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 Respondent

III. Conclusion

As discussed herein, EPSA urges the Commission to adopt certain aspects of the Commission’s recommendations and to make certain modifications thereto before the Staff Report is adopted and implemented in full. Specifically, EPSA urges the Commission to retain the limited scope and duration of the market mitigation measures and the use of the single market clearing price auction. However, EPSA urges the Commission to:

clarify that these market mitigation measures are being put into place to address structural defects in the California market, not the abuse of market power by any market participants;

avoid the use of cost-based rates as a proxy for competitive prices during times of scarcity;

ensure that if cost-based proxy rates are used, those rates includes the full value of scarcity, capacity, opportunity costs, and other factors;

develop proxy rates, if necessary, using the formula in the March 9th Refund Order;

not delegate or grant authority to the California ISO as it is presently constituted; and

forego forced bidding into real-time markets.

March 22, 2001

Respectfully submitted,

Julie Simon
Vice President of Policy
Electric Power Supply Association

1401 New York Avenue, NW
11th Floor
Washington, DC 20005
(202) 628-8200