FERC Filings

INFORMATION DISCLOSURE COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION

CONCLUSION

While supporting the Commission’s efforts to develop more efficient public utility filing requirements, the Commission should carefully consider the discretion it has under Section 205 of the Federal Power Act to shape information filing requirements that meet the needs of the public, the industry and the Commission. The Commission should reconsider the competitive harm of the release of commercially sensitive wholesale market data contemplated by this NOPR. Even if produced confidentially, the proposed filing requirement, while extensive, will not give the Commission the information it needs to meaningfully monitor wholesale electricity markets, which needs to be considered separately. At a minimum, the Commission should look to the filing requirements for natural gas suppliers in RM01-9-000 and limit reporting to physical transactions, keep commercially sensitive data confidential, and, if necessary, release the data in aggregated form with a delay. Doing so will help foster competitive wholesale markets

while allowing the Commission to satisfy its Federal Power Act obligations.

October 5, 2001

Respectfully submitted,

______________________________
Julie Simon, Vice President of Policy
Jacqueline Gallagher, Research/Policy Assistant
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW 11th Floor
Washington, D.C. 20005
202-628-8200

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