FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: REGULATION OF CASH MANAGEMENT PRACTICES

CONCLUSION

While recent events have put the focus on accounting practices in the energy industry and elsewhere, the proposals in the Accounting NOPR that would extend Uniform System of Accounts requirements to competitive suppliers and in turn the requirements of the Cash Management NOPR deviate from longstanding Commission precedent and are not the proper course of action. Extending these requirements to competitive suppliers does not further the Commission’s goal of regulating rates and protecting the customers of jurisdictional entities. To date, the Commission has not adequately explained this relationship and thus the need for changing its longstanding precedent. The Commission therefore should not inadvertently subject competitive suppliers to the Cash Management NOPR’s requirements.

August 28, 2002

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, DC 20005
202-628-8200

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