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FERC Filings

MOTION TO INTERVENE, AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION-DOCKET NO. ER01-180-000 AND ER01-181-000

IV. Conclusion

Extending the price caps as requested by NYISO would seriously jeopardize the continued development of competitive markets in New York. Clearly, on behalf of their customers, some parties find high energy prices difficult to accept. However, imposing price caps for an indefinite time period is the wrong response to the situation, and fails to address the underlying problems. The impediments to utilities engaging more actively in bilateral, forward markets and other hedging strategies are the real problems that must be addressed. Accordingly, for the reasons explained herein, EPSA urges the Commission to deny the NYISO’s request to extend price caps in perpetuity.

Dated: November 9, 2000
Respectfully submitted,

_____________________________
Julie Simon, Vice President of Policy
Erin N. Perrigo, Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005
<sup> (8) Kennedy Maize, “Commentary: High Prices Aren’t Always Wrong.” The Electricity Daily. Volume 5, Number 77. October 23, 2000, at 4.</sup>