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

4. The Order Is Not Clear On How Marketer Bids That Exceed The Proxy Price Can Be Justified

The Order notes that applying marginal cost mitigation to marketers would be extremely difficult. Instead, the Order permits marketers to accept the proxy market-clearing price or submit their own bids. Where bids exceed the market -clearing price, the marketer will be required to justify the bid based on the price paid for power. However, the Order offers no guidance as to what that justification might consist of. Obviously, there is little or no reason for a marketer to resell power at the price it pays for that power. Guidance on what markup can be justified or the basis for making that showing is wholly lacking from the Order. Will marketers be limited to a set markup or a set percentage above its purchase price? To avoid uncertainty and confusion, which will decrease available supply and increase prices, the Commission should clarify its expectations of marketers.

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