FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION AND THE WESTERN POWER TRADING FORUM ON THE REQUEST FOR REHEARING AND CLARIFICATION OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR

CONCLUSION

The Commission should not grant the CAISO’s rehearing or clarification requests and should focus its efforts on implementation of a MMCP that does not vary based on parameters under the control of any market participant. This set MMCP must be transparent and not subject to retroactive refund, in order to allow for transactional certainty. The Commission needs to act quickly to protect California consumers by bringing certainty to the marketplace and sending the correct incentives for increased supply, adequate capital investment, risk management and demand responsiveness.

June 21, 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

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the comments by first class mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Washington, D.C., June 21, 2002.

/S/__________________________
Julie Simon