FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Comments Regarding Retail Electric Competition-V010003
I. Introduction
The Electric Power Supply Association (EPSA) is pleased to submit the following comments in response to the Federal Trade Commission’s (Commission) Notice Requesting Comments on Retail Electricity Competition Plans. The Commission has recognized a number of significant issues facing the electricity industry in its attempt to examine the many regulatory and legislative approaches states have taken to restructure their electricity markets.
EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. EPSA members provide reliable, competitively priced electricity from environmentally responsible facilities in U.S. and global power markets. EPSA seeks to bring the benefits of competition to all power customers.
EPSA believes that all consumers should have a choice of electricity suppliers. To date, 25 states and the District of Columbia have taken steps to restructure their electricity industry to give customers that choice. Competition is the most effective tool to enhance reliability, bolster economic development, provide new services to consumers and keep prices as affordable and stable as possible. While acknowledging that every state is unique, EPSA believes that every consumer nationwide can and will benefit from having a choice of electricity suppliers.
In November 2000, EPSA published a revised version of its white paper, Retail Competition: Getting It Right! This document includes detailed recommendations regarding the issues encountered by states that have already implemented retail electricity competition. Among its conclusions, EPSA recommends that states ensure a “date certain” when competition will begin; create effective customer choice through the unbundling of utility services; guarantee the full recovery of all legitimate, verifiable, non-mitigable, prudently incurred, net (eligible) stranded costs; provide open and fair access to the transmission and distribution system for all suppliers; establish regional transmission organizations (RTOs); and eliminate barriers to participation in a competitive market. A copy of the white paper is attached for the Commission’s consideration. Further, EPSA would like to expand on a few critical issues that are affecting retail markets in states that have already opened to competition.
For ease of reading, EPSA’s comments track the identification of issues in the Commission’s notice. Given that EPSA represents competitive power suppliers nationwide, we will not respond to every question in the Commission’s notice, but will instead discuss the issues on a broader basis. EPSA member companies will submit their experiences in state retail markets in greater detail in their filings with the Commission.