FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: 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 entities using the transmission system. Such a shift would better reflect the changing structure of the energy industry. If successful, improved standards could substantially contribute to the comparability that is essential to achieving 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. Indeed, the new standards will provide a behavioral remedy that will complement the eventual structural changes the Commission is contemplating in its SMD process. These structural changes and the resulting benefit to consumers far out-weigh any of the potential costs incurred by the industry.
June 28, 2001
Respectfully submitted,
/S/______________________________
Julie Simon, Vice President of Policy
Jack Cashin, Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW 11th Floor
Washington, D.C. 20005
202-628-8200
