FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON REVISED PUBLIC UTILITY FILING REQUIREMENTS

CONCLUSION

While supporting the streamlining of reporting requirements, EPSA has serious concerns about the public disclosure of such commercially sensitive data included in the Order. The public reporting of this information would create unacceptable risks to the continued development of competitive markets by reducing the number of competitors and impairing the liquidity of power markets. Information disclosure policies that protect information, such as that captured in the data sets identified above, that amounts to intellectual property, will better advance the Commission’s objective to establish well-functioning competitive markets. At the very least, if the Commission believes it is necessary to collect this information, the information should be kept confidential, and public utilities should not be required to disclose this information to the public. If not, the public disclosure should be done so in an aggregated form with a delay.

January 28, 2002

Respectfully submitted,

/S/________________

Mark Bennett, Senior Manager of Policy
Jacqueline Gallagher, Research/Policy Coordinator

Electric Power Supply Association
1401 New York Avenue, NW 11th Floor
Washington, DC 20005
(202) 628-8200

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