• CONTACT US
  • SITE MAP
Advocating the power of competition

FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE INVESTIGATION OF PUBLIC UTILITY RATES IN WHOLESALE WESTERN ENERGY MARKETS

IV. Application of Mitigation Designed for California to the WSCC Has Not Been Adequately Thought Through.

EPSA is concerned that this Order overlooks the inherent differences between California and the WSCC, and fails to address some obvious obstacles to implementation of California-designed mitigation measures:

  • How will price mitigation measures imposed on the WSCC be effected if the CAISO fails to make the required RTO filing by June 1st?


  • EPSA is concerned that any mitigation measures would be limited to energy sold under conditions when contingency reserves, for any control area fall below 7%, as defined by the WSCC. Currently, the WSCC includes over 30 individual control areas, many of which reach beyond the scope of the RTO West (which, of course, is not operational yet). How will standards to measure load, demand and contingency reserves be determined by a reliability region that is not a FERC-approved RTO, and therefore lacks a sufficiently independent governance structure? The Commission should make sure that any methodology to determine contingency calculations are transparent, consistent and open to public comment.


  • Why do the mitigation measures apply when any one of the 30-plus control areas in the WSCC fall below the 7% reserve requirement? If required, mitigation measures should only apply when reserve requirements within the WSCC as a whole fall below 7%.


  • The proposed mitigation plan will require marketers to justify bids above the market clearing price. This requirement lacks specificity, may be applied subjectively, and has not been well thought out. How does the Commission propose to evaluate the level at which a marketer bid is considered to be just and reasonable above the market clearing price? What criteria will be used to determine a just and reasonable mark up?


    • Allowing the proposal to be implemented without addressing these issues will impose greater uncertainty into the Western markets – a consequence the Commission should want to avoid.