FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON STANDARDS OF CONDUCT FOR TRANSMISSION PROVIDERS

CONCLUSION

EPSA supports the Commission’s effort to revise and update the affiliate standards of conduct so as to capture all load using the transmission system. Such a change would better reflect the changing structure of the energy industry. If successful, improved standards could substantially contribute to the comparability that is essential to the achievement of truly competitive markets. Treating employees engaged in sales or purchases solely on behalf of bundled retail native load as wholesale employees will help to create a more level playing field for all market participants.

The Commission’s efforts to rationalize the standards of conduct can best be accomplished by recognizing that not all standards are transferable between electric and gas markets. Mandating announcement of discounts to all potential customers by OASIS or on a website at the time of offer will inhibit the gas market. The current selective discounting practices by pipelines provide a vibrant market for shippers that should be continued.

December 19, 2001

Respectfully submitted,

/s/______________________________
Julie Simon, Vice President of Policy
Mark Bennett, Senior Manager 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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