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COMMENTS OUT OF TIME OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE NEW ENGLAND STANDARD MARKET DESIGN PROPOSAL

SUMMARY

EPSA supports the SMD proposal made by the New England entities, including the aggressive timeline that is proposed for the implementation of a regional standard market. The establishment of a framework which relies on locational marginal pricing, a new multi-settlement system and congestion management system should provide appropriate price and investment signals to allow for a robust, competitive wholesale electric market. Many aspects of the New England proposal echo those that have been issued by FERC in its own Standard Market Design NOPR (SMD NOPR), which is crucial to the development of a competitive national wholesale electric market. While the New England proposal must be analyzed in light of the FERC’s SMD NOPR, the Commission should approve Market Rule 1 with certain modifications. As discussed below, these modifications include: (1) the requirement to file NEPOOL’s Manuals with FERC; (2) the inclusion of the Patton Reforms; and (3) the reinstatement of reserve markets in the New England market.