FERC Filings
REQUEST FOR REHEARING OF THE ELECTRIC POWER SUPPLY ASSOCIATION-12/01/00
II. CONCLUSION
The Commission’s reversal in setting the refund effective date in Docket EL00-98-000 as October 2, 2000 (i) violated the clear statutory provisions of Section 206(b) of the Federal Power Act. Moreover it defeated Congress’ specific intent to balance not only the needs of consumers but to protect utilities from unreasonable exposure to refunds. The Commission therefore should grant rehearing, and should reinstate its initial and correct determination that the earliest refund effective date allowable under Section 206 is October 29, 2000.
Dated: December 1, 2000
Respectfully submitted,
Julie Simon, Vice President of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005
Larry F. Eisenstat
Mark L. Perlis
Robert C. Fallon
Dickstein Shapiro Morin & Oshinsky
2101 L Street, N.W.
Washington, D.C. 20037