FERC Filings

SUPPLEMENTAL COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: INVESTIGATION OF TERMS AND CONDITIONS OF PUBLIC UTILITY MARKET-BASED RATE AUTHORIZATIONS

THE REFUND CONDITION SHOULD NOT APPLY TO MARKETERS

Additionally, the November 20th Order for an open-ended refund obligation on all market-based rates sales should not apply to marketers. If the Commission finds that a marketer’s sale is indicative of market abuse, the marketer will be required to justify the bid based on the price paid for power. However, the Order offers no guidance as to what that justification might consist of. Obviously, there is little or no reason for a marketer to resell power at the price it pays for that power. Guidance on what markup can be justified or the basis for making that showing is wholly lacking from the Order. Will marketers be limited to a set markup or a set percentage above its purchase price? Marketers bring value in the form of risk management, liquidity and transparency. Commission policy should not drive marketers from participation in wholesale power markets.

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