FERC Filings

INFORMATION DISCLOSURE COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION

IV. The Data the Commission is Requesting Will Not Give the Information It Needs to Meaningfully Monitor Electricity Markets

The Commission states in the NOPR that it is “not intended as a comprehensive review” of its market-monitoring efforts. However, EPSA is concerned that information collection and review is an important part of that effort. By suggesting that a subsequent process will be undertaken that addresses market-monitoring disclosure issues, EPSA is concerned about the duplication of effort. As noted above, EPSA has serious concerns that the NOPR, if implemented as proposed, will have a significant impact on the Commission’s goals of creating robustly competitive regional power markets. The NOPR will require the filing of significant commercially sensitive information, yet this type and amount of data will not actually provide the insight needed by the Commission to determine the state of the physical market or to determine the existence of market power. Even if all the information contemplated by the NOPR is produced, without knowing a marketer’s complete portfolio, it is not possible to conduct a meaningful market power analysis. Thus, even if this NOPR were intended to assist in the Commission’s market-monitoring efforts, it would not accomplish that goal.
EPSA recommends that the Commission reconsider, on a comprehensive basis, what information it needs, what information the market needs, what information is properly held confidential and what information needs to be disclosed to satisfy its market-monitoring obligations. That process is different from determining what information must be filed to satisfy the requirements of Section 205.

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