FERC Filings

REQUEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION FOR INTERVENTION, CLARIFICATION AND REHEARING OF THE COMMISSION’S NOVEMBER 20, 2001 ORDER ESTABLISHING REFUND EFFECTIVE DATE AND PROPOSING TO IMPOSE CONDITIONS ON MARKET-BASED RATE TARIFFS AND AUTHORIZATION

CONCLUSION

EPSA respectfully but strongly objects to the Commission conditioning market-based rate tariffs with a blanket refund obligation. Such action guarantees regulatory uncertainty and increases perceived risk levels to the investment community, does not reflect the realities of the way markets work, creates disincentives to build vital infrastructure, and is illegal under the FPA. The resources of the Commission and the industry would be better served addressing the most important objective: fostering the formation of RTO markets consistent with Order No. 2000. The Commission must not set aside the overarching actions that are much more important to the formation of successful competitive markets: a standardized market design and market structures; development of a new pro forma transmission tariff; broadening competitors’ access to non-discriminatory transmission service by establishing broadly defined RTOs; and facilitating new entry with actions that require fair and effective interconnection policies for new merchant plants. Creating a vibrant wholesale marketplace with these criteria in fact, by its very existence, limits opportunities for market power abuse.

December 19, 2001

Respectfully submitted,

Julie Simon, Vice President of Policy
Erin Perrigo, Manager of Policy
Electric Power Supply Association
1401 New York Avenue, NW
11th Floor
Washington, DC 20005
202) 628-8200

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