FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION

HOW SHOULD CBM BE TREATED?

In the Notice of Technical Conference, the Commission poses a number of questions concerning how CBM should be calculated, by whom and for what purpose. As set forth above, EPSA believes that CBM has no place in a competitive market and should be returned to the market as firm capacity.

However, if the Commission concludes that CBM has a continuing legitimate purpose, perhaps during a transition period, these questions take on great importance. Because of the inherent value of firm transmission capacity in a competitive market, the Commission must carefully work to minimize the negative impacts of CBM withdrawals on competitive markets, and to keep the treatment of CBM consistent with the Commission's goal of comparability. Thus, calculation and allocation of CBM must be done fairly, openly and by parties with no stake in the generation market. Ideally, a regional transmission organization might be charged with this function. The availability of CBM for non-firm service must also be explicitly addressed.

Since EPSA advocates that CBM be eliminated, we are not offering detailed comments on these issues. However, if the Commission continues to allow CBM to be used, EPSA and its members are prepared to offer more detailed comments on specific issues.

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