FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION AND THE WESTERN POWER TRADING FORUM ON THE PROPOSED REVISIONS AND ADDITIONAL ELEMENTS OF THE COMPREHENSIVE MARKET DESIGN PROPOSAL OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR
I.
Comments
The CAISO has filed three major documents with the Federal Energy Regulatory Commission (Commission or FERC) outlining the details and tariff revisions to implement its proposed MD02 since May 15th. The Supplemental Filing was made on June 17, 2002, with comments due to the Commission by July 19, 2002. On June 28, 2002, the CAISO filed a 1430 page “clean” version of its full MD02 tariff, which included numerous errata not previously filed with FERC. While EPSA has been supportive of brisk timetables for the development and advancement of functional regional markets, the comment period for the Supplemental Filing is unworkable due to the circumstances surrounding the CAISO filings. EPSA and WPTF plan to file comments on the substance of the MD02 proposal, but the proposal itself remains a moving target that does not warrant final consideration by stakeholders. As noted in the transmittal letter of the Supplemental Filing, “the ISO will commence a series of technical conferences to explain the proposed tariff revisions and to receive comments from stakeholders beginning in July, 2002,” and also proposes “a week-long meeting with stakeholders in the first half of August to try to reach agreement as far as possible on issues that were not resolved at the July meetings.” A schedule of meetings has been published subsequent to the June 17th Supplemental Filing. The first workshop was scheduled for July 2, 2002.
EPSA and WPTF applaud the continuation of settlement discussions and workshops among stakeholders during the Commission’s deliberations over ISO and RTO development; however, the meetings scheduled by the ISO are not a part of the federal regulatory process and they will not be attended by FERC representatives. Further, due to the ongoing stakeholder discussions, there is not a solid, final proposal on file with the Commission for adequate comment from parties. EPSA and WPTF cannot turn around complete, substantive and valuable comments, even with the 10-day extension granted by the Commission, while changes are still taking place. According to CAISO representatives at the June 27th CAISO “Market Issues Forum” meeting, the ISO planned to file a complete black-line tariff with all revisions (including errata not filed previously at FERC) at the Commission on June 28, 2002. This new version of the CAISO Tariff draws additional attention to the impermanent status of the proposal currently before FERC and underscores why parties cannot properly comment on all substantive issues in the case.
EPSA and WPTF would like to reserve the right to file substantive comments on the CAISO proposal as soon as feasible. While the press of business is a valid concern at this time across the board, it is especially true in this case due to the copious amounts of time that must be spent developing comments on a proposal that will likely change many times in the coming weeks and months.
July 18, 2002
Respectfully submitted,
/S/
Julie Simon, Vice President of Policy
Nancy Bagot, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, NW
11th Floor
Washington, DC 20005
(202) 628-8200
/S/_____________________
Daniel W. Douglass
Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd., Suite 244
Woodland Hills, CA 91367
(818) 596-2201
(818) 346-6502 (fax)
douglass@energyattorney.com
Attorneys for the Western Power
Trading Forum <sup>1 EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. These suppliers, who account for more than a third of the nation's installed generating capacity, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers. The comments contained in this filing represent the position of EPSA as an organization, but not necessarily the views of any particular member with respect to any issue.
2 WPTF is a California non-profit, mutual benefit corporation. It is a broadly based membership organization dedicated to enhancing competition in Western electric markets in order to reduce the cost of electricity to consumers throughout the region while maintaining the current high level of system reliability. WPTF actions are focused on supporting development of competitive electricity markets throughout the region and developing uniform operating rules to facilitate transactions among market participants. WPTF provides a voice through which members can influence the development of market structures throughout the region. The membership of WPTF includes energy service providers, scheduling coordinators, generators, municipal utilities and a power exchange, all of which are active participants in the restructured California electricity market. The comments contained in this filing represent the position of WPTF as an organization, but not necessarily the views of any particular member with respect to any issue.
3 EPSA and WPTF note that the Commission issued an extensive order today, July 18th, on the California Comprehensive Market Redesign Proposal. The FERC order accepts, rejects and modifies aspects of the CAISO's May 1st filing, as well as implementing a West-wide market power mitigation program. The order sets issues in the June 17th Supplemental Filing for technical conference and states that those issues will be the subject of a separate Commission order to be issued at a later date. EPSA and WPTF, along with all other interested parties, need to analyze today's order and determine its impact on the development of a market design for California.
4 CAISO MD02 Supplemental Filing at p. 2
5 Id.
6 See the Meeting Calendar section of www.caiso.com for meeting schedule, including MD02 Filing Stakeholder Meeting, July 2, 2002.
7 See the Meeting Calendar section of www.caiso.com for meeting information and agenda for June Market Issues Forum.</sup>