FERC Filings

REQUEST FOR CLARIFICATION OR IN THE ALTERNATIVE REHEARING OF THE ELECTRIC POWER SUPPLY ASSOCIATION-Docket No. EL00-95-012, Docket No. EL00-98-000, Docket No. RT01-85-000, Docket No. EL01-68-000

2. The Commission Should Ensure That Confidential Data Is Provided Only To An Independent Entity

EPSA has, in several other pleadings, raised significant concerns about the independence of the CAISO Board. Until these concerns are resolved and the CAISO Board has been replaced by an independent entity, confidential data about heat rates and emission rates should not be provided to the CAISO.

Rather, if the Commission reaffirms its current approach to price mitigation, commercially sensitive data should be provided to an independent entity to perform the calculations required to derive a proxy price. The CAISO should not be charged with that role.

As EPSA has pointed out, the CAISO Board is now a political entity, appointed by and serving at the pleasure of the Governor and the California Electricity Oversight Board (EOB). In addition, the State of California is now involved in power procurement through its Department of Water Resources (DWR). The CAISO could easily be subject to political pressure to provide commercially sensitive data to DWR, which is actively negotiating contracts to purchase power from the very units required to provide data under this Order.

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