FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON NOTICE OF PROPOSED POLICY STATEMENT ON STANDARD OF REVIEW FOR PROPOSED CHANGES TO MARKET-BASED RATE CONTRACTS FOR WHOLESALE SALES OF ELECTRIC ENERGY BY PUBLIC UTILITIES

INTRODUCTION

Notice of Proposed Policy Statement on Standard of Review for Proposed Changes to Market-Based Rate Contracts for Wholesale Sales of Electric Energy by Public Utilities

Docket No. PL02-7-000

The Electric Power Supply Association (EPSA) welcomes the opportunity to comment on the Commission’s Notice of Proposed Policy Statement on Standard of Review for Proposed Changes to Market-Based Rate Contracts for Wholesale Sales of Electric Energy by Public Utilities (Policy Statement). The general subject of the Policy Statement—after-the-fact changes to negotiated and agreed upon contractual terms between willing sellers with market-based rate authority and willing buyers—addresses one of the lynchpins of all business activity, and competitive electric energy markets in particular, contract sanctity. As such, the proposed policy statement provides an excellent opportunity for the Commission to heed the recent direction of the Court of Appeals to “not take contract abrogation lightly.” Accordingly, EPSA supports the intent underlying the Commission’s action: to preserve the sanctity of contracts and the related goal of promoting certainty and stability in electricity markets while protecting customers.

• View Next Section
• Back to Issue Menu