FERC Filings

REQUEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION FOR REHEARING OF THE COMMISSION’S MARCH 9, 2001 ORDER DIRECTING SELLERS TO PROVIDE REFUNDS OF EXCESS AMOUNTS CHARGED FOR CERTAIN ELECTRIC ENERGY SALES DURING JANUARY 2001 OR, ALTERNATELY, TO PROVIDE FURTHER

CONCLUSION

EPSA appreciates the enormous hours, and considerable attention that the Commission has devoted to re-restructuring the California markets. The Commission is to be commended for seeking a fair and reasoned resolution to each issue brought before it. Nevertheless, EPSA believes that the Commission’s novel methodological approach of trying to recreate bidding scenarios under optimum conditions in the March 9 Order is unfair to the Sellers who were not able to bid under optimum conditions and will have long-term adverse consequences to energy supplies in California. For these reasons, EPSA requests the Commission grant rehearing of its March 9 Order (as well as the March 16 Order and all subsequent orders based on the March 9 Order.

Dated: April 9, 2001

Respectfully submitted,

_____________________________________
Larry F. Eisenstat
Mark L. Perlis
Robert C. Fallon
Michael J. Wentworth
Dickstein Shapiro Morin & Oshinsky
2101 L Street, N.W.
Washington, D.C. 20037
Counsel for Electric Power Supply Association

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