FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN OPPOSITION TO THE MOTIONS FOR EMERGENCY AND INTERIM RELIEF

Overview

The Electric Power Supply Association (“EPSA”) hereby files comments in opposition to the Joint Motion of Pacific Gas & Electric Company (PG&E), Southern California Edison Company (Edison) and The Utility Reform Network (TURN) seeking an immediate determination by the Commission that the California markets are not workably competitive, imposing a $100/MWh price cap, requiring generators to provide cost-of-service information and instituting procedures for comprehensive fixes to the California markets and refund responsibilities. EPSA also files in opposition to the California Public Utilities Commission (CPUC) Motion for Interim Relief seeking load differentiated price caps and mandatory forward contracting and the San Diego Gas & Electric (SDG&E) filing seeking a $100/MWh price cap. An interim cost-based bid cap and a restructuring of the California ISO Board. For the reasons explained below, EPSA, which has previously intervened in these dockets, urges the Commission to deny the relief sought in the various Motions. <sup>(1) To the extent comments on the California ISO’s proposed Offer of Settlement are appropriate at this time, EPSA’s comment are relevant to the proposals therein.
(2) The staff’s fact-finding investigation is being conducted pursuant to an Order Directing Staff Investigation issued by the Commission on July 26, 2000 and includes California as well as other regions of the country.
(3)Id at p. 7.

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