FERC Filings

PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE MIDWEST ISO MARKET MITIGATION MEASURES

INTRODUCTION

Midwest Independent Transmission System Operator, Inc.

Docket No. ER03-323-000

The Electric Power Supply Association (EPSA) hereby files comments in the above-captioned proceeding on the Midwest Independent Transmission System Operator, Inc.’s (MISO) Market Mitigation Measures (Mitigation Measures) filed on December 23, 2002. EPSA intervened in this proceeding in a timely manner on January 8, 2003, and now files comments with the Federal Energy Regulatory Commission (FERC or the Commission) on the Mitigation Measures. EPSA opposes mitigation in the absence of demonstrable structural market problems, such as a defined load pocket, and without the concurrent implementation of a resource adequacy program and the other provisions contained in the Commission’s Standard Market Design (SMD). As a result, EPSA opposes this filing. In the comments that follow, EPSA demonstrates that the MISO filing is inconsistent with the recent Commission order in New England and the FERC SMD NOPR, is fundamentally flawed technically and is premature in its timing. For these reasons, the Commission should reject this filing and direct the MISO to finalize and submit revised Mitigation Measures at the time that it submits its final Market Rules.

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