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COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN RESPONSE TO NOTICE INVITING COMMENTS ON TIMELINE AND REPORT BY THE NORTHEAST INDEPENDENT SYSTEM OPERATORS ON SEAMS RESOLUTIONS

INTRODUCTION

Regional Transmission Organizations


Docket Nos. RT01-99-000,


001, 002 and 003


Midwest Independent System Operator


Docket No. RT01-87


New York Independent System Operator Inc.


Docket Nos. RT01-95-000,


001 and 002


Bangor Hydro-Electric Company


Docket Nos. RT01-86-000,

001 and 002


PJM Interconnection, L.L.C.


Docket No. RT01-98-000


Alliance Companies


Docket No. EL02-65

The Electric Power Supply Association (EPSA) appreciates the opportunity to comment on the Timeline and Report by the Northeast Independent System Operators on Seams Resolution, issued on June 18, 2002 (Report). The effort to identify and resolve issues relating to seams between emerging markets represents an essential dimension of the Commission’s initiative to form regional transmission organizations (RTOs) and well-functioning, competitive markets. For at least three years, EPSA and its member companies, along with other parties, have engaged in a protracted effort to address seams issues. However, numerous issues critical to effective market operation remain unresolved. Therefore, EPSA applauds the Commission’s renewed focus on what can fairly be described as one of the lynchpins for successful RTOs and markets.

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