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COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE SCOPE OF THE RTO ENVIRONMENTAL ASSESSMENT

CONCLUSION

As the RTO rulemaking is limited to transmission-management aspects of electricity supply, it will have no significant environmental impacts. The rulemaking simply supports the efficiency and independence of open-access electricity markets. EPSA believes that increasing market competition among electricity suppliers is part of the environmental solution, not part of the environmental problem. To the extent that industry restructuring has environmental impacts, they will be beneficial. Accordingly, any indirect environmental impacts of the proposed rulemaking would be positive, as the rule's reinforcement of the increasingly competitive electricity market also reinforces its incentives for efficiency and environmental performance improvements.

EPSA appreciates the opportunity to provide comments on these important issues, and appreciates the Commission's efforts in promoting non-discriminatory, open-access markets for electricity supply.



June 14, 1999

Respectfully submitted,

Lynne H. Church, Executive Director
Julie Simon, Director of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 H Street, NW, Suite 760
Washington, DC 20005
202-789-7200