FERC Filings

FERC RTO NOPR COMMENTS

Conclusion

Conclusion
The electric power industry is in the midst of a major restructuring, and FERC's continuing leadership in this process is crucial. EPSA supports FERC's commitment to building a competitive wholesale market, and believes that a competitive wholesale market is a prerequisite to the development of competitive retail markets. EPSA concurs with FERC's concern about mandating any particular market structure and, in this vein, encourages the Commission to foster the development of market structures to provide the flexibility needed for today and the future. The very idea of a market suggests that it cannot be pre-designed. It is critical, though, that FERC advance the process of evolving markets by doing everything possible to promote the establishment of RTOs capable of addressing the ongoing discrimination and inefficiencies that still exist in the wholesale power markets. As the markets develop, understanding what form of transmission organizations will work best will similarly develop; form will follow function.
The Commission correctly concludes that promoting RTOs need not pre-ordain a final industry structure. While some argue that RTOs are a transitional step to a different industry structure, EPSA contends that, transitional or not, RTOs may be the best mechanism, in conjunction with full comparability, currently available to address

many of the structural problems in the existing market. Thus, with the issues raised herein addressed, FERC should expeditiously adopt a Final Rule in the proceeding and move to implement it aggressively.

July 27, 1999

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