FERC's core logic on the most important part of its rulemaking is that those projections are often wrong. Very true! But that is a problem with utility-owned & QF generation alike.
The most significant proposal @FERC makes is that QF rates can be paid for their energy based on the prevailing market price. Good, ordinarily. But without preconditioning that change on corresponding reforms of the utility business model? Well, that's unlawful.
FERC has a great deal of latitude here, but it is under a black-letter statutory duty to "insure" that its rules result in "rates" which "shall not discriminate" against QFs.
Has the agency done any work to "insure" this? No. 
A better way to solve the legitimate problems of government setting prices based on guesses is to channel *everyone* into a market where they vie against one another in competition to set prices.
To grapple seriously with this problem requires a lot of work -- work that some places, such as Texas, have already achieved. And work that other places -- such as IL, NY, NJ, OH, to name only a few -- are backsliding on. And work that never got off the ground elsewhere.
You can view the full @EPSAnews comments here: epsa.org/wp-content/upl…
Finally, on a personal note, I've spent an inordinate amount of time dealing with PURPA over the last decade. I appreciate what a racket much of it is. But you know what's often a bigger racket? Utility rate-based generation. /fin
