FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN RESPONSE TO NOTICE INVITING COMMENTS ON SEAMS RESOLUTION UPDATE BY PJM INTERCONNECTION, L.L.C., NEW YORK INDEPENDENT SYSTEM OPERATOR, INC. AND ISO NEW ENGLAND, INC.

CONCLUSION

Accordingly, EPSA restates its appreciation for the ISO staffs’ efforts in pursuing the general framework for seams issues resolution. However, EPSA respectfully requests that the Commission establish a clearer basis for prioritizing the projects described in the report, create hard deadlines for their completion and continue the focus on reforming, integrating and unifying tariffs and market rules. Finally, EPSA notes that while resolution of seams issues can significantly improve the performance of competitive markets, the ultimate seams resolution tool is the Commission’s adoption, and ISO/RTO implementation, of Standard Market Design, replete with common market structures and software.

February 26, 2003

Respectfully Submitted,

________________________
Julie Simon, Vice President of Policy
Mark Bennett, Senior Manager of Policy
Electric Power Supply Association

1401 New York Avenue, NW
11th Floor
Washington, DC 20005

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., February 26, 2003.

____________________
Julie Simon