FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-New York Independent System Operator, Inc, Central Hudson Gas & Electric Corporation,Consolidated Edison Company of New York, Inc., New York State Electric & Gas Corporation, Niagara Mo

III. CONCLUSION

The proposed New York RTO does not meet the Commission’s requirements (1) that an RTO be independent of market participants, (2) with respect to scope and regional configuration, (3) as to possession of exclusive authority over interconnection of generators to the transmission grid and with respect to planing and expansion, (4) with respect to parallel path flows, (5) with respect to market monitoring, and (6) with respect to interregional coordination.

The Commission should not accept NYISO’s Compliance Filing and the NYISO should be directed to amend the Compliance Filing in a manner consistent with the issues raised by EPSA in this Protest. In particular, the Commission should direct the NYISO to work with the two other northeastern ISOs to adopt the best market rules and business practices of the three ISOs and should specify practical measures, such as involvement of the Commission’s ADR unit and a settlement judge, to require the three ISOs to integrate the market functions and subsequently the ISOs’ structures. The Commission should issue an order immediately directing that such a regional integration effort commence.

February 22, 2001

Respectfully submitted,

Julie Simon, Vice President of Policy
Erin Perrigo, Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005

Larry F. Eisenstat
Michael J. Rustum
Charles M. Pratt
Dickstein Shapiro Morin & Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037

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