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COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: NOTICE OF INQUIRY CONCERNING NATURAL GAS PIPELINE NEGOTIATED RATE POLICIES AND PRACTICES

CONCLUSION

EPSA supports the current negotiated rates program and feels that the program provides the market with flexibility that increases options for customers and, in turn, meets the Commission’s goals for competitive gas and electric markets. The current program’s flexibility must be retained, and it is important that limitations and caps not be used since they will dampen the program’s positive attributes and undermine its goals. Rather than limiting the flexibility the market wants, the Commission should focus on ways to enhance comparability and consistency as set forth herein and address any violations of the current program through diligent market oversight.

September 25, 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