FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE NEW ENGLAND ANSWER PROVIDING ADDITIONAL SUPPORT FOR APPLICATION OF "FIRST LEVEL MITIGATION" IN UNCONSTRAINED AREAS UNDER NEW ENGLAND SMD MITIGATION PLAN
INTRODUCTION
New England Power Pool
Docket No. ER02-2330-001
and
ISO New England Inc.
Docket No. EL00-62-039
The Electric Power Supply Association (EPSA) hereby files comments in the above-captioned proceeding in response to the answer filed by the ISO New England, Inc. (ISO-NE) on October 7, 2002. That answer provided additional support for the application of “first level mitigation” in unconstrained areas under the mitigation plan developed for the New England Standard Market Design (NE SMD). EPSA intervened in this proceeding in a timely manner on July 31, and now files comments on the first level mitigation proposal. EPSA opposes mitigation in the absence of transmission constraints.