FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON METHOD FOR DETERMINING NATURAL GAS PRICES FOR PURPOSES OF CALCULATING REFUNDS

CONCLUSION

In the Initial Report, the FERC Staff states that it has not made specific findings of price manipulation, but will continue to assess the published price data. In light of this, Staff is recommending a major change to the refund mechanism while still assessing and analyzing the relevant information. To change course at this point in the refund proceedings is to introduce a further level of uncertainty into a proceeding that, by its very nature and complexity, has already played a prominent role in the financial woes of the merchant power and marketing industry. The potential damage that could be caused by the proposed changes is too great for the Commission to consider. The Commission must not change the natural gas pricing data used to calculate the California refunds.

October 15, 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

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., October 15, 2002.

/S/________________
Julie Simon