entered into under Southern`s OATT since 2014. Southern states, however, that while the Commission recognises these concerns, Regulation No 845 `does not address solutions on the customer side`. [343] Southern also opposes Regulation 343. .

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