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FERC Filings

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

THERE ARE SOUND MEANS OF PROMOTING SUPPLY

If, however, the Commission is concerned about adequate generating supplies, it could consider adopting the type of mechanisms adopted in prior years to promote adequate supply. For example, the Commission has granted temporary waivers of operating and efficiency standards under PURPA, authorized market-based rate authority for wholesale sales from on-site and self-generation, and authorized wholesale and retail customers, where permitted by state law, to resell their load reductions at market-based rates. Similar programs designed to maximize available generation could also be implemented this summer, such as creating national interconnection procedures and agreements and increasing FERC cooperation with state and other federal regulatory agencies to develop a more unified and streamlined approach to needed electric and gas infrastructure development.

In 2000, the Commission requested input from the industry on short- and long-term measures designed to enhance reliability. Many of the suggestions made by EPSA at the time—including elimination of Capacity Benefit Margins, independent calculation of ATC values, OASIS and TLR audits, and national interconnection procedures and agreements—could be implemented by this summer and would improve the overall availability of resources on the transmission system (see EPSA’s comments in Docket No. EL00-75). Following the U.S. Supreme Court decision on FERC Order No. 888, FERC clearly has the right to proceed with these issues as part of its authority over transmission in interstate commerce. However, again the Commission must tailor any action to the particular identification of a problem.