FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION-San Diego Gas & Electric Company -Complainant v. Sellers of Energy and Ancillary Services Into Markets Operated by the California Independent System Operator and the California Power Exchange-Respondents D

3. Prescribe a limited period for mitigating bids

As currently proposed, all bids remain in a form of suspended animation for a period of up to two years. This is unnecessary to serve the Commission’s monitoring (or deterrence) goals and will be destabilizing to new investment. As such, EPSA believes that all bids below $150 should be subject to a safe harbor and the Commission should so state in the final order. Moreover, EPSA recommends that the Commission announce an expedited procedure for determining whether to scrutinize any bid, and a short period thereafter in which Commission action to mitigate the bid must be taken. Suppliers must be able to move on and have assurances that their bids will not be forever open to scrutiny and their revenues subject to rescission. EPSA proposes that 15 days should be a sufficient period in which to inform a bidder that its bid is being formally scrutinized and that up to 60 days should be sufficient to determine whether to apply clearly articulated standards to mitigate such bid. The Commission should also provide a written explanation of why particular bids have been mitigated so that future business can be planned accordingly.

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